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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 27, 2024, Vol. 28, No. 300

                            Headlines

20 TIMES 2018-20TS: DBRS Confirms CCC Rating on 2 Tranches
A&D MORTGAGE 2024-NQM5: S&P Assigns Prelim 'B-'Rating on B-2 Certs
ALLEGRO CLO VIII-S: Fitch Assigns BB-(EXP)sf Rating on Cl. F Notes
AMCR ABS 2024-A: DBRS Gives Prov. BB(low) Rating on Class C Notes
AMERICAN CREDIT 2024-4: S&P Assigns BB-(sf) Rating on Cl. E Notes

ANGEL OAK 2024-10: Fitch Assigns Bsf Final Rating on Cl. B-2 Certs
APIDOS CLO XLI: Fitch Assigns 'BB+sf' Rating on Class E-R Notes
APIDOS CLO XLI: Moody's Assigns B3 Rating to $500,000 F-R Notes
ARES XLIX: Fitch Assigns 'BB-sf' Rating on Class E-R Notes
ATLAS SENIOR XX: S&P Assigns BB- (sf) Rating on Class E-R Notes

ATRIUM HOTEL 2024-ATRM: DBRS Gives Prov. B Rating on HRR Certs
BAIN CAPITAL 2022-4: Fitch Assigns 'BB-sf' Rating on Cl. E-R Notes
BALLYROCK CLO 21: S&P Assigns BB- (sf) Rating on Class D-R Notes
BAMLL COMMERCIAL 2015-200P: S&P Affirms BB- (sf) Rating on F Certs
BANK 2019-BNK26: Fitch Affirms B-sf Rating on 2 Tranches

BANK 2021-BNK34: Fitch Affirms 'B-sf' Rating on Two Tranches
BANK 2021-BNK35: DBRS Confirms B Rating on Class J Certs
BANK5 2024-5YR10: Fitch Assigns 'B-sf' Final Rating on Two Tranches
BARINGS CLO 2022-IV: Fitch Assigns BB-sf Rating on Class E-R Notes
BARINGS CLO 2024-V: Fitch Assigns BB-(EXP)sf Rating on Cl. E Notes

BATTERY PARK II: Fitch Assigns 'BB-sf' Rating on Class E-R Notes
BBCMS MORTGAGE 2020-C8: DBRS Confirms BB Rating on Class X-H Certs
BENCHMARK 2019-B15: DBRS Cuts Rating on G-RR Certs to B(low)
BENEFIT STREET IX: Fitch Assigns 'BB+sf' Rating on Class E-R2 Notes
BENEFIT STREET IX: Moody's Assigns B3 Rating to $250,000 F-R2 Notes

BLUE STREAM 2024-1: Fitch Assigns 'BB-(EXP)sf' Rating on Cl. C Note
BLUEMOUNTAIN CLO XXXV: Fitch Assigns 'BB-' Rating on Two Tranches
BMO 2024-C10: Fitch Assigns 'B-(EXP)sf' Rating on Class GRR Certs
BREAN ASSET 2024-RM9: DBRS Finalizes B Rating on Class M5 Notes
BRIDGE STREET III: Fitch Assigns 'BB-sf' Rating on Class E-R Notes

BRIDGECREST LENDING 2024-4: DBRS Gives Prov. BB(high) on E Notes
BRIDGECREST LENDING 2024-4: S&P Assigns BB (sf) Rating on E Notes
BRIGHTWOOD 2019-1: S&P Assigns Prelim BB-(sf) Rating on E-R Notes
BRIGHTWOOD CAPITAL 2019-1: S&P Assigns BB-(sf) Rating on E-R Notes
BX TRUST 2024-BRBK: Moody's Assigns Ba1 Rating to Cl. E Certs

CARLYLE US 2024-7: Fitch Assigns 'BB-(EXP)sf' Rating on Cl. E Notes
CARVAL CLO VIII-C: S&P Assigns BB- (sf) Rating on Cl. E-2R Debt
CASTLELAKE AIRCRAFT 2019-1: Fitch Affirms 'CCC' Rating on C Debt
CD 2017-CD6: DBRS Confirms B Rating on Class G-RR Certs
CEDAR FUNDING XIV: S&P Assigns B- (sf) Rating on Class F Notes

CFMT 2024-R1: DBRS Gives Prov. BB(low) Rating on Class M2 Notes
CHASE HOME 2024-8: DBRS Finalizes BB Rating on Class B4 Certs
CHASE HOME 2024-9: Fitch Assigns B+(EXP)sf Rating on Cl. B-5 Certs
CIFC FUNDING 2019-I: Fitch Assigns 'BB-sf' Rating on Cl. E-R Notes
CIFC FUNDING 2024-IV: Fitch Assigns 'BB-sf' Final Rating on E Notes

CITIGROUP 2019-GC43: Fitch Affirms 'B-sf' Rating on GRR Certs
COLT 2024-6: Fitch Assigns 'Bsf' Final Rating on Class B2 Certs
COMM 2016-CCRE28: Fitch Lowers Rating on Two Tranches to 'BB-sf'
CSTL COMMERCIAL 2024-GATE: Fitch Assigns BB-sf Rating on HRR Certs
DANBY PARK: S&P Assigns BB- (sf) Rating on Class E-R Notes

DBGS 2019-1735: S&P Affirms B (sf) Rating on Class F Certs
DIAMETER CAPITAL 1: S&P Assigns Prelim BB-(sf) Rating on D-R Notes
DIAMETER CAPITAL 2: S&P Assigns Prelim BB-(sf) Rating on D-R Notes
DRYDEN 113: Fitch Assigns 'BB-sf' Rating on Class E-R2 Notes
EMPOWER CLO 2022-1: S&P Assigns BB- (sf) Rating on Class E-R Notes

FIGRE TRUST 2024-HE5: DBRS Gives Prov. B(low) Rating on F Notes
FLAGSHIP CREDIT 2024-3: S&P Assigns Prelim 'BB-' Rating on E Notes
FORTRESS CREDIT XVI: Fitch Hikes Rating on Class E Notes to 'BB+sf'
FORTRESS CREDIT XVI: Moody's Ups Rating on $500,000 F Notes to B2
GOODLEAP SUSTAINABLE 2023-1: S&P Affirms BB (sf) Rating on C Notes

GS MORTGAGE 2015-590M: S&P Lowers Class E Certs Rating to 'B+(sf)'
GS MORTGAGE 2017-375H: S&P Affirms B+ (sf) Rating on Cl. D Certs
GS MORTGAGE 2025-RPL5: Fitch Gives 'Bsf' Rating on Class B-2 Certs
HAMLET SECURITIZATION 2020-CRE1: DBRS Confirms CCC on F-RR Certs
HPS LOAN 2024-21: S&P Assigns BB- (sf) Rating on Class E Notes

IMSCI 2016-7: DBRS Confirms B Rating on Class G Certs
INVESCO CLO 2022-3: Fitch Assigns 'BB-sf' Rating on Class E-R Notes
JP MORGAN 2024-10: DBRS Gives Prov. B(low) Rating on B-5 Certs
JP MORGAN 2024-9: DBRS Finalizes B(low) Rating on Class B5 Certs
JP MORGAN 2024-INV1: Moody's Assigns (P)B3 Rating to Cl. B-5 Certs

KEY COMMERCIAL 2018-S1: DBRS Cuts Class F Certs Rating to CCC
KKR CLO 49: Moody's Assigns B3 Rating to $500,000 Class F-R Notes
KRR CLO 49: Fitch Assigns 'BBsf' Rating on Class E-R Notes
LCCM TRUST 2021-FL3: DBRS Confirms B(low) Rating on Cl. G Notes
LENDMARK FUNDING 2024-2: DBRS Finalizes BB(low) Rating on E Notes

LHOME MORTGAGE 2024-RTL5: DBRS Gives Prov. B Rating on M2 Certs
MADISON PARK LXVI: Fitch Assigns 'BB+(EXP)sf' Rating on Cl. E Notes
MADISON PARK XX: Fitch Assigns 'BB+sf' Rating on Class E-RR Notes
MADISON PARK XX: Moody's Assigns B3 Rating to $250,000 F-RR Notes
MANUFACTURED HOUSING 2000-3: S&P Lowers Class A Certs to 'D (sf)'

MARINER FINANCE 2024-B: DBRS Gives Prov. BB Rating on E Notes
MF1 2023-FL12: DBRS Confirms B(low) Rating on 3 Classes
MORGAN STANLEY 2015-C21: Fitch Lowers Rating on 555A Certs to BBsf
MORGAN STANLEY 2019-PLND: DBRS Cuts Rating on 2 Tranches to CCC
MORGAN STANLEY 2020-HR8: DBRS Confirms BB Rating on J-RR Certs

MRCD 2019-PARK: Fitch Lowers Rating on Class D Certs to 'BB-sf'
NEUBERGER BERMAN 26: Fitch Assigns 'BB-sf' Rating on Cl. E-R Notes
NEUBERGER BERMAN 52: Fitch Assigns 'BB-(EXP)sf' Rating on E-R Notes
NXPT COMMERCIAL 2024-STOR: Moody's Assigns B2 Rating to Cl. F Certs
NYMT LOAN 2024-INV1: S&P Assigns B (sf) Rating on Class B-2 Notes

OAKTREE CLO 2022-2: S&P Assigns Prelim 'BB' Rating on E-R2 Notes
OCP CLO 2016-12: S&P Assigns B+ (sf) Rating on Cl. E-2R3 Notes
OCP CLO 2024-36: S&P Assigns Prelim BB- (sf) Rating on E Notes
OCTAGON 60: Fitch Assigns 'BB-sf' Rating on Class E-R Notes
OHA CREDIT 5: S&P Assigns BB- (sf) Rating on Class E-R Notes

OZLM LTD XI: Moody's Affirms B1 Rating on $26.2MM Class D-R Notes
PALMER SQUARE 2021-2: Moody's Ups Rating on $7MM Cl. E Notes to Ba1
PALMER SQUARE 2023-4: S&P Assigns BB- (sf) Rating on E-R Notes
PARK BLUE 2022-I: Moody's Assigns Ba3 Rating to $11MM Cl. E-R Notes
PROGRESS RESIDENTIAL 2021-SFR1: DBRS Confirms B(low) on G Certs

PRPM LLC 2024-RCF6: DBRS Gives Prov. BB Rating on Class M2 Notes
RAD CLO 6: Fitch Assigns 'BB-sf' Rating on Class E-R Notes
RADIAN MORTGAGE 2024-J2: DBRS Gives (P) B(low) Rating on B5 Certs
RATE MORTGAGE 2024-J3: DBRS Finalizes B Rating on Class B5 Certs
RCKT MORTGAGE 2021-4: Moody's Hikes Rating on Cl. B-5 Certs to B2

RCKT MORTGAGE 2024-CES8: Fitch Assigns B(EXP) Rating to 5 Tranches
READY CAPITAL 2021-FL7: DBRS Confirms B(low) Rating on G Notes
REALT 2017: DBRS Hikes Class G Certs Rating to B(high)
REGATTA FUNDING XXII: Moody's Gives Ba3 Rating to $20MM E-R Notes
SEQUOIA MORTGAGE 2024-10: Fitch Assigns 'B+sf' Rating on B5 Certs

SEQUOIA MORTGAGE 2024-HYB1: Fitch Gives B(EXP)sf Rating on B2 Certs
SHACKLETON 2015-VII-R: Moody's Ups Rating on $26.5MM E Notes to Ba3
SHELTER GROWTH 2022-FL4: DBRS Confirms B(low) Rating on G Notes
SIERRA TIMESHARE 2024-3: Fitch Assigns 'BB-sf' Rating on D Notes
SIERRA TIMESHARE 2024-3: S&P Assigns BB (sf) Rating on Cl. D Notes

SILVER ROCK I: S&P Assigns BB- (sf) Rating on Class E-RR Notes
TOWD POINT 2024-4: Fitch Assigns 'B-(EXP)sf' Rating on Cl. B2 Notes
TRESTLES CLO III: Fitch Assigns 'BB-sf' Rating on Class E-R Notes
TRICOLOR AUTO 2024-3: Moody's Assigns B2 Rating to Class F Notes
TRIMARAN CAVU 2022-1: S&P Assigns BB-(sf) Rating on Cl. E-R Notes

TRIMARAN CAVU 2022-1: S&P Assigns Prelim 'BB-' Rating on E-R Notes
VELOCITY COMMERCIAL 2024-5: DBRS Gives Prov. B Rating on 3 Tranches
VENTURE 46: Fitch Assigns 'BB-sf' Rating on Class ER Notes
VERUS SECURITIZATION 2024-8: S&P Assigns B Rating on B-2 Notes
VIBRANT CLO XIII: Fitch Assigns 'BB-(EXP)sf' Rating on E-R Notes

WELLFLEET CLO 2022-2: S&P Assigns BB- (sf) Rating on Cl. E-R Notes
WELLS FARGO 2018-C43: DBRS Confirms B(low) Rating on Class F Certs
WESTLAKE AUTOMOBILE 2024-3: Fitch Assigns BB Rating on Class E Debt
WFLD 2014-MONT: DBRS Cuts Rating on Class D Certs to CCCsf
WFRBS COMMERCIAL 2013-C18: DBRS Confirms C Rating on Class D Certs

WIND RIVER 2015-1: Moody's Cuts Class F-R Notes Rating to Caa2
WIND RIVER 2022-1: S&P Affirms 'BB- (sf)' Rating on Class E Notes
[*] DBRS Confirms 7 Ratings From 3 United Auto Credit Transactions
[*] DBRS Reviews 113 Classes From 9 US RMBS Transactions
[*] Moody's Takes Action on 12 Bonds From 5 US RMBS Deals

[*] Moody's Takes Action on 14 Bonds From Nine US RMBS Deals
[*] Moody's Takes Action on 31 Bonds From 24 US RMBS Deals
[*] Moody's Takes Action on 36 Bonds From 22 US RMBS Deals
[*] Moody's Upgrades Ratings on 7 Bonds From 4 US RMBS Deals

                            *********

20 TIMES 2018-20TS: DBRS Confirms CCC Rating on 2 Tranches
----------------------------------------------------------
DBRS, Inc. confirmed all credit ratings on the Commercial Mortgage
Pass-Through Certificates, Series 2018-20TS issued by 20 Times
Square Trust 2018-20TS as follows:

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

All trends are Stable with the exception of Classes H and V, which
have ratings that do not typically carry a trend in commercial
mortgage-backed securities (CMBS) ratings.

The credit rating confirmations and Stable trends reflect the
stabilization of performance and deleveraging of the loan following
its successful modification and return to the master servicer in
January 2024. The loan was formerly in special servicing because of
numerous undischarged mechanics liens against the underlying
property in violation of the ground-lease terms. In October 2023,
the mezzanine lender assumed the loan following the execution of a
uniform commercial code (UCC) foreclosure. As part of the UCC, the
loan's maturity was extended for two years to May 2025 in exchange
for a $50.0 million principal curtailment and the loan was
transferred back to the master servicer in January 2024. An
additional one-year extension option will be exercisable provided
an additional $25.0 million is paid and applied to the principal
balance of the loan.

According to the servicer commentary, the aforementioned mechanics
liens have been resolved and half of the excess cash generated by
the collateral as of August 2024 is to be applied as principal
paydown. At the last rating action in October 2023, Morningstar
DBRS downgraded Class H to CCC (sf) following 10 remittance periods
of shorted interest to the class stemming from the loan's time in
special servicing. While all interest shortfalls have been since
been repaid, Morningstar DBRS confirmed the credit ratings based on
the previous demonstration of untimely interest over an extended
period of time.

At issuance, the loan represented a $600 million pari passu
participation of a $750 million whole first mortgage loan secured
by the leased-fee interest in 16,066 square feet (sf) of land under
20 Times Square. The property's ground lease and the leased-fee
financing are senior to the leasehold interest and leasehold
financing. The 99-year ground lease expires in April 2117 and has
no termination options. The initial ground rent payment was $29.3
million, increasing by 2.0% annually during the first five years
and then by 2.75% per year thereafter. As of September 2024, the
annualized ground rent payment reported by the servicer was $32.2
million.

The noncollateral improvements consist of a mixed-use property at
20 Times Square, at the corner of Seventh Avenue and West 47th
Street. The property comprises a 452-key Marriott Edition luxury
hotel, 74,820 sf of retail space (5,500 sf of which is
non-revenue-generating storage space), and 18,000 sf of digital
billboards. The debt on the noncollateral leasehold interest had
gone into default in December 2019, with the lender citing numerous
undischarged mechanics liens against the property as well as a
missed deadline to lease up the retail space, and the property was
foreclosed in January 2022. The subject loan was transferred to
special servicing in November 2022 in relation to the
aforementioned mechanics liens, which have since been resolved.

Morningstar DBRS estimated the value of the leased-fee component at
approximately $758.6 million based on an analysis of the payments
expected from the in-place ground lease and applying a blended cap
rate to the ground rent payment at maturity. Based on the derived
value and the current loan balance as of the September 2024
remittance, the implied whole-loan loan-to-value ratio (LTV) is
90.2% and 109.8% when including the $150.0 million of mezzanine
debt. No positive or negative qualitative adjustments were made to
the LTV sizing benchmarks, which were carried over from the
analysis in 2020 when the ratings were assigned. With both the
leasehold interest and leased-fee interest of the collateral being
taken over by motivated parties, as well as the additional
de-leveraging provided by the $50.0 million principal curtailment,
Morningstar DBRS views these developments positively with regard to
the loan's resolution, further supporting the credit rating
confirmations and Stable trends.

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


A&D MORTGAGE 2024-NQM5: S&P Assigns Prelim 'B-'Rating on B-2 Certs
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to A&D Mortgage
Trust 2024-NQM5's mortgage-backed certificates.

The certificate issuance is an RMBS transaction backed by first-
and second-lien, fixed- and adjustable-rate, fully amortizing
residential mortgage loans (some with interest-only periods) to
both prime and nonprime borrowers. The loans are primarily secured
by single-family residential properties, planned unit developments,
condominiums, townhomes, two- to four-family residential
properties, condotels, mixed-use properties, manufactured housing,
and five- to 10-unit multifamily residences. The pool consists of
1,171 loans, which are qualified mortgage (QM) safe harbor (average
prime offer rate), QM rebuttable presumption (average prime offer
rate), ability to repay-exempt loans and non-QM/ability to
repay-compliant loans.

The preliminary ratings are based on information as of Oct. 22,
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 and geographic
concentration;

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

-- The mortgage originator, A&D Mortgage LLC;

-- The 100% due diligence results consistent with represented loan
characteristics; and

-- The potential impact current and near-term macroeconomic
conditions may have on the performance of the mortgage borrowers in
the pool. S&P said, "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 the 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 unemployment rate and lower
inflation. However, our probability of a recession starting over
the next 12 months remains unchanged at 25%. With 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."

S&P Global Ratings announced on Oct. 16, 2024, that it is
requesting comments on its proposal to update its criteria for
rating U.S. residential mortgage-backed security (RMBS)
transactions issued 2009 and later. The proposal, if implemented,
would apply to the transaction discussed in this presale report.

  Preliminary Ratings Assigned(i)

  A&D Mortgage Trust 2024-NQM5

  Class A-1A, $188,664,000: AAA (sf)
  Class A-1B, $39,061,000: AAA (sf)
  Class A-1, $227,725,000: AAA (sf)
  Class A-2, $40,624,000: AA- (sf)
  Class A-3, $56,052,000: A- (sf)
  Class M-1, $24,218,000: BBB- (sf)
  Class B-1A, $12,304,000: BB (sf)
  Class B-1B, $6,641,000: BB- (sf)
  Class B-2, $14,257,000: B- (sf)
  Class B-3, $8,789,163: NR
  Class A-IO-S, notional(ii): NR
  Class X, notional(ii): NR
  Class R, not applicable: NR

(i)The preliminary ratings address the ultimate payment of interest
and principal.
(ii)The notional amount will equal the aggregate stated principal
balance of the mortgage loans as of the first day of the related
due period and is initially $390,610,163.
NR--Not rated.



ALLEGRO CLO VIII-S: Fitch Assigns BB-(EXP)sf Rating on Cl. F Notes
------------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
Allegro CLO VIII-S, Ltd.

   Entity/Debt        Rating           
   -----------        ------           
Allegro CLO
VIII-S, Ltd.

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

Transaction Summary

Allegro CLO VIII-S, Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that will be managed by AXA
Investment Managers US Inc. Net proceeds from the issuance of the
secured and subordinated notes will provide financing on a
portfolio of approximately $398.8 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'/'B-', which is in line with that of
recent CLOs. The weighted average rating factor (WARF) of the
indicative portfolio is 24.53 versus a maximum covenant, in
accordance with the initial expected matrix point of 27.1. 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
99.65% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 74.8% versus a
minimum covenant, in accordance with the initial expected matrix
point of 72.7%.

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 4.9-year
reinvestment period and reinvestment criteria similar to other
CLOs. Fitch's analysis was based on a stressed portfolio created by
adjusting the indicative portfolio to reflect permissible
concentration limits and collateral quality test levels.

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

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

RATING SENSITIVITIES

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

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

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

Variability in key model assumptions, such as increases in recovery
rates and decreases in default rates, could result in an upgrade.
Fitch evaluated the notes' sensitivity to potential changes in such
metrics; the minimum rating results under these sensitivity
scenarios are 'AAAsf' for class B, 'AA+sf' for class C, 'A+sf' for
class D-1, 'Asf' for class D-2, 'BBB+sf' for class E, and 'BBB+sf'
for class F.

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 Allegro CLO VIII-S,
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.


AMCR ABS 2024-A: DBRS Gives Prov. BB(low) Rating on Class C Notes
-----------------------------------------------------------------
DBRS, Inc. assigned provisional credit ratings to the following
classes of notes to be issued by AMCR ABS Trust 2024-A (AMCR 2024-A
or the Issuer):

-- $70,205,000 Class A Notes at (P) A (low) (sf)
-- $18,193,000 Class B Notes at (P) BBB (low) (sf)
-- $17,582,000 Class C Notes at (P) BB (low) (sf)

CREDIT RATING RATIONALE/DESCRIPTION

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

(1) The transaction's form and sufficiency of available credit
enhancement.

-- Subordination, overcollateralization, amounts held in the
Reserve Fund, and excess spread create credit enhancement levels
that are commensurate with the credit ratings.

-- Transaction cash flows are sufficient to repay investors under
all A (low)(sf), BBB (low) (sf), and BB (low) (sf) stress scenarios
in accordance with the terms of the AMCR 2024-A transaction
documents.

(2) The experience, sourcing, and servicing capabilities of
Credit9. Morningstar DBRS has performed an operational risk
assessment of Credit9 and believes the Company is an acceptable
consumer loan servicer with an acceptable Backup Servicer and
Backup Servicer Subcontractor.

(3) Americor has an experienced management team.

(4) The experience, sourcing, and servicing capabilities of
Credit9, LLC. Morningstar has performed an operational risk
assessment of Credit9 and believes the Company is an acceptable
consumer loan servicer with an acceptable Backup Servicer and
Backup Servicer Subcontractor.

(5) The experience, underwriting, and origination capabilities of
Cross River Bank (CRB).

(6) The ability of Wilmington Trust National Association to perform
duties as a Backup Servicer and the ability of Nelnet Servicing,
LLC dba Firstmark to perform duties as a Backup Servicer
Subcontractor.

(7) The annual percentage rate (APR) charged on the loans and the
status of CRB as the true lender.

-- Approximately 99% of loans included in AMCR 2024-A are
originated by CRB, a New Jersey state-chartered FDIC-insured bank.

-- Loans originated by CRB are all within the New Jersey state
usury limit of 30.00%.

-- The weighted-average APR of the loans in the pool is 28.62%.

-- Loans may be in excess of individual state usury laws; however,
CRB as the true lender is able to export rates that pre-empt state
usury rate caps.

-- Loans originated to borrowers in Vermont, Colorado, Maine, West
Virginia and Puerto Rico are excluded from the pool.

-- Under the Loan Sale Agreement, CRB is obligated to repurchase
any loan if there is a breach of representation and warranty that
materially and adversely affects the interests of the purchaser.

(8) The legal structure and expected legal opinions that will
address the true sale of the unsecured loans, the nonconsolidation
of the trust, that the trust has a valid perfected security
interest in the assets, and consistency with the Morningstar DBRS
Legal Criteria for U.S. Structured Finance.

(9) The transaction assumptions consider Morningstar DBRS' baseline
macroeconomic scenarios for rated sovereign economies, available in
its commentary Baseline Macroeconomic Scenarios for Rated
Sovereigns September 2024 Update, published on September 25, 2024.
These baseline macroeconomic scenarios replace Morningstar DBRS'
moderate and adverse coronavirus pandemic scenarios, which were
first published in April 2020.

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

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


AMERICAN CREDIT 2024-4: S&P Assigns BB-(sf) Rating on Cl. E Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its ratings to American Credit
Acceptance Receivables Trust 2024-4's automobile receivables-backed
notes.

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

The ratings reflect S&P's view of:

-- The availability of approximately 65.00%, 58.50%, 48.56%,
38.96%, and 34.09% credit support (hard credit enhancement and
haircut to excess spread) for the class A, B, C, D, and E notes,
respectively, based on stressed final post-pricing cash flow
scenarios. These credit support levels provide at least 2.35x,
2.10x, 1.70x, 1.37x, and 1.20x coverage of S&P's expected
cumulative net loss of 27.25% for the class A, B, C, D, and E
notes, respectively.

-- The expectation that under a moderate ('BBB') stress scenario
(1.37x S&P's expected loss level), all else being equal, its 'AAA
(sf)', 'AA (sf)', 'A (sf)', 'BBB (sf)', and 'BB- (sf)' ratings on
the class A, B, C, D, and E notes, respectively, are within its
credit stability limits.

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

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

-- The series' bank accounts at Wells Fargo Bank N.A., which do
not constrain the ratings.

-- S&P's operational risk assessment of American Credit Acceptance
LLC as servicer, and its view of the company's underwriting and
backup servicing arrangement with Computershare Trust Co. N.A.

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

-- The transaction's payment and legal structures.

  Ratings Assigned

  American Credit Acceptance Receivables Trust 2024-4

  Class A, $228.00 million: AAA (sf)
  Class B, $51.00 million: AA (sf)
  Class C, $99.00 million: A (sf)
  Class D, $90.00 million: BBB (sf)
  Class E, $39.00 million: BB- (sf)



ANGEL OAK 2024-10: Fitch Assigns Bsf Final Rating on Cl. B-2 Certs
------------------------------------------------------------------
Fitch Ratings has assigned final ratings to Angel Oak Mortgage
Trust 2024-10 (AOMT 2024-10).

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

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

Transaction Summary

Fitch has assigned final ratings to the RMBS 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 $316.77 million as of the cutoff date. This represents the 43rd
Fitch-rated AOMT transaction and the 10th 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 an 'Acceptable' originator. Select
Portfolio Servicing, Inc. (RPS1-/Negative) is the servicer for the
loans.

Of the loans, 57.6% are designated non-qualified mortgage (non-QM)
loans and 42.4% are exempted mortgage loans 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, 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 and
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.

Since the presale report was published, the collateral was updated
to reflect updated balances for several loans in the pool. The
final pool now consists of 661 loans with a total outstanding
balance of $316.77 million as of the cutoff date. In addition, the
transaction was re-structured to reflect the updated collateral
pool and certificate balances.

After the presale report was published, balances were updated on
the pool. Fitch re-ran the loss and cash flow analysis based on the
updated pool and revised structure with the post pricing coupons.
The revised pool had no impact on Fitch's loss expectations and the
losses remain the same as disclosed in the presale report. Fitch
ran its cash flow analysis on the post pricing structure that
reflected the revised class balances and CEs, and confirmed that
each rated class had sufficient credit enhancement to pass the
previously assigned rating stresses. As a result, the final ratings
remain unchanged from the expected ratings. Fitch's expected losses
that reflect the final pool and revised transaction CE are listed
below.

- Class A-1 rated 'AAAsf'; Fitch expected loss 21.75%; transaction
CE 25.40%;

- Class A-2 rated 'AAsf'; Fitch expected loss 16.75%; transaction
CE 20.60%;

- Class A-3 rated 'Asf'; Fitch expected loss 12.25%; transaction CE
13.15%;

- Class M-1 rated 'BBB-sf'; Fitch expected loss 7.75%; transaction
CE 7.95%;

- Class B-1 rated 'BBsf'; Fitch expected loss 6.25%; transaction CE
6.30%;

- Class B-2 rated 'Bsf'; Fitch expected loss 4.50%; transaction CE
4.35%.

Hurricane Helene impacted many areas in Florida, Georgia, North
Carolina, South Carolina and Tennessee. Hurricane Milton impacted
many areas in Florida. Based on the transaction documents, 6.9% of
the mortgage loans are secured by mortgaged properties located in
areas the Federal Emergency Management Agency (FEMA) designated
disaster areas due to Hurricane Helene. Based on FEMA recorded
disaster areas, Fitch noted that 108 mortgage loans (14.4% by UPB)
are secured by mortgage properties located areas FEMA designated
disaster areas due to Hurricane Milton.

The servicer is following standard servicing practices to assess
any property damage to the impacted homes, including ordering
post-disaster inspection reports and a call campaign to reach out
to borrowers in the impacted areas (to assess any damage and the
need of a modification). Currently, the sponsor is not aware of
material damage on the homes located in the FEMA declared disaster
area due to Hurricane Helene. Fitch will keep the loans in the
pool, as the representation and warranty (R&W)provider will
repurchase the home if there is material damage, per the no damage
R&W.

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 supported by
limited inventory.

Non-QM Credit Quality (Mixed): The collateral consists of 661 loans
totaling $316.77 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%.

Fitch's analysis shows that 57.1% of the pool loans are for primary
or secondary residence, while 42.9% are for investor properties.
Fitch's 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 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.
Additionally, 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 believed 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.


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

   Entity/Debt           Rating               Prior
   -----------           ------               -----
Apidos CLO XLI Ltd

   A-1 03770CAA3     LT PIFsf  Paid In Full   AAAsf
   A-1R              LT AAAsf  New Rating     AAA(EXP)sf
   A-2 03770CAC9     LT PIFsf  Paid In Full   AAAsf
   A-2R              LT AAAsf  New Rating     AAA(EXP)sf
   B-1 03770CAE5     LT PIFsf  Paid In Full   AAsf
   B-2 03770CAG0     LT PIFsf  Paid In Full   AAsf
   B-R               LT AAsf   New Rating     AA(EXP)sf
   C 03770CAJ4       LT PIFsf  Paid In Full   Asf
   C-R               LT Asf    New Rating     A(EXP)sf
   D 03770CAL9       LT PIFsf  Paid In Full   BBB-sf
   D-1R              LT BBB-sf New Rating     BBB-(EXP)sf
   D-2R              LT BBB-sf New Rating     BBB-(EXP)sf
   E 03770EAA9       LT PIFsf  Paid In Full   BBsf
   E-R               LT BB+sf  New Rating     BB+(EXP)sf
   F-R               LT NRsf   New Rating     NR(EXP)sf

Transaction Summary

Apidos CLO XLI Ltd (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) managed by CVC Credit
Partners, LLC., that originally closed on September 2022. The CLO's
secured notes will be refinanced in whole on Oct. 21, 2024 from
proceeds of the new secured notes. The net proceeds from the
issuance of the secured 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', which is in line with that of recent
CLOs. Issuers rated in the 'B' rating category denote a highly
speculative credit quality; however, the notes benefit from
appropriate credit enhancement and standard CLO structural
features.

Asset Security (Positive): The indicative portfolio consists of
96.78% first-lien senior secured loans and has a weighted average
recovery assumption of 73.5%. Fitch stressed the indicative
portfolio by assuming a higher portfolio concentration of assets
with lower recovery prospects and further reduced recovery
assumptions for higher rating stresses.

Portfolio Composition (Positive): The largest three industries may
comprise up to 39% of the portfolio balance in aggregate while the
top five obligors can represent up to 12.5% of the portfolio
balance in aggregate. The level of diversity required by industry,
obligor and geographic concentrations is in line with other recent
CLOs.

Portfolio Management (Neutral): The transaction has a 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-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, 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-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, 'Asf'
for class D-1R, 'A-sf' 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 Apidos CLO XLI
Ltd.

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


APIDOS CLO XLI: Moody's Assigns B3 Rating to $500,000 F-R Notes
---------------------------------------------------------------
Moody's Ratings has assigned ratings to two classes of CLO
refinancing notes (the Refinancing Notes) issued by Apidos CLO XLI
Ltd (the Issuer):  

US$307,500,000 Class A-1R Senior Secured Floating Rate Notes due
2036, Definitive Rating Assigned Aaa (sf)

US$500,000 Class F-R Mezzanine Deferrable Floating Rate Notes due
2037, Definitive Rating Assigned B3 (sf)

RATINGS RATIONALE

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

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
96.0% of the portfolio must consist of first lien senior secured
loans and up to 4.0% of the portfolio may consist of second lien
loans, unsecured loans, first lien last out loans and permitted
non-loan assets.

CVC Credit Partners, 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 the 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: $498,930,778

Diversity Score: 65

Weighted Average Rating Factor (WARF): 2995

Weighted Average Spread (WAS): 3.30%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 46.0%

Weighted Average Life (WAL): 8.0 years

Methodology Underlying the Rating Action:

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

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

The performance of the 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.


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

   Entity/Debt           Rating               Prior
   -----------           ------               -----
Ares XLIX CLO Ltd.

   A-1 04017JAA9     LT  PIFsf   Paid In Full   AAAsf
   A-1R              LT  AAAsf   New Rating     AAA(EXP)sf
   A-2 04017JAC5     LT  PIFsf   Paid In Full   AAAsf
   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  BBB-sf  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
   X-R               LT  AAAsf   New Rating     AAA(EXP)sf

Transaction Summary

Ares XLIX CLO Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) managed by Ares CLO Management
LLC that originally closed in August 2018 and is being reset on
Oct. 22, 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', which is in line with that of recent
CLOs. The weighted average rating factor (WARF) of the indicative
portfolio is 23.83 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
97.34% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 75.33% 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 39% of the portfolio balance in aggregate while the
top five obligors can represent up to 12.5% of the portfolio
balance in aggregate. The level of diversity resulting from the
industry, obligor and geographic concentrations is in line with
other recent CLOs.

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

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

The 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-R, 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, and between
less than 'B-sf' and 'B+sf' for class E-R.

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

Upgrade scenarios are not applicable to the class X-R, 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, 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 Ares XLIX CLO 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.


ATLAS SENIOR XX: S&P Assigns BB- (sf) Rating on Class E-R Notes
---------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-1R, A-2R,
B-R, C-R, D-1R, D-2R, and E-R replacement debt and the new class
X-R debt from Atlas Senior Loan Fund XX Ltd./Atlas Senior Loan Fund
XX LLC, a CLO originally issued in October 2022 that is managed by
Crescent Capital Group L.P. At the same time, S&P withdrew its
ratings on the original class A, B-1, B-2, C, D-1, D-2, and E debt
following payment in full on the Oct. 21, 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-1R, A-2R, B-R, C-R, D-1R, and E-R debt
and the new class X-R debt were issued at a floating spread.

-- The replacement class D-2R debt was issued at a fixed coupon.

-- The non-call period was extended by two years to Oct. 19,
2026.

-- The reinvestment period was extended by three years to Oct. 19,
2029.

-- The legal final maturity dates for the replacement debt and the
existing subordinated notes were extended to Oct. 19, 2037.

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

  Atlas Senior Loan Fund XX Ltd./Atlas Senior Loan Fund XX LLC

  Class X-R, $2.0 million: AAA (sf)
  Class A-1R, $244.0 million: AAA (sf)
  Class A-2R, $12.0 million: AAA (sf)
  Class B-R, $48.0 million: AA (sf)
  Class C-R (deferrable), $24.0 million: A (sf)
  Class D-1R (deferrable), $20.0 million: BBB+ (sf)
  Class D-2R (deferrable), $8.0 million: BBB- (sf)
  Class E-R (deferrable), $11.5 million: BB- (sf)

  Ratings Withdrawn

  Atlas Senior Loan Fund XX Ltd./Atlas Senior Loan Fund XX LLC

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

  Other Debt

  Atlas Senior Loan Fund XX Ltd./Atlas Senior Loan Fund XX LLC

  Subordinated notes, $34.9 million: NR



ATRIUM HOTEL 2024-ATRM: DBRS Gives Prov. B Rating on HRR Certs
--------------------------------------------------------------
DBRS, Inc. assigned provisional credit ratings to the following
classes of Commercial Mortgage Pass-Through Certificates, Series
2024-ATRM (the Certificates) to be issued by Atrium Hotel Portfolio
Trust 2024-ATRM (the Trust):

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

All trends are Stable.

The Atrium Hotel Portfolio Trust 2024-ATRM transaction is secured
by the borrower's fee-simple and/or leasehold interests in 24
hospitality properties across 14 states. The portfolio totals 6,106
keys and includes 14 properties that operate under the Hilton brand
family (3,946 keys, representing 73.5% of the allocated loan amount
(ALA)), nine properties that operate under the Marriott brand
family (1,859 keys, representing 21.5% of ALA), and one independent
property (301 keys, representing 5.1% of ALA). The portfolio
includes 18 full-service hotels (5,060 keys), three limited-service
hotels (609 keys), and three extended-stay hotels (437 keys). The
properties were constructed between 1992 and 2009, with a
weighted-average (WA) year built of 2003 and a WA year renovated of
2015.

The sponsor of the transaction is Atrium Holding Company (Atrium),
a leading owner and operator of hospitality properties in the
United States. Atrium has acquired approximately $5 billion of
hospitality properties since 2001 and has a portfolio of 77 hotels
totaling approximately 20,000 keys across 28 states. Atrium
acquired 21 of the 24 properties in the subject portfolio out of a
bankruptcy reorganization of The Revocable Trust of John Q. Hammons
and its affiliates. Nineteen of these properties were acquired in
2018 and securitized in the AHPT 2018-ATRM transaction. The sponsor
acquired the remaining five properties between 2005 and 2019; three
have existing debt (two of which were securitized), while two are
currently unencumbered.

From 2019 to July 2024, the borrower invested approximately $121.1
million ($19,830 per key) into property improvement plan (PIP)
renovations and other capital expenditures across the portfolio,
with investment at each property ranging from $4,085 per key to
$56,606 per key. The borrower plans to spend approximately an
additional $126.1 million ($20,659 per key or $34,466 per renovated
key) from Q4 2024 to 2029 to complete brand-mandated PIP
renovations at 14 properties. From 2019 to 2023, properties in the
portfolio that received full renovations experienced revenue per
available room (RevPAR) penetration growth of 16.5%, compared with
1.0% for nonrenovated properties. Morningstar DBRS believes that
the future PIP renovations will help the portfolio maintain or
improve its competitive position and sustain its current RevPAR
growth.

The brand-mandated PIP renovations will be partially funded by a
$40.0 million upfront PIP reserve. The remaining approximate $86.1
million of renovation costs will be funded via an ongoing monthly
PIP work, replacements, and furniture, fixtures, and equipment
reserve in the amount of 4% of gross revenue and an additional
ongoing monthly reserve in the amount of $1.0 million per month
that begins in November 2026. Morningstar DBRS considers using
ongoing reserves to fund future capital improvements to be a less
prudent loan feature for loans secured by hospitality properties
compared with reserving all costs for future capital improvements
upfront. Morningstar DBRS considered the portfolio's reliance on
ongoing reserves to fund the brand-mandated PIP renovations when
making adjustments to the Morningstar DBRS loan-to-value (LTV)
Sizing Benchmarks.

The largest properties by net cash flow (NCF) for the trailing
12-month period ended August 31, 2024 (T-12 2024), are Rogers
(Bentonville) Embassy Suites, which represents approximately 11.6%
of the T-12 2024 NCF; Frisco Embassy Suites, which represents
approximately 7.7% of the T-12 2024 NCF; and Hilton Long Beach,
which represents approximately 6.7% of the T-12 NCF. The portfolio
is located across 14 states and 21 distinct metropolitan
statistical areas, with the largest concentrations by ALA in Texas
(18.4% of ALA), Arkansas (14.3% of ALA), Nebraska (11.1% of ALA),
and Missouri (10.3% of ALA). Most properties in the portfolio are
in areas with a Morningstar DBRS Market Rank of 2 (41.4% of ALA), 3
(21.3% of ALA), or 5 (21.2% of ALA), and the portfolio has a
Morningstar DBRS WA Market Rank of 3.3. The majority of the
properties are in suburban areas within secondary or tertiary
markets, but they benefit from being near local demand drivers.

In 2019, prior to the coronavirus pandemic, the portfolio achieved
an occupancy rate of 68.8% and an average daily rate (ADR) of
$145.63, resulting in a RevPAR of $100.13. Following a significant
decline during 2020 because of the pandemic, the portfolio's
performance was able to recover to pre-pandemic levels by 2022,
with the YE2022 RevPAR of $101.83 representing a 1.7% increase over
the YE2019 RevPAR. Over the past two years, the portfolio has
continued to experience consistent topline growth. During the T-12
2024, the portfolio achieved a RevPAR of $115.55, representing a
15.4% increase over the YE2019 RevPAR and a 3.2% increase over the
YE2023 RevPAR. The portfolio achieved a WA RevPAR penetration of
127.3% during the T-12 ended July 31, 2024, and did not see WA
RevPAR penetration decline to less than 105.9% between 2015 and
2023, indicating that the majority of properties in the portfolio
have historically outperformed their respective competitive sets.
Based on an occupancy rate of 70.1% and an ADR of $161.81,
Morningstar DBRS concluded a RevPAR of $113.46, which is 1.8% lower
than the T-12 2024 RevPAR of $115.55 and 1.4% greater than the
YE2023 RevPAR of $111.93.

The portfolio's appraised value is approximately $1.45 billion,
which includes a premium of approximately 4.8% for the treatment of
the individual properties as a portfolio; this equates to a
moderately high Issuer LTV of 68.0%. Without the portfolio premium,
the Issuer LTV increases to 71.3%. The Morningstar DBRS-concluded
value of approximately $1.11 billion ($181,753 per key) represents
a 23.4% discount to the appraised value and results in a
Morningstar DBRS whole loan LTV of 88.8%, which indicates
high-leverage financing.

Morningstar DBRS' credit rating on the Certificates addresses the
credit risk associated with the identified financial obligations in
accordance with the relevant transaction documents. The associated
financial obligations are the related Principal Distribution
Amounts and Interest Distribution Amounts for the rated classes.

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


BAIN CAPITAL 2022-4: Fitch Assigns 'BB-sf' Rating on Cl. E-R Notes
------------------------------------------------------------------
Fitch Ratings has assigned ratings to Bain Capital Credit CLO
2022-4, Limited reset transaction.

   Entity/Debt            Rating               Prior
   -----------            ------               -----
Bain Capital Credit
CLO 2022-4, Limited

   A-1 05685BAA4      LT PIFsf  Paid In Full   AAAsf
   X                  LT AAAsf  New Rating
   A-1R               LT NRsf   New Rating
   A-2 05685BAC0      LT PIFsf  Paid In Full   AAAsf
   A-2R               LT AAAsf  New Rating
   B-1 05685BAE6      LT PIFsf  Paid In Full   AAsf
   B-2 05685BAL0      LT PIFsf  Paid In Full   AAsf
   B-R                LT AAsf   New Rating
   C 05685BAG1        LT PIFsf  Paid In Full   Asf
   C-R                LT Asf    New Rating
   D 05685BAJ5        LT PIFsf  Paid In Full   BBB-sf
   D-1R               LT BBBsf  New Rating
   D-2R               LT BBB-sf New Rating
   E 05685CAA2        LT PIFsf  Paid In Full   BB-sf
   E-R                LT BB-sf  New Rating

Transaction Summary

Bain Capital Credit CLO 2022-4, Limited (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. The CLO
originally closed in 2022, and its secured notes were refinanced on
Oct. 16, 2024. Net proceeds from the issuance of the secured and
subordinated notes will provide financing on a portfolio of
approximately $498 million of primarily first lien senior secured
leveraged loans (other than defaulted assets).

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 23.5, versus a maximum covenant, in accordance with
the initial expected matrix point of 24.5. 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
96.82% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 75% versus a
minimum covenant, in accordance with the initial expected matrix
point of 68.9%.

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 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-R, 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, and between
less than 'B-sf' and 'B+sf' for class E-R.

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

Upgrade scenarios are not applicable to the class X-R and class
A-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, 'AAsf' for class C-R, 'A+sf'
for class D-1R, 'A-sf' 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 Bain Capital Credit
CLO 2022-4, 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 any ESG factor that is a
key rating driver in the key rating drivers section of the relevant
rating action commentary.


BALLYROCK CLO 21: S&P Assigns BB- (sf) Rating on Class D-R Notes
----------------------------------------------------------------
S&P Global Ratings assigned its ratings to the replacement class
A-1a-R, A-1b-R, A-2-R, B-R, C-1-R, C-2-R, and D-R debt from
Ballyrock CLO 21 Ltd./Ballyrock CLO 21 LLC, a CLO originally issued
in November 2022 that is managed by Ballyrock Investment Advisors
LLC, an affiliate of Fidelity Management & Research Co. LLC. At the
same time, we withdrew our ratings on the original class A-1, A-2a,
A-2b, B, C, and D debt following payment in full.

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

-- The weighted average cost of debt of the replacement debt is
lower than the original debt.

-- The original class A-1 debt was replaced by two classes of
floating-rate debt (classes A-1a-R and A-1b-R). Class A-1a-R is
senior to class A-1b-R.

-- The original class A-2a and A-2b debt was combined into the
class A-2-R debt.

-- The original class C debt was replaced by two classes of
floating- and fixed-rate debt (classes C-1-R and C-2-R). Class
C-1-R is senior to class C-2-R.

-- The non-call period, reinvestment period, and stated maturity
were extended 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."

  Ratings Assigned

  Ballyrock CLO 21 Ltd./Ballyrock CLO 21 LLC

  Class A-1a-R, $256.0 million: AAA (sf)
  Class A-1b-R, $8.0 million: AAA (sf)
  Class A-2-R, $40.0 million: AA (sf)
  Class B-R (deferrable), $24.0 million: A (sf)
  Class C-1-R (deferrable), $24.0 million: BBB- (sf)
  Class C-2-R (deferrable), $4.0 million: BBB- (sf)
  Class D-R (deferrable), $12.0 million: BB- (sf)

  Ratings Withdrawn

  Ballyrock CLO 21 Ltd./Ballyrock CLO 21 LLC

  Class A-1 to NR from 'AAA (sf)'
  Class A-2a to NR from 'AA (sf)'
  Class A-2b to NR from 'AA (sf)'
  Class B to NR from 'A+ (sf)'
  Class C to NR from 'BBB+ (sf')
  Class D to NR from 'BB- (sf)'

  Other Debt

  Ballyrock CLO 21 Ltd./Ballyrock CLO 21 LLC

  Subordinated notes, $32.5 million: NR

  NR--Not rated.



BAMLL COMMERCIAL 2015-200P: S&P Affirms BB- (sf) Rating on F Certs
------------------------------------------------------------------
S&P Global Ratings affirmed its ratings on eight classes of
commercial mortgage pass-through certificates from BAMLL Commercial
Mortgage Securities Trust 2015-200P, a U.S. CMBS transaction.

This is a U.S. CMBS transaction backed by a fixed-rate,
interest-only (IO) mortgage loan secured by 200 Park Avenue, also
known as The Metlife Building, which is an office property located
in the Grand Central office submarket.

Rating Actions

The affirmations on classes A, B, C, D, E, and F primarily reflect
the following:

-- Since S&P's last published review in May 2023, the property's
reported occupancy rate has increased to 96.9% as of the June 30,
2024, rent roll, up from 85.9% as of the March 31, 2023, rent roll.
The increase in occupancy was driven in part by new tenant signings
including BDO USA P.C. (4.6% of property net rentable area [NRA])
and Herbert Smith Freehills New York LLC (1.2%), as well as
existing tenant expansions including Golub Capital LLC (1.4% of
additional property NRA) and Paul Hastings LLP (0.7%).

-- The largest tenant, Metlife Services and Solutions LLC
(Metlife; 17.6% of property NRA; 16.8% of S&P Global Ratings'
in-place gross rent; September 2038 and March 2025 lease
expirations), recently extended a significant portion of its space
(16.1% of property NRA) through September 2038. This portion of
Metlife's space was previously set to expire in September 2037, and
it is S&P's understanding that the renewed rental rate reflects a
premium over the prior rent. In addition, the fifth-largest tenant,
CBRE Inc. (6.4%; 7.7%; 2037), recently extended its lease through
2037. CBRE Inc.'s leases were previously set to expire in 2026 and
2031. S&P said, "It's our understanding that the renewed rental
rate also reflects a premium over the prior rent. We view the
recent lease signings/extensions and rental rate premiums as
positive indicators of the property's ability to attract and retain
tenancy at competitive rental rates."

-- While still elevated, the submarket's 15.6% availability rate
for year-to-date (YTD) October 2024 is down from the 20.8% for YTD
May 2023 as seen at S&P's last published review, reflecting CoStar
information for four- and five-star properties in the Grand Central
office submarket.

-- These factors, and others, were considered in S&P's current
analysis, which supports the sustainability of its existing S&P
Global Ratings' net cash flow (NCF) and value, as reflected in the
affirmations.

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

-- S&P said, "We noted the loan's imminent April 10, 2025,
maturity date, and its relatively low 3.60% coupon rate, which is
well-below prevailing market interest rates, and could exacerbate
its refinance risk. While the loan's 1.97x 2023-reported debt
service coverage ratio and 48.3% issuance-appraisal-based
loan-to-value ratio bode positively, we will continue to monitor
the performance of the property, the submarket, and the loan's
upcoming maturity. If we receive information that differs
materially from our expectations, we may revisit our analysis and
take additional rating actions as we determine necessary."

Updates To Property Analysis

S&P said, "Our updated analysis primarily considers the June 2024
property rent roll, updated property performance information, and
subsequent updates gleaned from CoStar data, news articles, and
servicer correspondence.

"In our re-evaluation of the property, we derived an S&P Global
Ratings' gross rent of $90.51 per sq. ft., which reflects our
review of the June 2024 rent roll, and making adjustments for
tenants in free rent periods. Our figure was comparable to CoStar's
current gross asking rent of $86.69 per sq. ft. for four- and
five-star properties in their Grand Central office submarket.
Despite the property's generally high historical occupancy rates,
in recognition of the 5.2% of property NRA either currently being
subleased or marketed for sublease (the same as at our last
published review), we maintained our 11.5% long-term vacancy
assumption, which is the same as our last published review. Using
primarily 2023 operating expense assumptions, we derived an S&P
Global Ratings' NCF in line with the $109.8 million derived at our
last published review, which we are maintaining. We applied our
6.25% capitalization rate (unchanged from our last published
review) and arrived at an S&P Global Ratings' expected-case value
of $1.76 billion ($572 per sq. ft.), the same as our last published
review and issuance."

The five largest tenants at the property by NRA, are:

-- Metlife Services and Solutions LLC (17.6% of property NRA;

-- 16.8% of S&P Global Ratings' in-place gross rent; September
2038 and March 2025 lease expirations);

-- Gibson, Dunn and Crutcher LLP (10.1%; 11.6%; October 2031);

-- Paul Hastings LLP (8.4%; 8.8%; June 2035);

-- Winston and Strawn LLP (7.7%; 7.9%; August 2037); and

-- CBRE Inc. (6.4%; 7.7%; 2037).

  Table 1

  Servicer-reported collateral performance

                      YTD March 2024(i)  2023(i)  2022(i)  2021(i)

  Occupancy rate (%)            95.7     91.1     85.9     92.7
  Net cash flow (mil. $)        27.6    100.6     94.6    115.9
  Debt service coverage (x)     2.17     1.97     1.85     2.27
  Appraisal value (mil. $)    2,900.0  2,900.0  2,900.0  2,900.0

  (i)Reporting period.
  YTD--Year-to-date.

  Table 2

  S&P Global Ratings' key assumptions
                         Current     Last review    Issuance
                   (October 2024)(i) (May 2023)(i) (April 2015)(i)

  Occupancy rate (%)        88.5          88.5            95.0
  Net cash flow (mil. $)   109.8         109.8           109.4
  Capitalization rate (%)   6.25          6.25            6.25
  Value (mil. $)         1,756.8       1,756.8         1,756.8
  Value per sq. ft. ($)      572           572             572
  Loan-to-value ratio (%)   79.7          79.7            79.7

  (i)Review period.

Transaction Summary

The IO mortgage loan had an initial and current balance of $1.4
billion (as of the October 2024, trustee remittance report), pays
an annual fixed interest rate of 3.60%, and matures on April 10,
2025.

The loan had a current payment status according to the October 2024
trustee remittance report. To our knowledge, there is no additional
debt outstanding. Also, the trust has not incurred any principal
losses to date.

  Ratings Affirmed

  BAMLL Commercial Mortgage Securities Trust 2015-200P

  Class A: AAA (sf)
  Class B: AA- (sf)
  Class C: A- (sf)
  Class D: BBB- (sf)
  Class E: BBB- (sf)
  Class F: BB- (sf)
  Class X-A: AAA (sf)
  Class X-B: AA- (sf)



BANK 2019-BNK26: Fitch Affirms B-sf Rating on 2 Tranches
--------------------------------------------------------
Fitch Ratings has affirmed 17 classes of BANK 2019-BNK22 Commercial
Mortgage Pass-Through Certificates, series 2019-BNK22. The Rating
Outlooks for classes G and X-G were revised to Negative from
Stable.

Fitch has also affirmed 29 classes of BANK 2020-BNK26 commercial
mortgage pass-through certificates, series 2020-BNK26. The Rating
Outlooks for classes F, G, X-F and X-G were revised to Negative
from Stable.

   Entity/Debt            Rating           Prior
   -----------            ------           -----
BANK 2019-BNK22

   A-1 06540XBC4      LT AAAsf  Affirmed   AAAsf
   A-2 06540XBD2      LT AAAsf  Affirmed   AAAsf
   A-3 06540XBF7      LT AAAsf  Affirmed   AAAsf
   A-4 06540XBG5      LT AAAsf  Affirmed   AAAsf
   A-S 06540XBK6      LT AAAsf  Affirmed   AAAsf
   A-SB 06540XBE0     LT AAAsf  Affirmed   AAAsf
   B 06540XBL4        LT AA-sf  Affirmed   AA-sf
   C 06540XBM2        LT A-sf   Affirmed   A-sf
   D 06540XAL5        LT BBBsf  Affirmed   BBBsf
   E 06540XAN1        LT BBB-sf Affirmed   BBB-sf
   F 06540XAQ4        LT BB-sf  Affirmed   BB-sf
   G 06540XAS0        LT B-sf   Affirmed   B-sf
   X-A 06540XBH3      LT AAAsf  Affirmed   AAAsf
   X-B 06540XBJ9      LT AA-sf  Affirmed   AA-sf
   X-D 06540XAA9      LT BBB-sf Affirmed   BBB-sf
   X-F 06540XAC5      LT BB-sf  Affirmed   BB-sf
   X-G 06540XAE1      LT B-sf   Affirmed   B-sf

BANK 2020-BNK26

   A-1 06540JAY8      LT AAAsf  Affirmed   AAAsf
   A-2 06540JAZ5      LT AAAsf  Affirmed   AAAsf
   A-3 06540JBB7      LT AAAsf  Affirmed   AAAsf
   A-3-1 06540JBC5    LT AAAsf  Affirmed   AAAsf
   A-3-2 06540JBD3    LT AAAsf  Affirmed   AAAsf
   A-3-X1 06540JBE1   LT AAAsf  Affirmed   AAAsf
   A-3-X2 06540JBF8   LT AAAsf  Affirmed   AAAsf
   A-4 06540JBG6      LT AAAsf  Affirmed   AAAsf
   A-4-1 06540JBH4    LT AAAsf  Affirmed   AAAsf
   A-4-2 06540JBJ0    LT AAAsf  Affirmed   AAAsf
   A-4-X1 06540JBK7   LT AAAsf  Affirmed   AAAsf
   A-4-X2 06540JBL5   LT AAAsf  Affirmed   AAAsf
   A-S 06540JBP6      LT AAAsf  Affirmed   AAAsf
   A-S-1 06540JBQ4    LT AAAsf  Affirmed   AAAsf
   A-S-2 06540JBR2    LT AAAsf  Affirmed   AAAsf
   A-S-X1 06540JBS0   LT AAAsf  Affirmed   AAAsf
   A-S-X2 06540JBT8   LT AAAsf  Affirmed   AAAsf
   A-SB 06540JBA9     LT AAAsf  Affirmed   AAAsf
   B 06540JBU5        LT AA-sf  Affirmed   AA-sf
   C 06540JBV3        LT A-sf   Affirmed   A-sf
   D 06540JAJ1        LT BBBsf  Affirmed   BBBsf
   E 06540JAL6        LT BBB-sf Affirmed   BBB-sf
   F 06540JAN2        LT BB-sf  Affirmed   BB-sf
   G 06540JAQ5        LT B-sf   Affirmed   B-sf
   X-A 06540JBM3      LT AAAsf  Affirmed   AAAsf
   X-B 06540JBN1      LT A-sf   Affirmed   A-sf
   X-D 06540JAA0      LT BBB-sf Affirmed   BBB-sf
   X-F 06540JAC6      LT BB-sf  Affirmed   BB-sf
   X-G 06540JAE2      LT B-sf   Affirmed   B-sf

KEY RATING DRIVERS

Stable 'Bsf' Loss Expectations: The affirmations reflect generally
stable pool performance and loss expectations since Fitch's prior
rating action. Deal-level 'Bsf' rating case losses are 2.9% for
BANK 2019-BNK22 and 3.7% for BANK 2020-BNK26. The BANK 2019-BNK22
transaction has three Fitch Loans of Concern (FLOCs; 6.0% of the
pool). The BANK 2020-BNK26 transaction has three FLOCs (11.3%).
There are currently no specially serviced loans in both of these
transactions.

The Negative Outlooks on classes G and X-G in BANK 2019-BNK22
reflect performance concerns with the FLOCs, particularly Tysons
Tower (3.8%), The Blvd (1.2%) and Columbia Hotel Portfolio (1.0%).
The Negative Outlooks on classes F, G, X-F and X-G in BANK
2020-BNK26 reflect the pool's elevated office exposure of 38.2% and
possible future downgrades should performance of the FLOCs,
particularly F Street and K Street Office Portfolio (2.7%), Bravern
Office Commons (6.4%) and Coral Sky Plaza (2.2%), continue to
deteriorate.

FLOCs: The largest FLOC in the BANK 2019-BNK22 transaction is the
Tysons Tower loan (3.8%), which is secured by a 22-story,
528,730-sf office tower developed in 2014 and located in McLean,
VA, about 11 miles west of Washington, D.C. The largest tenants
include Intelsat (33.6% of NRA, leased through December 2030) and
Deloitte (17.3%; August 2027).

According to the June 2024 rent roll, occupancy has declined to 76%
from 85% at YE 2023, 92% at YE 2022 and 99.7% at YE 2021. Several
tenants have downsized, including Intelstat, which reduced its
space from 40.2% of the NRA at issuance. The servicer-reported NOI
DSCR was 2.82x for YTD June 2024, compared to 3.14x at YE 2023,
3.18x at YE 2022. Fitch's 'Bsf' rating case loss of 3.4% (prior to
a concentration adjustment) is based on a 9.50% cap rate and 15%
stress to the YE 2023 NOI to reflect the decline in performance.

The second largest FLOC in BANK 2019-BNK22 is The Blvd loan (1.2%),
which is secured by a 42,472-sf retail center located in Myrtle
Beach, SC. The property's major tenants include Tin Roof
Acquisition Company (23.7% of NRA, leased through June 2050), Smoky
Mountain Blades (15.0%, May 2028) and Legends Sports Bar (10.7%,
February 2033). Property occupancy fell to 65.1% as of March 2024.
Occupancy decline was largely attributed to former major tenants,
Epic Arcades LLC (previously 34.2% of NRA) and Banditos (20.2%),
vacating the property, but a portion of that vacancy was backfilled
by Smoky Mountain Blades. Fitch's 'Bsf' rating case loss of 22.4%
(prior to a concentration adjustment) is based on a 10.50% cap rate
and 7.5% stress to the YE 2023 NOI.

The largest increase in loss since the prior rating action in the
BANK 2020-BNK26 transaction is the F Street and K Street Office
Portfolio loan (2.7%), which is secured by a two-property office
portfolio totaling 124,667-sf located in Washington, D.C. Major
tenants include First Book (12.7% of portfolio NRA, leased through
July 2027), Proper Ventures, LLC (6.0%, November 2026) and Fed Ex
Office & Print (4.2%; January 2029).

Overall portfolio occupancy was 73.4% as of March 2024, compared
with 73.0% at YE 2023, 76.4% at YE 2022, 74.0% at YE 2021, and
90.0% at YE 2020. Portfolio occupancy declined in 2021 due to CAIR
(previously 6.7% of portfolio NRA) and other smaller tenants
vacating upon lease expiry. In addition, Green America downsized to
2.5% of portfolio NRA from 4.6%. The servicer-reported NOI DSCR was
1.24x as of YTD March 2024, compared to 1.29x at YE 2023, and 1.30x
at YE 2022. The loan reported $1.3 million in total reserves as of
September 2024.

Per CoStar, the property lies within the CBD office submarket of
Washington, D.C. As of 3Q24, submarket asking rents averaged $54.54
psf and the submarket vacancy rate was 19.4%. Fitch's 'Bsf' rating
case loss of 26.0% (prior to a concentration adjustment) is based
on a 9.75% cap rate and 10% stress to the YE 2023 NOI.

Fitch is also monitoring the performance of the Bravern Office
Commons loan (6.4%) in BANK 2020-BNK26, which is secured by two
office buildings totaling 749,694 sf located in Bellevue, WA, due
to the imminent deterioration of property occupancy and cash flow
following the announced departure of the single tenant at its
upcoming 2025 lease expiration, coupled with weakening submarket
fundamentals. The property is 100% leased to Microsoft Corporation
across two leases with 34.0% of NRA expiring in June 2025 and 66.0%
expiring in August 2025. However, Microsoft plans to fully vacate
the property in mid-2025. The Microsoft space is predominantly
dark, but Microsoft continues to pay rent and is expected to pay
rent through its lease expiry dates.

According to the servicer, there are currently no leasing prospects
to backfill the vacated Microsoft space to date and Microsoft is
not subleasing any space at the property. The loan reported $31.6
million ($42.1 psf) in total reserves as of September 2024.

Minimal Changes to Credit Enhancement (CE): As of the September
2024 distribution date, the aggregate pool balances of the BANK
2019-BNK22 and BANK 2020-BNK26 transactions have been paid down by
1.5% and 2.5%, respectively, since issuance. The BANK 2019-BNK22
transaction includes four loans (8.4% of the pool) that have been
fully defeased. Two loans (4.0%) are fully defeased in BANK
2020-BNK26.

Interest shortfalls totaling $7,240 are impacting the nonrated
class J and risk retention class RRI in the BANK 2019-BNK22
transaction, and interest shortfalls totaling $18,853 are impacting
the nonrated class H and risk retention class RRI in the BANK
2020-BNK26 transaction.

RATING SENSITIVITIES

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

- Downgrades to the '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 affect
these classes;

- Downgrades to classes rated in the 'AAsf', 'Asf' and 'BBBsf'
categories could occur if deal-level losses increase significantly
from outsized losses on larger FLOCs, including Tysons Tower, The
Blvd and Columbia Hotel Portfolio in BANK 2019-BNK22 and F Street
and K Street Office Portfolio, Bravern Office Commons and Coral Sky
Plaza in BANK 2020-BNK26, 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 the aforementioned FLOCs, additional transfers to
special servicing, and/or with greater certainty of losses on the
specially serviced loans and/or 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, coupled with
stable-to-improved pool-level loss expectations and stabilized
performance on the FLOCs, including Tysons Tower, The Blvd and
Columbia Hotel Portfolio in BANK 2019-BNK22 and F Street and K
Street Office Portfolio, Bravern Office Commons and Coral Sky Plaza
in BANK 2020-BNK26;

- 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 the likelihood of 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.

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.


BANK 2021-BNK34: Fitch Affirms 'B-sf' Rating on Two Tranches
------------------------------------------------------------
Fitch Ratings has affirmed 38 classes of BANK 2021-BNK34,
commercial mortgage pass-through certificates series 2021-BNK34.
The Rating Outlook on classes F, G, X-F and X-G remain Negative.

   Entity/Debt            Rating           Prior
   -----------            ------           -----
BANK 2021-BNK34

   A-1 06541JAA9      LT AAAsf  Affirmed   AAAsf
   A-2 06541JAB7      LT AAAsf  Affirmed   AAAsf
   A-3 06541JAC5      LT AAAsf  Affirmed   AAAsf
   A-4 06541JAF8      LT AAAsf  Affirmed   AAAsf
   A-4-1 06541JAG6    LT AAAsf  Affirmed   AAAsf
   A-4-2 06541JAH4    LT AAAsf  Affirmed   AAAsf
   A-4-X1 06541JAJ0   LT AAAsf  Affirmed   AAAsf
   A-4-X2 06541JAK7   LT AAAsf  Affirmed   AAAsf
   A-5 06541JAL5      LT AAAsf  Affirmed   AAAsf
   A-5-1 06541JAM3    LT AAAsf  Affirmed   AAAsf
   A-5-2 06541JAN1    LT AAAsf  Affirmed   AAAsf
   A-5-X1 06541JAP6   LT AAAsf  Affirmed   AAAsf
   A-5-X2 06541JAQ4   LT AAAsf  Affirmed   AAAsf
   A-S 06541JAT8      LT AAAsf  Affirmed   AAAsf
   A-S-1 06541JAU5    LT AAAsf  Affirmed   AAAsf
   A-S-2 06541JAV3    LT AAAsf  Affirmed   AAAsf
   A-S-X1 06541JAW1   LT AAAsf  Affirmed   AAAsf
   A-S-X2 06541JAX9   LT AAAsf  Affirmed   AAAsf
   A-SB 06541JAD3     LT AAAsf  Affirmed   AAAsf
   B 06541JAY7        LT AA-sf  Affirmed   AA-sf
   B-1 06541JAZ4      LT AA-sf  Affirmed   AA-sf
   B-2 06541JBA8      LT AA-sf  Affirmed   AA-sf
   B-X1 06541JBB6     LT AA-sf  Affirmed   AA-sf
   B-X2 06541JBC4     LT AA-sf  Affirmed   AA-sf
   C 06541JBD2        LT A-sf   Affirmed   A-sf
   C-1 06541JBE0      LT A-sf   Affirmed   A-sf
   C-2 06541JBF7      LT A-sf   Affirmed   A-sf
   C-X1 06541JBG5     LT A-sf   Affirmed   A-sf
   C-X2 06541JBH3     LT A-sf   Affirmed   A-sf
   D 06541JBS9        LT BBBsf  Affirmed   BBBsf
   E 06541JBU4        LT BBB-sf Affirmed   BBB-sf
   F 06541JBW0        LT BB-sf  Affirmed   BB-sf
   G 06541JBY6        LT B-sf   Affirmed   B-sf
   X-A 06541JAR2      LT AAAsf  Affirmed   AAAsf
   X-B 06541JAS0      LT A-sf   Affirmed   A-sf
   X-D 06541JBJ9      LT BBB-sf Affirmed   BBB-sf
   X-F 06541JBL4      LT BB-sf  Affirmed   BB-sf
   X-G 06541JBN0      LT B-sf   Affirmed   B-sf

KEY RATING DRIVERS

Performance and 'Bsf' Loss Expectations: The affirmations reflect
generally stable pool performance and loss expectations since the
prior rating action. Deal-level 'Bsf' rating case loss is 3.4% and
the transaction has three Fitch Loans of Concern (FLOCs; 2.4% of
the pool), including the specially serviced 928 San Vicente loan
(0.5%), which is secured by a 24-unit multi-family property located
in West Hollywood, CA. The other FLOCs, Sherman Oaks Plaza (1.1%)
and North Ridge Center (0.9%), have experienced occupancy and cash
flow declines since issuance.

The Negative Outlooks reflect the high office concentration of
51.6% (including seven of the top 10 loans) and the potential for
downgrades should performance of the FLOCs fail to stabilize.

Largest Contributors to Loss: The largest contributor to overall
loss expectations and largest loan in the pool is the 375 Pearl
Street (9.7%) loan, which is secured by a 573,083-sf office
building located in Manhattan, NY. The property's major tenants
include; NYC Human Resources Administration (33.8% of NRA, leased
through September 2039), Department of Finance (31.8%, September
2038) and NYPD (18.5%, January 2042). The property was 100%
occupied as of June 2024 and the servicer-reported NOI DSCR was
2.32x for the same period.

Fitch's 'Bsf' case loss of 7.0% (prior to a concentration
adjustment) is based on an 8.75% cap rate and 10% stress to the YE
2023 net operating income (NOI).

The second largest contributor to expected losses is the 261-275
Amsterdam Avenue (3.9%) loan, which is secured by a 146-unit
multifamily and ground floor retail mixed use property located in
Manhattan, NY. The property was 99% occupied as of March 2024 and
the servicer-reported NOI DSCR was 1.73x for the same period, down
from 1.95x at YE 2023 and 1.61x at YE 2022. Fitch's 'Bsf' case loss
of 6.6% (prior to a concentration adjustment) is based on an 8.75%
cap rate to the Fitch issuance net cash flow (NCF).

The third largest contributor to expected losses is the U.S. Steel
Tower (6.8%) loan, which is secured by a 2.3 million-sf office
building located in Pittsburgh, PA. The property's major tenants
include; University of Pittsburgh Medical Center (46.2% of NRA,
leased through March 2030), US Steel Corporation (10.0%, January
2038) and Eckert Seamans (4.5%, December 2030). Property occupancy
was 74.1% as of June 2024, 74.0% at YE 2023 and 74.7% at YE 2022.
The servicer-reported NOI DSCR was 2.46x as of June 2024, down from
2.72x at YE 2023 and 2.47x at YE 2022. Fitch's 'Bsf' case loss of
3.7% (prior to a concentration adjustment) is based on an 10.0% cap
rate and 10% stress to the YE 2023 NOI.

Minimal Increase in CE: As of the September 2024 remittance
reporting, the pool's aggregate principal balance has been reduced
by 0.3% since issuance. Thirty-eight loans (92.7%) are full term,
interest-only. Four loans (2.7%) have a partial, interest-only
component, of which two loans (1.1%) have begun amortizing. There
are no defeased loans. Cumulative interest shortfalls are impacting
the risk-retention RRI class and class H.

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 and/or interest shortfalls occur or
are expected to occur;

- Downgrades to classes rated in the 'AAsf', 'Asf' and 'BBBsf'
categories may occur should performance of the FLOCs and/or office
properties deteriorate further, or should expected losses for the
pool increase significantly and/or if additional loans become
FLOCs.

- Downgrades to classes rated in the 'BBsf', and 'Bsf' categories,
which have Negative Outlooks, could occur with higher than expected
losses from continued underperformance of the FLOCs and with
greater certainty of losses on the specially serviced loan or other
FLOCs.

