UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

 WASHINGTON,
D.C. 20549

 FORM 10 K

 (Mark one)

 /X/
ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES

EXCHANGE ACT OF 1934

 For the fiscal year ended
December 31, 2024

OR

 //
TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES

EXCHANGE ACT OF 1934

 For the transition period from
to

 Commission file number: 333-206582-01

 Central Index Key Number of the issuing entity:
0001664682

 Morgan Stanley Capital I Trust 2016-UBS9

 (exact name of issuing entity as specified in its
charter)

 Central Index Key Number of the depositor: 0001547361

 Morgan Stanley Capital I Inc.

 (exact name of the depositor as specified in its
charter)

 Central Index Key Number of the sponsor: 0001541886

 UBS Real Estate Securities Inc.

 (exact names of the sponsors as specified in their
charters)

 Central Index Key Number of the sponsor: 0001541557

 Morgan Stanley Mortgage Capital Holdings LLC

 (exact names of the sponsors as specified in their
charters)

 Central Index Key Number of the sponsor: 0001102113

 Bank of America, National Association

 (exact names of the sponsors as specified in their
charters)

 New York

 38 3991339

 38 3991340

 38 7145096

 (State or other jurisdiction of incorporation or
 organization)

 (I.R.S. Employer Identification Numbers)

 c/o
Computershare Trust Company, National Association, as agent for

 Wells Fargo Bank, National
Association

 9062 Old Annapolis Road

 Columbia, MD

 (Address of principal
executive offices)

 21045

 (Zip Code)

 Telephone number,
including area code:

 (667) 786 1992

 Securities
registered pursuant to Section 12(b) of the Act:

 Title of each class

 Trading Symbol(s)

 Name of each exchange on which registered

 None

 Securities
registered pursuant to Section 12(g) of the Act:

 NONE.

by check mark if the registrant is a well-known seasoned issuer, as defined in
Rule 405 of the Securities Act.

 Yes
___ No X

by check mark if the registrant is not required to file reports pursuant to
Section 13 or Section 15(d) of the Act.

 Yes
___ No X

 Note
- Checking the box above will not relieve any registrant required to file
reports pursuant to Section 13 or 15(d) of the Exchange Act from their
obligations under those Sections.

Indicate by check mark whether the registrant (1) has filed all reports
required to be filed by Section 13 or 15(d) of the Securities Exchange Act of
1934 during the preceding 12 months (or for such shorter period that the
registrant was required to file such reports), and (2) has been subject to such
filing requirements for the past 90 days.

 Yes
X No ___

by check mark whether the registrant has submitted electronically every
Interactive Data File required to be submitted pursuant to Rule 405 of
Regulation S-T (Section 232.405 of this chapter) during the preceding 12 months
(or for such shorter period that the registrant was required to submit such
files).

 Not

by check mark whether the registrant is a large accelerated filer, an
accelerated filer, a non-accelerated filer, a smaller reporting company, or
emerging growth company. See the definitions of "large accelerated
filer", "accelerated filer," "smaller reporting
company," and "emerging growth company" in Rule 12b-2 of the Exchange Act.

 Large
accelerated filer ___

Accelerated filer ___

Non-accelerated filer X (Do not check if a smaller reporting company)

Smaller reporting company ___

 Emerging
growth company ___

 If
an emerging growth company, indicate by check mark if the registrant has
elected not to use the extended transition period for complying with any new or
revised financial accounting standards provided pursuant to Section 13(a) of
the Ex change Act.

 Not

 Indicate by check mark whether the registrant has filed
a report on and attestation to its management's assessment of the effectiveness
of its internal control over financial reporting under Section 404(b) of the
Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm
that prepared or issued its audit report.

 Not

 If
securities are registered pursuant to Section 12(b) of the Act, indicate by
check mark whether the financial statements of the

 registrant
included in the filing reflect the correction of an error to previously issued
financial statements.

 Not

by check mark whether any of those error corrections are restatements that
required a recovery analysis of incentive-based compensation received by any of
the registrant's executive officers during the relevant recovery period
pursuant to §240.10D-1(b).

 Not

by check mark whether the registrant is a shell company (as defined in Rule
12b-2 of the Act).

 Yes
___ No X

 State
the aggregate market value of the voting and non-voting common equity held by
non-affiliates computed by reference to the price at which the common equity
was last sold, or the average bid and asked price of such common equity, as of
the last business day of the registrant's most recently completed second fiscal
quarter.

 Not

by check mark whether the registrant has filed all documents and reports
required to be filed by Section 12, 13 or 15(d) of the Securities Exchange Act
of 1934 subsequent to the distribution of securities under a plan confirmed by
a court.

 Not

the number of shares outstanding of each of the registrant's classes of common
stock, as of the latest practicable date.

 Not

 DOCUMENTS
INCORPORATED BY REFERENCE

 List
hereunder the following documents if incorporated by reference and the Part of
the Form 10-K (e.g., Part I, Part II, etc.) into which the document is
incorporated: (1)Any annual report to security holders; (2) Any proxy or
information statement; and (3)Any prospectus filed pursuant to Rule 424(b) or
(c) under the Securities Act of 1933. The listed documents should be clearly
described for identification purposes (e.g., annual report to security holders
for fiscal year ended December 24, 1980).

 Not

 EXPLANATORY NOTES

 The MSC
2016-UBS9 mortgage pool includes the following mortgage loans, each of which is
serviced pursuant to a separate pooling and servicing agreement (each, an
"Outside Pooling and Servicing Agreement"):

 the 525 Seventh Avenue mortgage loan and
the Ellenton Premium Outlets mortgage loan, which are serviced pursuant to the
MSC 2015-UBS8 pooling and servicing agreement attached hereto as Exhibit 4.2;

 the Princeton Pike Corporate Center
mortgage loan, which is serviced pursuant to the MSBAM 2016-C28 pooling and
servicing agreement attached hereto as Exhibit 4.3;

 the Gulfport Premium Outlets mortgage loan,
which is serviced pursuant to the MSBAM 2016-C29 pooling and servicing
agreement attached hereto as Exhibit 4.4;

the Twenty Ninth Street Retail mortgage loan, which is serviced pursuant to the
GSMS 2016-GS2 pooling and servicing agreement attached hereto as Exhibit 4.5;
and

 the
Grove City Premium Outlets mortgage loan, which is serviced pursuant to the
BACM 2016-UBS10 pooling and servicing agreement attached hereto as Exhibit 4.6.

 Except as
set forth below, each of the parties to each pooling and servicing agreement
listed in the Exhibit Index both (1) participates in the servicing function for
purposes of Item 1122 of Regulation AB and (2) constitutes a servicer that
meets the criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB for
purposes of Item 1123 of Regulation AB:

 The trustee under a pooling and servicing
agreement has a nominal role with respect to the mortgage pool securitized
pursuant to such pooling and servicing agreement. The trustee's only servicing
function is the contingent obligation to make certain advances if the master
servicer under such pooling and servicing agreement fails to do so, while all
other servicing functions are performed by other parties. The trustee under
each of the pooling and servicing agreements listed in the Exhibit Index has
confirmed to the registrant that it has not made any such contingent advances
during the reporting period, and consequently, each such trustee does not
participate in the servicing function for purposes of Item 1122 of Regulation
AB, nor does it perform the functions of a servicer for purposes of the
definition of "servicer" under Item 1101 of Regulation AB or for purposes of
Item 1123 of Regulation AB.

 The certificate administrator under a
pooling and servicing agreement performs various payment administration
functions solely for the securitization governed by such pooling and servicing
agreement and the mortgage pool securitized pursuant to such pooling and
servicing agreement and does not have any obligations with respect to any other
transaction. Consequently, the certificate administrator under an Outside
Pooling and Servicing Agreement does not participate in the servicing function
for purposes of Item 1122 of Regulation AB, nor does it perform the functions
of a servicer for purposes of the definition of "servicer" under Item 1101 of
Regulation AB or for purposes of Item 1123 of Regulation AB.

 The operating advisor under a pooling and
servicing agreement represents the interests of senior certificateholders in
the transaction governed by such pooling and servicing agreement and is
responsible for monitoring the performance of the special servicer under such
pooling and servicing agreement and producing certain reports to
certificateholders relating to the resolution of the mortgage pool securitized
pursuant to such pooling and servicing agreement. The operating advisor under a
pooling and servicing agreement does not have any obligations with respect to
any other transaction and is solely obligated to perform loan reporting
functions with respect to the securitization governed by such pooling and
servicing agreement. Consequently, the operating advisor under an Outside
Pooling and Servicing Agreement neither participates in the servicing function
for purposes of Item 1122 of Regulation AB nor performs the functions of a
servicer for purposes of the definition of "servicer" under Item 1101 of
Regulation AB or for purposes of Item 1123 of Regulation AB. In addition, while
the operating advisor under a pooling and servicing agreement has certain
reporting obligations in respect of the related mortgage pool, it has no
obligation to collect or disburse funds in respect of the mortgage pool or to
administer any of the underlying mortgage loans. Consequently, the operating
advisor under a pooling and servicing agreement participates in the servicing
function for purposes of Item 1122 of Regulation AB, but is not responsible for
the "management or collection of the pool assets or making allocations or
distributions to holders of the asset-backed securities" within the meaning of
"servicer" under Item 1101 of Regulation AB and does not perform the functions
of a servicer for purposes of Item 1123 of Regulation AB.

 The asset representations reviewer under a
pooling and servicing agreement has a limited obligation to review certain
delinquent mortgage loans after a specified delinquency threshold has been met
and the required percentage of certificateholders vote to direct a review of
such delinquent mortgage loans, and has no obligation to collect or disburse
funds in respect of the mortgage pool, to administer any of the underlying
mortgage loans or to perform any servicing function. Consequently, the
asset representations reviewer under a pooling and servicing agreement does not
participate in the servicing function for purposes of Item 1122 of Regulation
AB, is not responsible for the "management or collection of the pool assets or
making allocations or distributions to holders of the asset-backed securities"
within the meaning of "servicer" under Item 1101 of Regulation AB and does not
perform the functions of a servicer for purposes of Item 1123 of Regulation AB.

 LNR Partners,
LLC is the current special servicer under the GSMS 2016-GS2 pooling and
servicing agreement, pursuant to which the Twenty Ninth Street Retail mortgage
loan is serviced. In November 2019, Torchlight Loan Services, LLC was replaced
as special servicer under the GSMS 2016-GS2 pooling and servicing agreement and
succeeded by LNR Partners, LLC. Because LNR Partners, LLC is not the MSC
2016-UBS9 special servicer, is not affiliated with any sponsor and services
only the Twenty Ninth Street Retail mortgage loan, which constitutes more than
5% but less than 10% of the mortgage pool, LNR Partners, LLC, as GSMS 2016-GS2
special servicer, constitutes a reporting "servicing function participant" for
purposes of Item 1122 of Regulation AB, as specified in the Instruction 3 to
Item 1122, but does not constitute a reporting "servicer" for purposes of Item
1123 of Regulation AB, as specified in the Instruction to Item 1123.

