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

 o 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 of the issuing entity: 333-226850-03

 Central Index Key Number of the issuing entity:
0001780131

 BBCMS Mortgage Trust 2019-C4

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

 Central Index Key Number of the depositor: 0001541480

 Barclays Commercial Mortgage
Securities LLC

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

 Central Index Key Number of the sponsor: 0001549574

 Barclays Capital Real Estate Inc.

 Central Index Key Number of the sponsor: 0001755531

 Societe Generale Financial
Corporation

 Central Index Key Number of the sponsor: 0001685185

 UBS AG, acting through its branch
located at 1285 Avenue of the Americas, New York, New York

 Central Index Key Number of the sponsor: 0001548405

 Starwood Mortgage Capital LLC

 Central Index Key Number of the sponsor: 0001654834

 Rialto Real Estate Fund III – Debt,
LP

 Central Index Key Number of the sponsor: 0001548567

 CIBC Inc.

 Central Index Key Number of the sponsor: 0001542256

 Natixis Real Estate Capital LLC

 New York

 (State or other jurisdiction of

 incorporation or organization of

 the issuing entity)

 38-4123641

 38-4123642

 38-7221351

 (I.R.S. Employer

 Identification Numbers)

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

 Wells Fargo Bank, National Association

 as Certificate Administrator

 9062 Old Annapolis Road

 Columbia, MD

 (Address of principal
executive offices of the issuing entity)

 21045

 (Zip Code)

 Registrant's telephone number,
including area code:

 (212) 412-4000

 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.

 Indicate by check mark if the registrant is a well-known
seasoned issuer, as defined in Rule 405 of the Securities Act. o Yes
No

 Indicate by check mark if the registrant is not required to
file reports pursuant to Section 13 or Section 15(d) of the Act. o Yes
No

 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 o No

 Indicate 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).

 Indicate by check mark whether the registrant is a large
accelerated filer, an accelerated filer, a non-accelerated filer, a smaller
reporting company, or an 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 o
Accelerated
filer
o

 Non-accelerated
filer
Smaller reporting
company
o

Emerging growth
company
o

 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 Exchange Act. o

 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. o

 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. o

 Indicate 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). o

 Indicate by check mark whether the registrant is a shell
company (as defined in Rule 12b-2 of the Act). o Yes No

 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.

 Indicate 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. o
Yes o
No

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

 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).

 EXPLANATORY NOTES

 The 188 Spear Street Mortgage Loan, the
ExchangeRight Net Leased Portfolio 28 Mortgage Loan, the Meidinger Tower
Mortgage Loan, the Maui Portfolio Mortgage Loan and the Marriott SpringHill
Suites and Towneplace Suites Mortgage Loan, which constituted approximately
6.4%, 4.7%, 2.0%, 1.7% and 1.3%, respectively, of the asset pool of the issuing
entity as of its cut-off date, are each an asset of the issuing entity and are
each part of a loan combination that includes (a) with respect to the 188 Spear
Street Mortgage Loan, two other pari passu loans, which are not assets
of the issuing entity, (b) with respect to the ExchangeRight Net Leased
Portfolio 28 Mortgage Loan, two other pari passu loans, which are not
assets of the issuing entity, (c) with respect to the Meidinger Tower Mortgage
Loan, one other pari passu loan, which is not an asset of the issuing
entity, (d) with respect to the Maui Portfolio Mortgage Loan, one other pari
passu loan, which is not an asset of the issuing entity and (e) with
respect to the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan,
one other pari passu loan, which is not an asset of the issuing entity.
These loan combinations, including the 188 Spear Street Mortgage Loan, the
ExchangeRight Net Leased Portfolio 28 Mortgage Loan, the Meidinger Tower
Mortgage Loan, the Maui Portfolio Mortgage Loan and the Marriott SpringHill
Suites and Towneplace Suites Mortgage Loan, are being serviced and administered
pursuant to the Pooling and Servicing Agreement, which is incorporated by
reference as Exhibit 4.1 to this Annual Report on Form 10-K.

Exhibit Index) with respect to the ILPT Hawaii Portfolio Mortgage Loan, which
constituted approximately 2.0% of the asset pool of the issuing entity as of
its cut-off date. The ILPT Hawaii Portfolio Mortgage Loan is an asset of
the issuing entity and is part of a loan combination that includes the ILPT
Hawaii Portfolio Mortgage Loan and seventeen other pari passu loans,
which are not assets of the issuing entity. A pari passu portion of the
loan combination was securitized in the ILPT Trust 2019-SURF transaction (the " ILPT
2019-SURF Transaction "). This loan combination, including the ILPT Hawaii
Portfolio Mortgage Loan, is being serviced and administered pursuant to the
trust and servicing agreement for the ILPT 2019-SURF Transaction, which is
incorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K.

Exhibit Index) with respect to the 2 North 6th Place Mortgage Loan, which
constituted approximately 2.1% of the asset pool of the issuing entity as of its
cut-off date. The 2 North 6th Place Mortgage Loan is an asset of the
issuing entity and is part of a loan combination that includes the 2 North 6th
Place Mortgage Loan, two other pari passu loans and two subordinate
companion loans, which are not assets of the issuing entity. A pari passu
portion of the loan combination was securitized in the Natixis Commercial
Mortgage Securities Trust 2019-LVL transaction (the " NCMS 2019-LVL
Transaction "). This loan combination, including the 2 North 6th Place
Mortgage Loan, is being serviced and administered pursuant to the trust and
servicing agreement for the NCMS 2019-LVL Transaction, which is incorporated by
reference as Exhibit 4.3 to this Annual Report on Form 10-K.

Exhibit Index) with respect to the Town Square Mortgage Loan, which constituted
approximately 1.1% of the asset pool of the issuing entity as of its cut-off
date. The Town Square Mortgage Loan is an asset of the issuing entity and
is part of a loan combination that includes the Town Square Mortgage Loan and
one other pari passu loan, which is not an asset of the issuing entity.
The other pari passu portion of the loan combination was securitized in
the Wells Fargo Commercial Mortgage Trust 2019-C50 transaction, Commission File
Number 333-226486-05 (the " WFCM 2019-C50 Transaction "). This loan
combination, including the Town Square Mortgage Loan, is being serviced and
administered pursuant to the pooling and servicing agreement for the WFCM
2019-C50 Transaction, which is incorporated by reference as Exhibit 4.4 to this
Annual Report on Form 10-K.