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

- Upgrades to 'AAsf' and 'Asf' category rated classes are possible
with significantly increased CE from paydowns, coupled with
stable-to-improved pool-level loss expectations and performance
stabilization of FLOCs. Upgrades of these classes to 'AAAsf' will
also consider the concentration of defeased loans in the
transaction;

- Upgrades to the 'BBBsf' category rated classes would be limited
based on sensitivity to concentrations or the potential for future
concentration and would only occur with sustained improved
performance of the FLOCs;

- Upgrades to '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 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.


BANK 2021-BNK35: DBRS Confirms B Rating on Class J Certs
--------------------------------------------------------
DBRS, Inc. confirmed the credit ratings on all classes of
Commercial Mortgage Pass-Through Certificates, Series 2021-BNK35
issued by BANK 2021-BNK35 as follows:

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-SB at AAA (sf)
-- Class A-3 at AAA (sf)
-- Class A-4 at AAA (sf)
-- Class A-4-1 at AAA (sf)
-- Class A-4-2 at AAA (sf)
-- Class A-4-X1 at AAA (sf)
-- Class A-4-X2 at AAA (sf)
-- Class A-5 at AAA (sf)
-- Class A-5-1 at AAA (sf)
-- Class A-5-2 at AAA (sf)
-- Class A-5-X1 at AAA (sf)
-- Class A-5-X2 at AAA (sf)
-- Class X-A at AAA (sf)
-- Class A-S at AAA (sf)
-- Class A-S-1 at AAA (sf)
-- Class A-S-2 at AAA (sf)
-- Class A-S-X1 at AAA (sf)
-- Class A-S-X2 at AAA (sf)
-- Class B at AAA (sf)
-- Class B-1 at AAA (sf)
-- Class B-2 at AAA (sf)
-- Class B-X1 at AAA (sf)
-- Class B-X2 at AAA (sf)
-- Class X-B at AA (sf)
-- Class C at AA (low) (sf)
-- Class C-1 at AA (low) (sf)
-- Class C-2 at AA (low) (sf)
-- Class C-X1 at AA (low) (sf)
-- Class C-X2 at AA (low) (sf)
-- Class X-D at A (low) (sf)
-- Class D at A (low) (sf)
-- Class E at BBB (high) (sf)
-- Class X-FG at BBB (low) (sf)
-- Class F at BBB (low) (sf)
-- Class X-H at BB (high) (sf)
-- Class G at BB (high) (sf)
-- Class H at BB (sf)
-- Class X-J at B (high) (sf)
-- Class J at B (sf)

All trends are Stable.

The credit rating confirmations and Stable trends reflect the
overall strong performance of the transaction, as exhibited by a
healthy weighted-average (WA) pool debt service coverage ratio
(DSCR) of 3.36 times (x), low WA pool expected loss and no loans in
special servicing. As of the September 2024 remittance, all 76 of
the original loans remain in the pool with a marginal collateral
reduction of 1.2% since issuance. One loan, representing 0.2% of
the pool, has been fully defeased. Additionally, there are only
three loans, representing 1.3% of the pool balance, on the
servicer's watchlist, all of which are being monitored for deferred
maintenance concerns. The pool is concentrated with loans backed by
office and retail properties that make up 27.6% and 25.1% of the
pool balance, respectively.

The loans backed by office properties have generally performed
well, reporting a WA DSCR of 3.6x, slightly higher than the pool
average for all loans. There is a notable concentration of
government- and city-affiliated tenant exposure for the collateral
properties, with three loans in the top 15 (accounting for 9.6% of
the pool balance) 100% leased to such entities. While the
office-backed loans are expected to continue to perform overall,
there are challenges for the office sector as a whole and, as such,
select loans with factors suggesting risks could increase over the
loan term were stressed in the analysis for this review.

Among these loans is One Trinity Center (Prospectus ID#11, 2.9% of
the pool balance), which is secured by a Class B office property
located in downtown San Francisco. The $40.0 million fixed-rate
loan pays interest-only (IO) for the entirety of its 10-year term.
According to the June 2024 rent roll, occupancy was 86.0%, and
increase from 81.2% in June 2023 due to the signing of a new
tenant, Department of Public Health (4.7% of the net rentable area
(NRA), lease expiry July 2034). In addition, San Francisco City
Health Service System (14.4% of the NRA, lease expiry in June 2034)
recently renewed their lease for a 10-year term. However, a recent
lease expiration and exposure to month-to-month (MTM) tenancy are
concerns for two of the top three tenants, City and County of San
Francisco (27.4% of NRA, lease expiry in July 2024) and the San
Francisco Law Library (14.8% of the NRA, MTM lease). Online news
sources located by Morningstar DBRS indicated that the City and
County of San Francisco has been in discussions regarding a lease
extension, but this has not been confirmed by the servicer. Per the
Reis Q2 2024 report for the Van Ness/Civic Center submarket, the
average vacancy rate was 49.1%, indicating severely depressed
demand, of particular concern given the rollover risk at the
subject, and a contributor to Morningstar DBRS' expectation that
the in-place DSCR, which is hovering at 3.0x, could significantly
decline. As such, Morningstar DBRS applied a stressed loan-to-value
ratio and an elevated probability of default in its analysis for
this review, resulting in an expected loss nearly three times the
deal average.

At issuance, Morningstar DBRS shadow-rated three loans
investment-grade: Four Constitution (Prospectus ID#3, 4.0% of the
pool balance), River House Coop (Prospectus ID#4 3.7% of the pool
balance), and Three Constitution (Prospectus ID#12, 2.8% of the
pool balance). As confirmed with this review, these loans continue
to exhibit credit characteristics consistent with the respective
investment-grade shadow ratings. The Four Constitution and Three
Constitution loans are backed by office properties that are 100%
occupied by the United States Department of Justice on 15-year
leases with no termination options through maturity, and the River
House Coop loan is backed by an exclusive co-operative apartment
building in Manhattan with high property quality.

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


BANK5 2024-5YR10: Fitch Assigns 'B-sf' Final Rating on Two Tranches
-------------------------------------------------------------------
Fitch Ratings has assigned final ratings and Ratings Outlooks to
the BANK5 2024-5YR10 commercial mortgage pass-through certificates,
series 2024-5YR10 as follows:

   Entity/Debt         Rating             Prior
   -----------         ------             -----
BANK5 2024-5YR10

   A-1             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-S             LT AAAsf  New Rating   AAA(EXP)sf
   B               LT AA-sf  New Rating   AA-(EXP)sf
   C               LT A-sf   New Rating   A-(EXP)sf
   D               LT BBBsf  New Rating   BBB(EXP)sf
   E               LT BBB-sf New Rating   BBB-(EXP)sf
   F               LT BB-sf  New Rating   BB-(EXP)sf
   G               LT B-sf   New Rating   B-(EXP)sf
   H-RR            LT NRsf   New Rating   NR(EXP)sf
   RR              LT NRsf   New Rating   NR(EXP)sf
   RRI             LT NRsf   New Rating   NR(EXP)sf
   X-A             LT AAAsf  New Rating   AAA(EXP)sf
   X-B             LT A-sf   New Rating   A-(EXP)sf
   X-D             LT BBB-sf New Rating   BBB-(EXP)sf
   X-F             LT BB-sf  New Rating   BB-(EXP)sf
   X-G             LT B-sf   New Rating   B-(EXP)sf

- $8,457,000a class A-1 'AAAsf'; Outlook Stable;

- $125,000,000a class A-2 'AAAsf'; Outlook Stable;

- $432,149,000a class A-3 'AAAsf'; Outlook Stable;

- $565,606,000b class X-A 'AAAsf'; Outlook Stable;

- $94,941,000a class A-S 'AAAsf'; Outlook Stable;

- $39,391,000a class B 'AA-sf'; Outlook Stable;

- $29,290,000a class C 'A-sf'; Outlook Stable;

- $163,622,000b class X-B 'A-sf'; Outlook Stable;

- $12,120,000ac class D 'BBBsf'; Outlook Stable;

- $8,080,000ac class E 'BBB-sf'; Outlook Stable;

- $20,200,000bc class X-D 'BBB-sf'; Outlook Stable;

- $16,160,000ac class F 'BB-sf'; Outlook Stable;

- $16,160,000bc class X-F 'BB-sf'; Outlook Stable;

- $12,121,000ac class G 'B-sf'; Outlook Stable;

- $12,121,000ac class X-G 'B-sf'; Outlook Stable.

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

- $30,300,381acd class H-RR;

- $23,541,794.26e class RR;

- $6,285,180e RR Interest.

(a) Class balances, excluding the combined vertical risk retention
(VRR) interest, are net of their proportionate share of the VRR
interest, totaling 3.56% of the notional amount of the
certificates.

(b) Notional amount and interest only.

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

(d) Class H-RR certificates comprise the transaction's horizontal
risk retention (HRR) interest.

(e) The class RR and RR Interest comprise the transaction's
combined vertical risk retention interest.

Since Fitch published its expected ratings on Sept. 26, 2024, the
following changes have occurred: the balances for classes A-2 and
A-3 were finalized. At the time the expected ratings were
published, the initial aggregate certificate balance of the A-2
class was expected to be in the $0-$275,000,000 range and the
initial certificate balance of the A-3 class was expected to be in
the $282,149,000-$557,149,000 range. The final class balances for
classes A-2 and A-3 are $125,000,000 and $432,149,000,
respectively.

Transaction Summary

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 42 loans secured by 83
commercial properties with an aggregate principal balance of
$837,836,355 as of the cut-off date.

The loans were contributed to the trust by Wells Fargo Bank,
National Association; Morgan Stanley Mortgage Capital Holdings LLC;
JPMorgan Chase Bank, National Association and Bank of America,
National Association.

The master servicer is expected to be Wells Fargo Bank, National
Association and the special servicer is expected to be Rialto
Capital Advisors, LLC. The trustee and certificate administrator
are both expected to be Computershare Trust Company, National
Association.

The certificates are expected to follow a sequential paydown
structure.

KEY RATING DRIVERS

Fitch Net Cash Flow: Fitch performed cash flow analyses on 22 loans
totaling 85.5% of the pool by balance. Fitch's resulting net cash
flow (NCF) of $88.4 million represents an 11.9% decline from the
issuer's underwritten NCF of $99.3 million. Aggregate NCFs include
only the pro-rated trust portion of any pari passu loan. The NCF
decline is below the 2024 YTD five-year and 2023 five-year averages
of 13.2% and 12.9%, respectively.

Higher Fitch Leverage: The pool has higher leverage than recent
five-year multiborrower transactions rated by Fitch. The pool's
Fitch loan-to-value ratio (LTV) of 95.5% is worse than both the
2024 YTD and 2023 averages of 93.5% and 89.7%, respectively. The
pool's Fitch NCF debt yield (DY) of 10.4% is approximately in line
with the 2024 YTD and 2023 averages of 10.4% and 10.6%,
respectively.

Investment Grade Credit Opinion Loans: One loan representing 6.0%
of the pool balance received an investment grade credit opinion.
Bronx Terminal Market received a credit opinion of 'BBB-sf*' on a
standalone basis. The pool's total credit opinion percentage is
below the 2024 YTD and 2023 five-year averages of 12.0% and 14.6%,
respectively. Fitch NCF DY and LTV net of the credit opinion loan
are 10.4% and 96.7%, respectively.

Higher Loan Concentration: The largest 10 loans constitute 60.8% of
the pool, which is higher than the 2024 YTD five-year average of
59.2% but below the 2023 five-year average of 65.3%. Fitch measures
loan concentration risk using an effective loan count, which
accounts for both the number and size of the loans in the pool. The
pool's effective loan count is 22.5, which is better than the 2023
five-year average of 19.7 but marginally worse than the 2024 YTD
five-year average of 23.0. Fitch views diversity as a key mitigant
to idiosyncratic risk. Fitch raises the overall loss for pools with
effective loan counts below 40.

Geographic Concentration: The transaction has a higher geographic
diversity than recent five-year multiborrower transactions Fitch
has rated, but the pool remains somewhat concentrated overall. The
top three MSA concentrations are New York-Newark-Jersey City,
NY-NJ-PA (19.4%), Los Angeles-Long Beach-Anaheim, CA (12.1%) and
Louisville/Jefferson County, KY-IN (9.9%). The pool's effective
geographic count of 13.0 is above the 2024 YTD and 2023 five-year
averages of 10.3 and 10.7, respectively.

Pools that have a greater concentration by geographic region are at
greater risk of losses, all else equal. Fitch therefore raises the
overall losses for pools with effective geographic counts below 15
MSAs (regions for Canada).

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

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

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

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

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

The list 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 Increase:
'AAAsf'/'AAAsf'/'AA+sf'/'Asf'/'A-sf'/'BBB+sf'/'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 Deloitte & Touche LLP. The third-party due diligence
described in Form 15E focused on a comparison and re-computation of
certain characteristics with respect to each of the mortgage loans.
Fitch considered this information in its analysis, and it did not
have an effect on Fitch's analysis or conclusions.

ESG Considerations

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.


BARINGS CLO 2022-IV: Fitch Assigns BB-sf Rating on Class E-R Notes
------------------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to Barings
CLO Ltd. 2022-IV reset transaction.

   Entity/Debt         Rating               Prior
   -----------         ------               -----
Barings CLO
Ltd. 2022-IV

   A 06763HAA4     LT PIFsf  Paid In Full   AAAsf
   X               LT AAAsf  New Rating
   A-1-R           LT AAAsf  New Rating
   A-2-R           LT AAAsf  New Rating
   B 06763HAC0     LT PIFsf  Paid In Full   AAsf
   B-R             LT AAsf   New Rating
   C 06763HAE6     LT PIFsf  Paid In Full   Asf
   C-R             LT Asf   New Rating
   D 06763HAG1     LT PIFsf  Paid In Full   BBBsf
   D-1-R           LT BBB-sf  New Rating
   D-2-R           LT BBB-sf
   E 06763JAA0     LT PIFsf  Paid In Full   BB-sf
   E-R             LT BB-sf    New Rating

Transaction Summary

Barings CLO Ltd. 2022-IV (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that originally closed in
November 2022 and is managed by Barings LLC. Net proceeds from the
issuance of the refinancing notes and 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 23.66, 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
97.38% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 76.1% versus a
minimum covenant, in accordance with the initial expected matrix
point of 73%.

Portfolio Composition (Positive): The largest three industries may
comprise up to 39% of the portfolio balance in aggregate while the
top five obligors can represent up to 12.5% of the portfolio
balance in aggregate. The level of diversity resulting from the
industry, obligor and geographic concentrations is in line with
other recent CLOs.

Portfolio Management (Neutral): The transaction has a five-year
reinvestment period and reinvestment criteria similar to other
CLOs. Fitch's analysis was based on a stressed portfolio created by
adjusting 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 'AAAsf' for class X, between 'BBB+sf' and 'AA+sf' for
class A-1-R, between 'BBBsf' and 'AA+sf' for class A-2-R, 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-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, 'A-sf' for class D-2-R, and 'BBB+sf' for class
E-R.

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

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

DATA ADEQUACY

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


BARINGS CLO 2024-V: Fitch Assigns BB-(EXP)sf Rating on Cl. E Notes
------------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
Barings CLO Ltd. 2024-V.

   Entity/Debt              Rating          
   -----------              ------           
Barings CLO
Ltd. 2024-V

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

Transaction Summary

Barings CLO Ltd. 2024-V (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that will be managed by
Barings 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 22.09, versus a maximum covenant, in
accordance with the initial expected matrix point of 24.59. 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%
first-lien senior secured loans. The weighted average recovery rate
(WARR) of the indicative portfolio is 76.1% versus a minimum
covenant, in accordance with the initial expected matrix point of
76.1%.

Portfolio Composition (Neutral): The largest three industries may
comprise up to 40.5% 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 5.1-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 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 'AAAsf' for class X, between 'A-sf' and 'AAAsf' for class
A-1, between 'BBB+sf' and 'AA+sf' for class A-2, between 'BB+sf'
and 'AA-sf' for class B, between 'B+sf' and 'A-sf' for class C,
between less than 'B-sf' and 'BB+sf' for class D-1, between less
than 'B-sf' and 'BB+sf' for class D-2, and between less than 'B-sf'
and 'BB-sf' for class E.

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

Upgrade scenarios are not applicable to the class X, 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, 'AA+sf' for class C, 'A+sf' for
class D-1, 'A+sf' for class D-2, and 'BBB+sf' for class E.

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

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

DATA ADEQUACY

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

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

ESG Considerations

Fitch does not provide ESG relevance scores for Barings CLO Ltd.
2024-V.

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.


BATTERY PARK II: Fitch Assigns 'BB-sf' Rating on Class E-R Notes
----------------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to the
Battery Park CLO II Ltd. reset transaction.

   Entity/Debt        Rating           
   -----------        ------            
Battery Park
CLO II Ltd

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

Transaction Summary

Battery Park CLO II Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that will be managed by
Goldman Sachs Asset Management L.P. that originally closed in
October 2022. The secured notes were refinanced in full on Oct. 21,
2024 (the refinancing date). Net proceeds from the issuance of the
secured and subordinated notes will provide financing on a
portfolio of approximately $397 million (excluding defaulted
obligations) 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 24.27, 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
98.87% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 76.33% versus a
minimum covenant, in accordance with the initial expected matrix
point of 73.9%.

Portfolio Composition (Positive): The largest three industries may
comprise up to 39% of the portfolio balance in aggregate while the
top five obligors can represent up to 12.5% of the portfolio
balance in aggregate. The level of diversity resulting from the
industry, obligor and geographic concentrations is in line with
other recent CLOs.

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

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

The 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 '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-R, between less than 'B-sf' and 'BB+sf' for class D-J,
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

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-R, 'Asf' for class D-J, 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, 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 Battery Park CLO II
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.


BBCMS MORTGAGE 2020-C8: DBRS Confirms BB Rating on Class X-H Certs
------------------------------------------------------------------
DBRS, Inc. confirmed all credit ratings on the classes of
Commercial Mortgage Pass-Through Certificates, Series 2020-C8
issued by BBCMS Mortgage Trust 2020-C8 as follows:

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

Morningstar DBRS changed the trends on Classes H, J-RR, and X-H to
Negative from Stable. All other trends are Stable.

The Negative trends reflect Morningstar DBRS' concerns about a
number of loans that are beginning to show signs of distress, most
notably office collateral with high concentrations of scheduled
rollover and locations within soft submarkets. Morningstar DBRS
notes the pool generally has a high concentration of loans backed
by office properties, which represent 36.5% of the pool, followed
by loans secured by self-storage and lodging properties at 14.0%
and 10.9%, respectively. In addition, four loans, representing
approximately 7.4% of the pool, are secured by single-tenant
properties with lease expiries within the next 12 months, including
two office-backed and two industrial-backed loans. While most
office loans in the pool have reported healthy performance metrics
to date, the increased risks as described above resulted in
stressed scenarios to increase the expected losses (ELs) in the
analysis for this review, resulting in a weighted-average (WA) EL
that is nearly 50% higher for those loans than the pool EL as a
whole.

The credit rating confirmations reflect the transaction's overall
stable performance, which remains in line with Morningstar DBRS'
expectations at issuance as evidenced by a strong WA debt service
coverage ratio (DSCR) for the pool of 2.82 times (x). As of the
September 2024 remittance, 47 of the original 48 loans remained in
the pool, representing a collateral reduction of 2.0% since
issuance, and four loans, representing 3.7% of the pool, have been
fully defeased. One loan, 2260 University Drive (Prospectus ID#23,
1.3% of the pool balance), is in special servicing and there are 12
loans, representing 19.4% of the pool, that are on the servicer's
watchlist. Among the watchlisted loans, approximately 25% are being
monitored for performance- or tenancy-related concerns, with the
remaining on the watchlist for nonperformance/life safety
concerns.

The only loan in special servicing, 2260 University Drive, is
secured by a two-story, 25,000-square-foot (sf) office property in
Newport Beach, California. The loan transferred to the special
servicer in February 2024 for several reasons, but most notably for
the unauthorized transfer of ownership without the lender's
consent, constituting an event of default and full-recourse trigger
under the loan documents. The property was formerly 100% occupied
by Golden State Medicare Health Plan, which lost its license to
operate in California in June 2022 and vacated the property shortly
thereafter. Following the unauthorized sale of the property, the
buyer moved its medical business, Excelera DSE, into the property
on a one-year lease that expires in February 2025. According to the
servicer, the property is currently listed for sale again and the
lender is dual-tracking foreclosure while continuing discussions
with the current owner. Given the outstanding defaults and
likelihood that the special servicer will pursue foreclosure as a
resolution strategy, Morningstar DBRS analyzed a liquidation
scenario, taking a 70% haircut to the issuance appraised value of
$16.3 million, resulting in an implied loss of just over $5.0
million, which would be contained to the unrated Class K-RR.

One of the office loans of concern, Abele Business Park (Prospectus
ID#7, 3.7% of the current pool balance), is secured by a flex
property (office and industrial) totaling 301,230 sf. The property,
located in Bridgeville, Pennsylvania, consists of 17 buildings with
approximately 82.0% of the sf configured for office space and 18%
of the sf configured for warehouse space. As of the March 2024 rent
roll, occupancy has declined to 81.0%, compared with the issuance
occupancy of 98.6%. There are additional rollover concerns
including the fifth-largest tenant, Sizewise (3.9% of the net
rentable area, lease expiry in September 2024). The occupancy
declines have significantly reduced revenues, as the servicer
reported a March 2024 DSCR of 1.39x, down from 2.29x in YE2022.
Given already declining occupancy trends and the location within a
secondary market, Morningstar DBRS believes the as-is property
value has significantly declined since issuance. As such, a
stressed loan-to-value ratio was applied based on a cap to the
YE2023 net cash flow, resulting in an EL approaching three times
the pool WA.

At issuance, Morningstar DBRS shadow-rated two loans as investment
grade, One Manhattan West (Prospectus ID#1, 10.2% of the pool) and
MGM Grand & Mandalay Bay (Prospectus ID#3, 10.1% of the pool). With
this review, Morningstar DBRS confirms the performance for both
loans remains in line with the investment-grade shadow ratings.

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


BENCHMARK 2019-B15: DBRS Cuts Rating on G-RR Certs to B(low)
------------------------------------------------------------
DBRS, Inc. downgraded its credit ratings on two classes of
Commercial Mortgage Pass-Through Certificates, Series 2019-B15
issued by Benchmark 2019-B15 Mortgage Trust as follows:

-- Class F to B (high) (sf) from BB (low) (sf)
-- Class G-RR to B (low) (sf) from B (high) (sf)

In addition, Morningstar DBRS confirmed its credit ratings on the
remaining classes as follows:

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

Morningstar DBRS changed the trends on Classes C, D, E, F, G-RR,
X-D, and X-F to Negative from Stable. All other trends are Stable.

The downgrades reflect the moderate increase in expected losses
(ELs) to the trust driven by specially serviced loan Hilton
Cincinnati Netherland Plaza (Prospectus ID#18; 2.2% of the pool).
The loan is secured by a 561-key full-service hotel in Cincinnati
that transferred to special servicing in February 2021. Since the
last credit rating action, a new appraisal was obtained, valuing
the property at $57.1 million, a value reduction of more than 30%
from its previous appraisal in January 2023. Morningstar DBRS
analyzed this loan with a liquidation scenario, resulting in
implied losses of approximately $7.1 million, which would partially
erode the non-rated Class J-RR Certificate.

The Negative trends reflect increased risks outside of the
specially serviced loan, primarily driven by two large loans,
Innovation park (Prospectus ID#2; 8.1% of the pool) and Downtown
Winter Haven Portfolio (Prospectus ID#8; 4.7% of the pool). Both
loans are secured by suburban office collateral that have
illustrated cash flow contraction since issuance and have major
tenants vacating during the loan term, which could lead to large
reductions in property value when compared to issuance. The pool's
concentration of loans backed by office properties is considered
high at nearly 40.0% of the pool balance, most of which are located
in noncore suburban markets. In the analysis for this review,
Morningstar DBRS increased the probability of default (POD)
penalties and/or stressed loan-to-value ratios (LTV) for each of
the office loans to increase the expected losses as applicable.

Morningstar DBRS also maintains a cautious outlook for large loans
Tysons Tower (Prospectus ID#9; 4.2% of the pool) and 600 & 620
National Avenue (Prospectus ID#13; 3.5% of the pool). The Tysons
Tower loan is secured by a 528,730-sf suburban office property in
McLean, Virginia, approximately 12 miles west of Washington, D.C.
As of the March 2024 rent roll, the property was 78.9% occupied,
down from 85% as of YE2023 and 92.4% as of YE2022, with leases
representing another 5.0% of the net rentable area (NRA) scheduled
to expire in the next 12 months. Largest tenants at the subject
include Intelsat (36.2% of NRA, lease expiry in December 2030) and
Deloitte (17.8% of the NRA, lease expiry in August 2027). The
Tysons Corner submarket is experiencing high vacancy, at 24.4%
according to Reis as of Q2 2024, up from 21.3% as of Q2 2023.
Morningstar DBRS expects the 2024 financial reporting will reflect
a decline in cash flow given the occupancy loss, though the DSCR
remains strong as of the March 2024 reporting.

600 & 620 National Avenue is secured by a Class A office property
in Mountain View, California, approximately 12 miles north of San
Jose. The property is currently vacant but fully leased to
single-tenant Google through May 2029 and is structured with three
five-year renewal options. In 2023, various news outlets revealed
that Google is no longer in occupancy and that the company was
looking to offload more than 1.4 million sf of office space in
Silicon Valley, including the subject location. Google's lease does
not contain a termination option, suggesting that loan performance
should remain steady through lease expiration despite the dark
space. According to Reis, the Santa Clara/Sunnyvale submarket
reported a Q2 2024 vacancy rate of 19.4%, which is expected to
remain flat through loan maturity. However, there is significant
tail-end risk given the lease expiration is commensurate with the
loan's maturity. Morningstar DBRS analyzed both of these loans with
a stressed LTV, which resulted in an average EL that was in line
with the pool average.

The credit rating confirmations reflect the otherwise overall
stable performance of the transaction, as illustrated by the
weighted average debt service coverage ratio (WA DSCR) of 2.45
times (x) based on the most recent year-end financials. As of the
September 2024 remittance, all of the original 32 loans remain in
the trust, with minimal collateral reduction since issuance. There
are nine loans, representing 37.5% of the pool, on the servicer's
watchlist; however, only two of these, representing 10.1% of the
pool, are being monitored for unresolved recent or upcoming tenant
rollover risk and/or a low DSCR. There are two specially serviced
loans representing 5.4% of the pool balance, one of which, 2.2% of
the pool, is delinquent and the other, which transferred for
payment default but is current and reporting a DSCR of 2.46x as of
YE2023, is expected to return to the master servicer in the coming
months.

Morningstar DBRS shadow-rated the Century Plaza Towers loan
(Prospectus ID#3; 7.5% of the pool), The Essex (Prospectus ID#14;
3.0% of the pool) and Osborn Triangle (Prospectus ID#16; 2.4% of
the pool) loans as investment-grade. As performance metrics for
each of the three loans remain in line with expectations,
Morningstar DBRS maintained the shadow rating on all three loans
with this review.

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


BENEFIT STREET IX: Fitch Assigns 'BB+sf' Rating on Class E-R2 Notes
-------------------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to Benefit
Street Partners CLO IX, Ltd. Reset Transaction

   Entity/Debt              Rating           
   -----------              ------           
Benefit Street
Partners CLO IX, Ltd.

   A-1-R2               LT NRsf   New Rating
   A-2-R2               LT AAAsf  New Rating
   B-R2                 LT AA+sf  New Rating
   C-R2                 LT A+sf   New Rating
   D-1-R2               LT BBB+sf New Rating
   D-2-R2               LT BBB-sf New Rating
   E-R2                 LT BB+sf  New Rating
   F-R2                 LT NRsf   New Rating
   Subordinated Notes   LT NRsf   New Rating

Transaction Summary

Benefit Street Partners CLO IX, Ltd. (the issuer) is an arbitrage
cash flow collateralized loan obligation (CLO) managed by Benefit
Street Partners L.L.C., that originally closed in July 2016. On
Oct, 21, 2024 (the second refinancing date), the existing notes
will be refinanced in whole. Net proceeds from the issuance of the
secured and existing 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', 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%
first-lien senior secured loans and has a weighted average recovery
assumption of 75.68%. Fitch stressed the indicative portfolio by
assuming a higher portfolio concentration of assets with lower
recovery prospects and further reduced recovery assumptions for
higher rating stresses.

Portfolio Composition (Positive): The largest three industries may
comprise up to 39% of the portfolio balance in aggregate while the
top five obligors can represent up to 12.5% of the portfolio
balance in aggregate. The level of diversity required by industry,
obligor and geographic concentrations is in line with other recent
CLOs.

Portfolio Management (Neutral): The transaction has a 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-2-R2, between
'BB+sf' and 'AA-sf' for class B-R2, between 'B+sf' and 'BBB+sf' for
class C-R2, between less than 'B-sf' and 'BBB-sf' for class D-1-R2,
between less than 'B-sf' and 'BB+sf' for class D-2-R2, and between
less than 'B-sf' and 'BB-sf' for class E-R2.

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

Upgrade scenarios are not applicable to the class A-2-R2 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-R2, 'AA+sf' for class C-R2,
'A+sf' for class D-1-R2, 'A+sf' for class D-2-R2, and 'BBB+sf' for
class E-R2.

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

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

DATA ADEQUACY

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

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

ESG Considerations

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


BENEFIT STREET IX: Moody's Assigns B3 Rating to $250,000 F-R2 Notes
-------------------------------------------------------------------
Moody's Ratings has assigned ratings to two classes of refinancing
notes (the Refinancing Notes) issued by Benefit Street Partners CLO
IX, Ltd. (the Issuer):

US$320,000,000 Class A-1-R2 Senior Secured Floating Rate Notes Due
2037, Assigned Aaa (sf)

US$250,000 Class F-R2 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  and bonds.

Benefit Street Partners, L.L.C. (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, the other six
classes of secured notes, a variety of other changes to transaction
features will occur in connection with the refinancing. These
include: reinstatement and 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  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: $500,000,000

Diversity Score: 75

Weighted Average Rating Factor (WARF): 3278

Weighted Average Spread (WAS): 3.40%

Weighted Average Coupon (WAC): 6.5%

Weighted Average Recovery Rate (WARR): 47.00%

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 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.


BLUE STREAM 2024-1: Fitch Assigns 'BB-(EXP)sf' Rating on Cl. C Note
-------------------------------------------------------------------
Fitch Ratings expects to rate Blue Stream Issuer, LLC, Secured
Fiber Network Revenue Notes, Series 2024-1 and assign Rating
Outlooks as follows:

- $201,600,000 series 2024-1, class A-2, 'Asf'; Outlook Stable;

- $21,100,000 series 2024-1, class B, 'BBB-sf'; Outlook Stable;

- $39,300,000 series 2024-1, class C, 'BB-sf'; Outlook Stable.

The note balances include $94.7 million of prefunding, which is
allocated between classes A, B and C.

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

- $13,800,000(a) series 2024-1, class R.

(a) Horizontal credit risk retention interest representing 5% of
the 2024-1 notes.

The ratings on all existing notes are expected to be affirmed
concurrently with the transaction close and the assignment of final
ratings.

Transaction Summary

The transaction is a securitization of the contract payments
derived from existing Fiber to the Home (FTTH) networks. Debt is
secured by the cash flow from operations and benefits from a
perfected security interest in the securitized assets, which
include conduits, cables, network-level equipment, access rights,
customer contracts, transaction accounts and an equity pledge from
the asset entities.

The collateral consists of high-quality fiber networks that support
the provision of internet, cable, telephony and alarm services to a
portfolio of homeowners' associations (HOAs) and condominium
owners' associations (COAs), located exclusively in Florida. These
agreements are governed by long-term contracts with the
associations directly. The transaction also includes right of entry
(ROE) networks and supporting contracts, which represent a small
portion (4.6%) of annualized run-rate revenue (ARRR) of the total
collateral pool.

The ratings reflect a structured finance analysis of the cash flows
from the ownership interest in the pledged fiber optic networks,
not an assessment of the corporate default risk of the ultimate
parent, Blue Stream Communications LLC.

KEY RATING DRIVERS

Net Cash Flow and Leverage: Fitch's net cash flow (NCF) on the pool
is $55.3 million, implying a 17.3% haircut to issuer NCF. The debt
multiple relative to Fitch's NCF on the rated classes is 11.5x
versus the debt/issuer NCF leverage of 9.5x.

Inclusive of the prefunding and the cash flow required to draw on
the maximum variable funding note (VFN) commitment of $70 million,
the Fitch NCF on the pool is $71.9 million, implying a 17.9%
haircut to issuer NCF. The debt multiple relative to Fitch's NCF on
the rated classes is 11.1x compared with the debt/issuer NCF
leverage of 9.1x.

Based on the Fitch NCF and assumed annual revenue growth consistent
with the weighted average (WA) escalator of the fiber networks, and
following the transaction's ARD, the notes would be repaid 21.3
years from closing, excluding the VFN with 3.0% contractual
escalators, and in 15.4 years, including the VFN.

Credit Risk Factors: The major factors impacting Fitch's
determination of cash flow and MPL include the high quality of the
underlying collateral networks, long-term contractual cash flow, a
diverse and creditworthy customer base, the market position of the
sponsor, the capability of the operator, and the strength of the
transaction structure.

Technology-Dependent Credit: Due to the specialized nature of the
collateral and potential for changes in technology to affect
long-term demand for digital infrastructure, the senior classes of
this transaction do not achieve ratings above 'Asf'. The securities
have a rated final payment date 30 years after closing, and the
long-term tenor of the securities increases the risk that an
alternative technology, rendering obsolete the current transmission
of data through fiber optic cables, will be developed. Fiber optic
cable networks are currently the fastest and most reliable means of
transmitting information, and data providers continue to invest in
and utilize this technology.

RATING SENSITIVITIES

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

Declining cash flow as a result of higher expenses, contract churn,
declining contract rates, contract amendments or the development of
an alternative technology for the transmission of data could lead
to downgrades.

Fitch's NCF was 17.7% below the issuer's underwritten cash flow
inclusive of prefunding as of August 2024. A further 10% decline in
Fitch's NCF indicates the following ratings based on Fitch's
determination of Maximum Potential Leverage: class A to 'BBBsf'
from 'Asf', class B to 'BB+sf' from 'BBBsf', and class C to 'B-'
from 'BB-sf'.

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

Increasing cash flow without an increase in corresponding debt from
rate increases, additional contracts, lower expenses, or contract
amendments could lead to upgrades.

A 10% increase in Fitch's NCF indicates the following ratings based
on Fitch's determination of Maximum Potential Leverage: class A to
'Asf' from 'Asf', class B to 'BBB+' from 'BBB-sf', and class C to
'BBsf' from 'BB-sf'.

Upgrades are unlikely for these transactions due to the issuer's
ability to issue additional notes that rank pari passu with or
subordinate to existing notes, without the benefit of additional
collateral. In addition, the transaction is structured with a VFN
and prefunding accounts, which allow for further draws as cash flow
increases, resulting in limited deleveraging in the event of cash
flow growth. Moreover, the transaction is capped in the 'Asf'
category due to the risk of technological obsolescence.

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 of certain
characteristics with respect to the portfolio of fiber assets and
related contracts in the 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.


BLUEMOUNTAIN CLO XXXV: Fitch Assigns 'BB-' Rating on Two Tranches
-----------------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to
BlueMountain CLO XXXV Ltd. reset transaction.

   Entity/Debt         Rating               Prior
   -----------         ------               -----
BlueMountain
CLO XXXV Ltd.

   A-1R            LT NRsf   New Rating
   A-2R            LT AAAsf  New Rating
   B 09631RAC2     LT PIFsf  Paid In Full   AAsf
   B-R             LT AAsf   New Rating
   C 09631RAE8     LT PIFsf  Paid In Full   A+sf
   C-R             LT Asf    New Rating
   D 09631RAG3     LT PIFsf  Paid In Full   BBB-sf
   D-1AR           LT BBB-sf New Rating
   D-1BR           LT BBB-sf New Rating
   D-2AR           LT BBB-sf New Rating
   D-2BR           LT BBB-sf New Rating
   E 09631TAA2     LT PIFsf  Paid In Full   BB+sf
   E-1R            LT BB-sf  New Rating
   E-2R            LT BB-sf  New Rating
   X               LT NRsf   New Rating

Transaction Summary

BlueMountain CLO XXXV Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that will be managed by Sound
Point Capital Management, LP and originally closed in June 2022.
Net proceeds from the issuance of the secured and subordinated
notes will provide financing on a portfolio of approximately $549
million (excluding defaulted obligations) 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 23.15, versus a maximum covenant, in
accordance with the initial expected matrix point of 24.4. 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
94.64% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 75.53% versus a
minimum covenant, in accordance with the initial expected matrix
point of 67.7%.

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 9% 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-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 D1-R,
between less than 'B-sf' and 'BB+sf' for class D2-R, between less
than 'B-sf' and 'B+sf' for class E1-R, and between less than 'B-sf'
and 'B+sf' for class E2-R.

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

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

Variability in key model assumptions, such as increases in recovery
rates and decreases in default rates, could result in an upgrade.
Fitch evaluated the notes' sensitivity to potential changes in such
metrics; the minimum rating results under these sensitivity
scenarios are 'AAAsf' for class B-R, 'AAsf' for class C-R, 'A+sf'
for class D1-R, 'A-sf' for class D2-R, 'BBB+sf' for class E1-R, and
'BBB+sf' for class E2-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, 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 BlueMountain CLO
XXXV 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.


BMO 2024-C10: Fitch Assigns 'B-(EXP)sf' Rating on Class GRR Certs
-----------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
BMO 2024-C10 Mortgage Trust commercial mortgage pass-through
certificates, series 2024-C10 as follows:

- $1,337,000 class A1 'AAAsf'; Outlook Stable;

- $2,221,000 class ASB 'AAAsf'; Outlook Stable;

- $69,700,000 class A3 'AAAsf'; Outlook Stable;

- $200,000,000 class A4 'AAAsf'; Outlook Stable;

- $233,523,000 class A5 'AAAsf'; Outlook Stable;

- $506,781,000 class XA 'AAAsf'; Outlook Stable;

- $66,968,000 class AS 'AAAsf'; Outlook Stable;

- $39,818,000 class B 'AA-sf'; Outlook Stable;

- $28,959,000 class C 'A-sf'; Outlook Stable;

- $135,745,000 class XB 'A-sf'; Outlook Stable;

- $7,457,000 class D 'BBBsf'; Outlook Stable;

- $7,457,000 class XD 'BBBsf'; Outlook Stable;

- $16,072,000 class ERR 'BBB-sf'; Outlook Stable;

- $15,385,000 class FRR 'BB-sf'; Outlook Stable;

- $10,859,000 class GRR 'B-sf'; Outlook Stable.

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

- $31,674,555 class JRR.

Transaction Summary

The certificates represent the beneficial ownership interest in the
trust, the primary assets of which are 28 loans secured by 65
commercial properties having an aggregate principal balance of
$723,973,556 as of the cut-off date. The loans were contributed to
the trust by Bank of Montreal, 3650 Real Estate Investment Trust 2
LLC, Citi Real Estate Funding Inc., Starwood Mortgage Capital LLC,
Zions Bancorporation, N.A., German American Capital Corporation,
and Goldman Sachs Mortgage Company.

The master servicer is expected to be KeyBank National Association,
and the special servicer is expected to be 3650 REIT Loan Servicing
LLC. The trustee is expected to be Wilmington Savings Fund Society,
FSB and Citibank N.A. as certificate administrator. The
certificates are expected to follow a sequential paydown
structure.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 62.5% of the loans by
balance, cash flow analysis of 95.9% of the pool and asset summary
reviews on 100% of the pool.

KEY RATING DRIVERS

Higher Leverage Compared to Recent Transactions: The pool has
higher leverage compared to recent U.S. Private Label Multiborrower
transactions rated by Fitch. The pool's Fitch loan to value ratio
(LTV) of 92.8% is higher than the 2024 YTD and 2023 averages of
91.1% and 88.3%, respectively. The pool's Fitch NCF debt yield (DY)
of 10.6% is lower than the 2024 YTD and 2023 averages of 11.0% and
10.9%, respectively.

Investment-Grade Credit Opinion Loans: Two loans representing 10.6%
of the pool received an investment-grade credit opinion. Newport
Centre (8.3% of the pool) received a standalone credit opinion of
'BBBsf*' and Arizona Grand Resort and Spa (2.3% of the pool)
received a standalone credit opinion of 'A-sf*'. The pool's total
credit opinion percentage is lower than the 2024 YTD and 2023
averages of 15.2% and 17.8%, respectively. Excluding credit opinion
loans, the pool's Fitch LTV and DY is 96.5% and 10.2%,
respectively, are in line with the equivalent conduit 2023 LTV and
DY averages of 93.3% and 10.4%, respectively.

Average Pool Concentration: The pool has an average concentration
compared to recently rated Fitch transactions. The top 10 loans in
the pool make up 60.3% of the pool, which is in line with the 2024
YTD and 2023 averages of 60.3% and 63.7%, respectively. The pool's
effective loan count of 21.3 is in line with the 2024 YTD and 2023
average of 22.4 and 20.6, respectively.

Limited Amortization: Based on the scheduled balances at maturity,
the pool will pay down 0.6%, which is below the 2024 YTD and 2023
averages of 1.0% and 1.4%, respectively. Only four loans (5.1% of
the pool) have amortization during the loan term, with the
remaining 24 loans (94.9% of the pool) paying interest only, which
is above the 2024 YTD average of 88.0% and higher than the 2023
average 84.5%.

Lower Concentration of Pari Passu Loans: Ten loans representing
43.2% of the pool are pari passu loans, which is lower than the
2024 YTD average of 45.7% and the 2023 average of 60.1%.

Higher Single-Tenant Occupancy: The pool has more single-tenant
occupied properties compared to recently rated Fitch transactions.
Forty-four properties representing 28.4% of the pool by balance are
single-tenant occupied properties, which is higher than the 2024
YTD average of 9.4% and the 2023 average of 17.8%. Furthermore,
four loans representing 17.8% of the pool were acquired by sponsors
in sale-leaseback transactions.

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'/'B-sf';

- 10% NCF Decline:
'AA-sf'/'A-sf'/'BBB-sf'/'BBB-sf'/'BBsf'/'B-sf'/less than 'CCCsf'.

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

Improvement in cash flow increases property value and capacity to
meet its debt service obligations. The 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'/'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 re-computation of certain
characteristics with respect to each mortgage loan. Fitch
considered this information in its analysis and it did not have an
effect on 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.


BREAN ASSET 2024-RM9: DBRS Finalizes B Rating on Class M5 Notes
---------------------------------------------------------------
DBRS, Inc. finalized its provisional credit ratings on the
Mortgage-Backed Notes, Series 2024-RM9 (the Notes) issued by Brean
Asset-Backed Securities Trust 2024-RM9 as follows:

-- $154.0 million Class A1 at AAA (sf)
-- $25.9 million Class A2 at AAA (sf)
-- $179.9 million Class AM at AAA (sf)
-- $1.9 million Class M1 at AA (sf)
-- $1.9 million Class M2 at A (sf)
-- $5.3 million Class M3 at BBB (sf)
-- $5.1 million Class M4 at BB (sf)
-- $2.3 million Class M5 at B (sf)

Class AM is an exchangeable note. This class can be exchanged for
combinations of exchange notes as specified in the offering
documents.

The AAA (sf) credit rating reflects 111.5% of cumulative advance
rate. The AA (sf), A (sf), BBB (sf), BB (sf), and B (sf) ratings
reflect 112.7%, 113.9%, 117.1%, 120.3%, and 121.7% of cumulative
advance rates, respectively.

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

Lenders typically offer reverse mortgage loans to people who are at
least 62 years old. Through reverse mortgage loans, borrowers have
access to home equity through a lump sum amount or a stream of
payments without periodically repaying principal or interest,
allowing the loan balance to accumulate over a period of time until
a maturity event occurs. Loan repayment is required (1) if the
borrower dies, (2) if the borrower sells the related residence, (3)
if the borrower no longer occupies the related residence for a
period (usually a year), (4) if it is no longer the borrower's
primary residence, (5) if a tax or insurance default occurs, or (6)
if the borrower fails to properly maintain the related residence.
In addition, borrowers must be current on any homeowner's
association dues, if applicable. Reverse mortgages are typically
nonrecourse; borrowers don't have to provide additional assets in
cases where the outstanding loan amount exceeds the property's
value (the crossover point). As a result, liquidation proceeds will
fall below the loan amount in cases where the outstanding balance
reaches the crossover point, contributing to higher loss severities
for these loans.

As of the September 1, 2024, cut-off date, the collateral has
approximately $161.3 million in current unpaid principal balance
from 487 performing fixed-rate jumbo reverse mortgage loans secured
by first liens on single-family residential properties,
condominiums, townhomes, multifamily (two- to four-family)
properties, cooperatives, and manufactured homes. All loans in this
pool were originated in 2024, with ages ranging from one month to
four months. All loans in this pool have a fixed interest rate with
a 9.654% weighted-average coupon.

The transaction uses a structure in which cash distributions are
made sequentially to each rated note until the rated amounts with
respect to such notes are paid off. No subordinate note shall
receive any payments until the balance of senior notes has been
reduced to zero.

The note rate for the Class A1 and A2 Notes (collectively, the
Class A Notes) will reduce to 0.25% if the Home Price Percentage
(as measured using Standard and Poor's CoreLogic Case-Shiller
National Index) declines by 30% or more compared with the value on
the cut-off date.

If the notes are not paid in full or redeemed by the issuer on the
Expected Repayment Date in September 2029, the Issuer will be
required to conduct an auction within 180 calendar days of the
Expected Repayment Date to offer all the mortgage assets and use
the proceeds, net of fees and expenses from auction, to be applied
to payments to all amounts owed. If the proceeds of the auction are
not sufficient to cover all the amounts owed, the Issuer will be
required to conduct an auction within six months of the previous
auction.

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

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


BRIDGE STREET III: Fitch Assigns 'BB-sf' Rating on Class E-R Notes
------------------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to the
Bridge Street CLO III Ltd. reset transaction.

   Entity/Debt       Rating               Prior
   -----------       ------               -----
Bridge Street
CLO III Ltd.

   A-1-R         LT NRsf   New Rating
   A-1-R Loans   LT NRsf   New Rating
   A-2-R         LT AAAsf  New Rating
   B 10806YAE0   LT PIFsf  Paid In Full   AAsf
   B-R           LT AAsf   New Rating
   C-R           LT Asf    New Rating
   D 10806YAJ9   LT PIFsf  Paid In Full   BBBsf
   D-1A-R        LT BBB-sf New Rating
   D-1B-R        LT BBB-sf New Rating
   D-2-R         LT BBB-sf New Rating
   E 10806GAA7   LT PIFsf  Paid In Full   BB-sf
   E-R           LT BB-sf  New Rating

Transaction Summary

Bridge Street CLO III Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that will be managed by FS
Structured Products Advisor, LLC that originally closed in December
2022. Net proceeds from the issuance of the secured and
subordinated notes will provide financing on a portfolio of
approximately $350 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 23.88, versus a maximum covenant, in accordance with
the initial expected matrix point of 26. Issuers rated in the 'B'
rating category denote a highly speculative credit quality;
however, the notes benefit from appropriate credit enhancement and
standard U.S. CLO structural features.

Asset Security (Positive): The indicative portfolio consists of
95.59% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 75.77% versus a
minimum covenant, in accordance with the initial expected matrix
point of 73.7%.

Portfolio Composition (Positive): The largest three industries may
comprise up to 39% of the portfolio balance in aggregate while the
top five obligors can represent up to 12.5% of the portfolio
balance in aggregate. The level of diversity resulting from the
industry, obligor and geographic concentrations is in line with
other recent CLOs.

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

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

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

RATING SENSITIVITIES

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

Variability in key model assumptions, such as decreases in recovery
rates and increases in default rates, could result in a downgrade.
Fitch evaluated the notes' sensitivity to potential changes in such
a metric. The results under these sensitivity scenarios are as
severe as between 'BBB-sf' and 'AA+sf' for class A-2-R, between
'BB+sf' and '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-1A-R
and D-1B-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 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-1A-R and D-1B-R, 'A+sf' for class D-2-R, and 'BBB+sf'
for class E-R.

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

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

DATA ADEQUACY

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

Overall, 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 Bridge Street CLO
III 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.


BRIDGECREST LENDING 2024-4: DBRS Gives Prov. BB(high) on E Notes
----------------------------------------------------------------
DBRS, Inc. assigned provisional credit ratings to the following
classes of notes to be issued by Bridgecrest Lending Auto
Securitization Trust 2024-4 (BLAST 2024-4 or the Issuer):

-- $70,500,000 Class A-1 Notes at (P) R-1 (high) (sf)
-- $137,520,000 Class A-2 Notes at (P) AAA (sf)
-- $91,680,000 Class A-3 Notes at (P) AAA (sf)
-- $56,700,000 Class B Notes at (P) AA (sf)
-- $93,480,000 Class C Notes at (P) A (sf)
-- $89,100,000 Class D Notes at (P) BBB (sf)
-- $41,520,000 Class E Notes at (P) BB (high) (sf)

CREDIT RATING RATIONALE/DESCRIPTION

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

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

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

-- The ability of the transaction to withstand stressed cash flow
assumptions and repay investors according to the terms in which
they have invested. For this transaction, the ratings address the
payment of timely interest on a monthly basis and principal by the
legal final maturity date for each respective class.

(2) BLAST 2024-4 provides for the Notes' coverage multiples that
are slightly below the Morningstar DBRS range of multiples set
forth in the criteria for this asset class. Morningstar DBRS
believes that this is warranted, given the magnitude of expected
loss, company history, and structural features of the transaction.

(3) The Morningstar DBRS CNL assumption is 26.60% based on the
expected pool composition for both the base and the upsize pools.

-- The structure may upsize during premarketing, subject to market
conditions, among other considerations, up to a total issuance of
$688 million. If the Upsize Transaction is issued, the following
notes will be issued: $81,600,000 for the Class A-1 notes,
$164,160,000 for the Class A-2 notes, $109,440,000 for the Class
A-3 notes, $67,200,000 for the Class B notes, $110,800,000 for the
Class C notes, $105,600,000 for the Class D notes, and $49,200,000
for the Class E notes.

(4) The transaction assumptions consider Morningstar DBRS' baseline
macroeconomic scenarios for rated sovereign economies, available in
its commentary Baseline Macroeconomic Scenarios for Rated
Sovereigns September 2024 Update, published on September 25, 2024.
These baseline macroeconomic scenarios replace Morningstar DBRS'
moderate and adverse COVID-19 pandemic scenarios, which were first
published in April 2020.

(5) The transaction parties' capabilities with regard to
originations, underwriting, and servicing are as follows:

-- DriveTime has an experienced and stable management team and has
had relatively stable performance in varying economic environments
because of its expertise in the subprime auto market.

-- Morningstar DBRS has performed an operational review of
DriveTime and Bridgecrest and considers the entities acceptable
originators and servicers of subprime auto loans.

-- Morningstar DBRS did not perform an operational review of GoFi
given its relatively small contribution to the pool.

-- DriveTime has made substantial investments in technology and
infrastructure to continue to improve its ability to predict
borrower behavior, manage risk, and mitigate loss.

-- DriveTime has centrally developed and maintained underwriting
and loan servicing platforms. Underwriting is performed in the
DriveTime dealerships by specially trained DriveTime employees.

-- Computershare, an experienced auto-loan servicer, is the
standby servicer for the portfolio in this transaction.

(6) The quality and consistency of historical static pool data for
DriveTime originations and performance of the DriveTime auto loan
portfolio.

(7) The legal structure and presence of legal opinions that are
expected to address the true sale of the assets to the Issuer, the
nonconsolidation of the special-purpose vehicle with DriveTime,
that the trust has a valid first-priority security interest in the
assets, and the consistency with the Morningstar DBRS Legal
Criteria for U.S. Structured Finance.

The transaction represents a securitization of a portfolio of motor
vehicle installment sales contracts originated by DriveTime Car
Sales Company, LLC and GoFi, LLC. DriveTime Car Sales Company, LLC
is a wholly owned subsidiary of DriveTime, a leading used-vehicle
retailer in the United States that focuses primarily on the sale
and financing of vehicles to the subprime market. GoFi is an
AI-enabled, digital-first lending platform primarily focused on
franchise dealers.

The rating on the Class A Notes reflects 57.10% of initial hard
credit enhancement provided by the subordinated notes in the pool
(41.60%), the reserve account (1.50%), and OC (14.00%). The ratings
on the Class B, C, D, and E Notes reflect 48.70%, 34.85%, 21.65%,
and 15.50% of initial hard credit enhancement, respectively.
Additional credit support may be provided from excess spread
available in the structure.

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


BRIDGECREST LENDING 2024-4: S&P Assigns BB (sf) Rating on E Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its ratings to Bridgecrest Lending Auto
Securitization Trust 2024-4's automobile receivables-backed notes.

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

The ratings reflect S&P's view of:

-- The availability of approximately 62.46%, 57.72%, 47.75%,
38.67%, and 34.19% credit support (hard credit enhancement and a
haircut to excess spread) for the class A (collectively, A-1, A-2,
and A-3), B, C, D, and E notes, respectively, based on stressed
post pricing breakeven cash flow scenarios. These credit support
levels provide at least 2.37x, 2.12x, 1.72x, 1.38x, and 1.25x
coverage of S&P's expected cumulative net loss of 25.50% for the
class A, B, C, D, and E notes, respectively.

-- The expectation that under a moderate ('BBB') stress scenario
(1.38x S&P's expected loss level), all else being equal, its 'A-1+
(sf)', 'AAA (sf)', 'AA (sf)', 'A (sf)', 'BBB (sf)', and 'BB (sf)'
ratings on the class A-1, A-2/A-3, B, C, D, and E notes,
respectively, will be within its credit stability limits.

-- The timely payment of interest and principal by the designated
legal final maturity dates under S&P's stressed cash flow modeling
scenarios that it believes are appropriate for the assigned
ratings.

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

-- The series' bank accounts at Wells Fargo Bank N.A.
(A+/Stable/A-1), which do not constrain the ratings.

-- S&P's operational risk assessment of Bridgecrest Acceptance
Corp. as servicer, along with its view of the originator's
underwriting and the backup servicing arrangement with
Computershare Trust Co. N.A. (BBB/Stable/--).

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

-- The transaction's payment and legal structures.

  Ratings Assigned

  Bridgecrest Lending Auto Securitization Trust 2024-4

  Class A-1, $81.60 million: A-1+ (sf)
  Class A-2, $164.16 million: AAA (sf)
  Class A-3, $109.44 million: AAA (sf)
  Class B, $67.20 million: AA (sf)
  Class C, $110.80 million: A (sf)
  Class D, $105.60 million: BBB (sf)
  Class E, $49.20 million BB (sf)



BRIGHTWOOD 2019-1: S&P Assigns Prelim BB-(sf) Rating on E-R Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the class
A-1R, A-2R, B-R, C-R, and D-R replacement debt and proposed new
class E-R debt from Brightwood Capital MM CLO 2019-1
Ltd./Brightwood Capital MM CLO 2019-1 LLC, a CLO originally issued
in December 2019 that is managed by Brightwood SPV Advisors, LLC,
an affiliate of Brightwood Capital Advisors LLC.

The preliminary ratings are based on information as of Oct. 18,
2024. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the Oct. 23, 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 stated maturity will be extended to October 2034.

-- A new reinvestment period will be established, which will end
in October 2026.

-- A new non-call period will be established, which will end in
October 2025.

-- A proposed new class E-R floating-rate debt will be added to
the capital structure.

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

  Brightwood Capital MM CLO 2019-1 Ltd./
  Brightwood Capital MM CLO 2019-1 LLC

  Class A-1R, $180.00 million: AAA (sf)
  Class A-2R, $12.00 million: AAA (sf)
  Class B-R, $12.00 million: AA (sf)
  Class C-R (deferrable), $24.00 million: A (sf)
  Class D-R (deferrable), $18.00 million: BBB- (sf)
  Class E-R (deferrable), $18.00 million: BB- (sf)

  Other Debt

  Brightwood Capital MM CLO 2019-1 Ltd./
  Brightwood Capital MM CLO 2019-1 LLC

  Subordinated notes, $65.00 million: Not rated



BRIGHTWOOD CAPITAL 2019-1: S&P Assigns BB-(sf) Rating on E-R Notes
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-1R, A-2R,
B-R, C-R, and D-R replacement debt and new class E-R debt from
Brightwood Capital MM CLO 2019-1 Ltd./Brightwood Capital MM CLO
2019-1 LLC, a CLO originally issued in December 2019 that is
managed by Brightwood SPV Advisors, LLC, an affiliate of Brightwood
Capital Advisors LLC. At the same time, S&P withdrew its ratings on
the class A-1-L, A-1-N, A-2, B-1, B-2, C, D-1, and D-2 debt
following payment in full on the Oct. 23, 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 stated maturity was extended to October 2034.

-- A new reinvestment period was established, which will end in
October 2026.

-- A new non-call period was established, which will end in
October 2025.

-- A new class E-R floating-rate debt was added to the capital
structure.

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

  Brightwood Capital MM CLO 2019-1 Ltd./
  Brightwood Capital MM CLO 2019-1 LLC

  Class A-1R, $180.00 million: AAA (sf)
  Class A-2R, $12.00 million: AAA (sf)
  Class B-R, $12.00 million: AA (sf)
  Class C-R (deferrable), $24.00 million: A (sf)
  Class D-R (deferrable), $18.00 million: BBB- (sf)
  Class E-R (deferrable), $18.00 million: BB- (sf)

  Ratings Withdrawn

  Brightwood Capital MM CLO 2019-1 Ltd./
  Brightwood Capital MM CLO 2019-1 LLC

  Class A-1-L to not rated from 'AAA (sf)'
  Class A-1-N to not rated from 'AAA (sf)'
  Class A-2 to not rated from 'AAA (sf)'
  Class B-1 to not rated from 'AA (sf)'
  Class B-2 to not rated from 'AA (sf)'
  Class C to not rated from 'A (sf)'
  Class D-1 to not rated from 'BBB+ (sf)'
  Class D-2 to not rated from 'BBB (sf)'

  Other Debt

  Brightwood Capital MM CLO 2019-1 Ltd./
  Brightwood Capital MM CLO 2019-1 LLC

  Subordinated notes, $65.00 million: Not rated



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

Cl. A, Definitive Rating Assigned Aaa (sf)

Cl. B, Definitive Rating Assigned Aa2 (sf)

Cl. C, Definitive Rating Assigned A2 (sf)

Cl. D, Definitive Rating Assigned Baa3 (sf)

Cl. E, Definitive Rating Assigned Ba1 (sf)

Cl. HRR, Definitive Rating Assigned Ba2 (sf)

The ratings assigned to Class B and Class C reflect an error
correction.  Previously these two classes were assigned provisional
ratings of (P) Aa3 (sf) and (P) A3 (sf), respectively.  However,
given the credit enhancement provided for these classes, they
should have received provisional ratings that were one notch
higher, consistent with the definitive ratings stated above.
Separately, Moody's previously assigned provisional ratings of
(P)Baa2 (sf) to Class X-CP and Class X-NCP as described in the
prior press release. Subsequent to the release of the provisional
ratings, the overall structure of the transaction was modified, and
Class X-CP and Class X-NCP are no longer being offered. Based on
the current structure, Moody's have withdrawn the provisional
ratings for Class X-CP and Class X-NCP.

RATINGS RATIONALE

The certificates are collateralized by a single loan backed by
first lien mortgages on the borrowers' fee simple interests in a
portfolio of four properties encompassing approximately 2,100,672
SF located in Burbank, CA. Moody's ratings are based on the credit
quality of the loan and the strength of the securitization
structure.

The portfolio consist of four office properties spread across eight
distinct office buildings in the heart of the Media District in
Burbank, CA.

-- Media Studios (36.5% of ALA) is a collection of five class A
office buildings within its own award winning 19-acre media and
entertainment campus.

-- 3800 Alameda (30.2% of ALA) is a 20-story class A office
building totaling 428,992 SF and 100% leased to the Walt Disney
Company and two retailers as of September 1, 2024.

-- The Pointe (29.4% of ALA) is a LEED Gold trophy office tower
situated on an expansive 4.9-acre campus within walking distance to
The Burbank Studios and Walt Disney Studios production lots.

-- Central Park (4.0% of ALA) is a 20-story class A office
building totaling 259,864 SF located adjacent to Warner Bros
Studios and the Burbank Studios.

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

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

The Moody's first mortgage actual DSCR is 1.00x and Moody's first
mortgage actual stressed DSCR is 0.96x. Moody's DSCR is based on
Moody's stabilized net cash flow.

The loan first mortgage balance of $600,000,000 represents a
Moody's LTV ratio of 106.5% based on Moody's Value. Adjusted
Moody's LTV ratio for the first mortgage balance is 97.4% based on
Moody's Value using a cap rate adjusted for the current interest
rate environment.

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

Notable strengths of the transaction include: location, asset
quality, committed investment-grade tenants, and institutional
quality sponsorship and equity commitment.

Notable concerns of the transaction include: market vacancy,
declining occupancy, rollover profile, floating-rate interest-only
profile, and credit negative legal features.

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

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

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

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

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


CARLYLE US 2024-7: Fitch Assigns 'BB-(EXP)sf' Rating on Cl. E Notes
-------------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
Carlyle US CLO 2024-7, Ltd.

   Entity/Debt          Rating           
   -----------          ------           
Carlyle US
CLO 2024-7, Ltd.

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

Transaction Summary

Carlyle US CLO 2024-7, Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that will be managed by
Carlyle CLO Management L.L.C. 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 24.4 versus a maximum covenant, in accordance with the
initial expected matrix point of 26.44. 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
97.62% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 73.12% versus a
minimum covenant, in accordance with the initial expected matrix
point of 71.1%.

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 5.1-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-1, between
'BBB+sf' and 'AA+sf' for class A-2, between 'BB+sf' and 'A+sf' for
class B, between 'B+sf' and 'BBB+sf' for class C, between less than
'B-sf' and 'BB+sf' for class D-1, between less than 'B-sf' and
'BB+sf' for class D-2, and between less than 'B-sf' and '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, 'AA+sf' for class C, 'Asf' for
class D-1, 'A-sf' for class D-2, and 'BBB+sf' for class E.

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

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

DATA ADEQUACY

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

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

ESG Considerations

Fitch does not provide ESG relevance scores for Carlyle US CLO
2024-7, 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.


CARVAL CLO VIII-C: S&P Assigns BB- (sf) Rating on Cl. E-2R Debt
---------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-1R, A-2R,
B-R, C-R, D-1R, D-2R, E-1R, and E-2R replacement debt from CarVal
CLO VIII-C Ltd./CarVal CLO VIII-C LLC, a CLO originally issued in
October 2022 that is managed by CarVal CLO Management LLC. At the
same time, S&P withdrew its ratings on the original class A, B-1,
B-2, C, D, and E debt following payment in full.

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-1R, A-2R, B-R, C-R, D-1R, E-1R, and
E-2R debt was issued at a lower spread over the three-month CME
term SOFR than the original debt.

-- The replacement class D-2R debt was issued at a higher coupon
than the original debt.

-- The stated maturity and non-call period were extended two
years, and the reinvestment period was 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 debt remain consistent with the credit enhancement
available to support them and take rating actions as we deem
necessary."


  Ratings Assigned

  CarVal CLO VIII-C Ltd./CarVal CLO VIII-C LLC

  Class A-1R, $240.00 million: AAA (sf)
  Class A-2R, $8.00 million: AAA (sf)
  Class B-R, $56.00 million: AA (sf)
  Class C-R (deferrable), $24.00 million: A (sf)
  Class D-1R (deferrable), $20.00 million: BBB (sf)
  Class D-2R (deferrable), $7.00 million: BBB- (sf)
  Class E-1R (deferrable), $6.00 million: BB- (sf)
  Class E-2R (deferrable), $7.00 million: BB- (sf)

  Ratings Withdrawn

  CarVal CLO VIII-C Ltd./CarVal CLO VIII-C LLC

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

  Other Debt

  CarVal CLO VIII-C Ltd./CarVal CLO VIII-C LLC

  Subordinated notes, $41.60 million: NR

  NR--Not rated.



CASTLELAKE AIRCRAFT 2019-1: Fitch Affirms 'CCC' Rating on C Debt
----------------------------------------------------------------
Fitch Ratings has affirmed the ratings on the following Castlelake
Aircraft ABS transactions:

- Castlelake Aircraft Structured Trust 2018-1 (CLAS 2018-1);

- Castlelake Aircraft Structured Trust 2019-1 (CLAS 2019-1).

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

   Entity/Debt            Rating           Prior
   -----------            ------           -----
Castlelake Aircraft
Structured Trust
2019-1

   A 14855MAA6        LT BBBsf  Affirmed   BBBsf
   B 14855MAB4        LT BBsf   Affirmed   BBsf
   C 14855MAC2        LT CCCsf  Affirmed   CCCsf

Castlelake Aircraft
Structured Trust
2018-1

   A 14856CAA7        LT Asf    Affirmed   Asf
   B 14856CAB5        LT BBBsf  Affirmed   BBBsf
   C 14856CAC3        LT Bsf    Affirmed   Bsf

Transaction Summary

CLAS 2018-1: Collections exceeded Fitch's expectations since the
last review, primarily driven by earlier than anticipated asset
sales, which included the sale of seven aircraft and four engines,
generating approximately $100 million in cash, which has delevered
the class A notes. As of the October servicer report, the class A
notes are 18% ahead of schedule, the class B notes have not
received principal since March 2022, and the class C notes have not
received principal since March 2020 and continue to accrue
interest.

The transaction features two sources of potentially large cash
inflows which could materially delever the transaction: Russian
aircraft insurance proceeds and EOL payments. The servicer
continues to pursue insurance claims on an aircraft seized in
Russia, and eight of the 12 assets (eight aircraft and four
engines) in the remaining pool are on leases that include EOL
provisions. Receipt of insurance proceeds and substantial EOL
payments could materially delever the transaction and potentially
have a positive ratings impact, though quantifying the amount and
timing of the proceeds remains speculative.

CLAS 2019-1: Transaction performance has remained challenged. Rent
collections were slightly below Fitch's expectations, the notes
have fallen further behind schedule, and the loan-to-values (LTVs)
have increased across all classes. The transaction remains in
breach of both the rapid amortization and cash trap triggers,
leading to sequential pay. The class A notes received $44 million
in principal over the past year, but remain 34% behind schedule.
The class B notes are $41 million behind schedule and haven't
received principal payments in three years, while the class C notes
haven't received any payments since March 2020 and continue to
accrue interest.

Similar to CLAS 2018-1, the transaction features two sources of
potentially large cash inflows which could materially delever the
transaction: Russian aircraft insurance proceeds and EOL payments.
The servicer continues to pursue insurance claims on two aircraft
seized in Russia, and 19 of 21 aircraft in the pool are on leases
that include EOL provisions. Quantifying the amount and timing of
the proceeds from the Russian aircraft and the cash inflows from
EOL payments remains speculative.

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

Aircraft Collateral and Asset Values: Aircraft ABS transaction
servicers are reporting strong demand and increased lease rates for
aircraft, particularly those with maintenance green time remaining.
Demand for A320 CEOs and 737-800s, particularly for aircraft in
good maintenance condition, has materially strengthened. Fitch is
also seeing meaningful improvement in sale proceeds for aircraft
approaching the end of leasable life. Appraiser market values are
currently higher than base values for many aircraft types, which is
something Fitch hasn't seen for several years.

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

KEY RATING DRIVERS

Asset Values: The aircraft in the Castlelake transactions are
generally mid-aged with a weighted-average age (by value) of
approximately 14 years for both transactions.

Using mean maintenance-adjusted base value in order to make period
to period comparisons and to control for changes in Fitch's
approach to determining the Fitch Value, the LTV for the CLAS
2018-1 A note decreased since Fitch's last review (October 2023).
The LTVs for the subordinated CLAS 2018-1 notes and the CLAS 2019-1
notes increased. The LTVs are as follows:

- CLAS 2018-1: A Note 60% to 48%, B note 83% to 86%, and C note
from 99% to 115%;

- CLAS 2019-1: A Note 72% to 75%, B note 88% to 94%, and C note
from 102% to 112%.

In determining the Fitch value of each pool, Fitch used appraisals
from April 2024 for the 2018-1 transaction and from August 2024 for
the 2019-1 transaction, and adjusted each for depreciation. Fitch
values are generally derived from base values unless the remaining
leasable life is less than three years, in which case a market
value is used.

Fitch then uses the lesser of mean and median of the given value.
The Fitch value for each of the transactions is as follows:

- CLAS 2018-1: $216 million;

- CLAS 2019-1: $469 million.

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

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

- CLAS 2018-1: Age — 13.6 years; Tier — 1.6;

- CLAS 2019-1: Age — 14.0 years; Tier — 1.5;

Pool Concentration: The aircraft count and number of lessees by
transaction are as follows:

- CLAS 2018-1: Eight aircraft and four engines; seven lessees;

- CLAS 2019-1: 21 aircraft; nine lessees.

As pools age and aircraft are assumed to be are sold at the end of
their leasable lives, pool concentrations are assumed to increase.
Fitch stresses cash flows based on the effective aircraft count
given the increased riskiness of the cash flows, particularly
maintenance cash flows for smaller pools. The effective count for
CLAS 2018-1 and CLAS 2019-1 is nine and 15, respectively.

Lessee Credit Risk: Fitch considers the credit risk posed by
incumbent lessees to be moderate to high. Lessee performance has
broadly improved since its prior review. However, Fitch has
generally maintained the lessee credit ratings pending a
demonstrated longer track record of timely payment performance,
particularly for airlines that have recently been restructured.

The lessee credit risk has particular importance in these
transactions, as both include high proportion of lessees who are
EOL payers. Fitch received projected EOL payments for each pool and
applied a haircut based on lessee credit quality and forecast
payment time horizon. The weighted-average lessee credit rating by
transaction is as follows:

- CLAS 2018-1: 'CCCsf';

- CLAS 2019-1: 'Bsf'.

Operation and Servicing Risk: Fitch considers the servicer,
Castlelake, L.P., to be qualified based on its experience as a
lessor, overall servicing capabilities, and historical ABS
performance to date.

RATING SENSITIVITIES

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

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

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

Fitch ran various sensitives depending on the transaction and the
source of cash flow that is particularly impactful and/or
uncertain. For example, Fitch conducted sensitivities in which
residual values were reduced by 20% to simulate underperformance in
sales beyond the haircuts, depreciation, and market value declines
already incorporated into Fitch's model. Fitch also ran
sensitivities regarding insurance proceeds from aircraft seized in
Russia and end of lease maintenance cash flows.

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

If contractual lease rates outperform modeled cash flows or lessee
credit quality improves materially, this could lead to an upgrade.
Similarly, if assets in the pool display higher values and stronger
rent generation than Fitch's stressed scenarios this could also
lead to an upgrade. Fitch also ran sensitivities regarding higher
recovery rates for the insurance proceeds from aircraft seized in
Russia.

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

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.


CD 2017-CD6: DBRS Confirms B Rating on Class G-RR Certs
-------------------------------------------------------
DBRS Limited confirmed its credit ratings on the Commercial
Mortgage Pass-Through Certificates, Series 2017-CD6 issued by CD
2017-CD6 Mortgage Trust as follows:

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

In addition, Morningstar DBRS changed the trends on Classes E-RR,
F-RR, and G-RR to Negative from Stable. The trends on all remaining
Classes are Stable.