 • Rialto
Capital Advisors, LLC, as Veritas Multifamily Pool 2 special servicer under the
GSMS 2016-GS2 pooling and servicing agreement, only has obligations in respect
of Veritas Multifamily Pool 2 mortgage loan securitized thereunder. Rialto
Capital Advisors, LLC, as Veritas Multifamily Pool 2 special servicer under the
GSMS 2016-GS2 pooling and servicing agreement, has no obligations with respect
to any mortgage loan included in the MSC 2016-UBS9 mortgage pool and therefore
such party in such capacity does not constitute a reporting "servicing function
participant" for purposes of Item 1122 of Regulation AB, as specified in the
Instruction 3 to Item 1122, and does not constitute a reporting "servicer" for
purposes of Item 1123 of Regulation AB, as specified in the Instruction to Item
1123.

 Greystone Servicing Company LLC is
the current special servicer under the MSBAM 2016-C28 pooling and servicing
agreement, pursuant to which the Princeton Pike Corporate Center mortgage loan
is serviced. On August 26, 2020, C-III Asset Management LLC was replaced as
special servicer under the MSBAM 2016-C28 pooling and servicing agreement and
was succeeded by Greystone Servicing Company LLC, to which C-III Asset
Management assigned substantially all of its assets. Because Greystone
Servicing Company LLC is not the MSC 2016-UBS9 special servicer, is not
affiliated with any sponsor and serviced only the Princeton Pike Corporate
Center mortgage loan, which constitutes more than 5% but less than 10% of the
mortgage pool, Greystone Servicing Company LLC, as MSBAM 2016-C28 special
servicer, constitutes a reporting "servicing function participant" for purposes
of Item 1122 of Regulation AB, as specified in the Instruction 3 to Item 1122,
but does not constitute a reporting "servicer" for purposes of Item 1123 of
Regulation AB, as specified in the Instruction to Item 1123.

 The GLP Industrial Portfolio B
mortgage loan, which was serviced pursuant to the CSMC 2015-GLPB pooling and
servicing agreement, was paid in full on September 26, 2019.

 In
addition, each of the following parties engaged the services of certain
servicing function participants and sub-servicers for the reporting period, as
set forth below:

 KeyBank National Association, as master
servicer, engaged the services of Berkadia Commercial Mortgage LLC, as a
sub-servicer in respect of the entire mortgage pool for the reporting
period.

master servicer under the MSBAM 2016-C28 pooling and servicing agreement,
pursuant to which the Princeton Pike Corporate Center mortgage loan is
serviced, engaged the services of CoreLogic Solutions, LLC as a servicing
function participant in respect of the Princeton Pike Corporate Center mortgage
loan for the reporting period.

master servicer under the BACM 2016-UBS10 pooling and servicing agreement,
pursuant to which the Grove City Premium Outlets mortgage loan is serviced,
engaged the services of Midland Loan Services, a Division of PNC Bank, National
Association as sub-servicer, and CoreLogic Solutions, LLC, each as a servicing
function participant, in each case in respect of the Grove City Premium Outlets
mortgage loan for the reporting period.

 Wells Fargo Bank, National Association, as master servicer
under the MSBAM 2016-C29 pooling and servicing agreement, pursuant to which the
Gulfport Premium Outlets mortgage loan is serviced, engaged the services of
Midland Loan Services, a Division of PNC Bank, National Association as
sub-servicer, and CoreLogic Solutions, LLC, each as a servicing function
participant, in each case in respect of the Gulfport Premium Outlets mortgage
loan for the reporting period.

 On November 1, 2021, pursuant to the second amended and
restated servicing agreement attached hereto as Exhibit 99.15, Computershare
Trust Company, National Association was engaged to perform all or virtually all
of Wells Fargo Bank, National Association's roles as certificate administrator,
custodian and trustee, as applicable, under (i) the pooling and servicing
agreement and (ii) each Outside Pooling and Servicing Agreement

 Item 1.

 Business.

 Item 1A.

 Risk Factors.

 Item 1B.

 Unresolved Staff
 Comments.

 None.

 Item 1C.

 Cybersecurity.

 Item 2.

 Properties.

 Item 3.

 Legal Proceedings.

 Item 4.

 Mine Safety Disclosures.

 Item 5.

 Market for Registrant's
 Common Equity, Related Stockholder Matters and Issuer Purchases of Equity
 Securities.

 Item 6.

 [Reserved]

 Item 7.

 Management's Discussion
 and Analysis of Financial Condition and Results of Operations.

 Item 7A.

 Quantitative and
 Qualitative Disclosures About Market Risk.

 Item 8.

 Financial Statements and
 Supplementary Data.

 Item 9.

 Changes in and
 Disagreements With Accountants on Accounting and Financial Disclosure.

 Item 9A.

 Controls and Procedures.

 Item 9B.

 Other Information.

 None.

 Item 9C.

 Disclosure Regarding
 Foreign Jurisdictions that Prevent Inspections.

 None.

 Item 10.

 Directors, Executive
 Officers and Corporate Governance.

 Item 11.

 Executive Compensation.

 Item 12.

 Security Ownership of
 Certain Beneficial Owners and Management and Related Stockholder Matters.

 Item 13.

 Certain Relationships and
 Related Transactions, and Director Independence.

 Item 14.

 Principal Accountant Fees
 and Services.

 ADDITIONAL
DISCLOSURE ITEMS FOR REGULATION AB

 Item
1112(b) of Regulation AB, Significant Obligor Financial Information.

 Not

 Item
1114(b)(2) of Regulation AB, Significant Enhancement Provider Financial
Information.

 No entity
or group of affiliated entities provides any enhancement or other support for
the certificates as described under Item 1114 (a) of Regulation AB.

 Item
1115(b) of Regulation AB, Certain Derivatives Instruments (Financial
Information).

 No
entity or group of affiliated entities provides any derivative instruments for
the certificates as described under Item 1115 of Regulation AB.

 Item
1117 of Regulation AB, Legal Proceedings.

 The registrant knows of no legal
proceeding pending against the sponsors, depositor, trustee, issuing entity,
servicer contemplated by Item 1108(a)(3) of Regulation AB, originator
contemplated by Item 1110(b) of Regulation AB, or other party contemplated by
Item 1100(d)(1) of Regulation AB, or of which any property of the foregoing is
the subject, that is material to security holders, other than as follows:

 In
December 2014, Phoenix Light SF Limited (Phoenix Light) and certain related
entities filed a complaint in the United States District Court for the Southern
District of New York alleging claims against Wells Fargo Bank, N.A., in its
capacity as trustee for a number of residential mortgage-backed securities
(RMBS) trusts. Complaints raising similar allegations have been filed by
Commerzbank AG in the Southern District of New York, IKB International and IKB
Deutsche Industriebank (together, IKB) in New York state court, and Park Royal
I LLC and Park Royal II LLC in New York state court. In each case, the
plaintiffs allege that Wells Fargo Bank, N.A., as trustee, caused losses to
investors, and plaintiffs assert causes of action based upon, among other things,
the trustee's alleged failure to notify and enforce repurchase obligations of
mortgage loan sellers for purported breaches of representations and warranties,
notify investors of alleged events of default, and abide by appropriate
standards of care following alleged events of default. In July 2022, the
district court dismissed Phoenix Light's claims and certain of the claims
asserted by Commerzbank AG, and subsequently entered judgment in each case in
favor of Wells Fargo Bank, N.A. In August 2022, Phoenix Light and Commerzbank
AG each appealed the district court's decision to the United States Court of
Appeals for the Second Circuit. Phoenix Light dismissed its appeal in May 2023,
terminating its case. In October 2024, the Second Circuit denied Commerzbank
AG's appeal. In November 2023, Wells Fargo Bank, N.A. entered into an agreement
with IKB to resolve IKB's claims. Wells Fargo Bank, N.A. previously settled two
class actions filed by institutional investors and an action filed by the
National Credit Union Administration with similar allegations.

 From time to time, CWCapital Asset Management LLC, a
Delaware limited liability company ("CWCAM"), is a party to lawsuits and other
legal proceedings as part of its duties as a special servicer (e.g.,
enforcement of loan obligations) and/or arising in the ordinary course of
business. Other than as set forth in the following paragraphs, there are
currently no legal proceedings pending, and no legal proceedings known to be
contemplated by governmental authorities, against CWCAM or of which any of its
property is the subject, that are material to the certificateholders.

 On December 17, 2015, U.S. Bank National Association, the
trustee under five pooling and servicing agreements for (i) Wachovia Bank
Commercial Mortgage Trust 2007-C30, (ii) COBALT CMBS Commercial Trust 2007-C2,
(iii) Wachovia Bank Commercial Mortgage Trust 2007-C31, (iv) ML-CFC Commercial
Mortgage Trust 2007-5 and (v) ML-CFC Commercial Mortgage Trust 2007-6 commenced
a proceeding with the Second Judicial District Court of Ramsey County,
Minnesota (the "State Court") for a declaratory judgment as to the proper
allocation of certain proceeds ("Disputed Proceeds") received by CWCAM in
connection with the sale of the Peter Cooper Village and Stuyvesant Town
property in New York, New York securing loans held by those trusts. CWCAM was
the special servicer of such property. The petition requests the State Court to
instruct the trustee, the trust beneficiaries, and any other interested parties
as to the amount of the Disputed Proceeds, if any, that constitute penalty
interest and/or the amount of the Disputed Proceeds, if any, that constitute
gain-on-sale proceeds, with respect to each trust. On February 24, 2016, CWCAM
made a limited appearance with the State Court to file a motion to dismiss this
proceeding based on lack of jurisdiction, mootness, standing and forum non
conveniens. On July 19, 2016, the State Court denied CWCAM's motion to dismiss.
On July 22, 2016, the action was removed to federal court in Minnesota
("Federal Court"). On October 21, 2016, the Federal Court held a hearing on the
motion to transfer the action to the United States District Court for the
Southern District of New York ("SDNY Court"), a motion to remand to state court
and a motion to hear CWCAM's request for reconsideration of the motion to
dismiss. On March 14, 2017, the Federal Court reserved the determination on the
motion to hear CWCAM's request for reconsideration of the motion to dismiss,
denied the motion to remand the matter to state court and granted the motion to
transfer the proceeding to the SDNY Court. Cross motions for judgment on the
pleadings were filed but the SDNY Court was unable to decide the case based on
the pleadings and the SDNY Court ordered discovery. All fact discovery was
completed in December, 2018 and expert discovery was completed on March 15,
2019. The parties submitted cross motions for summary judgment, and on March
19, 2020, the SDNY Court entered an opinion and order in which it granted
summary judgment in CWCAM's favor and held that CWCAM was entitled to the
entire amount of penalty interest and that CWCAM's determination of Yield
Maintenance was correct. In the 127-page opinion, the SDNY Court found for
CWCAM on every issue presented by the trustee's petition, namely, that the
funds in dispute constitute penalty interest and yield maintenance, not gain-on-sale
proceeds, and that the amount of penalty interest and yield maintenance was
correctly calculated. An appeal of the SDNY Court's decision was taken on April
29, 2020. Oral argument on the appeal occurred on June 21, 2021. On July 14,
2022, the Second Circuit entered a decision affirming in part and reversing in
part the SDNY Court's decision and remanding to the SDNY Court for further
proceedings. The Second Circuit affirmed the SDNY's Court holding that Penalty
Interest and Yield Maintenance are paid before Gain-On-Sale Proceeds. The
Second Circuit reversed and remanded for further proceedings that portion of
the SDNY Court's decision related to approximately $67.2 million in interest on
advances. On January 13, 2023, the parties entered into a settlement agreement,
in which (among other things) they agreed to stipulate that the amount of
interest on advances that accrued on or before June 3, 2014 is $27.5 million,
and that CWCAM would pay that amount into escrow for distribution to
certificateholders upon the entry of an order by the Court approving the
settlement. U.S. Bank National Association, as Trustee for the trusts, provided
notice of the settlement to all parties in interest via a notice program
approved by the Court. A hearing on the settlement is scheduled for March 16,
2023.