Exhibit Index) with respect to the 10000 Santa Monica Boulevard Mortgage Loan,
which constituted approximately 1.1% of the asset pool of the issuing entity as
of its cut-off date. The 10000 Santa Monica Boulevard Mortgage Loan is an
asset of the issuing entity and is part of a loan combination that includes the
10000 Santa Monica Boulevard Mortgage Loan, seven other pari passu loans
and one subordinate companion loan, which are not assets of the issuing entity.
A pari passu portion of the loan combination was securitized in the
Natixis Commercial Mortgage Securities Trust 2019-10K transaction (the " NCMS
2019-10K Transaction "). This loan combination, including the 10000 Santa
Monica Boulevard Mortgage Loan, is being serviced and administered pursuant to
the trust and servicing agreement for the NCMS 2019-10K Transaction, which is
incorporated by reference as Exhibit 4.5 to this Annual Report on Form 10-K.

Exhibit Index) with respect to the Vanguard Portfolio Mortgage Loan and the
SWVP Portfolio Mortgage Loan, which constituted approximately 6.1% and 1.6%,
respectively, of the asset pool of the issuing entity as of its cut-off
date. The Vanguard Portfolio Mortgage Loan and the SWVP Portfolio
Mortgage Loan are each an asset of the issuing entity and are each part of a
loan combination that includes (a) with respect to the Vanguard Portfolio
Mortgage Loan, three other pari passu loans and one subordinate
companion loan, which are not assets of the issuing entity or (b) with respect
to the SWVP Portfolio Mortgage Loan, eight other pari passu loans, which
are not assets of the issuing entity. A pari passu portion of each loan
combination was securitized in the BBCMS Mortgage Trust 2019-C3 transaction,
Commission File Number 333-226850-02 (the " BBCMS 2019-C3 Transaction ").
These loan combinations, including the Vanguard Portfolio Mortgage Loan and the
SWVP Portfolio Mortgage Loan, are being serviced and administered pursuant to
the pooling and servicing agreement for the BBCMS 2019-C3 Transaction, which is
incorporated by reference as Exhibit 4.6 to this Annual Report on Form 10-K.

Exhibit Index) with respect to the Moffett Towers II - Buildings 3 & 4
Mortgage Loan, which constituted approximately 6.9% of the asset pool of the
issuing entity as of its cut-off date. The Moffett Towers II - Buildings
3 & 4 Mortgage Loan is an asset of the issuing entity and is part of a loan
combination that includes the Moffett Towers II - Buildings 3 & 4 Mortgage
Loan, ten other pari passu loans and three subordinate companion loans,
which are not assets of the issuing entity. A pari passu portion of the
loan combination was securitized in the MFTII 2019-B3B4 Mortgage Trust
transaction (the " MFTII 2019-B3B4 Transaction "). This loan combination,
including the Moffett Towers II - Buildings 3 & 4 Mortgage Loan, is being
serviced and administered pursuant to the trust and servicing agreement for the
MFTII 2019-B3B4 Transaction, which is incorporated by reference as Exhibit 4.7
to this Annual Report on Form 10-K.

Exhibit Index) with respect to the ExchangeRight Net Leased Portfolio #27
Mortgage Loan, which constituted approximately 1.1% of the asset pool of the issuing
entity as of its cut-off date. The ExchangeRight Net Leased Portfolio #27
Mortgage Loan is an asset of the issuing entity and is part of a loan
combination that includes the ExchangeRight Net Leased Portfolio #27 Mortgage
Loan and one other pari passu loan, which is not an asset of the issuing
entity. The other pari passu portion of the loan combination was
securitized in the Wells Fargo Commercial Mortgage Trust 2019-C51 transaction,
Commission File Number 333-226486-06 (the " WFCM 2019-C51 Transaction ").
This loan combination, including the ExchangeRight Net Leased Portfolio #27
Mortgage Loan, is being serviced and administered pursuant to the pooling and
servicing agreement for the WFCM 2019-C51 Transaction, which is incorporated by
reference as Exhibit 4.8 to this Annual Report on Form 10-K.

Exhibit Index) with respect to the Visions Hotel Portfolio II Mortgage Loan and
the 125 Borinquen Place Mortgage Loan, which constituted approximately 1.8% and
1.8%, respectively, of the asset pool of the issuing entity as of its cut-off
date. The Visions Hotel Portfolio II Mortgage Loan and the 125 Borinquen
Place Mortgage Loan are each an asset of the issuing entity and are each part
of a loan combination that includes (a) with respect to the Visions Hotel
Portfolio II Mortgage Loan, two other pari passu loans, which are not
assets of the issuing entity or (b) with respect to the 125 Borinquen Place
Mortgage Loan, one other pari passu loan, which is not an asset of the
issuing entity. The other pari passu portion of each loan combination
was securitized in the Morgan Stanley Capital I Trust 2019-H7 transaction,
Commission File Number 333-227446-05 (the " MSC 2019-H7 Transaction ").
These loan combinations, including the Visions Hotel Portfolio II Mortgage Loan
and the 125 Borinquen Place Mortgage Loan, are being serviced and administered
pursuant to the pooling and servicing agreement for the MSC 2019-H7
Transaction, which is incorporated by reference as Exhibit 4.9 to this Annual
Report on Form 10-K.