The pool includes a high concentration of loans secured by office
properties or mixed-use properties with significant office
components, representing approximately 30.0% of the current
balance. While a select number of those loans continue to perform
as expected, several others, including the largest loan in the
pool, Headquarters Plaza (Prospectus ID#1; 8.2% of the pool), which
is secured by a mixed-use property in Morristown, New Jersey, and
the sole specially serviced loan Cleveland East (Prospectus ID#32;
1.2% of the pool), which is secured by two suburban office
properties in Mayfield Heights and Highland Hills, Ohio, are
exhibiting increased credit risk, as further outlined below. The
Negative trends assigned to the three lowest-rated classes reflect
these loan-specific challenges considering those classes are most
exposed to loss if the performance of the underlying collateral
continues to deteriorate. Where applicable, Morningstar DBRS
increased the probability of default (POD) penalties and/or applied
stressed loan-to-value ratios (LTV) for loans exhibiting increased
credit risk, resulting in expected losses that were between 2.0
times (x) and 3.4x greater than the pool average.

The Cleveland East loan recently transferred to the special
servicer in June 2024 for imminent monetary default after the
borrower requested approval of the first extension option with a
waiver of the required reserve top up provision, as stipulated in
the October 2022 loan modification. According to the April 2024
rent roll, the collateral was 53.2% occupied, down from 92.0% at
issuance. Likewise, net cash flow (NCF) has trended lower with the
YE2023 figure of $1.3 million (a debt service coverage ratio (DSCR)
of 0.6x), nearly 70.0% lower than the issuance figure of $4.3
million (a DSCR of 1.6x). The collateral was most recently
appraised in August 2022 at a value of $45.9 million, 23.5% below
the issuance appraised value of $60.0 million. Morningstar DBRS
analyzed the loan with an elevated POD penalty and stressed LTV
ratio resulting in an expected loss that was more than 2.5x greater
than the pool average.

The Headquarters Plaza loan is secured by a mixed-use property
comprising three office towers totaling 562,242 square feet (sf),
in addition to 167,274 sf of ground-floor retail space, and a
256-key Hyatt Regency hotel. As of December 2023, the office and
retail components of the property were 89.8% occupied. The tenant
mix is relatively granular, with the largest tenant, Riker Danzig
Sherer, occupying 9.1% of the net rentable area (NRA) on a lease
through July 2025. The largest retail tenant, AMC Theatres,
occupies 5.5% of the NRA on a lease that runs through April 2029.
According to the YE2023 financial reporting, the property generated
$9.5 million of NCF (a DSCR of 1.4x), approximately 35.0% lower
than the issuance figure of $14.7 million (a DSCR of 2.2x). The
property was most recently appraised in June 2021 for $172.6
million, a considerable decline from the appraised value at
issuance of $239.0 million. Although the collateral's historical
occupancy rate has been healthy, in-place cash flows have
contracted considerably since issuance and the Morristown/Morris
Township submarket has been particularly challenged amid the
office-sector shifts post-pandemic, as evidenced by the Reis
reported Q2 2024 vacancy rate of 19.5%. As such, Morningstar DBRS
believes the collateral's as-is value has likely declined further
from the figure reported in the June 2021 appraisal. Morningstar
DBRS analyzed the loan with a stressed LTV ratio, resulting in an
expected loss that was approximately 2.5x greater than the pool
average.

Morningstar DBRS also has concerns with the Tustin Center I & II
(Prospectus ID#10; 3.4% of the pool) and Corporate Woods Portfolio
(Prospectus ID#16; 2.4% of the pool) loans, both of which have
exposure to upcoming lease roll-overs, softening office submarket
fundamentals, and/or have experienced sustained performance
declines. The Tustin Center I & II loan is secured by a portfolio
of two Class A, LEED Gold certified office buildings in Santa Ana,
California, totaling 282,959 sf. The property's occupancy rate has
dropped from 98.9% at issuance to 78.5% as of June 2024 with the
YE2023 NCF more than 54.0% below the issuance figure. The Corporate
Woods Portfolio loan is secured by 16 office buildings totaling 2.0
million sf in the Overland Park suburb of Kansas City. The loan was
added to the servicer's watchlist for a cash management trigger
resulting from a low DSCR, which was reported at just 1.06x as of
the June 2024 financials. The drop is attributed to a decline in
occupancy from 83.3% at YE2023 to 74.7% as of June 2024. The
stressed scenarios considered for each resulted in significantly
increased loss expectations for both loans, further supporting the
Negative trends assigned with this review.

The credit rating confirmations reflect the otherwise overall
stable performance of the transaction, which remains in line with
Morningstar DBRS' expectations. The pool continues to exhibit
healthy credit metrics, as evidenced by the weighted-average (WA)
DSCR of 2.0x, based on the most recent financial reporting
available. In addition, the transaction benefits from increased
credit support to the bonds as a result of scheduled amortization,
loan repayments, and defeasance. In addition, Morningstar DBRS
notes there is a sizable unrated first-loss piece, totaling $39.8
million, with no losses incurred to the trust to date.

According to the September 2024 remittance, 54 of the original 58
loans remain within the transaction with a trust balance of $916.4
million, reflecting a collateral reduction of 13.7% since issuance.
There are nine loans, representing 22.3% of the pool, on the
servicer's watchlist; however, only four of those loans,
representing 11.0% of the pool, are being monitored for
performance-related reasons. Nine loans, representing 9.7% of the
pool balance, have fully defeased. Since Morningstar DBRS' prior
credit rating action in October 2023, the Hotel Mela Times Square
loan (Prospectus ID#9; 3.5% of the pool), which is secured by a
234-key, full-service hotel in the Times Square submarket of New
York was returned to the master servicer in March of this year. The
loan, which matured in November 2023, was modified, terms of which
included a one-year extension to November 2024 with the option for
further extension to November 2025.

At issuance, Morningstar DBRS shadow-rated three loans - Burbank
Office Portfolio (Prospectus ID#3; 5.4% of the pool), Moffett Place
Building 4 (Prospectus ID#15; 2.7% of the pool), and Colorado
Center (Prospectus ID#23; 2.2% of the pool), as investment grade.
With this review, Morningstar DBRS confirms that the performance of
those loans remains consistent with investment-grade
characteristics, given the loans' strong credit metrics,
experienced sponsorship, and the underlying collateral's
historically stable performance.

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


CEDAR FUNDING XIV: S&P Assigns B- (sf) Rating on Class F Notes
--------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-R, B-1-R,
B-2-R, C-R, D-1-R, D-2-R, and E-R replacement debt and new class X
and F debt from Cedar Funding XIV CLO Ltd./Cedar Funding XIV CLO
LLC, a CLO managed by Aegon USA Investment Management LLC that was
originally issued in June 2021. At the same time, S&P withdrew its
ratings on the class A, B, C, D, and E debt following payment in
full on the Oct. 17, 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 stated maturity will be extended to October 2037.

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

-- The non-call period will be extended up to October 2026.

-- The concentration limitations of the collateral portfolio's
investment guidelines will be amended.

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

  Ratings Assigned

  Cedar Funding XIV CLO Ltd./Cedar Funding XIV CLO LLC

  Class X, $3.00 million: AAA (sf)
  Class A-R, $247.00 million: AAA (sf)
  Class B-1-R, $40.00 million: AA+ (sf)
  Class B-2-R, $13.00 million: AA (sf)
  Class C-R (deferrable), $28.00 million: A (sf)
  Class D-1-R (deferrable), $9.00 million: BBB- (sf)
  Class D-2-R (deferrable), $15.00 million: BBB- (sf)
  Class E-R (deferrable), $14.90 million: BB- (sf)
  Class F (deferrable), $4.000 million: B- (sf)

  Ratings Withdrawn

  Cedar Funding XIV CLO Ltd./Cedar Funding XIV CLO LLC

  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)'

  Other Debt

  Cedar Funding XIV CLO Ltd./Cedar Funding XIV CLO LLC

  Subordinated notes, $42.79 million: NR

  NR--Not rated.



CFMT 2024-R1: DBRS Gives Prov. BB(low) Rating on Class M2 Notes
---------------------------------------------------------------
DBRS, Inc. assigned the following provisional credit ratings to the
Mortgage-Backed Notes, Series 2024-R1 (the Notes) to be issued by
CFMT 2024-R1, LLC (CFMT 2024-R1 or the Issuer):

-- $118.7 million Class A-1 at (P) AAA (sf)
-- $17.9 million Class A-2 at (P) AA (high) (sf)
-- $17.9 million Class A-3 at (P) A (high) (sf)
-- $15.4 million Class M-1 at (P) BBB (high) (sf)
-- $29.9 million Class M-2 at (P) BB (low) (sf)

The (P) AAA (sf) credit rating on the Class A-1 Notes reflects
48.65% of credit enhancement provided by the subordinated notes.
The (P) AA (high) (sf), (P) A (high) (sf), (P) BBB (high) (sf), and
(P) BB (low) (sf) credit ratings reflect 40.90%, 33.15%, 26.50%,
and 13.55% of credit enhancement, respectively.

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

CFMT 2024-R1 is a securitization of a portfolio of newly originated
and seasoned, performing and reperforming, first-lien and
second-lien residential mortgages to be funded by the issuance of
the Notes. The Notes are backed by 1,040 loans with a total
principal balance of $231,135,598 as of the cut-off date (August
31, 2024).

Morningstar DBRS calculated the portfolio to be approximately 67
months seasoned on average, though the age of the loans is
dispersed, ranging from seven months to 372 months. Approximately
69.7% of the loans had origination guideline or document
deficiencies, which prevented them from being sold to Fannie Mae,
Freddie Mac, or another purchaser, and the loans were subsequently
put back to the sellers. In its analysis, Morningstar DBRS assessed
such defects and applied certain penalties, consequently increasing
expected losses on the mortgage pool.

In the portfolio, 19.7% of the loans are modified, 73.2% of which
were modified more than two years ago. Within the portfolio, 151
mortgages have noninterest-bearing deferred amounts, equating to
1.5% of the total unpaid principal balance (UPB). Unless specified
otherwise, Morningstar DBRS based all statistics on the mortgage
loans on the current UPB, including the applicable
noninterest-bearing deferred amounts.

Based on Issuer-provided information, 24.2% of the loans in the
pool are not subject to or exempt from the Consumer Financial
Protection Bureau's (CFPB) Ability-to-Repay (ATR)/Qualified
Mortgage (QM) Rule because of seasoning or because they are
business-purpose loans. The loans subject to the ATR/QM Rule are
designated as QM Safe Harbor (44.3%), QM Rebuttable Presumption
(10.4%), and Non-Qualified Mortgage (21.0%) by UPB.

Cascade Funding, LP - Series 12 (the Sponsor) acquired the mortgage
loans prior to the upcoming closing date and, through a wholly
owned subsidiary, Cascade Funding Mortgage Depositor, LLC, will
contribute the loans to CFMT 2024-R1. As the Sponsor, Cascade
Funding, LP - Series 12 or one of its majority-owned affiliates
will retain the membership certificate representing the initial
overcollateralization amount and, if required, a portion of the
Class B Notes to satisfy the credit risk retention requirements.

CFMT 2024-R1 is the Issuer's first scratch-and-dent rated
securitization. The Sponsor has securitized many rated and unrated
transactions under the CFMT shelf, most of which have been reverse
mortgage and other residential mortgage transactions.

Carrington Mortgage Services, LLC (the Servicer) will service all
of the mortgage loans.

The Servicer will not advance any delinquent principal and interest
(P&I) on the mortgages; however, it is obligated to make advances
in respect of prior liens, insurance, real estate taxes, and
assessments as well as reasonable costs and expenses incurred in
the course of servicing and disposing of properties.

The Issuer has the option to redeem the Notes in full at a price
equal to the sum of (1) the remaining aggregate Note amount; (2)
any accrued and unpaid interest due on the Notes through the
redemption date (including any cap carryover); and (3) any fees and
expenses incurred by the transaction parties, including any
unreimbursed servicing advances. Optional redemption may be
exercised on or after the payment date in October 2026.

Additionally, failure to pay the Notes in full by the payment date
in October 2029 will trigger a mandatory auction of the underlying
certificates by the Asset Manager or an agent it appoints on the
payment date of November 2029. If the auction fails to elicit
sufficient proceeds to make the Notes whole, another auction will
follow every four months for the first year and subsequent auctions
will be carried out every six months. If the Asset Manager fails to
conduct the auction, holders of the most junior class of Notes
(other than any rated Notes retained and held by the Sponsor or its
affiliates holding more than 50% of such class of Notes) will have
the right to appoint an auction agent to conduct the auction.

The transaction employs a sequential-pay cash flow structure with a
bullet feature to Class A-2 and more subordinate notes on the
expected redemption date (the payment date in October 2028). The
Issuer will first use the P&I collections to pay interest and any
cap carryover amount to the Notes sequentially and then to pay
Class A-1 until its balance is reduced to zero, which may provide
for timely payment of interest on certain rated Notes. Class A-2
and below are not entitled to any payments of principal until the
expected redemption date or upon the occurrence of a credit event,
except for remaining available funds representing net sales
proceeds of the mortgage loans. Prior to the expected redemption
date or an event of default (EOD), any available funds remaining
after Class A-1 is paid in full will be deposited into a redemption
account. Beginning on the payment date in October 2028, the Class
A-1 and the other offered Notes will be entitled to their initial
note rate plus the step-up note rate of 1.00% per annum. If the
Issuer does not redeem the rated Notes in full by the payment date
in October 2030 or an EOD occurs and is continuing, this
constitutes a credit event. Upon the occurrence of a credit event,
accrued interest on Class A-2 and the other offered Notes will be
paid as principal to Class A-1 or the succeeding senior Notes until
it has been paid in full. The redirected amounts will accrue on the
balances of the respective Notes and will later be paid as
principal payments.

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


CHASE HOME 2024-8: DBRS Finalizes BB Rating on Class B4 Certs
-------------------------------------------------------------
DBRS, Inc. finalized its provisional credit ratings on the Mortgage
Pass-Through Certificates, Series 2024-8 (the Certificates) issued
by Chase Home Lending Mortgage Trust 2024-8 (CHASE 2024-8) as
follows:

-- $529.5 million Class A-2 at AAA (sf)
-- $529.5 million Class A-3 at AAA (sf)
-- $529.5 million Class A-3-X at AAA (sf)
-- $397.1 million Class A-4 at AAA (sf)
-- $397.1 million Class A-4-A at AAA (sf)
-- $397.1 million Class A-4-X at AAA (sf)
-- $132.4 million Class A-5 at AAA (sf)
-- $132.4 million Class A-5-A at AAA (sf)
-- $132.4 million Class A-5-X at AAA (sf)
-- $317.7 million Class A-6 at AAA (sf)
-- $317.7 million Class A-6-A at AAA (sf)
-- $317.7 million Class A-6-X at AAA (sf)
-- $211.8 million Class A-7 at AAA (sf)
-- $211.8 million Class A-7-A at AAA (sf)
-- $211.8 million Class A-7-X at AAA (sf)
-- $79.4 million Class A-8 at AAA (sf)
-- $79.4 million Class A-8-A at AAA (sf)
-- $79.4 million Class A-8-X at AAA (sf)
-- $53.3 million Class A-9 at AAA (sf)
-- $53.3 million Class A-9-A at AAA (sf)
-- $53.3 million Class A-9-X at AAA (sf)
-- $582.8 million Class A-X-1 at AAA (sf)
-- $582.8 million Class A-X-2 at AAA (sf)
-- $582.8 million Class A-X-3 at AAA (sf)
-- $16.8 million Class B-1 at AA (low) (sf)
-- $16.8 million Class B-1-A at AA (low) (sf)
-- $16.8 million Class B-1-X at AA (low) (sf)
-- $9.3 million Class B-2 at A (low) (sf)
-- $9.3 million Class B-2-A at A (low) (sf)
-- $9.3 million Class B-2-X at A (low) (sf)
-- $6.9 million Class B-3 at BBB (low) (sf)
-- $3.1 million Class B-4 at BB (sf)
-- $1.9 million Class B-5 at B (low) (sf)

Classes A-5-X, A-6-X, A-8-X, A-9-X, A-X-2, A-X-3, B-1-X, and B-2-X
are interest-only (IO) certificates. The class balances represent
notional amounts.

Classes A-2, A-3, A-3-X, A-4, A-4-A, A-4-X, A-5, A-6, A-7, A-7-A,
A-7-X, A-8, A-9, A-X-1, B-1, and B-2 are exchangeable certificates.
These classes can be exchanged for combinations of depositable
certificates as specified in the offering documents.

Classes A-5-A, A-6-A, and A-8-A are super senior certificates.
These classes benefit from additional protection from the senior
support certificates (Classes A-9 and A-9-A) with respect to loss
allocation.

The AAA (sf) credit ratings on the Certificates reflect 6.45% of
credit enhancement provided by subordinated certificates. The AA
(low) (sf), A (low) (sf), BBB (low) (sf), BB (sf), and B (low) (sf)
credit ratings reflect 3.75%, 2.25%, 1.15%, 0.65%, and 0.35% of
credit enhancement, respectively.

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

DBRS, Inc. (Morningstar DBRS) finalized its provisional ratings on
Chase Home Lending Mortgage Trust 2024-8 (CHASE 2024-8), a
securitization of a portfolio of first-lien, fixed-rate prime
residential mortgages funded by the issuance of the Mortgage
Pass-Through Certificates, Series 2024-8 (the Certificates). The
Certificates are backed by 501 loans with a total principal balance
of $622,964,795 as of the Cut-Off Date (September 1, 2024).

The pool consists of fully amortizing fixed-rate mortgages with
original terms to maturity from 15 to 30 years and a
weighted-average (WA) loan age of three months. All of the loans
are traditional, nonagency, prime jumbo mortgage loans. Details on
the underwriting of conforming loans can be found in the Key
Probability of Default Drivers section. In addition, all the loans
in the pool were originated in accordance with the new general
Qualified Mortgage (QM) rule.

JP Morgan Chase Bank, N.A. (JPMCB) is the Originator and Servicer
of 100.0% of the pool.

For this transaction, generally, the servicing fee payable for
mortgage loans is composed of three separate components: the base
servicing fee, the delinquent servicing fee, and the additional
servicing fee. These fees vary based on the delinquency status of
the related loan and will be paid from interest collections before
distribution to the securities.

U.S. Bank Trust Company, National Association, rated AA with a
Stable trend by Morningstar DBRS, will act as Securities
Administrator. U.S. Bank Trust National Association will act as
Delaware Trustee. JPMCB will act as Custodian. Pentalpha
Surveillance LLC (Pentalpha) will serve as the Representations and
Warranties (R&W) Reviewer.

The transaction employs a senior-subordinate, shifting-interest
cash flow structure that incorporates performance triggers and
credit enhancement floors.

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


CHASE HOME 2024-9: Fitch Assigns B+(EXP)sf Rating on Cl. B-5 Certs
------------------------------------------------------------------
Fitch Ratings has assigned expected ratings to Chase Home Lending
Mortgage Trust 2024-9 (Chase 2024-9).

   Entity/Debt      Rating           
   -----------      ------            
Chase 2024-9

   A-2          LT AAA(EXP)sf  Expected Rating
   A-3          LT AAA(EXP)sf  Expected Rating
   A-3-X        LT AAA(EXP)sf  Expected Rating
   A-4          LT AAA(EXP)sf  Expected Rating
   A-4-A        LT AAA(EXP)sf  Expected Rating
   A-4-X        LT AAA(EXP)sf  Expected Rating
   A-5          LT AAA(EXP)sf  Expected Rating
   A-5-A        LT AAA(EXP)sf  Expected Rating
   A-5-X        LT AAA(EXP)sf  Expected Rating
   A-6          LT AAA(EXP)sf  Expected Rating
   A-6-A        LT AAA(EXP)sf  Expected Rating
   A-6-X        LT AAA(EXP)sf  Expected Rating
   A-7          LT AAA(EXP)sf  Expected Rating
   A-7-A        LT AAA(EXP)sf  Expected Rating
   A-7-X        LT AAA(EXP)sf  Expected Rating
   A-8          LT AAA(EXP)sf  Expected Rating
   A-8-A        LT AAA(EXP)sf  Expected Rating
   A-8-X        LT AAA(EXP)sf  Expected Rating
   A-9          LT AAA(EXP)sf  Expected Rating
   A-9-A        LT AAA(EXP)sf  Expected Rating
   A-9-X        LT AAA(EXP)sf  Expected Rating   
   A-11         LT AAA(EXP)sf  Expected Rating
   A-11-X       LT AAA(EXP)sf  Expected Rating
   A-12         LT AAA(EXP)sf  Expected Rating
   A-13         LT AAA(EXP)sf  Expected Rating
   A-13-X       LT AAA(EXP)sf  Expected Rating
   A-14         LT AAA(EXP)sf  Expected Rating
   A-14-X       LT AAA(EXP)sf  Expected Rating
   A-14-X2      LT AAA(EXP)sf  Expected Rating
   A-14-X3      LT AAA(EXP)sf  Expected Rating
   A-14-X4      LT AAA(EXP)sf  Expected Rating
   A-X-1        LT AAA(EXP)sf  Expected Rating
   A-X-2        LT AAA(EXP)sf  Expected Rating
   A-X-3        LT AAA(EXP)sf  Expected Rating
   B-1          LT AA-(EXP)sf  Expected Rating
   B-1-A        LT AA-(EXP)sf  Expected Rating
   B-1-X        LT AA-(EXP)sf  Expected Rating
   B-2          LT A-(EXP)sf   Expected Rating
   B-2-A        LT A-(EXP)sf   Expected Rating
   B-2-X        LT A-(EXP)sf   Expected Rating
   B-3          LT BBB-(EXP)sf Expected Rating
   B-4          LT BB(EXP)sf   Expected Rating
   B-5          LT B+(EXP)sf   Expected Rating
   B-6          LT NR(EXP)sf   Expected Rating

Transaction Summary

Fitch expects to rate the residential mortgage-backed certificates
issued by Chase Home Lending Mortgage Trust 2024-9 (Chase 2024-9),
as indicated above. The certificates are supported by 488 loans
with a total balance of approximately $606.28 million as of the
cutoff date. The scheduled balance as of the cutoff date is $605.92
million.

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

Of the loans, 99.8% qualify as safe-harbor qualified mortgage
(SHQM) average prime offer rate (APOR) loans, with 0.2% qualifying
as rebuttable presumption (APOR) qualified mortgage loans. There is
no exposure to Libor in this transaction. The collateral comprises
100% fixed-rate loans. The certificates are either fixed rate and
capped at the net weighted average coupon (WAC), or
floating/inverse rate based on the SOFR index and capped at the net
WAC, or based on the net WAC. Consequently, the certificates have
no Libor exposure.

Based on the FEMA declared disaster zip codes for Hurricane Helene,
27 mortgage loans (5.2% based on UPB) in the pool are secured by
homes in FEMA declared disaster areas in GA, NC and SC. Post
Disaster Inspections have come back on some of the 27 loans and
indicated that there was no damage to the homes they received post
disaster property inspection reports on. Based on Fitch's review of
the zip codes associated with FEMA declared disaster areas due to
Hurricane Milton, there are no loans located in the impacted
areas.

The servicer is following standard servicing practices to assess
any property damage to the impacted homes, including ordering
post-disaster inspection reports and a call campaign to reach out
to borrowers in the impacted areas (to assess any damage and the
need of a modification). Fitch did not increase the loss severity
or the losses for the loans in the impacted areas, as the
representation and warranty (R&W) provider is rated investment
grade and will repurchase the loan if there is material damage, per
the no damage R&W.

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 11.1% above a long-term sustainable level (versus
11.5% on a national level as of 1Q24, up 0.4% since last quarter.
Housing affordability is the worst it has been in decades, driven
by both high interest rates and elevated home prices. Home prices
have increased 5.9% yoy nationally as of May 2024, despite modest
regional declines, but are still being supported by limited
inventory.

High Quality Prime Mortgage Pool (Positive): The pool consists of
488 high quality, fixed-rate, fully amortizing loans with
maturities of up to 30 years that total $605.92 million. In total,
99.8% of the loans qualify as SHQM; the remining 0.2% are
rebuttable presumption QM. The loans were made to borrowers with
strong credit profiles, relatively low leverage and large liquid
reserves.

The loans are seasoned at an average of 4.8 months, according to
Fitch. The pool has a WA FICO score of 770, as determined by Fitch,
and is based on the original FICO for newly originated loans and
the updated FICO for loans seasoned at 12 months or more, which is
indicative of very high credit-quality borrowers. A large
percentage of the loans have a borrower with a Fitch-derived FICO
score equal to or above 750.

Fitch determined that 79.0% of the loans have a borrower with a
Fitch-determined FICO score equal to or above 750. Based on Fitch's
analysis of the pool, the original weighted average (WA) combined
loan-to-value (CLTV) ratio is 76.3% (76.3% per the transaction
documents), which translates to a sustainable loan-to-value (sLTV)
ratio of 84.9%. This represents moderate borrower equity in the
property and reduced default risk compared with a borrower with a
CLTV over 80%.

Of the pool, 100.0% of the loans are designated as QM loans.

Of the pool, 100% comprises loans where the borrower maintains a
primary or secondary residence. Single-family homes and planned
unit developments (PUDs) constitute 94.0% of the pool, and
condominiums make up 6.0%. Fitch views favorably the fact that
there are no investor loans in the pool.

The pool consists of loans with the following loan purposes, as
determined by Fitch: purchases (95.9%), cashout refinances (1.6%)
and rate-term refinances (2.5%). Fitch views favorably that no
loans are for

Of the pool loans, 23.0% are concentrated in California followed by
Washington and Massachusetts. The largest MSA concentration is in
the Seattle MSA (8.4%), followed by the Los Angeles MSA (6.5%) and
the Boston MSA (6.1%). The top three MSAs account for 21.1% of the
pool. As a result, no probability of default (PD) penalty was
applied for geographic concentration.

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 to 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.

The servicer, JPMCB, is obligated to advance delinquent principal
and interest (P&I) until deemed nonrecoverable. Although full P&I
advancing will provide liquidity to the certificates, it will also
increase the loan-level loss severity (LS) since the servicer looks
to recoup P&I advances from liquidation proceeds, which results in
less recoveries.

There is no master servicer for this transaction. U.S. Bank Trust
National Association is the trustee that will advance as needed
until a replacement servicer can be found. The trustee is the
ultimate advancing party.

CE Floor (Positive): A CE or senior subordination floor of 1.20%
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. Additionally, a junior
subordination floor of 0.70% has been considered to mitigate
potential tail-end risk and loss exposure for subordinate 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 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.

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by AMC. The third-party due diligence described in Form
15E focused on four areas: compliance review, credit review,
valuation review and data integrity. Fitch considered this
information in its analysis and, as a result, Fitch decreased its
loss expectations by 0.13% at the 'AAAsf' stress due to 53.7% due
diligence with no material findings.

DATA ADEQUACY

Fitch relied on an independent third-party due diligence review
performed on 53.7% of the pool. The third-party due diligence was
generally consistent with Fitch's "U.S. RMBS Rating Criteria." AMC
and Digital Risk 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
provided was considered comprehensive. The data contained in the
ResiPLS layout data tape were reviewed by the due diligence
companies, and no material discrepancies were noted.

ESG Considerations

Chase 2024-9 has an ESG Relevance Score of '4' [+] for Transaction
Parties & Operational Risk due to the strong transaction parties
and low operational risk present in the transaction as a result of
an above average originator and RPS1- rated servicer. The above
average originator and RPS1- servicer both have a positive impact
on the credit profile, and are relevant to the rating[s] 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.


CIFC FUNDING 2019-I: Fitch Assigns 'BB-sf' Rating on Cl. E-R Notes
------------------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to CIFC
Funding 2019-I, Ltd. reset transaction.

   Entity/Debt        Rating           
   -----------        ------           
CIFC Funding 2019-I, Ltd.

   A-1-R2          LT  NRsf    New Rating
   A-2-R2          LT  AAAsf   New Rating
   B-R2            LT  AAsf    New Rating
   C-R2            LT  Asf     New Rating
   D-1-R2          LT  BBB-sf  New Rating
   D-2-R2          LT  BBB-sf  New Rating
   E-R             LT  BB-sf   New Rating
   Subordinated    LT  NRsf    New Rating

Transaction Summary

CIFC Funding 2019-I, Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) managed by CIFC Asset
Management LLC that originally closed in March of 2019 and it was
partially refinanced in April 2021. This is the second refinancing
where the existing secured notes will be reset in whole and new
notes will be issued on Oct. 21, 2024. Net proceeds from the
issuance of refinancing secured notes and additional subordinated
notes will provide financing on a portfolio of approximately $525
million of primarily first lien senior 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 24.11, 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
99.16% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 74.98% versus a
minimum covenant, in accordance with the initial expected matrix
point of 72.8%.

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 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-2-R2, between
'BB+sf' and 'A+sf' for class B-R2, between 'B+sf' and 'BBB+sf' for
class C-R2, between less than 'B-sf' and 'BB+sf' for class D-1-R2,
between less than 'B-sf' and 'BB+sf' for class D-2-R2, 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-2-R2 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-R2, 'AA+sf' for class C-R2, 'Asf'
for class D-1-R2, 'A-sf' for class D-2-R2, 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
2019-I, Ltd. In cases where Fitch does not provide ESG relevance
scores in connection with the credit rating of a transaction,
programme, instrument or issuer, Fitch will disclose in the key
rating drivers any ESG factor which has a significant impact on the
rating on an individual basis.


CIFC FUNDING 2024-IV: Fitch Assigns 'BB-sf' Final Rating on E Notes
-------------------------------------------------------------------
Fitch Ratings has assigned final ratings and Rating Outlooks to
CIFC Funding 2024-IV, Ltd.

   Entity/Debt        Rating             Prior
   -----------        ------             -----
CIFC Funding
2024-IV, Ltd.

   A              LT NRsf   New Rating   NR(EXP)sf
   A Loan         LT NRsf   New Rating   NR(EXP)sf
   B              LT AAsf   New Rating   AA(EXP)sf
   C              LT Asf    New Rating   A(EXP)sf
   D-1            LT BBB-sf 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

CIFC Funding 2024-IV, Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that will be managed by CIFC
Asset Management LLC. 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 24.4 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
98.9% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 74.36% versus a
minimum covenant, in accordance with the initial expected matrix
point of 71.2%.

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

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

Variability in key model assumptions, such as increases in recovery
rates and decreases in default rates, could result in an upgrade.
Fitch evaluated the notes' sensitivity to potential changes in such
metrics; the minimum rating results under these sensitivity
scenarios are 'AAAsf' for class B, 'AA+sf' for class C, 'A+sf' for
class D-1, 'Asf' for class D-2, and 'BBB+sf' for class E.

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

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

DATA ADEQUACY

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

09 October 2024

ESG Considerations

Fitch does not provide ESG relevance scores for CIFC Funding
2024-IV, Ltd.

In cases where Fitch does not provide ESG relevance scores in
connection with the credit rating of a transaction, program,
instrument or issuer, Fitch will disclose any ESG factor that is a
key rating driver in the key rating drivers section of the relevant
rating action commentary.


CITIGROUP 2019-GC43: Fitch Affirms 'B-sf' Rating on GRR Certs
-------------------------------------------------------------
Fitch Ratings has affirmed 16 classes of Citigroup Commercial
Mortgage Trust 2019-GC41 commercial mortgage pass-through
certificates (CGCMT 2019-GC41). Fitch has revised the Rating
Outlooks for two classes to Negative from Stable. The Rating
Outlooks on three classes remain Negative.

Fitch has also affirmed 17 classes of Citigroup Commercial Mortgage
Trust 2019-GC43 commercial mortgage pass-through certificates
(CGCMT 2019-GC43). Fitch has revised the Outlook for one class to
Negative from Stable. The Rating Outlooks on six classes remain
Negative.

   Entity/Debt            Rating               Prior
   -----------            ------               -----
CGCMT 2019-GC41

   A-2 17328FAT2      LT  AAAsf   Affirmed       AAAsf
   A-3 17328FAU9      LT  AAAsf   Affirmed       AAAsf
   A-4 17328FAV7      LT  AAAsf   Affirmed       AAAsf
   A-5 17328FAW5      LT  AAAsf   Affirmed       AAAsf
   A-AB 17328FAX3     LT  AAAsf   Affirmed       AAAsf
   A-S 17328FAY1      LT  AAAsf   Affirmed       AAAsf
   B 17328FAZ8        LT  AA-sf   Affirmed       AA-sf
   C 17328FBA2        LT  A-sf    Affirmed       A-sf
   D 17328FAA3        LT  BBBsf   Affirmed       BBBsf
   E 17328FAC9        LT  BBB-sf  Affirmed       BBB-sf
   F 17328FAE5        LT  BB-sf   Affirmed       BB-sf
   GRR 17328FAG0      LT  B-sf    Affirmed       B-sf
   X-A 17328FBB0      LT  AAAsf   Affirmed       AAAsf
   X-B 17328FAL9      LT  A-sf    Affirmed       A-sf
   X-D 17328FAN5      LT  BBB-sf  Affirmed       BBB-sf
   X-F 17328FAQ8      LT  BB-sf   Affirmed       BB-sf

Citigroup
Commercial Mortgage
Trust 2019-GC43

   A-1 17328HBA8      LT PIFsf  Paid In Full   AAAsf
   A-2 17328HBB6      LT AAAsf  Affirmed       AAAsf
   A-3 17328HBC4      LT AAAsf  Affirmed       AAAsf
   A-4 17328HBD2      LT AAAsf  Affirmed       AAAsf
   A-AB 17328HBE0     LT AAAsf  Affirmed       AAAsf
   A-S 17328HBG5      LT AAAsf  Affirmed       AAAsf
   B 17328HBH3        LT AA-sf  Affirmed       AA-sf
   C 17328HBJ9        LT A-sf   Affirmed       A-sf
   D 17328HAJ0        LT BBBsf  Affirmed       BBBsf
   E 17328HAL5        LT BBB-sf Affirmed       BBB-sf
   F 17328HAN1        LT B+sf   Affirmed       B+sf
   G 17328HAQ4        LT B-sf   Affirmed       B-sf
   J-RR 17328HAS0     LT CCCsf  Affirmed       CCCsf  
   X-A 17328HBF7      LT AAAsf  Affirmed       AAAsf
   X-B 17328HAA9      LT AA-sf  Affirmed       AA-sf
   X-D 17328HAC5      LT BBB-sf Affirmed       BBB-sf
   X-F 17328HAE1      LT B+sf   Affirmed       B+sf
   X-G 17328HAG6      LT B-sf   Affirmed       B-sf

KEY RATING DRIVERS

'Bsf' Loss Expectations: Fitch's current ratings reflect a
deal-level 'Bsf' rating case loss of 4.4% in CGCMT 2019-GC41 and
5.5% in CGCMT 2019-GC43. The CGCMT 2019-GC41 transaction has seven
Fitch Loans of Concern (FLOCs; 19.9% of the pool), including two
loans (5.9%) in special servicing. The CGCMT 2019-GC43 transaction
has four FLOCs (19.5%), including two loans (7.4%) in special
servicing.

The affirmations reflect the generally stable pool performance and
loss expectations in both transactions since Fitch's prior rating
action. The Negative Outlooks in CGCMT 2019-GC41 reflect possible
further downgrades should performance continue to deteriorate
beyond expectations, recovery prospects worsen or workouts are
prolonged for the specially serviced office loans, particularly The
Zappettini Portfolio (4.6%) in CGCMT 2019-GC41 and Midland Office
Portfolio (4.9%) and 222 Kearny Street (2.6%) in CGCMT 2019-GC43.
The Negative Outlooks also consider these pools' high office
concentration (31.5% in CGCMT 2019-GC41 and 50.8% in CGCMT
2019-GC43).

FLOCs; Largest Loss Contributors: The largest increase in loss
since the prior rating action and the largest contributor to
overall loss expectations in CGCMT 2019-GC41 is The Zappettini
Portfolio loan, which is secured by a portfolio of 10 office
buildings totaling 251,716-sf located in Mountain View, CA.

The loan transferred to special servicing in June 2024 for maturity
default. Per the most recent servicer update, portfolio occupancy
fell to 58% as of May 2024 from 70.4% at YE 2023, 88.7% at YE 2021
and 100% at YE 2020. The recent occupancy decline was mainly due to
the County of Santa Clara (9.9% of NRA) vacating at its September
2023 lease expiration. The special servicer is dual-tracking
foreclosure, while continuing discussions with the borrower who has
reportedly submitted a workout proposal which is currently under
review. Major tenants include Iridex Corporation (11.9% of the
portfolio NRA through August 2026) and Egnyte (11.8%; December
2025).

Fitch's 'Bsf' rating case loss of 34.2% (prior to concentration
add-ons) reflects a 9.25% cap rate, 20% stress to the annualized Q3
2023 NOI due to upcoming rollover concerns of largest in-place
tenants, and factors the loan's defaulted status.

The largest increase in loss since the prior rating action and the
largest contributor to overall loss expectations in CGCMT 2019-GC43
is the Midland Office Portfolio loan, secured by a portfolio of
five office properties totaling 699,584-sf located in Midland, TX.

The loan transferred to special servicing in September 2023 for
imminent monetary default. Per the most recent update, a receiver
is in place and has placed the portfolio under contract for sale.

Portfolio occupancy dropped to 59% as of Q1 2024 from 68% at YE
2023, 74% at YE 2022, 73% at YE 2021 and 90% at YE 2020. The recent
occupancy decline was caused by multiple smaller tenants vacating
at lease expiration, with the largest being Parallel Petroleum
(1.6%; lease expired February 2024). Largest tenants include Enlink
Midstream Operating (8.0% of the NRA through June 2026) and First
Capital Bank (4.9%; November 2027).

Fitch's 'Bsf' rating case loss of 33.9% (prior to concentration
add-ons) reflects a 10% cap rate, 20% stress to the YE 2023 NOI,
and factors an elevated probability of default as the loan has
transferred to special servicing.

The second largest increase in loss since the prior rating action
and the second largest contributor to overall loss expectations in
CGCMT 2019-GC43 is the 222 Kearny Street loan, secured by a
148,199-sf office property in San Francisco, CA. The loan
transferred to special servicing in July 2023 for imminent monetary
default. As of October 2024, the loan remains 90+ days delinquent.
The special servicer is implementing a dual track strategy;
foreclosure is expected in late fourth quarter 2024, while workout
negotiations with the borrower remain ongoing. Fitch requested an
updated appraisal value, but it was not provided.

Occupancy declined after the departure of the Kimpton Hotel and
Restaurant (16.7% of the NRA; lease expiry in June 2021). Per the
February 2024 rent roll, the property was 56% occupied, compared
with 49% at YE 2023 and 79% at YE 2022. The largest tenants at the
property include Ouraring Inc (6.4% of the NRA through February
2026), BTS USA (5.4%; March 2027), and Montgomery Technologies
(4.4%; September 2028).

Fitch's 'Bsf' rating case loss of 43.9% (prior to concentration
add-ons) reflects a 10% cap rate, 30% stress to the annualized T9
September 2023 NOI, and factors in the loan's delinquency status.

Increased Credit Enhancement (CE): As of the October 2024
distribution date, the pool's aggregate balance in CGCMT 2019-GC41
has been paid down by 6.6% to $1.19 billion from $1.28 billion at
issuance. Two loans (1.1% of the pool) are fully defeased. There
are 25 loans (81.2%) that are full-term interest-only, and the
remaining 15 loans (18.8%) are amortizing. Interest shortfalls of
$114,168 and $4,138 are affecting the JRR and VRR classes,
respectively.

As of the October 2024 distribution date, the pool's aggregate
balance in CGCMT 2019-GC43 has been paid down by 1.6% to $922.1
million from $936.8 million at issuance. One loan (8.5%) is fully
defeased. There are 24 loans (86.1%) that are full-term, and the
remaining nine loans (13.9%) are amortizing. Interest shortfalls of
$340,732 and $13,321 are affecting the KRR and VRR classes,
respectively.

RATING SENSITIVITIES

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

- Downgrades to the 'AAAsf' 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 affect
these classes.

- Downgrades to classes rated in the 'AAsf', 'Asf' and 'BBBsf'
categories, especially those with Negative Outlooks, may occur with
outsized loss expectations on the specially serviced loans,
including The Zappettini Portfolio in CGCMT 2019-GC41 and Midland
Office Portfolio and 222 Kearny Street in CGCMT 2019-GC43, increase
beyond expectations, and with limited to no improvement in these
classes' CE.

- Downgrades to the 'BBsf' and 'Bsf' categories are likely with
higher than expected losses from continued underperformance of the
FLOCs 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 and/or default or as losses are
realized and/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 stabilized performance on The Zappettini Portfolio
and The Millennium Park Plaza in CGCMT 2019-GC41, and Midland
Office Portfolio and 222 Kearny Street in CGCMT 2019-GC43.

- 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.


COLT 2024-6: Fitch Assigns 'Bsf' Final Rating on Class B2 Certs
---------------------------------------------------------------
Fitch Ratings has assigned final ratings to the residential
mortgage-backed certificates to be issued by COLT 2024-6 Mortgage
Loan Trust (COLT 2024-6).

   Entity/Debt       Rating            Prior
   -----------       ------            -----
COLT 2024-6

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

Transaction Summary

Fitch has assigned final ratings to the residential mortgage-backed
certificates to be issued by COLT 2024-6 Mortgage Loan Trust as
indicated above. The certificates are supported by 520 nonprime
loans with a total balance of approximately $333.8 million as of
the cutoff date.

Loans in the pool were originated by multiple originators,
including The Loan Store Inc., Foundation Mortgage Corporation,
Northpointe Bank (NPB) and various others. The loans were
aggregated by Hudson Americas L.P. and are currently serviced by
Fay Servicing LLC (Fay), Select Portfolio Servicing, Inc. (SPS) and
NPB.

KEY RATING DRIVERS

Updated Sustainable Home Prices (Negative): Fitch views the home
price values of this pool as 9.5% above a long-term sustainable
level (versus 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.

COLT 2024-6 has a combined original loan-to-value (cLTV) of 75.1%,
slightly lower than that of the previous Hudson transaction, COLT
2024-5. Based on Fitch's updated view of housing market
overvaluation, this pool's sustainable LTV (sLTV) is 83.0%,
compared with 84.4% for the previous transaction.

Non-QM Credit Quality (Negative): The collateral consists of 520
loans totaling $333.8 million and seasoned at approximately three
months in aggregate as calculated by Fitch. The borrowers have a
moderate credit profile, consisting of a 741.2 model FICO, and
moderate leverage with an 83.0% sLTV and a 75.1% cLTV.

Of the pool, 58.1% of the loans are of a primary residence, while
37.3% comprise an investor property. Additionally, 57.1% are
non-qualified mortgages (non-QMs, or NQMs), including 2.0%
designated as Ability-to-Repay (ATR) risk, and QM rule does not
apply to the remainder.

Fitch's expected loss in the 'AAAsf' stress is 20.50%. This is
mainly driven by the NQM collateral and the significant investor
cash flow product (debt service coverage ratio [DSCR])
concentration.

Loan Documentation (Negative): About 92.9% of loans in the pool
were underwritten to less than full documentation and 64.6% were
underwritten to a bank statement program for verifying income,
which is not consistent with Fitch's view of a full documentation
program. A key distinction between this pool and legacy Alt-A loans
is that these loans adhere to underwriting and documentation
standards required under the Consumer Financial Protections
Bureau's (CFPB) ATR Rule (the Rule). Fitch's treatment of
alternative loan documentation increased 'AAAsf' expected losses by
600bps, compared with a deal of 100% fully documented loans.

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

Advances of delinquent principal and interest (P&I) will be made on
the mortgage loans serviced by SPS, Fay and NPB for the first 90
days of delinquency, to the extent such advances are deemed
recoverable. If the P&I advancing party fails to make a required
advance, the master servicer and then the securities administrator
will be obligated to make such advance.

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

COLT 2024-6 has a step-up coupon for the senior classes (A-1, A-2
and A-3). After four years, the senior classes pay the lower of a
100-bp increase to the fixed coupon or the net weighted average
coupon (NWAC) rate. Any class B-3 interest distribution amount will
be distributed to class A-1, A-2 and A-3 certificates on and after
the step-up date if the cap carryover amount is greater than zero.
This increases the P&I allocation for the senior classes.

RATING SENSITIVITIES

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

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

The defined negative rating sensitivity analysis demonstrates how
the ratings would react to steeper MVDs at the national level. The
analysis assumes MVDs of 10.0%, 20.0% and 30.0% in addition to the
model projected 41.2% at 'AAA'. The analysis indicates that there
is some potential rating migration with higher MVDs for all rated
classes, compared with the model projection. A 10% additional
decline in home prices would lower all rated classes by one full
category.

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

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

The defined positive rating sensitivity analysis demonstrates how
the ratings would react to positive home price growth of 10% with
no assumed overvaluation. Excluding the senior class, which is
already rated 'AAAsf', the analysis indicates there is potential
positive rating migration for all of the rated classes. A 10% gain
in home prices would result in a full category upgrade for the
rated class excluding those assigned 'AAAsf' ratings.

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 Consolidated Analytics, SitusAMC, Evolve, Selene,
Clarifii, Opus and Maxwell. 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 adjustment to its analysis: a 5%
credit was given at the loan level for each loan where satisfactory
due diligence was completed. This adjustment resulted in a 51bps
reduction to the 'AAA' expected loss.

ESG Considerations

COLT 2024-6 has an ESG Relevance Score of '4' for Transaction
Parties & Operational Risk due to origination, underwriting and/or
aggregator standards, which 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.


COMM 2016-CCRE28: Fitch Lowers Rating on Two Tranches to 'BB-sf'
----------------------------------------------------------------
Fitch Ratings has affirmed 12 classes of COMM 2015-LC19 Mortgage
Trust. The Rating Outlooks remain Negative for classes B, C, D, E,
X-B, X-C and PEZ.

Fitch has also downgraded six and affirmed 10 classes of COMM
2016-CCRE28 Mortgage Trust. Following their downgrades, classes D,
E and X-C were assigned Negative Outlooks. The Outlooks for classes
B and C were revised to Negative from Stable.

   Entity/Debt          Rating            Prior
   -----------          ------            -----
COMM 2016-CCRE28

   A-3 12593YBD4    LT AAAsf  Affirmed    AAAsf
   A-4 12593YBE2    LT AAAsf  Affirmed    AAAsf
   A-HR 12593YBF9   LT AAAsf  Affirmed    AAAsf
   A-M 12593YBK8    LT AAAsf  Affirmed    AAAsf
   A-SB 12593YBC6   LT AAAsf  Affirmed    AAAsf
   B 12593YBL6      LT AA-sf  Affirmed    AA-sf
   C 12593YBM4      LT A-sf   Affirmed    A-sf
   D 12593YBN2      LT BBsf   Downgrade   BBBsf
   E 12593YAL7      LT BB-sf  Downgrade   BBB-sf
   F 12593YAN3      LT CCCsf  Downgrade   Bsf
   G 12593YAQ6      LT CCsf   Downgrade   CCCsf
   X-A 12593YBH5    LT AAAsf  Affirmed    AAAsf
   X-C 12593YAC7    LT BB-sf  Downgrade   BBB-sf
   X-D 12593YAE3    LT CCCsf  Downgrade   Bsf
   X-HR 12593YBJ1   LT AAAsf  Affirmed    AAAsf
   XP-A 12593YBG7   LT AAAsf  Affirmed    AAAsf

COMM 2015-LC19

   A-3 200474BB9    LT AAAsf  Affirmed    AAAsf
   A-4 200474BC7    LT AAAsf  Affirmed    AAAsf
   A-M 200474BE3    LT AAAsf  Affirmed    AAAsf
   B 200474BF0      LT AA-sf  Affirmed    AA-sf
   C 200474BH6      LT A-sf   Affirmed    A-sf
   D 200474AE4      LT BBB-sf Affirmed    BBB-sf
   E 200474AG9      LT Bsf    Affirmed    Bsf
   F 200474AJ3      LT CCCsf  Affirmed    CCCsf
   PEZ 200474BG8    LT A-sf   Affirmed    A-sf
   X-A 200474BD5    LT AAAsf  Affirmed    AAAsf
   X-B 200474AA2    LT AA-sf  Affirmed    AA-sf
   X-C 200474AC8    LT BBB-sf Affirmed    BBB-sf

KEY RATING DRIVERS

Performance and 'Bsf' Loss Expectations; Pool Concentrations:
Fitch's current ratings incorporate a 'Bsf' rating case loss of
6.0% for COMM 2015-LC19 and 8.7% for COMM 2016-CCRE28 transactions.
Fitch Loans of Concern (FLOCs) comprise 18 loans (48% of the pool),
including one specially serviced loan (0.8%) in COMM 2015-LC19, and
14 loans (48%), including two specially serviced loans (12.0%) in
COMM 2016-CCRE28.

Due to the concentration of upcoming scheduled maturities and
adverse selection concerns, Fitch performed a sensitivity and
liquidation analysis that 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 expectation.
Loan maturities, accounting for 95.8% of the pool balance in COMM
2015-LC19, are concentrated between 4Q24 and 1Q25, and 86.1% of the
pool balance in COMM 2016-CCRE28 matures during 4Q25.

The downgrades in the COMM 2016-CCRE28 transaction reflect
increased pool loss expectations since Fitch's prior rating action,
driven primarily by continued performance deterioration of the
specially serviced 1155 Market Street loan, as well as other FLOCs
including Promenade Gateway and 32 Avenue of the Americas. The
affirmations in the COMM 2015-LC19 transaction reflect generally
stable pool performance and loss expectations since the prior
rating action.

The Negative Outlooks in both transactions reflect the high
concentration of FLOCs and these classes' significant reliance on
proceeds from FLOCs to repay. Potential future downgrades are
likely if the performance stabilization of the FLOCs does not
stabilize, more loans than expected default at maturity, and/or
recovery prospects worsen or workouts are prolonged for the
specially serviced loans.

The above-mentioned risks particularly affect Central Plaza,
Decorative Center of Houston and TPI Hospitality Pool B in COMM
2015-LC19, as well as 1155 Market Street loan, Promenade Gateway,
32 Avenue of the Americas and 19925 Stevens Creek in COMM
2016-CCRE28. The Negative Outlooks in COMM 2016-CCRE28 also reflect
an office exposure of 42.8%.

The largest increase in losses since the prior rating action in the
COMM 2015-LC19 transaction is the TPI Hospitality Pool B loan (4.7%
of the pool), which is secured by a portfolio of five hotels
totaling 590 keys located in the Minneapolis-Saint-Paul-Bloomington
MSA. Portfolio performance has declined, with the TTM September
2023 occupancy and NOI DSCR falling to 60% and 1.66x, respectively,
compared to 61% and 1.78x, respectively, at YE 2022 and 71% and
1.90x, respectively, at YE 2019. The annualized September 2023 and
YE 2022 NOI are 22% and 16.3% below the originator's underwritten
NOI at issuance, respectively.

Fitch's 'Bsf' rating case loss of 13.4% (prior to concentration
adjustments) is based on an 11.50% cap rate and 10% stress to the
YE 2022 NOI, and factors in an increased probability of default due
to anticipated refinance concerns.

The largest contributor to overall pool loss expectations in the
COMM 2015-LC19 transaction is the Central Plaza loan (7.8%), which
is secured by an 888,061-sf office property located in the
Koreatown neighborhood of Los Angeles, CA. The property has
sustained lower operating performance as occupancy has fallen
further to 53% as of June 2024 from 56% at YE 2023, and remains
below the occupancy of 64% at issuance. The servicer-reported NOI
DSCR was 1.55x for the YE 2023 reporting period, compared to 1.64x
at YE 2022 and 1.64x at YE 2019.

Fitch's 'Bsf' rating case loss of 19.9% (prior to concentration
adjustments) reflects a 10% cap rate and 15% stress to the YE 2023
NOI, and factors in an increased probability of default to account
for the heightened maturity default concerns.

The second largest contributor to overall pool loss expectations in
the COMM 2015-LC19 transaction is the Decorative Center Houston
loan (4.2%), which is secured by a 504,416-sf office/design center
located in Houston, TX. Tenancy at the property is granular as no
individual tenant accounts for greater than 2.7% of the NRA.
Occupancy and NOI DSCR have both declined to 58.5% and 1.17x,
respectively, for YE 2023, compared to 85% and 1.39x, respectively,
at YE 2022, and 77% and 1.54x, respectively, at YE 2019. Per the
December 2023 rent roll, upcoming rollover includes 11 leases
accounting for 5.5% of the NRA in 2024, 12 leases for 8.2% in 2025
and 12 leases for 11.4% in 2026.

Fitch's 'Bsf' rating case loss of 26% (prior to concentration
adjustments) reflects an 11.25% cap rate, 10% stress to the YE 2023
NOI and factors an increased probability of default due to the
loan's heightened maturity default concerns.

The largest increase in loss since the prior rating action and the
largest contributor to overall loss expectations in COMM
2016-CCRE28 is the 1155 Market Street loan (6.0%), which is secured
by a 103,487-sf office property located in downtown San Francisco,
CA. The loan transferred to special servicing in March 2024 after
the sole tenant, City and County of San Francisco, vacated in May
2024. A resolution to extend the lease on a five-year lease term
through January 2028 was rejected by the municipality.

According to CoStar, the subject is located in the Midmarket
submarket of San Francisco, which reported a vacancy rate of 23.9%
and an availability rate of 35%. Average asking rents in the
submarket were $48.59 psf, compared to the former single tenant's
in-place rent of $49.58 psf.

Fitch's 'Bsf' rating case loss of 36.6% (prior to concentration
adjustments) reflects a 10% cap rate and a 40% stress to the YE
2023 NOI, and factors an increased probability of default due to
the departure of the single tenant coupled with leasing challenges
in the submarket.

The next largest increase in loss since the prior rating action and
second largest contributor to overall loss expectations in COMM
2016-CCRE28 is the Promenade Gateway loan (7.6%), which is secured
by a 132,443-sf mixed-use property located in Santa Monica, CA that
is comprised of 102,396 sf of retail/commercial space and 32
multifamily units. Major tenants include Luma Pictures (23.1% of
the commercial space; November 2029 lease expiration) and AMC
Theaters (21.4%; October 2024).

Commercial space occupancy declined to approximately 85% after
WeWork (13.7%) vacated prior to its March 2035 lease expiration.
Occupancy at the multifamily portion of the collateral has improved
to 93.8% as of March 2024 from 87.5% at June 2023 and 68.8% at
April 2020.

Per the March 2024 rent roll, 21.4% of the NRA is scheduled to roll
in 2024 and 11.5% is expected to roll in 2025. The loan has a
December 2025 maturity.

Fitch's 'Bsf' rating case loss of 13.7% (prior to concentration
adjustments) reflects a 9% cap rate and a 20% stress to the YE 2023
NOI and factors an increased probability of default to account for
the loan's heightened maturity default concerns.

The third largest increase in loss since the prior rating action
and third largest contributor to loss expectations in COMM
2016-CCRE28 is the 32 Avenue of the Americas loan (7.2%), which is
secured by a 1.2 million-sf office/data center located 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
1Q24 from 60.5% at YE 2023, and remains below the 70% at YE 2022
and 89% at YE 2020. Due to the occupancy declines, NOI DSCR was
slightly above a 1.00x coverage for the 1Q24 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 9.5% 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 next largest contributor to loss in COMM 2016-CCRE28 is the
19925 Stevens Creek loan (3.3%), which is secured by a 74,984-sf
office property located in Cupertino, CA. Occupancy declined after
the second largest tenant, American Executive Center (23.4% of the
NRA), vacated at their November 2023 lease expiration. The
remaining tenant, Apple, which accounts for 76.6% of the NRA, has
an upcoming lease expiration in August 2025. Due to the occupancy
decline, the NOI DSCR has fallen to 1.05x for the YTD June 2024
reporting period from 1.72x at YE 2023 and 1.77x at YE 2022.

Fitch's 'Bsf' rating case loss of 24.8% (prior to concentration
adjustments) includes a 10% cap rate and 10% stress to the YE 2023
NOI, and factors in the loan's heightened maturity default
concerns.

Changes to Credit Enhancement (CE): As of the October 2024
distribution date, aggregate balances of COMM 2015-LC19 and COMM
2016-CCRE28 have been reduced by 28.9% and 22.8%, respectively.
Defeasance comprises 12 loans (19.3% of the pool) in COMM 2015-LC19
and nine loans (19.5%) in COMM 2016-CCRE28.

Realized losses and interest shortfalls of $6.3 million and $1.1
million, respectively, are impacting the non-rated class H in COMM
2015-LC19, and $9.4 million and $1.2 million, respectively, are
impacting the non-rated class J in COMM 2016-CCRE28.

RATING SENSITIVITIES

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

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

Downgrades to the 'AAsf' and 'Asf' rated categories, especially
classes with Negative Outlooks, could occur with further
performance deterioration and/or lack of stabilization of the
FLOCs, including Central Plaza, TPI Hospitality and Decorative
Center Houston in COMM 2015-LC19, and Promenade Gateway, 32 Avenue
of the Americas, Equitable City Center, Phoenix Center, Element LA,
19925 Stevens Creek, Hall Office Park - A2 and/or 888 Prospect in
COMM 2016-CCRE28.

Downgrades to 'BBBsf' and 'Bsf' rated categories in COMM 2015-LC19
and 'BBBsf' and 'BBsf' rated categories in COMM 2016-CCRE28 could
occur with additional performance declines of the aforementioned
FLOCS as well as the loans in special servicing, including 56-15
Northern Boulevard in COMM 2015-LC19 and 1115 Market Street in COMM
2016-CCRE28.

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

Upgrades to 'AAsf' and 'Asf' rated categories would occur with
continued improvement in CE from defeasance, amortization and/or
loan paydowns, as well as performance improvement of the FLOCs
including Central Plaza, TPI Hospitality and Decorative Center
Houston in COMM 2015-LC19, and Promenade Gateway, 32 Avenue of the
Americas, Equitable City Center, Phoenix Center, Element LA, 19925
Stevens Creek, Hall Office Park - A2 and 888 Prospect in COMM
2016-CCRE28.

Upgrades to 'BBBsf' and 'Bsf' rated categories in COMM 2015-LC19
and 'BBBsf' and 'BBsf' rated categories in COMM 2016-CCRE28 rated
categories could occur with performance improvements of the
aforementioned FLOCs as well as better recovery prospects of the
loans in special servicing, including 56-15 Northern Boulevard in
COMM 2015-LC19 and 1115 Market Street in COMM 2016-CCRE28.

Upgrades to distressed classes are not expected but would only
occur with better than expected recoveries on specially serviced
loans.

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

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

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' means ESG
issues are credit-neutral or have only a minimal credit impact on
the entity, either due to their nature or the way in which they are
being managed by the entity. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.


CSTL COMMERCIAL 2024-GATE: Fitch Assigns BB-sf Rating on HRR Certs
------------------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to CSTL
Commercial Mortgage Trust 2024-GATE, Commercial Mortgage
Pass-Through Certificates, Series 2024-GATE as follows:

- $272,400,000 class A 'AAAsf'; Outlook Stable;

- $47,300,000 class B 'AA-sf'; Outlook Stable;

- $37,100,000 class C 'A-sf'; Outlook Stable;

- $52,400,000 class D 'BBB-sf'; Outlook Stable;

- $30,650,000 class E 'BBsf'; Outlook Stable;

- $23,150,000(a) class HRR 'BB-sf'; Outlook Stable.

(a) Horizontal risk retention interest representing at least 5.0%
of the fair value of all classes.

The ratings are based on information provided by the issuer as of
Oct. 22, 2024.

Transaction Summary

The certificates represent the beneficial interests in a trust that
holds a five-year, fixed-rate, interest-only mortgage loan. The
mortgage is secured by the borrowers' fee simple and leasehold
interests in nine multifamily properties with a total of 2,806
units located across six states. The portfolio is 95.0% leased as
of the September 2024 rent rolls.

Loan proceeds coupled with $70.0 million in mezzanine loan proceeds
were used to pay off $506.0 million in debt, pay tax abatement
filing fees, fund a $2.3 million upfront abated real estate tax
reserve, pay closing costs and return approximately $8.1 million in
cash equity to the sponsor.

The loan is originated by Citi Real Estate Funding Inc. Midland
Loan Services, a Division of PNC Bank, National Association will
act as servicer, and Argentic Services Company LP is will act as
special servicer. Wilmington Savings Fund Society, FSB will act as
trustee, and Citibank, N.A. will act as certificate administrator.
Park Bridge Lender Services LLC will act as operating advisor. The
certificates follow a standard senior-sequential paydown
structure.

KEY RATING DRIVERS

Fitch Net Cash Flow: Fitch's stressed net cash flow (NCF) for the
portfolio is estimated at $38.0 million. This is 6.5% lower than
the issuer's NCF and 11.2% above the TTM ended in August 2024 NCF.
Fitch's NCF is higher than the TTM ended in August 2024 NCF due to
lower real estate taxes as a result of four properties entering
into tax abatement programs. Assuming full unabated real estate
taxes, Fitch's NCF would be 0.1% below the TTM ended in August 2024
NCF. Fitch applied a 7.5% cap rate, resulting in a Fitch value of
approximately $506.7 million.

Fitch Leverage: The $463.0 million total mortgage loan ($165,004
per unit) has a Fitch-stressed debt service coverage ratio (DSCR),
loan-to-value (LTV) ratio and debt yield (DY) of 0.97x, 91.4% and
8.2%, respectively. Based on total debt of $533.0 million ($189,950
per unit), inclusive of the $70.0 million mezzanine loan, the
Fitch-stressed DSCR, LTV and DY are 0.84x, 105.2% and 7.1%,
respectively. The mortgage loan represents approximately 62.7% of
the portfolio appraised value of $738.3 million. The total debt
represents approximately 72.2% of the portfolio appraised value.

Geographically Diverse Portfolio: The portfolio is secured by 2,806
units distributed among nine garden-style multifamily properties
located in six states across eight markets. The largest property
contains 13.7% of the units and 13.3% of the allocated loan amount
(ALA). No other property constitutes more than 13.5% of the total
units or 12.6% of the ALA. No state or market represents more than
29.5% of the ALA. The portfolio's effective geographic count is
7.4.

Institutional Sponsorship and Management: The loan sponsor and
property manager, West Shore, is a fully integrated real estate
investment firm focused on the acquisition and management of
multifamily assets. West Shore currently owns and operates a
portfolio comprising more than 15,000 units across 46 multifamily
properties. West Shore's portfolio spans the U.S., with a focus on
the Sunbelt region. Led by Steve and Lee Rosenthal, who have
decades of experience in the multifamily market, West Shore has
raised over $1.0 billion across six funds. Investors in these funds
include ultra-high net worth individuals and family offices.

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'/'BBsf'/'BB-sf';

- 10% NCF Decline: 'AAsf'/'A-sf'/'BBB-sf'/'BBsf'/'BB-sf'/'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'/'BBB-sf'/'BBsf'/'BB-sf';

- 10% NCF Increase:
'AAAsf'/'AAsf'/'A+sf'/'BBBsf'/'BBB-sf'/'BB+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 PricewaterhouseCoopers LLP. The third-party due
diligence described in Form 15E focused on a comparison and
re-computation of certain characteristics with respect to the
mortgage loan. Fitch considered this information in its analysis
and it did not have an effect on its analysis or conclusions.

ESG Considerations

Fitch increased the ESG score for exposure to environmental impacts
to '3' from '2' due to four properties in the portfolio (44.9% of
ALA) being located in a Tier 1 wind zone, including Preserve at
Godley Station (13.3% of ALA), Uptown Village (11.6%), Parker at
East Village (11.1%) and 17 South (8.9%).

The loan's insurance policy includes wind/named storm coverage for
full location limits up to a maximum loss limit of $100.0 million,
which applies per occurrence and reinstates after every loss.
Resilience Insurance Analytics considered an aggregate probable
maximum loss (PML) for the four properties located in Tier 1 wind
zones across a range of scenarios, including 500-year ($15.0
million PML), 1,000-year ($21.9 million PML), 5,000-year ($43.7
million PML) and 10,000-year return periods ($56.2 million PML).
The maximum loss limit for wind/named storms compares favorably to
all four scenarios.

Hurricane Helene made landfall in the eastern Florida Panhandle on
Sept. 26, 2024, and Hurricane Milton made landfall in central west
Florida on Oct. 9, 2024. Six properties in the portfolio —
Preserve at Godley Station, Slate Nexton, Uptown Village, Parker at
East Village, 17 South, and Vantage at Wildewood — are located in
affected areas. The borrower confirmed the properties are
operational and did not suffer any major damage as a result of the
storms.

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.


DANBY PARK: S&P Assigns BB- (sf) Rating on Class E-R Notes
----------------------------------------------------------
S&P Global Ratings assigned its ratings to the class B-1-R, B-2-R,
C-R, D-1-R, D-2-R, and E-R replacement debt from Danby Park CLO
Ltd./Danby Park CLO LLC, a CLO originally issued in November 2022
that is managed by Blackstone Liquid Credit Strategies LLC. At the
same time, S&P withdrew its ratings on the original class A-2, B,
C, D, and E debt following payment in full on the Oct. 21, 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 Oct. 21, 2026.

-- The reinvestment period was extended to Oct. 21, 2029.

-- The legal final maturity dates (for the replacement debt and
the existing subordinated notes) was extended to Oct. 21, 2037.

-- The target initial par amount remains at $400 million. There is
no additional effective date or ramp-up period, and the first
payment date following the refinancing is Jan. 21, 2025.

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

-- No additional subordinated notes were 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."

  Ratings Assigned

  Danby Park CLO Ltd./Danby Park CLO LLC

  Class B-1-R, $39.00 million: AA (sf)
  Class B-2-R, $5.00 million: AA (sf)
  Class C-R (deferrable), $28.00 million: A (sf)
  Class D-1-R (deferrable), $20.00 million: BBB- (sf)
  Class D-2-R (deferrable), $4.00 million: BBB- (sf)
  Class E-R (deferrable), $14.00 million: BB- (sf)

  Ratings Withdrawn

  Danby Park CLO Ltd./Danby Park CLO LLC

  Class A-2 to NR from 'AA+ (sf)'
  Class B to NR from 'AA (sf)'
  Class C (deferrable) to NR from 'A (sf)'
  Class D (deferrable) to NR from 'BBB- (sf)'
  Class E (deferrable) to NR from 'BB- (sf)'

  Other Debt

  Danby Park CLO Ltd./Danby Park CLO LLC

  Class A-R, $256.00 million: NR
  Subordinated notes, $29.35 million: NR

  NR--Not rated.



DBGS 2019-1735: S&P Affirms B (sf) Rating on Class F Certs
----------------------------------------------------------
S&P Global Ratings affirmed its ratings on seven classes of
commercial mortgage pass-through certificates from DBGS 2019-1735
Mortgage Trust, a U.S. CMBS transaction.

This is a U.S. standalone (single-borrower) CMBS transaction that
is backed by a 10-year, fixed rate, interest-only (IO) mortgage
loan secured by the borrower's fee-simple interest in 1735 Market
Street, a 53-story, 1.3 million sq. ft. class A office building in
Philadelphia.

Rating Actions

The affirmations on classes A, B, C, D, E, and F primarily reflect
(despite our model indicating a lower rating on class B due to
rounding differences between the required enhancement levels and
the class's actual enhancement level):

-- The property's occupancy remaining relatively unchanged. While
there is subleasing activity and the office submarket fundamentals
remain challenged, the property continues to perform at the
submarket occupancy rates, with spaces being marketed for sublease
and vacant spaces backfilled. Rental rates at the property have
increased and are above market rates. The servicer reported
improvement in cash flow for year-end 2023 to $28.7 million and the
six months ending June 2024 to $14.8 million, compared to 2022,
when it was $24.8 million.

-- The expected improvement in occupancy rate at the property to
approximately 87.0% in the near-term based on known tenant
movements, compared to 81.0% as of the June 2024 rent roll.
Although the office fundamentals within the Market Street West
submarket remain challenged, the property's ability to re-tenant
vacant space is a laudable.

-- The manageable lease rollover risk at the property through the
loan's maturity date in April 2029 and the diverse tenant base,
with the largest tenant (Ballard Spahr LLP; lease expiration 2031)
making up just 13.1% of the square footage.

-- S&P's expected-case valuation for the property, which has
remained the same as the valuation it derived at issuance in 2019
and during our last review in June 2023.

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

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

Property-Level Analysis

The loan collateral is a 53-story, 1.3 million sq. ft. class A
office building located at 1735 Market Street in Philadelphia's
central business district. The property, built in 1990, has a
176-space parking garage and features The Pyramid Club, a private
social club, on the 52nd floor. According to the appraiser at
issuance, it is the only trophy-quality multitenant office building
that has direct interior concourse access to SEPTA Suburban
Station, the city's primary commuter rail station in the submarket
area. Amenities at the property, which are on the fifth floor,
include a bar, lockers, outdoor seating, a coffee station, games, a
fitness center, and conference rooms.

S&P said, "In our last review, in June 2023, while the property was
88.0% occupied using the March 2023 rent roll, down from 92.2% at
issuance, we considered the weakened office submarket fundamentals
by utilizing a 17.7% vacancy rate, an S&P Global Ratings gross rent
of $40.47 per sq. ft., and a 38.8% operating expense ratio to
arrive at our long-term sustainable net cash flow (NCF) of $24.4
million. Using a 7.0% S&P Global Ratings capitalization rate, we
arrived at an expected-case valuation of $348.3 million, or $271.00
per sq. ft.

"As of the June 2024 rent roll, the property was 81.0% occupied.
However, after accounting for two new tenants, HKA Global (1.2% of
net rentable area [NRA]; starting in April 2025; lease expiration
in November 2032) and Saul Ewing LLP (4.7%; June 2025; January
2042), that have recently signed leases at the property, we expect
occupancy to increase to approximately 87.0% by mid-2025. We noted
that Saul Ewing LLP is leasing the majority of the space previously
occupied by UBS Financial Services Inc., which downsized at the
property to 22,625 sq. ft. from 31,306 sq. ft. According to the
master servicer, KeyBank Real Estate Capital, HKA Global has a
lease termination option effective November 2030, while Saul Ewing
has lease termination rights effective on the 10th anniversary date
following rent commencement."

After including known tenant movements, the five largest tenants,
which comprise 36.0% of NRA, are:

-- Ballard Spahr LLP (13.1% of NRA; 15.9% of in-place gross rent;
January 2031 lease expiration).

-- Willis Towers Watson US LLC (7.6%; 8.3%; February 2031).

-- According to the master servicer, the tenant's entire space has
been sublet to KPMG until January 2031.

-- Montgomery McCracken Walker (5.5%; 6.2%; May 2034).

-- Brandywine Global Investment (5.2%; 5.8%; June 2028).

-- Saul Ewing LLP (4.7%; 3.8%; January 2042).

The property has minimal (less than 10.0% of NRA) lease rollover
risk through 2027 and about 11.6% of leases, measured by NRA,
expiring in 2028. The majority of the rollover in 2028 is from
Brandywine Global Investment. While the property has manageable
rollover risk through the loan's maturity in April 2029, there is
concentrated rollover risk in 2030 (11.0% of NRA) and 2031 (25.9%
of NRA), which S&P believes may affect the sponsor's ability to
refinance the loan if it is unable to renew or attract new tenants
to the property.