 On December 1, 2017, a complaint against CWCAM and others
was filed in the United States District Court for the Southern District of New
York styled as CWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al.,
No. 17-cv-9463 (the "Original Complaint"). The gravamen of the Original
Complaint alleged breaches of a contract and fiduciary duties by CWCAM's
affiliate, CWCapital Investments LLC in its capacity as collateral manager for
the collateralized debt obligation transaction involving CWCapital Cobalt Vr,
Ltd. In total, there are 14 counts pled in the Original Complaint. Of those 14,
5 claims were asserted against CWCAM for aiding and abetting breach of
fiduciary duty, conversion and unjust enrichment. On May 23, 2018, the Original
Complaint was dismissed for lack of subject matter jurisdiction. On June 28,
2018, CWCapital Cobalt Vr Ltd. filed a substantially similar complaint in the
Supreme Court of the State of New York, County of New York styled as CWCapital
Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., Index No. 653277/2018 (the
"New Complaint"). The gravamen of the New Complaint is the same as the previous
complaint filed in the United State District Court for the Southern District of
New York. In total there are 16 counts pled in the New Complaint. Of those 16
counts, 5 claims were asserted against CWCAM for aiding and abetting breach of
fiduciary duty, conversion and unjust enrichment, 1 count seeks a declaratory
judgement that the plaintiff has the right to enforce the contracts in question
and 1 count seeks an injunction requiring the defendants to recognize the
plaintiff as the directing holder for the trusts in question. On January 11,
2019, the plaintiff dismissed with prejudice the declaratory judgment and
injunction counts. The New Complaint and related summons was not served on the
defendants until July 13, 2018 and July 16, 2018. The plaintiff's motion for a
preliminary injunction was denied by the court on July 31, 2018. On August 3,
2018, the defendants, including CWCAM, filed a motion to dismiss the New
Complaint in its entirety. On August 20, 2019, the court entered an order
granting defendants' motion almost in its entirety, dismissing 11 of the 16
counts and partially dismissing 2 additional counts. Of the remaining counts, 2
are asserted against CWCAM for aiding and abetting breach of fiduciary duty and
unjust enrichment. On September 19, 2019, CWCapital Cobalt Vr Ltd. filed a
notice of appeal relating to the August 20, 2019 dismissal order and on
September 26, 2019, filed an amended complaint against CWCI and CWCAM
attempting to address deficiencies relating to certain of the claims dismissed
by the August 20, 2019 order. CWCI and CWCAM filed its Motion to Dismiss the
amended complaint on October 28, 2019. The court heard argument on the Motion
to Dismiss the amended complaint on January 22, 2020 and on October 23, 2020,
the court granted the motion dismissing the amended claims. On November 30,
2020, CWCapital Cobalt Vr Ltd filed a notice of appeal relating to the October
23, 2020 dismissal order. On April 27, 2021, the First Department affirmed the
dismissal as to claims against CWCAM that were part of the August 20, 2019
dismissal, but reversed the dismissal of two counts for breach of the
Collateral Management Agreement against CWCI. CWCI sought leave to file an
appeal of the decision. The plaintiff also sought leave to appeal the dismissal
of the claims against CWCAM. Both requests for leave were denied by the First
Department. On May 15, 2020, CWCI and CWCAM filed a motion to renew its motion
to dismiss as to 4 of the remaining counts (including the remaining two counts
against CWCAM for aiding and abetting breach of fiduciary duty and unjust
enrichment), based on a decision entered by Judge Failla in a trust instruction
proceeding in the US District Court for the Southern District of New York
awarding summary judgment in favor of CWCAM. On September 7, 2021, the court
denied the motion to renew. CWCI and CWCAM filed a notice of appeal, which they
perfected by the filing of their opening brief on July 1, 2022. On November 15,
2022, the First Department affirmed the court's denial of the motion to renew.
On October 1, 2021, CWCI and CWCAM moved to reargue the denial of the motion to
renew (or alternatively, the motion to dismiss) with respect to certain of
Cobalt's claims, including the remaining 2 claims against CWCAM, based on the
First Department's April 27, 2021 decision. On March 24, 2022, the court denied
the relief sought in the motion to reargue. CWCI and CWCAM have appealed the
court's decision on the motion to reargue and filed their opening brief on July
11, 2022. The appeal was dismissed as being nonappealable on August 30, 2022.
CWCAM believes that it has performed its obligations under the related pooling
and servicing agreements in good faith and the remaining allegations in the New
Complaint are without merit.

 Item
1119 of Regulation AB, Affiliations and Certain Relationships and Related
Transactions.

 The
information regarding this Item has been provided previously in an annual
report on Form 10-K of the issuing entity or in the prospectus of the issuing
entity filed in a 424(b)(2) filing dated March 9, 2016.

 Item
1122 of Regulation AB, Compliance with Applicable Servicing Criteria.

 The
reports on assessment of compliance with the servicing criteria for
asset-backed securities and the related attestation reports on such assessments
of compliance are attached hereto under Item 15.

 Item
1123 of Regulation AB, Servicer Compliance Statement.

 The
servicer compliance statements are attached hereto under Item 15.

 Item
15. Exhibits, Financial Statement Schedules.

 (a) Exhibits.

 (4.1)
 Pooling and Servicing Agreement, dated as of March 1,
2016, between Morgan Stanley Capital I Inc., as depositor, KeyBank National
Association, as master servicer, CWCapital Asset Management LLC, as special
servicer, Park Bridge Lender Services LLC, as operating advisor and asset
representations reviewer, and Wells Fargo Bank, National Association, as
trustee, certificate administrator, certificate registrar, authenticating agent
and custodian (filed as Exhibit 4.1 to the registrant's Current Report on Form 8-K/A
filed on March 16, 2016 under SEC File No. 333-206582-01 and incorporated by
reference herein).

 (4.2)
 Pooling and Servicing Agreement, dated as of December
1, 2015, between Morgan Stanley Capital I Inc., as depositor, Midland Loan
Services, a division of PNC Bank, National Association, as master servicer,
Rialto Capital Advisors, LLC, as special servicer, Situs Holdings, LLC, as
trust advisor, and Wells Fargo Bank, National Association, as trustee,
certificate administrator and custodian, relating to the MSC 2015-UBS8
securitization transaction, pursuant to which the 525 Seventh Avenue Mortgage
Loan and the Ellenton Premium Outlets Mortgage Loan are serviced (filed as
Exhibit 4.2 to the registrant's Current Report on Form 8-K filed on March 9,
2016 under SEC File No. 333-206582-01 and incorporated by reference herein).

 (4.3)
 Pooling and Servicing Agreement, dated as of February
1, 2016, between Banc of America Merrill Lynch Commercial Mortgage Inc., as
depositor, Wells Fargo Bank, National Association, as master servicer, C-III
Asset Management LLC, as special servicer, Wells Fargo Bank, National
Association, as certificate administrator, U.S. Bank National Association, as
trustee, Park Bridge Lender Services LLC, as operating advisor, and Park Bridge
Lender Services LLC, as asset representations reviewer, relating to the MSBAM
2016-C28 securitization transaction, pursuant to which the Princeton Pike
Corporate Center Mortgage Loan is serviced (filed as Exhibit 4.4 to the
registrant's Current Report on Form 8-K filed on March 9, 2016 under SEC File
No. 333-206582-01 and incorporated by reference herein).

 (4.4)
 Pooling and Servicing Agreement, dated as of May 1,
2016, between Morgan Stanley Capital I Inc., as depositor, Wells Fargo Bank,
National Association, as master servicer, Rialto Capital Advisors, LLC, as
special servicer, Park Bridge Lender Services LLC, as operating advisor and
asset representations reviewer, Wells Fargo Bank, National Association, as
custodian, certificate administrator, certificate registrar and authenticating
agent, and Wilmington Trust, National Association, as trustee, relating to the
MSBAM 2016-C29 securitization transaction, pursuant to which the Gulfport
Premium Outlets Mortgage Loan is serviced (filed as Exhibit 4.5 to the
registrant's Current Report on Form 8-K filed on May 11, 2016 under SEC File
No. 333-206582-01 and incorporated by reference herein).

 (4.5)
 Pooling and Servicing Agreement, dated as of May 1,
2016, between GS Mortgage Securities Corporation II, as depositor, Midland Loan
Services, a Division of PNC Bank, National Association, as master servicer,
Torchlight Loan Services, LLC, as a special servicer, Rialto Capital Advisors,
LLC, as a special servicer, Pentalpha Surveillance LLC, as operating advisor
and asset representations reviewer, and Wells Fargo Bank, National Association,
as trustee, custodian, certificate administrator, certificate registrar and
authenticating agent, relating to the GSMS 2016-GS2 securitization transaction,
pursuant to which the Twenty Ninth Street Retail Mortgage Loan is serviced
(filed as Exhibit 4.6 to the registrant's Current Report on Form 8-K filed on
June 6, 2016 under SEC File No. 333-206582-01 and incorporated by reference
herein).

 (4.6)
 Pooling and Servicing Agreement, dated as of June 1,
2016, between Banc of America Merrill Lynch Commercial Mortgage Inc., as
depositor, Wells Fargo Bank, National Association, as master servicer, Rialto
Capital Advisors, LLC, as special servicer, Park Bridge Lender Services LLC, as
operating advisor and asset representations reviewer, Wells Fargo Bank,
National Association, as custodian, certificate administrator, certificate
registrar and authenticating agent, and Wilmington Trust, National Association,
as trustee, relating to the BACM 2016-UBS10 securitization transaction,
pursuant to which the Grove City Premium Outlets Mortgage Loan is serviced
(filed as Exhibit 4.7 to the registrant's Current Report on Form 8-K filed on
June 13, 2016 under SEC File No. 333-206582-01 and incorporated by reference
herein).

 (31) Rule
13a-14(d)/15d-14(d) Certification.

 (33)
Reports on assessment of compliance with servicing criteria for asset-backed
securities.