Exhibit Index) with respect to the CIRE Equity Retail & Industrial
Portfolio Mortgage Loan, which constituted approximately 1.0% of the asset pool
of the issuing entity as of its cut-off date. The CIRE Equity Retail
& Industrial Portfolio Mortgage Loan is an asset of the issuing entity and
is part of a loan combination that includes the CIRE Equity Retail &
Industrial Portfolio Mortgage Loan and six other pari passu loans, which
are not assets of the issuing entity. A pari passu portion of the loan
combination was securitized in the Benchmark 2019-B12 Mortgage Trust
transaction, Commission File Number 333-228597-01 (the " Benchmark 2019-B12
Transaction "). This loan combination, including the CIRE Equity Retail
& Industrial Portfolio Mortgage Loan, is being serviced and administered
pursuant to the pooling and servicing agreement for the Benchmark 2019-B12
Transaction, which is incorporated by reference as Exhibit 4.10 to this Annual
Report on Form 10-K.

Exhibit Index) with respect to the Mount Kemble Mortgage Loan and the
Renaissance Center VI Mortgage Loan, which constituted approximately 1.5% and
1.3%, respectively, of the asset pool of the issuing entity as of its cut-off
date. The Mount Kemble Mortgage Loan and the Renaissance Center VI
Mortgage Loan are each an asset of the issuing entity and are each part of a
loan combination that includes the Mount Kemble Mortgage Loan or the
Renaissance Center VI Mortgage Loan and one other pari passu loan, each
of which is not an asset of the issuing entity. The other pari passu
portion of each loan combination was securitized in the Wells Fargo Commercial
Mortgage Trust 2019-C52 transaction, Commission File Number 333-226486-08 (the
" WFCM 2019-C52 Transaction "). These loan combinations, including the
Mount Kemble Mortgage Loan and the Renaissance Center VI Mortgage Loan, are
being serviced and administered pursuant to the pooling and servicing agreement
for the WFCM 2019-C52 Transaction, which is incorporated by reference as
Exhibit 4.11 to this Annual Report on Form 10-K.

Exhibit Index) with respect to the Ambler Yards Mortgage Loan, which
constituted approximately 1.1% of the asset pool of the issuing entity as of
its cut-off date. The Ambler Yards Mortgage Loan is an asset of the
issuing entity and is part of a loan combination that includes the Ambler Yards
Mortgage Loan and one other pari passu loan, which is not an asset of
the issuing entity. This loan combination, including the Ambler Yards Mortgage
Loan, was serviced under the Pooling and Servicing Agreement for the issuing
entity prior to the closing of the securitization of the other pari passu
portion of the Ambler Yards loan combination in the UBS Commercial Mortgage
Trust 2019-C17 transaction, Commission File Number 333-227784-04 (the " UBS
2019-C17 Transaction "). After the closing of the UBS 2019-C17
Transaction on October 15, 2019, this loan combination, including the Ambler
Yards Mortgage Loan was, and will continue to be, serviced and administered
pursuant to the pooling and servicing agreement with respect to the UBS
2019-C17 Transaction, which is incorporated by reference as Exhibit 4.12 to
this Annual Report on Form 10-K.

Exhibit Index) with respect to the Inland Life Storage Portfolio Mortgage Loan,
which constituted approximately 3.3% of the asset pool of the issuing entity as
of its cut-off date. The Inland Life Storage Portfolio Mortgage Loan is
an asset of the issuing entity and is part of a loan combination that includes
the Inland Life Storage Portfolio Mortgage Loan and four other pari passu
loans, which are not assets of the issuing entity. This loan combination,
including the Inland Life Storage Portfolio Mortgage Loan, was serviced under
the pooling and servicing agreement for the WFCM 2019-C52 Transaction prior to
the closing of the securitization of a pari passu portion of the Inland
Life Storage Portfolio loan combination in the CF 2019-CF2 Mortgage Trust
transaction, Commission File Number 333-228697-02 (the " CF 2019-CF2
Transaction "). After the closing of the CF 2019-CF2 Transaction on
October 17, 2019, this loan combination, including the Inland Life Storage
Portfolio Mortgage Loan was, and will continue to be, serviced and administered
pursuant to the pooling and servicing agreement with respect to the CF 2019-CF2
Transaction, which is incorporated by reference as Exhibit 4.13 to this Annual
Report on Form 10-K.

 The master servicer of a pooling
and servicing agreement or trust and servicing agreement also functions as the
primary servicer of the related mortgage loans serviced and administered
pursuant to such agreement unless a separate primary servicer is identified
herein. If this report does not identify a separate primary servicer, the
servicer compliance statement provided by the master servicer under any such
agreement also encompasses its responsibilities as primary servicer of the
related mortgage loan or mortgage loans.

 Wells Fargo Bank, National
Association is the master servicer and certificate administrator of the
mortgage loans serviced under the Pooling and Servicing Agreement and the
primary servicer of the Mount Kemble Mortgage Loan, the Renaissance Center VI
Mortgage Loan, the ExchangeRight Net Leased Portfolio #27 Mortgage Loan, the
Town Square Mortgage Loan and the Ambler Yards Mortgage Loan. As a result,
Wells Fargo Bank, National Association is a "servicer" as defined in Item
1108(a)(2)(iii) of Regulation AB, in the capacities described above, because it
is servicing mortgage loans that constituted 10% or more of the assets of the
issuing entity as of its cut-off date. The assessments of compliance with
applicable servicing criteria, accountants' attestation reports and servicer
compliance statements delivered by Wells Fargo Bank, National Association in
the capacities described above are listed in the Exhibit Index.

 Wells Fargo Bank, National
Association is the custodian of the mortgage loans serviced under the Pooling
and Servicing Agreement, the Moffett Towers II - Buildings 3 & 4 Mortgage
Loan, the Vanguard Portfolio Mortgage Loan, the 2 North 6th Place Mortgage
Loan, the ILPT Hawaii Portfolio Mortgage Loan, the Visions Hotel Portfolio II
Mortgage Loan, the 125 Borinquen Place Mortgage Loan, the SWVP Portfolio
Mortgage Loan, the Mount Kemble Mortgage Loan, the Renaissance Center VI
Mortgage Loan, the 10000 Santa Monica Boulevard Mortgage Loan, the Town Square
Mortgage Loan, the ExchangeRight Net Leased Portfolio #27 Mortgage Loan and the
Ambler Yards Mortgage Loan. As a result, Wells Fargo Bank, National
Association is a servicing function participant in the capacities described
above, because it is servicing mortgage loans that constituted 5% or more of
the assets of the issuing entity as of its cut-off date. The assessments of
compliance with applicable servicing criteria and accountants' attestation
reports delivered by Wells Fargo Bank, National Association in the capacities
described above are listed in the Exhibit Index.