According to CoStar, the Market Street West office submarket, where
the property is located, still faces elevated vacancy and
availability rates. CoStar noted that the submarket's available
inventory has stabilized at around 8 million sq. ft. (against a
total office inventory of about 41 million sq. ft.). However, it
also noted that nearly 2 million sq. ft. of office space are
scheduled to expired over the next two years, potentially adding to
the submarket's vacancy rate. The reported vacancy rate for 4- and
5-star office properties in the submarket was 17.4%, the
availability rate was 22.1%, and asking rent was $36.59 per sq. ft.
as of year-to-date October 2024. CoStar projects the vacancy rate
for 4- and 5-star office properties to increase to 17.4% by 2028
and asking rent to increase modestly to $38.26 per sq. ft. for the
same period .

S&P said, "Considering the property's performance trends and the
office submarket metrics, in our current analysis, we assumed a
17.8% vacancy rate (in line with the current submarket vacancy rate
for like-quality office properties), a $46.28 per sq. ft. S&P
Global Ratings in-place gross rent, a 42.3% operating expense
ratio, and higher tenant improvement costs to arrive at a NCF of
$24.4 million, the same as in our last review and at issuance.
While our assumed occupancy rate has declined since issuance, it is
offset by the higher rental rates at the property. Utilizing an S&P
Global Ratings capitalization rate of 7.00% (unchanged from last
review and at issuance), we derived an S&P Global Ratings
expected-case value of $348.3 million, or $271.00 per sq. ft. While
this is unchanged from our last review and at issuance, it is 20.9%
below the issuance appraisal value of $440.3 million. This yielded
an S&P Global Ratings loan-to-value ratio of 89.4%."

  Table 1

  Servicer-reported collateral performance

                      Six months ending
                      June 30, 2024(i)  2023(i)  2022(i)  2021(i)

  Occupancy rate (%)           81.0     85.4     88.0     82.9

  Net cash flow (mil. $)       14.8     28.7     24.8     28.6

  Debt service coverage (x)    2.21     2.16     1.87     2.15
  
  Appraisal value (mil. $)    440.3    440.3    440.3    440.3

  (i)Reporting period.

  Table 2

  S&P Global Ratings' key assumptions

                           Current     Last review  Issuance
                          (Oct 2024)  (June 2023)  (April 2019)
                              (i)         (i)           (i)

  Assumed occupancy rate (%)   82.2         82.3          89.0

  Net cash flow (mil. $)       24.4         24.4          24.4

  Capitalization rate (%)       7.0          7.0           7.0

  Value (mil. $)              348.3        348.3         348.3

  Value per sq. ft. ($)      271.00       271.00        271.00

  Loan-to-value ratio (%)      89.4         89.4          89.4

(i)Review period.

Transaction Summary

The 10-year, fixed-rate IO mortgage loan had an initial and current
balance of $311.4 million (as of the October 2024 trustee
remittance report), pays a per annum interest rate of 4.21%, and
matures on April 6, 2029. There is no additional subordinate debt.
According to the October 2024 reserve report, there are currently
no funds held in reserves by the servicer.

The loan has a reported current payment status through its October
2024 payment date and is currently not on the master servicer's
watchlist. However, the loan, as recently as September 2024, was on
the servicer watchlist due to water damage caused by Hurricane Ida
in the lowest level of the parking garage, where the mechanical
equipment is located. It is our understanding that the repair work
has been completed.

To date, the trust has not incurred any principal losses.

  Ratings Affirmed

  DBGS 2019-1735 Mortgage Trust
  
  Class A: AAA (sf)
  Class B: AA- (sf)
  Class C: A- (sf)
  Class D: BBB- (sf)
  Class E: BB- (sf)
  Class F: B (sf)
  Class X: A- (sf)



DIAMETER CAPITAL 1: S&P Assigns Prelim BB-(sf) Rating on D-R Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Diameter
Capital CLO 1 Ltd./Diameter Capital CLO 1 LLC's floating-rate debt.
This is a proposed refinancing of a July 2021 transaction, which
S&P Global Ratings did not originally rate.

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 Diameter CLO Advisors LLC.

The preliminary ratings are based on information as of Oct. 22,
2024. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

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

-- The diversification of the collateral pool;

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

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

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

  Preliminary Ratings Assigned

  Diameter Capital CLO 1 Ltd./Diameter Capital CLO 1 LLC

  Class A-1-R, $341.00 million: AAA (sf)
  Class A-2-R, $77.00 million: AA (sf)
  Class B-R (deferrable), $33.00 million: A (sf)
  Class C-R (deferrable), $30.25 million: BBB- (sf)
  Class D-R (deferrable), $22.00 million: BB- (sf)
  Subordinated notes, $47.00 million: Not rated



DIAMETER CAPITAL 2: S&P Assigns Prelim BB-(sf) Rating on D-R Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the class
A-1-R, A-2-R, B-R, C-R, and D-R replacement debt from Diameter
Capital CLO 2 Ltd./Diameter Capital CLO 2 LLC, a CLO originally
issued in October 2021 that is managed by Diameter CLO Advisors
LLC.

The preliminary ratings are based on information as of Oct. 22,
2024. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the Oct. 24, 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-1-R, A-2-R, B-R, C-R, and D-R debt are
expected to be issued at floating spreads, replacing the current
floating spreads.

-- The stated maturity will be extended to October 2037, and the
reinvestment period will be extended to October 2029.

-- The non-call period will be extended to Oct. 24, 2026.

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

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

-- The required minimum overcollateralization and interest
coverage ratios will be amended.

-- $9.5 million in 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

  Diameter Capital CLO 2 Ltd./Diameter Capital CLO 2 LLC

  Class A-1-R, $341.00 million: AAA (sf)
  Class A-2-R, $77.00 million: AA (sf)
  Class B-R (deferrable), $33.00 million: A (sf)
  Class C-R (deferrable), $30.25 million: BBB- (sf)
  Class D-R (deferrable), $22.00 million: BB- (sf)

  Other Debt

  Diameter Capital CLO 2 Ltd./Diameter Capital CLO 2 LLC

  Subordinated notes, $48.35 million: Not rated



DRYDEN 113: Fitch Assigns 'BB-sf' Rating on Class E-R2 Notes
------------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to the
Dryden 113 CLO, Ltd. reset transaction.

   Entity/Debt            Rating                Prior
   -----------            ------                -----
Dryden 113 CLO, Ltd.

   A-R2               LT AAAsf  New Rating
   B-R 26253EAT5      LT PIFsf  Paid In Full   AAsf     
   B-R2               LT AAsf   New Rating
   C-R 26253EAV0      LT PIFsf  Paid In Full   A+sf
   C-R2               LT Asf    New Rating
   D-1R2              LT BBB-sf New Rating
   D-2R2              LT BBB-sf New Rating
   D-R 26253EAX6      LT PIFsf  Paid In Full   BBBsf
   E-R 26253GAE3      LT PIFsf  Paid In Full   BB+sf
   E-R2               LT BB-sf  New Rating

Transaction Summary

Dryden 113 CLO, Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that is managed by PGIM, Inc.
It originally closed on November 2022 and refinanced on October
2023. Net proceeds from the issuance of the secured and
subordinated notes will provide financing on a portfolio of
approximately $396 million (excluding defaulted obligations) 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 21.98 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
94.75% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 75.57% versus a
minimum covenant, in accordance with the initial expected matrix
point of 68.2%.

Portfolio Composition (Positive): The largest three industries may
comprise up to 50% 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 three-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-R2, between
'BB+sf' and 'A+sf' for class B-R2, between 'BB-sf' and 'BBB+sf' for
class C-R2, between less than 'B-sf' and 'BB+sf' for class D-1R2,
between less than 'B-sf' and 'BB+sf' for class D-2R2, and between
less than 'B-sf' and 'B+sf' for class E-R2.

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

Upgrade scenarios are not applicable to the class A-R2 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-R2, 'AAsf' for class C-R2, 'A-sf'
for class D-1R2, 'BBB+sf' for class D-2R2, and 'BBB-sf' for class
E-R2.

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

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

DATA ADEQUACY

The majority of the underlying assets or risk-presenting entities
have ratings or credit opinions from Fitch and/or other NRSROs
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 Dryden 113 CLO,
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.


EMPOWER CLO 2022-1: S&P Assigns BB- (sf) Rating on Class E-R Notes
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to Empower CLO 2022-1
Ltd./Empower CLO 2022-1 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 Empower Capital Management LLC, an
indirect subsidiary of Empower Annuity Insurance Co. of America.
This is a reset of the original transaction issued in 2022, which
S&P Global Ratings did not rate.

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
  Empower CLO 2022-1 Ltd./Empower CLO 2022-1 LLC

  Class A-1R, $310.00 million: AAA (sf)
  Class A-2R, $20.00 million: AAA (sf)
  Class B-R, $50.00 million: AA (sf)
  Class C-R (deferrable), $30.00 million: A (sf)
  Class D-1R (deferrable), $27.50 million: BBB (sf)
  Class D-2R (deferrable), $7.50 million: BBB- (sf)
  Class E-R (deferrable), $15.00 million: BB- (sf)
  Subordinated notes, $38.70 million: Not rated



FIGRE TRUST 2024-HE5: DBRS Gives Prov. B(low) Rating on F Notes
---------------------------------------------------------------
DBRS, Inc. assigned provisional credit ratings to the following
Mortgage-Backed Notes, Series 2024-HE5 (the Notes) to be issued by
FIGRE Trust 2024-HE5 (FIGRE 2024-HE5 or the Trust):

-- $341.6 million Class A at (P) AAA (sf)
-- $30.2 million Class B at (P) AA (low) (sf)
-- $28.8 million Class C at (P) A (low) (sf)
-- $14.2 million Class D at (P) BBB (low) (sf)
-- $17.4 million Class E at (P) BB (low) (sf)
-- $17.4 million Class F at (P) B (low) (sf)

The (P) AAA (sf) credit rating on the Class A Notes reflects 26.50%
of credit enhancement provided by subordinate notes. The (P) AA
(low) (sf), (P) A (low) (sf), (P) BBB (low) (sf), (P) BB (low)
(sf), and (P) B (low) (sf) credit ratings reflect 20.00%, 13.80%,
10.75%, 7.00%, and 3.25% of credit enhancement, respectively.

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

Morningstar DBRS assigned provisional credit ratings to FIGRE
2024-HE5, a securitization of recently originated first- and
junior-lien revolving home equity lines of credit (HELOCs) funded
by the issuance of the Notes. The Notes are backed by 6,675 loans
(individual HELOC draws), which correspond to 6,192 HELOC families
(each consisting of an initial HELOC draw and subsequent draws by
the same borrower) with a total unpaid principal balance (UPB) of
$464,810,939 and a total current credit limit of $496,951,709 as of
the Cut-Off Date (September 30, 2024).

The portfolio, on average, is three months seasoned, though
seasoning ranges from one to 31 months. All of the HELOCs are
current and have been performing since origination. All of the
loans in the pool are exempt from the Consumer Financial Protection
Bureau Ability-to-Repay (ATR)/Qualified Mortgage (QM) rules because
HELOCs are not subject to the ATR/QM rules.

Figure is a wholly owned, indirect subsidiary of Figure
Technologies, Inc. (Figure Technologies) that was formed in 2018.
Figure Technologies is a financial services and technology company
that leverages blockchain technology for the origination and
servicing of loans, loan payments, and loan sales. In addition to
the HELOC product, Figure has offered several different lending
products within the consumer lending space including student loan
refinance, unsecured consumer loans, and conforming first-lien
mortgage. In June 2023, the company launched a wholesale channel
for its HELOC product. Figure originates and services loans in 48
states and the District of Columbia. As of October 2024, Figure
originated, funded, and serviced more than 159,000 HELOCs totaling
approximately $11.9 billion.

Figure is the Originator of most and the Servicer of all HELOCs in
the pool. Other originators in the pool are Figure Wholesale and
certain other lenders (together, the White Label Partner
Originators). The White Label Partner Originators originated HELOCs
using Figure's online origination applications under Figure's
underwriting guidelines. Also, Figure is the Seller of all the
HELOCs. Morningstar DBRS performed a telephone operational risk
review of Figure's origination and servicing platform and believes
the Company is an acceptable HELOC originator and servicer with a
backup servicer that is acceptable to Morningstar DBRS.

Figure is the transaction's Sponsor. FIGRE 2024-HE5 is the ninth
rated securitization of HELOCs by the Sponsor. Also,
Figure-originated HELOCs are included in five securitizations
sponsored by Saluda Grade. These transactions' performances to date
are satisfactory.

The transaction includes mostly junior liens (primarily second
liens) and some first-lien HELOCs.

In this transaction, all loans except one are open HELOCs that have
a draw period of two, three, four, or five years during which
borrowers may make draws up to a credit limit, though such right to
make draws may be temporarily frozen, suspended, or terminated
under certain circumstances. At the end of the draw term, the HELOC
mortgagors have a repayment period ranging from three to 25 years.
During the repayment period, borrowers are no longer allowed to
draw, and their monthly principal payments will equal an amount
that allows the outstanding loan balance to evenly amortize down.
All HELOCs in this transaction are fixed-rate loans. The HELOCs
have no interest-only payment period, so borrowers are required to
make both interest and principal payments during the draw and
repayment periods. No loans require a balloon payment.

The loans are made mainly to borrowers with prime and near-prime
credit quality who seek to take equity cash out for various
purposes. These HELOCs are fully drawn at origination, as evidenced
by the weighted-average (WA) utilization rate by current line
amount of approximately 97.2% after three months of seasoning on
average. For each borrower, the HELOC, including the initial and
any subsequent draws, is defined as a loan family within which
every new credit line draw becomes a de facto new loan with a new
fixed interest rate determined at the time of the draw by adding
the margin determined at origination to the then-current prime
rate.

Relative to other HELOCs in Morningstar DBRS-rated deals, the loans
in the pool are all fixed rate, fully amortizing with a shorter
draw period, and may have terms significantly shorter than 30
years, including five- to 10-year maturities.

Certain Unique Factors in HELOC Origination Process

Figure seeks to originate HELOCs for borrowers of prime and
near-prime credit quality with ample home equity. It leverages
technology in underwriting, title searching, regulatory compliance,
and other lending processes to shorten the approval and funding
process and improve the borrower experience. Below are certain
aspects in the lending process that are unique to Figure's
origination platform:

-- To qualify a borrower for income, Figure seeks to confirm the
borrower's stated income using proprietary technology algorithms.

-- The lender uses the FICO 9 credit score model instead of the
classic FICO credit score model used by most mortgage originators.

-- Instead of title insurance, Figure uses an electronic lien
search algorithm to identify existing property liens.

-- Instead of a full property appraisal, Figure uses a property
valuation provided by an automatic valuation model (AVM), or in
some cases where an AVM is not available or is ineligible, a broker
price opinion (BPO) or a residential evaluation.

The credit impact of these factors is generally loan specific.
Although technologically advanced, the income, employment, and
asset verification methods used by Figure were treated as less than
full documentation in the RMBS Insight model. In addition,
Morningstar DBRS applied haircuts to the provided AVM and BPO
valuations, reduced the projected recoveries on junior-lien HELOCs,
and generally stepped up expected losses from the model to account
for a combined effect of these and other factors. Please see the
Documentation Type and Underwriting Guidelines sections of the
related report for details.

Transaction Counterparties

Figure will service all loans within the pool for a servicing fee
of 0.25% per year. Also, Newrez LLC doing business as Shellpoint
Mortgage Servicing (Shellpoint) will act as a Subservicer for loans
that default or become 60 or more days delinquent under the
Mortgage Bankers Association (MBA) method. In addition, Northpointe
Bank (Northpointe) will act as a Backup Servicer for all mortgage
loans in this transaction for a fee of 0.01% per year. If Figure
fails to remit the required payments, fails to observe or perform
the Servicer's duties, or experiences other unremedied events of
default described in detail in the transaction documents, servicing
will be transferred to Northpointe from Figure, under a successor
servicing agreement. Such servicing transfer will occur within 45
days of Figure's termination. In the event of a servicing transfer,
Shellpoint will retain servicing responsibilities on all loans that
were being special serviced by Shellpoint at the time of the
servicing transfer. Morningstar DBRS performed an operational risk
review of Northpointe's servicing platform and believes the company
is an acceptable loan servicer for Morningstar DBRS-rated
transactions.

The Bank of New York Mellon will serve as Indenture Trustee, Paying
Agent, Note Registrar, Certificate Registrar, and REMIC
Administrator. Wilmington Savings Fund Society, FSB will serve as
the Custodian and the Owner Trustee. DV01, Inc. will act as the
loan data agent.

The Sponsor or a majority-owned affiliate of the Sponsor will
acquire and intends to retain an eligible vertical interest
consisting of the required percentage of the Class A, B, C, D, E,
F, and CE Note amounts and Class FR Certificate to satisfy the
credit risk-retention requirements under Section 15G of the
Securities Exchange Act of 1934 and the regulations promulgated
thereunder. The Sponsor or a majority-owned affiliate of the
Sponsor will be required to hold the required credit risk until the
later of (1) the fifth anniversary of the Closing Date and (2) the
date on which the aggregate loan balance has been reduced to 25% of
the loan balance as of the Cut-Off Date, but in any event no longer
than the seventh anniversary of the Closing Date.

Similar to other transactions backed by junior-lien mortgage loans
or HELOCs, but different from certain Morningstar DBRS-rated FIGRE
transactions, the HELOCs that are 180 days delinquent under the MBA
delinquency method may not be charged off by the Servicer in its
discretion. In its analysis, Morningstar DBRS assumes all
junior-lien HELOCs that are 180 days delinquent under the MBA
delinquency method will be charged off.

Draw Funding Mechanism

This transaction uses a structural mechanism similar to other HELOC
transactions to fund future draw requests. The Servicer will be
required to fund draws and will be entitled to reimburse itself for
such draws from the principal collections prior to any payments on
the Notes and the Class FR Certificates.

If the aggregate draws exceed the principal collections (Net Draw),
the Servicer is entitled to reimburse itself for draws funded from
amounts on deposit in the Reserve Account (including amounts
deposited into the Reserve Account on behalf of the Class FR
Certificate holder after the Closing Date).

The Reserve Account is funded at closing initially with a rounded
balance of $1,626,838 (0.35% of the aggregate UPB as of the Cut-Off
Date). Prior to the payment date in November 2029, the Reserve
Account Required Amount will be 0.35% of the aggregate UPB as of
the Cut-Off Date. On and after the payment date in November 2029
(after the draw period ends for all HELOCs), the Reserve Account
Required Amount will become $0. If the Reserve Account is not at
target, the Paying Agent will use the available funds remaining
after paying transaction parties' fees and expenses, reimbursing
the Servicer for any unpaid fees or Net Draws, and paying the
accrued and unpaid interest on the bonds to build it to the target.
The top-up of the account occurs before making any principal
payments to the Class FR Certificate holder or the Notes. To the
extent the Reserve Account is not funded up to its required amount
from the principal and interest (P&I) collections, the Class FR
Certificate holder will be required to use its own funds to
reimburse the Servicer for any Net Draws.

Nevertheless, the Servicer is still obligated to fund draws even if
the principal collections and the Reserve Account are insufficient
in a given month for full reimbursement. In such cases, the
Servicer will be reimbursed on subsequent payment dates, first from
amounts on deposit in the Reserve Account (subject to the deposited
funds), and second from the principal collections in subsequent
collection periods. Figure, as a holder of the Trust
Certificate/Class FR Certificates, will have an ultimate
responsibility to ensure draws are funded by remitting funds to the
Reserve Account to reimburse the Servicer for the draws made on the
loans, as long as all borrower conditions are met to warrant draw
funding. The Class FR Certificates' balance will be increased by
the amount of any Net Draws funded by the Class FR Certificate
holder. The Reserve Account's required amount will become $0 on the
payment date in November 2029 (after the draw period ends for all
HELOCs), at which point the funds will be released through the
transaction waterfall.

In its analysis of the proposed transaction structure, Morningstar
DBRS does not rely on the creditworthiness of either the Servicer
or Figure. Rather, the analysis relies on the assets' ability to
generate sufficient cash flows, as well as the Reserve Account, to
fund draws and make interest and principal payments.

Additional Cash Flow Analytics for HELOCs

Morningstar DBRS performs a traditional cash flow analysis to
stress prepayments, loss timing, and interest rates. Generally, in
HELOC transactions, because prepayments (and scheduled principal
payments, if applicable) are primary sources from which to fund
draws, Morningstar DBRS also tests a combination of high draw and
low prepayment scenarios to stress the transaction.

Transaction Structure

The transaction employs a pro rata cash flow structure subject to a
Credit Event, which is based on certain performance triggers
related to cumulative losses and delinquencies. This transaction
differs from certain previous Morningstar DBRS-rated FIGRE
transactions where there is no performance trigger related to Net
WA Coupon (WAC) Rate.

Relative to a sequential pay structure, a pro rata structure
subject to sequential trigger (Credit Event) is more sensitive to
the timing of the projected defaults and losses as the losses may
be applied at a time when the amount of credit support is reduced
as the bonds' principal balances amortize over the life of the
transaction.

Excess cash flows can be used to cover any realized losses and are
then used to maintain overcollateralization (OC) at the target. The
excess interest can be released to the residual holder if the OC is
built to the OC Target so long as the Credit Event does not exist.
Please see the Cash Flow Structure and Features section of the
related report for more details.

Notable Structural Features

Similar to previous Morningstar DBRS-rated FIGRE transactions, this
deal employs a Delinquency Trigger and a Cumulative Loss Trigger.
The effective dates for the triggers may differ from prior rated
transactions. The Delinquency Trigger is applicable on or after the
12th payment date (October 2025) rather than being applicable
immediately after the Closing Date.

Unlike some of the prior FIGRE securitizations that employed a pro
rata pay structure among all rated notes, this transaction includes
rated classes (Class D, Class E, and Class F) that receive their
principal payments after the pro rata classes (Class A, Class B,
and Class C) are paid in full. The inclusion of sequential-pay
classes retains credit support that would otherwise be reduced in
the absence of a credit event.

The OC floor (1.50% of Cut-Off Date balance) is lower than in some
of the prior FIGRE securitizations. However, the Class CE Notes
support the (P) B (low) (sf)-rated Class F Notes, rather than
investment-grade classes in those prior deals, and the Class CE,
Class F, and Class E Notes support the investment-grade classes.

The Reserve Account Required Amount will be 0.35% of the aggregate
UPB as of the Cut-Off Date, lower than the prior FIGRE
securitizations.

Other Transaction Features

For this transaction, other than the Servicer's obligation to fund
any monthly Net Draws, described above, neither the Servicer nor
any other transaction party will fund any monthly advances of P&I
on any HELOC. However, the Servicer is required to make advances in
respect of taxes, insurance premiums, and reasonable costs incurred
in the course of servicing and disposing of properties (servicing
advances) to the extent such advances are deemed recoverable or as
directed by the Controlling Holder (the holder of more than a 50%
interest of the Class CE Notes). For the junior-lien HELOCs, the
Servicer will make servicing advances only if such advances are
deemed recoverable or if the associate first-lien mortgage has been
paid off and such HELOC has become a senior-lien mortgage loan.

The Depositor may, at its option, on or after the earlier of (1)
the payment date on which the balance of the Class A Notes is
reduced to zero, or (2) the date on which the total loans' and real
estate owned (REO) properties' balance falls to or below 25% of the
loan balance as of the Cut-Off Date (Optional Termination Date),
purchase all of the loans and REO properties at the optional
termination price described in the transaction documents.

The Depositor, at its option, may purchase any mortgage loan that
is 90 days or more delinquent under the MBA method at the
repurchase price (Optional Purchase) described in the transaction
documents. The total balance of such loans purchased by the
Depositor will not exceed 10% of the Cut-Off Date balance.

The Servicer, at a direction of the Controlling Holder, may direct
the Issuer to sell (and direct the Indenture Trustee to release its
lien on and relinquish its security interest in) eligible
nonperforming loans (NPLs) (those 120 days or more delinquent under
the MBA method) or REO properties (both eligible NPLs) to third
parties individually or in bulk sales. The Controlling Holder will
have sole authority over the decision to sell the eligible NPLs, as
described in the transaction documents.

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


FLAGSHIP CREDIT 2024-3: S&P Assigns Prelim 'BB-' Rating on E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Flagship
Credit Auto Trust 2024-3's automobile receivables-backed notes.

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

The preliminary ratings are based on information as of Oct. 23,
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 availability of approximately 52.07%, 44.59%, 34.34%,
26.69%, and 20.87% credit support--hard credit enhancement and
haircut to excess spread--for the class A, B, C, D, and E notes,
respectively, based on stressed cash flow scenarios. These credit
support levels provide at least 3.40x, 2.90x, 2.25x, 1.75x, and
1.40x coverage of S&P's expected net loss (ECNL) of 14.50% for the
class A, B, C, D, and E notes, respectively.

-- The expectation that under a moderate ('BBB') stress scenario
(1.75x S&P's expected loss level), all else being equal, its
preliminary 'AAA (sf)', 'AA (sf)', 'A (sf)', 'BBB (sf)', and 'BB-
(sf)' ratings on the class A, B, C, D, and E notes, respectively,
are within the credit stability limits.

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

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

-- The series' bank accounts at UMB Bank N.A., which do not
constrain the preliminary ratings.

-- S&P's operational risk assessment of Flagship Credit Acceptance
LLC (Flagship) as servicer, along with its view of the company's
underwriting and the backup servicing arrangement with UMB Bank.

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

-- The transaction's payment and legal structures.

  Preliminary Ratings Assigned

  Flagship Credit Auto Trust 2024-3

  Class A, $84.64 million: AAA (sf)
  Class B, $18.81 million: AA (sf)
  Class C, $22.69 million: A (sf)
  Class D, $15.67 million: BBB (sf)
  Class E, $11.64 million: BB- (sf)



FORTRESS CREDIT XVI: Fitch Hikes Rating on Class E Notes to 'BB+sf'
-------------------------------------------------------------------
Fitch Ratings has taken the various rating actions following the
partial note refinancing of Fortress Credit BSL XVI Limited.

   Entity/Debt          Rating               Prior
   -----------          ------               -----
Fortress Credit
BSL XVI Limited

   A-1L              LT  AAAsf   Affirmed       AAAsf
   A-1N 349927AA1    LT  PIFsf   Paid In Full   AAAsf
   A-R               LT  AAAsf   New Rating
   B 349927AE3       LT  PIFsf   Paid In Full   AAsf
   B-R               LT  AA+sf   New Rating
   C 349927AG8       LT  PIFsf   Paid In Full   Asf
   C-R               LT  A+sf    New Rating
   D-1 349927AJ2     LT  PIFsf   Paid In Full   BBB+sf
   D-1-R             LT  BBB+sf  New Rating
   D-2 349927AL7     LT  PIFsf   Paid In Full   BBB-sf
   D-2-R             LT  BBB+sf  New Rating
   E 34964QAA3       LT  BB+sf   Upgrade        BB-sf

Transaction Summary

Fortress Credit BSL XVI Limited (the issuer) is an arbitrage cash
flow collateralized loan obligation (CLO) that is managed by FC BSL
CLO Manager II LLC, which originally closed on Nov. 17, 2022. The
CLO's secured debt will be partially refinanced on Oct. 21, 2024
from the proceeds of the issuance of new secured debt.

The class A-1, A-2, B, C, D-1 and D-2 notes (the refinanced notes)
are refinanced by the class A-R, B-R, C-R, D-1-R, D-2-R notes
(collectively, the first refinancing notes) with lower spreads
while the notional balance of the notes remain unchanged (A1-N and
A-2 notes are refinanced to A-R notes).

The class A-1 Loans, class E notes, class F notes and the
subordinated notes are not refinanced and shall remain outstanding
following the refinancing date whereas the debt interest rate of
class A-1 loans are amended.

Net proceeds from the issuance of the secured and subordinated
notes will provide financing on a portfolio of approximately $389
million (excluding defaulted obligations) 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
97.45% first-lien senior secured loans and has a weighted average
recovery assumption of 74.47%. Fitch stressed the indicative
portfolio by assuming a higher portfolio concentration of assets
with lower recovery prospects and further reduced recovery
assumptions for higher rating stresses.

Portfolio Composition (Positive): The largest three industries may
comprise up to 39% of the portfolio balance in aggregate while the
top five obligors can represent up to 12.5% of the portfolio
balance in aggregate. The level of diversity required by industry,
obligor and geographic concentrations is in line with other recent
CLOs.

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

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

The WAL used for the transaction stress portfolio is 12 months less
than the WAL covenant, floored at six years 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.

KEY PROVISION CHANGES

- The amended spread for the class A-1 loans and the spread for the
refinancing note classes A-R, B-R, C-R, D-1-R notes are 1.37%,
1.37%, 1.85%, 2.35% and 4.25% respectively compared to the spread
of 2.35%, 2.35%, 3.40%, 4.67% and 6.38% for the A-1 loans, class
A-1, B, C and D-1 notes respectively at closing. The floating
spread of class D-2 was 7.77% and is now refinanced into a fixed
rate class with a coupon of 8.37%.

- The non-call period for the refinancing notes will end in October
2025.

- The reinvestment period and stated maturity on refinanced notes
remained the same as compared to the original notes.

FITCH ANALYSIS

The current portfolio presented to Fitch dated Sept. 6, 2024
includes 193 assets from 168 primarily high yield obligors.

The portfolio balance, including the amount of principal cash, was
approximately $388.5 million. As per the latest trustee report, the
transaction fails some of its coverage tests and concentration
limits, such as the 'CCC' concentration limit. The weighted average
rating of the current portfolio is 'B'/'B-'. Fitch has an explicit
rating, credit opinion or private rating for 29.1% of the current
portfolio par balance; ratings for 67.6% of the portfolio were
derived from using Fitch's IDR equivalency map.

Fitch's analysis focused on the Fitch stressed portfolio (FSP) and
cash flow model analysis was conducted for this refinancing. The
FSP included the following concentrations, reflecting the maximum
limitations per the indenture or Fitch's assumption:

-Largest five obligors: 2.5% each, for an aggregate of 12.5%;

- Largest three industries: 16.6% (the largest industry exceeded
the permitted concentration limitation of 15.0% in the current
portfolio based on Fitch's industry classifications and was
maintained at that level in the Fitch stressed portfolio), 12.0%,
and 12.0%, respectively;

- Assumed risk horizon: 6.00 years;

- Minimum weighted average coupon of 6.5%;

- Minimum weighted average spread of 4.05%;

- Fixed rate Assets: 5.0%

Fitch conducted cash flow analysis due to the CLO still having two
years remaining on its reinvestment period.

Projected default and recovery statistics for the performing
collateral of the FSP were generated using Fitch's portfolio credit
model (PCM).

The PCM default rate outputs for the FSP at the 'AAAsf', 'AA+sf',
'A+sf', 'BBB+sf' and 'BB+sf' rating stress were 55.5%, 54.2%,
48.5%, 41.8% and 35.2% respectively. The PCM recovery rate outputs
for the FSP at the 'AAAsf', 'AA+sf', 'A+sf', 'BBB+sf' and 'BB+sf'
rating stress were 37.1%, 45.8%, 55.3%, 64.6% and 69.9%
respectively. In the analysis of the FSP, the class A-1 loans and
class A-R notes, class B-R, class C-R, class D-1-R, class D-2-R and
class E notes all passed the respective rating threshold in all
nine cash flow scenarios with minimum cushions of 9.7%, 5.0%, 4.9%,
7.7%, 4.0% and 5.5% respectively.

The PCM default rate outputs for the current portfolio at the
'AAAsf', 'AA+sf', 'A+sf', 'BBB+sf' and 'BB+sf' rating stress were
49.8%, 48.9%, 43.6%, 37.0% and 30.9% respectively. The PCM recovery
rate outputs for the current portfolio at the 'AAAsf', 'AA+sf',
'A+sf', 'BBB+sf' and 'BB+sf' rating stress were 39.4%, 48.5%,
58.5%, 68.1% and 73.1% respectively. In the analysis of the current
portfolio the class A-1 loans and class A-R notes, class B-R, class
C-R, class D-1-R, class D-2-R and class E notes all passed the
respective rating threshold in all nine cash flow scenarios with
minimum cushions of 15.2%, 5.9%, 10.2%, 13.9%, 9.9% and 9.1%
respectively.

Fitch assigned 'AAAsf' to the class A-R notes, 'AA+sf' to the class
B-R notes, and 'A+sf' to the class C-R notes, 'BBB+sf' to the class
D-1-R notes, 'BBB+sf' to the class D-2-R notes. Fitch also affirmed
the class A-1 loans at 'AAAsf', and upgraded the class E notes to
'BB+sf'. The Outlooks for all notes are Stable. The rating actions
are based on that the notes can sustain a robust level of defaults
combined with low recoveries, as well as other factors, such as the
degree of cushion when analyzing the indicative portfolio and the
strong performance in the sensitivity scenarios.

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 'Asf' and 'AAAsf' for class A-1/AR, between
'BBB-sf' and 'AAsf' for class BR, between 'BB-sf' and 'Asf' for
class CR, between less than 'B-sf' and 'BBB+sf' for class D-1R,
between less than 'B-sf' and 'BBB-sf' for class D-2R, and between
less than 'B-sf' and 'BB+sf' for class E.

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

Upgrade scenarios are not applicable to the class A-1/AR 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 BR, 'AA+sf' for class CR, 'A+sf'
for class D-1R, 'A+sf' for class D-2R, 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 Fortress Credit BSL
XVI 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 any ESG factor that is a
key rating driver in the key rating drivers section of the relevant
rating action commentary.


FORTRESS CREDIT XVI: Moody's Ups Rating on $500,000 F Notes to B2
-----------------------------------------------------------------
Moody's Ratings has assigned a rating to one class of CLO
refinancing notes issued (the "Refinancing Debts") by Fortress
Credit BSL XVI Limited (the "Issuer") and upgrades one class of
outstanding notes.

Moody's rating action is as follows:

US$121,500,000 Class A-R Senior Secured Floating Rate Notes due
2035, Assigned Aaa (sf)

Additionally, Moody's have taken rating action on the following
outstanding notes originally issued by the Issuer on November 17,
2022 (the "Original Closing Date"):

US$500,000 Class F Deferrable Mezzanine Floating Rate Notes due
2035, Upgraded to B2 (sf); previously on November 17, 2022
Definitive Rating Assigned B3 (sf)

RATINGS RATIONALE

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

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.

FC BSL CLO Manager II 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 remaining
reinvestment period.

The Issuer previously issued one class of secured loans, two other
classes of secured notes, and one class of subordinated notes,
which will remain outstanding.

In addition to the issuance of the Refinancing Debts, a variety of
other changes to transaction features will occur in connection with
the refinancing, including extensions of the non-call period.

No action was taken on the Class A-1 Loans because its expected
loss remain commensurate with its current rating, 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 rating action(s) on the Class F Notes is primarily a result
of the refinancing, which increases excess spread available as
credit enhancement to the rated notes.

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: $389,271,480

Defaulted par: $777,143

Diversity Score: 61

Weighted Average Rating Factor (WARF): 3300

Weighted Average Spread (WAS): 4.05%

Weighted Average Coupon (WAC): 6.50%

Weighted Average Recovery Rate (WARR): 46.67%

Weighted Average Life (WAL): 5.63 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 Underlying the Rating Action:

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

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

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


GOODLEAP SUSTAINABLE 2023-1: S&P Affirms BB (sf) Rating on C Notes
------------------------------------------------------------------
S&P Global Ratings reviewed its ratings on 16 classes of notes from
GoodLeap Sustainable Home Solutions Trust (GoodLeap) 2021-4,
2021-5, 2022-2, 2022-3, 2022-4, and 2023-1, each an underlying
trust certificate representing an ownership interest in the trust,
whose assets consist primarily of residential solar loans, with
some non-solar home efficiency loans included in some transactions.
Of the 16 ratings, S&P downgraded five and affirmed 11.

The rating changes and affirmations are driven by our assessment of
each transaction's performance under a range of scenarios. The main
drivers of performance in each scenario are the magnitude and
timing of defaults, prepayment rates, and the features specific to
each transaction structure. In each case, S&P considered the
current state of each transaction, incorporating information on
performance to date.

COLLATERAL PERFORMANCE -- PREPAYMENTS

The rated transactions have average debt coupons in excess of the
average collateral coupon, and thus a portion of principal proceeds
has to be used to pay debt interest. The longer the debt remains
outstanding, the higher likelihood that the total amount of
principal will be used to pay interest. This means that faster
prepayment rates tend to contribute positively to overall
transaction credit enhancement, while the opposite holds true of
slower prepayment rates. In S&P's initial rating analysis, it
considered a range of possible prepayment scenarios, from 3% to 20%
annual constant prepayment rates (CPRs). Actual prepayment rates
over the last 18 months have been near or even below the lower
limits of that range. Earlier transactions benefited from higher
prepayment rates in 2022, and entered the period of lower
prepayments with relatively higher credit enhancement.

Table 1 shows the annualized CPRs for the six rated transactions
over the last six, 12, and 18 months.

  Table 1

  GoodLeap Sustainable Home Solutions Trust -- annualized CPR
(%)(i)

  Series   Six-month avg.   12-month avg.   18-month avg.

  2021-4             2.40            3.67            3.11
  2021-5             3.27            2.99            2.38
  2022-2             2.37            2.58            1.95
  2022-3             2.09            2.70            1.98
  2022-4             2.73            1.96            1.35
  2023-1             3.16            1.61            1.06

(i)As of the September 2024 payment distribution date.
CPR--Constant prepayment rate.

COLLATERAL PERFORMANCE -- DEFAULTS

Alongside the slower than anticipated prepayments, these
transactions appear to be experiencing defaults at a higher level
than S&P's base-case assumptions, and even some of the rating
stress scenarios considered at the time of issuance. However, it is
uncertain what shape the loss curves will actually exhibit over
time and how losses to date will relate to cumulative losses over
the lifetimes of the transactions. Table 2 shows defaults across
the six transactions and the trends over the past 18 months.

  Table 2

  GoodLeap Sustainable Home Solutions Trust
  -- average monthly default rate (%)(i)

  Series   Six-month avg.   12-month avg.   18-month avg.

  2021-4             0.22            0.15            0.20
  2021-5             0.19            0.17            0.18
  2022-2             0.19            0.21            0.17
  2022-3             0.26            0.25            0.21
  2022-4             0.26            0.21            0.18
  2023-1             0.19            0.19            0.15

(i)As of the September 2024 payment distribution date.


COLLATERAL PERFORMANCE -- RECOVERIES

Recoveries on defaulted loans have been minimal so far. This is in
line with our rating scenarios, which assume no recoveries. Should
increased recoveries be observed in the future, this would have a
positive impact on the transactions.

STRUCTURAL CONSIDERATIONS – YIELD SUPPLEMENT
OVERCOLLATERALIZATION (YSOC)

Each transaction is structured with a YSOC amount, which adjusts
down the collateral balance to an adjusted collateral balance that
is used in calculating class-specified overcollateralization (O/C)
levels and plays a role in the distribution of principal payments
among the classes. The YSOC amount represents collateral that is
set aside to cover fees and interest payments on the notes, since
the underlying interest collected on the collateral is less than
that paid on the notes. In transactions where YSOC calculations are
linked to the maximum monthly payment of a loan, the YSOC amount
can only decline over time. In transactions where calculations are
linked to the most recent payment amount, and that amount can
increase, the YSOC amount could also increase over time and O/C
levels could be negatively impacted (even before adverse credit
performance is taken into account). The latter has been the case
for all the rated transactions.

Most of the loans in the collateral pools had initial payment
amounts less than what would be required to fully amortize the loan
over its term, with the payment adjusting to a fully amortizing
amount at month 18. If the loan is not at least partially paid down
at that point, the monthly payment would increase, and this would
increase the YSOC amount for the pool. At this point, the vast
majority of loans have passed their re-amortization point, though
this may not be the case yet for certain interest-only loans, which
may contribute to further increases in YSOC (and decreases in the
specified O/C) at their re-amortization date. For each transaction,
depending on their collateral composition and performance (both in
terms of prepayments and defaults), specified O/C levels have
changed over the past 12 months.

  Table 3

  GoodLeap Sustainable Home Solutions Trust
  –- specified O/C levels (%)

            Target   Actual   Diff.    Actual   Diff.  Class
            O/C(i)   O/C(i)     (i)   O/C(ii)    (ii)  factor(iii)

  Series 2021-4

  Class A     27.3     27.3     0.0      27.3     0.0    702.8
  Class B     18.1     17.7    (0.4)     18.0    (0.1)   899.2
  Class C     12.3      9.3    (2.9)     10.3    (2.0)   829.6

  Series 2021-5

  Class A     30.8     30.8     0.0      30.8     0.0    729.3
  Class B     20.8     20.8     0.0      20.7     0.0    896.0
  Class C     15.3     15.3     0.0      15.3     0.0    904.9

  Series 2022-2

  Class A     26.4     20.6    (5.8)     21.3    (5.1)   835.7
  Class B     18.6     11.3    (7.3)     12.7    (5.9)   965.1
  Class C     12.2      2.6    (9.6)      4.7    (7.5)   947.0

  Series 2022-3(iv)

  Class A     24.8     15.4    (9.4)     19.4    (5.4)   855.6
  Class B     17.9      6.9   (11.0)     11.9    (6.0) 1,000.0
  Class C     11.8     (2.2)  (14.0)      3.8    (8.0) 1,000.0

  Series 2022-4(v)(vi)

  Class A     41.1     37.3    (3.8)     38.6    (2.5)   880.6
  Class B     37.8     32.9    (4.9)     34.5    (3.3) 1,000.0
  Class C     34.1     27.9    (6.2)     30.0    (4.1) 1,000.0

  Series 2023-1(v)

  Class A     42.8     41.4    (1.3)     42.0    (0.8)   877.9
  Class B     38.3     36.5    (1.7)     37.5    (0.8) 1,000.0
  Class C     35.3     32.9    (2.3)     34.2    (1.1) 1,000.0

(i)September 2024 payment distribution date.
(ii)September 2023 payment distribution date.
(iii)Class factor is as of the September 2024 payment distribution
date.
(iv)GoodLeap Sustainable Home Solutions Trust 2022-3's class C
shows negative specified O/C. This means the class is
undercollateralized. This number was calculated by S&P Global
Ratings.
v)Series 2022-4 and series 2023-1 calculate their O/C levels
inclusive of the YSOC balance, differently from the previous
series.
(vi)S&P Global Ratings calculated the values shown for series
2022-4, in a manner consistent with other data provided in the
servicer report.
O/C--Overcollateralization.
Diff.--Difference.
YSOC--Yield supplement overcollateralization.

  Table 4

  GoodLeap Sustainable Home Solutions Trust
  -- transaction age and default levels(i)

              Seasoning        Cumulative          Monthly
  Series       (months)       default (%)      default (%)

  2021-4             36              4.72            0.131
  2021-5             34              3.99            0.117
  2022-2             29              3.68            0.127
  2022-3             26              4.13            0.159
  2022-4             23              3.29            0.143
  2023-1             19              2.74            0.144

(i)As of the September 2024 payment distribution date.


As seen in table 3, both GoodLeap 2022-3 and 2022-4 show
significant shortfalls from their target specified O/C levels. As
neither class A have reached its specified O/C level, both
transactions have been limited to paying principal payments to the
class A noteholders. (The same is true for GoodLeap 2023-1, but it
has been outstanding for a shorter period and is significantly
closer to its target O/C level.) Should the trends of elevated
defaults and slow prepayments continue for these transactions,
these O/C levels could further deteriorate. If either transaction
breaches the cumulative default trigger, interest payments on the
class B and C notes will be subordinate to the principal payments
on the class A notes. In such event, the interest amount due on the
class B and C notes will defer and accrue interest by the amount
and number of days of any unpaid interest period. Only a failure to
pay the total interest due on the class B and C notes by legal
final maturity will be deemed an event of default.


STRUCTURAL CONSIDERATIONS –- PAYMENT PRIORITY, O/C TARGETS, AND
PERFORMACE TRIGGERS

Certain structural features in the transactions define how the
proceeds are distributed to the various classes. For instance, each
class has an overcollateralization target; until it is reached,
principal payments will not be made to the more junior classes.
While this is generally beneficial to the senior class, it could
also over time lead to higher amounts of interest getting paid to
the junior class, which remains outstanding. Such junior interest
amounts are payable before senior principal in the regular
transaction waterfall. However, if a cumulative default trigger is
breached, interest payments on junior classes are deferred, and
those amounts are used to pay down senior principal instead. The
increased loss levels leading to the breach would generally be a
credit negative, but the diversion of cash flows could end up being
a positive for the senior noteholders.   

The overall performance of each class is therefore expected to
reflect the interplay of a number of factors related to the
collateral composition and performance, and the structural features
of each transaction. S&P said, "We considered a number of possible
scenarios in each case, varying factors such as default timing and
prepayment rates. Where we affirmed ratings, the scenarios
generally indicated that the class could withstand collateral loss
levels in line with its current rating. Where we lowered ratings,
the scenarios generally indicated that the class could not
withstand levels of loss in line with the original rating. Even
after the downgrades, some classes might not be able to withstand
lower levels of loss, under specific default timing and prepayment
scenarios. We did not rely on any single scenario, as the
performance of each class could be impacted by both the magnitude
and timing of multiple factors, as detailed above.
We will continue to review whether the ratings are consistent with
the credit enhancement available to support the notes."


  RATINGS LOWERED

  GoodLeap Sustainable Home Solutions Trust 2022-3

                    Rating        
  Class   To                  From

  B       BB (sf)             BBB (sf)
  C       B (sf)              BB (sf)

  GoodLeap Sustainable Home Solutions Trust 2022-4

                    Rating        
  Class   To                  From

  A       BBB+ (sf)           A (sf)
  B       BB+ (sf)            BBB- (sf)
  C       BB- (sf)            BB (sf)


  RATINGS AFFIRMED

  GoodLeap Sustainable Home Solutions Trust 2021-4

  Class   Rating        

  A       A (sf)   
  B       BBB (sf)
  C       BB (sf)

  GoodLeap Sustainable Home Solutions Trust 2021-5

  Class   Rating        

  A       A (sf)   
  B       BBB (sf)
  C       BB (sf)

  GoodLeap Sustainable Home Solutions Trust 2022-2

  Class   Rating        
  A       A (sf)   

  GoodLeap Sustainable Home Solutions Trust 2022-3

  Class   Rating        

  A       A (sf)   

  GoodLeap Sustainable Home Solutions Trust 2023-1

  Class   Rating        

  A       A (sf)   
  B       BBB (sf)
  C       BB (sf)



GS MORTGAGE 2015-590M: 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 GS Mortgage Securities
Corp. Trust 2015-590M, a U.S. CMBS transaction.

This is a U.S. standalone (single-borrower) CMBS transaction that
is backed by a portion of a fixed-rate, interest-only (IO) whole
mortgage loan secured by the borrower's fee simple interest in a
class A office property located at 590 Madison Ave. in Midtown
Manhattan's Plaza District office submarket.

Rating Actions

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

-- Occupancy, which S&P assumed to be about 79.4% after adjusting
the June 30, 2024, rent roll for known tenant movements, including
a new lease comprising 10.5% of the property's net rentable area
(NRA) that was recently signed by Louis Vuitton (AA-/Stable/A-1+),
is lower than the 82.3% rate S&P assumed in its last published
review, in July 2022. In addition, there is about 13.2% of NRA
rolling through the loan's maturity date in 2025. Moreover, the new
tenant's gross rental rate is significantly below the outgoing
tenant's (Crowell & Moring) gross rent, as calculated by S&P Global
Ratings.

-- The property's office submarket, albeit stabilizing, continues
to experience elevated vacancy (14.0%) and availability (15.0%)
rates. CoStar projects the submarket vacancy to remain at around
15.0% by the loan's maturity in 2025. S&P said, "We assessed that
the sponsor would need to continue 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 would likely decline to our revised
assumptions and not return to historical levels in the near term."

-- S&P said, "We revised our expected-case valuation for the
property, which is now 6.3% lower than the value we derived in our
last review and at issuance. To arrive at our revised value, we
utilized higher vacancy rate and TI costs assumptions."

-- S&P said, "We are concerned with the sponsor's ability to
refinance the loan by its October 2025 maturity date if the
property's performance does not improve beyond our expectations.
While the servicer reported a debt service coverage (DSC) of 1.84x
for the six months ended June 30, 2024, and 2.62x for year-end
2023, this is based on the 3.815% fixed annual interest rate that
is well below prevailing rates for office properties in the current
interest rate environment."

-- S&P said, "The downgrade on the class X-A IO certificates
reflects our criteria for rating IO securities, in which the rating
on the IO securities would not be higher than that of the
lowest-rated reference class. The notional amount of the class X-A
certificates references class A."

-- S&P said, "We will continue to monitor the tenancy and
performance of the property and the sponsor's ability to refinance
the loan by its October 2025 maturity date. If we receive
information that differs materially from our expectations, we may
revisit our analysis and take further rating actions, as we
determine necessary."

Property-Level Analysis

The collateral property is a 42-story, 1.03 million-sq.-ft. class A
office building with ground floor retail space located at 590
Madison Avenue between East 56th and 57th Streets in midtown
Manhattan's Plaza District office submarket. The property, built in
1981 by IBM, was acquired by the sponsor, The Board of the State
Teachers Retirement System of Ohio, in 1994, and has views of
Central Park from the top 13 floors. The collateral also includes
10,040 sq. ft. of land adjacent to the office property, which is
leased to an affiliate of The Trump Organization. The ground lease
extends to Jan. 31, 2094, with ground rent increasing by 3.0%
annually, except in 2020, when it increased by 16.0%. The ground
rent was $2.4 million, according to the June 30, 2024, rent roll.
Amenities at the property include a fitness center and a
15,000-sq.-ft. glass-enclosed atrium adjacent to the building (part
of the collateral) that serves as a cafeteria and is open to the
public. According to the master servicer, Wells Fargo Bank N.A.,
the sponsor is currently working on converting the office space
previously occupied by IBM on the third floor to house various
amenities, including a cafeteria, a clubhouse, private study rooms,
and a meeting hall. The new amenity space is expected to open in
Spring 2025.

S&P said, "In our July 2022 published review, we assumed an 82.3%
occupancy rate, a $117.25 per sq. ft. S&P Global Ratings gross
rent, and a 44.8% operating expense ratio to arrive at an S&P
Global Ratings long-term sustainable net cash flow (NCF) of $52.1
million. Utilizing a 6.25% S&P Global Ratings capitalization rate,
we derived an S&P Global Ratings expected-case value of $820.8
million or $793 per sq. ft. However, we noted at that time, while
the property had positive leasing momentum that boosted its
occupancy to the 80's percent range, the major tenant, IBM,
exercised its option to surrender two floors totaling 4.6% of NRA
by October 2022 and that IBM and another major tenant, Crowell &
Moring (totaling 21.4% of NRA), confirmed they will vacate the
property upon their lease expirations in 2025 and 2024,
respectively."

According to the June 30, 2024, rent roll, the property was 74.6%
occupied, reflecting Crowell & Moring LLP leaving the property, as
expected, in February 2024, and IBM continuing to downsize,
vacating two additional floors. According to various news reports,
it is expected to fully move out by its June 2025 lease expiration.
After adjusting for known tenant movements, including the recently
signed lease for four and a half floors (totaling 10.5% of NRA)
formerly occupied by Crowell & Moring LLP and IBM, to Louis
Vuitton, S&P's assumed property's occupancy is about 79.4%.

The five largest tenants comprise 40.3% of NRA and they are:

-- Louis Vuitton (10.5% of NRA; 9.6% of S&P Global Ratings'
in-place gross rent; September 2041 lease expiration). It is S&P's
understanding that the tenant received TI allowance and rent
concessions in line with current market standard. The tenant's
gross rent, as calculated by S&P Global Ratings, while in line with
the office submarket asking rent, is over 30% below Crowell &
Moring LLP's and slightly below IBM's gross rent at the property.
Schonfield Strategic Advisors (9.6%; 10.4%; July 2024 and January
2036).

-- American Securities (8.6%; 10.6%; March 2037).

-- Aspen Insurance U.S. Service (7.0%; 6.9%; February 2032).

-- Morgan Stanley Smith Barney (4.6%; 4.4%; July 2025).

The property has about 13.2% of NRA (18.6% of S&P Global Ratings'
in place gross rent) rolling through the loan's maturity in 2025.
In addition, about 7.2% of NRA (8.8%) rolls in 2026--of which, S&P
were informed that the tenant, Bonhams and Butterfield (3.2% of
NRA), which recently renewed its lease for one year to January
2026, is expected to vacate the property at the end of its lease
and move into its new office location in New York City.

According to CoStar, the Plaza District office submarket, where the
subject property is located, has experienced an increase in new
leasing activity in recent quarters, though the submarket
fundamentals remain well below pre-pandemic levels. As of
year-to-date October 2024, the 4- and 5-star office properties in
the office submarket had a $97.65 per sq. ft. average asking rent,
14.0% vacancy rate, and 15.0% availability rate. This compares with
a $119.75 per sq. ft. S&P Global Ratings gross rent and 20.6%
vacancy rate at the property. CoStar projects vacancy for 4- and
5-star office properties to remain elevated at 14.5% and asking
rent to marginally increase to $98.81 per sq. ft. in 2025 (when the
loan matures).

In S&P's current analysis, it utilized a 79.4% occupancy rate
(which reflects our assumed rate after adjusting the June 30, 2024,
rent roll for known tenant movements), an S&P Global Ratings' gross
rent of $119.75 per sq. ft., a 45.5% operating expense ratio, and
higher TI costs to arrive at an S&P Global Ratings' long-term
sustainable NCF of $47.6 million, 8.6% lower than our NCFs at last
review and issuance.

Using a 6.25% S&P Global Ratings capitalization rate (unchanged
from S&P's last review) and adding to the value $7.5 million for
the present value of the future rent steps for investment grade
rated tenant Louis Vuitton, S&P arrived at an S&P Global Ratings
expected-case value of $768.9 million or $743 per sq. ft., 6.3%
lower than its last review and issuance values of $820.8 million,
and 48.7% below the issuance appraised value of $1.5 billion. This
yielded an S&P Global Ratings loan-to-value (LTV) ratio of 84.5% on
the whole loan balance.

  Table 1

  Servicer-reported collateral performance

                     Six months ended
                     June 30, 2024(i)  2023(i)  2022(i)  2021(i)

  Occupancy rate (%)       74.6     88.0     85.0     85.9
  Net cash flow (mil. $)      23.2     65.8     62.9     49.5
  Debt service coverage (x)(ii) 1.84   2.62     2.50     1.97
  Appraisal value (mil. $)  1,500.0   1,500.0  1,500.0  1,500.0

(i)Reporting period.

(ii)On the whole loan balance of $650.0 million.

  Table 2

  S&P Global Ratings' key assumptions

                              Current   Last review  At issuance
                             (Oct 2024)  (July 2022)  (Nov 2015)
                                (i)          (i)         (i)

  Occupancy rate (%)            79.4         82.3      85.0(ii)
  Net cash flow (mil. $)        47.6         52.1      52.1(ii)
  Capitalization rate (%)   6.25         6.25      6.25
  Value (mil. $)               768.9(iii)   820.8     820.8(ii)
  Value per sq. ft. ($)         743          793       793
  Loan-to-value ratio (%)(iv)   84.5         79.2      79.2

(i)Review period.
(ii)At issuance, the property was 77.9% occupied. We assumed a
stabilized occupancy rate of 85.0%, yielding an incremental net
cash flow from stabilization of $6.4 million and the present value
of the incremental value discounted at 6.5% of $85.1 million.
(iii)Includes an add-to-value for the present value of future rent
steps for investment grade rated tenant, Louis Vuitton, of $7.5
million.
(iv)On the whole loan balance of $650.0 million.

Transaction Summary

The IO whole mortgage loan had an initial and current balance of
$650.0 million, pays an annual fixed interest rate of 3.815%, and
matures on Oct. 6, 2025. The whole loan is split into three senior
A notes totaling $369.4 million and a subordinate junior B note
totaling $280.6 million. The $450.0 million trust balance
(according to the Oct. 11, 2024, trustee remittance report),
comprises the $169.4 million senior note A-1 and $280.6 million
subordinate note B. The other two senior A notes totaling $200.0
million are in two CMBS conduit transactions. The senior A notes
are pari passu to each other and senior to the junior B note in
right of payments.

According to the transaction documents, the borrower is permitted
to incur mezzanine debt, subject to certain conditions, including a
combined LTV ratio of less than 41.2% and a combined DSC greater
than 2.14x. Wells Fargo Bank N.A. confirmed that no mezzanine debt
was incurred to date. To date, the trust has not incurred any
principal losses.

  Ratings Lowered

  GS Mortgage Securities Corp. Trust 2015-590M

  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)'



GS MORTGAGE 2017-375H: S&P Affirms B+ (sf) Rating on Cl. D Certs
----------------------------------------------------------------
S&P Global Ratings lowered its ratings on four classes of
commercial mortgage pass-through certificates from GS Mortgage
Securities Corp. Trust 2017-375H, a U.S. CMBS transaction. At the
same time, S&P affirmed its 'B+ (sf)' rating on class D from the
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 ground leasehold (the ground lease expires in August
2110 with no options to extend and no annual base rent payment for
the entire term) and 93-year estate-for-years interests in 375
Hudson Street, a 1987-built, 19-story, 1.09 million-sq.-ft. class A
office building with 1.03 million sq. ft. of office space, 15,690
sq. ft. of ground floor retail space, 46,000 sq. ft. of underground
storage space, and a 100-space parking garage in lower Manhattan's
Hudson Square office submarket. The property is two blocks east of
the Hudson River, near the Greenwich Village, Tribeca, and Soho
neighborhoods, and is accessible by multiple modes of
transportation.

Rating Actions

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

-- The property has had very limited leasing activity since the
sole tenant, Lion Re:Sources Inc., signed a new lease at the
property, for about 89.5% of the net rentable area (NRA). S&P
considered the possibility that the property's fundamentals may
approach those of its weakened office submarket if Lion Re:Sources
Inc. exercises its option to terminate up to two full floors
(representing up to 13.2% of the NRA) between Jan. 1, 2027 (the
loan's maturity is in September 2027) and July 31, 2031. In S&P's
last review, it noted that the tenant had marketed about 288,471
sq. ft. or 26.4% of the building's NRA for sublease. According to
CoStar, there has been no direct or subleasing office activity at
the property, and the space was withdrawn from the market between
May 2024 and August 2024. It is unclear if the tenant is fully
utilizing its space currently or if the space was removed from the
market due to a lack of interest. CoStar, on the other hand, noted
that the property currently has a 33.7% vacancy rate.

The property's office submarket's fundamentals continue to
deteriorate with over 20.0% vacancy and availability rates for 4-
and 5-Star office properties. CoStar projects the submarket vacancy
to remain around 20.0% by the loan's maturity in 2027. S&P said,
"We assessed that the sponsor would need to offer substantial
tenant improvement (TI) costs and rent concessions to attract
tenants at the property. Given these factors, we considered that
the property's performance would likely not return to historical
levels if the sole tenant exercises its termination option."

S&P said, "Our expected-case valuation, which, while unchanged from
our last review, is 17.0% lower than the valuation we derived at
issuance due primarily to our higher vacancy rate and TI costs
assumptions.

"We lowered our rating on the class X-A IO certificates based on
our criteria for rating IO securities, in which the rating on the
IO securities would not be higher than that of the lowest-rated
reference class. The notional amount of class X-A references class
A.

"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 maturity date in September 2027. If we receive
information that differs materially from our expectations, such as
reported negative changes in the performance beyond what we have
already considered or the loan is transferred to special servicing
and the workout strategy negatively affects the transaction's
payment waterfall, we may revisit our analysis and take further
rating actions as we deem necessary."

Property-Level Analysis Updates

S&P said, "In our January 2024 review, we noted that the property
was 91.4% leased (using the Sept. 30, 2023, rent roll) to Lion Re:
Sources Inc., an affiliate of former tenant Saatchi & Saatchi North
America Inc. (89.5% of the property's NRA), since mid-2019 at
$79.53 per sq. ft. gross rent, as calculated by S&P Global Ratings.
The lease expires Jan. 31, 2043, and provides for rent abatement on
63.9% of NRA on February and March of each year from 2028 to 2035,
January of each year from 2039 to 2043, and each month from August
2042 to December 2042 (a total of 26 months). In addition, the
tenant received free rent on 25.6% of property's NRA the first 16
months following the rent commencement date, January of each year
from 2039 to 2043, and each month from August 2042 through December
2042 (a total of 26 months). Moreover, the tenant has a one-time
option to terminate one to two full floors beginning Jan. 1, 2027,
through July 31, 2031. As a result, assuming an 82.0% occupancy
rate, an S&P Global Ratings' $78.06 per sq. ft. gross rent, a 44.7%
operating expense ratio, and higher TI costs, we derived a
long-term sustainable net cash flow (NCF) of $32.3 million. Using a
6.5% S&P Global Ratings' capitalization rate and deducting $33.2
million predominantly for the present value of the remaining
unreserved rent abatements, we arrived at an S&P Global Ratings
expected-case value of $465.5 million or $427 per sq. ft.

"As of the June 30, 2024, rent roll, the property was 90.3% leased,
which is relatively unchanged from our last review. The servicer,
Wells Fargo Bank N.A., reported an NCF of $23.5 million as of the
six months ended June 30, 2024, and $46.6 million as of year-end
2023."

According to CoStar, as of year-to-date October 2024, the four- and
five-star office properties in the Hudson Square office submarket
had a reported 22.1% vacancy rate, 22.6% availability rate, and
$81.81-per-sq.-ft. asking rent versus a 17.2% vacancy rate and
$76.95-per-sq.-ft. asking rent at the time of S&P's last review.
CoStar projects the vacancy rate to rise to 31.8% in 2024, before
normalizing at 19.3% in 2025, 19.4% in 2026, and 19.9% in 2027, the
year the loan matures. The asking rent is expected to remain
relatively flat at $82.03 per sq. ft., $81.98 per sq. ft., $81.82
per sq. ft., and $81.72 per sq. ft., respectively, for the same
periods. This compares with the property's in-place vacancy rate of
9.7% and gross rent of $81.09 per sq. ft., as calculated by S&P
Global Ratings.

S&P said, "Given the lack of leasing activity, concentrated
tenancy, potential lower utilization rate than pre-COVID-19
pandemic levels, weakened office submarket, and minimal changes in
performance at the property, we maintained our NCF and
expected-case assumptions that we derived in our last review. Our
current expected-case value represents a 17.0% decline from our
issuance value of $560.7 million, is 55.7% below the issuance
appraisal value of $1.05 billion, and yields an S&P Global Ratings'
loan-to-value ratio of 85.9%."

  Ratings Lowered

  GS Mortgage Securities Corp. Trust 2017-375H

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

  Rating Affirmed

  GS Mortgage Securities Corp. Trust 2017-375H

  Class D: B+ (sf)



GS MORTGAGE 2025-RPL5: Fitch Gives 'Bsf' Rating on Class B-2 Certs
------------------------------------------------------------------
Fitch Ratings rates the residential mortgage-backed certificates
issued by GS Mortgage-Backed Securities Trust 2025-RPL5 (GSMBS
2024-RPL5) as follows:

   Entity/Debt         Rating           
   -----------         ------           
GSMBS 2024-RPL5

   A-1             LT AAAsf New Rating
   A-2             LT AAsf  New Rating
   A-3             LT AAsf  New Rating
   A-4             LT Asf   New Rating
   A-5             LT BBBsf New Rating
   M-1             LT Asf   New Rating
   M-2             LT BBBsf New Rating
   B-1             LT BBsf  New Rating
   B-2             LT Bsf   New Rating
   B-3             LT NRsf  New Rating
   B-4             LT NRsf  New Rating
   B-5             LT NRsf  New Rating
   B               LT NRsf  New Rating
   X               LT NRsf  New Rating
   PT              LT NRsf  New Rating
   R               LT NRsf  New Rating
   RETAINED        LT NRsf  New Rating
   SA              LT NRsf  New Rating

Transaction Summary

The notes are supported by 2,174 reperforming loans with a total
balance of approximately $447 million as of the cutoff date.

KEY RATING DRIVERS

Updated Sustainable Home Prices (Negative): Due to Fitch's updated
view on sustainable home prices, Fitch views the home price values
of this pool as 12.0% above a long-term sustainable level versus
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.

RPL Credit Quality (Negative): The collateral pool consists
primarily of peak-vintage SPLs and RPLs first lien loans. As of the
cutoff date, the pool was 97.9% current. Approximately 35.1% of the
loans were treated as having clean payment histories for the past
two years or more (clean current) or have been clean since
origination if seasoned less than two years. Additionally, 90.3% of
loans have a prior modification. The borrowers have a moderate
credit profile (683 FICO and 45% debt-to-income ratio [DTI]) and
relatively low leverage (56% sustainable LTV ratio [sLTV]).

Sequential-Pay Structure (Positive): The transaction's cash flow is
based on a sequential-pay structure, whereby the subordinate
classes do not receive principal until the senior classes are
repaid in full. The credit enhancement consists of subordinated
notes, the distributions of which will be subordinated to P&I
payments due to senior noteholders. In addition, excess cash flow
resulting from the difference between the interest earned on the
mortgage collateral and that paid on the notes may be available to
pay down the bonds sequentially (after prioritizing fees to
transaction parties, Net WAC shortfalls and to the breach reserve
account).

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

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 MVDs at the national level. The
analysis assumes MVDs of 10.0%, 20.0% and 30.0% in addition to the
model projected 42.8% 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'.

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. The third-party due diligence described in
Form 15E focused on a regulatory compliance review that covered
applicable federal, state and local high-cost loan and/or
anti-predatory laws, as well as the Truth In Lending Act (TILA) and
Real Estate Settlement Procedures Act (RESPA). The scope was
consistent with published Fitch criteria for due diligence on RPL
RMBS. Fitch considered this information in its analysis and, as a
result, Fitch made the following adjustments to its analysis:

- Loans with an indeterminate HUD1 located in states that fall
under Freddie Mac's "Do Not Purchase List" received a 100% LS
over-ride;

- Loans with an indeterminate HUD1 but not located in states that
fall under Freddie Mac's "Do Not Purchase List" received a
five-point LS increase;

- Loans with a missing modification agreement received a
three-month liquidation timeline extension;

- Unpaid taxes and lien amounts were added to the LS.

In total, these adjustments increased the 'AAAsf' loss by
approximately 150bps.

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.


HAMLET SECURITIZATION 2020-CRE1: DBRS Confirms CCC on F-RR Certs
----------------------------------------------------------------
DBRS, Inc. confirmed all credit ratings on the classes of
Commercial Mortgage Pass-Through Certificates, Series 2020-CRE1
issued by Hamlet Securitization Trust 2020-CRE1 as follows:

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

All classes have Stable trends with the exception of Class F-RR as
its rating does not carry a trend in commercial mortgage-backed
securities (CMBS) transactions.

The credit rating confirmations and Stable trends reflect the
overall stable performance of the transaction since the previous
Morningstar DBRS credit rating action. As of the September 2024
remittance, 21 of the original 23 loans remain in the pool, with a
current trust balance of $1.6 billion, representing a collateral
reduction of 14.4% since issuance. Eight loans, representing 38.8%
of the pool balance, are on the servicer's watchlist, four of which
(27.1% of the current pool balance) were flagged solely for a
failure of the respective borrowers to submit financials, while the
remaining four loans (11.6% of the current pool balance) are being
monitored primarily for low debt service coverage ratios (DSCRs)
and servicing trigger events. Two loans, representing 24.7% of the
pool are in special servicing. At issuance, there were four
transitional loans in the pool. As of this review, only one loan
(20 Broad Street, Prospectus ID#1, 13.6% of the pool) has a
business plan that remains in progress as the borrower has yet to
lease the retail component of the property to stabilization.

At last review, Morningstar DBRS downgraded Class F-RR to CCC (sf),
primarily as a result of a sustained period of outstanding interest
shortfalls for that class. Morningstar DBRS also noted realized
losses for the unrated Class G-RR contributing to the credit rating
downgrade rationale. At the time of that October 2023 credit rating
action, shortfalls had been outstanding for five months and were
approaching the end of Morningstar DBRS' shortfall tolerance. The
interest shortfalls and realized loss were both tied to the 545 &
555 North Michigan Avenue loan (Prospectus ID#12, 3.4% of the
pool). The interest shortfall remained outstanding until it was
repaid with the July 2024 remittance. As of the September 2024
remittance, interest shortfalls remained outstanding for only the
unrated Class G-RR certificate, with cumulative unpaid interest of
$3.9 million. Although the outlook for the 545 & 555 North Michigan
Avenue loan has improved overall with a tenant signing for the
entirety of the collateral space, the modified loan structure that
divided the loan into a senior $55.0 million A note and a
subordinate $20.0 million B note in May 2023 suggests a loss will
be incurred at disposition. This factor, as well as the two new
loans that have transferred to special servicing since the last
review, are drivers for confirming the CCC (sf) credit rating for
Class F-RR.

The pool is concentrated with loans secured by office, multifamily,
and retail properties, representing 38.7%, 19.7%, and 17.1% of the
current pool balance, respectively. In general, the office sector
has been challenged given soft submarket conditions and the shift
in workplace dynamics observed across the United States. Regarding
office loans exhibiting increased risk, such as increased vacancy
rates, upcoming material lease rollover, or located in markets with
weak fundamentals, Morningstar DBRS increased the probability of
default penalties (POD) and, in certain cases, applied stressed
loan-to-value ratios (LTVs) in its analysis, resulting in a
weighted-average expected loss for those loans at approximately
1.35 times the overall pool average.

The largest loan in special servicing, 20 Broad Street, is secured
by a 533-unit, luxury multifamily property with 39,029 square feet
of retail space located in Manhattan's Financial District. The loan
transferred to the special servicer in August 2024 ahead of the
scheduled loan maturity in September 2024. According to the most
recent servicer commentary, the lender, for a $70 million mezzanine
loan, is preparing to enforce its rights and take ownership of the
borrower, an affiliate of MetroLoft. Once that is actioned, the
servicer and mezzanine lender are expected to finalize terms to
resolve the outstanding defaults for the subject loan. MetroLoft's
business plan was to lease up the renovated property and obtain a
permanent loan upon stabilization. The pandemic contributed to a
slower-than-expected stabilization timeline and cash flows have
generally been reported below issuance expectations. Most recently,
the servicer reported an annualized September 2022 net operating
income (NOI) of $14.1 million, below the Morningstar DBRS'
stabilized NOI derived at issuance of $15.4 million. A January 2024
rent roll showed an occupancy rate of 50.1% and 97.6% for the
retail and multifamily portions of the property, respectively. The
average rental rate for the residential units of approximately
$4,433 per unit at January 2024 compares with the December 2019
average of $3,959 per unit. Given the improvement in the occupancy
rate for the commercial space from the October 2021 occupancy of
17.1% and the residential rental rate growth, Morningstar DBRS
expects the in-place NOI has improved significantly since 2022.
Morningstar DBRS considered a stressed POD to increase the expected
loss in the analysis for this review but notes that the relatively
low LTV of approximately 58.0% on the issuance as-is appraisal,
recent performance improvements and the likelihood that the
mezzanine lender will be highly incentivized to come to an
agreement with the special servicer suggest the overall risk of
significant loss at resolution remains low.