 33.1 Wells Fargo Bank,
National Association, as Certificate Administrator

 33.2
as Servicing Function Participant for the Certificate Administrator

 33.3
Custodian

 33.4
as Servicing Function Participant for the Custodian

 33.5
 KeyBank National Association, as Master Servicer

 33.6
 CWCapital Asset Management LLC, as Special Servicer

 33.7
 Park Bridge Lender Services LLC, as Operating
Advisor

 33.8
 Berkadia Commercial Mortgage LLC, as Primary
Servicer

 33.9
National Association, as Master Servicer under the MSC 2015-UBS8
such party: 525 Seventh Avenue (from 1/1/24 to 12/31/24) and Ellenton Premium
Outlets (from 1/1/24 to 12/31/24)

 33.10

 33.11
Participant under the MSBAM 2016-C28 securitization, pursuant to which the

 33.12
National Association, as Master Servicer under the GSMS 2016-GS2
such party: Twenty Ninth Street Retail (from 1/1/24 to 12/31/24) (see exhibit
33.9)

 33.13
Servicer under the BACM 2016-UBS10 securitization, pursuant to which the
Outlets (from 1/1/24 to 12/31/24) (see exhibit 33.10)

 33.14
National Association, as Sub-Servicer under the BACM 2016-UBS10 securitization,
Grove City Premium Outlets (from 1/1/24 to 12/31/24) (see exhibit 33.9)

 33.15
Participant under the BACM 2016-UBS10 securitization, pursuant to which the
Outlets (from 1/1/24 to 12/31/24) (see exhibit 33.11)

 33.16
Servicer under the MSBAM 2016-C29 securitization, pursuant to which the
(from 1/1/24 to 12/31/24) (see exhibit 33.10)

 33.17
National Association, as Sub-Servicer under the MSBAM 2016-C29 securitization,
Gulfport Premium Outlets (from 1/1/24 to 12/31/24) (see exhibit 33.9)

 33.18
Participant under the MSBAM 2016-C29 securitization, pursuant to which the
(from 1/1/24 to 12/31/24) (see exhibit 33.11)

 33.19
under the MSC 2015-UBS8 securitization, pursuant to which the following
mortgage loans were serviced by such party: 525 Seventh Avenue (from 1/1/24 to
12/31/24) and Ellenton Premium Outlets (from 1/1/24 to 12/31/24)

 33.20
 Greystone Servicing Company LLC, as Special

 33.21
 LNR Partners, LLC, as Special Servicer under the
GSMS 2016-GS2 securitization, pursuant to which the following mortgage loans
were serviced by such party: Twenty Ninth Street Retail (from 1/1/24 to
12/31/24)

 33.22
under the BACM 2016-UBS10 securitization, pursuant to which the following
mortgage loans were serviced by such party: Grove City Premium Outlets (from
1/1/24 to 12/31/24) (see exhibit 33.19)

 33.23
 Rialto Capital Advisors, LLC, as Special Servicer under
the MSBAM 2016-C29 securitization, pursuant to which the following mortgage
loans were serviced by such party: Gulfport Premium Outlets (from 1/1/24 to
12/31/24) (see exhibit 33.19)

 33.24
Custodian under the MSC 2015-UBS8 securitization, pursuant to which the
following mortgage loans were serviced by such party: 525 Seventh Avenue (from
1/1/24 to 12/31/24) and Ellenton Premium Outlets (from 1/1/24 to 12/31/24) (see
exhibit 33.3)

 33.25
as Servicing Function Participant under the MSC 2015-UBS8 securitization,
pursuant to which the following mortgage loans were serviced by such party: 525
Seventh Avenue (from 1/1/24 to 12/31/24) and Ellenton Premium Outlets (from
1/1/24 to 12/31/24) (see exhibit 33.4)

 33.26
Custodian under the MSBAM 2016-C28 securitization, pursuant to which the
Center (from 1/1/24 to 12/31/24) (see exhibit 33.3)

 33.27
as Servicing Function Participant under the MSBAM 2016-C28 securitization,
Princeton Pike Corporate Center (from 1/1/24 to 12/31/24) (see exhibit 33.4)

 33.28
Custodian under the GSMS 2016-GS2 securitization, pursuant to which the
following mortgage loans were serviced by such party: Twenty Ninth Street
Retail (from 1/1/24 to 12/31/24) (see exhibit 33.3)

 33.29
as Servicing Function Participant under the GSMS 2016-GS2 securitization,
Twenty Ninth Street Retail (from 1/1/24 to 12/31/24) (see exhibit 33.4)

 33.30
Custodian under the BACM 2016-UBS10 securitization, pursuant to which the
Outlets (from 1/1/24 to 12/31/24) (see exhibit 33.3)

 33.31
as Servicing Function Participant under the BACM 2016-UBS10 securitization,
Grove City Premium Outlets (from 1/1/24 to 12/31/24) (see exhibit 33.4)

 33.32
Custodian under the MSBAM 2016-C29 securitization, pursuant to which the
(from 1/1/24 to 12/31/24) (see exhibit 33.3)

 33.33
as Servicing Function Participant under the MSBAM 2016-C29 securitization,
Gulfport Premium Outlets (from 1/1/24 to 12/31/24) (see exhibit 33.4)

 (34) Attestation
reports on assessment of compliance with servicing criteria for asset-backed
securities.

 34.1
Certificate Administrator

 34.2
as Servicing Function Participant for the Certificate Administrator

 34.3
Custodian

 34.4
as Servicing Function Participant for the Custodian

 34.5
 KeyBank National Association, as Master Servicer

 34.6
 CWCapital Asset Management LLC, as Special Servicer

 34.7
 Park Bridge Lender Services LLC, as Operating
Advisor

 34.8
 Berkadia Commercial Mortgage LLC, as Primary
Servicer

 34.9
National Association, as Master Servicer under the MSC 2015-UBS8
such party: 525 Seventh Avenue (from 1/1/24 to 12/31/24) and Ellenton Premium
Outlets (from 1/1/24 to 12/31/24)

 34.10

 34.11
Participant under the MSBAM 2016-C28 securitization, pursuant to which the

 34.12
National Association, as Master Servicer under the GSMS 2016-GS2
such party: Twenty Ninth Street Retail (from 1/1/24 to 12/31/24) (see exhibit
34.9)

 34.13
Servicer under the BACM 2016-UBS10 securitization, pursuant to which the
Outlets (from 1/1/24 to 12/31/24) (see exhibit 34.10)

 34.14
National Association, as Sub-Servicer under the BACM 2016-UBS10 securitization,
Grove City Premium Outlets (from 1/1/24 to 12/31/24) (see exhibit 34.9)

 34.15
Participant under the BACM 2016-UBS10 securitization, pursuant to which the
Outlets (from 1/1/24 to 12/31/24) (see exhibit 34.11)

 34.16
Servicer under the MSBAM 2016-C29 securitization, pursuant to which the
(from 1/1/24 to 12/31/24) (see exhibit 34.10)

 34.17
National Association, as Sub-Servicer under the MSBAM 2016-C29 securitization,
Gulfport Premium Outlets (from 1/1/24 to 12/31/24) (see exhibit 34.9)

 34.18
Participant under the MSBAM 2016-C29 securitization, pursuant to which the
(from 1/1/24 to 12/31/24) (see exhibit 34.11)

 34.19
under the MSC 2015-UBS8 securitization, pursuant to which the following
mortgage loans were serviced by such party: 525 Seventh Avenue (from 1/1/24 to
12/31/24) and Ellenton Premium Outlets (from 1/1/24 to 12/31/24)

 34.20
 Greystone Servicing Company LLC, as Special

 34.21
 LNR Partners, LLC, as Special Servicer under the
GSMS 2016-GS2 securitization, pursuant to which the following mortgage loans
were serviced by such party: Twenty Ninth Street Retail (from 1/1/24 to
12/31/24)

 34.22
under the BACM 2016-UBS10 securitization, pursuant to which the following
mortgage loans were serviced by such party: Grove City Premium Outlets (from
1/1/24 to 12/31/24) (see exhibit 34.19)

 34.23
under the MSBAM 2016-C29 securitization, pursuant to which the following
mortgage loans were serviced by such party: Gulfport Premium Outlets (from
1/1/24 to 12/31/24) (see exhibit 34.19)

 34.24
Custodian under the MSC 2015-UBS8 securitization, pursuant to which the
following mortgage loans were serviced by such party: 525 Seventh Avenue (from
1/1/24 to 12/31/24) and Ellenton Premium Outlets (from 1/1/24 to 12/31/24) (see
exhibit 34.3)

 34.25
as Servicing Function Participant under the MSC 2015-UBS8 securitization,
pursuant to which the following mortgage loans were serviced by such party: 525
Seventh Avenue (from 1/1/24 to 12/31/24) and Ellenton Premium Outlets (from
1/1/24 to 12/31/24) (see exhibit 34.4)

 34.26
Custodian under the MSBAM 2016-C28 securitization, pursuant to which the
Center (from 1/1/24 to 12/31/24) (see exhibit 34.3)

 34.27
as Servicing Function Participant under the MSBAM 2016-C28 securitization,
Princeton Pike Corporate Center (from 1/1/24 to 12/31/24) (see exhibit 34.4)

 34.28
Custodian under the GSMS 2016-GS2 securitization, pursuant to which the
following mortgage loans were serviced by such party: Twenty Ninth Street
Retail (from 1/1/24 to 12/31/24) (see exhibit 34.3)

 34.29
as Servicing Function Participant under the GSMS 2016-GS2 securitization,
Twenty Ninth Street Retail (from 1/1/24 to 12/31/24) (see exhibit 34.4)

 34.30
Custodian under the BACM 2016-UBS10 securitization, pursuant to which the
Outlets (from 1/1/24 to 12/31/24) (see exhibit 34.3)

 34.31
as Servicing Function Participant under the BACM 2016-UBS10 securitization,
Grove City Premium Outlets (from 1/1/24 to 12/31/24) (see exhibit 34.4)

 34.32
Custodian under the MSBAM 2016-C29 securitization, pursuant to which the
(from 1/1/24 to 12/31/24) (see exhibit 34.3)

 34.33
as Servicing Function Participant under the MSBAM 2016-C29 securitization,
Gulfport Premium Outlets (from 1/1/24 to 12/31/24) (see exhibit 34.4)

 (35) Servicer
compliance statement.

 35.1
Certificate Administrator

 35.2
as Servicing Function Participant for the Certificate Administrator

 35.3
Custodian

 35.4
as Servicing Function Participant for the Custodian

 35.5
 KeyBank National Association, as Master Servicer

 35.6
 CWCapital Asset Management LLC, as Special Servicer

 35.7
 Berkadia Commercial Mortgage LLC, as Primary
Servicer

 35.8
National Association, as Master Servicer under the MSC 2015-UBS8
such party: 525 Seventh Avenue (from 1/1/24 to 12/31/24) and Ellenton Premium
Outlets (from 1/1/24 to 12/31/24)

 35.9

 35.10
National Association, as Master Servicer under the GSMS 2016-GS2
such party: Twenty Ninth Street Retail (from 1/1/24 to 12/31/24) (see exhibit
35.8)

 35.11
Servicer under the BACM 2016-UBS10 securitization, pursuant to which the
Outlets (from 1/1/24 to 12/31/24) (see exhibit 35.9)

 35.12
National Association, as Sub-Servicer under the BACM 2016-UBS10 securitization,
Grove City Premium Outlets (from 1/1/24 to 12/31/24) (see exhibit 35.8)

 35.13
Servicer under the MSBAM 2016-C29 securitization, pursuant to which the
(from 1/1/24 to 12/31/24) (see exhibit 35.9)

 35.14
National Association, as Sub-Servicer under the MSBAM 2016-C29 securitization,
Gulfport Premium Outlets (from 1/1/24 to 12/31/24) (see exhibit 35.8)

 35.15
under the MSC 2015-UBS8 securitization, pursuant to which the following
mortgage loans were serviced by such party: 525 Seventh Avenue (from 1/1/24 to
12/31/24) and Ellenton Premium Outlets (from 1/1/24 to 12/31/24)

 35.16
under the BACM 2016-UBS10 securitization, pursuant to which the following
mortgage loans were serviced by such party: Grove City Premium Outlets (from
1/1/24 to 12/31/24) (see exhibit 35.15)