 Rialto Capital Advisors, LLC is
the special servicer of the mortgage loans serviced under the Pooling and
Servicing Agreement, the ILPT Hawaii Portfolio Mortgage Loan, the Ambler Yards
Mortgage Loan and the Town Square Mortgage Loan. As a result, Rialto Capital
Advisors, LLC is a "servicer" as defined in Item 1108(a)(2)(iii) of Regulation
AB, in the capacities described above, because it is servicing mortgage loans
that constituted 10% or more of the assets of the issuing entity as of its
cut-off date. The assessments of compliance with applicable servicing criteria,
accountants' attestation reports and servicer compliance statements delivered
by Rialto Capital Advisors, LLC in the capacities described above are listed in
the Exhibit Index.

 Park Bridge Lender Services LLC is
the operating advisor of the mortgage loans serviced under the Pooling and
Servicing Agreement, the Inland Life Storage Portfolio Mortgage Loan, the ILPT
Hawaii Portfolio Mortgage Loan and the Town Square Mortgage Loan. As a
result, Park Bridge Lender Services LLC is a servicing function participant in
the capacities described above, because it is servicing mortgage loans that
constituted 5% or more of the assets of the issuing entity as of its cut-off
date. The assessments of compliance with applicable servicing criteria and
accountants' attestation reports delivered by Park Bridge Lender Services LLC
in the capacities described above are listed in the Exhibit Index.

 Midland Loan
Services, a Division of PNC Bank, National Association is the primary servicer
of the Ambler Yards Mortgage Loan, the Meidinger Tower Mortgage Loan, the Maui
Portfolio Mortgage Loan, the ILPT Hawaii Portfolio Mortgage Loan, the 125
Borinquen Place Mortgage Loan, the Visions Hotel Portfolio II Mortgage Loan,
the SWVP Portfolio Mortgage Loan and the CIRE Equity Retail & Industrial
Portfolio Mortgage Loan and the primary servicer and special servicer of
the Vanguard Portfolio Mortgage Loan. As a result, Midland Loan Services, a
Division of PNC Bank, National Association is a "servicer" as defined in Item
1108(a)(2)(iii) of Regulation AB, in the capacities described above, because it
is servicing mortgage loans that constituted 10% or more of the assets of the
issuing entity as of its cut-off date. The assessments of compliance with
applicable servicing criteria, accountants' attestation reports and servicer
compliance statements delivered by Midland Loan Services, a Division of PNC
Bank, National Association in the capacities described above are listed in the
Exhibit Index.

 KeyBank National Association is
the primary servicer of the Moffett Towers II - Buildings 3 & 4 Mortgage
Loan, the Inland Life Storage Portfolio Mortgage Loan and the 2 North 6th Place
Mortgage Loan and the primary servicer and special servicer of the 10000 Santa
Monica Boulevard Mortgage Loan. As a result, KeyBank National Association is a
"servicer" as defined in Item 1108(a)(2)(iii) of Regulation AB, in the
capacities described above, because it is servicing mortgage loans that
constituted 10% or more of the assets of the issuing entity as of its cut-off
date. The assessments of compliance with applicable servicing criteria,
accountants' attestation reports and servicer compliance statements delivered
by KeyBank National Association in the capacities described above are listed in
the Exhibit Index.

 Situs Holdings, LLC is the special
servicer of the 2 North 6th Place Mortgage Loan and the Moffett Towers II -
Buildings 3 & 4 Mortgage Loan. These mortgage loans constitute more
than 5%, but less than 10%, of the pool assets of the issuing entity.
Therefore, the Depositor included in this Annual Report on Form 10-K an
assessment of compliance with applicable servicing criteria for Situs Holdings,
LLC and an accountants' attestation report pursuant to Item 1122 of Regulation
AB because Situs Holdings, LLC is servicing more than 5% of the pool
assets. Situs Holdings, LLC is an affiliate of Rialto Real Estate Fund
III – Debt, LP, one of the sponsors. Therefore, the Depositor included in this
Annual Report on Form 10-K a servicer compliance statement for Situs Holdings,
LLC pursuant to Item 1123 of Regulation AB.

 Pentalpha
Surveillance LLC is the operating advisor of the Vanguard Portfolio
Mortgage Loan, the 125 Borinquen Place Mortgage Loan, the Visions Hotel
Portfolio II Mortgage Loan, the SWVP Portfolio Mortgage Loan, the Mount Kemble
Mortgage Loan, the Renaissance Center VI Mortgage Loan, the Ambler Yards
Mortgage Loan, the ExchangeRight Net Leased Portfolio #27 Mortgage Loan and the
CIRE Equity Retail & Industrial Portfolio Mortgage Loan. As a result,
Pentalpha Surveillance LLC is a servicing function participant in the
capacities described above, because it is servicing mortgage loans that
constituted 5% or more of the assets of the issuing entity as of its cut-off
date. The assessments of compliance with applicable servicing criteria and
accountants' attestation reports delivered by Pentalpha Surveillance LLC in the
capacities described above are listed in the Exhibit Index.

 Argentic Services Company LP is
the special servicer of the Visions Hotel Portfolio II Mortgage Loan, the 125
Borinquen Place Mortgage Loan, the Renaissance Center VI Mortgage Loan and the
Mount Kemble Mortgage Loan. These mortgage loans constitute more than 5%,
but less than 10%, of the pool assets of the issuing entity. Therefore,
the Depositor included in this Annual Report on Form 10-K an assessment of
compliance with applicable servicing criteria for Argentic Services Company LP
and an accountants' attestation report pursuant to Item 1122 of Regulation AB
because Argentic Services Company LP is servicing more than 5% of the pool
assets. However, the Depositor is not required to include in this Annual
Report on Form 10-K a servicer compliance statement pursuant to Item 1123 of
Regulation AB of Argentic Services Company LP because Argentic Services Company
LP is an unaffiliated servicer servicing less than 10% of pool assets.