The other loan in special servicing and the loan with Morningstar
DBRS' highest expected loss in the analysis for this review,
Merritt on the River Portfolio (Prospectus ID#3, 12.0% of the pool
balance), is secured by a portfolio of three Class A office
buildings and two Class B office buildings, totaling 974,575 square
feet in Norwalk, Connecticut. The loan transferred to special
servicing in June 2024 in order to attain a loan modification,
which was subsequently granted. Terms of the modification included
a $20.7 million paydown funded by borrower funds from former tenant
GE Capital's lease termination deposit of $17.5 million and an
additional $3.2 million from a leasing reserve. GE Capital formerly
occupied 39.7% of the net rentable area (NRA). The significant
paydown indicates the borrower's commitment to the portfolio and
according to servicer commentary, the loan is expected to return to
the master servicer by October 2024. No updated rent roll has been
provided; however, according to LoopNet, approximately 55.0% of the
total NRA is currently being marketed for lease, including a
portion of the former GE Capital space. According to Reis figures,
the central submarket of Fairfield County reported a Q2 2024
vacancy rate of 23.2% compared with the Q2 2023 vacancy rate of
25.5%. While the sponsor commitment is notable, the increase in
vacancy and soft submarket conditions remain concerns. In its
analysis, Morningstar DBRS applied a stressed LTV and an elevated
POD penalty, resulting in an expected loss that was more than three
times than the pool average.

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


HPS LOAN 2024-21: S&P Assigns BB- (sf) Rating on Class E Notes
--------------------------------------------------------------
S&P Global Ratings assigned its ratings to HPS Loan Management
2024-21 Ltd./HPS Loan Management 2024-21 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 HPS Investment Partners 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

  HPS Loan Management 2024-21 Ltd./HPS Loan Management 2024-21 LLC

  Class A, $256.000 million: AAA (sf)
  Class B, $48.000 million: AA (sf)
  Class C (deferrable), $24.000 million: A (sf)
  Class D-1-A (deferrable), $15.000 million: BBB- (sf)
  Class D-1-B (deferrable), $9.000 million: BBB- (sf)
  Class D-2 (deferrable), $3.250 million: BBB- (sf)
  Class E (deferrable), $11.550 million: BB- (sf)
  Subordinated notes, $37.285 million: Not rated



IMSCI 2016-7: DBRS Confirms B Rating on Class G Certs
-----------------------------------------------------
DBRS Limited confirmed its credit ratings on all classes of
Commercial Mortgage Pass-Through Certificates, Series 2016-7 issued
by Institutional Mortgage Securities Canada Inc. (IMSCI) Series
2016-7 as follows:

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

All trends are Stable.

The credit rating confirmations reflect the stable performance of
the transaction, which remains in line with Morningstar DBRS'
expectations. Overall, the pool continues to exhibit healthy credit
metrics as evidenced by the weighted-average debt service coverage
ratio (DSCR) of 1.99 times (x), based on the most recent financial
reporting available. As of the September 2024 remittance, 23 of the
original 38 loans remain in the pool. In total, loan repayments and
amortization have reduced the pool balance to $167.4 million,
representing a collateral reduction of 52.5% since issuance. Since
Morningstar DBRS' prior credit rating action, one loan (4.5% of the
original pool balance) was repaid in full at the scheduled maturity
date. Despite the significant principal paydown since issuance,
which suggested upward pressure on the credit ratings, the largest
loan in the pool, Portage Place (Prospectus ID#1; 13.3% of the
pool) matured on October 1, 2024, and is currently being monitored
on the servicer's watchlist, the details of which are outlined
below. In addition, Morningstar DBRS has not received updated
loan-level financial reporting, and notes that the transaction's
structure includes minimal cushion at the bottom of the capital
stack to insulate against any potential losses. To further test the
durability of the credit ratings, Morningstar DBRS' analysis also
considered a stressed scenario that included a 20.0% haircut to the
issuer's underwritten cash flow for each remaining loan in the
pool. The resulting analysis suggests a significant amount of
cushion against future cash flow volatility remains, further
supporting the credit rating confirmations and Stable trends with
this review.

Only one loan, representing 7.8% of the pool, has been fully
defeased. No loans are in special servicing, but 12 loans,
representing 68.9% of the pool, are on the servicer's watchlist;
however, just two of those loans, which represent 14.3% of the
pool, are being monitored for performance-related concerns.

The Portage Place loan is secured by a 228,358 square foot (sf)
retail property in Peterborough, Ontario. The loan was added to the
servicer's watchlist with the August 2024 remittance because of a
pending maturity date on October 1, 2024. The servicer confirmed
that the borrower is considering financing options, and a payoff
quote is being prepared. According to the YE2023 servicer-provided
reporting, the property was 100.0% occupied and the loan's DSCR was
strong at 1.72x. Cashflows have improved year over year, with the
property generating $2.9 million of net cash flow (NCF) as of
YE2023, a notable increase from both the YE2022 and Morningstar
DBRS figures of $2.6 million and $2.1 million, respectively.
Although an updated rent roll was not provided, the five largest
tenants, which collectively account for 62.9% of net rentable area
(NRA) are on long-term leases with the nearest lease expiration
(approximately 6.0% of the NRA) in December 2027. Morningstar DBRS
analyzed the loan with a conservative probability of default (POD)
adjustment, resulting in an expected loss that was more than triple
the pool average.

The fourth-largest loan in the pool, Fortier Industrial Portfolio
(Prospectus ID#6; 7.5% of the pool), is secured by a portfolio of
three industrial properties totaling 308,932 sf in Saint-Hubert,
Québec, a city approximately 10 kilometers northeast of Montréal.
The collateral consists of three adjacent industrial properties
with 12 multi-tenant buildings that were constructed between 1975
and 1988. The loan was added to the servicer's watchlist in August
2023 for a decline in the DSCR, which was driven by a decrease in
expense reimbursements. Although updated reporting was not
provided, the portfolio was 97.5% occupied as of January 2023.
Based on the most recent financial reporting available, the
portfolio generated NCF of $2.3 million as of YE2022 (reflecting a
DSCR of 2.17x), an increase from the YE2021 and Morningstar DBRS
figures of $1.8 million (DSCR of 1.74x) and $1.5 million (DSCR of
1.41x), respectively. According to the January 2023 rent roll,
rollover risk was concentrated throughout 2023, with tenant leases
representing approximately 52.3% of the NRA scheduled to roll
throughout YE2024. Morningstar DBRS maintained the POD penalty from
the prior credit rating action to reflect the decline in the loan's
DSCR, elevated rollover risk, and outdated financial reporting,
resulting in an expected loss that was more than double the pool
average.

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


INVESCO CLO 2022-3: Fitch Assigns 'BB-sf' Rating on Class E-R Notes
-------------------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to the
Invesco CLO 2022-3, Ltd. reset transaction.

   Entity/Debt              Rating               Prior
   -----------              ------               -----
Invesco CLO 2022-3, Ltd.

   A-1 46146VAA7       LT   PIFsf   Paid In Full   AAAsf
   A-1-L               LT   AAAsf   New Rating
   A-1-R               LT   AAAsf   New Rating
   A-2 46146VAC3       LT   PIFsf   Paid In Full   AAAsf
   A-2-R               LT   AAAsf   New Rating
   B 46146VAE9         LT   PIFsf   Paid In Full   AAsf
   B-R                 LT   AAsf    New Rating
   C 46146VAG4         LT   PIFsf   Paid In Full   Asf
   C-R                 LT   Asf     New Rating
   D 46146VAJ8         LT   PIFsf   Paid In Full   BBB-sf
   D-1-R               LT   BBB-sf  New Rating
   D-2-R               LT   BBB-sf  New Rating
   E 46146WAA5         LT   PIFsf   Paid In Full   BB-sf
   E-R                 LT   BB-sf   New Rating

Transaction Summary

Invesco CLO 2022-3, Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that originally closed in
February 2022 and is managed by Invesco CLO Equity Fund 3 L.P. The
deal is refinancing all classes and 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', which is in line with that of recent
CLOs. The weighted average rating factor (WARF) of the indicative
portfolio is 23.42, 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
98.07% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 75.85% versus a
minimum covenant, in accordance with the initial expected matrix
point of 67.2%.

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 11.5% 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.

Invesco CLO 2022-3, Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that originally closed in
February 2022 and is managed by Invesco CLO Equity Fund 3 L.P. The
deal is refinancing all classes and 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.

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-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 A-1 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, 'AAsf' for class
C-R, 'A+sf' for class D-1-R, 'A-sf' for class D-2-R, and 'BBB+sf'
for class E-R.

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

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

DATA ADEQUACY

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

ESG Considerations

Fitch does not provide ESG relevance scores for Invesco CLO 2022-3
Ltd. In cases where Fitch does not provide ESG relevance scores in
connection with the credit rating of a transaction, programme,
instrument or issuer, Fitch will disclose in the key rating drivers
any ESG factor which has a significant impact on the rating on an
individual basis.


JP MORGAN 2024-10: DBRS Gives Prov. B(low) Rating on B-5 Certs
--------------------------------------------------------------
DBRS, Inc. assigned the following provisional credit ratings to the
Mortgage Pass-Through Certificates, Series 2024-10 (the
Certificates) to be issued by the J.P. Morgan Mortgage Trust
2024-10 (JPMMT 2024-10):

-- $459.5 million Class A-2 at (P) AAA (sf)
-- $459.5 million Class A-3 at (P) AAA (sf)
-- $459.5 million Class A-3-X at (P) AAA (sf)
-- $344.6 million Class A-4 at (P) AAA (sf)
-- $344.6 million Class A-4-A at (P) AAA (sf)
-- $344.6 million Class A-4-X at (P) AAA (sf)
-- $114.9 million Class A-5 at (P) AAA (sf)
-- $114.9 million Class A-5-A at (P) AAA (sf)
-- $114.9 million Class A-5-X at (P) AAA (sf)
-- $275.7 million Class A-6 at (P) AAA (sf)
-- $275.7 million Class A-6-A at (P) AAA (sf)
-- $275.7 million Class A-6-X at (P) AAA (sf)
-- $183.8 million Class A-7 at (P) AAA (sf)
-- $183.8 million Class A-7-A at (P) AAA (sf)
-- $183.8 million Class A-7-X at (P) AAA (sf)
-- $68.9 million Class A-8 at (P) AAA (sf)
-- $68.9 million Class A-8-A at (P) AAA (sf)
-- $68.9 million Class A-8-X at (P) AAA (sf)
-- $64.9 million Class A-9 at (P) AAA (sf)
-- $64.9 million Class A-9-A at (P) AAA (sf)
-- $64.9 million Class A-9-X at (P) AAA (sf)
-- $153.2 million Class A-11 at (P) AAA (sf)
-- $153.2 million Class A-11-X at (P) AAA (sf)
-- $153.2 million Class A-12 at (P) AAA (sf)
-- $153.2 million Class A-13 at (P) AAA (sf)
-- $153.2 million Class A-13-X at (P) AAA (sf)
-- $153.2 million Class A-14 at (P) AAA (sf)
-- $153.2 million Class A-14-X at (P) AAA (sf)
-- $153.2 million Class A-14-X2 at (P) AAA (sf)
-- $153.2 million Class A-14-X3 at (P) AAA (sf)
-- $153.2 million Class A-14-X4 at (P) AAA (sf)
-- $677.5 million Class A-X-1 at (P) AAA (sf)
-- $677.5 million Class A-X-2 at (P) AAA (sf)
-- $677.5 million Class A-X-3 at (P) AAA (sf)
-- $17.3 million Class B-1 at (P) AA (low) (sf)
-- $17.3 million Class B-1-A at (P) AA (low) (sf)
-- $17.3 million Class B-1-X at (P) AA (low) (sf)
-- $10.5 million Class B-2 at (P) A (low) (sf)
-- $10.5 million Class B-2-A at (P) A (low) (sf)
-- $10.5 million Class B-2-X at (P) A (low) (sf)
-- $7.6 million Class B-3 at (P) BBB (low) (sf)
-- $3.6 million Class B-4 at (P) BB (low) (sf)
-- $1.4 million Class B-5 at (P) B (low) (sf)

Classes A-3-X, A-4-X, A-5-X, A-6-X, A-7-X, A-8-X, A-9-X, A-11-X,
A-13-X, A-14-X, A-14-X2, A-14-X3, A-14-X4, A-X-1, A-X-2, A-X-3,
B-1-X, and B-2-X are interest-only (IO) certificates. The class
balances represent notional amounts.

Classes A-2, A-3, A-3-X, A-4, A-4-A, A-4-X, A-5, A-6, A-7, A-7-A,
A-7-X, A-8, A-9, A-11, A-11-X, A-12, A-13, A-13-X, A-X-1, B-1, and
B-2 are exchangeable certificates. These classes can be exchanged
for combinations of depositable certificates as specified in the
offering documents.

Classes A-2, A-3, A-4, A-4-A, A-5, A-5-A, A-6, A-6-A, A-7, A-7-A,
A-8, A-8-A, A-11, A-12, A-13, and A-14 are super-senior
certificates. These classes benefit from additional protection from
the senior support certificates (Classes A-9 and A-9-A) with
respect to loss allocation.

The AAA (sf) ratings on the Certificates reflect 6.00% of credit
enhancement provided by subordinated certificates. The AA (low)
(sf), A (low) (sf), BBB (low) (sf), BB (low) (sf), and B (low) (sf)
ratings reflect 3.60%, 2.15%, 1.10%, 0.60%, and 0.40% of credit
enhancement, respectively.

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

The transaction is a securitization of a portfolio of first-lien
fixed-rate prime residential mortgages to be funded by the issuance
of the Mortgage Pass-Through Certificates, Series 2024-10 (the
Certificates). The Certificates are backed by 582 loans with a
total principal balance of $720,784,007 as of the Cut-Off Date
(October 1, 2024).

The pool consists of fully amortizing fixed-rate mortgages with
original terms to maturity of 15 to 30 years and a weighted-average
(WA) loan age of three months. Approximately 93.2% of the loans are
traditional, nonagency, prime jumbo mortgage loans. The remaining
6.8% of the loans are conforming mortgage loans that were
underwritten using an automated underwriting system (AUS)
designated by Fannie Mae or Freddie Mac and were eligible for
purchase by such agencies. Details on the underwriting of
conforming loans can be found in the Key Probability of Default
Drivers section. In addition, all of the loans in the pool were
originated in accordance with the new general Qualified Mortgage
(QM) rule.

United Wholesale Mortgage, LLC (UWM) originated 46.2% of the pool.
Various other originators, each comprising less than 15%,
originated the remainder of the loans. The mortgage loans will be
serviced or subserviced, as applicable, by Shellpoint Mortgage
Servicing (Shellpoint or SMS; 39.5%), UWM (46.2%), and PennyMac
(14.3%). For the JPMorgan Chase Bank, N.A. (JPMCB)-serviced loans,
Shellpoint will act as interim servicer until the loans transfer to
JPMCB on the servicing transfer date (December 1, 2024).

For certain Servicers in this transaction, the servicing fee
payable for mortgage loans is composed of three separate
components: the base servicing fee, the delinquent servicing fee,
and the additional servicing fee. These fees vary based on the
delinquency status of the related loan and will be paid from
interest collections before distribution to the securities.

Nationstar Mortgage LLC (Nationstar) will act as the Master
Servicer. Citibank, N.A. (Citibank; rated AA (low) with a Stable
trend by Morningstar DBRS) will act as Securities Administrator and
Delaware Trustee. Computershare Trust Company, N.A. (Computershare)
will act as Custodian. Pentalpha Surveillance LLC (Pentalpha) will
serve as the Representations and Warranties (R&W) Reviewer.

The transaction employs a senior-subordinate, shifting-interest
cash flow structure that incorporates performance triggers and
credit enhancement floors.

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


JP MORGAN 2024-9: DBRS Finalizes B(low) Rating on Class B5 Certs
----------------------------------------------------------------
DBRS, Inc. finalized the following provisional credit ratings on
the Mortgage Pass-Through Certificates, Series 2024-9 (the
Certificates) issued by the J.P. Morgan Mortgage Trust 2024-9
(JPMMT 2024-9):

-- $426.6 million Class A-2 at AAA (sf)
-- $426.6 million Class A-3 at AAA (sf)
-- $426.6 million Class A-3-X at AAA (sf)
-- $319.9 million Class A-4 at AAA (sf)
-- $319.9 million Class A-4-A at AAA (sf)
-- $319.9 million Class A-4-X at AAA (sf)
-- $106.6 million Class A-5 at AAA (sf)
-- $106.6 million Class A-5-A at AAA (sf)
-- $106.6 million Class A-5-X at AAA (sf)
-- $255.9 million Class A-6 at AAA (sf)
-- $255.9 million Class A-6-A at AAA (sf)
-- $255.9 million Class A-6-X at AAA (sf)
-- $170.6 million Class A-7 at AAA (sf)
-- $170.6 million Class A-7-A at AAA (sf)
-- $170.6 million Class A-7-X at AAA (sf)
-- $64.0 million Class A-8 at AAA (sf)
-- $64.0 million Class A-8-A at AAA (sf)
-- $64.0 million Class A-8-X at AAA (sf)
-- $62.2 million Class A-9 at AAA (sf)
-- $62.2 million Class A-9-A at AAA (sf)
-- $62.2 million Class A-9-X at AAA (sf)
-- $142.2 million Class A-11 at AAA (sf)
-- $142.2 million Class A-11-X at AAA (sf)
-- $142.2 million Class A-12 at AAA (sf)
-- $142.2 million Class A-13 at AAA (sf)
-- $142.2 million Class A-13-X at AAA (sf)
-- $142.2 million Class A-14 at AAA (sf)
-- $142.2 million Class A-14-X at AAA (sf)
-- $142.2 million Class A-14-X2 at AAA (sf)
-- $142.2 million Class A-14-X3 at AAA (sf)
-- $142.2 million Class A-14-X4 at AAA (sf)
-- $631.0 million Class A-X-1 at AAA (sf)
-- $631.0 million Class A-X-2 at AAA (sf)
-- $631.0 million Class A-X-3 at AAA (sf)
-- $14.7 million Class B-1 at AA (low) (sf)
-- $14.7 million Class B-1-A at AA (low) (sf)
-- $14.7 million Class B-1-X at AA (low) (sf)
-- $9.0 million Class B-2 at A (low) (sf)
-- $9.0 million Class B-2-A at A (low) (sf)
-- $9.0 million Class B-2-X at A (low) (sf)
-- $7.0 million Class B-3 at BBB (low) (sf)
-- $3.3 million Class B-4 at BB (low) (sf)
-- $1.3 million Class B-5 at B (low) (sf)

Classes A-3-X, A-4-X, A-5-X, A-6-X, A-7-X, A-8-X, A-9-X, A-11-X,
A-13-X, A-14-X, A-14-X2, A-14-X3, A-14-X4, A-X-1, A-X-2, A-X-3,
B-1-X, and B-2-X are interest-only (IO) certificates. The class
balances represent notional amounts.

Classes A-2, A-3, A-3-X, A-4, A-4-A, A-4-X, A-5, A-6, A-7, A-7-A,
A-7-X, A-8, A-9, A-11, A-11-X, A-12, A-13, A-13-X, A-X-1, B-1, and
B-2 are exchangeable certificates. These classes can be exchanged
for combinations of depositable certificates as specified in the
offering documents.

Classes A-2, A-3, A-4, A-4-A, A-5, A-5-A, A-6, A-6-A, A-7, A-7-A,
A-8, A-8-A, A-11, A-12, A-13, and A-14 are super-senior
certificates. These classes benefit from additional protection from
the senior support certificates (Classes A-9 and A-9-A) with
respect to loss allocation.

The AAA (sf) ratings on the Certificates reflect 5.70% of credit
enhancement provided by subordinated certificates. The AA (low)
(sf), A (low) (sf), BBB (low) (sf), BB (low) (sf), and B (low) (sf)
ratings reflect 3.50%, 2.15%, 1.10%, 0.60%, and 0.40% of credit
enhancement, respectively.

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

This transaction is a securitization of a portfolio of first-lien
fixed-rate prime residential mortgages funded by the issuance of
the Mortgage Pass-Through Certificates, Series 2024-9 (the
Certificates). The Certificates are backed by 606 loans with a
total principal balance of $669,134,610 as of the Cut-Off Date
(September 1, 2024).

Subsequent to the issuance of the related Presale Report, seven
loans were removed from the pool. The Certificates are backed by
613 mortgage loans with a total principal balance of $678,046,077
in the Presale Report. Unless specified otherwise, all the
statistics regarding the mortgage loans in this press release and
corresponding Rating Report are based on the Presale Report
balance.

The pool consists of fully amortizing fixed-rate mortgages with
original terms to maturity of 15 to 30 years and a weighted-average
(WA) loan age of two months. Approximately 85.3% of the loans are
traditional, nonagency, prime jumbo mortgage loans. The remaining
14.7% of the loans are conforming mortgage loans that were
underwritten using an automated underwriting system (AUS)
designated by Fannie Mae or Freddie Mac and were eligible for
purchase by such agencies. Details on the underwriting of
conforming loans can be found in the Key Probability of Default
Drivers section. In addition, all of the loans in the pool were
originated in accordance with the new general Qualified Mortgage
(QM) rule.

United Wholesale Mortgage, LLC (UWM) originated 37.2% of the pool.
Various other originators, each comprising less than 15%,
originated the remainder of the loans. The mortgage loans will be
serviced or subserviced, as applicable, by Shellpoint Mortgage
Servicing (Shellpoint or SMS) (49.1%), UWM (37.2%), PennyMac
(13.3%), and loanDepot.com (0.4%). For the JPMorgan Chase Bank,
N.A. (JPMCB)-serviced loans, Shellpoint will act as interim
servicer until the loans transfer to JPMCB on the servicing
transfer date (December 1, 2024).

For certain Servicers in this transaction, the servicing fee
payable for mortgage loans is composed of three separate
components: the base servicing fee, the delinquent servicing fee,
and the additional servicing fee. These fees vary based on the
delinquency status of the related loan and will be paid from
interest collections before distribution to the securities.

Nationstar Mortgage LLC (Nationstar) will act as the Master
Servicer. Citibank, N.A. (Citibank; rated AA (low) with a Stable
trend by Morningstar DBRS) will act as Securities Administrator and
Delaware Trustee. Computershare Trust Company, N.A. (Computershare)
will act as Custodian. Pentalpha Surveillance LLC (Pentalpha) will
serve as the Representations and Warranties (R&W) Reviewer.

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


JP MORGAN 2024-INV1: Moody's Assigns (P)B3 Rating to Cl. B-5 Certs
------------------------------------------------------------------
Moody's Ratings has assigned provisional ratings to 33 classes of
residential mortgage-backed securities (RMBS) to be issued by J.P.
Morgan Mortgage Trust 2024-INV1, and sponsored by J.P. Morgan
Mortgage Acquisition Corp.

The securities are backed by a pool of prime jumbo (63.1% by
balance) and GSE-eligible (36.9% by balance) residential mortgages
aggregated by JPMMAC, including loans aggregated by MAXEX Clearing
LLC (MAXEX; 0.9% by loan balance), and originated and serviced by
multiple entities.        

The complete rating actions are as follows:

Issuer:  J.P. Morgan Mortgage Trust 2024-INV1

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Cl. A-9, Assigned (P)Aa1 (sf)

Cl. A-9-A, Assigned (P)Aa1 (sf)

Cl. A-9-X*, Assigned (P)Aa1 (sf)

Cl. A-X-1*, Assigned (P)Aa1 (sf)

Cl. A-X-2*, Assigned (P)Aa1 (sf)

Cl. A-X-3*, Assigned (P)Aa1 (sf)

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

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

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

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

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

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

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

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

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

*Reflects Interest-Only Classes

RATINGS RATIONALE

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

Moody's expected loss for this pool in a baseline scenario-mean is
0.75%, in a baseline scenario-median is 0.42% and reaches 9.00% 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.


KEY COMMERCIAL 2018-S1: DBRS Cuts Class F Certs Rating to CCC
-------------------------------------------------------------
DBRS Limited downgraded its credit ratings on two classes of
Commercial Mortgage Pass-Through Certificates, Series 2018-S1
issued by Key Commercial Mortgage Trust 2018-S1 as follows:

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

In addition, Morningstar DBRS confirmed its credit ratings on the
remaining classes as follows:

-- Class A-3 at AAA (sf)
-- Class A-S at AAA (sf)
-- Class X at AA (sf)
-- Class B at AA (low) (sf)
-- Class C at A (low) (sf)
-- Class D at BBB (sf)

Morningstar DBRS also changed the trend on Class E to Stable from
Negative. All other trends are Stable, with the exception of Class
F, which has a credit rating that does not typically carry a trend
in commercial mortgage-backed securities (CMBS) credit ratings.

The credit rating downgrades on Classes E and F reflect an increase
in Morningstar DBRS' loss projections, attributable to the one loan
in special servicing, 775 West Jackson Boulevard (Prospectus ID#25,
2.6% of the pool), and St. Charles Executive Center (Prospectus
ID#11, 5.7% of the pool), which Morningstar DBRS considers to be at
high risk for near-term default. Although St. Charles Executive
Center has not yet transferred to special servicing, Morningstar
DBRS believes that the property's value has declined significantly
from issuance because of performance challenges that are not
expected to improve ahead of the loan's maturity, as further
described below. Losses from these loans' liquidation scenarios
would erode the majority of the Class G certificate balance.
Morningstar DBRS notes that the capital structure provides limited
cushion to the junior bonds in the event of increased losses, given
the very thin tranching supporting the credit rating downgrades on
Classes E and F.

Morningstar DBRS changed the trend on Class E to Stable from
Negative with this review, which is supported by the punitive
analysis for the two loans noted above. Although the performance of
those two loans is worrisome, Morningstar DBRS' liquidation
scenarios adequately capture the ongoing credit risk and, in the
event performance and value deteriorate further, Class E's current
credit rating reflects a high level of uncertainty. All other
trends remain Stable, with the exception of Class F as noted
above.

The remaining credit rating confirmations and Stable trends reflect
the performance of the remaining loans in the pool, which remains
in line with Morningstar DBRS' expectations at issuance evidenced
by a weighted-average debt service coverage ratio (DSCR) of 1.90
times (x) at YE2023. This is further supported by the favorable
property type concentration in loans backed by retail and
self-storage properties, which collectively represent 43.1% of the
pool.

The pool's continued deleveraging also helps to offset concerns
regarding the capital structure. As of the September 2024
remittance, the pool had experienced 43.2% collateral reduction
since issuance, with 21 of the original 31 loans remaining in the
pool with an aggregate principal balance of $75.1 million. Three
loans are fully defeased, representing 13.5% of the pool balance.
Only two loans, representing 14.4% of the pool balance, are secured
by office properties and, where applicable, Morningstar DBRS
increased the probability of default penalties (and, in certain
cases, applied stressed loan-to-value ratios) for office loans
exhibiting performance concerns.

There is one loan in special servicing, 775 West Jackson Boulevard,
which is secured by a mixed-use property comprising retail and
office space in Chicago's Greektown neighborhood. The loan
transferred to the special servicer in May 2020 for monetary
default related to performance declines stemming from the effects
of the coronavirus pandemic. In December 2020, the borrower filed
for bankruptcy; however, the court dismissed the bankruptcy claim
in August 2023 and the special servicer resumed foreclosure
proceedings. There is now a receiver in place, though updated
financials have not been made available since March 2022. According
to the August 2023 rent roll, the subject appears to be 100%
occupied by four tenants. The property was reappraised in October
2023 at $2.2 million compared with the January 2021 appraised value
of $2.0 million and the issuance appraised value of $3.5 million.
In its analysis for this review, Morningstar DBRS liquidated this
loan from the trust using a haircut on the most recent appraised
value, resulting in an implied loss approaching $1.0 million, or a
loss severity in excess of 45.0%.

St. Charles Executive Center is secured by two suburban office
properties (one low-rise office and one medical office) in St.
Charles, Illinois, approximately 40 miles west of downtown Chicago.
The troubled loan remains on the servicer's watchlist because of
its low occupancy and DSCR. According to the April 2024 rent roll,
the subject was 66.3% occupied, down from 85% at issuance. Average
vacancy for the submarket was reported to be 31.7% as of Q2 2024,
according to Reis. The largest tenant, RS&H, Inc., represents 11.0%
of net rentable area (NRA) and has a near-term lease expiration in
August 2025. In total, leases representing approximately 20% of the
NRA are scheduled to expire in the next 12 months. The subject's
declined occupancy has also stressed revenue. Although the reported
YE2023 net cash flow (NCF) is an improvement over YE2022, DSCR
remains low at 0.80x, and Morningstar DBRS expects performance to
remain depressed given upcoming rollover and high submarket
vacancy. Given these concerns, Morningstar DBRS expects that the
property's value has likely declined significantly from issuance
and expects it to remain depressed as maturity approaches in 2028,
supporting the liquidation analysis. Morningstar DBRS derived an
updated value based on in-place performance using the YE2023 NCF of
$253,595 and applying a stressed capitalization rate. The resulting
value of $2.5 million represents an approximate decline of 70% from
the issuance appraisal of $8.1 million. The implied loss to the
trust in this year's review was in excess of $2.0 million, or a
loss severity approaching nearly 50%.

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


KKR CLO 49: Moody's Assigns B3 Rating to $500,000 Class F-R Notes
-----------------------------------------------------------------
Moody's Ratings has assigned ratings to four classes of CLO
refinancing notes (the Refinancing Notes) issued by KKR CLO 49 Ltd.
(the Issuer):  

US$4,000,000 Class X Senior Secured Floating Rate Notes due 2037,
Assigned Aaa (sf)

US$300,000,000 Class A-R Senior Secured Floating Rate Notes due
2037, Assigned Aaa (sf)

US$80,000,000 Class B-R Senior Secured Floating Rate Notes due
2037, Assigned Aa2 (sf)

US$500,000 Class F-R Senior 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
92.5% of the portfolio must consist of first lien senior secured
loans and up to 7.5% of the portfolio may consist of second lien
loans, unsecured loans and permitted non-loan assets.

KKR Financial Advisors II, 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 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, the other
classes of secured notes and 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; and changes to the overcollateralization
test levels; changes to benchmark rate replacement provisions;
additions to the CLO's ability to hold workout and restructured
assets; 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: $500,000,000

Diversity Score: 80

Weighted Average Rating Factor (WARF): 2829

Weighted Average Spread (WAS): 3.50%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 46.0%

Weighted Average Life (WAL): 8.0 years

Methodology Underlying the Rating Action

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

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

The performance of the 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.


KRR CLO 49: Fitch Assigns 'BBsf' Rating on Class E-R Notes
----------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to the KKR
CLO 49 Ltd. reset transaction.

   Entity/Debt         Rating               Prior
   -----------         ------               -----
KKR CLO 49 Ltd.

   X               LT  NRsf    New Rating
   A-2 481939AC0   LT  PIFsf   Paid In Full   AAAsf
   A-R             LT  NRsf    New Rating
   B-1 481939AE6   LT  PIFsf   Paid In Full   AAsf
   B-2 481939AG1   LT  PIFsf   Paid In Full   AAsf
   B-R             LT  NRsf    New Rating
   C 481939AJ5     LT  PIFsf   Paid In Full   Asf
   C-R             LT  Asf     New Rating
   D 481939AL0     LT  PIFsf   Paid In Full   BBB-sf
   D-1-R           LT  BBBsf   New Rating
   D-2-R           LT  BBB-sf  New Rating
   E 481940AA2     LT  PIFsf   Paid In Full   BB-sf
   E-R             LT  BBsf    New Rating
   F-R             LT  NRsf    New Rating

Transaction Summary

KKR CLO 49 Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) managed by KKR Financial
Advisors II, LLC that originally closed in July 2022. The existing
secured notes will be redeemed in full on Oct. 21, 2024 (the
refinancing date). 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', 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
97.57% first-lien senior secured loans and has a weighted average
recovery assumption of 74.7%. 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 40% of the portfolio balance in aggregate while the
top five obligors can represent up to 12.5% of the portfolio
balance in aggregate. The level of diversity required by industry,
obligor and geographic concentrations is in line with other recent
CLOs.

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

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

The 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 '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

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 'AAsf' 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 KKR CLO 49 Ltd. In
cases where Fitch does not provide ESG relevance scores in
connection with the credit rating of a transaction, programme,
instrument or issuer, Fitch will disclose in the key rating drivers
any ESG factor which has a significant impact on the rating on an
individual basis.


LCCM TRUST 2021-FL3: DBRS Confirms B(low) Rating on Cl. G Notes
---------------------------------------------------------------
DBRS Limited confirmed its credit ratings on all classes of Offered
Notes issued by LCCM 2021-FL3 Trust as follows:

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

All trends are Stable.

The credit rating confirmations reflect the overall stable
performance of the transaction as majority of the individual
borrowers continue to progress in their stated business plans to
increase property cash flow. The transaction structure also
benefits from approximately $114.0 million in below-investment
grade credit support, inclusive of the $53.8 million unrated Class
H bond. In conjunction with this press release, Morningstar DBRS
has published a Surveillance Performance Update report with
in-depth analysis and credit metrics for the transaction and with
business plan updates on select loans. To access this report,
please click on the link under Related Documents below or contact
us at info-DBRS@morningstar.com.

At issuance, the initial collateral consisted of 35 floating-rate
mortgage loans secured by 48 mostly transitional properties, with a
cut-off balance totaling $729.4 million. As of the September 2024
remittance, the pool comprised 24 loans secured by 24 transitional
properties, with a cumulative trust balance of $631.5 million. The
transaction is a managed vehicle and was structured with a 24-month
reinvestment period that expired with the December 2023 payment
date. Since issuance, 26 loans with a cumulative trust balance of
$423.1 million have been paid in full, and 13 of these (totaling
$196.4 million) were paid in full since Morningstar DBRS' previous
credit rating action in October 2023. Additionally, eight loans,
totaling $141.5 million, have been added to the trust since the
October 2023 Morningstar DBRS credit rating action. The remaining
loans in the transaction are concentrated by property type, with 11
loans backed by multifamily properties (39.1% of the current trust
balance), five loans (28.5% of the current trust balance) secured
by office properties, and four loans (19.0% of the current trust
balance) by mixed-use properties. In comparison, at issuance,
multifamily properties represented 40.9% of the pool, office
properties represented 18.9%, and mixed-use properties represented
9.0%.

As of September 2024, no loans were in special servicing; however,
there are two loans, representing 5.9% of the pool, that surpassed
their respective July 2024 and August 2024 maturity dates and are
no longer remitting payments. The issuer has the option to exchange
underperforming loans out of the pool, conditional upon a rating
agency confirmation. A third loan, Aventura Corporate Center (7.9%
of the pool) has also passed its maturity date but continues to
remit monthly payments, and discussions surrounding a loan
modification or a potential sale of asset remain ongoing. Five
loans, representing 18.5% of the current trust balance, are being
monitored on the servicer's watchlist for upcoming maturities.
While borrowers continue to progress in their business plans to
stabilize the assets, the majority of loans report DSCRs below 1.0x
based on the most recent financials, largely as a result of the
floating-rate nature of all the loans in the pool. Occupancy
remains depressed at select properties; however, it is expected to
improve as the borrowers work toward achieving their respective
business plans.

The loans are primarily secured by properties in urban and suburban
markets. Ten loans, representing 42.3% of the current trust
balance, are secured by properties in urban markets, as defined by
their Morningstar DBRS Market Ranks of 6, 7, and 8. Ten loans,
representing 40.9% of the pool, are secured by properties in
Morningstar DBRS Market Ranks of 3, 4, and 5, denoting suburban
markets, while four loans, representing 16.7% of the pool, are
secured by properties in tertiary markets, as defined by their
Morningstar DBRS Market Rank of 1 and 2. Leverage across the pool
has remained relatively unchanged since issuance; the current WA
as-is appraised LTV is 71.9% and the WA stabilized LTV is 62.5%. In
comparison, these figures were 67.3% and 63.1%, respectively, at
issuance. Morningstar DBRS recognizes that select property values
may be inflated as the majority of the individual property
appraisals were completed in 2021 and may not reflect the current
environment of rising interest rates or widening capitalization
rates faced by borrowers and lenders. In its analysis for this
review, Morningstar DBRS applied upward LTV adjustments to four
loans, representing 23.8% of the current trust balance.

Through June 2024, the lender had advanced a cumulative $88.2
million in loan future funding to 17 individual borrowers to aid in
property stabilization efforts. The largest advance of $29.9
million was made to the borrower of McArthur Studios (3.5% of the
current pool balance), which is secured by a 152,000 sf mixed-use
(multifamily/event/studio) property located in the McArthur Park
neighborhood of Los Angeles. The borrower's business plan focuses
on completing building system upgrades as well as a complete
renovation of the lobby, ballrooms, and event spaces. An additional
$42.7 million of loan future funding allocated to 12 individual
borrowers remains available. The largest unadvanced portion of
$12.2 million was allocated to the borrower of the Citigroup Center
(10.3% of the pool), which is discussed in detail within the Rating
Report. In addition to this loan, Morningstar DBRS identified a
number of loans that are lagging in their original business plans.
Morningstar DBRS' analysis includes additional adjustments to the
loan-level probability of default for these assets to reflect these
concerns.

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


LENDMARK FUNDING 2024-2: DBRS Finalizes BB(low) Rating on E Notes
-----------------------------------------------------------------
DBRS, Inc. finalized its provisional credit ratings on the classes
of notes to be issued by Lendmark Funding Trust 2024-2 (Lendmark
2024-2), as follows:

-- $200,020,000 Class A Notes at AAA (sf)
-- $28,910,000 Class B Notes at AA (low) (sf)
-- $23,860,000 Class C Notes at A (low) (sf)
-- $22,910,000 Class D Notes at BBB (low) (sf)
-- $32,380,000 Class E Notes at BB (low) (sf)

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

(1) The transaction assumptions consider Morningstar DBRS's
baseline macroeconomic scenarios for rated sovereign economies,
available in its commentary Baseline Macroeconomic Scenarios for
Rated Sovereigns: September 2024 Update, published on September 24,
2024. These baseline macroeconomic scenarios replace Morningstar
DBRS's moderate and adverse coronavirus pandemic scenarios, which
were first published in April 2020.

(2) The Morningstar DBRS CNL assumption is 11.00% and is driven by
the re-investment criteria in a worst case pool scenario. The CNL
assumption reflects an increase in inflation-led portfolio losses
throughout 2022 and early 2023. Lendmark has since tightened their
underwriting, enhanced their servicing touchpoints and tightened
the re-investment criteria for Series 2024-2. While losses remain
elevated, overall they are stable. The CNL assumption additionally
incorporates a 5.00% recovery credit for all products based upon
historical recovery performance

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

-- Credit enhancement is in the form of OC, subordination, amounts
held in the reserve fund, and excess spread. Credit enhancement
levels are sufficient to support Morningstar DBRS's stressed
projected finance yield, principal payment rate, and charge-off
assumptions under various stress scenarios.

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

(5) Lendmark's capabilities with regard to originations,
underwriting, and servicing.

-- Morningstar DBRS has performed an operational review of
Lendmark and considers the entity to be an acceptable originator
and servicer of unsecured personal loans with an acceptable back-up
servicer.

-- Lendmark's senior management team has considerable experience
and a successful track record within the consumer loan industry.
(6) The credit quality of the collateral and performance of
Lendmark's consumer loan portfolio. Morningstar DBRS has used a
hybrid approach in analyzing the Lendmark portfolio that
incorporates elements of static pool analysis employed for assets,
such as consumer loans, and revolving asset analysis, employed for
such assets as credit card master trusts.

-- The weighted-average (WA) remaining term of the Statistical
Cut-Off Date is 46 months.

-- The WA Current Bureau Score as of the Statistical Cut-Off Date
is approximately 625.

-- The weighted-average coupon (WAC) as of Statistical Cut-Off
Date is 26.78%, and the transaction includes a Reinvestment
Criteria Event if the WAC is less than 24.50%.

-- The Morningstar DBRS's base-case assumption for the finance
yield is 24.50%.

-- Morningstar DBRS applied a finance yield haircut of 10.00% for
Class A, 7.78% for Class B, 5.33% for Class C, 3.33% for Class D
and 1.33% for Class E. While these haircuts are lower than the
range described in the Morningstar DBRS's Rating U.S. Credit Card
Asset-Backed Securities methodology, the fixed-rate nature of the
underlying loans, lack of interchange fees, and historical yield
consistency support these stressed assumptions.

-- Principal payment rates for Lendmark's portfolio, as estimated
by Morningstar DBRS, have generally averaged between 3.0% and 5.0%
over the past several years.

-- The Morningstar DBRS's base-case assumption for the principal
payment rate is 3.20%.

-- Morningstar DBRS applied a payment rate haircut of 45.00% for
Class A, 39.44% for Class B, 33.33% for Class C, 26.67% for Class D
and 16.67% for Class E.

-- The legal structure and expected presence of legal opinions
that address the true sale of the assets to the Issuer, the
nonconsolidation of the special-purpose vehicle with Lendmark, that
the trust has a valid first-priority security interest in the
assets, and consistency with the Morningstar DBRS's Legal Criteria
for U.S. Structured Finance.

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

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


LHOME MORTGAGE 2024-RTL5: DBRS Gives Prov. B Rating on M2 Certs
---------------------------------------------------------------
DBRS, Inc. assigned provisional credit ratings to the
Mortgage-Backed Notes, Series 2024-RTL5 (the Notes) to be issued by
LHOME Mortgage Trust 2024-RTL5 (LHOME 2024-RTL5 or the Issuer) as
follows:

-- $289.9 million Class A1 at (P) A (low) (sf)
-- $20.6 million Class A2 at (P) BBB (low) (sf)
-- $23.8 million Class M1 at (P) BB (low) (sf)
-- $15.7 million Class M2 at (P) B (sf)

The (P) A (low) (sf) credit rating reflects 21.30% of credit
enhancement (CE) provided by the subordinated notes and
overcollateralization. The (P) BBB (low) (sf), (P) BB (low) (sf),
and (P) B (sf) credit ratings reflect 15.70%, 9.25%, and 5.00% of
CE, respectively.

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

This transaction is a securitization of a two-year revolving
portfolio of residential transition loans (RTLs) funded by the
issuance of the Mortgage-Backed Notes, Series 2024-RTL5 (the
Notes). As of the Initial Cut-Off Date, the Notes are backed by:

-- 780 mortgage loans with a total principal balance of
approximately $200,064,773

-- Approximately $168,356,280 in the Accumulation Account

-- Approximately $3,000,000 in the Prefunding Interest Account.

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

LHOME 2024-RTL5 represents the 20th RTL securitization issued by
the Sponsor, Kiavi Funding, Inc. (Kiavi). Founded in 2013 as
LendingHome Funding Corporation and rebranded as Kiavi in November
2021, Kiavi is a privately held, technology-enabled lender that
provides business-purpose loans for real estate investors engaged
in acquiring, renovating, and either reselling or holding for
investment purposes single-family residential properties.

The revolving portfolio generally consists of first-lien,
fixed-rate, interest-only (IO) balloon RTL with original terms to
maturity of 12 to 24 months. The loans may include extension
options, which can lengthen maturities beyond the original terms.
The characteristics of the revolving pool will be subject to
eligibility criteria specified in the transaction documents and
include:

-- A minimum non-zero weighted-average (NZ WA) FICO score of 735.
-- A maximum NZ WA loan-to-cost ratio of 91.5%.
-- A maximum NZ WA as-repaired loan-to-value ratio 73.0%.

RTL FEATURES

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

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

In the LHOME 2024-RTL5 revolving portfolio, RTLs may be:

(1) Fully funded:

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

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

(2) Partially funded:

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

After completing certain construction/repairs using their own
funds, the borrower usually seeks reimbursement by making draw
requests. Generally, construction draws are disbursed only upon the
completion of approved construction/repairs and after a
satisfactory construction progress inspection. Based on the LHOME
2024-RTL5 eligibility criteria, unfunded commitments are limited to
40.0% of the portfolio by aggregate principal limit.

CASH FLOW STRUCTURE AND DRAW FUNDING

The transaction employs a sequential-pay cash flow structure.
During the reinvestment period, the Notes will generally be IO.
After the reinvestment period, principal will be applied to pay
down the Notes sequentially. If the Issuer does not redeem the
Notes by the payment date in March 2027, the fixed rates on the
Class A1 and Class A2 Notes will step up by 1.000% the following
month.

There will be no advancing of delinquent (DQ) interest on any
mortgage by the Servicer or any other party to the transaction.
However, the Servicer is obligated to fund Servicing Advances,
which include taxes, insurance premiums, and reasonable costs
incurred in the course of servicing and disposing properties. The
Servicer will be entitled to reimburse itself for Servicing
Advances from available funds prior to any payments on the Notes.

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

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

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

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

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

OTHER TRANSACTION FEATURES

Optional Redemption

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

Repurchase Option

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

Loan Sales

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

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

-- The Depositor elects to exercise its Repurchase Option;

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

-- An optional redemption occurs.

U.S. Credit Risk Retention

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

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


MADISON PARK LXVI: Fitch Assigns 'BB+(EXP)sf' Rating on Cl. E Notes
-------------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
Madison Park Funding LXVI, Ltd.

   Entity/Debt              Rating           
   -----------              ------            
Madison Park Funding
LXVI, Ltd.

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

Transaction Summary

Madison Park Funding LXVI, Ltd. (the issuer) is an arbitrage cash
flow collateralized loan obligation (CLO) that will be managed by
UBS Asset Management (Americas) LLC. 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'/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
97.1% first-lien senior secured loans and has a weighted average
recovery assumption of 74.63%. 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 5.1-year
reinvestment period and reinvestment criteria similar to other
CLOs. Fitch's analysis was based on a stressed portfolio created by
adjusting the indicative portfolio to reflect permissible
concentration limits and collateral quality test levels.

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

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

RATING SENSITIVITIES

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

Variability in key model assumptions, such as decreases in recovery
rates and increases in default rates, could result in a downgrade.
Fitch evaluated the notes' sensitivity to potential changes in such
metrics; the results under these sensitivity scenarios are as
severe as between 'BBB+sf' and 'AA+sf' for class A-1 notes, between
'BBB+sf' and 'AA+sf' for class A-2 notes, between 'BB+sf' and
'A+sf' for class B notes, between 'B+sf' and 'BBB+sf' for class C
notes, between less than 'B-sf' and 'BB+sf' for class D-1 notes,
between less than 'B-sf' and 'BB+sf' for class D-2 notes, and
between less than 'B-sf' and 'BB-sf' for class E notes.

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 notes, 'AA+sf' for class C notes,
'Asf' for class D-1 notes, 'A-sf' for class D-2 notes, and 'BBB+sf'
for class E notes.

Key Rating Drivers and Rating Sensitivities are further described
in the presale report, which is available at www.fitchratings.com.

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 LXVI, 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.


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

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

   A-1-RR           LT AAAsf  New Rating     AAA(EXP)sf
   A-1R 55819TAN1   LT PIFsf  Paid In Full   AAAsf
   A-2-RR           LT AAAsf  New Rating     AAA(EXP)sf
   A-2R 55819TAQ4   LT PIFsf  Paid In Full   AAAsf
   B-1-RR           LT AA+sf  New Rating     AA+(EXP)sf
   B-2-RR           LT AA+sf  New Rating     AA+(EXP)sf
   C-RR             LT A+sf   New Rating     A+(EXP)sf
   D-1-RR           LT BBB+sf New Rating     BBB-(EXP)sf
   D-2-RR           LT BBB-sf New Rating     BBB-(EXP)sf
   E-RR             LT BB+sf  New Rating     BB+(EXP)sf
   F-RR             LT NRsf   New Rating     NR(EXP)sf

The final ratings on the class D-1-RR notes differs from the
expected rating of 'BBB-(EXP)sf' published on Sept. 12, 2024.
Following the updated cost of funding for the liabilities and final
portfolio analysis, the class D-1-RR notes are deemed robust to
assign a 'BBB+sf' rating. These notes can withstand a default rate
of 42.8% versus the 'BBB+sf' default stress of 40.5% assuming a
63.5% recovery given default, assuming portfolio of 95% floating
rate assets and 5% fixed rate assets, and can withstand a default
rate of 44.3% when assuming the portfolio is 100% floating rate
assets. There are approximately 3% fixed rate assets in the
portfolio.

Madison Park Funding XX, Ltd. has issued fixed rate D-2-RR notes,
rather than the floating rate D-2-RR notes that were anticipated
when the expected ratings were assigned in September.

Transaction Summary

Madison Park Funding XX, Ltd. (the issuer) is an arbitrage cash
flow collateralized loan obligation (CLO) that will be managed by
UBS Asset Management (Americas) LLC which originally closed in
April 2016 and was first refinanced in June 2018. The secured notes
will be refinanced in whole on Oct. 21, 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 $424 million, excluding defaults, of primarily first
lien senior secured leveraged loans.

KEY RATING DRIVERS

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

Asset Security (Positive): The indicative portfolio consists of
95.98% first-lien senior secured loans and has a weighted average
recovery assumption of 75.24%. 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 as
severe as between 'Asf' and 'AAAsf' for class A-1-RR, between
'BBB+sf' and 'AA+sf' for class A-2-RR, between 'BB+sf' and 'A+sf'
for class B-RR, between 'B+sf' and 'A-sf' for class C-RR, between
less than 'B-sf' and 'BB+sf' for class D-1-RR, between less than
'B-sf' and 'BB+sf' for class D-2-RR, and between less than 'B-sf'
and 'BB-sf' for class E-RR.

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

Upgrade scenarios are not applicable to the class A-1-RR and class
A-2-RR 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-RR, 'AA+sf' for class C-RR,
'A+sf' for class D-1-RR, 'Asf' for class D-2-RR, and 'BBB+sf' for
class E-RR.

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

A 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 XX, 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.


MADISON PARK XX: Moody's Assigns B3 Rating to $250,000 F-RR Notes
-----------------------------------------------------------------
Moody's Ratings has assigned ratings to two classes of CLO
refinancing notes (the Refinancing Notes) issued by Madison Park
Funding XX, Ltd. (the Issuer):  

US$260,095,000 Class A-1-RR Floating Rate Senior Notes due 2036,
Definitive Rating Assigned Aaa (sf)

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

RATINGS RATIONALE

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

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 96%
of the portfolio must consist of first lien senior secured loans
and eligible investments and up to 4.0% of the portfolio may
consist of non-senior secured loans.

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

In addition to the issuance of the Refinancing Notes, the other
classes of secured notes and additional subordinated notes, a
variety of other changes to transaction features will occur in
connection with the refinancing. These include: reinstatement and
extension of the reinvestment period; extensions of the stated
maturity and non-call period; changes to certain collateral quality
tests; and 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: $425,000,000

Diversity Score: 60

Weighted Average Rating Factor (WARF): 2998

Weighted Average Spread (WAS): 3.10%

Weighted Average Coupon (WAC): 6.0%

Weighted Average Recovery Rate (WARR): 46.25%

Weighted Average Life (WAL): 8.0 years

Methodology Underlying the Rating Action:

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

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

The performance of the 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.


MANUFACTURED HOUSING 2000-3: S&P Lowers Class A Certs to 'D (sf)'
-----------------------------------------------------------------
S&P Global Ratings lowered its rating to 'D (sf)' from 'CC (sf)' on
the class A certificates from Manufactured Housing Contract
Senior/Subordinate Pass-Through Certificates Series 2000-3. S&P
subsequently withdrew its rating on the class.

The transaction is a U.S. ABS transaction backed by manufactured
housing loans.

The downgrade follows the transaction's failure to make timely
interest payments for 12 consecutive months.




MARINER FINANCE 2024-B: DBRS Gives Prov. BB Rating on E Notes
-------------------------------------------------------------
DBRS, Inc. assigned provisional credit ratings to the following
classes of notes (collectively, the Notes) to be issued by Mariner
Finance Issuance Trust 2024-B (MFIT 2024-B):

-- $199,560,000 Class A Notes at (P) AAA (sf)
-- $31,180,000 Class B Notes at (P) AA (low) (sf)
-- $21,330,000 Class C Notes at (P) A (sf)
-- $18,710,000 Class D Notes at (P) BBB (sf)
-- $29,220,000 Class E Notes at (P) BB (sf)

CREDIT RATING RATIONALE/DESCRIPTION

The credit ratings are based on Morningstar DBRS' review of the
following analytical considerations:
(1) The transaction assumptions consider Morningstar DBRS' baseline
macroeconomic scenarios for rated sovereign economies, available in
its commentary Baseline Macroeconomic Scenarios For Rated
Sovereigns: September 2024 Update, published on September 25, 2024.
These baseline macroeconomic scenarios replace Morningstar DBRS'
moderate and adverse COVID-19 pandemic scenarios, which were first
published in April 2020.

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

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

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

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

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

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

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

-- The weighted-average (WA) remaining term of the collateral pool
is approximately 38 months.

-- The WA coupon (WAC) of the pool is 26.35% and the transaction
includes a reinvestment criteria event that the WAC is less than
24.50%. All loans going into the pool will have an APR less than
36.00%.

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

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

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

-- The Morningstar DBRS base-case assumption for the charge-off
rate is 12.90% which is based on the MFIT 2024-B reinvestment
criteria and recent credit performance.

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

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

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

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

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


MF1 2023-FL12: DBRS Confirms B(low) Rating on 3 Classes
-------------------------------------------------------
DBRS, Inc. confirmed all credit ratings on the classes of notes
issued by MF1 2023-FL12 LLC as follows:

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

All trends are Stable.

The credit rating confirmations reflect the overall stable
performance of the transaction, which has remained in line with
Morningstar DBRS' expectations since issuance as evidenced by
stable performance and leverage metrics. Additionally, the trust
continues to be primarily solely secured by multifamily collateral,
which have historically exhibited lower default rates and retained
values in times of market downturns as compared with other property
types. In conjunction with this press release, Morningstar DBRS has
published a Surveillance Performance Update report with in-depth
analysis and credit metrics for the transaction as well as business
plan updates on select loans.

The initial collateral consisted of 21 floating-rate mortgages
secured by 21 mostly transitional properties with a cut-off date
balance totaling $895.2 million, excluding $129.2 million of future
funding commitments. Most loans were in a period of transition with
plans to stabilize performance and improve the underlying assets'
values. The managed transaction includes an 18-month reinvestment
period expiring in April 2025. As of the September 2024 remittance,
the pool is unchanged since issuance.

The pool is primarily secured by properties in suburban markets,
with nine loans, representing 42.1% of the pool, assigned a
Morningstar DBRS Market Rank of 3, 4, or 5. An additional seven
loans, representing 40.6% of the pool, are secured by properties in
urban markets with a Morningstar DBRS Market Rank of 6, 7, or 8.
The remaining five loans, representing 17.3% of the pool, are
backed by properties with a Morningstar DBRS Market Rank of 1 or 2,
denoting tertiary markets. These market-type concentrations remain
generally in line with the pool composition at closing.

Leverage across the pool has remained unchanged since issuance. The
current weighted-average (WA) as-is loan-to-value ratio (LTV) is
65.0% and the current WA stabilized LTV is 63.5%, based on the
as-is and stabilized appraised values for the collateral properties
as provided at issuance or contribution and the current outstanding
loan balances. In the analysis for this review, Morningstar DBRS
applied LTV adjustments to 10 loans, representing 58.2% of the
current trust balance, generally reflective of higher
capitalization rate (cap rate) assumptions compared with the
implied cap rates based on the appraisals. This was merited either
based on an appraiser's cap rate that was low as compared with
assumptions for similarly located and/or positioned assets placed
in recent vintage deals or low compared with market cap rates,
which have generally increased since 2022 when interest rate
increases began.

As of the September 2024 remittance, there were no loans in special
servicing, but one loan, Poth Brewery, representing 3.9% of the
current trust balance, was reported 30 days delinquent. The loan is
secured by a mid-rise, mixed-use building totaling 131 multifamily
units and 27,646 square feet (sf) of commercial space in
Philadelphia. As of the July 2024 rent roll, the multifamily
portion was 87.9% occupied (93.9% leased) while the commercial
portion was 50% occupied (75% leased). In the analysis for this
loan, Morningstar DBRS applied upward LTV adjustments for both the
as-is and stabilized figures and increased the loan's probability
of default to reflect the increased risk due to the outstanding
delinquency and lag in property stabilization, which resulted in a
loan-level expected loss (EL) that exceeded the pool's average EL.

There were 16 loans, representing 79.1% of the current trust
balance, on the servicer's watchlist as of the September 2024
reporting. The majority of these loans have been flagged for
occupancy and cash flow concerns; however, Morningstar DBRS notes
that the majority of the underlying properties are newly built and
are in the early stages of their respective business plans. In
addition to the unrated equity piece at the bottom of the capital
stack with a balance of just under $50 million, there is also
approximately $61.5 million in classes with below investment-grade
credit ratings, with total credit enhancement of 12.4% for the BBB
(low) (sf)-rated Class E Note.

Through August 2024, the lender had advanced cumulative loan future
funding of $79.9 million to 14 outstanding individual borrowers to
aid in property stabilization efforts. The largest advance, $12.6
million, was to the borrower of the Oaklyn loan, which is secured
by a newly built, Class A, high-rise multifamily property
consisting of 275 luxury rental apartments and 19,328 sf of
ground-floor retail space in the Fort Lauderdale suburb of Oakland
Park, Florida. The advanced funds have been used to fund the
remaining construction costs and leasing costs associated with the
retail space. According to the collateral manager, the remaining
construction items have been completed and the certificate of
occupancy was received in May 2024. The remaining future funding is
allocated to fund interest shortfalls as well as a $2.0 million
earn-out reserve, which is subject to certain performance
benchmarks. As of the provided July 2024 rent roll, the multifamily
component was 86.1% occupied while the retail portion was 59%
occupied.

An additional $68.2 million of loan future funding allocated to 10
of the outstanding individual borrowers remains available. The
largest portion of available funding ($30.2 million) is allocated
to the Creekside loan, which is secured by a newly built, 155-unit,
built-to-rent community in Guyton, Georgia, approximately 30 miles
north of Savannah. The property was constructed in two phases, with
Phase 1 consisting of 79 units and Phase 2, which is currently
under development, consisting of 76 units. The funds are available
to fund construction costs and two separate performance-based
earn-outs totaling $12.5 million and $6.5 million. As of the July
2024 rent roll provided by the Issuer, Phase 1 was 91.1% occupied
while Phase 2 is currently in the early stages of construction and
no units have been delivered by the sponsor.

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


MORGAN STANLEY 2015-C21: Fitch Lowers Rating on 555A Certs to BBsf
------------------------------------------------------------------
Fitch Ratings has downgraded and assigned a Negative Rating Outlook
to Class 555A of Morgan Stanley Bank of America Merrill Lynch
Trust, commercial mortgage pass-through certificates, series
2015-C21 (MSBAM 2015-C21).  Fitch has also affirmed 13 classes of
MSBAM 2015-C21.  The Outlooks for classes B and X-B have been
revised to Negative from Stable, and the Outlooks for classes PST
and C remain Negative.

The MSBAM 2015-C21 transaction contains a $30 million non-pooled
senior B note (rake certificates) that represents the beneficial
interest in the 555 11th Street NW loan. The 555A and 555B rake
certificates are subordinate in right of payment of interest and
principal to the 555 11th Street NW A notes and derive their cash
flow solely from the 555 11th Street NW loan. The 555A and 555B
rake certificates are generally not subject to losses from any of
the other loans collateralizing the MSBAM 2015-C21 transaction.

In addition, Fitch has affirmed 13 classes of Morgan Stanley Bank
of America Merrill Lynch Trust, commercial mortgage pass-through
certificates, series 2015-C26 (MSBAM 2015-C26). The Outlooks for
classes B, X-B and C have been revised to Negative from Stable, and
the Outlooks for classes D, X-D, E and F remain Negative.

   Entity/Debt          Rating           Prior
   -----------          ------           -----
MSBAM 2015-C26

   A-3 61690VAX6    LT AAAsf  Affirmed   AAAsf
   A-4 61690VAY4    LT AAAsf  Affirmed   AAAsf
   A-5 61690VAZ1    LT AAAsf  Affirmed   AAAsf
   A-S 61690VBB3    LT AAAsf  Affirmed   AAAsf
   A-SB 61690VAW8   LT AAAsf  Affirmed   AAAsf
   B 61690VBC1      LT AAsf   Affirmed   AAsf
   C 61690VBD9      LT Asf    Affirmed   Asf
   D 61690VAE8      LT BBB-sf Affirmed   BBB-sf
   E 61690VAG3      LT BB-sf  Affirmed   BB-sf
   F 61690VAJ7      LT B-sf   Affirmed   B-sf
   X-A 61690VBA5    LT AAAsf  Affirmed   AAAsf
   X-B 61690VAA6    LT AAsf   Affirmed   AAsf
   X-D 61690VAC2    LT BBB-sf Affirmed   BBB-sf

MSBAM 2015-C21

   555A 61764XBA2   LT BBsf   Downgrade  BBB-sf
   A-3 61764XBH7    LT AAAsf  Affirmed   AAAsf
   A-4 61764XBJ3    LT AAAsf  Affirmed   AAAsf
   A-S 61764XBL8    LT AAAsf  Affirmed   AAAsf
   A-SB 61764XBG9   LT AAAsf  Affirmed   AAAsf
   B 61764XBM6      LT Asf    Affirmed   Asf
   C 61764XBP9      LT BBsf   Affirmed   BBsf
   D 61764XAN5      LT CCCsf  Affirmed   CCCsf
   E 61764XAQ8      LT CCsf   Affirmed   CCsf
   F 61764XAS4      LT Csf    Affirmed   Csf
   PST 61764XBN4    LT BBsf   Affirmed   BBsf
   X-A 61764XBK0    LT AAAsf  Affirmed   AAAsf
   X-B 61764XAA3    LT Asf    Affirmed   Asf
   X-E 61764XAG0    LT CCsf   Affirmed   CCsf

KEY RATING DRIVERS

Declining Performance on 555 11th Street NW: The downgrade to class
555A reflects a lower Fitch sustainable net cash flow (NCF) since
the prior rating action, factoring in the continued deterioration
of both property performance and Washington, D.C. office market
fundamentals, as well as the significant refinance risk as the loan
approaches its November 2024 maturity.

The Negative Outlook on class 555A reflects the potential for
further downgrade should Fitch's sustainable NCF and value decline
further from the lack of leasing progress and/or continued
worsening market conditions.

The 555 11th Street NW loan is secured by a 414,204-sf office
building in Washington, D.C. The property also contains
approximately 57,000 sf of retail space, the majority of which is
occupied by a theater tenant, Silver Cinemas. Occupancy at the
property has fallen further to 77% as of the June 2024 rent roll
from 85% in May 2023, 90% at YE 2022 and 97% at YE 2021. The latest
decrease in occupancy was due to three tenants vacating upon lease
expiration; FGS Global (US), LLC (5.4% NRA), The Alliance for
Climate Protection (2.3% NRA) and Rasky Baerlein Strategic
Communications, Inc. (0.8% NRA).

Major in-place tenants include Latham & Watkins (58.2% of NRA;
lease expiry in January 2031) and Silver Cinemas (9.7%; March
2032). There is minimal near-term rollover, particularly given that
Latham & Watkins has already agreed to expand into the available
20,173-sf space on the building's fourth floor beginning in January
2027.

Fitch's updated NCF of $11.2 million is 19.8% below Fitch's
issuance NCF of $14 million, largely driven by increased operating
expenses, higher tenant improvement and leasing commission costs
(TI/LCs), and lower occupancy assumptions.

Fitch's updated NCF incorporates leases-in-place as of the June
2024 rent roll and assumed a gross up rent of $58 psf to achieve a
stabilized occupancy of 82.5%; this is in line with the overall
Washington, D.C. office market and factors in Latham & Watkins'
long-term tenancy, overall minimal near-term rollover and the
property's historical overperformance relative to the market. Fitch
also assumed 60% reimbursement rate and expenses in line with most
recent servicer-reporting. Fitch's total TI/LCs of $3.72 psf are
well above the $0.89 psf assumed at issuance.

Fitch increased its cap rate to 9% from 8.5% at issuance due to the
deteriorating office sector outlook and worsened office market
conditions in Washington, D.C. Fitch's analysis also applied an
upward loan-to-value (LTV) hurdle adjustment due to the low
fixed-rate coupon of 3.1%.

Performance and 'B' Loss Expectations: Transaction-level 'B' rating
case losses for MSBAM 2015-C21 and MSBAM 2015-C26 are 12.43% and
4.41%, respectively. Fitch Loans of Concern (FLOCs) comprise eight
loans (27.7% of the pool) in MSBAM 2015-C21, including three
specially serviced loans (13%) and five loans (25.1%) in MSBAM
2015-C26, including one specially serviced loan (11.1%).

The Negative Outlooks in MSBAM 2015-C21 reflect the elevated office
concentration (25.2%) and the potential for future downgrades
should performance of the FLOCs, primarily Westfield Palm Desert
Mall (9.1%), 555 11th Street NW (8.8%) and International Park
(3.3%), continue to decline or fail to stabilize.

Negative Outlooks in MSBAM 2015-C26 reflect the elevated office
concentration of 31.4% and the potential for downgrades should more
loans than expected fail to refinance, along with lack of
performance stabilization of the FLOCs, Herald Center (11.1%),
Palmer Center (7.1%), Skylight Office Tower (2.9%) and Market
Square (2.7%).

FLOCs; Specially Serviced Loans: Westfield Palm Desert Mall (9.1%
of MSBAM 2015-C21) is the largest loss contributor for the MSBAM
2015-C21 transaction. The loan, which transferred to special
servicing in July 2020 due to payment default, is secured by a
572,724-sf portion of a 977,888-sf regional mall located in Palm
Desert, CA with non-collateral anchor tenants that include Macy's
and JCPenney.

The loan was assumed in November 2023 by Pacific Retail Capital
Partners and modified with a two-year extension until March 2027.
Occupancy was 90.4% as of July 2024. Fitch's 'Bsf' rating case loss
of 63.6% (prior to concentration add-ons) is based on a discount to
the June 2023 appraisal value, reflecting a stressed value of $80
psf.

Stone Ridge Plaza (2.5% of MSBAM 2015-C21), the second largest loss
contributor for the MSBAM 2015-C21 transaction, transferred to
special servicing in October 2020 due to payment default. The loan
is secured by a 178,915-sf shopping center located in the
Rochester, NY metro area. The loan transferred to special servicing
shortly after two tenants accounting for 16.3% of the property's
NRA vacated and reduced the occupancy at the time to 68%. A
foreclosure action was initiated in April 2022 and a receiver was
put in place. Current occupancy was 60% per the June 2024 rent
roll, down from 67% a year ago.

The receiver continues to focus efforts on lease renewals and
improving occupancy with a foreclosure sale expected in the fourth
quarter of 2024. Fitch's 'Bsf' rating case loss of 86.5% (prior to
concentration add-ons) is based on a discount to the March 2023
appraisal value, reflecting a stressed value of $40 psf.

Palmer Center (7.1% of MSBAM 2015-C26), the largest loss
contributor for the MSBAM 2015-C26 transaction, is secured by a
480,390-sf office complex located in Colorado Springs, CO.
Occupancy was 78% as of the June 2024 rent roll, which is in line
with historical levels over the past two years since Wells Fargo
(formerly 9.2% of NRA) and Colorado Springs Health Care (formerly
8.8% of NRA) vacated their respective spaces between June and
December 2022. As of the June 2024 rent roll, an additional 16.0%
of the in-place leases are scheduled to roll by YE 2026.

Fitch's 'Bsf' rating case loss of 25.2% (prior to concentration
add-ons) is based on a 10% cap rate and 25% stress to the YE 2023
NOI due to the occupancy decline and near-term rollover concerns.
In addition, Fitch's analysis incorporated a higher probability of
default due to recent performance and anticipated refinance
concerns.

Market Square Plaza (2.7% of MSBAM 2015-C26), the second largest
loss contributor for the MSBAM 2015-C26 transaction, is secured by
a 172,629-sf office building constructed in 2005 and located in
downtown Harrisburg, PA. The property was 93% occupied as of the
June 2024 rent roll; however, the property has 39% of the NRA
rolling by YE 2025.

Fitch's 'Bsf' rating case loss of 25.1% (prior to concentration
add-ons) is based on a 20% stress to YE 2023 NOI and a 10% cap
rate. In addition, Fitch's analysis incorporated a higher
probability of default due to the near-term rollover and recent
cash flow declines, as well as refinance concerns.

Increased Credit Enhancement and Defeasance Concentration: As of
the September 2024 reporting, the MSBAM 2015-C21 pool's aggregate
balance has declined 21.4% since issuance. In addition, 10.2% of
the pool has been fully defeased.

As of the September 2024 reporting, the MSBAM 2015-C26 pool's
aggregate balance has declined 17.5% since issuance. In addition,
16.2% of the pool has been fully defeased.

RATING SENSITIVITIES

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

- Downgrades to senior and junior '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 classes rated in the 'AAsf' and 'Asf' categories,
especially those with Negative Outlooks, may occur should
performance of the FLOCs deteriorate further or if more loans than
expected default at or prior to maturity. These FLOCs include
Westfield Palm Desert Mall, International Park and Stone Ridge
Plaza in MSBAM 2015-C21, Herald Center, Palmer Center, Skylight
Office Tower, and Market Square Plaza in MSBAM 2015-C26;

- Downgrades to 'BBBsf', 'BBsf' and 'Bsf' category rated classes
are possible with higher expected losses from continued
underperformance of the FLOCs or with greater certainty of
near-term losses on specially serviced assets;

- Downgrades to 'CCCsf', 'CCsf', and 'Csf' could occur should
additional loans transfer to special servicing and/or default, or
should losses be realized or become more certain;

- Further downgrades to Class 555A could occur with continued
occupancy and cash flow deterioration at 555 11th Street NW, or
lack of leasing progress to achieve stabilized occupancy assumed by
Fitch.

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

- Upgrades to 'AAsf' and 'Asf' category rated classes are possible
with significantly increased CE from paydown, coupled with stable
to improved pool-level loss expectations and improved performance
of FLOCs;

- Upgrades to the 'BBBsf' category rated classes could 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
are larger than expected and there is sufficient CE to the
classes;

- Upgrades to 'CCCsf', 'CCsf', and 'Csf' are not expected but
possible with better than expected recoveries on specially serviced
loans or significantly higher values on FLOCs;

- An upgrade to Class 555A is unlikely as the loan nears its
original scheduled maturity in November 2024, but could occur with
sustained occupancy and cash flow improvement at 555 11th Street
NW.

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.


MORGAN STANLEY 2019-PLND: DBRS Cuts Rating on 2 Tranches to CCC
---------------------------------------------------------------
DBRS, Inc. downgraded credit ratings on three classes of Commercial
Mortgage Pass-Through Certificates, Series 2019-PLND issued by
Morgan Stanley Capital I Trust 2019-PLND as follows:

-- Class A to CCC (sf) from BB (sf)
-- Class B to CCC (sf) from B (sf)
-- Class X-EXT to CCC (sf) from BB (high) (sf)

DBRS Morningstar also confirmed the credit ratings on the following
classes:

-- Class C at CCC (sf)
-- Class D at C (sf)
-- Class E at C (sf)
-- Class F at C (sf)
-- Class G at C (sf)

All credit ratings have been removed from the Under Review with
Negative Implications designation where they had been placed on
July 5, 2024, following the shorting of interest to the entire
capital stack that began in May 2024. In May 2024, the servicer
provided a Notice of Non-Recoverability, citing the proceeds
implied by the December 2023 appraisals. As of the September 2024
remittance, cumulative interest shortfalls on Morningstar DBRS
rated bonds totalled $11.0 million (with all classes being shorted
interest), up from $5.8 million at Morningstar DBRS' last credit
rating action in July 2024. Inclusive of the $39.5 million in
previously advanced principal and interest, the total exposure as
of September 2024 stood at $289.5 million.