 35.17
under the MSBAM 2016-C29 securitization, pursuant to which the following
mortgage loans were serviced by such party: Gulfport Premium Outlets (from
1/1/24 to 12/31/24) (see exhibit 35.15)

 35.18
Custodian under the MSC 2015-UBS8 securitization, pursuant to which the
following mortgage loans were serviced by such party: 525 Seventh Avenue (from
1/1/24 to 12/31/24) and Ellenton Premium Outlets (from 1/1/24 to 12/31/24) (see
exhibit 35.3)

 35.19
as Servicing Function Participant under the MSC 2015-UBS8 securitization,
pursuant to which the following mortgage loans were serviced by such party: 525
Seventh Avenue (from 1/1/24 to 12/31/24) and Ellenton Premium Outlets (from
1/1/24 to 12/31/24) (see exhibit 35.4)

 35.20
Custodian under the MSBAM 2016-C28 securitization, pursuant to which the
Center (from 1/1/24 to 12/31/24) (see exhibit 35.3)

 35.21
as Servicing Function Participant under the MSBAM 2016-C28 securitization,
Princeton Pike Corporate Center (from 1/1/24 to 12/31/24) (see exhibit 35.4)

 35.22
Custodian under the GSMS 2016-GS2 securitization, pursuant to which the
following mortgage loans were serviced by such party: Twenty Ninth Street
Retail (from 1/1/24 to 12/31/24) (see exhibit 35.3)

 35.23
as Servicing Function Participant under the GSMS 2016-GS2 securitization,
Twenty Ninth Street Retail (from 1/1/24 to 12/31/24) (see exhibit 35.4)

 35.24
Custodian under the BACM 2016-UBS10 securitization, pursuant to which the
Outlets (from 1/1/24 to 12/31/24) (see exhibit 35.3)

 35.25
as Servicing Function Participant under the BACM 2016-UBS10 securitization,
Grove City Premium Outlets (from 1/1/24 to 12/31/24) (see exhibit 35.4)

 35.26
Custodian under the MSBAM 2016-C29 securitization, pursuant to which the
(from 1/1/24 to 12/31/24) (see exhibit 35.3)

 35.27
as Servicing Function Participant under the MSBAM 2016-C29 securitization,
Gulfport Premium Outlets (from 1/1/24 to 12/31/24) (see exhibit 35.4)

 (99.1)
 Mortgage Loan Purchase Agreement, dated February 19,
2016, between Morgan Stanley Capital I Inc. and Morgan Stanley Mortgage Capital
Holdings LLC (filed as Exhibit 99.1 to the registrant's Current Report on Form
8-K filed on March 9, 2016 under SEC File No. 333-206582-01 and incorporated by
reference herein).

 (99.2)
 Mortgage Loan Purchase Agreement, dated February 19,
2016, between Morgan Stanley Capital I Inc. and Bank of America, National
Association. (filed as Exhibit 99.2 to the registrant's Current Report on Form
8-K filed on March 9, 2016 under SEC File No. 333-206582-01 and incorporated by
reference herein).

 (99.3)
 Mortgage Loan Purchase Agreement, dated February 19,
2016, between Morgan Stanley Capital I Inc. and UBS Real Estate Securities Inc.
(filed as Exhibit 99.3 to the registrant's Current Report on Form 8-K filed on
March 9, 2016 under SEC File No. 333-206582-01 and incorporated by reference
herein).

 (99.4)
 Agreement Between Note Holders, dated as of March 8,
2016, between UBS Real Estate Securities Inc., as Initial Note A-1 Holder, UBS
Real Estate Securities Inc., as Initial Note A-2 Holder, UBS Real Estate
Securities Inc., as Initial Note A-3 Holder, and UBS Real Estate Securities
Inc., as Initial Note A-4 Holder, relating to the 2100 Ross loan combination
(filed as Exhibit 99.4 to the registrant's Current Report on Form 8-K filed on
March 9, 2016 under SEC File No. 333-206582-01 and incorporated by reference
herein).

 (99.5)
 Agreement Between Note Holders, dated as of March 8,
2016, between Goldman Sachs Mortgage Company, as Initial Note A-1 Holder, UBS
Real Estate Securities Inc., as Initial Note A-2 Holder, and UBS Real Estate
Securities Inc., as Initial Note A-3 Holder, relating to the Twenty Ninth
Street Retail loan combination (filed as Exhibit 99.5 to the registrant's
Current Report on Form 8-K filed on March 9, 2016 under SEC File No.
333-206582-01 and incorporated by reference herein).

 (99.6)
 Agreement Between Note Holders, dated as of March 8,
2016, between UBS Real Estate Securities Inc., as Initial Note A-1 Holder, UBS
Real Estate Securities Inc., as Initial Note A-2 Holder, and UBS Real Estate
Securities Inc., as Initial Note A-3 Holder, relating to the Gateway Plaza loan
combination (filed as Exhibit 99.6 to the registrant's Current Report on Form
8-K filed on March 9, 2016 under SEC File No. 333-206582-01 and incorporated by
reference herein).

 (99.7)
 Amended and Restated Agreement Between Note Holders,
dated as of March 8, 2016, between UBS Real Estate Securities Inc., as Initial
Note A-1 Holder, Wells Fargo Bank, National Association as MSC 2015-UBS8
trustee, as Initial Note A-2 Holder, UBS Real Estate Securities Inc., as
Initial Note A-3 Holder, and UBS Real Estate Securities Inc., as Initial Note
A-4 Holder, relating to the 525 Seventh Avenue loan combination (filed as
Exhibit 99.7 to the registrant's Current Report on Form 8-K filed on March 9, 2016
under SEC File No. 333-206582-01 and incorporated by reference herein).

 (99.8)
 Co-Lender Agreement, dated as of December 22, 2015,
between Column Financial, Inc., as Initial Note A-1 Holder, Morgan Stanley
Mortgage Capital Holdings LLC, as Initial Note A-2 Holder, Column Financial,
Inc., as Initial Note A-3 Holder, Morgan Stanley Bank, N.A., as Initial Note
A-4 Holder, Column Financial, Inc., as Initial Note B-1 Holder, and Morgan
Stanley Mortgage Capital Holdings LLC, as Initial Note B-2 Holder, relating to
the GLP Industrial Portfolio B loan combination (filed as Exhibit 99.8 to the
registrant's Current Report on Form 8-K filed on March 9, 2016 under SEC File
No. 333-206582-01 and incorporated by reference herein), as amended and
restated pursuant to that certain Amended and Restated Co-Lender Agreement,
dated as of May 26, 2016, between Wells Fargo Bank, National Association, not
in its individual capacity but solely as trustee for the benefit of the Holders
of the CSMC 2015-GLPB Mortgage Trust Commercial Mortgage Pass-Through
Certificates, as the Holder of Note A-1, Note A-2, Note B-1 and Note B-2,
Column Financial, Inc., as the Holder of Note A-3-1 and Note A-3-2, and Wells
Fargo Bank, National Association, not in its individual capacity but solely as
trustee for the benefit of the Holders of the MSC 2016-UBS9 Mortgage Trust
Commercial Mortgage Pass-Through Certificates, as the Holder of Note A-4 (filed
as Exhibit 99.16 to the registrant's Current Report on Form 8-K filed on June
2, 2016 under SEC File No. 333-206582-01 and incorporated by reference herein).

 (99.9)
 Agreement Between Note Holders, dated as of February
19, 2016, between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder, Morgan
Stanley Bank, N.A., as Initial Note A-2 Holder, and Morgan Stanley Bank, N.A.,
as Initial Note A-3 Holder, relating to the Princeton Pike Corporate Center
loan combination (filed as Exhibit 99.9 to the registrant's Current Report on
Form 8-K filed on March 9, 2016 under SEC File No. 333-206582-01 and
incorporated by reference herein), as amended and restated pursuant to that certain
Amended and Restated Agreement Between Note Holders, dated as of April 21,
2016, between U.S. Bank National Association, as trustee for Morgan Stanley
Bank of America Merrill Lynch Trust 2016-C28, Commercial Mortgage Pass-Through
Certificates, Series 2016-C28, as Note A-1 Holder, Wells Fargo Bank, National
Association, as trustee for Morgan Stanley Capital I Trust 2016-UBS9,
Commercial Mortgage Pass-Through Certificates, Series 2016-UBS9, as Note A-2
Holder, Morgan Stanley Bank, N.A., as Note A-3 Holder, and Morgan Stanley Bank,
N.A., as Note A-4 Holder (filed as Exhibit 99.15 to the registrant's Current
Report on Form 8-K filed on April 26, 2016 under SEC File No. 333-206582-01 and
incorporated by reference herein).

 (99.10)
 Agreement Between Note Holders, dated as of November 5,
2015, between UBS Real Estate Securities Inc., as Initial Note A-1 Holder, UBS
Real Estate Securities Inc., as Initial Note A-2 Holder, UBS Real Estate
Securities Inc., as Initial Note A-3 Holder, and Bank of America, National
Association, as Initial Note A-4 Holder, relating to the Ellenton Premium
Outlets loan combination (filed as Exhibit 99.10 to the registrant's Current
Report on Form 8-K filed on March 9, 2016 under SEC File No. 333-206582-01 and
incorporated by reference herein).

 (99.11)
 Amended and Restated Agreement Between Note Holders,
dated as of March 8, 2016, between Wells Fargo Bank, National Association, as
MSC 2015-UBS8 trustee, as Initial Note A-1 Holder, UBS Real Estate Securities
Inc., as Initial Note A-2 Holder, UBS Real Estate Securities Inc., as Initial
Note A-3 Holder, UBS Real Estate Securities Inc., as Initial Note A-4 Holder,
and Bank of America, National Association, as Initial Note A-5 Holder, relating
to the Grove City Premium Outlets loan combination (filed as Exhibit 99.11 to
the registrant's Current Report on Form 8-K filed on March 9, 2016 under SEC
File No. 333-206582-01 and incorporated by reference herein).

 (99.12)
 Agreement Between Note Holders, dated as of November 5,
2015, between UBS Real Estate Securities Inc., as Initial Note A-1 Holder, UBS
Real Estate Securities Inc., as Initial Note A-2 Holder, and UBS Real Estate
Securities Inc., as Initial Note A-3 Holder, relating to the Gulfport Premium
Outlets loan combination (filed as Exhibit 99.12 to the registrant's Current
Report on Form 8-K filed on March 9, 2016 under SEC File No. 333-206582-01 and
incorporated by reference herein).

 (99.13)
 Amended and Restated Subservicing Agreement, dated as
of January 18, 2013 between KeyBank National Association (as successor by
merger to KeyCorp Real Estate Capital Markets, Inc.), as master servicer, and
Berkadia Commercial Mortgage LLC, as subservicer (filed as Exhibit 99.13 to the
registrant's Current Report on Form 8-K/A filed on March 16, 2016 under SEC
File No. 333-206582-01 and incorporated by reference herein).

 (99.14)
 Subservicing Agreement, dated as of March 1, 2016
between KeyBank National Association, as master servicer, and Berkadia
Commercial Mortgage LLC, as subservicer (filed as Exhibit 99.14 to the
registrant's Current Report on Form 8-K/A filed on March 16, 2016 under SEC
File No. 333-206582-01 and incorporated by reference herein).