 LNR Partners, LLC is an affiliate
of Starwood Mortgage Capital LLC, one of the sponsors. Therefore, the
Depositor included in this Annual Report on Form 10-K a servicer compliance
statement for LNR Partners, LLC pursuant to Item 1123. Because LNR
Partners, LLC is servicing less than 5% of the pool assets, an assessment of
compliance with applicable servicing criteria and an accountants' attestation
report pursuant to Item 1122 of Regulation AB are not required by Regulation
AB. As the attestation made in the servicer compliance statement required
by Item 1123 relates to a review of the servicing activities of LNR Partners,
LLC under the applicable servicing agreement, and that review was conducted in
conjunction with the servicer's preparation of its assessment of compliance
with applicable servicing criteria, that assessment of compliance with
applicable servicing criteria and the accompanying accountants' attestation
report are included in this Annual Report on Form 10-K for the sake of
completeness.

 Wells Fargo Bank, National
Association acts as trustee of the ILPT Hawaii Portfolio Mortgage Loan, the 2
North 6th Place Mortgage Loan, the 10000 Santa Monica Boulevard Mortgage Loan,
the Vanguard Portfolio Mortgage Loan, the SWVP Portfolio Mortgage Loan, the
Moffett Towers II - Buildings 3 & 4 Mortgage Loan, the 125 Borinquen Place
Mortgage Loan and the Visions Hotel Portfolio II Mortgage Loan. Pursuant
to the trust and servicing agreement for the ILPT 2019-SURF Transaction, the
trust and servicing agreement for the NCMS 2019-LVL Transaction, the trust and
servicing agreement for the NCMS 2019-10K Transaction, the pooling and
servicing agreement for the BBCMS 2019-C3 Transaction, the trust and servicing
agreement for the MFTII 2019-B3B4 Transaction and the pooling and servicing
agreement for the MSC 2019-H7 Transaction, the trustee is required to provide
an assessment of compliance with applicable servicing criteria solely with
respect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances of funds
or guarantees regarding collections, cash flows or distributions, and any
interest or other fees charged for such advances, are made, reviewed and
approved as specified in the transaction agreements). However, during the
reporting period, the trustee did not perform any servicing function with
respect to the servicing criteria specified in Item 1122(d)(2)(iii) of
Regulation AB. The master servicer or the special servicer, to the extent
required, performed the servicing function identified with respect to Item
1122(d)(2)(iii) of Regulation AB, and each such party included Item
1122(d)(2)(iii) of Regulation AB in the assessment of compliance with
applicable servicing criteria and accountant's attestation report for the
subject transaction. As a result, this Annual Report on Form 10-K does
not include an assessment of compliance with applicable servicing criteria of
the trustee. One or more other servicers of the ILPT Hawaii Portfolio Mortgage
Loan, the 2 North 6th Place Mortgage Loan, the 10000 Santa Monica Boulevard
Mortgage Loan, the Vanguard Portfolio Mortgage Loan, the SWVP Portfolio
Mortgage Loan, the Moffett Towers II - Buildings 3 & 4 Mortgage Loan, the
125 Borinquen Place Mortgage Loan and the Visions Hotel Portfolio II Mortgage
Loan have delivered one or more assessments of compliance with respect to Item
1122(d)(2)(iii) of Regulation AB.

 Wilmington Trust, National
Association acts as trustee of the mortgage loans serviced under the Pooling
and Servicing Agreement, the Town Square Mortgage Loan, the ExchangeRight Net
Leased Portfolio #27 Mortgage Loan, the CIRE Equity Retail & Industrial
Portfolio Mortgage Loan, the Mount Kemble Mortgage Loan, the Renaissance Center
VI Mortgage Loan and the Ambler Yards Mortgage Loan. Pursuant to the
Pooling and Servicing Agreement, the pooling and servicing agreement for the
WFCM 2019-C50 Transaction, the pooling and servicing agreement for the WFCM
2019-C51 Transaction, the pooling and servicing agreement for the Benchmark
2019-B12 Transaction, the pooling and servicing agreement for the WFCM 2019-C52
Transaction and the pooling and servicing agreement for the UBS 2019-C17
Transaction, the trustee is required to provide an assessment of compliance
with applicable servicing criteria solely with respect to Item 1122(d)(2)(iii)
of Regulation AB (regarding advances of funds or guarantees regarding collections,
cash flows or distributions, and any interest or other fees charged for such
advances, are made, reviewed and approved as specified in the transaction
agreements). However, during the reporting period, the trustee did not perform
any servicing function with respect to the servicing criteria specified in Item
1122(d)(2)(iii) of Regulation AB. The master servicer or the special
servicer, to the extent required, performed the servicing function identified
with respect to Item 1122(d)(2)(iii) of Regulation AB, and each such party
included Item 1122(d)(2)(iii) of Regulation AB in the assessment of compliance
with applicable servicing criteria and accountant's attestation report for the
subject transaction. As a result, this Annual Report on Form 10-K does
not include an assessment of compliance with applicable servicing criteria of
the trustee. One or more other servicers of the mortgage loans serviced under
the Pooling and Servicing Agreement, the Town Square Mortgage Loan, the
ExchangeRight Net Leased Portfolio #27 Mortgage Loan, the CIRE Equity Retail
& Industrial Portfolio Mortgage Loan, the Mount Kemble Mortgage Loan, the
Renaissance Center VI Mortgage Loan and the Ambler Yards Mortgage Loan have
delivered one or more assessments of compliance with respect to Item
1122(d)(2)(iii) of Regulation AB.