There has been no interest distributed to bondholders since May
2024, when the Notice of Non-Recoverability was provided. The
credit rating downgrades for Classes A, B, and X-EXT are reflective
of continued interest shortfalls. Morningstar DBRS has limited
tolerance for unpaid interest, limited to six reporting periods for
the BB (sf) and B (sf) credit rating categories. The underlying
assets, The Hilton Portland Downtown (Hilton Downtown) and The
Duniway Portland (the Duniway), have been real estate owned (REO)
since January 2023, and Morningstar DBRS remains concerned
regarding the properties' deteriorated performance and uncertain
disposition timeline. Since the last credit rating action, the
special servicer has provided minimal updates with regards to plans
for stabilization and/or disposition. Although a liquidation
scenario based on the most recent appraised value indicates the
senior classes are insulated from loss, Morningstar DBRS' credit
ratings are constrained given the expectation of untimely interest.
Morningstar DBRS expects interest shortfalls will continue to
increase through the remainder of the workout period, a key
contributing factor for the credit rating downgrades.

At issuance, the floating rate transaction was secured by a $240.0
million first-lien mortgage loan on two Hilton-branded,
full-service hotels on adjacent city blocks in Portland, Oregon.
The Hilton Downtown and The Duniway are near the corner of SW
Taylor Street and SW 6th Avenue in Portland's downtown core. The
two hotels combine for 782 rooms, approximately 63,000 square feet
of meeting space, and three food and beverage outlets. The loan
initially transferred to the special servicer for monetary default
in June 2020, with a foreclosure action finalized in January 2023,
and the assets are now REO. There is a planned property improvement
plan in 2025 for both properties, which is targeted to renovate
guest rooms, the meeting space, and common areas. The special
servicer is reportedly working to stabilize property performance
ahead of disposition.

The December 2023 appraisals value the properties on an as-is basis
at $204.5 million combined, a decline from the March 2023 combined
value of $254.8 million and the issuance value of $340.6 million.
Including the expected liquidation expenses, Morningstar DBRS
estimates a trust exposure in excess of $307 million at final
resolution. To determine the potential for recoverability,
Morningstar DBRS applied a 15% haircut to the December 2023
appraised figures, resulting in a liquidated loss of $132.7
million. That scenario suggests losses will be realized through
Class D; it is noteworthy that the transaction structure includes a
concentration of smaller balance classes, which include Classes B
and C, which combine for $30.0 million, meaning there is relatively
low cushion against losses for the senior three classes against
further value decline in the Morningstar DBRS liquidation scenario.
This factor likely contributed to the servicer's decision to issue
a Non-Recoverability Notice and to short the full capital stack.

For the trailing 12-month (T-12) period ended April 30, 2024, STR
reported that occupancy, average daily rate, and revenue per
available room (RevPAR) were 54.0%, $164.28, and $88.75,
respectively, for the Hilton Downtown, and 53.25%, $164.21, and
$87.85, respectively, for the Duniway. For the same T-12 period,
the two properties achieved RevPAR penetrations of 103.6% and
100.3%, relative to their competitive sets. Both properties
exhibited RevPAR and RevPAR penetration metrics that were mostly in
line with the prior year reporting. The subject properties have
seen some improvements across certain performance metrics coming
out of the coronavirus pandemic; however, cash flows remain
significantly depressed as compared with pre-pandemic figures.
According to the most recent financials, YE2023 net cash flow (NCF)
was reported at approximately $8.1 million, sharply below the
Morningstar DBRS NCF of $18.2 million derived when credit ratings
were assigned in 2020.

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


MORGAN STANLEY 2020-HR8: DBRS Confirms BB Rating on J-RR Certs
--------------------------------------------------------------
DBRS Limited confirmed its credit ratings on the following classes
of Commercial Mortgage Pass-Through Certificates, Series 2020-HR8,
issued by Morgan Stanley Capital I Trust 2020-HR8:

-- Class A-3 at AAA (sf)
-- Class A-4 at AAA (sf)
-- Class A-S at AAA (sf)
-- Class A-SB at AAA (sf)
-- Class X-A at AAA (sf)
-- Class A-3-1 at AAA (sf)
-- Class A-3-2 at AAA (sf)
-- Class A-3-X1 at AAA (sf)
-- Class A-3-X2 at AAA (sf)
-- Class A-4-1 at AAA (sf)
-- Class A-4-2 at AAA (sf)
-- Class A-4-X1 at AAA (sf)
-- Class A-4-X2 at AAA (sf)
-- Class A-S-1 at AAA (sf)
-- Class A-S-2 at AAA (sf)
-- Class A-S-X1 at AAA (sf)
-- Class A-S-X2 at AAA (sf)
-- Class B at AAA (sf)
-- Class X-B at AA (low) (sf)
-- Class X-D at AA (low) (sf)
-- Class C at A (high) (sf)
-- Class D at A (high) (sf)
-- Class E-RR at A (low) (sf)
-- Class F-RR at A (low) (sf)
-- Class G-RR at BBB (sf)
-- Class H-RR at BB (high) (sf)
-- Class J-RR at BB (sf)
-- Class K-RR at B (high) (sf)
-- Class L-RR at B (low) (sf)

All trends are Stable.

The credit rating confirmations and Stable trends reflect the
overall stable performance of the transaction since Morningstar
DBRS' last credit rating action given the relatively low
concentration of loans on the servicer's watchlist and the lack of
specially serviced loans as of the September 2024 remittance. Cash
flows have remained in line with issuance expectations as evidenced
by the pool's strong weighted-average (WA) debt service coverage
ratio (DSCR) of 2.93 times (x). As of September 2024 remittance, 42
of the original 43 loans remain in the pool, with an aggregate
principal balance of $633.5 million, representing a collateral
reduction of 8.3%. Two loans, representing 1.2% of the pool, are
fully defeased. Only two loans, representing 5.4% of the pool, are
currently being monitored on the watchlist.

The pool is relatively concentrated by loan size, as the largest 10
loans represent 59.3% of the current pool balance. Additionally,
the pool is concentrated by property type, with loans secured by
multifamily and office collateral comprising 30.6% and 28.2% of the
pool, respectively. Despite the significant office concentration,
Morningstar DBRS notes that, overall, the office loans are
generally performing in line with issuance expectations. For office
loans that Morningstar DBRS identified as exhibiting increased
credit risk since issuance, stressed loan-to-value ratios (LTVs)
and elevated probabilities of default were applied in the analysis
to reflect the elevated risk. Following these adjustments, the WA
Morningstar DBRS expected loss for office loans in the pool was
approximately 2.3x greater than the pool average. The credit rating
confirmations reflect the durability of the credit ratings despite
Morningstar DBRS' stressed analysis for these loans.

The 525 Market Street - Trust loan (Prospectus ID#5, 6.3% of the
pool) is secured by the fee, leasehold, and subleasehold interests
in a 38-story, 1.1 million-square-foot Class A office tower in San
Francisco's central business district. The whole loan of $682.0
million encompasses the $60.0 million trust loan, $410.0 million
pari passu notes, and subordinate B note debt of $212.0 million.
The controlling piece is secured in the MKT 2020-525M Mortgage
Trust transaction, which is also rated by Morningstar DBRS. To read
more on Morningstar DBRS' recent credit rating action on this
transaction, please see the press release titled "Morningstar DBRS
Takes Rating Actions on North American Single-Asset/Single-Borrower
Transactions Backed by Office Properties," published on April 15,
2024, on the Morningstar DBRS website.

As of the July 2024 rent roll, the property was 71.0% occupied with
approximately 15.0% of the net rentable area (NRA) scheduled to
rollover in the upcoming 12 months, including the second-largest
tenant. Occupancy continues to decline from 97.0% at issuance. The
largest tenants at the building include Amazon.com Services, Inc.
(39.0% of the NRA; leases expire between 2028 and 2031); Wells
Fargo Bank (13.7% of the NRA; lease expires in June 2025); and
Disney Streaming Services, LLC (3.5% of the NRA; lease expires in
July 2027). Morningstar DBRS inquired whether Wells Fargo Bank will
be renewing its lease but did not receive a response as of this
review. As per the most recently reported financials, the loan
reported a healthy DSCR of 2.73x as of YE2023, compared with the
Morningstar DBRS DSCR of 2.51x. At issuance, the loan was
shadow-rated investment grade given its strong sponsorship and
long-term credit tenancy. In its analysis, Morningstar DBRS updated
the LTV to reflect its updated value for the property as concluded
with the April 15, 2024, credit rating action, as well as a
stressed probability of default to account for the decline in
occupancy from issuance, concentrated tenant rollover risk, and
softening submarket, which reported a vacancy rate of 19.8% in Q2
2024 as per Reis. Given the aforementioned factors, Morningstar
DBRS removed the loan's previously assigned shadow rating as the
loan's characteristics are no longer consistent with the
investment-grade shadow rating determined at issuance.

The UHG Optum Health Campus (Prospectus ID#8, 4.2% of the pool) is
secured by a suburban office property in Eden Prairie, Minnesota.
Although the loan is not currently being monitored on the
servicer's watchlist, Morningstar DBRS considers the loan to be at
increased credit risk given that the property is now fully vacant
following the departure of sole tenant UnitedHealth Group upon its
lease expiration in December 2023. The re-leasing efforts will
likely be challenging given the high submarket vacancy, with Reis
Inc. reporting a Q2 2024 vacancy rate of 23.1% for office space in
the Southwest/Northeast Scott County submarket. In its analysis,
Morningstar DBRS conducted a dark value analysis based on a
stabilized NCF of $4.7 million, using an 11% capitalization rate
that incorporates a 100-basis-point stress for the fully vacant
status of the asset and soft submarket location and deducting
leasing and downtime costs of approximately $15.5 million. The
resulting dark value of $27.5 million reflects an LTV ratio of 96%.
Morningstar DBRS analyzed the loan using a stressed LTV, resulting
in an expected loss that is 2.3x greater than the pool's WA.

The Bellagio Hotel and Casino (Prospectus ID#6, 6.2% of the pool),
is shadow-rated investment grade. Morningstar DBRS confirms that
the characteristics of the loan remain consistent with an
investment-grade shadow rating, supported by above average property
quality, sponsorship strength and the strong performance of the
collateral.

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


MRCD 2019-PARK: Fitch Lowers Rating on Class D Certs to 'BB-sf'
---------------------------------------------------------------
Fitch Ratings has downgraded four classes of MRCD 2019-PARK
Mortgage Trust Commercial Mortgage Pass-Through Certificates,
Series 2019-PARK. All classes have been assigned Negative Rating
Outlooks.

   Entity/Debt        Rating            Prior
   -----------        ------            -----
MRCD 2019-PARK

   A 55348UAG3    LT AA-sf  Downgrade   AAAsf
   B 55348UAL2    LT A-sf   Downgrade   AA-sf
   C 55348UAN8    LT BBB-sf Downgrade   A-sf
   D 55348UAQ1    LT BB-sf  Downgrade   BBB-sf

KEY RATING DRIVERS

The downgrades are attributed to performance deterioration with
recent occupancy declines and stagnating cashflow impeding recovery
toward issuance levels. The Negative Outlooks reflect continued
stabilization concerns with competition from nearby San Francisco
State University (SFSU) and soft market conditions hampering
performance recovery as the loan approaches maturity in December
2024. Without positive leasing momentum and sustained progress
towards performance at issuance, further downgrades to these
classes are possible. Fitch will continue to monitor performance
trends and any indications on the borrower's ability to refinance
the loan at or prior to maturity.

Collateral occupancy has declined to 79.1% as of August 2024, down
from 82.7% in September 2023, and remains below issuance occupancy
of 94.2%. The TTM March 2024 NOI has improved 25% from YE 2022 NOI,
but remains 37% below the originator's underwritten NOI from
issuance

The updated Fitch sustainable NCF of $50.4 million, which is 13%
below Fitch's issuance NCF of $57.7 million, reflects the August
2024 rent roll with a lease-up of vacant units to market rental
rates at a stabilized occupancy of 88%.

Fitch's lease-up assumption of market rental rates is based upon
the higher rents achieved from actual recently signed leases in the
prior six months, accounting for the various unit type differences
at the property, averaging $3,382 per unit. Of note, recent leases
signed at the property over the prior six months reflect rental
rates in line with the market, with a 54% premium above current
average in-place rents across the property.

Fitch's sustainable long-term vacancy assumption of 12% reflects
the sustained leasing challenges in stabilizing the asset to reach
market levels. The subject property represents one-third of the
units within the submarket; when excluding the subject units from
the submarket inventory, this reduces the submarket vacancy to
5.8%. According to Costar and as of 3Q24, the submarket vacancy and
average asking rent were 11.0% and $2,932, respectively, compared
to 20.1% and $2,191 for the subject.

Refinance Concerns; High Leverage: The Fitch-stressed debt service
coverage ratio (DSCR) and loan-to-value (LTV) for the entire trust,
inclusive of a $653 million B note, are 0.50x and 174.3%,
respectively, while the Fitch-stressed DSCR and LTV for class D,
the lowest rated by Fitch (BBB-sf), are 1.05x and 83.6%,
respectively.

The Fitch-stressed DSCR and LTV of the whole loan, inclusive of a
C-note are 0.42x and 208.3%, respectively. The capital structure
also includes a $275.0 million mezzanine loan. The total debt Fitch
DSCR and LTV are 0.36x and 246.5%, respectively, and a total debt
of $560,821 per unit.

Based on the servicer-reported YE 2023 NCF, the debt yield at the
lowest Fitch-rated 'BBB-sf' level is 6.2%, adding refinance stress
at maturity should NCF not improve.

Rent Control and Below Market Rents: Because the buildings were
constructed before 1979, they are subject to the San Francisco Rent
Control Ordinance, limiting the ability to raise rents on occupied
units at the property. Due to rent controls, tenants are
incentivized to remain at the property, and from 2015 to 2018,
average tenant tenure at the property was 11.9 years for fair
market units. The current in-place rents are approximately 40.7%
below market.

Occupancy and in-place rental rates have been affected by softening
demand for housing caused by shifts in the San Francisco employment
sector and a disruption to the student concentration at the
property caused by the onset of the pandemic and new student
housing supply coming online, reducing the need for beds at the
subject property. At issuance, the student population accounted for
approximately 16.9% of units at the property (535 units).

With the onset of the pandemic and shift to virtual classrooms, the
student concentration at the subject fell to less than 1% of units.
The student concentration recovered to 8.6% (271 units) by
September 2023, but has since declined to 5.9% (188 units) as of
August 2024. Corporate units, which have historically commanded
premiums to rental rates due to the short-term nature of leases,
accounted for 1% of units at issuance, but have since declined to
0.2%.

RATING SENSITIVITIES

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

- Lack of performance stabilization towards issuance levels and/or
a reversal of recent positive leasing momentum, including a decline
in occupancy and/or lower rental revenues at The Parkmerced.

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

- Upgrades are considered unlikely; however, a sustained and
significant improvement in performance, including occupancy and
cash flow exceeding issuance levels at The Parkmerced, and/or a
greater certainty of the borrower's ability to refinance the loan
at or prior to maturity in December 2024.

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

MRCD 2019-PARK has an ESG Relevance Score of '4' [+] for Human
Rights, Community Relations, Access & Affordability due to
constraints on the sponsor's ability to increase tenant rents, as
the property is subject to San Francisco rent controls, which has a
positive impact on the credit profile, and is relevant to the
rating[s] 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.


NEUBERGER BERMAN 26: Fitch Assigns 'BB-sf' Rating on Cl. E-R Notes
------------------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to the
Neuberger Berman Loan Advisers CLO 26, Ltd. reset transaction.

   Entity/Debt              Rating           
   -----------              ------           
Neuberger Berman
Loan Advisers
CLO 26, LTD.

   A-R2                 LT NRsf   New Rating
   B-R2                 LT AAsf   New Rating
   C-R                  LT Asf    New Rating
   D-1R                 LT BBB-sf New Rating
   D-2R                 LT BBB-sf New Rating
   E-R                  LT BB-sf  New Rating
   Subordinated Notes   LT NRsf   New Rating

Transaction Summary

Neuberger Berman Loan Advisers CLO 26, Ltd. (the issuer) is an
arbitrage cash flow collateralized loan obligation (CLO) that will
be managed by Neuberger Berman Loan Advisers LLC. It originally
closed in November 2017 and was refinanced for the first time on
November 2021. This is the second refinancing where the existing
notes will be refinanced in whole on Oct. 18, 2024. 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 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 24.26, 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
94.02% 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 73.8%.

Portfolio Composition (Positive): The largest three industries may
comprise up to 39% of the portfolio balance in aggregate while the
top five obligors can represent up to 12.5% of the portfolio
balance in aggregate. The level of diversity resulting from the
industry, obligor and geographic concentrations is in line with
other recent CLOs.

Portfolio Management (Neutral): The transaction has a five-year
reinvestment period and reinvestment criteria similar to other
CLOs. Fitch's analysis was based on a stressed portfolio created by
adjusting 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 'BB+sf' and 'A+sf' for class B-R2, 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, 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

Variability in key model assumptions, such as increases in recovery
rates and decreases in default rates, could result in an upgrade.
Fitch evaluated the notes' sensitivity to potential changes in such
metrics; the minimum rating results under these sensitivity
scenarios are 'AAAsf' for class B-R2, 'AA+sf' for class C-R, 'A+sf'
for class D-1R, 'A-sf' 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 the data is adequately reliable.

ESG Considerations

Fitch does not provide ESG relevance scores for Neuberger Berman
Loan Advisers CLO 26, Ltd. In cases where Fitch does not provide
ESG relevance scores in connection with the credit rating of a
transaction, programme, instrument or issuer, Fitch will disclose
in the key rating drivers any ESG factor which has a significant
impact on the rating on an individual basis.


NEUBERGER BERMAN 52: Fitch Assigns 'BB-(EXP)sf' Rating on E-R Notes
-------------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
Neuberger Berman Loan Advisers NBLA CLO 52, Ltd.

   Entity/Debt          Rating           
   -----------          ------           
Neuberger Berman
Loan Advisers
NBLA CLO 52, Ltd.

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

Transaction Summary

Neuberger Berman Loan Advisers NBLA CLO 52, Ltd. (the issuer) is an
arbitrage cash flow collateralized loan obligation (CLO) that will
be managed by Neuberger Berman Loan Advisers II LLC. Net proceeds
from the issuance of the secured and subordinated notes will
provide financing on a portfolio of approximately $485 million of
primarily first lien senior secured leveraged loans.

KEY RATING DRIVERS

Asset Credit Quality (Negative): The average credit quality of the
indicative portfolio is 'B/B-', which is in line with that of
recent CLOs. The weighted average rating factor (WARF) of the
indicative portfolio is 25.23, versus a maximum covenant, in
accordance with the initial expected matrix point of 25.5. 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
94.77% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 74.26% versus a
minimum covenant, in accordance with the initial expected matrix
point of 70%.

Portfolio Composition (Positive): The largest three industries may
comprise up to 40.75% 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 '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, 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

Variability in key model assumptions, such as increases in recovery
rates and decreases in default rates, could result in an upgrade.
Fitch evaluated the notes' sensitivity to potential changes in such
metrics; the minimum rating results under these sensitivity
scenarios are 'AAAsf' for class B-R, 'AAsf' for class C-R, 'Asf'
for class D-1R, 'A-sf' 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 Neuberger Berman
Loan Advisers NBLA CLO 52, 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.


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

Cl. A, Definitive Rating Assigned Aaa (sf)

Cl. B, Definitive Rating Assigned Aa2 (sf)

Cl. C, Definitive Rating Assigned A2 (sf)

Cl. D, Definitive Rating Assigned Baa3 (sf)

Cl. E, Definitive Rating Assigned Ba3 (sf)

Cl. F, Definitive Rating Assigned B2 (sf)

Cl. HRR, Definitive Rating Assigned B3 (sf)

RATINGS RATIONALE

The certificates are collateralized by a single loan backed by a
first lien commercial mortgage related to a portfolio of 61
self-storage properties located across 21 states. Moody's ratings
are based on the credit quality of the loan and the strength of the
securitization structure.

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

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

With respect to loan level diversity, the portfolio's property
level Herfindahl score is 50.9. The ten largest properties
represent 29.5% of the portfolio balance.

The Moody's first mortgage actual DSCR is 1.15x and Moody's first
mortgage actual stressed DSCR is 0.70x. Moody's DSCR is based on
Moody's stabilized net cash flow.

The loan first mortgage balance of $750,000,000 represents a
Moody's LTV ratio of 130.4%. Moody's LTV ratio is based on Moody's
Value. The Moody's adjusted LTV is 119.3%,  compared with 119.0% in
place at Moody's provisional ratings, based on Moody's adjusted
Moody's Value taking in to account the current interest rate
environment.

Moody's also grade properties on a scale of 0 to 5 (best to worst)
and consider those grades when assessing the likelihood of debt
payment. The factors considered include property age, quality of
construction, location, market, and tenancy. The portfolio's
weighted average property quality grade is 1.5.

Notable strengths of the transaction include: (i) Recently built,
(ii) Strong operating performance, (iii) Strong area demographics,
(iv) Portfolio diversity

Notable concerns of the transaction include: (i) High Moodys LTV,
(ii) Interest only loan profile, (iii), Release provisions.

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

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

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


NYMT LOAN 2024-INV1: S&P Assigns B (sf) Rating on Class B-2 Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its ratings to NYMT Loan Trust
2024-INV1's mortgage-backed notes.

The note issuance is an RMBS securitization backed by first-lien,
fixed- and adjustable-rate, fully amortizing residential mortgage
loans to both prime and nonprime borrowers (some with interest-only
periods). The loans are secured by single-family residential
properties, planned-unit developments, condominiums, and two- to
four-family residential properties, townhomes, and five- to 10-unit
multifamily properties. The pool consists of 1,503 business-purpose
investment property loans (including 106 cross-collateralized loans
backed by 420 properties) which are all business-purpose investment
property ATR-exempt loans.

The ratings reflect S&P's view of:

-- The pool's collateral composition;

-- The transaction's credit enhancement, associated structural
mechanics, representation and warranty (R&W) framework, and
geographic concentration;

-- The mortgage aggregator and reviewed originators; and

-- One key change in our baseline forecast since June is an
acceleration in the pace of monetary policy easing. S&P said, "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."

  Ratings Assigned

  NYMT Loan Trust 2024-INV1

  Class A-1A, $156,123,000: AAA (sf)
  Class A-1B, $31,038,000: AAA (sf)
  Class A-1, $187,161,000: AAA (sf)
  Class A-2, $25,141,000: AA- (sf)
  Class A-3, $39,885,000: A- (sf)
  Class M-1, $22,347,000: BBB- (sf)
  Class B-1, $16,761,000: BB- (sf)
  Class B-2, $8,846,000: B (sf)
  Class B-3, $10,243,222: NR
  Class A-IO-S, Notional(i): NR
  Class XS, Notional(i): NR
  Class R, N/A: NR

(i) The notional amount will equal the aggregate state principle
balance of the mortgage loans as of the first day of the related
due period, which will be initially $310,384,222.
NR--Not rated.
N/A--Not applicable.



OAKTREE CLO 2022-2: S&P Assigns Prelim 'BB' Rating on E-R2 Notes
----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the class
A-1-R2, A-2-R2, B-R2, C-R2, D-1-R2, D-2-R2, and E-R2 replacement
debt from Oaktree CLO 2022-2 Ltd./Oaktree CLO 2022-2 LLC, a CLO
managed by Oaktree Capital Management L.P. that was originally
issued in June 2022 and subsequently refinanced in January 2024.

The preliminary ratings are based on information as of Oct. 22,
2024. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the Oct. 30, 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 debt is expected to be issued at a lower
weighted average cost of debt than the previous debt.

-- The replacement class D-R debt will be split into the class
D-1-R2 and D-2-R2 debt, which will be sequential in payment.

-- The non-call period will be extended to Oct. 30, 2026.

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

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

-- The target initial par amount will remain at $500.00 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 and interest
coverage 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

  Oaktree CLO 2022-2 Ltd./Oaktree CLO 2022-2 LLC

  Class A-1-R2, $320.00 million: AAA (sf)
  Class A-2-R2, $10.00 million: AAA (sf)
  Class B-R2, $50.00 million: AA (sf)
  Class C-R2 (deferrable), $30.00 million: A (sf)
  Class D-1-R2 (deferrable), $30.00 million: BBB (sf)
  Class D-2-R2 (deferrable), $5.00 million: BBB- (sf)
  Class E-R2 (deferrable), $15.00 million: BB (sf)

  Other Debt

  Oaktree CLO 2022-2 Ltd./Oaktree CLO 2022-2 LLC

  Subordinated notes, $41.80 million: Not rated



OCP CLO 2016-12: S&P Assigns B+ (sf) Rating on Cl. E-2R3 Notes
--------------------------------------------------------------
S&P Global Ratings assigned its ratings to OCP CLO 2016-12 Ltd./OCP
CLO 2016-12 LLC's fixed and floating-rate debt a CLO managed by
Onex Credit Partners LLC that was originally issued in 2016 and
underwent a second refinancing in 2022. The 2022 transaction was
not rated by S&P Global Ratings.

The debt issuance is a CLO securitization governed by investment
criteria and backed primarily by broadly syndicated
speculative-grade (rated 'BB+' or lower) senior secured term
loans.

The 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

  OCP CLO 2016-12 Ltd./OCP CLO 2016-12 LLC

  Class X-R3, $3.80 million: AAA (sf)
  Class A-1R3, $352.00 million: AAA (sf)
  Class A-2R3, $8.25 million: AAA (sf)
  Class B-1AR3, $27.00 million: AA+ (sf)
  Class B-1BR3, $16.75 million: AA (sf)
  Class B-2R3, $14.00 million: AA (sf)
  Class C-R3 (deferrable), $33.00 million: A (sf)
  Class D-1R3 (deferrable), $33.00 million: BBB- (sf)
  Class D-2R3 (deferrable), $4.00 million: BBB- (sf)
  Class E-1R3 (deferrable), $18.00 million: BB- (sf)
  Class E-2R3 (deferrable), $2.50 million: B+ (sf)
  Subordinated notes, $61.70 million: Not rated



OCP CLO 2024-36: S&P Assigns Prelim BB- (sf) Rating on E Notes
--------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to OCP CLO
2024-36 Ltd./OCP CLO 2024-36 LLC's floating- and fixed-rate debt.

The debt issuance is a CLO securitization governed by investment
criteria and backed primarily by broadly syndicated
speculative-grade (rated 'BB+' or lower) senior secured term loans.
The transaction is managed by Onex Credit Partners LLC, a
subsidiary of Onex Corp.

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

The preliminary ratings reflect:

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

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

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

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

  Preliminary Ratings Assigned

  OCP CLO 2024-36 Ltd./OCP CLO 2024-36 LLC

  Class A-1, $155.5 million: AAA (sf)
  Class A-1L loans(i), $164.5 million: AAA (sf)
  Class A-1L(i), $0.0 million: AAA (sf)
  Class A-2, $7.5 million: AAA (sf)
  Class B-1, $50.0 million: AA (sf)
  Class B-2, $2.5 million: AA (sf)
  Class C (deferrable), $30.0 million: A (sf)
  Class D-1 (deferrable), $30.0 million: BBB (sf)
  Class D-2 (deferrable), $5.0 million: BBB- (sf)
  Class E (deferrable), $15.0 million: BB- (sf)
  Subordinated notes, $48.7 million: Not rated

(i)All or a portion of the class A-1L loans may be converted into
class A-1L notes. No portion of the class A-1L notes may be
converted into class A-1L loans.



OCTAGON 60: Fitch Assigns 'BB-sf' Rating on Class E-R Notes
-----------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to Octagon
60, Ltd. reset transaction.

   Entity/Debt         Rating               Prior
   -----------         ------               -----
Octagon 60, Ltd.

   A-1 675935AA8   LT   PIFsf   Paid In Full   AAAsf
   A-1-R           LT   AAAsf   New Rating     AAA(EXP)sf
   A-2 675935AC4   LT   PIFsf   Paid In Full   AAAsf
   A-2-R           LT   AAAsf   New Rating     AAA(EXP)sf
   B 675935AE0     LT   PIFsf   Paid In Full   AAsf
   B-R             LT   AAsf    New Rating     AA(EXP)sf
   C 675935AG5     LT   PIFsf   Paid In Full   Asf
   C-R             LT   Asf     New Rating     A(EXP)sf
   D-1 675935AJ9   LT   PIFsf   Paid In Full   BBB-sf
   D-1-R           LT   BBB-sf  New Rating     BBB-(EXP)sf
   D-2 675935AL4   LT   PIFsf   Paid In Full   BBB-sf
   D-2-R           LT   BBB-sf  New Rating     BBB-(EXP)sf
   E 675936AA6     LT   PIFsf   Paid In Full   BB-sf
   E-R             LT   BB-sf   New Rating     BB-(EXP)sf
   X               LT   NRsf    New Rating     NR(EXP)sf

Transaction Summary

Octagon 60, Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that will be managed by
Octagon Credit Investors, LLC. It originally closed in October
2022. This is the first refinancing where the existing notes will
be refinanced in whole on Oct. 21, 2024. 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 $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', which is in line with that of recent
CLOs. The weighted-average rating factor of the indicative
portfolio is 24.03, versus a maximum covenant, in accordance with
the initial expected matrix point of 27. Issuers rated in the 'B'
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
97.15% first-lien senior secured loans. The weighted-average
recovery rate of the indicative portfolio is 74.80%, versus a
minimum covenant, in accordance with the initial expected matrix
point of 69.4%.

Portfolio Composition (Positive): The largest three industries may
comprise up to 36% of the portfolio balance in aggregate, while the
top-five obligors can represent up to 12.5% of the portfolio
balance in aggregate. The level of diversity resulting from the
industry, obligor and geographic concentrations is in line with
other recent CLOs.

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

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

The weighted average life (WAL) used for the transaction stress
portfolio and matrices analysis is 12 months less than the WAL
covenant to account for structural and reinvestment conditions
after the reinvestment period. Fitch believes 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-R, between
'BBBsf' and 'AA+sf' for class A-2-R, 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-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 A-1-R and A-2-R
notes as these notes are in the highest rating category.

Variability in key model assumptions, such as increases in recovery
rates and decreases in default rates, could result in an upgrade.
Fitch evaluated the notes' sensitivity to potential changes in such
metrics; the minimum rating results under these sensitivity
scenarios are 'AAAsf' for class B-R, 'AAsf' for class C-R, 'A+sf'
for class D-1-R, 'A+sf' for class D-2-R, and 'BBB+sf' for class
E-R.

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

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

DATA ADEQUACY

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

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

ESG Considerations

Fitch does not provide ESG relevance scores for Octagon 60, 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.


OHA CREDIT 5: S&P Assigns BB- (sf) Rating on Class E-R Notes
------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-L loans, A-L
notes, and A-R, B-1-R, B-2-R, C-R, D-1-R, D-2-R, and E-R
replacement debt from OHA Credit Funding 5 Ltd./OHA Credit Funding
5 LLC, a CLO originally issued in March 2020 that is managed by Oak
Hill Advisors L.P. At the same time, S&P withdrew its ratings on
the original class X, A-1, B, C, D, and E debt following payment in
full.

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 Oct. 18, 2026.

-- The reinvestment period was extended to Oct. 18, 2029.

-- The legal final maturity dates (for the replacement debt and
the existing subordinated notes) was extended to Oct. 18, 2037.

-- The target initial par amount remain unchanged at $600.0
million. There was no additional effective date or ramp-up period,
and the first payment date following the refinancing is Jan. 18,
2025.

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

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

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

  Ratings Assigned

  OHA Credit Funding 5 Ltd./OHA Credit Funding 5 LLC

  Class A-R, $248.00 million: AAA (sf)
  Class A-L loans, $124.00 million: AAA (sf)
  Class A-L notes, $0.00 million: AAA (sf)
  Class B-1-R, $69.00 million: AA (sf)
  Class B-2-R, $15.00 million: AA (sf)
  Class C-R (deferrable), $36.00 million: A (sf)
  Class D-1-R (deferrable), $36.00 million: BBB- (sf)
  Class D-2-R (deferrable), $6.00 million: BBB- (sf)
  Class E-R (deferrable), $18.00 million: BB- (sf)

  Ratings Withdrawn

  OHA Credit Funding 5 Ltd./OHA Credit Funding 5 LLC

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

  Other Debt

  OHA Credit Funding 5 Ltd./OHA Credit Funding 5 LLC

  Subordinated notes, $46.30 million: NR

  NR--Not rated.



OZLM LTD XI: Moody's Affirms B1 Rating on $26.2MM Class D-R Notes
-----------------------------------------------------------------
Moody's Ratings has upgraded the rating on the following notes
issued by OZLM XI, Ltd.:

US$33M Class C-R Senior Secured Deferrable Floating Rate Notes,
Upgraded to A1 (sf); previously on Jun 20, 2024 Upgraded to A3
(sf)

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

US$332.3M (Current outstanding amount US$ 17,261,922) Class A-1-R
Senior Secured Floating Rate Notes, Affirmed Aaa (sf); previously
on Jun 20, 2024 Affirmed Aaa (sf)

US$66M Class A-2-R Senior Secured Floating Rate Notes, Affirmed
Aaa (sf); previously on Jun 20, 2024 Affirmed Aaa (sf)

US$24.6M Class B-R Senior Secured Deferrable Floating Rate Notes,
Affirmed Aaa (sf); previously on Jun 20, 2024 Upgraded to Aaa (sf)

US$26.2M Class D-R Secured Deferrable Floating Rate Notes,
Affirmed B1 (sf); previously on Jun 20, 2024 Affirmed B1 (sf)

US$10.5M Class E-R Secured Deferrable Floating Rate Notes,
Affirmed Caa3 (sf); previously on Jun 20, 2024 Affirmed Caa3 (sf)

OZLM XI, Ltd., issued in March 2015 and refinanced in August 2017,
is a managed cashflow CLO. The notes are collateralized primarily
by a portfolio of broadly syndicated senior secured corporate
loans. The portfolio is managed by Sculptor CLO Management LLC. The
transaction's reinvestment period ended in October 2022.

RATINGS RATIONALE

The rating upgrade on the Class C-R notes is primarily a result of
the deleveraging of the Class A-1-R notes following amortisation of
the underlying portfolio since the last rating action in June
2024.

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

The Class A-1-R notes have paid down by approximately USD68.6
million (20.6%) since the last rating action in June 2024 and
USD315.0 million (94.8%) since closing. 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 215.5%, 166.4%, 127.4% and 107.4% compared to May 2024
[2] levels of 165.2%, 142.2%, 119.8% and 106.5%, respectively.

The deleveraging and OC improvements primarily resulted from high
prepayment rates of leveraged loans in the underlying portfolio.
Most of the prepaid proceeds have been applied to amortise the
liabilities. All else held equal, such deleveraging is generally a
positive credit driver for the CLO's rated liabilities.

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: USD185.13m

Defaulted Securities: USD1.28m

Diversity Score: 52

Weighted Average Rating Factor (WARF): 3041

Weighted Average Life (WAL): 3.33 years

Weighted Average Spread (WAS): 3.29%

Weighted Average Coupon (WAC): 2.00%

Weighted Average Recovery Rate (WARR): 46.00%

Par haircut in OC tests and interest diversion test: 3.52%

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" published in
October 2024. Moody's concluded the ratings of the notes are not
constrained by these risks.

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

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

Additional uncertainty about performance is due to the following:

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

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

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


PALMER SQUARE 2021-2: Moody's Ups Rating on $7MM Cl. E Notes to Ba1
-------------------------------------------------------------------
Moody's Ratings has upgraded the ratings on the following notes
issued by Palmer Square Loan Funding 2021-2, Ltd.:

US$24.5M Class C Senior Secured Deferrable Floating Rate Notes,
Upgraded to Aa1 (sf); previously on Jun 19, 2024 Upgraded to A2
(sf)

US$24.5M Class D Senior Secured Deferrable Floating Rate Notes,
Upgraded to Baa2 (sf); previously on Jun 19, 2024 Affirmed Ba1
(sf)

US$7M Class E Senior Secured Deferrable Floating Rate Notes,
Upgraded to Ba1 (sf); previously on Jun 19, 2024 Affirmed Ba3 (sf)

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

US$476M (Current outstanding amount US$31,959,348) Class A-1
Senior Secured Floating Rate Notes, Affirmed Aaa (sf); previously
on Jun 19, 2024 Affirmed Aaa (sf)

US$84M Class A-2 Senior Secured Floating Rate Notes, Affirmed Aaa
(sf); previously on Jun 19, 2024 Affirmed Aaa (sf)

US$42M Class B Senior Secured Deferrable Floating Rate Notes,
Affirmed Aaa (sf); previously on Jun 19, 2024 Upgraded to Aaa (sf)

Palmer Square Loan Funding 2021-2, Ltd., issued in April 2021, is a
static collateralised loan obligation (CLO) backed by a portfolio
of mostly high-yield senior secured US loans. The portfolio is
serviced by Palmer Square Capital Management LLC. The servicer may
sell assets on behalf of the Issuer during the life of the
transaction. Reinvestment is not permitted and all sales and
unscheduled principal proceeds received will be used to amortize
the notes in sequential order.

RATINGS RATIONALE

The rating upgrades on the Class C, D and E notes are primarily a
result of the significant deleveraging of the senior notes
following amortisation of the underlying portfolio since the last
rating action in June 2024.

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

The Class A-1 notes have paid down by approximately USD72.2 million
(15.2%) since the last rating action in June 2024 and USD444.0
million (93.3%) since closing. 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
213.08%, 156.42%, 135.42% and 119.39% compared to May 2024[2]
levels of 155.44%, 132.22%, 121.62% and 112.60%, 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: USD248.7m

Defaulted Securities: none

Diversity Score: 47

Weighted Average Rating Factor (WARF): 2958

Weighted Average Life (WAL): 3.15 years

Weighted Average Spread (WAS) (before accounting for reference rate
floors): 3.17%

Weighted Average Recovery Rate (WARR): 47.26%

Par haircut in OC tests and interest diversion test:  0.68%

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 Moody's are 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" published in
October 2024. Moody's concluded the ratings of the notes are not
constrained by these risks.

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

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

Additional uncertainty about performance is due to the following:

-- Portfolio amortisation: The main source of uncertainty in this
transaction is the pace of amortisation of the underlying
portfolio, which can vary significantly depending on market
conditions and have a significant impact on the notes' ratings.
Amortisation could accelerate as a consequence of high loan
prepayment levels or collateral sales by the servicer 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.

-- 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.


PALMER SQUARE 2023-4: S&P Assigns BB- (sf) Rating on E-R Notes
--------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-1-L, A-1-R,
A-2-R, B-R, C-R, D-1-R, D-2-R, and E-R replacement debt from Palmer
Square CLO 2023-4 Ltd./Palmer Square CLO 2023-4 LLC, a CLO
originally issued in 2023 that is managed by Palmer Square Capital
Management LLC. At the same time, S&P withdrew its ratings on the
original class A, B, C, D, and E debt following payment in full on
the Oct. 21, 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 Oct. 20, 2026.

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

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

-- The target initial par amount remains at $500 million. There is
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 were amended.

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

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

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

  Ratings Assigned

  Palmer Square CLO 2023-4 Ltd./Palmer Square CLO 2023-4 LLC

  Class A-1-L loans, $172.0 million: AAA (sf)
  Class A-1-R, $148.0 million: AAA (sf)
  Class A-2-R, $7.5 million: AAA (sf)
  Class B-R, $52.5 million: AA (sf)
  Class C-R (deferrable), $30.0 million: A (sf)
  Class D-1-R (deferrable), $30.0 million: BBB- (sf)
  Class D-2-R (deferrable), $5.0 million: BBB- (sf)
  Class E-R (deferrable), $15.0 million: BB- (sf)

  Ratings Withdrawn

  Palmer Square CLO 2023-4 Ltd./Palmer Square CLO 2023-4 LLC

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

  Other Debt

  Palmer Square CLO 2023-4 Ltd./Palmer Square CLO 2023-4 LLC

  Subordinated notes, $42.5 million: NR

  NR--Not rated.



PARK BLUE 2022-I: Moody's Assigns Ba3 Rating to $11MM Cl. E-R Notes
-------------------------------------------------------------------
Moody's Ratings has assigned ratings to two classes of CLO
refinancing notes (the Refinancing Notes) issued by Park Blue CLO
2022-I, Ltd. (the Issuer):  

US$240,000,000 Class A-1R Senior Secured Floating Rate Notes due
2037, Assigned Aaa (sf)

US$11,000,000 Class E-R Deferrable Mezzanine Floating Rate Notes
due 2037, Assigned Ba3 (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
92.5% of the portfolio must consist of first lien senior secured
loans, cash, and eligible investments and up to 7.5% of the
portfolio may consist of first lien last out loans, second lien
loans, unsecured loans and bonds.

Centerbridge Credit Funding Advisors, 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 five 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 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: $400,000,000

Diversity Score: 70

Weighted Average Rating Factor (WARF): 2937

Weighted Average Spread (WAS): 3.55%

Weighted Average Coupon (WAC): 6.00%

Weighted Average Recovery Rate (WARR): 45.00%

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 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.


PROGRESS RESIDENTIAL 2021-SFR1: DBRS Confirms B(low) on G Certs
---------------------------------------------------------------
DBRS, Inc. reviewed its credit ratings on 47 classes from six U.S.
single-family rental transactions. Of the 47 classes reviewed,
Morningstar DBRS confirmed its credit ratings on 38 classes and
upgraded its credit ratings on nine.

Progress Residential 2021-SFR1 Trust

-- Single-Family Rental Pass-Through Certificate, Class A
confirmed at AAA (sf)

-- Single-Family Rental Pass-Through Certificate, Class B upgraded
to AAA (sf)

-- Single-Family Rental Pass-Through Certificate, Class C upgraded
to AA (sf)

-- Single-Family Rental Pass-Through Certificate, Class D upgraded
to A (sf)

-- Single-Family Rental Pass-Through Certificate, Class E
confirmed at BBB (low) (sf)

-- Single-Family Rental Pass-Through Certificate, Class F
confirmed at BB (low) (sf)

-- Single-Family Rental Pass-Through Certificate, Class G
confirmed at B (low) (sf)

Progress Residential 2021-SFR2 Trust

-- Single-Family Rental Pass-Through Certificate, Class A
confirmed at AAA (sf)

-- Single-Family Rental Pass-Through Certificate, Class B
confirmed at AAA (sf)

-- Single-Family Rental Pass-Through Certificate, Class C upgraded
to AAA (sf)

-- Single-Family Rental Pass-Through Certificate, Class D upgraded
to AA (high) (sf)

-- Single-Family Rental Pass-Through Certificate, Class E-1
upgraded to A (high) (sf)

-- Single-Family Rental Pass-Through Certificate, Class E-2
confirmed at BBB (low) (sf)

-- Single-Family Rental Pass-Through Certificate, Class F
confirmed at BB (low) (sf)

-- Single-Family Rental Pass-Through Certificate, Class G
confirmed at B (low) (sf)

Progress Residential 2021-SFR4 Trust

-- Single-Family Rental Pass-Through Certificate, Class A
confirmed at AAA (sf)

-- Single-Family Rental Pass-Through Certificate, Class B upgraded
to AA (high) (sf)

-- Single-Family Rental Pass-Through Certificate, Class C upgraded
to A (high) (sf)

-- Single-Family Rental Pass-Through Certificate, Class D upgraded
to A (low) (sf)

-- Single-Family Rental Pass-Through Certificate, Class E-1
confirmed at BBB (sf)

-- Single-Family Rental Pass-Through Certificate, Class E-2
confirmed at BBB (low) (sf)

-- Single-Family Rental Pass-Through Certificate, Class F
confirmed at BB (low) (sf)

-- Single-Family Rental Pass-Through Certificate, Class G
confirmed at B (low) (sf)

Progress Residential 2021-SFR7 Trust

-- Single-Family Rental Pass-Through Certificates, Class A
confirmed at AAA (sf)

-- Single-Family Rental Pass-Through Certificates, Class B
confirmed at AA (high) (sf)

-- Single-Family Rental Pass-Through Certificates, Class C
confirmed at A (high) (sf)

-- Single-Family Rental Pass-Through Certificates, Class D
confirmed at A (low) (sf)

-- Single-Family Rental Pass-Through Certificates, Class E-1
confirmed at BBB (sf)

-- Single-Family Rental Pass-Through Certificates, Class E-2
confirmed at BBB (low) (sf)

-- Single-Family Rental Pass-Through Certificates, Class F
confirmed at BB (low) (sf)

-- Single-Family Rental Pass-Through Certificates, Class G
confirmed at B (sf)

Progress Residential 2021-SFR9 Trust

-- Single-Family Rental Pass-Through Certificate, Class A
confirmed at AAA (sf)

-- Single-Family Rental Pass-Through Certificate, Class B
confirmed at AA (high) (sf)

-- Single-Family Rental Pass-Through Certificate, Class C
confirmed at A (high) (sf)

-- Single-Family Rental Pass-Through Certificate, Class D
confirmed at A (low) (sf)

-- Single-Family Rental Pass-Through Certificate, Class E-1
confirmed at BBB (sf)

-- Single-Family Rental Pass-Through Certificate, Class E-2
confirmed at BBB (low) (sf)

-- Single-Family Rental Pass-Through Certificate, Class F
confirmed at BB (sf)

-- Single-Family Rental Pass-Through Certificate, Class G
confirmed at B (low) (sf)

PATH 2023-1 Trust

-- Single-Family Rental Pass-Through Certificate, Class A
confirmed at AAA (sf)

-- Single-Family Rental Pass-Through Certificate, Class B
confirmed at AA (high) (sf)

-- Single-Family Rental Pass-Through Certificate, Class C
confirmed at A (high) (sf)

-- Single-Family Rental Pass-Through Certificate, Class D
confirmed at A (low) (sf)

-- Single-Family Rental Pass-Through Certificate, Class E-1
confirmed at BBB (high) (sf)

-- Single-Family Rental Pass-Through Certificate, Class E-2
confirmed at BBB (low) (sf)

-- Single-Family Rental Pass-Through Certificate, Class F
confirmed at BB (sf)

-- Single-Family Rental Pass-Through Certificate, Class G
confirmed at B (sf)

The credit rating confirmations reflect asset performance and
credit-support levels that are consistent with the current credit
ratings.

Morningstar DBRS' credit rating actions are based on the following
analytical considerations:

-- Key performance measures as reflected in month-over-month
changes in vacancy and delinquency, quarterly analysis of the
actual expenses, credit enhancement increases since deal inception,
and bond paydown factors.


PRPM LLC 2024-RCF6: DBRS Gives Prov. BB Rating on Class M2 Notes
----------------------------------------------------------------
DBRS, Inc. assigned the following provisional credit ratings to the
Mortgage-Backed Notes, Series 2024-RCF6 (the Notes) to be issued by
PRPM 2024-RCF6, LLC (PRPM 2024-RCF6 or the Trust):

-- $92.7 million Class A-1 at (P) AAA (sf)
-- $7.9 million Class A-2 at (P) AA (sf)
-- $8.0 million Class A-3 at (P) A (sf)
-- $8.8 million Class M-1 at (P) BBB (sf)
-- $8.7 million Class M-2 at (P) BB (sf)

The (P) AAA (sf) credit rating on the Class A-1 Notes reflects
38.55% of credit enhancement provided by the subordinated notes.
The (P) AA (sf), (P) A (high) (sf), (P) BBB (high) (sf), and (P) BB
(low) (sf) credit ratings reflect 33.30%, 28.00%, 22.15%, and
16.40% of credit enhancement, respectively.

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

The Trust is a securitization of a portfolio of newly originated
and seasoned, performing and reperforming, first-lien residential
mortgages, to be funded by the issuance of mortgage-backed notes
(the Notes). The Notes are backed by 675 loans with a total
principal balance of $150,885,691 as of the Cut-Off Date (August
31, 2024).

Morningstar DBRS calculated the portfolio to be approximately 103
months seasoned on average, though the age of the loans is quite
dispersed, ranging from two months to 385 months. Approximately
43.2% of the loans had origination guideline or document
deficiencies, which prevented these loans from being sold to Fannie
Mae, Freddie Mac, or another purchaser, and the loans were
subsequently put back to the sellers. In its analysis, Morningstar
DBRS assessed such defects and applied certain penalties,
consequently increasing expected losses on the mortgage pool.

No originator accounted for more than 15% of loans in the pool.

In the portfolio, 44.7% of the loans are modified. The
modifications happened more than two years ago for 72.7% of the
modified loans. Within the portfolio, 165 mortgages have
non-interest-bearing deferred amounts, equating to 5.2% of the
total unpaid principal balance (UPB). Unless specified otherwise,
all statistics on the mortgage loans in this report are based on
the current UPB, including the applicable non-interest-bearing
deferred amounts.

Based on Issuer-provided information, certain loans in the pool
(44.9%) are not subject to or exempt from the Consumer Financial
Protection Bureau's (CFPB) Ability-to-Repay (ATR)/Qualified
Mortgage (QM) rules because of seasoning or because they are
business-purpose loans. The loans subject to the ATR rules are
designated as QM Safe Harbor (46.9%), QM Rebuttable Presumption
(7.3%), and Non-Qualified Mortgage (Non-QM; 0.9%) by UPB.

BMCF-EG II, LLC (the Sponsor) acquired the mortgage loans prior to
the up-coming Closing Date and, through a wholly owned subsidiary,
PRP Depositor 2024-RCF6, LLC (the Depositor), will contribute the
loans to the Trust. As the Sponsor, BMCF-EG II, LLC or one of its
majority-owned affiliates will acquire and retain a portion of the
Class B Notes and the membership certificate representing the
initial overcollateralization amount to satisfy the credit risk
retention requirements.

PRPM 2024-RCF6 is the eighth scratch and dent rated securitization
for the Issuer. The Sponsor has securitized many rated and unrated
transactions under the PRPM shelf, most of which have been
seasoned, reperforming, and nonperforming securitizations.

SN Servicing Corporation (SNSC; 99.5%) and Fay Servicing, LLC (Fay
Servicing; 0.5%) will act as the Servicers of the mortgage loans.

The Servicers will not advance any delinquent principal and
interest (P&I) on the mortgages; however, the Servicers are
obligated to make advances in respect of prior liens, insurance,
real estate taxes, and assessments as well as reasonable costs and
expenses incurred in the course of servicing and disposing of
properties.

The Issuer has the option to redeem the Notes in full at a price
equal to the sum of (1) the remaining aggregate Note Amount; (2)
any accrued and unpaid interest due on the Notes through the
redemption date (including any Cap Carryover); and (3) any fees and
expenses of the transaction parties, including any unreimbursed
servicing advances (Redemption Price). Such Optional Redemption may
be exercised on or after the payment date in October 2026.

Additionally, a failure to pay the Notes in full by the Payment
Date in October 2029 will trigger a mandatory auction of the
underlying certificates on the November 2029 payment date by the
Asset Manager or an agent appointed by the Asset Manager. If the
auction fails to elicit sufficient proceeds to make-whole the
Notes, another auction will follow every four months for the first
year and subsequently auctions will be carried out every six
months. If the Asset Manager fails to conduct the auction, the
holder of more than 50% of the Class M-2 Notes will have the right
to appoint an auction agent to conduct the auction.

The transaction employs a sequential-pay cash flow structure with a
bullet feature to Class A-2 and more subordinate notes on the
Expected Redemption Date (Payment Date in October 2028) or the
occurrence of a Credit Event. Interest and principal collections
are first used to pay interest and any Cap Carryover amount to the
Notes sequentially and then to pay Class A-1 until its balance is
reduced to zero, which may provide for timely payment of interest
on certain rated Notes. Class A-2 and below are not entitled to any
payments of principal until the Expected Redemption Date or upon
the occurrence of a Credit Event, except for remaining available
funds representing net sale proceeds of the mortgage loans. Prior
to the Expected Redemption Date or a Credit Event, any available
funds remaining after Class A-1 is paid in full will be deposited
into a Redemption Account. Beginning on the Payment Date in October
2028, the Class A-1 and the other offered Notes will be entitled to
its initial Note Rate plus the step-up note rate of 1.00% per
annum. If the Issuer does not redeem the rated Notes in full by the
payment date in January 2031, or an Event of Default occurs and is
continuing, a Credit Event will have occurred. Upon the occurrence
of a Credit Event, accrued interest on Class A-2 and the other
offered Notes will be paid as principal to Class A-1 or the
succeeding senior Notes until it has been paid in full. The
redirected amounts will accrue on the balances of the respective
Notes and will later be paid as principal payments.

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


RAD CLO 6: Fitch Assigns 'BB-sf' Rating on Class E-R Notes
----------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to Rad CLO
6, Ltd. reset transaction.

   Entity/Debt         Rating               Prior
   -----------         ------               -----
Rad CLO 6, Ltd.

   A-1 48661NAA6   LT PIFsf  Paid In Full   AAAsf
   A-1R            LT NRsf   New Rating
   A-2R            LT AAAsf  New Rating
   B-R             LT AAsf   New Rating
   C-R             LT Asf    New Rating
   D-1R            LT BBBsf  New Rating
   D-2R            LT BBB-sf New Rating
   E-R             LT BB-sf  New Rating
   X-R             LT NRsf   New Rating

Transaction Summary

Rad CLO 6, Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that will be managed by
Irradiant Partners, LP. Which originally closed in December 2019
and was rated by Fitch. On Oct. 21, 2024 the secured notes will be
refinanced in whole. Net proceeds from the refinancing of the
secured and 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'/'B-', which is in line with that of
recent CLOs. The weighted average rating factor (WARF) of the
indicative portfolio is 24.7, versus a maximum covenant, in
accordance with the initial expected matrix point of 26. Issuers
rated in the 'B' rating category denote a highly speculative credit
quality; however, the notes benefit from appropriate credit
enhancement and standard U.S. CLO structural features.

Asset Security (Positive): The indicative portfolio consists of
97.75% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 75.28% versus a
minimum covenant, in accordance with the initial expected matrix
point of 69.7%.

Portfolio Composition (Positive): The largest three industries may
comprise up to 39% of the portfolio balance in aggregate while the
top five obligors can represent up to 12.5% of the portfolio
balance in aggregate. The level of diversity resulting from the
industry, obligor and geographic concentrations is in line with
other recent CLOs.

Portfolio Management (Neutral): The transaction has a five-year
reinvestment period and reinvestment criteria similar to other
CLOs. Fitch's analysis was based on a stressed portfolio created by
adjusting 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-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, 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, 'AAsf' 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 Rad CLO 6, Ltd. In
cases where Fitch does not provide ESG relevance scores in
connection with the credit rating of a transaction, programme,
instrument or issuer, Fitch will disclose in the key rating drivers
any ESG factor which has a significant impact on the rating on an
individual basis.


RADIAN MORTGAGE 2024-J2: DBRS Gives (P) B(low) Rating on B5 Certs
-----------------------------------------------------------------
DBRS, Inc. assigned the following provisional credit ratings on the
Mortgage Pass-Through Certificates, Series 2024-J2 (the
Certificates) to be issued by the Radian Mortgage Capital Trust
2024-J2 (RMCT 2024-J2):

-- $387.2 million Class A-1 at (P) AAA (sf)
-- $387.2 million Class A-1-X at (P) AAA (sf)
-- $387.2 million Class A-2 at (P) AAA (sf)
-- $359.7 million Class A-3 at (P) AAA (sf)
-- $359.7 million Class A-3-X at (P) AAA (sf)
-- $359.7 million Class A-4 at (P) AAA (sf)
-- $179.8 million Class A-5 at (P) AAA (sf)
-- $179.8 million Class A-5-X at (P) AAA (sf)
-- $179.8 million Class A-6 at (P) AAA (sf)
-- $215.9 million Class A-7 at (P) AAA (sf)
-- $215.9 million Class A-7-X at (P) AAA (sf)
-- $215.9 million Class A-8 at (P) AAA (sf)
-- $36.0 million Class A-9 at (P) AAA (sf)
-- $36.0 million Class A-9-X at (P) AAA (sf)
-- $36.0 million Class A-10 at (P) AAA (sf)
-- $89.9 million Class A-11 at (P) AAA (sf)
-- $89.9 million Class A-11-X at (P) AAA (sf)
-- $89.9 million Class A-12 at (P) AAA (sf)
-- $53.9 million Class A-13 at (P) AAA (sf)
-- $53.9 million Class A-13-X at (P) AAA (sf)
-- $53.9 million Class A-14 at (P) AAA (sf)
-- $269.7 million Class A-15 at (P) AAA (sf)
-- $269.7 million Class A-15-X at (P) AAA (sf)
-- $269.7 million Class A-16 at (P) AAA (sf)
-- $179.8 million Class A-17 at (P) AAA (sf)
-- $179.8 million Class A-17-X at (P) AAA (sf)
-- $179.8 million Class A-18 at (P) AAA (sf)
-- $143.9 million Class A-19 at (P) AAA (sf)
-- $143.9 million Class A-19-X at (P) AAA (sf)
-- $143.9 million Class A-20 at (P) AAA (sf)
-- $89.9 million Class A-21 at (P) AAA (sf)
-- $89.9 million Class A-21-X at (P) AAA (sf)
-- $89.9 million Class A-22 at (P) AAA (sf)
-- $27.5 million Class A-23 at (P) AAA (sf)
-- $27.5 million Class A-23-X at (P) AAA (sf)
-- $27.5 million Class A-24 at (P) AAA (sf)
-- $387.2 million Class A-X at (P) AAA (sf)
-- $21.2 million Class B-1 at (P) AA (low) (sf)
-- $21.2 million Class B-1-A at (P) AA (low) (sf)
-- $21.2 million Class B-1-X at (P) AA (low) (sf)
-- $5.9 million Class B-2 at (P) A (low) (sf)
-- $5.9 million Class B-2-A at (P) A (low) (sf)
-- $5.9 million Class B-2-X at (P) A (low) (sf)
-- $4.4 million Class B-3 at (P) BBB (low) (sf)
-- $4.4 million Class B-3-A at (P) BBB (low) (sf)
-- $4.4 million Class B-3-X at (P) BBB (low) (sf)
-- $1.9 million Class B-4 at (P) BB (low) (sf)
-- $1.1 million Class B-5 at (P) B (low) (sf)
-- $31.5 million Class B at (P) BBB (low) (sf)
-- $31.5 million Class B-X at (P) BBB (low) (sf)

Classes A-1-X, A-3-X, A-5-X, A-7-X, A-9-X, A-11-X, A-13-X, A-15-X,
A-17-X, A-19-X, A-21-X, A-23-X, A-X, B-1-X, B-2-X, B-3-X, and B-X
are interest-only (IO) certificates. The class balances represent
notional amounts.

Classes A-1, A-1-X, A-2, A-3, A-3-X, A-4, A-6, A-7, A-7-X, A-8,
A-10, A-11, A-11-X, A-12, A-14, A-15, A-15-X, A-16, A-17, A-17-X,
A-18, A-19, A-19-X, A-20, A-22, A-24, B-1, B-2 and B-3 are
exchangeable certificates. These classes can be exchanged for
combinations of exchange certificates as specified in the offering
documents.

Classes A-5, A-9, A-13, and A-21 are super-senior certificates.
These classes benefit from additional protection from the senior
support certificate (Class A-23) with respect to loss allocation.

The AAA (sf) ratings on the Certificates reflect 8.50% of credit
enhancement provided by subordinated certificates. The AA (low)
(sf), A (low) (sf), BBB (low) (sf), BB (low) (sf), and B (low) (sf)
ratings reflect 3.50%, 2.10%, 1.05%, 0.60%, and 0.35% of credit
enhancement, respectively.

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

The transaction is a securitization of a portfolio of first-lien
fixed-rate prime residential mortgages funded by the issuance of
the Mortgage Pass-Through Certificates, Series 2024-J2 (the
Certificates). The Certificates are backed by 409 loans with a
total principal balance of $423,129,527 as of the Cut-Off Date
(October 1, 2024).

The pool consists of fully amortizing fixed-rate mortgages with
original terms to maturity of 30 years and a weighted-average (WA)
loan age of 3 months. Approximately 88.0% of the loans are
traditional, nonagency, prime jumbo mortgage loans. The remaining
12.0% of the loans are conforming mortgage loans that were
underwritten using an automated underwriting system (AUS)
designated by Fannie Mae or Freddie Mac and were eligible for
purchase by such agencies. Details on the underwriting of
conforming loans can be found in the Key Probability of Default
Drivers section. In addition, all of the loans in the pool were
originated in accordance with the new general Qualified Mortgage
(QM) rule.

Rocket Mortgage, LLC (Rocket Mortgage) originated 56.4% of the
pool. Various other originators, each comprising less than 15%,
originated the remainder of the loans. All the mortgage loans will
be serviced by Shellpoint Mortgage Servicing (Shellpoint or SMS).

Computershare Trust Company, N.A. (Computershare; rated BBB with a
Stable trend by Morningstar DBRS) will act as the Master Servicer
and Securities Administrator. Wilmington Trust, National
Association will serve as Trustee. Deutsche Bank National Trust
Company (Deutsche Bank) will act as Custodian.

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


RATE MORTGAGE 2024-J3: DBRS Finalizes B Rating on Class B5 Certs
----------------------------------------------------------------
DBRS, Inc. finalized its provisional credit ratings on the
Mortgage-Backed Notes, Series 2024-J3 (the Notes) issued by RATE
Mortgage Trust 2024-J3 (RATE 2024-J3, or the Trust) as follows:

-- $317.7 million Class A-1 at AAA (sf)
-- $317.7 million Class A-2 at AAA (sf)
-- $317.7 million Class A-3 at AAA (sf)
-- $238.2 million Class A-4 at AAA (sf)
-- $238.2 million Class A-5 at AAA (sf)
-- $238.2 million Class A-6 at AAA (sf)
-- $190.6 million Class A-7 at AAA (sf)
-- $190.6 million Class A-8 at AAA (sf)
-- $190.6 million Class A-9 at AAA (sf)
-- $47.7 million Class A-10 at AAA (sf)
-- $47.7 million Class A-11 at AAA (sf)
-- $47.7 million Class A-12 at AAA (sf)
-- $127.1 million Class A-13 at AAA (sf)
-- $127.1 million Class A-14 at AAA (sf)
-- $127.1 million Class A-15 at AAA (sf)
-- $79.4 million Class A-16 at AAA (sf)
-- $79.4 million Class A-17 at AAA (sf)
-- $79.4 million Class A-18 at AAA (sf)
-- $39.6 million Class A-19 at AAA (sf)
-- $39.6 million Class A-20 at AAA (sf)
-- $39.6 million Class A-21 at AAA (sf)
-- $357.3 million Class A-22 at AAA (sf)
-- $357.3 million Class A-23 at AAA (sf)
-- $357.3 million Class A-24 at AAA (sf)
-- $357.3 million Class A-25 at AAA (sf)
-- $357.3 million Class A-X-1 at AAA (sf)
-- $317.7 million Class A-X-2 at AAA (sf)
-- $317.7 million Class A-X-3 at AAA (sf)
-- $317.7 million Class A-X-4 at AAA (sf)
-- $238.2 million Class A-X-5 at AAA (sf)
-- $238.2 million Class A-X-6 at AAA (sf)
-- $238.2 million Class A-X-7 at AAA (sf)
-- $190.6 million Class A-X-8 at AAA (sf)
-- $190.6 million Class A-X-9 at AAA (sf)
-- $190.6 million Class A-X-10 at AAA (sf)
-- $47.7 million Class A-X-11 at AAA (sf)
-- $47.7 million Class A-X-12 at AAA (sf)
-- $47.7 million Class A-X-13 at AAA (sf)
-- $127.1 million Class A-X-14 at AAA (sf)
-- $127.1 million Class A-X-15 at AAA (sf)
-- $127.1 million Class A-X-16 at AAA (sf)
-- $79.4 million Class A-X-17 at AAA (sf)
-- $79.4 million Class A-X-18 at AAA (sf)
-- $79.4 million Class A-X-19 at AAA (sf)
-- $39.6 million Class A-X-20 at AAA (sf)
-- $39.6 million Class A-X-21 at AAA (sf)
-- $39.6 million Class A-X-22 at AAA (sf)
-- $357.3 million Class A-X-23 at AAA (sf)
-- $357.3 million Class A-X-24 at AAA (sf)
-- $357.3 million Class A-X-25 at AAA (sf)
-- $357.3 million Class A-X-26 at AAA (sf)
-- $5.4 million Class B-1 at AA (sf)
-- $5.4 million Class B-1A at AA (sf)
-- $5.4 million Class B-X-1 at AA (sf)
-- $6.2 million Class B-2 at A (low) (sf)
-- $6.2 million Class B-2A at A (low) (sf)
-- $6.2 million Class B-X-2 at A (low) (sf)
-- $1.9 million Class B-3 at BBB (low) (sf)
-- $747.0 thousand Class B-4 at BB (high) (sf)
-- $935.0 thousand Class B-5 at B (sf)
-- $317.7 million Class A-2L at AAA (sf)

Classes A-X-1, A-X-2, A-X-3, A-X-4, A-X-5, A-X-6, A-X-7, A-X-8,
A-X-9, A-X-10, A-X-11, A-X-12, A-X-13, A-X-14, A-X-15, A-X-16,
A-X-17, A-X-18, A-X-19, A-X-20, A-X-21, A-X-22, A-X-23, A-X-24,
A-X-25, A-X-26, B-X-1, and B-X-2 are interest-only (IO) notes. The
class balances represent notional amounts.

Classes A-1, A-2, A-3, A-4, A-6, A-7, A-8, A-10, A-11, A-13, A-14,
A-15, A-16, A-17, A-19, A-20, A-22, A-23, A-24, A-25, A-X-2, A-X-3,
A-X-4, A-X-5, A-X-6, A-X-7, A-X-8, A-X-11, A-X-14, A-X-15, A-X-16,
A-X-17, A-X-20, A-X-23, A-X-24, A-X-25, A-X-26, B-1, B-X-1, B-2,
and A-2L are exchangeable classes. These classes can be exchanged
for combinations of initial exchangeable notes as specified in the
offering documents.

Classes A-1, A-2, A-3, A-4, A-5, A-6, A-7, A-8, A-9, A-10, A-11,
A-12, A-13, A-14, A-15, A-16, A-17, A-18, and A-2L are super senior
tranches. These classes benefit from additional protection from the
senior support notes (Classes A-19, A-20, and A-21) with respect to
loss allocation.
The AAA (sf) credit ratings on the Certificates reflect 4.40% of
credit enhancement provided by subordinated certificates. The AA
(sf), A (low) (sf), BBB (low) (sf), BB (high) (sf), and B (sf)
credit ratings reflect 2.95%, 1.30%, 0.80%, 0.60%, and 0.35% of
credit enhancement, respectively.

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

DBRS, Inc. (Morningstar DBRS) finalized its provisional credit
ratings on RATE Mortgage Trust 2024-J3 (RATE 2024-J3 or the Trust),
a securitization of a portfolio of first-lien, fixed-rate prime
residential mortgages to be funded by the issuance of the
Mortgage-Backed Notes (the Notes). The Notes are backed by 333
loans with a total principal balance of $373,717,060 as of the
Cut-Off Date (September 1, 2024).

Guaranteed Rate, Inc. (Guaranteed Rate or GRI), as the Sponsor,
began issuing prime jumbo securitizations from its RATE shelf in
early 2021 and this transaction represents the eighth prime jumbo
RATE deal. The pool consists of fully amortizing fixed-rate
mortgages (FRMs) with original terms to maturity of 30 years and a
weighted-average (WA) loan age of one month. All of the pool
consists of traditional, nonagency, prime jumbo mortgage loans that
were underwritten using an automated underwriting system (AUS)
designated by Fannie Mae, but may be ineligible for purchase by
such agencies because of loan size.

All of the mortgage loans were originated by Guaranteed Rate.
Guaranteed Rate is also the Servicing Administrator and Sponsor of
the transaction. The loans will be serviced by ServiceMac, LLC
(ServiceMac). Computershare Trust Company, N.A. (Computershare
Trust Company; rated BBB with a Stable trend by Morningstar DBRS)
will act as the Master Servicer, Loan Agent, Paying Agent, Note
Registrar, and Certificate Registrar. Deutsche Bank National Trust
Company will act as the Custodian. Wilmington Savings Fund Society,
FSB will serve as Trustee.

Similar to the prior RATE securitizations, the Servicing
Administrator will fund advances of delinquent principal and
interest (P&I) on any mortgage until such loan becomes 120 days
delinquent or such P&I advances are deemed to be unrecoverable by
the Servicer or the Master Servicer (Stop-Advance Loan). The
Servicing Administrator will also fund advances in respect of
taxes, insurance premiums, and reasonable costs incurred in the
course of servicing and disposing properties.

The interest entitlements for each class in this transaction are
reduced reverse sequentially by the delinquent interest that would
have accrued on the Stop-Advance Loans. In other words, investors
are not entitled to any interest on such severely delinquent
mortgages, unless such interest amounts are recovered. The
delinquent interest recovery amounts, if any, will be distributed
sequentially to the P&I notes.

The Sponsor will have the option, but not the obligation, to
repurchase any mortgage loan that becomes 90 to 120 days delinquent
under the Mortgage Bankers Association (MBA) method at a price
equal to par plus interest and unreimbursed servicing advance
amounts, provided that such repurchases in aggregate do not exceed
10% of the total principal balance as of the Cut-Off Date.

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

This transaction allowed for the issuance of Classes A-1L, A-2L,
and A-3L loans, which are the equivalent of ownership of Classes
A-1, A-2, and A-3 Notes, respectively. These classes are issued in
the form of a loan made by the investor to the issuer instead of a
note purchased by the investor. Only the Class A-2L loan was funded
at closing. The holder may convert this class into an equal
aggregate debt amount of the corresponding Class A-2 Notes. There
is no change to the structure with this Class elected.

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


RCKT MORTGAGE 2021-4: Moody's Hikes Rating on Cl. B-5 Certs to B2
-----------------------------------------------------------------
Moody's Ratings has upgraded the ratings of 15 bonds issued by RCKT
Mortgage Trust. The collateral backing these deals consists of
prime jumbo mortgage loans.