 (99.15)
 Second Amended and Restated Servicing Agreement,
effective as of October 31, 2021, between Wells Fargo Bank, N.A., Wells Fargo
Delaware Trust Company, N.A., Computershare Trust Company, N.A., Computershare
Delaware Trust Company and Computershare Limited (filed as Exhibit 99.1 to the
registrant's Current Report on Form 8-K filed on November 5, 2021 under SEC
File No. 333-206582-01 and incorporated by reference herein).

 (b)
See (a) above.

 (c)
Not applicable.

 SIGNATURES

 Pursuant
to the requirements of Section 13 or 15(d) of the Securities Exchange Act of
1934, the registrant has duly caused this report to be signed on its behalf by
the undersigned, thereunto duly authorized.

 Morgan
Stanley Capital I Inc.

 (Depositor)

 By:
/s/ Jane Lam

 Jane
Lam, President

 (senior
officer in charge of securitization of the depositor)

 Date:
March 26, 2025


UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

 WASHINGTON,
D.C. 20549

 FORM 10 K

 (Mark one)

 /X/
ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES

EXCHANGE ACT OF 1934

 For the fiscal year ended
December 31, 2024

OR

 //
TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES

EXCHANGE ACT OF 1934

 For the transition period from
to

 Commission file number: 333-227446-06

 Central Index Key Number of the issuing entity:
 0001784958

 BANK 2019-BNK20

 (exact name of issuing entity as specified in its
charter)

 Central Index Key Number of the depositor: 0001547361

 Morgan Stanley Capital I Inc.

 (exact name of the depositor as specified in its
charter)

 Central Index Key Number of the sponsor: 0001102113

 Bank of America, National
Association

 (exact name of the sponsor as specified in its charter)

 Central Index Key Number of the sponsor: 0001541557

 Morgan Stanley Mortgage
Capital Holdings LLC

 (exact name of the sponsor as specified in its charter)

 Central Index Key Number of the sponsor: 0000740906

 Wells Fargo Bank, National Association

 (exact name of the sponsor as specified in its charter)

 Central Index Key Number of the sponsor: 0001577313

 National Cooperative Bank,
N.A.

 (exact name of the sponsor as specified in its charter)

 New York

 38-4123673

 38-4123674

 38-7221365

 (State or other jurisdiction of incorporation or
 organization)

 (I.R.S. Employer Identification Numbers)

 c/o Computershare Trust Company, National Association,
as agent for

 Wells Fargo Bank, National Association

 9062 Old Annapolis Road

 Columbia, MD

 (Address of principal executive offices)

 21045

 (Zip Code)

 Telephone number, including area code:

 (667) 786 1992

 Securities
registered pursuant to Section 12(b) of the Act:

 Title of each class

 Trading Symbol(s)

 Name of each exchange on which registered

 None

 Securities
registered pursuant to Section 12(g) of the Act:

 NONE.

by check mark if the registrant is a well-known seasoned issuer, as defined in
Rule 405 of the Securities Act.

 Yes
___ No X

by check mark if the registrant is not required to file reports pursuant to
Section 13 or Section 15(d) of the Act.

 Yes
___ No X

 Note
- Checking the box above will not relieve any registrant required to file
reports pursuant to Section 13 or 15(d) of the Exchange Act from their
obligations under those Sections.

Indicate by check mark whether the registrant (1) has filed all reports
required to be filed by Section 13 or 15(d) of the Securities Exchange Act of
1934 during the preceding 12 months (or for such shorter period that the
registrant was required to file such reports), and (2) has been subject to such
filing requirements for the past 90 days.

 Yes
X No ___

by check mark whether the registrant has submitted electronically every
Interactive Data File required to be submitted pursuant to Rule 405 of
Regulation S-T (Section 232.405 of this chapter) during the preceding 12 months
(or for such shorter period that the registrant was required to submit such
files).

 Not

by check mark whether the registrant is a large accelerated filer, an
accelerated filer, a non-accelerated filer, a smaller reporting company, or
emerging growth company. See the definitions of "large accelerated
filer", "accelerated filer," "smaller reporting
company," and "emerging growth company" in Rule 12b-2 of the Exchange Act.

 Large
accelerated filer ___

Accelerated filer ___

Non-accelerated filer X (Do not check if a smaller reporting company)

Smaller reporting company ___

 Emerging
growth company ___

 If
an emerging growth company, indicate by check mark if the registrant has
elected not to use the extended transition period for complying with any new or
revised financial accounting standards provided pursuant to Section 13(a) of
the Ex change Act.

 Not

by check mark whether the registrant has filed a report on and attestation to
its management's assessment of the effectiveness of its internal control over
financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C.
7262(b)) by the registered public accounting firm that prepared or issued its
audit report.

Not applicable.

 If securities are registered pursuant to Section 12(b)
of the Act, indicate by check mark whether the financial statements of the

 registrant
included in the filing reflect the correction of an error to previously issued
financial statements.

 Not applicable.

by check mark whether any of those error corrections are restatements that
required a recovery analysis of incentive-based compensation received by any of
the registrant's executive officers during the relevant recovery period
pursuant to §240.10D-1(b).

 Not applicable.

by check mark whether the registrant is a shell company (as defined in Rule
12b-2 of the Act).

 Yes
___ No X

 State
the aggregate market value of the voting and non-voting common equity held by
non-affiliates computed by reference to the price at which the common equity
was last sold, or the average bid and asked price of such common equity, as of
the last business day of the registrant's most recently completed second fiscal
quarter.

 Not

by check mark whether the registrant has filed all documents and reports
required to be filed by Section 12, 13 or 15(d) of the Securities Exchange Act
of 1934 subsequent to the distribution of securities under a plan confirmed by
a court.

 Not

the number of shares outstanding of each of the registrant's classes of common
stock, as of the latest practicable date.

 Not

 DOCUMENTS
INCORPORATED BY REFERENCE

 List
hereunder the following documents if incorporated by reference and the Part of
the Form 10-K (e.g., Part I, Part II, etc.) into which the document is
incorporated: (1)Any annual report to security holders; (2) Any proxy or
information statement; and (3)Any prospectus filed pursuant to Rule 424(b) or
(c) under the Securities Act of 1933. The listed documents should be clearly
described for identification purposes (e.g., annual report to security holders
for fiscal year ended December 24, 1980).

 Not

 EXPLANATORY NOTES

 The
BANK 2019-BNK20 mortgage pool includes the following mortgage loans, each of
which is serviced pursuant to a separate pooling and servicing agreement (each,
an "Outside Pooling and Servicing Agreement"):

 •
the Grand Canal Shoppes mortgage loan and the Legacy Tower mortgage loan, which
are serviced pursuant to the MSC 2019-H7 pooling and servicing agreement
attached hereto as Exhibit 4.2; and

 •
the Park Tower at Transbay mortgage loan, which is serviced pursuant to the
BANK 2019-BNK21 pooling and servicing agreement attached hereto as Exhibit 4.3.

 Except
as set forth below, each of the parties to each pooling and servicing agreement
listed in the Exhibit Index both (1) participates in the servicing function for
purposes of Item 1122 of Regulation AB and (2) constitutes a servicer that
meets the criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB for
purposes of Item 1123 of Regulation AB:

 •
The trustee under a pooling and servicing agreement has a nominal role with
respect to the mortgage pool securitized pursuant to such pooling and servicing
agreement. The trustee's only servicing function is the contingent
obligation to make certain advances if the master servicer under such pooling
and servicing agreement fails to do so, while all other servicing functions are
performed by other parties. The trustee under each of the pooling and
servicing agreements listed in the Exhibit Index has confirmed to the
registrant that it has not made any such contingent advances during the
reporting period, and consequently, each such trustee does not participate in
the servicing function for purposes of Item 1122 of Regulation AB, nor does it
perform the functions of a servicer for purposes of the definition of
"servicer" under Item 1101 of Regulation AB or for purposes of Item 1123 of
Regulation AB.

 •
The certificate administrator under a pooling and servicing agreement performs
various payment administration functions solely for the securitization governed
by such pooling and servicing agreement and the mortgage pool securitized
pursuant to such pooling and servicing agreement and does not have any
obligations with respect to any other transaction. Consequently, the
certificate administrator under an Outside Pooling and Servicing Agreement does
not participate in the servicing function for purposes of Item 1122 of
Regulation AB, nor does it perform the functions of a servicer for purposes of
the definition of "servicer" under Item 1101 of Regulation AB or for purposes
of Item 1123 of Regulation AB.

 •
The operating advisor under a pooling and servicing agreement represents the
interests of senior certificateholders in the transaction governed by such
pooling and servicing agreement and is responsible for monitoring the
performance of the special servicer under such pooling and servicing agreement
and producing certain reports to certificateholders relating to the resolution
of the mortgage pool securitized pursuant to such pooling and servicing
agreement. The operating advisor under a pooling and servicing agreement
does not have any obligations with respect to any other transaction and is
solely obligated to perform loan reporting functions with respect to the
securitization governed by such pooling and servicing agreement.
Consequently, the operating advisor under an Outside Pooling and Servicing
Agreement neither participates in the servicing function for purposes of Item
1122 of Regulation AB nor performs the functions of a servicer for purposes of
the definition of "servicer" under Item 1101 of Regulation AB or for purposes
of Item 1123 of Regulation AB. In addition, while the operating advisor
under a pooling and servicing agreement has certain reporting obligations in
respect of the related mortgage pool, it has no obligation to collect or
disburse funds in respect of the mortgage pool or to administer any of the
underlying mortgage loans. Consequently, the operating advisor under a
pooling and servicing agreement participates in the servicing function for
purposes of Item 1122 of Regulation AB, but is not responsible for the
"management or collection of the pool assets or making allocations or
distributions to holders of the asset-backed securities" within the meaning of
"servicer" under Item 1101 of Regulation AB and does not perform the functions
of a servicer for purposes of Item 1123 of Regulation AB.

 • The asset representations reviewer under a pooling
and servicing agreement has a limited obligation to review certain delinquent
mortgage loans after a specified delinquency threshold has been met and the
required percentage of certificateholders vote to direct a review of such
delinquent mortgage loans, and has no obligation to collect or disburse funds
in respect of the mortgage pool, to administer any of the underlying mortgage
loans or to perform any servicing function. Consequently, the asset representations
reviewer under a pooling and servicing agreement does not participate in the
servicing function for purposes of Item 1122 of Regulation AB, is not
responsible for the "management or collection of the pool assets or making
allocations or distributions to holders of the asset-backed securities" within
the meaning of "servicer" under Item 1101 of Regulation AB and does not perform
the functions of a servicer for purposes of Item 1123 of Regulation AB.

 •
 Midland Loan Services, a Division of PNC Bank, National Association
is the master servicer under the MSC 2019-H7 pooling and servicing agreement,
pursuant to which the Grand Canal Shoppes mortgage loan and the Legacy Tower
mortgage loan are serviced. Because Midland Loan Services, a Division of
PNC Bank, National Association is not the BANK 2019-BNK20 master servicer, is
not affiliated with any sponsor and services only the Grand Canal Shoppes
mortgage loan and the Legacy Tower mortgage loan, which collectively constitute
less than 5% of the mortgage pool, Midland Loan Services, a Division of PNC
Bank, National Association, as MSC 2019-H7 master servicer, does not constitute
a reporting "servicing function participant" for purposes of Item 1122 of Regulation
AB, as specified in the Instruction 3 to Item 1122, and does not constitute a
reporting "servicer" for purposes of Item 1123 of Regulation AB, as specified
in the Instruction to Item 1123.