 Citibank, N.A. acts as trustee of
the Inland Life Storage Portfolio Mortgage Loan. Pursuant to the pooling
and servicing agreement for the CF 2019-CF2 Transaction, the trustee is
required to provide an assessment of compliance with applicable servicing
criteria solely with respect to Item 1122(d)(2)(iii) of Regulation AB
(regarding advances of funds or guarantees regarding collections, cash flows or
distributions, and any interest or other fees charged for such advances, are
made, reviewed and approved as specified in the transaction agreements).
However, during the reporting period, the trustee did not perform any servicing
function with respect to the servicing criteria specified in Item
1122(d)(2)(iii) of Regulation AB. The master servicer or the special
servicer, to the extent required, performed the servicing function identified
with respect to Item 1122(d)(2)(iii) of Regulation AB, and each such party
included Item 1122(d)(2)(iii) of Regulation AB in the assessment of compliance
with applicable servicing criteria and accountant's attestation report for the
subject transaction. As a result, this Annual Report on Form 10-K does
not include an assessment of compliance with applicable servicing criteria of
the trustee. One or more other servicers of the Inland Life Storage Portfolio
Mortgage Loan have delivered one or more assessments of compliance with respect
to Item 1122(d)(2)(iii) of Regulation AB.

 This Annual Report on Form 10-K
includes assessments of compliance with applicable servicing criteria and
accountants' attestation reports from CoreLogic Solutions, LLC. This
entity was engaged by the master servicer under the Pooling and Servicing
Agreement (except with respect to those mortgage loans for which Midland Loan
Services, a Division of PNC Bank, National Association is the primary
servicer) and the primary servicer of the Town Square Mortgage Loan, the
ExchangeRight Net Leased Portfolio #27 Mortgage Loan, the Mount Kemble Mortgage
Loan and the Renaissance Center VI Mortgage Loan to remit tax payments received
from the escrow accounts of borrowers to local taxing authorities, to report
tax amounts due, to verify tax parcel information, and to verify non-escrow tax
payments. These servicing functions are included within the servicing criteria
set forth in Item 1122(d)(4)(xi) of Regulation AB. Therefore, under the
principles-based definition of "servicer" set forth in Item 1101(j) of Regulation
AB that looks to the functions that an entity performs, this vendor is a
"servicer" for the purposes of Item 1122 of Regulation AB. See
Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

 This Annual Report on Form 10-K includes an assessment of
compliance with applicable servicing criteria, accountants' attestation report
and servicer compliance statement from Computershare Trust Company, National
Association (" CTCNA "). CTCNA was engaged by Wells Fargo Bank,
National Association (" Wells Fargo "), in its capacity as certificate
administrator and custodian, to perform certain specified servicing functions
identified in the assessment of compliance with applicable servicing criteria
and accountants' attestation reports. Wells Fargo engaged CTCNA in
connection with the sale of Wells Fargo's corporate trust services business to
CTCNA and its affiliates. Further, under the principles-based definition
of "servicer" set forth in Item 1101(j) of Regulation AB that looks to the
functions that an entity performs, this party is a "servicer" for the purposes
of Item 1123 of Regulation AB. See Compliance and Disclosure
Interpretations, Section 301.01 (Item 1101(j)).

 The assessments of compliance with
applicable servicing criteria, accountants' attestation reports and servicer
compliance statements of the certificate administrator of the ILPT Hawaii
Portfolio Mortgage Loan, the 2 North 6th Place Mortgage Loan, the Town Square
Mortgage Loan, the 10000 Santa Monica Boulevard Mortgage Loan, the Vanguard
Portfolio Mortgage Loan, the SWVP Portfolio Mortgage Loan, the ExchangeRight
Net Leased Portfolio #27 Mortgage Loan, the Moffett Towers II - Buildings 3
& 4 Mortgage Loan, the 125 Borinquen Place Mortgage Loan, the Visions Hotel
Portfolio II Mortgage Loan, the Mount Kemble Mortgage Loan, the Renaissance
Center VI Mortgage Loan, the Ambler Yards Mortgage Loan, the CIRE Equity Retail
& Industrial Portfolio Mortgage Loan and the Inland Life Storage Portfolio
Mortgage Loan are omitted from this Annual Report on Form 10-K as the
certificate administrator pursuant to the related pooling and servicing
agreement or trust and servicing agreement does not perform any activities that
address servicing criteria with respect to the issuing entity and because they
are each not a "servicer" that meets the criteria in Item 1108(a)(2)(i) through
(iii) of Regulation AB.

 With respect to the pari passu
loan combinations that include the Inland Life Storage Portfolio Mortgage Loan,
the SWVP Portfolio Mortgage Loan, the CIRE Equity Retail & Industrial
Portfolio Mortgage Loan, the ExchangeRight Net Leased Portfolio #27 Mortgage
Loan, the Visions Hotel Portfolio II Mortgage Loan, the 125 Borinquen Place
Mortgage Loan, the Mount Kemble Mortgage Loan and the Renaissance Center VI
Mortgage Loan, (i) the reports on assessment of compliance with servicing
criteria and attestation reports on assessment of compliance with servicing
criteria of K-Star Asset Management LLC as special servicer of the SWVP
Portfolio Mortgage Loan and the CIRE Equity Retail & Industrial Portfolio
Mortgage Loan, Greystone Servicing Company LLC (as successor to C-III Asset
Management LLC) as special servicer of the ExchangeRight Net Leased Portfolio
#27 Mortgage Loan and Citibank, N.A. as custodian of the CIRE Equity Retail
& Industrial Portfolio Mortgage Loan and the Inland Life Storage Portfolio
Mortgage Loan, listed on the Exhibit Index are omitted from this Annual Report
on Form 10-K as they are not required to be included on this Annual Report on
Form 10-K per Instruction 3 to Item 1122 of Regulation AB because they are
parties performing activities that address servicing criteria relating to 5% or
less of the assets of the issuing entity; and (ii) the servicer compliance
statements of K-Star Asset Management LLC as special servicer of the SWVP
Portfolio Mortgage Loan and the CIRE Equity Retail & Industrial Portfolio
Mortgage Loan, Greystone Servicing Company LLC (as successor to C-III Asset
Management LLC) as special servicer of the ExchangeRight Net Leased Portfolio
#27 Mortgage Loan and Argentic Services Company LP as special servicer of the
Visions Hotel Portfolio II Mortgage Loan, the 125 Borinquen Place Mortgage
Loan, the Mount Kemble Mortgage Loan and the Renaissance Center VI Mortgage
Loan, listed on the Exhibit Index are omitted from this Annual Report on Form
10-K as they are not required by Item 1123 of Regulation AB to be included on
this Annual Report on Form 10-K because they are each an unaffiliated party
that is not a "servicer" that meets the criteria in Item 1108(a)(2)(i) through
(iii) of Regulation AB.