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

The complete rating actions are as follow:

Issuer: RCKT Mortgage Trust 2021-4

Cl. B-1, Upgraded to Aa1 (sf); previously on Dec 13, 2023 Upgraded
to Aa2 (sf)

Cl. B-1A, Upgraded to Aa1 (sf); previously on Dec 13, 2023 Upgraded
to Aa2 (sf)

Cl. B-2, Upgraded to A1 (sf); previously on Dec 13, 2023 Upgraded
to A2 (sf)

Cl. B-2A, Upgraded to A1 (sf); previously on Dec 13, 2023 Upgraded
to A2 (sf)

Cl. B-3, Upgraded to Baa1 (sf); previously on Dec 13, 2023 Upgraded
to Baa2 (sf)

Cl. B-5, Upgraded to B2 (sf); previously on Sep 24, 2021 Definitive
Rating Assigned B3 (sf)

Cl. B-X-1*, Upgraded to Aa1 (sf); previously on Dec 13, 2023
Upgraded to Aa2 (sf)

Cl. B-X-2*, Upgraded to A1 (sf); previously on Dec 13, 2023
Upgraded to A2 (sf)

Issuer: RCKT Mortgage Trust 2022-4

Cl. A-21, Upgraded to Aaa (sf); previously on Jun 9, 2022
Definitive Rating Assigned Aa1 (sf)

Cl. A-22, Upgraded to Aaa (sf); previously on Jun 9, 2022
Definitive Rating Assigned Aa1 (sf)

Cl. A-23, Upgraded to Aaa (sf); previously on Jun 9, 2022
Definitive Rating Assigned Aa1 (sf)

Cl. A-24, Upgraded to Aaa (sf); previously on Jun 9, 2022
Definitive Rating Assigned Aa1 (sf)

Cl. A-X-1*, Upgraded to Aaa (sf); previously on Jun 9, 2022
Definitive Rating Assigned Aa1 (sf)

Cl. A-X-12*, Upgraded to Aaa (sf); previously on Jun 9, 2022
Definitive Rating Assigned Aa1 (sf)

Cl. A-X-13*, Upgraded to Aaa (sf); previously on Jun 9, 2022
Definitive Rating Assigned Aa1 (sf)

* Reflects Interest-Only Classes

RATINGS RATIONALE

The rating upgrades reflect the increased levels of credit
enhancement available to the bonds, the recent performance, and
Moody's updated loss expectations on the underlying pool.

Each of the transactions Moody's reviewed continue to maintain low
cumulative loss levels under .03%. In addition, enhancement levels
for these tranches have grown, as the pools amortize relatively
quickly. The credit enhancement since closing has relative growth
of 17.8% for the non-exchangeable tranches upgraded.

In addition, while Moody's analysis applied a greater probability
of default stress on loans that have experienced modifications,
Moody's decreased that stress to the extent the modifications were
in the form of temporary payment relief.

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 this deal
because the expected losses on these bonds remain commensurate with
their current ratings, after taking into account the updated
performance information, structural features, and credit
enhancement.

Principal Methodologies

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 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 and/or pools.

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.


RCKT MORTGAGE 2024-CES8: Fitch Assigns B(EXP) Rating to 5 Tranches
------------------------------------------------------------------
Fitch Ratings expects to rate the residential mortgage-backed notes
issued by RCKT Mortgage Trust 2024-CES8 (RCKT 2024-CES8).

   Entity/Debt        Rating           
   -----------        ------           
RCKT 2024-CES8

   A1-A           LT AAA(EXP)sf Expected Rating
   A1-B           LT AAA(EXP)sf Expected Rating
   A-2            LT AA(EXP)sf  Expected Rating
   A-3            LT A(EXP)sf   Expected Rating
   M-1            LT BBB(EXP)sf Expected Rating
   B-1            LT BB(EXP)sf  Expected Rating
   B-2            LT B(EXP)sf   Expected Rating
   B-3            LT NR(EXP)sf  Expected Rating
   A-1            LT AAA(EXP)sf Expected Rating
   A-4            LT AA(EXP)sf  Expected Rating
   A-5            LT A(EXP)sf   Expected Rating
   A-6            LT BBB(EXP)sf Expected Rating
   B-1A           LT BB(EXP)sf  Expected Rating
   B-X-1A         LT BB(EXP)sf  Expected Rating
   B-1B           LT BB(EXP)sf  Expected Rating
   B-X-1B         LT BB(EXP)sf  Expected Rating
   B-2A           LT B(EXP)sf   Expected Rating
   B-X-2A         LT B(EXP)sf   Expected Rating
   B-2B           LT B(EXP)sf   Expected Rating
   B-X-2B         LT B(EXP)sf   Expected Rating
   XS             LT NR(EXP)sf  Expected Rating
   A-1L           LT AAA(EXP)sf Expected Rating
   R              LT NR(EXP)sf  Expected Rating

Transaction Summary

The notes are supported by 5,112 closed-end second lien (CES) loans
with a total balance of approximately $441.3 million as of the
cutoff date. The pool consists of CES mortgages acquired by
Woodward Capital Management LLC from Rocket Mortgage LLC.
Distributions of principal and interest (P&I) and loss allocations
are based on a traditional senior-subordinate, sequential structure
in which excess cash flow can be used to repay losses or net
weighted average coupon (WAC) shortfalls.

KEY RATING DRIVERS

Updated Sustainable Home Prices (Negative): As a result of its
updated view on sustainable home prices, Fitch views the home price
values of this pool as 11.7% above a long-term sustainable level
(versus 11.5% on a national level as of 1Q24). Housing
affordability is at its worst levels in decades, driven by both
high interest rates and elevated home prices. Home prices had
increased 5.9% yoy nationally as of May 2024, notwithstanding
modest regional declines, but are still being supported by limited
inventory.

Prime Credit Quality (Positive): The collateral consists of 5,112
loans totaling approximately $441.3 million and seasoned at about
3.4 months in aggregate, as calculated by Fitch (one month, per the
transaction documents) — taken as the difference between the
origination date and the cutoff date. The borrowers have a strong
credit profile, including a WA Fitch model FICO score of 740; a
debt-to-income ratio (DTI) of 38.3%; and moderate leverage, with a
sustainable loan-to-value ratio (sLTV) of 78.9%.

Of the pool, 99.2% of the loans are of a primary residence and 0.8%
represent second homes or investor properties, and 88.3% of loans
were originated through a retail channel. Additionally, 65.6% of
loans are designated as safe-harbor qualified mortgages (SHQMs) and
14.2% are higher-priced qualified mortgages (HPQMs). Given the 100%
loss severity (LS) assumption, no additional penalties were applied
for the HPQM loan status.

Second Lien Collateral (Negative): The entire collateral pool
comprises CES loans originated by Rocket Mortgage. Fitch assumed no
recovery and a 100% LS based on the historical behavior of second
lien loans in economic stress scenarios. Fitch assumes second lien
loans default at a rate comparable to first lien loans; after
controlling for credit attributes, no additional penalty was
applied to Fitch's probability of default (PD) assumption.

Sequential Structure (Positive): The transaction has a typical
sequential payment structure. Principal is used to pay down the
bonds sequentially and losses are allocated reverse sequentially.
Monthly excess cash flow is derived from remaining amounts after
allocation of the interest and principal priority of payments.
These amounts will be applied as principal, first to repay any
current and previously allocated cumulative applied realized loss
amounts and then to repay any potential net WAC shortfalls. The
senior classes incorporate a step-up coupon of 1.00% (to the extent
still outstanding) after the 48th payment date.

While Fitch had previously analyzed CES transactions using an
interest rate cut, this stress is no longer being applied. Given
the lack of evidence of interest rate modifications being used as a
loss mitigation tactic, applying the stress would have been overly
punitive. If interest rate modifications re-emerge as a common form
of loss mitigation or if certain structures are overly dependent on
excess interest, Fitch may apply additional sensitivities to test
the structure.

180-Day Chargeoff Feature (Positive): The class XS majority
noteholder has the ability, but not the obligation, to instruct the
servicer to write off the balance of a loan at 180 days delinquent
(DQ) based on the Mortgage Bankers Association (MBA) delinquency
method. To the extent the servicer expects meaningful recovery in
any liquidation scenario, the class XS majority noteholder may
direct the servicer to continue to monitor the loan and not charge
it off.

While the 180-day chargeoff feature will result in losses being
incurred sooner, there is a larger amount of excess interest to
protect against them. This compares favorably with a delayed
liquidation scenario, where losses occur later in the life of a
transaction and less excess is available to cover them. If a loan
is not charged off due to a presumed recovery, this will provide
added benefit to the transaction, above Fitch's expectations.

Additionally, recoveries realized after the writedown at 180 days
DQ (excluding forbearance mortgage or loss mitigation loans) will
be passed on to bondholders as principal.

RATING SENSITIVITIES

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

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

The defined negative rating sensitivity analysis demonstrates how
the ratings would react to steeper MVDs at the national level. The
analysis assumes MVDs of 10.0%, 20.0% and 30.0% in addition to the
model projected 42.6% at 'AAA'. The analysis indicates that there
is some potential rating migration with higher MVDs for all rated
classes, compared with the model projection. Specifically, a 10%
additional decline in home prices would lower all rated classes by
one full category.

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

The defined positive rating sensitivity analysis demonstrates how
the ratings would react to positive home price growth of 10% with
no assumed overvaluation. Excluding the senior class, which is
already rated 'AAAsf', the analysis indicates there is potential
positive rating migration for all of the rated classes.
Specifically, a 10% gain in home prices would result in a full
category upgrade for the rated class excluding those being assigned
ratings of 'AAAsf'.

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

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by AMC Diligence, LLC. The third-party due diligence
described in Form 15E focused on credit, regulatory compliance and
property valuation. Fitch considered this information in its
analysis and, as a result, Fitch made the following adjustment to
its analysis: a 5% PD credit to the 25.0% of the pool by loan count
in which diligence was conducted. This adjustment resulted in a
21bps 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.


READY CAPITAL 2021-FL7: DBRS Confirms B(low) Rating on G Notes
--------------------------------------------------------------
DBRS Limited confirmed all credit ratings on the notes issued by
Ready Capital Mortgage Financing 2021-FL7, LLC as follows:

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

All trends are Stable.

The credit rating confirmations reflect the favorable pool
composition as the majority of the 30 underlying loans,
representing 89.0% of the current trust balance, are secured by
multifamily properties, which have historically fared better during
times of distress, in terms of retained property value and cash
flow, as compared with other property types. Although the
transaction reports a significant percentage of specially serviced
loans, with seven loans, representing 25.0% of the pool,
Morningstar DBRS' analysis suggests that losses in the potential
liquidation scenarios considered as part of this review for two of
those loans would be well contained to the $85.8 million unrated
Class H Note. In addition, the significant paydown since issuance
and resulting increase in credit support to the rated Notes is seen
to be a mitigating factor for the increased pool expected loss (EL)
that resulted from the stressed scenarios considered for other
loans in special servicing to increase the loan-level ELs. In
total, there is almost $174.0 million in cushion against loss
across the unrated Class H and the below-investment-grade credit
rated Class F and Class G Notes, with credit enhancement of nearly
28.0% for the BBB (low) (sf) credit rated Class E Note.

In conjunction with this press release, Morningstar DBRS has
published a Surveillance Performance Update report with in-depth
analysis and credit metrics for the transaction as well as business
plan updates on select loans. For access to this report, please
click on the link under Related Documents below or contact us at
info-DBRS@morningstar.com.

The initial collateral consisted of 76 floating-rate mortgages
secured by 89 properties with a cut-off date balance totaling
$927.2 million. Most collateral properties were in a period of
transition with plans to stabilize performance and improve values
of the underlying assets. The transaction was structured with a
Replenishment Period that expired with the November 2023 payment
date. As of the September 2024 remittance, the pool comprised 37
loans secured by 43 properties with a cumulative trust balance of
$624.3 million, representing collateral reduction of 32.8% since
issuance. Since issuance, 39 loans with a prior cumulative trust
balance of $384.5 million have been successfully repaid from the
pool, including 17 loans totaling $221.2 million that have repaid
since the previous Morningstar DBRS rating action in October 2023.

Beyond the multifamily concentration noted above, five loans,
representing 6.4% of the pool, are secured by industrial properties
and the remaining two loans are secured by a lodging and a
self-storage property. The pool is primarily secured by properties
in suburban markets, as defined by Morningstar DBRS, with 32 loans,
representing 80.9% of the pool, assigned a Morningstar DBRS Market
Rank of 3, 4, or 5. An additional five loans, representing 19.1% of
the pool, are secured by properties with a Morningstar DBRS Market
Rank of 6 or 7, denoting urban markets. These concentrations are
generally in line with the pool composition in September 2023.

Leverage across the pool has remained similar since issuance as the
current weighted-average (WA) as-is appraised value loan-to-value
ratio (LTV) is 72.5%, with the current WA stabilized LTV of 65.3%.
In comparison, these figures were 72.9% and 65.3%, respectively, at
issuance. Some of the appraisals are from the early years of the
pandemic (completed in 2020 and 2021), suggesting some of the cap
rates utilized by the appraisers could be low compared to cap rates
utilized later in the cycle, after the interest rate increases that
began in 2022. As such, Morningstar DBRS evaluated the implied cap
rates for each of those loans and stressed the values where
applicable. In the analysis for this review, Morningstar DBRS
applied upward LTV adjustments to 17 loans, representing 55.1% of
the current trust balance.

As of the September 2024 reporting, seven loans, representing 25.0%
of the current trust balance, are in special servicing. In its
analysis, Morningstar DBRS liquidated the Asher Apartments
(Prospectus ID#6, 4.7% of the pool) and Highland Midtown loans
(Prospectus ID#19, 2.7% of the pool), with loss severities
exceeding 30.0% and 50.0%, respectively. The cumulative loss was
contained to Class H, the unrated $85.8 million first-loss piece.
The largest loan in special servicing, Skylar Pointe (Prospectus
ID#2, 6.3% of the pool), is secured by a 449-unit multifamily
complex in Houston, Texas. The loan transferred to special
servicing in November 2023 and is in the process of being modified
to facilitate the transfer of interest to the preferred equity
investor and also to extend its initial November 2024 maturity
date. Following the transfer of ownership, the loan is expected to
return to the master servicer. Given the collateral property's
underperformance as compared with issuance expectations,
Morningstar DBRS analyzed the loan with an elevated as-is LTV and
stabilized LTV, along with a probability of default penalty,
resulting in an expected loss approximately 70% greater than the
pool average.

There are 21 loans, representing 50.9% of the current trust
balance, on the servicer's watchlist as of the September 2024
reporting. The loans have generally been flagged for upcoming loan
maturity and low debt service coverage ratios. Excluding any
specially serviced loans, 26 loans, representing 65.1% of the
current trust balance, have scheduled maturity dates in the next 12
months. All but two loans (combined representing 0.9% of the
current trust balance) have outstanding extension options available
to the individual borrowers. If property performance does not
qualify to exercise the related options, Morningstar DBRS expects
the borrowers and lender to negotiate mutually beneficial loan
modifications to extend the loans. Based on prior modification
terms, Morningstar DBRS expects such agreements would likely
include fresh sponsor equity to fund principal curtailments,
funding of carry reserves, and/or the purchase of a new interest
rate cap agreement.

Through August 2024, the lender had advanced cumulative loan future
funding of $59.7 million to 32 borrowers to aid in property
stabilization efforts. The largest advance, $7.7 million, has been
made to the borrower of the 835-864 West Barry Avenue loan
(Prospectus ID#9, 4.7% of the pool). The loan is secured by a
115-unit apartment complex in Chicago. The advanced funds have been
used to fund the borrower's $10.3 million planned capital
expenditure (capex) across the portfolio. Less than $100,000 of
future funding remains available to the borrower to complete its
capex plan.

An additional $20.0 million of loan future funding allocated to 27
of the outstanding individual borrowers remains available. The
largest portion ($2.8 million) is allocated to the borrower of the
specially serviced Asher Apartments loan, for which $2.6 million in
future funding has been previously advanced to date. The remaining
available funds are for the borrower's capex plan; however, given
the specially serviced status of the loan, it is unlikely that
additional funds will be advanced to the borrower.

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


REALT 2017: DBRS Hikes Class G Certs Rating to B(high)
------------------------------------------------------
DBRS Limited upgraded its credit ratings on eight classes of the
Commercial Mortgage Pass-Through Certificates, Series 2017 issued
by Real Estate Asset Liquidity Trust (REALT) Series 2017 as
follows:

-- Class B to AAA (sf) from AA (high) (sf)
-- Class C to AA (high) (sf) from AA (sf)
-- Class D-1 to AA (low) (sf) from BBB (high) (sf)
-- Class D-2 to A (high) (sf) from BBB (high) (sf)
-- Class E to BBB (high) (sf) from BBB (low) (sf)
-- Class F to BB (high) (sf) from BB (sf)
-- Class G to B (high) (sf) from B (sf)
-- Class X to AAA (sf) from AA (high) (sf)

In addition, Morningstar DBRS confirmed the following credit
rating:

-- Class A-2 at AAA (sf)

Morningstar DBRS changed the trend on Class C to Positive from
Stable. The trends on all remaining classes are Stable with the
exception of Classes D-1 and D-2, which remain Positive.

The credit rating upgrades and Positive trends reflect the
significant deleveraging since issuance and the overall
stable-to-improving performance of the remaining collateral, as
evidenced by a healthy weighted-average (WA) debt service coverage
ratio (DSCR) of 1.84 times (x), based on the most recent year-end
financial reporting. Since Morningstar DBRS' prior credit rating
action, 10 loans (12.9% of the original pool balance) were repaid
in full at their scheduled maturity dates.

In total, loan repayments and amortization have reduced the pool
balance to $138.9 million as of the September 2024 reporting,
representing a collateral reduction of 65.9% since issuance. In
addition, three loans, representing 6.9% of the current pool
balance, have maturity dates within the next 12 months. Morningstar
DBRS expects these loans will repay from the trust based on their
WA debt yield and DSCR of 14.7% and 1.8x, respectively. This
additional paydown will lead to further improvement in credit
enhancement levels, especially toward the top and middle of the
capital stack, as indicated by the Positive trends carried by
Classes C, D-1, and D-2. Morningstar DBRS' analysis also considered
a stressed scenario to further evaluate the support for credit
rating upgrades. In addition to applying probability of default
(POD) and/or loan-to-value ratio adjustments to a select number of
loans where applicable, Morningstar DBRS also applied a 20.0%
haircut to the issuer's underwritten cash flow for each remaining
loan in the pool. The resulting analysis suggests a significant
amount of cushion remains against future cash flow volatility,
further supporting the credit rating upgrades with this review.

As of the September 2024 remittance, 34 of the original 71 loans
remain in the pool. No loans are delinquent or in special
servicing. Four loans, representing 27.8% of the pool, are on the
servicer's watchlist; however, only two of those loans,
representing 22.6% of the pool, are being monitored for
performance-related reasons. The transaction is generally well
distributed by property type, with loans representing 34.2%, 32.4%,
and 14.7% of the pool collateralized by self-storage, retail, and
industrial properties, respectively. Only three loans, representing
10.9% of the pool balance, are backed by office properties, further
highlighting the favorable makeup of the pool's underlying
collateral. The majority of loans remaining in the pool benefit
from some level of meaningful recourse to the loan's sponsor.

The largest loan in the pool, Skyline Thunder Centre (Prospectus
ID#1; 18.7% of the current pool balance), is secured by an
approximately 168,000 square feet (sf) anchored retail property in
Thunder Bay, Ontario. The loan is currently being monitored on the
servicer's watchlist for a low DSCR. According to the January 2024
rent roll, the property was 86.7% occupied, below the issuance
occupancy rate of 99.0%. Over the next year, four tenants, totaling
approximately 18.0% of the net rentable area (NRA), have scheduled
lease expirations, including the third-largest tenant, Old Navy,
which accounts for 8.9% of NRA and has a lease scheduled to expire
in November 2024. However, there has been positive leasing momentum
at the property in the past few months, with approximately 21,000
sf (12.5% of the NRA) of space being leased by two new tenants.
Those tenants had lease commencement dates in August and October of
this year, suggesting the property's physical occupancy rate has
returned to near 100.0%. According to the YE2023 financial
reporting, the property generated $1.8 million of net cash flow
(NCF) (a DSCR of 1.03x), an improvement from the YE2022 figure of
$1.5 million (a DSCR of 0.88x) but still lower than the Morningstar
DBRS figure of $2.2 million (a DSCR of 1.24x). Morningstar DBRS
expects revenue will improve once rent payments from new tenants
commence; however, given the upcoming rollover, Morningstar DBRS
analyzed this loan with an elevated POD penalty, resulting in an
expected loss that was more than 2.5x greater than the pool
average.

The second-largest loan on the servicer's watchlist, Worthington
Office North Bay (Prospectus ID#22; 3.92% of the current pool
balance), is secured by a 71,491-sf office property in North Bay,
Ontario. According to the servicer-reported financials, the
occupancy rate and DSCR were 68.0% and 0.51x, respectively, as of
YE2023, compared with 70.0% and 0.86x at YE2022, and well below the
issuance occupancy rate of 91.0% and the Morningstar DBRS DSCR of
1.38x. The former third-largest tenant, Strickland Larmer (8.0% of
the NRA), vacated the property upon lease expiration in 2022 while
the two largest tenants, Canada Post Corporation (27.3% of NRA),
and Redpath Mining (12.8% of NRA), extended their leases to 2027
and 2032, respectively. Morningstar DBRS analyzed this loan with an
elevated POD penalty to reflect the declines in occupancy rate and
cash flow, resulting in an expected loss that was almost 3.5x
greater than the pool average.

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


REGATTA FUNDING XXII: Moody's Gives Ba3 Rating to $20MM E-R Notes
-----------------------------------------------------------------
Moody's Ratings has assigned ratings to three classes of CLO
refinancing notes (the "Refinancing Notes") issued by Regatta XXII
Funding Ltd.

Moody's rating action is as follows:

US$320,000,000 Class A-R Senior Secured Floating Rate Notes due
2035, Assigned Aaa (sf)

US$60,000,000 Class B-R Senior Secured Floating Rate Notes due
2035, Assigned Aa1 (sf)

US$20,000,000 Class E-R Junior Secured Deferrable Floating Rate
Notes due 2035, Assigned Ba3 (sf)

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

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.

Napier Park Global Capital (US) LP (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 remaining
reinvestment period.

The Issuer previously issued two other classes of secured notes and
one class of subordinated notes, which will remain outstanding.

Other changes to transaction features in connection with the
refinancing include extension of the non-call period.

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: $499,187,870

Defaulted par: $2,916,888

Diversity Score: 85

Weighted Average Rating Factor (WARF): 2831

Weighted Average Spread (WAS) (before accounting for reference rate
floors): 3.48%

Weighted Average Coupon (WAC): 3.89%

Weighted Average Recovery Rate (WARR): 46.43%

Weighted Average Life (WAL): 5.91 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 Underlying the Rating Action

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

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

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


SEQUOIA MORTGAGE 2024-10: Fitch Assigns 'B+sf' Rating on B5 Certs
-----------------------------------------------------------------
Fitch Ratings has assigned final ratings to the residential
mortgage-backed certificates issued by Sequoia Mortgage Trust
2024-10 (SEMT 2024-10).

   Entity/Debt      Rating             Prior
   -----------      ------             -----
SEMT 2024-10

   A1           LT AAAsf  New Rating   AAA(EXP)sf
   A2           LT AAAsf  New Rating   AAA(EXP)sf
   A3           LT AAAsf  New Rating   AAA(EXP)sf
   A4           LT AAAsf  New Rating   AAA(EXP)sf
   A5           LT AAAsf  New Rating   AAA(EXP)sf
   A6           LT AAAsf  New Rating   AAA(EXP)sf
   A7           LT AAAsf  New Rating   AAA(EXP)sf
   A8           LT AAAsf  New Rating   AAA(EXP)sf
   A9           LT AAAsf  New Rating   AAA(EXP)sf
   A10          LT AAAsf  New Rating   AAA(EXP)sf
   A11          LT AAAsf  New Rating   AAA(EXP)sf
   A12          LT AAAsf  New Rating   AAA(EXP)sf
   A13          LT AAAsf  New Rating   AAA(EXP)sf
   A14          LT AAAsf  New Rating   AAA(EXP)sf
   A15          LT AAAsf  New Rating   AAA(EXP)sf
   A16          LT AAAsf  New Rating   AAA(EXP)sf
   A17          LT AAAsf  New Rating   AAA(EXP)sf
   A18          LT AAAsf  New Rating   AAA(EXP)sf
   A19          LT AAAsf  New Rating   AAA(EXP)sf
   A20          LT AAAsf  New Rating   AAA(EXP)sf
   A21          LT AAAsf  New Rating   AAA(EXP)sf
   A22          LT AAAsf  New Rating   AAA(EXP)sf
   A23          LT AAAsf  New Rating   AAA(EXP)sf
   A24          LT AAAsf  New Rating   AAA(EXP)sf
   A25          LT AAAsf  New Rating   AAA(EXP)sf
   AIO1         LT AAAsf  New Rating   AAA(EXP)sf
   AIO2         LT AAAsf  New Rating   AAA(EXP)sf
   AIO3         LT AAAsf  New Rating   AAA(EXP)sf
   AIO4         LT AAAsf  New Rating   AAA(EXP)sf
   AIO5         LT AAAsf  New Rating   AAA(EXP)sf
   AIO6         LT AAAsf  New Rating   AAA(EXP)sf
   AIO7         LT AAAsf  New Rating   AAA(EXP)sf
   AIO8         LT AAAsf  New Rating   AAA(EXP)sf
   AIO9         LT AAAsf  New Rating   AAA(EXP)sf
   AIO10        LT AAAsf  New Rating   AAA(EXP)sf
   AIO11        LT AAAsf  New Rating   AAA(EXP)sf
   AIO12        LT AAAsf  New Rating   AAA(EXP)sf
   AIO13        LT AAAsf  New Rating   AAA(EXP)sf
   AIO14        LT AAAsf  New Rating   AAA(EXP)sf
   AIO15        LT AAAsf  New Rating   AAA(EXP)sf
   AIO16        LT AAAsf  New Rating   AAA(EXP)sf
   AIO17        LT AAAsf  New Rating   AAA(EXP)sf
   AIO18        LT AAAsf  New Rating   AAA(EXP)sf
   AIO19        LT AAAsf  New Rating   AAA(EXP)sf
   AIO20        LT AAAsf  New Rating   AAA(EXP)sf
   AIO21        LT AAAsf  New Rating   AAA(EXP)sf
   AIO22        LT AAAsf  New Rating   AAA(EXP)sf
   AIO23        LT AAAsf  New Rating   AAA(EXP)sf
   AIO24        LT AAAsf  New Rating   AAA(EXP)sf
   AIO25        LT AAAsf  New Rating   AAA(EXP)sf
   AIO26        LT AAAsf  New Rating   AAA(EXP)sf
   B1           LT AAsf   New Rating   AA(EXP)sf
   B1A          LT AAsf   New Rating   AA(EXP)sf
   B1X          LT AAsf   New Rating   AA(EXP)sf
   B2           LT Asf    New Rating   A(EXP)sf
   B2A          LT Asf    New Rating   A(EXP)sf
   B2X          LT Asf    New Rating   A(EXP)sf
   B3           LT BBBsf  New Rating   BBB(EXP)sf
   B4           LT BBsf   New Rating   BB(EXP)sf
   B5           LT B+sf   New Rating   B+(EXP)sf
   B6           LT NRsf   New Rating   NR(EXP)sf
   AIOS         LT NRsf   New Rating   NR(EXP)sf

Transaction Summary

The SEMT 2024-10 certificates are supported by 313 loans with a
total balance of approximately $373.9 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.

Following the publication of the presale and expected ratings, the
issuer notified Fitch of an updated tape, which consisted of
updated cutoff balances. In addition, Redwood also provided Fitch
with an updated structure to reflect the new balances as well as
the credit enhancement increase from 5.65% to 6.00% on the senior
support class (and corresponding exchangeables). There were no
changes to the credit enhancement levels to the bonds. Fitch re-ran
both its asset and cash flow analysis, and there were no changes to
the loss feedback or the expected ratings.

KEY RATING DRIVERS

High-Quality Mortgage Pool (Positive): The collateral consists of
313 loans totaling approximately $373.9 million and seasoned at
approximately two months in aggregate, as determined by Fitch. The
borrowers have a strong credit profile, with a weighted-average
Fitch model FICO score of 775 and 36.3% debt-to-income (DTI) ratio,
and moderate leverage, with an 80.0% sustainable loan-to-value
(sLTV) ratio and 72.0% mark-to-market combined loan-to-value (cLTV)
ratio.

Overall, the pool consists of 94.1% in loans where the borrower
maintains a primary residence, while 5.9% are of a second home;
75.1% of the loans were originated through a retail channel.
Additionally, 100.0% of the loans are designated as qualified
mortgage (QM) loans.

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, remaining unchanged 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.

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).

Compared to 120-day stop advance framework in prior Redwood
transactions, SEMT 2024-10 will feature the servicing administrator
(RRAC) obligated to advance delinquent principal and interest (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 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 41.2% 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'.

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 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.


SEQUOIA MORTGAGE 2024-HYB1: Fitch Gives B(EXP)sf Rating on B2 Certs
-------------------------------------------------------------------
Fitch Ratings has assigned expected ratings to Sequoia Mortgage
Trust 2024-HYB1 (SEMT 2024-HYB1).

   Entity/Debt      Rating           
   -----------      ------           
SEMT 2024-HYB1

   A1           LT  AAA(EXP)sf   Expected Rating
   A1AF         LT  AAA(EXP)sf   Expected Rating
   A1A          LT  AAA(EXP)sf   Expected Rating
   A1AIO        LT  AAA(EXP)sf   Expected Rating
   A1BF         LT  AAA(EXP)sf   Expected Rating
   A1B          LT  AAA(EXP)sf   Expected Rating
   A1BIO        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
   AIOS         LT  NR(EXP)sf    Expected Rating
   R            LT  NR(EXP)sf    Expected Rating

Transaction Summary

The SEMT 2024-HYB1 certificates are supported by 424 seasoned loans
with a total balance of approximately $386.0 million as of the
cutoff date. The pool consists of seasoned performing,
adjustable-rate mortgages acquired by Redwood Residential
Acquisition Corp. (RRAC) from Washington Federal Bank.
Distributions of principal and interest (P&I) and loss allocations
are based on a sequential-pay structure.

KEY RATING DRIVERS

Updated Sustainable Home Prices (Negative): Fitch views the home
price values of this pool as 8.7% above a long-term sustainable
level (versus 11.5% on a national level as of 1Q24, up 0.4% since
the prior quarter). Housing affordability is the worst it has been
in decades, driven by both high interest rates and elevated home
prices. Home prices increased 4.9% yoy nationally as of July 2024,
despite modest regional declines, but are still being supported by
limited inventory.

Seasoned Prime Credit Quality (Positive): The collateral consists
of 424 loans totaling approximately $386.0 million and seasoned
about 63 months in aggregate, as determined by Fitch, based on the
origination date. All the loans were originated by Washington
Federal Bank, as successor in interest to Luther Burbank, and
borrowers have a strong credit profile with a weighted average (WA)
Fitch model FICO score of 762 and a 35.7% debt-to-income ratio
(DTI). 94.4% of the borrowers have been clean and current over the
past 24 months, including 7.9% which Fitch viewed as clean due to
servicing transfer related issues, while the remaining 5.6% have
experienced a delinquency in the past two years. All the loans are
current as of the cutoff date.

Low Leverage (Positive): The borrowers exhibit sizable equity in
the properties, with an original combined loan-to-value ratio
(cLTV) and mark-to-market cLTV of 52.3%, which after applicable
haircuts, based on the valuation product, translates to a 57.4%
sustainable loan-to-value ratio (sLTV) in the base case. This
reflects low-leverage borrowers and is stronger than comparable
seasoned transactions.

After accounting for Fitch's overvaluation haircuts, 63.1% of the
loans have a loss severity (LS) less than 30% and 24.8% are at
Fitch's minimum LS floor in Fitch's 'AAAsf' stress.

Hybrid ARM Concentration and Payment Shock (Negative): All the
loans in this transaction are adjustable-rate mortgages (ARMs) with
an initial fixed period between three and 84 months. A majority of
the loans will have rates subsequently reset every 12 months. In
addition, of the pool, 26.8% also have an interest-only (IO) period
between 12 and 84 months.

Fitch assumes in its analytical treatment that borrowers
approaching their initial and subsequent reset dates exhibit a
higher future payment shock as a result of their interest rates
changing and, consequently, a higher probability of default (PD).
Given the low rates when the adjustable-rate loans were first
originated and the current rate environment, the reset could prove
to be meaningful. The borrowers' credit profile and low leverage
should mitigate potential defaults arising from a payment.

Fitch expects the probability of default (PD) to be 1.42x higher in
the 'AAAsf' stress relative to a 100% fully amortizing fixed-rate
pool.

High Geographic Concentration (Negative): The pool has a high
California concentration at 93.2% by the unpaid principal balance
(UPB). The three highest metropolitan statistical areas (MSAs) of
Los Angeles (38.0%), San Francisco (23.2%) and San Jose (10.5%)
constitute over 71.7% of the pool.

Pools concentrated in a small number of geographic regions may be
highly sensitive to unforeseen localized stresses, such as natural
disaster events or deteriorating economic conditions on a regional
basis.

Fitch applied a geographic concentration penalty of 1.28x at the
'AAAsf' stress, which resulted in a roughly 121-bp penalty to
account for the significant geographic concentration in this pool.

Additionally, Fitch employs CATRADER, a natural catastrophe
modeling tool through AIR Worldwide Corporation, to estimate the
catastrophe risk in the form of natural disaster events such as
storm surges, inland flooding and earthquakes for each county. Due
to the large West Coast concentration, the adjustment was
concentrated on earthquake risk.

Sequential-Pay Structure with Full Advancing (Mixed): The mortgage
cash flow and loss allocation are based on a sequential-pay
structure, whereby interest and principal are paid pro-rata amongst
the classes A-1A and A-1B (with classes A-1AIO and A-1BIO receiving
their respective interest allocation), followed by classes A-2 to
B-3 sequentially. Realized losses will be allocated in
reverse-sequential order, beginning with class B-3.

SEMT 2024-HYB1 will feature the servicing administrator (RRAC),
following initial reductions in the class A-IO-S strip and
servicing administrator fees, obligated to advance delinquent (DQ)
P&I to the trust until deemed nonrecoverable. Full advancing of P&I
is a less common structural feature across seasoned performing
transactions but is beneficial in providing liquidity to the
certificates, and absent the full advancing, bonds can be
vulnerable to missed payments during periods of adverse performance
and delinquencies. Due to the sequential structure and full
advancing, the credit enhancement (CE) levels are equivalent to
Fitch's expected losses at each rating category.

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 40.6% 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'.

CRITERIA VARIATION

Fitch's analysis incorporated two criteria variations from the
"U.S. RMBS Rating Criteria" and the "U.S. RMBS Loan Loss
Criteria."

The first variation relates to the application of lower loss
severity (LS) floors than those described in Fitch's criteria. This
pool benefits from a material amount of equity buildup. Even after
a 40% home price decline environment (AAAsf rating case), the
stressed sLTV is only 88.8%. Additionally, the pool's sLTV of 57.4%
is below the SPL/RPL industry average. Fitch believes that applying
a 30% LS floor in this situation is highly punitive and that a 20%
LS floor at 'AAAsf' provides additional downside protection in the
event of idiosyncratic events while differentiating this pool from
other pools with much higher sLTVs. This treatment resulted in a
rating of approximately one to two notches higher for each class.

The second variation pertains to the lack of an updated tax and
title review. Fitch views the tax and title search to be an
essential part of its analysis to assess no liens were subsequently
placed on the property. Fitch's criteria allow for certain
mitigating factors deemed to be sufficient, such as an
investment-grade representation (rep) provider with adequate
loan-level reps pertaining to tax and title, or a Fitch-rated
servicer monitor for outstanding tax and title issues. Fitch
received direct communication from Washington Federal Bank
confirming the loans in the pool are in first position and that
their servicing practice entails using CoreLogic to track
delinquent (DQ) tax reports and establishing escrow accounts to
force borrowers to pay taxes if DQ more than 60 days. RRAC also has
strong loan-level reps and may repurchase the asset in the event of
any breach. As a result, Fitch is comfortable with not receiving
any tax and title reports and did not apply any further analytical
adjustments.

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 on all the loans in the pool. The third-party
due diligence described in Form 15E focused on a 100% regulatory
compliance review to ensure loans were originated in accordance
with predatory lending regulations. Additionally, 39.1% of the
loans also received a corresponding property valuation and credit
scope as well.

The diligence review presents a criteria variation given Fitch did
not receive an updated tax and title search on the population.
However, given the mitigating factors of the rep framework and
servicer monitoring delinquent taxes to maintain the first lien
position, Fitch is comfortable with not receiving any tax and title
reports, and did not apply any further analytical adjustments.
Overall, Fitch considered this information in its analysis and, as
a result, Fitch made the following adjustment to its analysis: a 5%
credit in its loss analysis. This adjustment resulted in a 17bp
reduction in Fitch's 'AAAsf' loss expectation.

ESG Considerations

SEMT 2024-HYB1 has an ESG Relevance Score of '4' for Exposure to
Environmental Impacts due to high geographic concentration risk,
which has a negative impact on the credit profile, and is relevant
to the ratings in conjunction with other factors.

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' means ESG
issues are credit-neutral or have only a minimal credit impact on
the entity, either due to their nature or the way in which they are
being managed by the entity. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.


SHACKLETON 2015-VII-R: Moody's Ups Rating on $26.5MM E Notes to Ba3
-------------------------------------------------------------------
Moody's Ratings has assigned ratings to four classes of CLO
refinancing notes (the "Refinancing Notes") issued by Shackleton
2015-VII-R CLO, Ltd. (the "Issuer").

Moody's rating action is as follows:

US$243,632,000 Class A-RR Senior Floating Rate Notes due 2031,
Assigned Aaa (sf)

US$56,200,000 Class B-RR Senior Floating Rate Notes due 2031,
Assigned Aaa (sf)

US$24,700,000 Class C-RR Mezzanine Deferrable Floating Rate Notes
due 2031, Assigned Aa2 (sf)

US$30,500,000 Class D-RR Mezzanine Deferrable Floating Rate Notes
due 2031, Assigned Baa1 (sf)

Additionally, Moody's have taken rating actions on the following
outstanding notes originally issued by the Issuer on July 16, 2018
(the "Original Closing Date"):

US$26,500,000 Class E Junior Deferrable Floating Rate Notes due
2031, Upgraded to Ba3 (sf); previously on September 11, 2020
Downgraded to B1 (sf)

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

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, including the expectation that the
notes will continue to be repaid given the end of the reinvestment
period in July 2023.

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.

Alcentra NY, LLC (the "Manager") will direct the selection,
acquisition and disposition of the assets on behalf of the Issuer
and may engage in trading activity, including discretionary
trading, during the transaction's remaining reinvestment period.

The Issuer previously issued two other classes of secured notes and
one class of subordinated notes, which will remain outstanding.

In addition to the issuance of the Refinancing Notes, a variety of
other changes to transaction features will occur in connection with
the refinancing. These include: extensions of the stated non-call
period.

No actions were taken on the 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: $402,795,552

Defaulted par: $5,818,127

Diversity Score: 69

Weighted Average Rating Factor (WARF): 2890

Weighted Average Spread (WAS) (before accounting for reference rate
floors): 3.48%

Weighted Average Recovery Rate (WARR): 47.60%

Weighted Average Life (WAL): 3.6 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 Underlying the Rating Action:

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

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

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


SHELTER GROWTH 2022-FL4: DBRS Confirms B(low) Rating on G Notes
---------------------------------------------------------------
DBRS Limited confirmed its credit ratings on all classes of notes
issued by Shelter Growth CRE 2022-FL4 Issuer Limited (SGCP
2022-FL4), as follows:

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

All trends are Stable.

The credit rating confirmations reflect the overall strength of the
transaction's credit profile, which benefits from the majority of
the underlying loans being backed by multifamily collateral, which
is facing some challenges in the current economic environment but
is generally well positioned to weather the downcycle as compared
with other property types such as office. There are some signs of
increased risk, however, for select loans. Morningstar DBRS has
concerns regarding the largest loan in the pool, City Club
Crossroads KC, which transferred to special servicing in January
2024 for maturity default (details below). In addition to the
unrated equity piece balance of $36.6 million, the transaction also
benefits from the Class F and Class G Notes, which have
below-investment-grade credit ratings assigned by Morningstar DBRS
and combine for another $44.2 million in cushion against loss for
the Notes with investment-grade credit ratings. In addition, since
Morningstar DBRS' previous credit rating action, four loans, with a
total cumulative balance of $71.8 million have successfully repaid
in full. In its analysis for this review, Morningstar DBRS
determined most individual borrowers are progressing with their
business plans to increase property cash flow and value; however,
select borrowers have encountered setbacks with contributing
factors including increased construction costs, slowed rent growth,
and increased debt service costs. These factors have led to
generally higher execution and refinance risks for those loans.
Where appropriate, Morningstar DBRS' analysis considered a stressed
scenario to reflect the higher risks and increase the expected
losses in the model. In conjunction with this press release,
Morningstar DBRS has published a Surveillance Performance Update
report with in-depth analysis and credit metrics for the
transaction as well as business plan updates on select loans.

The initial collateral consisted of 23 floating-rate mortgages
secured by 24 mostly transitional properties with a cut-off date
balance totaling $400.7 million. Most loans were in a period of
transition with plans to stabilize performance and improve values
of the underlying assets. As of the September 2024 remittance, the
pool comprised 17 loans secured by 18 properties with a cumulative
trust balance of $327.0 million. Since issuance, six loans with a
prior cumulative trust balance of $104.2 million have been
successfully repaid in full from the pool. The transaction is
static with no reinvestment period; however, the Issuer has the
right to use principal proceeds to acquire funded pari passu
companion participations subject to stated Acquisition Criteria
during the Permitted Funded Companion Participation Acquisition
period, which ended with the December 2023 payment date.

The transaction is concentrated by property type as 16 loans,
representing 87.5% of the current trust balance, are secured by
multifamily properties, with one loan secured by a mixed-use
property. The pool is primarily secured by properties in suburban
markets, with 11 loans, representing 53.2% of the pool, assigned a
Morningstar DBRS Market Rank of 3, 4, or 5. An additional four
loans, representing 30.8% of the pool, are secured by properties in
urban markets with a Morningstar DBRS Market Rank of 6, while two
loans, representing 16.0% of the pool, are secured by properties
with a Morningstar DBRS Market Rank of 1 or 2, denoting rural and
tertiary markets. The concentration of collateral in urban and
suburban markets is generally in line with the concentration levels
at issuance.

Leverage across the pool was generally stable to slightly elevated
as of the September 2024 reporting when compared with issuance
metrics. The current weighted-average (WA) as-is appraised
loan-to-value ratio (LTV) is 71.6%, with a current WA stabilized
LTV of 57.1%. In comparison, these figures were 72.3% and 65.7%,
respectively, at issuance. Given the age of some of the appraisals,
some of the appraiser's cap rates were considered to be low as
compared with the cap rate trends observed in the past few years
following the interest rate increases that began in the first half
of 2022. As such, in the analysis for this review, Morningstar DBRS
applied upward LTV adjustments in the analysis for nine loans,
representing 61.5% of the current trust balance.

Through September 2024, the lender had advanced cumulative loan
future funding of $36.3 million to 12 of the 18 outstanding
individual borrowers to aid in property stabilization efforts. The
largest advances have been made to the borrowers of the Phoenix
Huron Campus ($16.9 million) and Amalie Point & Greenbriar
Apartments ($4.3 million) loans. The Phoenix Huron Campus loan is
secured by a 3.1 million-sf mixed-use property consisting of 34
rentable buildings across 130 acres in Endicott, New York. The
collateral comprises 517,484 sf (17.0% of NRA) of office; 955,841
sf (31.0% of NRA) of industrial; and 1,582,532 sf (52.0% of NRA) of
flex space used for both manufacturing and warehousing. The
borrower's business plan is to complete a significant capital
expenditure (capex) program to improve the operational efficiency
and attractiveness of the property and to increase occupancy and
rental rates to market. According to the June 2024 rent roll, the
property was 68.0% occupied, a slight decline from 71.6% as of the
July 2023 rent roll. Beyond the funds advanced to date, Morningstar
DBRS received an update from the collateral manager noting that the
capital improvement plan has been completed and the borrower was
now working to lease vacant space using available future funds for
leasing costs. The Amalie Point & Greenbriar Apartments loan is
secured by a portfolio of two garden-style multifamily properties
totaling 169 units in Nashville, Tennessee. The borrower's business
plan is to increase rental rates to market levels by completing
unit renovations and exterior upgrades across both properties.
According to the collateral manager, the collateral was 90.0%
occupied as of June 2024 and the planned capex project was nearing
completion with just one unit left to be renovated.

An additional $9.5 million of future loan funding allocated to 13
of the outstanding individual borrowers remains available. The
largest portion of available funds ($3.9 million) is allocated to
the borrower of the largest loan, City Club Crossroads KC, which
has transferred to special servicing for imminent default with the
January 2024 reporting. The loan is secured by the borrower's
leasehold interest in a 283-unit multifamily property in downtown
Kansas City, Missouri. The unfunded future funding component is an
earnout advance the borrower may draw upon once per quarter,
subject to various performance tests. Through September 2024, there
have been no advances. The borrower's business plan is to lease up
the property to stabilized levels, and to increase rental rates to
market upon tenant renewals as concession loss burns off. According
to the June 2024 rent roll, the multifamily component was 56.0%
occupied while the commercial/retail component was 45.0% occupied.

As of the September 2024 remittance, the City Club Crossroads KC
loan was delinquent and due for the June 2024 loan payment and
there were four loans on the servicer's watchlist, representing
28.7% of the current trust balance, all of which are being
monitored for upcoming maturity risk. The largest of the four
loans, Phoenix Huron Campus, has an upcoming maturity date in
October 2024 with two 12-month extension options remaining. The
second largest loan, Residence at Lake Highlands, matures in
November 2024 with two 12-month extension options remaining.

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


SIERRA TIMESHARE 2024-3: Fitch Assigns 'BB-sf' Rating on D Notes
----------------------------------------------------------------
Fitch Ratings has assigned final ratings and Rating Outlooks to
notes issued by Sierra Timeshare 2024-3 Receivables Funding LLC
(2024-3).

   Entity/Debt           Rating             Prior
   -----------           ------             -----
Sierra Timeshare
2024-3 Receivables
Funding LLC

   A                 LT AAAsf  New Rating   AAA(EXP)sf
   B                 LT Asf    New Rating   A(EXP)sf
   C                 LT BBBsf  New Rating   BBB(EXP)sf
   D                 LT BB-sf  New Rating   BB-(EXP)sf

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 — Shifting
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, although 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%, 13.90% 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 8.99% per annum. Default
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: Fitch considers T+L to have 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 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
four notches 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 Assigns BB (sf) Rating on Cl. D Notes
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to Sierra Timeshare 2024-3
Receivables Funding LLC's (Sierra 2024-3) timeshare loan-backed
notes.

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

The transaction structure has been updated since the preliminary
ratings were published on Oct. 3, 2024. The subordination for the
class C tranche increased to 9.40% from 8.60%. As a result, the
initial hard credit enhancement for class C increased to 13.90%
from 13.10%. This includes the initial overcollateralization of
2.00% of the current collateral pool balance and a reserve account
that equals 2.50% of the initial pool balance represented by a
letter of credit. The overcollateralization, reserve account, and
ratings on the notes did not change.

  Coupons and credit enhancement

         Interest  Initial credit   Legal final
  Class  rate (%)  enhancement (i)  maturity date

  A      4.83         57.90         Aug. 20, 2041
  B      4.98         36.60         Aug. 20, 2041
  C      5.32         13.90         Aug. 20, 2041
  D      6.93          4.50         Aug. 20, 2041

(i)Includes the initial reserve account and overcollateralization,
as well as subordination for class A, B, and C.

The 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 73.30%, 57.68%, 41.21%, and 34.09% for the class
A, B, C, and D notes, respectively, based on our various stressed
cash flow scenarios. These levels are higher than the 3.21x, 2.44x,
1.79x, and 1.45x multiples of S&P's 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 its 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
ratings.

-- S&P's operational risk assessment of Wyndham Consumer Finance
Inc. 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 credit factors.

-- The transaction's payment and legal structures.

  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, $75.281 million: BBB (sf)
  Class D, $31.173 million: BB (sf)



SILVER ROCK I: S&P Assigns BB- (sf) Rating on Class E-RR Notes
--------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class X-RR, A-1-RR,
A-2-RR, B-RR, C-RR, D-RR, and E-RR replacement debt from Silver
Rock CLO I Ltd./Silver Rock CLO I LLC, a CLO managed by Silver Rock
Management LLC that was originally issued in November 2020 and
subsequently refinanced in November 2023. At the same time, S&P
withdrew its ratings on the 2023 class X-R, A-R, B-R, C-1-R, C-2-R,
D-R, and E-R debt following payment in full on the Oct. 21, 2024,
refinancing date.

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

-- The weighted average cost of debt of the replacement debt is
lower than the original debt.

-- The class X-RR debt will be paid down using interest proceeds
during the first seven payment dates, beginning with the January
2025 payment date.

-- The original class A-R debt was replaced by two classes of
floating-rate debt: A-1-RR and A-2-RR. Class A-1-RR is senior to
class A-2-RR.

-- The original class C-1-R and C-2-R debt was combined into the
class C-RR debt.

--The non-call period was extended two years to October 2026.

-- The reinvestment period and stated maturity was extended four
years to October 2029 and October 2037, respectively.

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

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

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

  Ratings Assigned

  Silver Rock CLO I Ltd./Silver Rock CLO I LLC

  Class X-RR, $3.500 million: AAA (sf)
  Class A-1-RR, $210.000 million: AAA (sf)
  Class A-2-RR, $10.500 million: AAA (sf)
  Class B-RR, $45.500 million: AA (sf)
  Class C-RR (deferrable), $21.000 million: A (sf)
  Class D-RR (deferrable), $21.000 million: BBB- (sf)
  Class E-RR (deferrable), $14.000 million: BB- (sf)

  Ratings Withdrawn

  Silver Rock CLO I Ltd./Silver Rock CLO I LLC

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

  Other Debt

  Silver Rock CLO I Ltd./Silver Rock CLO I LLC

  Subordinated notes, $30.1 million: NR

  NR--Not rated.



TOWD POINT 2024-4: Fitch Assigns 'B-(EXP)sf' Rating on Cl. B2 Notes
-------------------------------------------------------------------
Fitch Ratings has assigned expected ratings to Towd Point Mortgage
Trust 2024-4 (TPMT 2024-4).

   Entity/Debt       Rating           
   -----------       ------           
TPMT 2024-4

   A1A           LT AAA(EXP)sf  Expected Rating
   A1B           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
   B4            LT NR(EXP)sf   Expected Rating
   B5            LT NR(EXP)sf   Expected Rating
   A1            LT AAA(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

The TPMT 2024-4 transaction is expected to close on Oct. 30, 2024.
The notes are supported by 1,083 primarily seasoned performing
loans (SPLs) and reperforming loans (RPLs) with a total balance of
approximately $551 million, as of the statistical calculation
date.

Distributions of principal and interest (P&I) and loss allocations
are based on a traditional senior-subordinate sequential structure.
The sequential-pay structure locks out principal to the
subordinated notes until the most senior notes outstanding are paid
in full. The servicers will advance delinquent (DQ) monthly
payments of P&I for up to 150 days (under the Office of Thrift
Supervision method) or until deemed nonrecoverable.

KEY RATING DRIVERS

Updated Sustainable Home Prices (Negative): Due to its updated view
on sustainable home prices, Fitch views the home price values of
this pool as 9.4% above a long-term sustainable level (versus 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.

Seasoned Prime Credit Quality (Positive): The collateral consists
of 1,083 primarily seasoned performing first lien loans, totaling
$551 million and seasoned approximately 84 months in aggregate
(calculated as the difference between the origination date and the
run date). The pool is 98.9% current and 1.1% 30-59 days DQ. Over
the past two years, 94.2% of loans have been clean current.
Additionally, 0.8% of loans have a prior modification. The
borrowers have a very strong credit profile (769 Fitch model FICO
and 36% debt-to-income [DTI] ratio) and low leverage (50%
sustainable loan-to-value [sLTV] ratio). The pool consists of 86.9%
of loans where the borrower maintains a primary residence, while
13.1% are investment properties or a second home.

Low Leverage (Positive): The pool consists of loans with a weighted
average (WA) original combined LTV (CLTV) ratio of 66.9%. All loans
received updated property values, translating to a WA current
(mark-to-market) CLTV ratio of 44.8% after applicable haircuts
based on valuation type and an sLTV of 49.7% at the base case. This
reflects low-leverage borrowers and is stronger than in comparable
seasoned transactions.

Payment Shock (Negative): Approximately 68% of the pool loans are
vulnerable to a future payment shock, either as a result of
underlying adjustable-rate loans or loans currently in an
interest-only period (or both). As the adjustable-rate loans were
originated under low rates and given the current rate environment,
the reset could prove to be meaningful. The borrowers' credit
profile and very low leverage should mitigate potential defaults
arising from a payment shock; however, defaults were still
increased by 39% to account for this risk.

Limited Advancing (Mixed): The deal is structured to six months of
servicer advances for delinquent P&I. The limited advancing reduces
loss severities, as there is a lower amount repaid to the servicer
when a loan liquidates and liquidation proceeds are prioritized to
cover principal repayment over accrued but unpaid interest. The
downside to this is the additional stress on the structure side, as
there is limited liquidity in the event of large and extended
delinquencies.

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

Indemnification Clause (Mixed): U.S. Bank will act as the backstop
or remedy provider, indemnifying any losses resulting from
noncompliance with the ability-to-repay (ATR) standards for its
loans, which represents 80% of the pool by unpaid principal balance
(UPB). Fitch considers the indemnification provision robust enough
to address any ATR-related risks or losses, as detailed below.

U.S. Bank's ATR Representation states: "With respect to each U.S.
Bank Mortgage Loan originated on or after January 10, 2014, such
U.S. Bank Mortgage Loan complies with the "ability to repay"
standards as set forth in Section 1026.43(c) of Regulation Z."

If the U.S. Bank Remedy Provider receives notice of a claim or a
proposed settlement with respect to a U.S. Bank Mortgage Loan that
identifies a potential breach of the ATR Representation:

"…the U.S. Bank Remedy Provider will either repurchase such U.S.
Bank Mortgage Loan at the Repurchase Price or provide written
notice to the Issuer that the U.S. Bank Remedy Provider has
declined to repurchase such U.S. Bank Mortgage Loan, or (B) if the
U.S. Bank Remedy Provider has not repurchased such U.S. Bank
Mortgage Loan at the Repurchase Price, with respect to any losses
suffered by the Issuer as a result of a successful claim by the
underlying borrower that a U.S. Bank Mortgage Loan was in violation
of the ATR Rep, whether raised as a direct claim or a defense to
foreclosure, resulting in economic damages to the Issuer, pay an
amount (such amount, an "ATR Refund Amount") equal to the actual
losses or actual damages incurred by the Issuer as a result of the
successful claim or defense to foreclosure."

"In addition to the foregoing obligation, the U.S. Bank Remedy
Provider will be required to protect, indemnify, and hold harmless
the Issuer against any losses, liabilities, costs, damages,
penalties, fines, forfeitures, reasonable and necessary legal fees
and related costs, judgments, amounts paid in settlement (where the
U.S. Bank Remedy Provider consents in advance to such settlement)
and other costs and expenses resulting from any claim, demand,
defense or assertion based on or grounded upon, or arising from a
breach of the ATR Rep (solely with respect to the U.S. Bank
Mortgage Loans); provided, however, that in no event will the U.S.
Bank Remedy Provider be obligated to indemnify the Issuer to the
extent any such indemnified amounts result from (x) the gross
negligence or willful misconduct of the Issuer or (y) the Issuer's
failure to comply with the terms of the U.S. Bank MLPA, including
requirements of applicable law to the extent required by the U.S.
Bank MLPA."

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 MVDs at the national level. The
analysis assumes MVDs of 10.0%, 20.0% and 30.0% in addition to the
model projected 41.1% 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.

CRITERIA VARIATION

Fitch's analysis incorporated two criteria variations from its
"U.S. RMBS Rating Criteria" and "U.S. RMBS Loan Loss Criteria."

The first variation is that the due diligence sample size for the
transaction does not meet the minimum requirements as listed in
Fitch's criteria. Fitch expects a compliance review for the greater
of 200 loans or 10% sample if loans are sourced from a single
originator. Of the U.S. Bank-originated loans, which represent 80%
of the pool by UPB, only 77 loans, or 11% by loan count (10% by
UPB), received a compliance review. While the current sample is in
line on a percentage basis, it does not meet the minimum loan
count. This pool is part of a larger cohort being securitized in
pieces. Fitch was provided access to the entire diligence sample,
which covered roughly 10%, or 656 loans. Fitch relied on the larger
population sample, which had no material differences compared to
this pool, to mitigate the lower total number of loans reviewed for
this transaction. Additionally, the ATR rep for these loans is
being provided by U.S. Bank, and any potential breaches of the rep
will result in a repurchase, indemnification or cure by U.S. Bank.
This variation had no rating impact.

The second variation relates to the application of lower loss
severity floors than those described in Fitch's criteria. This pool
benefits from a material amount of equity buildup. Even after a 41%
home price decline environment (AAAsf rating case), the stressed
sLTV is only 76.8%. Additionally, the pool's sLTV of 49.7% is below
the RPL industry average. Fitch believes that applying a 30% loss
severity floor in this situation is highly punitive and considers a
20% loss severity floor at 'AAAsf' provides additional downside
protection in the event of idiosyncratic events while
differentiating this pool from other pools with much higher sLTVs.
This treatment resulted in a rating of approximately one notch
higher for each class.

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by AMC, Opus and Westcor. A third-party due diligence was
performed on approximately 27% of the pool by loan count by AMC and
Opus, both assessed as 'Acceptable' third-party review (TPR) firms
by Fitch. The scope primarily focused on a regulatory compliance
review to ensure loans were originated in accordance with predatory
lending regulations. Additionally, Westcor completed a tax and
title review on 100% of the loans.

While the review was substantially similar to Fitch criteria with
respect to RPL transactions, the sample size yielded minor
variations to the criteria as indicated above. Fitch considered
this information in its analysis, which is reflected in the 'AAAsf'
expected loss of 4.50%.

ESG Considerations

TPMT 2024-4 has an ESG Relevance Score of '4' for Exposure to
Environmental Impacts due to high geographic concentration leading
to increased risk of catastrophe exposure, which has a negative
impact on the credit profile, and is relevant to the ratings in
conjunction with other factors.

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' means ESG
issues are credit-neutral or have only a minimal credit impact on
the entity, either due to their nature or the way in which they are
being managed by the entity. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.


TRESTLES CLO III: Fitch Assigns 'BB-sf' Rating on Class E-R Notes
-----------------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to the
Trestles CLO III, Ltd. reset transaction.

   Entity/Debt          Rating               Prior
   -----------          ------               -----
Trestles CLO III,
Ltd.

   A-1 89532TAA4     LT  PIFsf  Paid In Full   AAAsf
   A-1R              LT  AAAsf  New Rating
   A-2 89532TAC0     LT  PIFsf  Paid In Full   AAAsf
   A-2R              LT  AAAsf  New Rating
   B-1R              LT  AAsf   New Rating
   B-2R              LT  AAsf   New Rating
   C-R               LT  Asf    New Rating
   D-1R              LT  BBB-sf New Rating
   D-2R              LT  BBB-sf New Rating
   E-R               LT  BB-sf  New Rating
   X                 LT  AAAsf  New Rating

Transaction Summary

Trestles CLO III, Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that is managed by Aristotle
Pacific Capital, LLC. The original transaction was rated by Fitch
and closed in February 2020. The CLO's existing notes will be
refinanced in whole on Oct. 21, 2024 from proceeds of the new
secured notes. Net proceeds from the issuance of the secured and
subordinated notes, along with the existing subordinated notes,
will provide financing on a portfolio of approximately $395 million
(excluding defaults) 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 24.56, versus a maximum covenant, in
accordance with the initial expected matrix point of 28. 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
98.89% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 75.48% versus a
minimum covenant, in accordance with the initial expected matrix
point of 73.9%.

Portfolio Composition (Positive): The largest three industries may
comprise up to 41% of the portfolio balance in aggregate while the
top five obligors can represent up to 11.5% 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 'BBBsf' and 'AA+sf' for class A-1R, between
'BBB-sf' and 'AA+sf' for class A-2R, between 'BBsf' and 'A+sf' for
pari-passu classes B-1R and B-2R, 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, 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-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 pari-passu classes B1-R and B2-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 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 Trestles CLO III,
Ltd. In cases where Fitch does not provide ESG relevance scores in
connection with the credit rating of a transaction, programme,
instrument or issuer, Fitch will disclose in the key rating drivers
any ESG factor which has a significant impact on the rating on an
individual basis.


TRICOLOR AUTO 2024-3: Moody's Assigns B2 Rating to Class F Notes
----------------------------------------------------------------
Moody's Ratings has assigned definitive ratings to the notes issued
by Tricolor Auto Securitization Trust 2024-3 (TAST 2024-3). This is
the third auto loan transaction of the year and the fourth rated by
us for Tricolor Auto Acceptance, LLC (Tricolor). The notes are
backed by a pool of retail automobile loan contracts originated by
affiliates of Tricolor, who is also the servicer and administrator
for the transaction.
   
The complete rating actions are as follows:

Issuer: Tricolor Auto Securitization Trust 2024-3

Class A Asset Backed Notes, Definitive Rating Assigned A1 (sf)

Class B Asset Backed Notes, Definitive Rating Assigned A1 (sf)

Class C Asset Backed Notes, Definitive Rating Assigned A2 (sf)

Class D Asset Backed Notes, Definitive Rating Assigned Baa1 (sf)

Class E Asset Backed Notes, Definitive Rating Assigned Ba1 (sf)

Class F Asset Backed Notes, Definitive Rating Assigned B2 (sf)

RATINGS RATIONALE

The ratings are based on the quality of the underlying collateral
and its expected performance, the strength of the capital
structure, the experience and expertise of Tricolor as the servicer
and administrator and the presence of Vervent, Inc. as named backup
servicer.

The definitive rating for the Class E notes, Ba1 (sf), is one notch
higher than its provisional rating, (P)Ba2 (sf). The difference is
a result of the transaction closing with a lower weighted average
cost of funds (WAC) than Moody's modeled when the provisional
ratings were assigned. The WAC assumptions and other structural
features were provided by the issuer.

Moody's median cumulative net loss expectation for the 2024-3 pool
is 21%, which is 1.50% lower than 2024-2.  This decrease in net
loss expectation was driven primarily by improving performance in
the issuer's recent managed portfolio origination vintages, and
early signs of improving performance in recently issued ABS
transactions.  The loss at a Aaa stress is 54.00%, which is
unchanged from 2024-2. Moody's based Moody's cumulative net loss
expectation and loss at a Aaa stress on an analysis of the credit
quality of the underlying collateral; the historical performance of
similar collateral, including securitization performance and
managed portfolio performance; the ability of Tricolor to perform
the servicing functions; and current expectations for the
macroeconomic environment during the life of the transaction.

At closing, the Class A notes, Class B notes, Class C notes, Class
D notes, Class E notes and Class F notes benefit from 50.85%,
46.45%, 42.05%, 35.45%, 28.10% and 20.50% of hard credit
enhancement respectively. Hard credit enhancement for the notes
consists of a combination of overcollateralization, a non-declining
reserve account and subordination, except for the Class F notes
which do not benefit from subordination. The notes may also benefit
from excess spread.

This securitization's governance risk is moderate and is higher
than other Auto ABS in the market. The governance risks are
partially mitigated by the transaction structure, documentation and
characteristics of the transaction parties. The sponsor and
servicer is relatively small and financially weak, which
corresponds to higher servicing transfer risk and which lends
additional variability to the pool's expected loss.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Auto Loan- and Lease-Backed ABS" published in
August 2024.

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

Up

Moody's could upgrade the notes if levels of credit enhancement are
higher than necessary to protect investors against current
expectations of portfolio losses. 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 vehicles securing an
obligor's promise of payment. Portfolio losses also depend greatly
on the US job market and the market for used vehicles. Other
reasons for better-than-expected performance include changes to
servicing practices that enhance collections or refinancing
opportunities that result in prepayments.

Down

Moody's could downgrade the notes if, given current expectations of
portfolio losses, levels of credit enhancement are consistent with
lower ratings. Credit enhancement could decline if excess spread is
not sufficient to cover losses in a given month. Moody's
expectation of pool losses could rise as a result of a higher
number of obligor defaults or deterioration in the value of the
vehicles securing an obligor's promise of payment. Portfolio losses
also depend greatly on the US job market, the market for used
vehicles, and poor servicing. Other reasons for worse-than-expected
performance include error on the part of transaction parties,
inadequate transaction governance, and fraud.


TRIMARAN CAVU 2022-1: S&P Assigns BB-(sf) Rating on Cl. E-R Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-R, B-R, C-R,
D-1-R, D-2-R, and E-R replacement debt from Trimaran CAVU 2022-1
Ltd./Trimaran CAVU 2022-1 LLC, a CLO originally issued in October
2022 that is managed by Trimaran Advisors LLC, an affiliate of
LibreMax Capital. At the same time, S&P withdrew its ratings on the
original class A, B-1, B-2, C, D, and E debt following payment in
full on the Oct. 22, 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:

-- Class D was replaced with the sequential classes D-1-R and
D-2-R, which are floating-rate and fixed-rate, respectively.

-- The stated maturity was extended to October 2037, and the
reinvestment period was extended to October 2029.

-- The non-call period was extended to October 2026.

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

  Trimaran CAVU 2022-1 Ltd./Trimaran CAVU 2022-1 LLC

  Class A-R, $248 million: AAA (sf)
  Class B-R, $56 million: AA (sf)
  Class C-R (deferrable), $24 million: A (sf)
  Class D-1-R (deferrable), $24 million: BBB- (sf)
  Class D-2-R (deferrable), $4 million: BBB- (sf)
  Class E-R (deferrable), $12 million: BB- (sf)

  Ratings Withdrawn

  Trimaran CAVU 2022-1 Ltd./Trimaran CAVU 2022-1 LLC

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

  Other Outstanding Debt

  Trimaran CAVU 2022-1 Ltd./Trimaran CAVU 2022-1 LLC

  Subordinated notes, $38 million: Not rated



TRIMARAN CAVU 2022-1: S&P Assigns Prelim 'BB-' Rating on E-R Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the class
A-R, B-R, C-R, D-1-R, D-2-R, and E-R replacement debt from Trimaran
CAVU 2022-1 Ltd./Trimaran CAVU 2022-1 LLC, a CLO originally issued
in October 2022 that is managed by Trimaran Advisors LLC, an
affiliate of LibreMax Capital.

The preliminary ratings are based on information as of Oct. 18,
2024. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the Oct. 22, 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:

-- Class D will be replaced with the sequential classes D-1-R and
D-2-R, which are expected to be floating-rate and fixed-rate,
respectively.

-- The stated maturity will be extended to October 2037, and the
reinvestment period will be extended to October 2029.

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

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

  Trimaran CAVU 2022-1 Ltd./Trimaran CAVU 2022-1 LLC

  Class A-R, $248 million: AAA (sf)
  Class B-R, $56 million: AA (sf)
  Class C-R (deferrable), $24 million: A (sf)
  Class D-1-R (deferrable), $24 million: BBB- (sf)
  Class D-2-R (deferrable), $4 million: BBB- (sf)
  Class E-R (deferrable), $12 million: BB- (sf)

  Other Outstanding Debt

  Trimaran CAVU 2022-1 Ltd./Trimaran CAVU 2022-1 LLC

  Subordinated notes, $38 million: Not rated



VELOCITY COMMERCIAL 2024-5: DBRS Gives Prov. B Rating on 3 Tranches
-------------------------------------------------------------------
DBRS, Inc. assigned provisional credit ratings to the
Mortgage-Backed Certificates, Series 2024-5 (the Certificates) to
be issued by Velocity Commercial Capital Loan Trust 2024-5 (VCC
2024-5 or the Issuer) as follows:

-- $199.6 million Class A at (P) AAA (sf)
-- $17.4 million Class M-1 at (P) AA (Low) (sf)
-- $18.8 million Class M-2 at (P) A (Low) (sf)
-- $33.2 million Class M-3 at (P) BBB (low) (sf)
-- $17.1 million Class M-4 at (P) BB (sf)
-- $6.8 million Class M-5 at (P) B (high) (sf)
-- $3.8 million Class M-6 at (P) B (sf)
-- $199.6 million Class A-S at (P) AAA (sf)
-- $199.6 million Class A-IO at (P) AAA (sf)
-- $17.4 million Class M1-A at (P) AA (Low) (sf)
-- $17.4 million Class M1-IO at (P) AA (Low) (sf)
-- $18.8 million Class M2-A at (P) A (Low) (sf)
-- $18.8 million Class M2-IO at (P) A (Low) (sf)
-- $33.2 million Class M3-A at (P) BBB (low) (sf)
-- $33.2 million Class M3-IO at (P) BBB (low) (sf)
-- $17.1 million Class M4-A at (P) BB (sf)
-- $17.1 million Class M4-IO at (P) BB (sf)
-- $6.8 million Class M5-A at (P) B (high) (sf)
-- $6.8 million Class M5-IO at (P) B (high) (sf)
-- $3.8 million Class M6-A at (P) B (sf)
-- $3.8 million Class M6-IO at (P) B (sf)

Classes A-IO, M1-IO, M2-IO, M3-IO, M4-IO, M5-IO, and M6-IO are
interest-only (IO) certificates. The class balances represent
notional amounts.

Classes A, M-1, M-2, M-3, M-4, M-5, and M-6 are exchangeable
certificates. These classes can be exchanged for combinations of
initial exchangeable certificates as specified in the offering
documents.

The (P) AAA (sf) credit ratings on the Certificates reflect 33.55%
of credit enhancement (CE) provided by subordinated certificates.
The (P) AA (low) (sf), (P) A (low) (sf), (P) BBB (low) (sf), (P) BB
(sf), (P) B (high) (sf), and (P) B (sf) credit ratings reflect
27.75%, 21.50%, 10.45%, 4.75%, 2.50%, and 1.25% of CE,
respectively.

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

Morningstar DBRS assigned provisional credit ratings to VCC 2024-5,
a securitization of a portfolio of newly originated and seasoned
fixed- and adjustable-rate, first-lien residential mortgages
collateralized by investor properties with one to four units
(residential investor loans), and small-balance commercial
mortgages (SBC) collateralized by various types of commercial,
multifamily rental, and mixed-use properties. Four of these loans
were originated through the U.S. SBA 504 loan program, and are
backed by first-lien, owner- occupied, commercial real estate. The
securitization is funded by the issuance of the Certificates. The
transaction includes 154 seasoned loans (17.0% of the pool) from
the prior VCC 2020-2 and VCC 2016-1 transactions. The Certificates
are backed by 832 mortgage loans with a total principal balance of
$300,390,172 as of the Cut-Off Date (September 1, 2024).

Approximately 54.3% of the pool comprises residential investor
loans, about 44.1% are traditional SBC loans, and about 1.6% are
the SBA 504 loans mentioned above. Most of the loans in this
securitization (93.9%) were originated by Velocity Commercial
Capital, LLC (Velocity or VCC). Fifteen loans (6.1% of the pool)
were originated by New Day Commercial Capital, LLC, a wholly owned
subsidiary of Velocity Commercial Capital, LLC, which in turn is
wholly owned by Velocity Financial, Inc.