 •
Argentic Services Company LP is the current special
servicer under the MSC 2019-H7 pooling and servicing agreement, with respect to
the Legacy Tower mortgage loan. On May 6, 2020, LNR Partners, LLC was replaced
as general special servicer under the MSC 2019-H7 pooling and servicing
agreement and succeeded by Argentic Services Company LP.
Because Argentic Services Company LP is not the
BANK 2019-BNK20 special servicer, is not affiliated with any sponsor and
services only the Legacy Tower mortgage loan,
which constitutes less than 5% of the mortgage pool, Argentic
Services Company LP, as MSC 2019-H7 special
servicer, does not constitute a reporting "servicing function participant" for
purposes of Item 1122 of Regulation AB, as specified in the Instruction 3 to
Item 1122, and does not constitute a reporting "servicer" for purposes of Item
1123 of Regulation AB, as specified in the Instruction to Item 1123.

 • Situs Holdings, LLC is the
current special servicer under the MSC 2019-H7 pooling and servicing agreement,
with respect to the Grand Canal Shoppes mortgage loan. On June 15, 2020, LNR
Partners, LLC was replaced as special servicer under the MSC 2019-H7 pooling
and servicing agreement with respect to the Grand Canal Shoppes mortgage loan
and succeeded by Situs Holdings, LLC. Because Situs Holdings, LLC is not the BANK 2019-BNK20 special
servicer, is not affiliated with any sponsor and services only the Grand Canal Shoppes mortgage loan, which constitutes
less than 5% of the mortgage pool, Situs Holdings, LLC,
as MSC 2019-H7 special servicer with respect to
the Grand Canal Shoppes mortgage loan, does not constitute a reporting
"servicing function participant" for purposes of Item 1122 of Regulation AB, as
specified in the Instruction 3 to Item 1122, and does not constitute a
reporting "servicer" for purposes of Item 1123 of Regulation AB, as specified
in the Instruction to Item 1123.

 • LNR
Partners, LLC is the current special servicer under the BANK 2019-BNK20 pooling
and servicing agreement. On July 13, 2021, Midland Loan Services, a Division of
PNC Bank, National Association was replaced as special servicer under the BANK
2019-BNK20 pooling and servicing agreement and was succeeded by LNR Partners,
LLC.

 In
addition, each of the following parties engaged the services of certain
servicing function participants and sub-servicers for the reporting period, as
set forth below:

 •
 Wells Fargo Bank, National Association, as master servicer, engaged the
services of CoreLogic Solutions, LLC as a servicing function participant in
respect of the entire mortgage pool for the reporting period.

 •
Wells Fargo Bank, National Association, as master servicer under the BANK
2019-BNK21 pooling and servicing agreement, pursuant to which the Park Tower at
Transbay mortgage loan is serviced, engaged the services of CoreLogic
Solutions, LLC as a servicing function participant in respect of the Park Tower
at Transbay mortgage loan for the reporting period.

 •
On November 1, 2021, pursuant to the second amended and restated servicing
agreement attached hereto as Exhibit 99.14, Computershare Trust Company,
National Association was engaged to perform all or virtually all of Wells Fargo
Bank, National Association's roles as certificate administrator, custodian and
trustee, as applicable, under (i) the pooling and servicing agreement and (ii)
each Outside Pooling and Servicing Agreement.

 Item 1.

 Business.

 Item 1A.

 Risk Factors.

 Item 1B.

 Unresolved Staff
 Comments.

 None.

 Item 1C.

 Cybersecurity.

 Item 2.

 Properties.

 Item 3.

 Legal Proceedings.

 Item 4.

 Mine Safety Disclosures.

 Item 5.

 Market for Registrant's
 Common Equity, Related Stockholder Matters and Issuer Purchases of Equity
 Securities.

 Item 6.

 [Reserved]

 Item 7.

 Management's Discussion
 and Analysis of Financial Condition and Results of Operations.

 Item 7A.

 Quantitative and
 Qualitative Disclosures About Market Risk.

 Item 8.

 Financial Statements and
 Supplementary Data.

 Item 9.

 Changes in and
 Disagreements With Accountants on Accounting and Financial Disclosure.

 Item 9A.

 Controls and Procedures.

 Item 9B.

 Other Information.

 None.

 Item 9C.

 Disclosure Regarding
 Foreign Jurisdictions that Prevent Inspections.

 None.

 Item 10.

 Directors, Executive
 Officers and Corporate Governance.

 Item 11.

 Executive Compensation.

 Item 12.

 Security Ownership of
 Certain Beneficial Owners and Management and Related Stockholder Matters.

 Item 13.

 Certain Relationships and
 Related Transactions, and Director Independence.

 Item 14.

 Principal Accountant Fees
 and Services.

 ADDITIONAL
DISCLOSURE ITEMS FOR REGULATION AB

 Item
1112(b) of Regulation AB, Significant Obligor Financial Information.

 Not

 Item
1114(b)(2) of Regulation AB, Significant Enhancement Provider Financial
Information.

 No entity
or group of affiliated entities provides any enhancement or other support for
the certificates as described under Item 1114 (a) of Regulation AB.

 Item
1115(b) of Regulation AB, Certain Derivatives Instruments (Financial
Information).

 No
entity or group of affiliated entities provides any derivative instruments for
the certificates as described under Item 1115 of Regulation AB.

 Item
1117 of Regulation AB, Legal Proceedings.

 The
registrant knows of no legal proceeding pending against the sponsors,
depositor, trustee, issuing entity, servicer contemplated by Item 1108(a)(3) of
Regulation AB, originator contemplated by Item 1110(b) of Regulation AB, or
other party contemplated by Item 1100(d)(1) of Regulation AB, or of which any
property of the foregoing is the subject, that is material to security holders,
other than as follows:

 In
December 2014, Phoenix Light SF Limited (Phoenix Light) and certain related
entities filed a complaint in the United States District Court for the Southern
District of New York alleging claims against Wells Fargo Bank, N.A., in its
capacity as trustee for a number of residential mortgage-backed securities
(RMBS) trusts. Complaints raising similar allegations have been filed by
Commerzbank AG in the Southern District of New York, IKB International and IKB
Deutsche Industriebank (together, IKB) in New York state court, and Park Royal
I LLC and Park Royal II LLC in New York state court. In each case, the
plaintiffs allege that Wells Fargo Bank, N.A., as trustee, caused losses to
investors, and plaintiffs assert causes of action based upon, among other things,
the trustee's alleged failure to notify and enforce repurchase obligations of
mortgage loan sellers for purported breaches of representations and warranties,
notify investors of alleged events of default, and abide by appropriate
standards of care following alleged events of default. In July 2022, the
district court dismissed Phoenix Light's claims and certain of the claims
asserted by Commerzbank AG, and subsequently entered judgment in each case in
favor of Wells Fargo Bank, N.A. In August 2022, Phoenix Light and Commerzbank
AG each appealed the district court's decision to the United States Court of
Appeals for the Second Circuit. Phoenix Light dismissed its appeal in May 2023,
terminating its case. In October 2024, the Second Circuit denied Commerzbank
AG's appeal. In November 2023, Wells Fargo Bank, N.A. entered into an agreement
with IKB to resolve IKB's claims. Wells Fargo Bank, N.A. previously settled two
class actions filed by institutional investors and an action filed by the
National Credit Union Administration with similar allegations.

 Item
1119 of Regulation AB, Affiliations and Certain Relationships and Related
Transactions.

 The
information regarding this Item has been provided previously in an annual
report on Form 10-K of the issuing entity or in the prospectus of the issuing
entity filed in a 424(b)(2) filing dated September 26, 2019.

 Item
1122 of Regulation AB, Compliance with Applicable Servicing Criteria.

 The
reports on assessment of compliance with the servicing criteria for
asset-backed securities and the related attestation reports on such assessments
of compliance are attached hereto under Item 15.

 Item
1123 of Regulation AB, Servicer Compliance Statement.

 The
servicer compliance statements are attached hereto under Item 15.

 Item
15. Exhibits, Financial Statement Schedules.

 (a) Exhibits.

 (4.1)
 Pooling and Servicing Agreement, dated as of September
1, 2019, between Morgan Stanley Capital I Inc., as depositor, Wells Fargo Bank,
National Association, as general master servicer, Midland Loan Services, a
Division of PNC Bank, National Association, as general special servicer,
National Cooperative Bank, N.A., as NCB master servicer and as NCB special
servicer, Wells Fargo Bank, National Association, as certificate administrator,
Wilmington Trust, National Association, as trustee, and Park Bridge Lender
Services LLC, as operating advisor and as asset representations reviewer (filed
as Exhibit 4.1 to the registrant's Current Report on Form 8-K filed on

 (4.2) Pooling and Servicing Agreement, dated as of July 1,
2019, between Morgan Stanley Capital I Inc., as depositor, Midland Loan
Services, a Division of PNC Bank, National Association, as master servicer, LNR
Partners, LLC, as special servicer, Wells Fargo Bank, National Association, as
certificate administrator and trustee, and Pentalpha Surveillance LLC, as
operating advisor and as asset representations reviewer, relating to the MSC
2019-H7 securitization transaction, pursuant to which the Grand Canal Shoppes
Mortgage Loan and the Legacy Tower Mortgage Loan are serviced (filed as Exhibit
4.2 to the registrant's Current Report on Form 8-K filed on September 26, 2019
under SEC File No. 333-227446-06 and incorporated by reference herein).

 (4.3)
 Pooling and Servicing Agreement, dated as of October 1,
2019, between Banc of America Merrill Lynch Commercial Mortgage Inc., as
depositor, Wells Fargo Bank, National Association, as master servicer, Rialto
Capital Advisors, LLC, as special servicer, Park Bridge Lender Services LLC, as
operating advisor and as asset representations reviewer, Wells Fargo Bank,
National Association, as certificate administrator, and Wilmington Trust,
National Association, as trustee, relating to the BANK 2019-BNK21
securitization transaction, pursuant to which the Park Tower at Transbay
Mortgage Loan is serviced (filed as Exhibit 4.3 to the registrant's Current
Report on Form 8-K filed on October 28, 2019 under SEC File No. 333-227446-06
and incorporated by reference herein).

 (31)
 Rule 13a-14(d)/15d-14(d) Certification.

 (33)
Reports on assessment of compliance with servicing criteria for asset-backed
securities.