 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.

 No single obligor represents 10% or more of the pool assets
held by the issuing entity.

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

 No entity or group of affiliated entities provides any external credit
enhancement or other support for the certificates within this transaction 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 or other support for the certificates within this
transaction as described under Item 1115 of Regulation AB.

 Item 1117 of Regulation AB, Legal Proceedings.

 The registrant knows of no material pending legal proceeding
involving the trust or any party related to the trust, other than routine
litigation incidental to the duties of those respective parties, and the
following, with respect to Wells Fargo Bank, National Association, as
certificate administrator, trustee, and custodian.

 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 previously
provided in the prospectus of the Registrant relating to the issuing entity
filed on August 28, 2019 pursuant to Rule 424(b)(2).

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

assessments of compliance with respect to the mortgage loans are attached
hereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA
to the Pooling and Servicing Agreement incorporated by reference as Exhibit 4.1
to this Annual Report on Form 10-K is a chart identifying the entities
participating in a servicing function for the transaction responsible for each

assessments of compliance with respect to the ILPT Hawaii Portfolio Mortgage
Loan, which is being serviced and administered pursuant to the trust and
servicing agreement for the ILPT 2019-SURF Transaction, are attached hereto
under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit L to the
trust and servicing agreement for the ILPT 2019-SURF Transaction incorporated
by reference as Exhibit 4.2 to this Annual Report on Form 10-K is a chart
identifying the entities participating in a servicing function for the ILPT
2019-SURF Transaction responsible for each applicable servicing criteria set
forth in Item 1122(d).

assessments of compliance with respect to the 2 North 6th Place Mortgage Loan,
which is being serviced and administered pursuant to the trust and servicing
agreement for the NCMS 2019-LVL Transaction, are attached hereto under Item 15
to this Annual Report on Form 10-K. Attached as Exhibit K to the trust and
servicing agreement for the NCMS 2019-LVL Transaction incorporated by reference
as Exhibit 4.3 to this Annual Report on Form 10-K is a chart identifying the
entities participating in a servicing function for the NCMS 2019-LVL
Transaction responsible for each applicable servicing criteria set forth in
Item 1122(d).

assessments of compliance with respect to the Town Square Mortgage Loan, which
is being serviced and administered pursuant to the pooling and servicing
agreement for the WFCM 2019-C50 Transaction, are attached hereto under Item 15
to this Annual Report on Form 10-K. Attached as Exhibit AA to the pooling and
servicing agreement for the WFCM 2019-C50 Transaction incorporated by reference
as Exhibit 4.4 to this Annual Report on Form 10-K is a chart identifying the
entities participating in a servicing function for the WFCM 2019-C50
Transaction responsible for each applicable servicing criteria set forth in
Item 1122(d).

assessments of compliance with respect to the 10000 Santa Monica Boulevard
Mortgage Loan, which is being serviced and administered pursuant to the trust
and servicing agreement for the NCMS 2019-10K Transaction, are attached hereto
under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit K to the
trust and servicing agreement for the NCMS 2019-10K Transaction incorporated by
reference as Exhibit 4.5 to this Annual Report on Form 10-K is a chart
identifying the entities participating in a servicing function for the NCMS
2019-10K Transaction responsible for each applicable servicing criteria set
forth in Item 1122(d).

assessments of compliance with respect to the Vanguard Portfolio Mortgage Loan
and the SWVP Portfolio Mortgage Loan, which are being serviced and administered
pursuant to the pooling and servicing agreement for the BBCMS 2019-C3
Transaction, are attached hereto under Item 15 to this Annual Report on Form
10-K. Attached as Exhibit AA to the pooling and servicing agreement for the
BBCMS 2019-C3 Transaction incorporated by reference as Exhibit 4.6 to this
Annual Report on Form 10-K is a chart identifying the entities participating in
a servicing function for the BBCMS 2019-C3 Transaction responsible for each

assessments of compliance with respect to the Moffett Towers II - Buildings 3
& 4 Mortgage Loan, which is being serviced and administered pursuant to the
trust and servicing agreement for the MFTII 2019-B3B4 Transaction, are attached
hereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit L
to the trust and servicing agreement for the MFTII 2019-B3B4 Transaction
incorporated by reference as Exhibit 4.7 to this Annual Report on Form 10-K is
a chart identifying the entities participating in a servicing function for the
MFTII 2019-B3B4 Transaction responsible for each applicable servicing criteria
set forth in Item 1122(d).

assessments of compliance with respect to the ExchangeRight Net Leased
Portfolio #27 Mortgage Loan, which is being serviced and administered pursuant
to the pooling and servicing agreement for the WFCM 2019-C51 Transaction, are
attached hereto under Item 15 to this Annual Report on Form 10-K. Attached as
Exhibit AA to the pooling and servicing agreement for the WFCM 2019-C51
Transaction incorporated by reference as Exhibit 4.8 to this Annual Report on
Form 10-K is a chart identifying the entities participating in a servicing
function for the WFCM 2019-C51 Transaction responsible for each applicable
servicing criteria set forth in Item 1122(d).