The loans were generally underwritten to program guidelines for
business-purpose loans where the lender generally expects the
property (or its value) to be the primary source of repayment (with
the exception being the four SBA 504 loans that, per SBA
guidelines, were underwritten to the small business cash flows
rather than to the property value). For all of the New
Day-originated loans, underwriting was based on business cash
flows, but loans were secured by real estate. For the SBC and
residential investor loans, the lender reviews the mortgagor's
credit profile although it does not rely on the borrower's income
to make its credit decision. However, the lender considers the
property-level cash flows or minimum debt service coverage ratio
(DSCR) in underwriting SBC loans with balances of more than
$750,000 for purchase transactions and more than $500,000 for
refinance transactions. Because the loans were made to investors
for business purposes, they are exempt from the Consumer Financial
Protection Bureau's Ability-to-Repay rules and TILA-RESPA
Integrated Disclosure rule.

On January 5, 2024, a suit was filed in the U.S. District Court for
the Central District of California by Harvest Small Business
Finance, LLC and Harvest Commercial Capital, LLC against certain
employees of New Day Business Finance LLC and Velocity Commercial
Capital, LLC d/b/a New Day Commercial Capital, LLC (New Day)
alleging violations of the Defend Trade Secrets Act, the California
Uniform Trade Secrets Act and the California Unfair Competition
Law. New Day has indicated that it does not believe that this suit
is material.

PHH Mortgage Corporation (PMC) will service all loans in the pool
for a servicing fee of 0.30% per annum. New Day will act as
subservicer for the 15 New Day-originated loans (including the four
SBA 504 loans), and PHH will act as the Backup Servicer for these
loans. In the event that New Day fails to service these loans in
accordance with the related subservicing agreement, PHH will
terminate the subservicing agreement and commence directly
servicing such mortgage loans within 30 days. In addition, Velocity
will act as a Special Servicer servicing the loans that defaulted
or became 60 or more days delinquent under the Mortgage Bankers
Association (MBA) method and other loans, as defined in the
transaction documents (Specially Serviced Mortgage Loans). The
Special Servicer will be entitled to receive compensation based on
an annual fee of 0.75% and the balance of Specially Serviced Loans.
Also, the Special Servicer is entitled to a liquidation fee equal
to 2.00% of the net proceeds from the liquidation of a Specially
Serviced Mortgage Loan, as described in the transaction documents.

The Servicer will fund advances of delinquent principal and
interest (P&I) until the advances are deemed unrecoverable. Also,
the Servicer is obligated to make advances with respect to taxes,
insurance premiums, and reasonable costs incurred in the course of
servicing and disposing properties.

U.S. Bank National Association (U.S. Bank; rated AA with a Stable
trend by Morningstar DBRS) will act as the Custodian. U.S. Bank
Trust Company, National Association will act as the Trustee.

The Seller, directly or indirectly through a majority-owned
affiliate, is expected to retain an eligible horizontal residual
interest consisting of the Class XS Certificates, collectively
representing at least 5% of the fair value of all Certificates, to
satisfy the credit risk-retention requirements under Section 15G of
the Securities Exchange Act of 1934 and the regulations promulgated
thereunder. Such retention aligns Sponsor and investor interest in
the capital structure.

On or after the later of (1) the three-year anniversary of the
Closing Date or (2) the date when the aggregate stated principal
balance of the mortgage loans is reduced to 30% of the Closing Date
balance, the Depositor may purchase all outstanding Certificates
(Optional Purchase) at a price equal to the sum of the remaining
aggregate balance of the Certificates plus accrued and unpaid
interest, and any fees, expenses, and indemnity payments due and
unpaid to the transaction parties, including any unreimbursed P&I
and servicing advances, and other amounts due as applicable. The
Optional Purchase will be conducted concurrently with a qualified
liquidation of the Issuer.

Additionally, if on any date on which the unpaid mortgage loan
balance and the value of real estate owned (REO) properties has
declined to less than 10% of the initial mortgage loan balance as
of the Cut-off Date, the Directing Holder, the Special Servicer, or
the Servicer, in that order of priority, may purchase all of the
mortgages, REO properties, and any other properties from the Issuer
(Optional Termination) at a price specified in the transaction
documents. The Optional Termination will be conducted as a
qualified liquidation of the Issuer. The Directing Holder
(initially, the Seller) is the representative selected by the
holders of more than 50% of the Class XS certificates (the
Controlling Class).

The transaction uses a structure sometimes referred to as a
modified pro rata structure. Prior to the Class A CE falling below
10.0% of the loan balance as of the Cut-off Date (Class A Minimum
CE Event), the principal distributions allow for amortization of
all senior and subordinate bonds based on CE targets set at
different levels for performing (same CE as at issuance) and
nonperforming (higher CE than at issuance) loans. The target
principal balance of each class is determined based on the CE
targets and the performing and nonperforming (i.e., those that are
90 or more days MBA delinquent, in foreclosure and REO, and subject
to a servicing modification within the prior 12 months) loan
amounts. As such, the principal payments are paid on a pro rata
basis, up to the target principal balance of each class, so long as
no loans in the pool are nonperforming. If the share of
nonperforming loans grows, the corresponding CE target increases.
Thus, the principal payment amount increases for the senior and
senior subordinate classes and falls for the more subordinate
bonds. The goal is to distribute the appropriate amount of
principal to the senior and subordinate bonds each month, to always
maintain the desired level of CE, based on the performing and
nonperforming pool percentages. After the Class A Minimum CE Event,
the principal distributions are made sequentially.

Relative to the sequential pay structure, the modified pro rata
structure is more sensitive to the timing of the projected defaults
and losses as the losses may be applied at a time when the amount
of credit support is reduced as the principal balances of the bonds
amortize over the life of the transaction. That said, the excess
spread can be used to cover realized losses after being allocated
to the unpaid net weighted-average coupon shortfalls (Net WAC Rate
Carryover Amounts). VCC 2024-5, in contrast to the prior VCC
securitizations, will also allocate certain excess spread amounts
(after first paying Net Wac Rate Carryover Amounts and before
covering realized losses) as principal in every period, when
available. In prior transactions, this feature was not incorporated
after the occurrence of a Class A Minimum Credit Enhancement Event.
Please see the Cash Flow Structure and Features section of the
report for more details.

COMMERCIAL MORTGAGE-BACKED SECURITIES (CMBS) METHODOLOGY - SMALL
BALANCE COMMERCIAL (SBC) LOANS

The collateral for the SBC portion of the pool consists of 278
individual loans secured by 278 commercial and multifamily
properties with an average cut-off date balance of $476,115. None
of the mortgage loans is cross-collateralized or cross-defaulted
with each other. Given the complexity of the structure and
granularity of the pool, Morningstar DBRS applied its "North
American CMBS Multi-Borrower Rating Methodology."

The CMBS loans have a weighted-average (WA) fixed-interest rate of
10.7%. This is approximately 70 basis points (bps) lower than the
VCC 2024-4 transaction, 100 bps lower than the VCC 2024-3
transaction, and 90 bps lower than the VCC 2024-2 and VCC 2024-1
transactions. While the overall interest rate is still relatively
elevated, highlighting the increase in interest rates over the last
few years, the reduced rate relative to the other 2024 transactions
reflects the lower interest rates of the loans originated between
2015 and 2020. Most of the loans in this transaction have original
term lengths of 30 years and fully amortize over 30-year schedules.
However, five loans, which represent 2.1% of the SBC pool, have an
initial IO period of 60 or 120 months.

All of the SBC loans were originated between October 2015 and
August 2024 (100.0% of the cut-off pool balance), resulting in a WA
seasoning of 13.5 months. The SBC pool has a WA original term
length of 360 months, or approximately 30 years. Based on the
current loan amount, which reflects 30 bps of amortization, and the
current appraised values, the SBC pool has a WA loan-to-value ratio
(LTV) of 59.0%. However, Morningstar DBRS made LTV adjustments to
31 loans that had an implied capitalization rate more than 200 bps
lower than the set of minimal capitalization rates established by
the Morningstar DBRS Market Rank. The Morningstar DBRS minimum
capitalization rates range from 5.0% for properties in Market Rank
8 to 8.0% for properties in Market Rank 1. This resulted in a
higher Morningstar DBRS LTV of 63.2%. Lastly, all loans fully
amortize over their respective remaining terms, resulting in 100%
expected amortization; this amount of amortization is greater than
what is typical for CMBS conduit pools. Morningstar DBRS' research
indicates that, for CMBS conduit transactions securitized between
2000 and 2021, average amortization by year has ranged between 6.5%
and 22.0%, with a median rate of 16.5%.

As contemplated and explained in Morningstar DBRS' "Rating North
American CMBS Interest-Only Certificates" methodology, the most
significant risk to an IO cash flow stream is term default risk. As
Morningstar DBRS notes in the methodology, for a pool of
approximately 63,000 CMBS loans that had fully cycled through to
their maturity defaults, the average total default rate across all
property types was approximately 17%, the refinance default rate
was 6% (approximately one-third of the total default rate), and the
term default rate was approximately 11%. Morningstar DBRS
recognizes the muted impact of refinance risk on IO certificates by
notching the IO rating up by one notch from the Reference
Obligation rating. When using the 10-year Idealized Default Table
default probability to derive a probability of default (POD) for a
CMBS bond from its rating, Morningstar DBRS estimates that, in
general, a one-third reduction in the CMBS Reference Obligation POD
maps to a tranche rating that is approximately one notch higher
than the Reference Obligation or the Applicable Reference
Obligation, whichever is appropriate. Therefore, similar logic
regarding term default risk supports the rationale for Morningstar
DBRS to reduce the POD in the CMBS Insight Model by one notch
because refinance risk is largely absent for this SBC pool of
loans.

The Morningstar DBRS CMBS Insight Model does not contemplate the
ability to prepay loans, which is generally seen as credit positive
because a prepaid loan cannot default. The CMBS predictive model
was calibrated using loans that have prepayment lockout features.
The historical prepayment performance of those loans is close to a
0% conditional prepayment rate. If the CMBS predictive model had an
expectation of prepayments, Morningstar DBRS would expect the
default levels to be reduced. Any loan that prepays is removed from
the pool and can no longer default. In previous VCC transactions,
Morningstar DBRS applied a 5.0% reduction to the cumulative default
assumptions to provide credit for expected payments. The assumption
reflects Morningstar DBRS' opinion that, in a rising interest-rate
environment, fewer borrowers may elect to prepay their loans. The
VCC 2024-5 transaction featured 77 seasoned loans (23.9% of the SBC
pool) from the prior VCC 2020-2 and VCC 2016-1 transactions.
Because of the larger concentration of seasoned loans that did not
elect to prepay, Morningstar DBRS elected to remove the 5.0%
reduction to the cumulative default assumptions to provide credit
for expected payments.

As a result of higher interest rates and lending spreads, the SBC
pool has had a significant increase in interest rates compared with
prior VCC transactions. Consequently, approximately 55.3% of the
deal has an Issuer net operating income DSCR of less than 1.0 times
(x), which is in line with VCC transactions in 2024 but represents
a larger composition than previous VCC transactions in 2023 and
2022. Although the Morningstar DBRS CMBS Insight Model does not
contemplate FICO scores, the WA FICO score for the SBC loans is
720, which is relatively similar to FICO scores in prior
transactions. With regard to these concerns, Morningstar DBRS
applied a 5.0% penalty to the fully adjusted cumulative default
assumptions to account for risks given these factors.

The SBC pool is quite diverse, based on loan count and size, with
an average cut-off date balance of $476,115, a concentration
profile equivalent to that of a transaction of 140 equal-size
loans, and a top 10 loan concentration of 17.6%. Increased pool
diversity helps insulate the higher-rated classes from event risk.

The loans are mostly secured by traditional property types (i.e.,
multifamily, retail, office, and industrial).

All loans in the SBC pool fully amortize over their respective
remaining loan terms, reducing refinance risk.

As classified by Morningstar DBRS for modeling purposes, the SBC
pool contains a significant exposure to retail (22.7% of the SBC
pool) and office (17.4% of the SBC pool), which are two of the
higher-volatility asset types. Loans counted as retail include
those identified as automotive and potentially as commercial
condominium. Combined, retail and office properties represent 40.1%
of the SBC pool balance. Morningstar DBRS applied a -21.1%
reduction to the net cash flow (NCF) for retail properties and a
-35.9% reduction to the NCF for office assets in the SBC pool,
which is above the average NCF reduction applied to comparable
property types in CMBS analyzed deals.

Morningstar DBRS did not perform site inspections on loans within
its sample for this transaction. Instead, Morningstar DBRS relied
upon analysis of third-party reports and online searches to
determine property quality assessments. Of the 80 loans Morningstar
DBRS sampled, 14 were of Average quality (21.4%), 39 were of
Average- quality (41.2%), 24 were of Below Average quality (34.8%),
and three were of Poor quality (2.6%). Morningstar DBRS assumed the
unsampled loans were of Average- quality, which has a slightly
increased POD level. This is consistent with the assessments of
sampled loans and other SBC transactions rated by Morningstar
DBRS.

Limited property-level information was available for Morningstar
DBRS to review. Asset summary reports, property condition reports ,
Phase I/II environmental site assessment (ESA) reports, and
historical cash flows were generally not available for review in
conjunction with this securitization. Morningstar DBRS received and
reviewed appraisals for sampled loans for the top 29 of the pool,
which represent 34.0% of the SBC pool balance. These appraisals
were issued between September 2019 and July 2024 when the
respective loans were originated. Morningstar DBRS was able to
perform a loan-level cash flow analysis on the top 29 loans in the
pool. The NCF haircuts to these loans ranged from -4.8% to -100.0%,
with an average of -19.8% when excluding outliers; however,
Morningstar DBRS generally applied more conservative haircuts on
the unsampled loans. No ESA reports were provided nor required by
the Issuer; however, all of the loans have an environmental
insurance policy that provides coverage to the Issuer and the
securitization trust in the event of a claim. No probable maximum
loss information or earthquake insurance requirements are provided.
Therefore, a loss severity given default penalty was applied to all
properties in California to mitigate this potential risk.

Morningstar DBRS received limited borrower information, net worth
or liquidity information, and credit histories. Additionally, the
WA interest rate of the deal is 10.7%, which is indicative of the
broader increased interest-rate environment and represents a large
increase over VCC deals in 2022 and early 2023. Morningstar DBRS
generally initially assumed loans had Weak sponsorship scores,
which increases the stress on the default rate. The initial
assumption of Weak sponsorship reflects the generally less
sophisticated nature of small balance borrowers and assessments
from past small balance transactions rated by Morningstar DBRS.
Furthermore, Morningstar DBRS received a 12-month pay history on
each loan through September 12, 2024. If any loan had more than two
late pays within this period or was currently 30 days past due,
Morningstar DBRS applied an additional stress to the default rate.
This occurred with 23 loans, representing 6.2% of the SBC pool
balance.

SBA 504 LOANS

The transaction includes four SBA 504 loans, totaling approximately
$4.9 million or 1.6% of the aggregate 2024-5 collateral pool. These
are owner-occupied, first-lien, commercial real estate-backed
loans, originated via the U.S. Small Business Administration's 504
loan program (SBA 504) in conjunction with community development
companies, made to small businesses, with the stated goal of
community economic development.

The SBA 504 loans are fixed rate with 360-month original terms and
are fully amortizing. The loans were originated between June 24,
2024, and August 13, 2024, via New Day, which will also act as
subservicer of the loans. The total outstanding principal balance
as of the Cut-Off Date is approximately $4.9 million, with an
average balance of $ 1,220,113. The WA interest rate is 10.05%. The
loans are subject to prepayment penalties of 5%,4%, 3%, 2%, and 1%
respectively in the first five years from origination. These loans
are for properties that are owner-occupied by the small business
owner. The WA LTV is 50.91%, the WA DSCR is 1.26x, and the WA FICO
score of this sub-pool is 674.

For these loans, Morningstar DBRS applied its "Rating U.S.
Structured Finance Transactions" methodology, Small Business
Appendix (XVIII). As there is limited historical information about
the originator, Morningstar DBRS used proxy data from the publicly
available SBA data set, which contains several decades of
performance data, stratified by industry categories of the small
business operators to derive an expected default rate. Recovery
assumptions were derived from the Morningstar DBRS CMBS data set of
loss given default stratified by property type, LTV, and market
rank. These were input into Morningstar DBRS' proprietary model,
the Morningstar DBRS CLO Insight Model, which uses a Monte Carlo
process to generate stressed loss rates corresponding to a specific
rating level.

RESIDENTIAL MORTGAGE-BACKED SECURITIES (RMBS) METHODOLOGY

The collateral pool consists of 550 mortgage loans with a total
balance of approximately $163.1 million collateralized by one- to
four-unit investment properties. Velocity underwrote the mortgage
loans to the No Ratio program guidelines for business-purpose
loans.

The transaction assumptions consider Morningstar DBRS' baseline
macroeconomic scenarios for rated sovereign economies, available in
its commentary "Baseline Macroeconomic Scenarios for Rated
Sovereigns September 2024 Update," published on September 25, 2024.
These baseline macroeconomic scenarios replace Morningstar DBRS'
moderate and adverse COVID-19 pandemic scenarios, which were first
published in April 2020.

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


VENTURE 46: Fitch Assigns 'BB-sf' Rating on Class ER Notes
----------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to Venture
46 CLO, Limited reset transaction.

   Entity/Debt          Rating               Prior
   -----------          ------               -----
Venture 46 CLO, Limited

   A-1F 92326CAE7   LT  PIFsf   Paid In Full   AAAsf
   A-1N 92326CAC1   LT  PIFsf   Paid In Full   AAAsf
   A1R              LT  AAAsf   New Rating
   A2R              LT  AAAsf   New Rating
   BR               LT  AAsf    New Rating
   C1R              LT  A+sf    New Rating
   C2R              LT  Asf     New Rating
   D1 92326CAU1     LT  PIFsf   Paid In Full   BBB+sf
   D1AR             LT  BBBsf   New Rating
   D1FR             LT  BBBsf   New Rating
   D2 92326CAS6     LT  PIFsf   Paid In Full   BBBsf
   D2R              LT  BBB-sf  New Rating
   ER               LT  BB-sf   New Rating
   X 92326CAA5      LT  PIFsf   Paid In Full   AAAsf
   XR               LT  NRsf    New Rating

Transaction Summary

Venture 46 CLO, Limited (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that is managed by MJX Venture
Management II LLC. The original transaction was rated by Fitch and
closed in July 2022. The CLO's existing secured notes will be
refinanced in whole on Oct. 21, 2024 from proceeds of the new
secured notes. Net proceeds from the refinanced notes and existing
subordinated notes will provide financing on a portfolio of
approximately $302.5 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 22.73 versus a maximum covenant, in
accordance with the initial expected matrix point of 23. 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
100% first-lien senior secured loans. The weighted average recovery
rate (WARR) of the indicative portfolio is 75.33% versus a minimum
covenant, in accordance with the initial expected matrix point of
64.75%.

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 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 'A-sf' and 'AA+sf' for class A1R, between
'BBB+sf' and 'AA+sf' for class A2R, between 'BBB-sf' and 'A+sf' for
class BR, between 'BBsf' and 'A-sf' for class C1R, between 'BB-sf'
and 'BBB+sf' for class C2R, between less than 'B-sf' and 'BB+sf'
for class D1R, between less than 'B-sf' and 'BB+sf' for class D2R,
and between less than 'B-sf' and 'B+sf' for class ER.

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

Upgrade scenarios are not applicable to the class A1R and class A2R
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 BR, 'AA+sf' for class C1R, 'AAsf'
for class C2R, 'A+sf' for class D1R, 'A-sf' for class D2R, and
'BBB-sf' for class ER.

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 the data is adequately reliable.

ESG Considerations

Fitch does not provide ESG relevance scores for Venture 46 CLO,
Limited.

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.


VERUS SECURITIZATION 2024-8: S&P Assigns B Rating on B-2 Notes
--------------------------------------------------------------
S&P Global Ratings assigned its 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 1,227 loans
backed by 1,231 properties, which are qualified
mortgage/non-higher-priced mortgage loan (QM/non-HPML; safe
harbor), QM rebuttable presumption, non-QM/
ability-to-repay-compliant (ATR-compliant), and ATR-exempt loans.
Of the 1,227 loans, two loans are cross-collateralized loan backed
by six properties.

After the preliminary ratings were issued, the issuer added initial
exchangeable classes A-1A and A-1B notes, which together can be
exchanged for exchangeable class A-1 notes. In addition, the issuer
provided loan balances with October cut-offs. The loss coverage
numbers and ratings are unchanged from the preliminary loss
coverage and ratings.

The ratings reflect S&P's view of:

-- The pool's collateral composition;

-- The transaction's credit enhancement, associated structural
mechanics, representations and warranties framework, prior credit
events, and geographic concentration;

-- The mortgage aggregator, Invictus Capital Partners; and

-- One key change in our baseline forecast since June, an
acceleration in the pace of monetary policy easing. S&P said, "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 25.0%. 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 2.5%. 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."

  Ratings Assigned

  Verus Securitization Trust 2024-8(i)

  Class A-1A, $326,543,000: AAA (sf)
  Class A-1B, $59,210,000: AAA (sf)
  Class A-1, $385,753,000: AAA (sf)
  Class A-2, $47,072,000: AA (sf)
  Class A-3, $71,644,000: A (sf)
  Class M-1, $38,783,000: BBB- (sf)
  Class B-1, $17,467,000: BB (sf)
  Class B-2, $19,243,000: B (sf)
  Class B-3, $12,138,490: Not rated
  Class A-IO-S, notional(ii): Not rated
  Class XS, notional(ii): Not rated
  Class R, Not applicable: Not rated

(i)The 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 XIII: Fitch Assigns 'BB-(EXP)sf' Rating on E-R Notes
----------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
Vibrant CLO XIII, Ltd. reset transaction.

   Entity/Debt           Rating           
   -----------           ------           
Vibrant CLO XIII,
Ltd.

   A-1-R             LT  NR(EXP)sf    Expected Rating
   A-2-R             LT  AAA(EXP)sf   Expected Rating
   B-1-R             LT  AA(EXP)sf    Expected Rating
   B-2-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
   Subordinated      LT  NR(EXP)sf    Expected Rating

Transaction Summary

Vibrant CLO XIII, Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that is managed by Vibrant
Capital Partners, Inc. that originally closed in June 2021 and is
being refinanced on Nov. 15, 2024. Net proceeds from the issuance
of new secured and existing 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', which is in line with that of recent
CLOs. The weighted average rating factor (WARF) of the indicative
portfolio is 23.73, versus a maximum covenant, in accordance with
the initial expected matrix point of 23.73. 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
99.11% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 76.61% versus a
minimum covenant, in accordance with the initial expected matrix
point of 76.61%.

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 5.2-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-2-R, between
'BB+sf' and 'AA-sf' for class B-R, between 'B+sf' and 'Asf' for
class C-R, between less than 'B-sf' and 'BBB-sf' for class D-1-R,
between less than 'B-sf' and 'BB+sf' for class D-2-R, and between
less than 'B-sf' and 'BB-sf' for class E-R.

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

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

Variability in key model assumptions, such as increases in recovery
rates and decreases in default rates, could result in an upgrade.
Fitch evaluated the notes' sensitivity to potential changes in such
metrics; the minimum rating results under these sensitivity
scenarios are 'AAAsf' for class B-R, 'AA+sf' for class C-R, 'A+sf'
for class D-1-R, 'A+sf' for class D-2-R, and 'BBB+sf' for class
E-R.

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

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

DATA ADEQUACY

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

Overall, 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 Vibrant CLO XIII,
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.


WELLFLEET CLO 2022-2: S&P Assigns BB- (sf) Rating on Cl. E-R Notes
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-R, B-R, C-R,
D-1-R, D-2-R, and E-R replacement debt and proposed new class X-R
debt from Wellfleet CLO 2022-2 Ltd./Wellfleet CLO 2022-2 LLC, a CLO
originally issued in September 2022 that is managed by Blue Owl
Liquid Credit Advisors LLC, formerly known as Wellfleet Credit
Partners LLC. At the same time, S&P withdrew its ratings on the
class A-1, B, C, D, and E debt following payment in full on the
Oct. 18, 2024, refinancing date.

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

-- The replacement class A-R, B-R, C-R, D-1-R, and E-R debt was
issued at a lower spread over three-month term SOFR than the
original debt.

-- The class D debt was replaced by the floating-rate class D-1-R
debt and the fixed-rate class D-2-R debt.

-- The stated maturity, reinvestment period, and non-call period
were each extended by two years.

-- The weighted average life test was extended to nine years from
the closing date.

-- The proposed class X-R debt was issued in connection with this
refinancing and is expected paid down using interest proceeds
during the first 12 payment dates beginning with the January 2025
payment date and ending in October 2027.

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

  Wellfleet CLO 2022-2 Ltd./Wellfleet CLO 2022-2 LLC

  Class X-R, $3.25 million: AAA (sf)
  Class A-R, $295.00 million: AAA (sf)
  Class B-R, $85.00 million: AA (sf)
  Class C-R (deferrable), $30.00 million: A (sf)
  Class D-1-R (deferrable), $25.00 million: BBB (sf)
  Class D-2-R (deferrable), $7.75 million: BBB- (sf)
  Class E-R (deferrable), $14.75 million: BB- (sf)

  Ratings Withdrawn

  Wellfleet CLO 2022-2 Ltd./Wellfleet CLO 2022-2 LLC

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

  Other Debt

  Wellfleet CLO 2022-2 Ltd./Wellfleet CLO 2022-2 LLC

  Subordinated notes, $56.70 million: Not rated



WELLS FARGO 2018-C43: DBRS Confirms B(low) Rating on Class F Certs
------------------------------------------------------------------
DBRS, Inc. confirmed all credit ratings on the classes of
Commercial Mortgage Pass-Through Certificates, Series 2018-C43
issued by Wells Fargo Commercial Mortgage Trust 2018-C43 as
follows:

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

Morningstar DBRS changed the trends on Classes X-D, D, E, and F to
Negative from Stable. The trends on all remaining classes are
Stable.

The credit rating confirmations reflect the stable performance of
the transaction, which remains in line with Morningstar DBRS'
expectations. Overall, the pool continues to exhibit healthy credit
metrics, as evidenced by the weighted-average (WA) debt service
coverage ratio (DSCR) of 2.22 times (x) based on the most recent
financial reporting available. In addition, the transaction
continues to benefit from increased credit support to the bonds as
a result of scheduled amortization, loan repayments, and
defeasance. Although the majority of loans in the pool continue to
exhibit healthy credit metrics, there is a meaningful concentration
of loans collateralized by office properties, which represent 32.6%
of the current pool balance. The Negative trends carried by the
Class D, E, and F certificates reflect loan-specific concerns
primarily related to the Southpoint Office Center (Prospectus ID#4:
5.5% of the pool) and 35 Waterview Boulevard (Prospectus ID#9: 3.2%
of the pool), which are secured by office properties in secondary
markets that are exhibiting increased credit risks, as outlined
below.

As of the September 2024 reporting, 56 of the original 63 loans
remain in the pool with an aggregate principal balance of $617.8
million, representing a collateral reduction of 14.5% since
issuance. Eleven loans, representing 12.5% of the pool, are secured
by collateral that has been defeased. Nine loans, representing
16.5% of the pool, are being monitored on the servicer's watchlist;
however, only four of those loans, representing 12.3% of the pool,
are being monitored for performance related reasons. In its
analysis for this review, Morningstar DBRS analyzed six loans
(16.8% of the pool) that exhibited declines in performance since
issuance with stressed loan-to-value ratios (LTVs) and/or elevated
probabilities of default (PODs), resulting in a WA expected loss
(EL) almost 2.5x the pool average.

Southpoint Office Center is secured by a 366,808-square-foot (sf),
Class A suburban office property in Bloomington, Minnesota. The
loan was placed on the watchlist in May 2021 for low occupancy and
DSCR following the departure of the property's former largest
tenant, Wells Fargo, in October 2020 (18.2% of the net rentable
area (NRA) at the time). As a result, the occupancy rate fell to
65.8% at YE2021 from 91.5% at issuance and was most recently
reported at 71.5% as of Q2 2024. While there has been moderate
leasing momentum in the last year and tenancy is rather granular
outside of the largest tenant, United Bank (11.4% of the NRA), 21
tenants, representing 48.6% of the NRA, have lease expirations
prior to loan maturity in February 2028. According to the September
2024 reporting, the borrower had access to only $0.2 million of
held leasing reserves to help with re-leasing efforts and the loan
is exhibiting a weak DSCR of 1.17x as of Q2 2024, limiting the cash
trap structure originally contemplated at issuance. According to
Reis, the Southwest/Northeast Scott County submarket reported a Q2
2024 vacancy rate of 23.1%, which had increased from 20.5% in Q2
2023 and 17.6% in Q2 2022. Given the depressed performance, soft
market conditions, and heightened rollover risk prior to loan
maturity, Morningstar DBRS analyzed the loan with an elevated POD
penalty and stressed LTV, resulting in an EL that was more than 3x
the pool average.

35 Waterview Boulevard is secured by a 172,498-sf, Class A suburban
office property in Parsippany, New Jersey. The loan was placed on
the watchlist in March 2023 for a low DSCR as a result of increased
vacancy. While the occupancy rate has improved to 81.7% as of Q2
2024 from 72.0% at YE2023, the space was re-leased at lower rates
and occupancy is still well below the issuance rate of 95.7%. The
borrower leased space to two tenants, representing 13.1% of NRA,
during H1 2024 at an average rental rate of $21.60 psf, below the
property's in-place rental rate of $26.50 psf. Rollover is limited
to 6.3% during the next 12 months, however, the largest tenant, Sun
Chemical Management (38.3% of NRA, lease expiry in December 2029),
has a one-time termination option in December 2024. While the
tenant initially indicated that it planned to exercise the option,
loan documents indicate the tenant would have needed to pay half
the termination fee by YE2023 and move out of the state of New
Jersey, neither of which have materialized. As a result, the
servicer did not initiate a cash flow sweep with only $0.5 million
held in leasing reserves to help with re-leasing efforts. Excluding
Sun Chemical Management's potential departure, coverage has hovered
around breakeven for the last couple of years, reported most
recently at 1.11x as of Q2 2024, despite the improved occupancy. As
of Q2 2024, the Parsippany/Troy Hills submarket reported a vacancy
rate of 28.6%, an average asking rental rate of $25.70 psf, and an
average effective rental rate of $21.10. Given the decline in
performance and uncertainty surrounding the Sun Chemical Management
termination option, Morningstar DBRS analyzed the loan with an
elevated POD penalty and stressed LTV, resulting in an EL that was
almost 3x the pool average.

At issuance, Morningstar DBRS shadow-rated two loans as investment
grade, Moffett Towers II - Building 2 (Prospectus ID#1; 8.5% of the
pool) and Apple Campus 3 (Prospectus ID#7; 4.9% of the pool).
Morningstar DBRS confirmed that the performance of these loans
remains consistent with investment-grade loan characteristics with
this review.

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


WESTLAKE AUTOMOBILE 2024-3: Fitch Assigns BB Rating on Class E Debt
-------------------------------------------------------------------
Fitch Ratings has assigned final ratings and Rating Outlooks to
Westlake Automobile Receivables Trust 2024-3 (WLAKE 2024-3).

   Entity/Debt           Rating             Prior
   -----------           ------             -----
Westlake Automobile
Receivables
Trust 2024-3

   A1                ST F1+sf  New Rating   F1+(EXP)sf
   A2A               LT AAAsf  New Rating   AAA(EXP)sf
   A2B               LT AAAsf  New Rating   AAA(EXP)sf
   A3                LT AAAsf  New Rating   AAA(EXP)sf
   B                 LT AA+sf  New Rating   AA+(EXP)sf
   C                 LT Asf    New Rating   A(EXP)sf
   D                 LT BBBsf  New Rating   BBB(EXP)sf
   E                 LT BBsf   New Rating   BB(EXP)sf

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 629, up two points from 2024-2,
and an internal WA Westlake score of 4.15, up from 3.96 in 2024-2.
WA seasoning is five months, down from six months in 2024-2, and
new vehicles total just 2.5% 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 44.5%, 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 cumulative net loss (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 9.73% per annum. Loss coverage for each class of notes is
sufficient to cover the respective multiples of Fitch's rating case
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 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
0.42%, 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.


WFLD 2014-MONT: DBRS Cuts Rating on Class D Certs to CCCsf
----------------------------------------------------------
DBRS Inc. downgraded its credit ratings on all classes of the
Commercial Mortgage Pass-Through Certificates, Series 2014-MONT
issued by WFLD 2014-MONT Mortgage Trust as follows:

-- Class A to AA (low) (sf) from AAA (sf)
-- Class B to BBB (low) (sf) from BBB (sf)
-- Class C to B (low) (sf) from BB (sf)
-- Class D to CCC (sf) from B (low) (sf)

Morningstar DBRS changed the trends on Classes A, B, and C to
Negative from Stable. Class D has a credit rating that does not
carry a trend in commercial mortgage-backed securities (CMBS).

The rating downgrades and Negative trends are reflective of the
elevated risk of potential loss to the trust given the updated
appraised value reported for the regional mall that secures the
trust's only loan. The loan transferred to special servicing in
April 2024 at the borrower's request, ahead of its August 2024
maturity. In August 2024, the loan was modified, extending loan
maturity by two years to August 2026. As part of the modification,
the borrower paid down the loan by $16.0 million and is required to
further deleverage the loan by an additional $5.5 million, spread
over the loan's remaining 24-month term. The loan will also be
subject to an excess cash flow sweep with funds to be used for
leasing costs and capital expenditures.

An updated appraisal completed in June 2024 valued the property at
$353.0 million, down 48.1% from the issuance appraisal of $680.0
million. The updated value reflects a loan-to-value ratio (LTV) of
94.6% and implies a cap rate of 7.2% based on the YE2023 NCF, which
Morningstar DBRS views as slightly aggressive for regional malls in
the current interest rate and investment sales environments. As
such, Morningstar DBRS applied a stressed haircut to the appraised
value to account for any outstanding servicing advances, fees, and
the potential for further value decline. Morningstar DBRS'
concluded value of $317.7 million implies an 8.0% cap rate based on
the YE2023 net cash flow (NCF) and represents a decrease of 13.5%
from Morningstar DBRS' previous value of $367.3 million, derived at
the time of the November 2023 credit rating action. The updated
Morningstar DBRS value indicates the increased propensity for loss
to the Class D certificate and high sensitivity to the Class C
certificate should the value decline further. Morningstar DBRS also
considered the high Morningstar DBRS LTV of 105.1%, which indicates
significant downward pressure on the senior-most bonds. These
considerations were the primary drivers of the downgrades and
Negative trends.

The interest-only loan is secured by 835,597 square feet (sf) of
the 1.3 million-sf Westfield Montgomery Mall in Bethesda, Maryland,
located 15 miles north of Washington, D.C. The loan sponsor is
Unibail-Rodamco-Westfield, which had previously announced its
intention to sell its U.S. portfolio and exit the market by YE2023.
Plans to divest its holdings have slowed amid the increase in foot
traffic to brick-and-mortar retail as well as increasing interest
rates.

The mall is anchored by tenants Macy's, Macy's Home, and Nordstrom,
which are not part of the loan collateral; however, Nordstrom
operates on a ground lease expiring in October 2025. Additionally,
there is a vacant Sears box at the property, which the sponsors
purchased in 2017 with the intention of redeveloping it as part of
a comprehensive expansion and renovation of the property and
surrounding area. As per the June 2024 rent roll, the collateral
was 92.6% occupied. The largest collateral tenants include American
Multi-Cinema (AMC; 7.3% of the net rental area (NRA), lease expiry
in March 2034), Forever 21 (2.4% of the NRA, lease expiry in April
2025), and Lucky Strike (1.8% of the NRA, lease expiry in January
2026). Upcoming rollover risk on the remaining collateral tenants
is moderate as only 15.5% of the collateral NRA has lease
expirations through YE2025.

The servicer reported NCF of $25.3 million for YE2023 compared with
$28.1 million for YE2022 and $33.6 million for pre-pandemic YE2019.
According to the tenant sales report for the trailing 12 months
(T-12) ended June 30, 2024, in-line tenants reported sales of $938
per square foot (psf). When Apple and Tesla were removed, in-line
sales were reported at $641 psf, a significant improvement when
compared with $554 psf for the T-12 ended June 30, 2023. During the
same period, the 16-screen AMC reported sales of just less than
$414,000 per screen, an improvement from the reported sales of
$323,000 per screen in June 2023.

The Morningstar DBRS ratings assigned to Classes A and B are higher
than the results implied by the LTV sizing benchmarks. The variance
is warranted given that Morningstar DBRS considers the bonds to be
well insulated from loss. While Morningstar DBRS remains concerned
about the loan's high leverage point and potential for further
value decline, there have been positive developments over the past
year, including the finalization of the loan modification and a
principal curtailment, which help to offset near-term default risk
and indicate continued sponsor commitment, as well as the
property-level performance that continues to stabilize.

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


WFRBS COMMERCIAL 2013-C18: DBRS Confirms C Rating on Class D Certs
------------------------------------------------------------------
DBRS Limited confirmed its credit rating on the remaining class of
Commercial Mortgage Pass-Through Certificates, Series 2013-C18
issued by WFRBS Commercial Mortgage Trust 2013-C18 as follows:

-- Class D at C (sf)

There is no trend as the class has a credit rating that does not
typically carry a trend in commercial mortgage-backed securities
(CMBS) credit ratings.

Since the last credit rating action, 44 loans have been repaid in
full and one loan was liquidated from the trust, resulting in only
two loans remaining as of the September 2024 remittance, both of
which are in special servicing. Given this concentration,
Morningstar DBRS' analysis was based on a recoverability analysis.
The credit rating confirmation on Class D reflects Morningstar
DBRS' continued expectation that the certificate will incur losses,
based on the recoverability analysis. The loss expectations are
primarily attributed to the Cedar Rapid Office Portfolio (79.2% of
the pool). The special servicer has deemed outstanding advances,
totaling $7.7 million as of September 2024, as nonrecoverable. As
such, Morningstar DBRS expects a full loss of the $20.0 million
loan balance upon disposition., which would fully erode the
remaining certificate balance of Class E, which has already
defaulted, and erode the certificate balance of Class D by over
50%.

The Cedar Rapids Office Portfolio has been real estate owned since
June 2020. The asset comprises two cross-collateralized Class A
office buildings in Cedar Rapids, Iowa. In June 2023, the buildings
were appraised at a combined as-is value of $6.0 million, an 84.0%
decline from the issuance appraised value of $36.2 million.
According to media sources, 600 Third Avenue (22.5% of the
allocated loan amount (ALA)) was sold for $2.3 million in January
2024; however, there has not been a principal paydown reflecting a
property release. Town Center Office (77.5% of the ALA) was
appraised at an individual as-is value of $2.2 million, indicating
a combined as-is property value of $4.5 million. Based on the
implied loan-to-value ratio (LTV) of more than 500% on total loan
exposure, Morningstar DBRS expects a full loss.

Staybridge Suites Royersford (21.8% of the pool) is secured by a
105-unit, extended stay hotel in Royersford, Pennsylvania. The loan
was transferred to special servicing in December 2023 for maturity
default and is listed as a performing matured balloon loan with the
September 2024 reporting. Property-level cash flow has been
negative since the onset of the pandemic and the lender is
currently dual tracking foreclosure. The property was reappraised
for $6.4 million in January 2024, a 57% drop from the issuance
appraisal of $14.9 million. When applying a conservative haircut to
the most recent appraisal, the loan would have an implied LTV
approaching 100% based on total loan exposure, indicating the
potential for loss upon disposition.

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


WIND RIVER 2015-1: Moody's Cuts Class F-R Notes Rating to Caa2
--------------------------------------------------------------
Moody's Ratings has upgraded the ratings on the following notes
issued by Wind River 2015-1 CLO Ltd.:

US$14,745,000 Class C-1 Mezzanine Secured Deferrable Floating Rate
Notes due 2030 (the "Class C-1 Notes"), Upgraded to Aa1 (sf);
previously on April 10, 2024 Upgraded to Aa2 (sf)

US$14,745,000 Class C-2 Mezzanine Secured Deferrable Floating Rate
Notes due 2030 (the "Class C-2 Notes"), Upgraded to Aa1 (sf);
previously on April 10, 2024 Upgraded to Aa2 (sf)

US$37,310,000 Class D-R Mezzanine Secured Deferrable Floating Rate
Notes due 2030 (the "Class D-R Notes"), Upgraded to A3 (sf);
previously on April 10, 2024 Upgraded to Baa1 (sf)

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

US$12,030,000 Class F-R Junior Secured Deferrable Floating Rate
Notes due 2030 (the "Class F-R Notes"), Downgraded to Caa2 (sf);
previously on September 11, 2023 Downgraded to Caa1 (sf)

Wind River 2015-1 CLO Ltd., originally issued in July 2015 and
refinanced most recently in April 2024, 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 2023.

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

RATINGS RATIONALE

The rating actions on the Class C-1, Class C-2 and Class D-R notes
are primarily a result of deleveraging of the senior notes and an
increase in the transaction's over-collateralization (OC) ratios
since April 2024. The Class A-1-R3 notes have been paid down by
approximately 38.13% or $135.3 million since then. Based on Moody's
calculation, the OC ratios for the Class C and Class D-R notes are
currently 129.78% and 116.69%, respectively, versus April 2024
levels of 122.24% and 113.22%, respectively.

The downgrade rating action on the Class F-R notes reflects the
specific risks to the junior notes posed by par loss observed in
the underlying CLO portfolio. Based on Moody's calculation,
transaction has lost approximately $5 million since April 2024, and
the cumulative loss amount on the underlying CLO portfolio amounts
to approximately $17.7 million or 2.95% of the initial total target
par amount.

No actions were taken on the Class A-1-R3, Class A-2-R3, Class B-R3
and Class E-R 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: $431,867,789

Diversity Score: 66

Weighted Average Rating Factor (WARF): 2825

Weighted Average Spread (WAS) (before accounting for reference rate
floors): 3.41%

Weighted Average Recovery Rate (WARR): 46.97%

Weighted Average Life (WAL): 3.9 years

Par haircut in OC tests and interest diversion test:  1.25%

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.


WIND RIVER 2022-1: S&P Affirms 'BB- (sf)' Rating on Class E Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-R, B-1-R,
C-R, and D-1-R replacement debt from Wind River 2022-1 CLO
Ltd./Wind River 2022-1 CLO LLC, a CLO originally issued in June
2022 that is managed by First Eagle Alternative Credit LLC. At the
same time, S&P withdrew its ratings on the original class A, B-1,
C, and D-1 debt following payment in full on the Oct. 21, 2024,
refinancing date. S&P also affirmed its ratings on the class B-2,
D-2, and E debt, which were not refinanced.

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

-- The non-call period was extended to Oct. 20, 2025.

-- No additional assets were purchased on the Oct. 21, 2024,
refinancing date, and the target initial par amount remains at $400
million. There was no additional effective date or ramp-up period,
and the first payment date following the refinancing is Jan. 20,
2025.

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

Replacement And Original Debt Issuances

Replacement debt

-- Class A-R, $240.00 million: Three-month CME term SOFR + 1.35%

-- Class B-1-R, $59.00 million: Three-month CME term SOFR + 1.85%

-- Class C-R, $24.00 million: Three-month CME term SOFR + 2.20%

-- Class D-1-R (deferrable), $15.00 million: Three-month CME term
SOFR + 3.35%

Original debt

-- Class A, $240.00 million: Three-month CME term SOFR + 1.53%

-- Class B-1, $59.00 million: Three-month CME term SOFR + 2.35%

-- Class B-2, $5.00 million: 5.03%

-- Class C, $24.00 million: Three-month CME term SOFR + 2.75%

-- Class D-1 (deferrable), $15.00 million: Three-month CME term
SOFR + 3.55%

-- Class D-2 (deferrable), $9.00 million: Three-month CME term
SOFR + 5.42%

  Class E (deferrable), $15.00 million: Three-month CME term SOFR +
8.12%

-- Subordinated notes, $36.39 million: Not applicable

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction data in the
trustee report, to estimate future performance. In line with our
criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults and 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

  Wind River 2022-1 CLO Ltd./Wind River 2022-1 CLO LLC

  Class A-R, $240.00 million: AAA (sf)
  Class B-1-R, $59.00 million: AA (sf)
  Class C-R, $24.00 million: A (sf)
  Class D-1-R (deferrable), $15.00 million: BBB+ (sf)

  Ratings Withdrawn

  Wind River 2022-1 CLO Ltd./Wind River 2022-1 CLO LLC

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

  Ratings Affirmed

  Wind River 2022-1 CLO Ltd./Wind River 2022-1 CLO LLC

  Class B-2: 'AA (sf)'
  Class D-2: 'BBB- (sf)'
  Class E: 'BB- (sf)'

  Other Debt

  Wind River 2022-1 CLO Ltd./Wind River 2022-1 CLO LLC

  Subordinated notes, $36.39 million: NR

  NR--Not rated.



[*] DBRS Confirms 7 Ratings From 3 United Auto Credit Transactions
------------------------------------------------------------------
DBRS, Inc. upgraded one credit rating, downgraded one credit
rating, and confirmed seven credit ratings from three United Auto
Credit Securitization Trust transactions.

The Affected Ratings are available at https://bit.ly/3YqESYd

The Issuers are:

United Auto Credit Securitization Trust 2022-1
United Auto Credit Securitization Trust 2023-1
United Auto Credit Securitization Trust 2022-2

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

-- The collateral performance to date and Morningstar DBRS'
assessment of future performance as of the September 2024 payment
date.

-- United Auto Credit Securitization Trust 2022-1 has amortized to
a pool factor of 18.91% and has a current cumulative net loss (CNL)
to date of 23.05%. Current CNL is tracking above Morningstar DBRS'
initial base-case loss expectation of 19.60%. Consequently, the
revised base-case loss expectation was increased to 25.75%. The
current level of hard Credit Enhancement (CE) and estimated excess
spread are sufficient to support the Morningstar DBRS projected
remaining CNL assumptions at a multiple of coverage commensurate
with the credit ratings.

-- United Auto Credit Securitization Trust 2022-2 has amortized to
a pool factor of 29.77% and has a current CNL to date of 27.30%.
Current CNL is tracking above Morningstar DBRS' initial base-case
loss expectation of 19.90%. Consequently, the revised base-case
loss expectation was increased to 33.50%. As of the September 2024
payment date, the current overcollateralization amount is 0.00%
relative to the target of 10.50% of the outstanding receivables
balance. Additionally, the transaction structure includes a fully
funded non-declining reserve account (RA) of 1.50% of the initial
aggregate pool balance. As of the September 2024 payment date, the
RA amount has been fully depleted. As a result, the current level
of hard CE and estimated excess spread are insufficient to support
the current credit rating on the Class E Notes and, consequently,
the credit rating has been downgraded to a rating level
commensurate with the current implied multiple. While CNL is
tracking above the initial expectation, the Class C Notes and the
Class D Notes have benefited from deleveraging and have sufficient
CE commensurate with the current credit ratings, and Morningstar
DBRS has confirmed the credit ratings on these classes.

-- For the Class E Notes in United Auto Credit Securitization
Trust 2022-2, given the insufficient level of CE to support the
full repayment of interest and principal, the credit rating has
been downgraded to 'CCC' (sf). In accordance with the applicable
Morningstar DBRS credit rating methodology, there is a high
probability that the Class E Notes will not receive the full
interest and principal payments by the legal final maturity.

-- United Auto Credit Securitization Trust 2023-1 has amortized to
a pool factor of 42.09% and has a current CNL to date of 17.55%.
Current CNL is tracking above Morningstar DBRS' initial base-case
loss expectation of 19.50%. Consequently, the revised base-case
loss expectation was increased to 26.75%. The current level of hard
Credit Enhancement (CE) and estimated excess spread are sufficient
to support the Morningstar DBRS projected remaining CNL assumptions
at a multiple of coverage commensurate with the credit ratings.

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

-- The Transaction assumptions consider Morningstar DBRS' baseline
macroeconomic scenarios for rated sovereign economies, available in
its commentary, " Baseline Macroeconomic Scenarios for Rated
Sovereigns September 2024 Update," published on September 25, 2024.
These baseline macroeconomic scenarios replace Morningstar DBRS'
moderate and adverse coronavirus pandemic scenarios, which were
first published in April 2020.

Notes: The principal methodology applicable to the credit ratings
is Morningstar DBRS Master U.S. ABS Surveillance.


[*] DBRS Reviews 113 Classes From 9 US RMBS Transactions
--------------------------------------------------------
DBRS, Inc. reviewed 113 classes from nine U.S. residential
mortgage-backed securities (RMBS) transactions. Of the nine
transactions reviewed seven are classified as Non-Qualified
Mortgage, one as Agency Credit and one is classified as a
Re-performing transaction. Of the 113 classes reviewed, Morningstar
DBRS upgraded eight credit ratings and confirmed 105 credit
ratings.

The Affected Ratings are available at https://bit.ly/3YsFDjz

The Issuers are:

MFA 2022-INV3 Trust
GCAT 2022-NQM5 Trust
NYMT Loan Trust 2022-INV1
PRPM 2023-NQM2 Trust
Citigroup Mortgage Loan Trust 2022-RP5
Verus Securitization Trust 2022-INV2
Imperial Fund Mortgage Trust 2022-NQM7
Connecticut Avenue Securities, Series 2023-R07
BRAVO Residential Funding Trust 2023-NQM7

The credit rating upgrades reflect positive performance trends and
increases in credit support sufficient to withstand stresses at
their new credit rating levels. The credit rating confirmations
reflect asset performance and credit-support levels that are
consistent with the current credit ratings.

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


[*] Moody's Takes Action on 12 Bonds From 5 US RMBS Deals
---------------------------------------------------------
Moody's Ratings, on Oct. 22, 2024, upgraded the ratings of five
bonds and downgraded the ratings of seven bonds from 12 US
residential mortgage-backed transactions (RMBS), backed by Subprime
and Alt-A 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 Trust 2003-AC7

Cl. A-1, Downgraded to Caa1 (sf); previously on May 29, 2019
Downgraded to B3 (sf)

Cl. A-2, Downgraded to Caa1 (sf); previously on May 29, 2019
Downgraded to B3 (sf)

Cl. A-3, Downgraded to Caa1 (sf); previously on May 29, 2019
Downgraded to B3 (sf)

Cl. A-4*, Downgraded to Caa1 (sf); previously on May 29, 2019
Downgraded to B3 (sf)

Issuer: CSFB Mortgage-Backed Pass-Through Certificates, Series
2005-4

Cl. II-A-2*, Downgraded to Caa1 (sf); previously on Feb 28, 2014
Downgraded to B3 (sf)

Cl. II-A-7, Downgraded to Caa1 (sf); previously on Feb 28, 2014
Downgraded to B3 (sf)

Cl. II-X*, Downgraded to Caa1 (sf); previously on Nov 29, 2017
Confirmed at B3 (sf)

Issuer: Home Equity Loan Asset-Backed Certificates, Series
2007-FRE1

Cl. 1-AV-1, Upgraded to Baa1 (sf); previously on Mar 24, 2023
Upgraded to Ba2 (sf)

Cl. 2-AV-3, Upgraded to B1 (sf); previously on Feb 1, 2019 Upgraded
to Caa3 (sf)

Cl. 2-AV-4, Upgraded to Caa1 (sf); previously on Feb 1, 2019
Upgraded to Caa3 (sf)

Issuer: J.P. Morgan Mortgage Acquisition Trust 2007-CH2,
Asset-Backed Pass-Through Certificates, Series 2007-CH2

Cl. MV-4, Upgraded to B1 (sf); previously on Apr 20, 2018 Upgraded
to Caa2 (sf)

Issuer: J.P. Morgan Mortgage Acquisition Trust 2007-CH5

Cl. A-1, Upgraded to Aaa (sf); previously on Nov 22, 2019 Upgraded
to Aa1 (sf)

* Reflects Interest-Only Classes

RATINGS RATIONALE

The  rating actions reflect the recent performance, the existing
credit enhancement levels and 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 primarily due to decline in credit enhancement available to the
bonds and/or the existence of interest shortfalls.

Each of the upgraded bonds have displayed improved collateral
performance and credit enhancement levels, since 12 months ago,
have grown, on average by 3.29%.

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.

The rating downgrade of Class A-4, an interest only bond from Bear
Stearns Asset-Backed Securities Trust 2003-AC7, as well as Classes
II-A-2 and II-X from CSFB Mortgage-Backed Pass-Through
Certificates, Series 2005-4, reflects the weakened performance and
reduced credit enhancement levels related to the bonds or the
reference bonds.

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.

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, credit enhancement and other
qualitative considerations. These include interest risk from
current or potential missed interest that remain unreimbursed and
the non-credit nature of zero payments to interest only bonds.

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 Takes Action on 14 Bonds From Nine US RMBS Deals
------------------------------------------------------------
Moody's Ratings has upgraded the ratings of six bonds and
downgraded the ratings of eight bonds from nine US residential
mortgage-backed transactions (RMBS), backed by prime jumbo,
subprime, 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: Ameriquest Mortgage Securities Inc., Series 2004-R2

Cl. M-3, Downgraded to B2 (sf); previously on Jun 9, 2020
Downgraded to B1 (sf)

Cl. M-4, Downgraded to B3 (sf); previously on Dec 31, 2019
Downgraded to B1 (sf)

Cl. M-5, Downgraded to Caa1 (sf); previously on Jan 13, 2017
Upgraded to B1 (sf)

Issuer: Bear Stearns Mortgage Funding Trust 2007-AR1

Cl. I-A-1, Upgraded to Caa1 (sf); previously on Dec 7, 2010
Confirmed at Caa2 (sf)

Issuer: Deutsche Alt-A Securities, Inc. Mortgage Loan Trust Series
2003-4XS

Cl. A-6A, Downgraded to Caa2 (sf); previously on Jun 25, 2024
Upgraded to Aa3 (sf)

Issuer: Lehman XS Trust Series 2006-GP3

Cl. 3-A5A, Upgraded to Ba3 (sf); previously on Jun 21, 2019
Upgraded to B3 (sf)

Issuer: Luminent Mortgage Trust 2005-1

Cl. A-1, Upgraded to B1 (sf); previously on May 27, 2015 Upgraded
to Caa1 (sf)

Cl. A-2, Upgraded to B1 (sf); previously on Jun 4, 2010 Downgraded
to C (sf)

Issuer: MortgageIT Trust 2005-3

Cl. A-1, Upgraded to Aaa (sf); previously on Dec 6, 2023 Upgraded
to Aa2 (sf)

Cl. A-2, Upgraded to Aaa (sf); previously on Dec 6, 2023 Upgraded
to A2 (sf)

Issuer: Park Place Securities, Inc., Asset-Backed Pass-Through
Certificates, Series 2005-WHQ4

Cl. M-2, Downgraded to B2 (sf); previously on Mar 11, 2016 Upgraded
to B1 (sf)

Issuer: Securitized Asset Backed Receivables LLC Trust 2005-OP2

Cl. M-2, Downgraded to Caa1 (sf); previously on May 3, 2019
Downgraded to B1 (sf)

Cl. M-3, Downgraded to Caa1 (sf); previously on Feb 26, 2018
Upgraded to B2 (sf)

Issuer: WaMu Mortgage Pass-Through Certificates, Series 2002-AR2

Cl. B-1, Downgraded to Caa1 (sf); previously on Oct 16, 2020
Downgraded to B2 (sf)

RATINGS RATIONALE

The rating actions reflect the recent performance, the level of
credit enhancement and Moody's updated loss expectations on the
underlying pools.

The transactions with upgrades continue to display strong
collateral performance. Credit enhancement levels, over the last 12
months, have grown on average 14.6% 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.

Most of the rating downgrades are the result of outstanding credit
interest shortfalls that are unlikely to be recouped. 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. The size
and length of the outstanding interest shortfalls were also
considered in Moody's analysis for both upgrades and downgrades.

Class B-1 issued by WaMu Mortgage Pass-Through Certificates, Series
2002-AR2 is expected to become impaired, and the rating downgrade
reflects Moody's expected future loss to the bond.

The rating downgrade for Class A-6A from Deutsche Alt-A Securities,
Inc. Mortgage Loan Trust Series 2003-4XS is driven by the fact that
the collateral pool backing the transaction has decreased to an
effective number below the threshold established in the US RMBS
Surveillance Methodology. Moody's does not maintain ratings on US
RMBS securities in a structure where the effective number of
borrowers has reduced below the threshold. However, Cl. A-6A has
the benefit of support provided by a certificate guarantee. For
structured finance securities with third party support, the rating
applied is the higher of the support provider's rating and the
rating without any consideration of the third party support. The
rating  on Cl. A-6A now reflects the rating of the support
provider, MBIA Insurance Corporation.

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, 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.


[*] Moody's Takes Action on 31 Bonds From 24 US RMBS Deals
----------------------------------------------------------
Moody's Ratings has upgraded the ratings of 13 bonds and downgraded
the ratings of 18 bonds from 24 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: ABFC Asset Backed Certificates, Series 2005-WF1

Cl. M-9, Upgraded to B2 (sf); previously on Oct 16, 2018 Upgraded
to Caa2 (sf)

Issuer: Asset Backed Securities Corporation Home Equity Loan Trust
2005-HE5

Cl. M4, Downgraded to Caa1 (sf); previously on Jun 24, 2015
Upgraded to B2 (sf)

Issuer: Citigroup Mortgage Loan Trust Inc. 2006-WMC1

Cl. M-1, Downgraded to Caa1 (sf); previously on Jun 13, 2019
Upgraded to B3 (sf)

Issuer: Citigroup Mortgage Loan Trust, Series 2005-HE3

Cl. M-3, Downgraded to B2 (sf); previously on Jan 18, 2017 Upgraded
to B1 (sf)

Issuer: Citigroup Mortgage Loan Trust, Series 2005-HE4

Cl. M-2, Downgraded to Caa1 (sf); previously on Jan 18, 2017
Upgraded to B2 (sf)

Cl. M-3, Downgraded to Caa1 (sf); previously on Jan 18, 2017
Upgraded to B2 (sf)

Issuer: CSFB Home Equity Asset Trust 2006-3

Cl. M-1, Upgraded to Aaa (sf); previously on Jun 7, 2022 Upgraded
to Aa2 (sf)

Cl. M-2, Upgraded to Ba3 (sf); previously on Nov 17, 2017 Upgraded
to Ca (sf)

Issuer: CWABS Asset-Backed Certificates Trust 2007-BC1

Cl. 1-A, Upgraded to B1 (sf); previously on Oct 17, 2016 Upgraded
to Caa3 (sf)

Cl. 2-A-4, Upgraded to B1 (sf); previously on Oct 17, 2016 Upgraded
to Caa3 (sf)

Issuer: IXIS Real Estate Capital Trust 2005-HE1

Cl. M-4, Downgraded to B3 (sf); previously on Oct 25, 2019 Upgraded
to B2 (sf)

Issuer: MASTR Asset Backed Securities Trust 2006-AM3

Cl. A-4, Upgraded to Ba1 (sf); previously on Jun 6, 2022 Upgraded
to Ba2 (sf)

Issuer: MASTR Asset Backed Securities Trust 2007-HE1

Cl. A-3, Upgraded to Ba1 (sf); previously on Jan 30, 2018 Upgraded
to Caa1 (sf)

Cl. A-4, Upgraded to B1 (sf); previously on Oct 16, 2018 Upgraded
to Caa1 (sf)

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2005-HE3

Cl. M-5, Downgraded to Caa1 (sf); previously on May 3, 2016
Upgraded to B2 (sf)

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2005-HE4

Cl. M-3, Downgraded to Caa1 (sf); previously on May 5, 2017
Upgraded to B1 (sf)

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2005-HE7

Cl. M-2, Downgraded to Caa1 (sf); previously on Apr 9, 2018
Upgraded to B1 (sf)

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2005-WMC2

Cl. M-3, Downgraded to Caa1 (sf); previously on Dec 19, 2019
Downgraded to B2 (sf)

Cl. M-4, Downgraded to Caa1 (sf); previously on Feb 27, 2018
Upgraded to B2 (sf)

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2005-WMC4

Cl. M-6, Downgraded to Caa1 (sf); previously on Feb 27, 2018
Upgraded to B3 (sf)

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2005-WMC5

Cl. M-5, Downgraded to Caa1 (sf); previously on Jun 25, 2015
Upgraded to B1 (sf)

Issuer: Opteum Mortgage Acceptance Corporation, Asset Backed
Pass-Through Certificates, Series 2005-1

Cl. M-8, Downgraded to Caa1 (sf); previously on Feb 13, 2017
Upgraded to B2 (sf)

Issuer: Renaissance Home Equity Loan Trust 2002-2

Cl. M-1, Downgraded to Caa1 (sf); previously on Jun 28, 2017
Upgraded to B1 (sf)

Issuer: Renaissance Home Equity Loan Trust 2005-4

Cl. A-4, Upgraded to A1 (sf); previously on Jul 15, 2011 Downgraded
to Caa2 (sf)

Issuer: Renaissance Home Equity Loan Trust 2006-4

Cl. AV-3, Downgraded to Ca (sf); previously on May 9, 2014
Downgraded to Caa3 (sf)

Issuer: Saxon Asset Securities Trust 2005-4

Cl. M-2, Downgraded to B2 (sf); previously on Jun 22, 2015 Upgraded
to B1 (sf)

Issuer: Specialty Underwriting and Residential Finance Series
2006-BC3

Cl. A-1, Upgraded to Ba1 (sf); previously on Apr 13, 2018 Upgraded
to Caa1 (sf)

Issuer: UCFC Home Equity Loan Trust 1998-D

MV-1, Downgraded to B2 (sf); previously on Apr 24, 2013 Downgraded
to B1 (sf)

Issuer: Wells Fargo Home Equity Asset-Backed Securities 2004-2
Trust

Cl. AIII-3, Upgraded to A2 (sf); previously on May 4, 2012
Downgraded to A3 (sf)

Cl. M-6, Upgraded to B1 (sf); previously on Nov 14, 2022 Upgraded
to B3 (sf)

Cl. M-7, Upgraded to B1 (sf); previously on Nov 14, 2022 Upgraded
to Caa2 (sf)

RATINGS RATIONALE

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

The rating upgrades are a result of the improving performance of
the related pools, and/or an increase in credit enhancement
available to the bonds. For instance, over the past 12 months,
Class A-3 from MASTR Asset Backed Securities Trust 2007-HE1, Class
A-4 from Renaissance Home Equity Loan Trust 2005-4, and Class A-1
from Specialty Underwriting and Residential Finance Series 2006-BC3
have amortized by 27.8%, 42.7%, and 8.9%, respectively.
Additionally, their credit enhancements have increased by 11.1%,
0.4%, and 7.2%, respectively.

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.

Additionally, Moody's analysis also considered the existence of
historical principal losses for some of the bonds. While all
principal losses have since been recouped, the size and length of
the past losses, as well as the potential for recurrence and
eventual repayment, were analyzed as part of the upgrades.

The rating downgrades are due to outstanding interest shortfalls on
these bonds that are not expected to be recouped. 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.

In addition, 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. This includes interest risk
from current or potential missed interest that remain
unreimbursed.

Principal Methodologies

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

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

Up

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

Down

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

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


[*] Moody's Takes Action on 36 Bonds From 22 US RMBS Deals
----------------------------------------------------------
Moody's Ratings has upgraded the ratings of eight bonds and
downgraded the ratings of 28 bonds from 22 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: ABFC Asset-Backed Certificates, Series 2005-HE1

Cl. M-2, Downgraded to B2 (sf); previously on Oct 14, 2016 Upgraded
to B1 (sf)

Issuer: Accredited Mortgage Loan Trust 2005-2, Asset-Backed Notes,
Series 2005-2

Cl. M-5, Downgraded to Caa1 (sf); previously on Jun 9, 2020
Downgraded to B1 (sf)

Cl. M-6, Downgraded to Caa1 (sf); previously on Jun 9, 2020
Downgraded to B1 (sf)

Issuer: Asset Backed Securities Corporation Home Equity Loan Trust
2005-HE2

Cl. M3, Downgraded to Caa1 (sf); previously on Feb 27, 2018
Upgraded to B2 (sf)

Issuer: Carrington Mortgage Loan Trust, Series 2005-NC3

Cl. M-4, Downgraded to B3 (sf); previously on Jun 20, 2017 Upgraded
to B1 (sf)

Issuer: Carrington Mortgage Loan Trust, Series 2005-OPT2

Cl. M-5, Downgraded to Caa1 (sf); previously on Nov 20, 2018
Upgraded to B1 (sf)

Issuer: Credit Suisse First Boston Mortgage Securities Corp. Series
2004-4

Cl. B-1, Upgraded to A3 (sf); previously on Dec 12, 2023 Upgraded
to Caa1 (sf)

Cl. M-1, Upgraded to Aa2 (sf); previously on Dec 12, 2023 Upgraded
to A1 (sf)

Issuer: CWABS Asset-Backed Certificates Trust 2005-3

Cl. MF-2, Upgraded to B1 (sf); previously on Jun 26, 2017 Upgraded
to Caa3 (sf)

Issuer: CWABS Asset-Backed Certificates Trust 2005-4

Cl. MF-2, Upgraded to B1 (sf); previously on May 31, 2018 Upgraded
to Caa2 (sf)

Issuer: Encore Credit Receivables Trust 2005-1

Cl. M-2, Downgraded to B3 (sf); previously on Mar 5, 2019
Downgraded to B1 (sf)

Cl. M-3, Downgraded to B3 (sf); previously on Mar 5, 2019
Downgraded to B1 (sf)

Cl. M-4, Downgraded to B3 (sf); previously on Dec 16, 2016Upgraded
to B1 (sf)

Issuer: Encore Credit Receivables Trust 2005-2

Cl. M-3, Downgraded to B2 (sf); previously on Nov 8, 2018
Downgraded to B1 (sf)

Cl. M-4, Downgraded to Caa1 (sf); previously on Nov 8, 2018
Downgraded to B2 (sf)

Issuer: GSAA Home Equity Trust 2005-4

Cl. M-1, Downgraded to Caa1 (sf); previously on Dec 28, 2018
Downgraded to B1 (sf)

Cl. M-2, Downgraded to Caa1 (sf); previously on Dec 28, 2018
Downgraded to B2 (sf)

Issuer: GSAA Home Equity Trust 2005-5

Cl. B-1, Downgraded to Caa1 (sf); previously on May 6, 2019
Upgraded to B2 (sf)

Cl. B-2, Downgraded to Caa1 (sf); previously on May 6, 2019
Upgraded to B2 (sf)

Issuer: GSAA Home Equity Trust 2005-6

Cl. M-1, Downgraded to B2 (sf); previously on Jun 9, 2020
Downgraded to B1 (sf)

Cl. M-2, Downgraded to Caa1 (sf); previously on Jun 9, 2020
Downgraded to B1 (sf)

Cl. M-3, Downgraded to Caa1 (sf); previously on Jun 21, 2018
Upgraded to B1 (sf)

Issuer: GSAA Home Equity Trust 2005-7

Cl. AF-4, Upgraded to Ba1 (sf); previously on Dec 18, 2018 Upgraded
to Caa1 (sf)

Cl. AF-5, Upgraded to Baa3 (sf); previously on Dec 18, 2018
Upgraded to B3 (sf)

Issuer: HomeBanc Mortgage Trust 2005-3

Cl. M-3, Downgraded to Caa1 (sf); previously on Jun 9, 2020
Downgraded to B1 (sf)

Issuer: MASTR Asset Backed Securities Trust 2005-HE1

Cl. M-5, Downgraded to Caa1 (sf); previously on May 15, 2019
Downgraded to B2 (sf)

Cl. M-6, Downgraded to Caa1 (sf); previously on May 15, 2019
Upgraded to B3 (sf)

Issuer: MASTR Asset Backed Securities Trust 2005-WMC1

Cl. M-5, Downgraded to Caa1 (sf); previously on Mar 24, 2017
Upgraded to B1 (sf)

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2005-WMC3

Cl. M-5, Downgraded to Caa1 (sf); previously on May 3, 2016
Upgraded to B2 (sf)

Issuer: New Century Home Equity Loan Trust 2005-3

Cl. M-6, Downgraded to Caa1 (sf); previously on Jul 11, 2018
Upgraded to B3 (sf)

Issuer: Opteum Mortgage Acceptance Corporation, Asset Backed
Pass-Through Certificates, Series 2005-2

Cl. M-6, Downgraded to Caa1 (sf); previously on Apr 13, 2017
Upgraded to B1 (sf)

Cl. M-7, Downgraded to Caa1 (sf); previously on Jun 21, 2019
Upgraded to B2 (sf)

Issuer: Opteum Mortgage Acceptance Corporation, Asset Backed
Pass-Through Certificates, Series 2005-3

Cl. M-3, Downgraded to B3 (sf); previously on Mar 5, 2019
Downgraded to B1 (sf)

Cl. M-4, Downgraded to B3 (sf); previously on Mar 21, 2018 Upgraded
to B1 (sf)

Issuer: Terwin Mortgage Trust, Series TMTS 2005-6HE

Cl. M-5, Upgraded to Aaa (sf); previously on Jan 31, 2020 Upgraded
to Aa3 (sf)

Cl. M-6, Upgraded to B2 (sf); previously on May 18, 2017 Upgraded
to Caa3 (sf)

RATINGS RATIONALE

The rating actions reflect the current levels of credit enhancement
available to the bonds, the recent performance, analysis of the
transaction structures, and Moody's updated loss expectations on
the underlying pools.

The rating upgrades are a result of the improving performance of
the related pools, and/or an increase in credit enhancement
available to the bonds. Each of the upgraded bonds has seen strong
growth in credit enhancement since Moody's last review, which is
the key driver for these upgrades. The credit enhancement has
grown, on average, by 12% for the upgraded tranches over the last
12 months. 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 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.

The rating downgrades are the result of outstanding credit interest
shortfalls that are unlikely to be recouped. Each of the downgraded
bonds has a 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. The size
and length of the outstanding interest shortfalls were considered
in Moody's analysis.

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 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 Upgrades Ratings on 7 Bonds From 4 US RMBS Deals
------------------------------------------------------------
Moody's Ratings has upgraded the ratings of seven bonds from four
US residential mortgage-backed transactions (RMBS), backed by
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: RAMP Series 2005-EFC1 Trust

Cl. M-5, Upgraded to Aaa (sf); previously on Jun 9, 2023 Upgraded
to Aa3 (sf)

Cl. M-6, Upgraded to Ba3 (sf); previously on Jul 17, 2017 Upgraded
to Caa3 (sf)

Issuer: RAMP Series 2005-EFC6 Trust

Cl. M-3, Upgraded to Aaa (sf); previously on Jun 9, 2023 Upgraded
to Aa3 (sf)

Cl. M-4, Upgraded to Baa1 (sf); previously on Nov 17, 2017 Upgraded
to Caa2 (sf)

Issuer: RASC Series 2005-AHL1 Trust

Cl. M-2, Upgraded to A2 (sf); previously on Mar 28, 2017 Upgraded
to Ba3 (sf)

Issuer: Soundview Home Loan Trust 2007-OPT3

Cl. II-A-3, Upgraded to Baa3 (sf); previously on Sep 14, 2022
Upgraded to Ba2 (sf)

Cl. II-A-4, Upgraded to Ba1 (sf); previously on Sep 14, 2022
Upgraded to Ba2 (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.

Each of the upgraded bonds has seen strong growth in credit
enhancement since Moody's last review, which is the key driver for
these upgrades. The credit enhancement has grown, on average, by
10%  for the upgraded tranches over the last 12 months.

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.

In addition, 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, 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.


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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.

                            *********

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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