 33.1
Certificate Administrator

 33.2
as Servicing Function Participant for the Certificate Administrator

 33.3
Custodian

 33.4
as Servicing Function Participant for the Custodian

 33.5

 33.6
 National Cooperative Bank, N.A., as NCB Master

 33.7
 LNR Partners, LLC, as Special Servicer

 33.8
 National Cooperative Bank, N.A., as NCB Special
Servicer (see Exhibit 33.6)

 33.9
 Park Bridge Lender Services LLC, as Operating
Advisor

 33.10
 CoreLogic Solutions, LLC, as Servicing Function
Participant

 33.11
Servicer under the BANK 2019-BNK21 securitization, pursuant to which the
(from 1/1/24 to 12/31/24) (see Exhibit 33.5)

 33.12
 CoreLogic Solutions, LLC, as Servicing Function
Participant under the BANK 2019-BNK21 securitization, pursuant to which the
(from 1/1/24 to 12/31/24) (see Exhibit 33.10)

 33.13
 Rialto Capital Advisors, LLC, as Special Servicer
under the BANK 2019-BNK21 securitization, pursuant to which the following
mortgage loans were serviced by such party: Park Tower at Transbay (from 1/1/24
to 12/31/24)

 33.14
Custodian under the BANK 2019-BNK21 securitization, pursuant to which the
(from 1/1/24 to 12/31/24) (see Exhibit 33.3)

 33.15
as Servicing Function Participant under the BANK 2019-BNK21 securitization,
Park Tower at Transbay (from 1/1/24 to 12/31/24) (see Exhibit 33.4)

 33.16
Custodian under the MSC 2019-H7 securitization, pursuant to which the following
mortgage loans were serviced by such party: Grand Canal Shoppes (from 1/1/24 to
12/31/24) and Legacy Tower (from 1/1/24 to 12/31/24) (see Exhibit 33.3)

 33.17
 Computershare Trust Company, National Association, as
Servicing Function Participant under the MSC 2019-H7 securitization, pursuant
to which the following mortgage loans were serviced by such party: Grand Canal
Shoppes (from 1/1/24 to 12/31/24) and Legacy Tower (from 1/1/24 to 12/31/24)
(see Exhibit 33.4)

 (34) Attestation
reports on assessment of compliance with servicing criteria for asset-backed
securities.

 34.1
Certificate Administrator

 34.2
as Servicing Function Participant for the Certificate Administrator

 34.3
Custodian

 34.4
as Servicing Function Participant for the Custodian

 34.5

 34.6
 National Cooperative Bank, N.A., as NCB Master

 34.7
 LNR Partners, LLC, as Special Servicer

 34.8
 National Cooperative Bank, N.A., as NCB Special
Servicer (see Exhibit 34.6)

 34.9
 Park Bridge Lender Services LLC, as Operating
Advisor

 34.10
 CoreLogic Solutions, LLC, as Servicing Function
Participant

 34.11
Servicer under the BANK 2019-BNK21 securitization, pursuant to which the
(from 1/1/24 to 12/31/24) (see Exhibit 34.5)

 34.12
 CoreLogic Solutions, LLC, as Servicing Function
Participant under the BANK 2019-BNK21 securitization, pursuant to which the
(from 1/1/24 to 12/31/24) (see Exhibit 34.10)

 34.13
 Rialto Capital Advisors, LLC, as Special Servicer
under the BANK 2019-BNK21 securitization, pursuant to which the following
mortgage loans were serviced by such party: Park Tower at Transbay (from 1/1/24
to 12/31/24)

 34.14
Custodian under the BANK 2019-BNK21 securitization, pursuant to which the
(from 1/1/24 to 12/31/24) (see Exhibit 34.3)

 34.15
as Servicing Function Participant under the BANK 2019-BNK21 securitization,
Park Tower at Transbay (from 1/1/24 to 12/31/24) (see Exhibit 34.4)

 34.16
Custodian under the MSC 2019-H7 securitization, pursuant to which the following
mortgage loans were serviced by such party: Grand Canal Shoppes (from 1/1/24 to
12/31/24) and Legacy Tower (from 1/1/24 to 12/31/24) (see Exhibit 34.3)

 34.17
as Servicing Function Participant under the MSC 2019-H7 securitization,
Grand Canal Shoppes (from 1/1/24 to 12/31/24) and Legacy Tower (from 1/1/24 to
12/31/24) (see Exhibit 34.4)

 (35) Servicer
compliance statement.

 35.1
Certificate Administrator

 35.2
as Servicing Function Participant for the Certificate Administrator

 35.3
Custodian

 35.4
as Servicing Function Participant for the Custodian

 35.5

 35.6
 National Cooperative Bank, N.A., as NCB Master

 35.7
 LNR Partners, LLC, as Special Servicer

 35.8
 National Cooperative Bank, N.A., as NCB Special
Servicer (see Exhibit 35.6)

 35.9
Servicer under the BANK 2019-BNK21 securitization, pursuant to which the
(from 1/1/24 to 12/31/24) (see Exhibit 35.5)

 35.10
 Rialto Capital Advisors, LLC, as Special Servicer
under the BANK 2019-BNK21 securitization, pursuant to which the following
mortgage loans were serviced by such party: Park Tower at Transbay (from 1/1/24
to 12/31/24)

 35.11
Custodian under the BANK 2019-BNK21 securitization, pursuant to which the
(from 1/1/24 to 12/31/24) (see Exhibit 35.3)

 35.12
as Servicing Function Participant under the BANK 2019-BNK21 securitization,
Park Tower at Transbay (from 1/1/24 to 12/31/24) (see Exhibit 35.4)

 35.13
Custodian under the MSC 2019-H7 securitization, pursuant to which the following
mortgage loans were serviced by such party: Grand Canal Shoppes (from 1/1/24 to
12/31/24) and Legacy Tower (from 1/1/24 to 12/31/24) (see Exhibit 35.3)

 35.14
as Servicing Function Participant under the MSC 2019-H7 securitization,
Grand Canal Shoppes (from 1/1/24 to 12/31/24) and Legacy Tower (from 1/1/24 to
12/31/24) (see Exhibit 35.4)

 (99.1)
 Mortgage
Loan Purchase Agreement, dated September 13, 2019, between Morgan Stanley
Capital I Inc. and Morgan Stanley Mortgage Capital Holdings LLC (filed as
Exhibit 99.1 to the registrant's Current Report on Form 8-K filed on September
26, 2019 under SEC File No. 333-227446-06 and incorporated by reference
herein).

 (99.2)
 Mortgage
Loan Purchase Agreement, dated September 13, 2019, between Morgan Stanley
Capital I Inc. and Bank of America, National Association (filed as Exhibit 99.2
to the registrant's Current Report on Form 8-K filed on September 26, 2019
under SEC File No. 333-227446-06 and incorporated by reference herein).

 (99.3)
 Mortgage
Loan Purchase Agreement, dated September 13, 2019, between Morgan Stanley
Capital I Inc. and Wells Fargo Bank, National Association (filed as Exhibit
99.3 to the registrant's Current Report on Form 8-K filed on September 26, 2019
under SEC File No. 333-227446-06 and incorporated by reference herein).

 (99.4)
 Mortgage
Loan Purchase Agreement, dated September 13, 2019, between Morgan Stanley
Capital I Inc. and National Cooperative Bank, N.A. (filed as Exhibit 99.4 to
the registrant's Current Report on Form 8-K filed on September 26, 2019 under
SEC File No. 333-227446-06 and incorporated by reference herein).

 (99.5)
Between Note Holders, dated as September 16, 2019, by and between Bank of
America, N.A., as initial note A-1 holder, initial note A-2 holder, initial
note A-3 holder, initial note A-4 holder, initial Note A-5 holder, initial note
A-6 holder, initial note A-7 holder, initial note A-8 holder, initial note A-9
holder and initial note A-10 holder, relating to the Park Tower at Transbay
loan combination (filed as Exhibit 99.5 to the registrant's Current Report on
Form 8-K filed on September 26, 2019 under SEC File No. 333-227446-06 and
incorporated by reference herein).

 (99.6)
Between Note Holders, dated as September 26, 2019, by and between Wells Fargo
Bank, National Association, as initial note A-1 holder, initial note A-2 holder
and initial note A-3 holder, relating to the Tower at Burbank loan combination
(filed as Exhibit 99.6 to the registrant's Current Report on Form 8-K filed on

 (99.7)
Between Note Holders, dated as September 26, 2019, by and between Morgan
Stanley Bank, N.A., as initial note A-1 holder and initial note A-2 holder,
relating to the NKX Multifamily Portfolio loan combination (filed as Exhibit
99.7 to the registrant's Current Report on Form 8-K/A filed on January 3, 2020
under SEC File No. 333-227446-06 and incorporated by reference herein).

 (99.8)
Between Note Holders, dated as September 13, 2019, by and between Morgan
Stanley Bank, N.A., as note A holder, Athene Annuity and Life Company, as note
B-1 holder, note B-2 holder and note B-6 holder, American Equity Investment
Life Insurance Company, as note B-3 holder, Athene Annuity & Life Assurance
Company, as note B-4 holder and The Lincoln National Life Insurance Company, as
note B-5 holder, relating to the Solstice on the Park loan combination (filed
as Exhibit 99.8 to the registrant's Current Report on Form 8-K filed on

 (99.9)
Between Note Holders, dated as July 3, 2019, by and between Morgan Stanley
Bank, N.A., as note A-1 holder, Wells Fargo Bank, National Association, as note
A-2 holder, JPMorgan Chase Bank, National Association, as note A-3 holder,
Goldman Sachs Bank USA, as note A-4 holder and CPPIB Credit Investments II
Inc., as note B holder, relating to the Grand Canal Shoppes loan combination
(filed as Exhibit 99.9 to the registrant's Current Report on Form 8-K filed on

 (99.10)
 Intercreditor
Agreement, dated as July 24, 2019, by and between Morgan Stanley Bank, N.A., as
note A holder and Morgan Stanley Mortgage Capital Holdings LLC, as note B
holder, relating to the Hawthorne Works Shopping Center loan combination (filed
as Exhibit 99.10 to the registrant's Current Report on Form 8-K filed on

 (99.11)
Between Note Holders, dated as July 25, 2019, by and between Morgan Stanley
Bank, N.A., as initial note A-1 holder, initial note A-2 holder, initial A-3
holder and initial Note A-4 holder, relating to the Eleven Seventeen Perimeter
loan combination (filed as Exhibit 99.11 to the registrant's Current Report on
Form 8-K filed on September 26, 2019 under SEC File No. 333-227446-06 and
incorporated by reference herein).

 (99.12)
Between Note Holders, dated as August 8, 2019, by and between Morgan Stanley
Bank, N.A., as initial note A-1 holder, initial note A-2 holder and initial A-3
holder, relating to the Polo Towne Crossing SC loan combination (filed as
Exhibit 99.12 to the registrant's Current Report on Form 8-K filed on September
26, 2019 under SEC File No. 333-227446-06 and incorporated by reference
herein).

 (99.13)
Between Note Holders, dated as July 25, 2019, by and between Morgan Stanley
Bank, N.A., as initial note A-1 holder and initial note A-2 holder, relating to
the Legacy Tower loan combination (filed as Exhibit 99.13 to the registrant's
Current Report on Form 8-K filed on September 26, 2019 under SEC File No.
333-227446-06 and incorporated by reference herein).

 (99.14)
 Second
Amended and Restated Servicing Agreement, effective as of October 31, 2021,
between Wells Fargo Bank, N.A., Wells Fargo Delaware Trust Company, N.A.,
Computershare Trust Company, N.A., Computershare Delaware Trust Company and
Computershare Limited (filed as Exhibit 99.1 to the registrant's Current Report
on Form 8-K filed on November 5, 2021 under SEC File No. 333-227446-06 and
incorporated by reference herein).

 (b)
See (a) above.

 (c) Not
Applicable.

 SIGNATURES

 Pursuant
to the requirements of Section 13 or 15(d) of the Securities Exchange Act of
1934, the registrant has duly caused this report to be signed on its behalf by
the undersigned, thereunto duly authorized.

 Morgan
Stanley Capital I Inc.

 (Depositor)

 By:
/s/ Jane Lam

 Jane
Lam, President

 (senior
officer in charge of securitization of the depositor)

 Date:
March 26, 2025