assessments of compliance with respect to the 125 Borinquen Place Mortgage Loan
and the Visions Hotel Portfolio II Mortgage Loan, which are being serviced and
administered pursuant to the pooling and servicing agreement for the MSC
2019-H7 Transaction, are attached hereto under Item 15 to this Annual Report on
Form 10-K. Attached as Exhibit AA to the pooling and servicing agreement for
the MSC 2019-H7 Transaction incorporated by reference as Exhibit 4.9 to this
Annual Report on Form 10-K is a chart identifying the entities participating in
a servicing function for the MSC 2019-H7 Transaction responsible for each

assessments of compliance with respect to the CIRE Equity Retail &
Industrial Portfolio Mortgage Loan, which is being serviced and administered
pursuant to the pooling and servicing agreement for the Benchmark 2019-B12
Transaction, are attached hereto under Item 15 to this Annual Report on Form
10-K. Attached as Exhibit O to the pooling and servicing agreement for the Benchmark
2019-B12 Transaction incorporated by reference as Exhibit 4.10 to this Annual
Report on Form 10-K is a chart identifying the entities participating in a
servicing function for the Benchmark 2019-B12 Transaction responsible for each

assessments of compliance with respect to the Mount Kemble Mortgage Loan and
the Renaissance Center VI Mortgage Loan, which are being serviced and
administered pursuant to the pooling and servicing agreement for the WFCM
2019-C52 Transaction, are attached hereto under Item 15 to this Annual Report
on Form 10-K. Attached as Exhibit AA to the pooling and servicing agreement for
the WFCM 2019-C52 Transaction incorporated by reference as Exhibit 4.11 to this
Annual Report on Form 10-K is a chart identifying the entities participating in
a servicing function for the WFCM 2019-C52 Transaction responsible for each

assessments of compliance with respect to the Ambler Yards Mortgage Loan, which
is being serviced and administered pursuant to the pooling and servicing
agreement for the UBS 2019-C17 Transaction, are attached hereto under Item 15
to this Annual Report on Form 10-K. Attached as Exhibit Z to the pooling and
servicing agreement for the UBS 2019-C17 Transaction incorporated by reference
as Exhibit 4.12 to this Annual Report on Form 10-K is a chart identifying the
entities participating in a servicing function for the UBS 2019-C17 Transaction
responsible for each applicable servicing criteria set forth in Item 1122(d).

assessments of compliance with respect to the Inland Life Storage Portfolio
Mortgage Loan, which is being serviced and administered pursuant to the pooling
and servicing agreement for the CF 2019-CF2 Transaction, are attached hereto
under Item 15 to this Annual Report on Form 10-K. Attached as Schedule II to
the pooling and servicing agreement for the CF 2019-CF2 Transaction
incorporated by reference as Exhibit 4.13 to this Annual Report on Form 10-K is
a chart identifying the entities participating in a servicing function for the
CF 2019-CF2 Transaction responsible for each applicable servicing criteria set
forth in Item 1122(d).

 Item 1123 of Regulation AB, Servicer Compliance Statement.

 The servicer compliance statements are attached as Exhibits
to this Annual Report on Form 10-K.

 Item 15. Exhibits and Financial Statement Schedules

 (a) The following is a list of documents filed as part of
this Annual Report on Form 10-K:

 (1) Not applicable

 (2) Not applicable

 (3) See below

 4.1
and Servicing Agreement, dated as of August 1, 2019, among Barclays Commercial
Mortgage Securities LLC, as Depositor, Wells Fargo Bank, National Association,
as Master Servicer, Rialto Capital Advisors, LLC, as 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 August 28, 2019 under

 4.2
 Trust
and Servicing Agreement, dated as of March 7, 2019, among Morgan Stanley
Capital I Inc., as Depositor, Midland Loan Services, a Division of PNC Bank,
National Association, as Servicer, Rialto Capital Advisors, LLC, as Special
Servicer, Wells Fargo Bank, National Association, as Certificate Administrator,
as Custodian and as Trustee, and Park Bridge Lender Services LLC, as Operating
Advisor (filed as Exhibit 4.6 to the registrant's Current Report on Form 8-K

 4.3
 Trust
and Servicing Agreement, dated as of April 23, 2019, among Natixis Commercial
Mortgage Securities LLC, as Depositor, KeyBank National Association, as
Servicer, Situs Holdings, LLC, as Special Servicer, and Wells Fargo Bank,
National Association, as Trustee and Certificate Administrator (filed as
Exhibit 4.5 to the registrant's Current Report on Form 8-K filed on August 28,

 4.4
and Servicing Agreement, dated as of May 1, 2019, among Wells Fargo Commercial
Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, National
Association, as Master Servicer, Rialto Capital Advisors, LLC, as 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 4.10 to the registrant's Current Report on Form 8-K filed on August
28, 2019 under Commission File No. 333-226850-03 and incorporated by reference

 4.5
 Trust
and Servicing Agreement, dated as of June 4, 2019, among Natixis Commercial
Mortgage Securities LLC, as Depositor, KeyBank National Association, as
Servicer, KeyBank National Association, as Special Servicer, and Wells Fargo
Bank, National Association, as Trustee and as Certificate Administrator (filed
as Exhibit 4.9 to the registrant's Current Report on Form 8-K filed on August
28, 2019 under Commission File No. 333-226850-03 and incorporated by reference

 4.6
and Servicing Agreement, dated as of June 1, 2019, among Barclays Commercial
Mortgage Securities LLC, as Depositor, Midland Loan Services, a Division of PNC
Bank, National Association, as Master Servicer, Midland Loan Services, a
Division of PNC Bank, National Association, as Special Servicer, Wells Fargo
Bank, National Association, as Certificate Administrator, Wells Fargo Bank,
National Association, as Trustee, and Pentalpha Surveillance LLC, as Operating
Advisor and as Asset Representations Reviewer (filed as Exhibit 4.3 to the

 4.7
 Trust
and Servicing Agreement, dated as of July 11, 2019, among Barclays Commercial
Mortgage Securities LLC, as Depositor, KeyBank National Association, as
Servicer, Situs Holdings, LLC, as Special Servicer, and Wells Fargo Bank,
National Association, as Certificate Administrator and Trustee (filed as
Exhibit 4.2 to the registrant's Current Report on Form 8-K filed on August 28,

 4.8
and Servicing Agreement, dated as of July 1, 2019, among Wells Fargo Commercial
Mortgage Securities, 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,
Wilmington Trust, National Association, as Trustee, and Pentalpha Surveillance
LLC, as Operating Advisor and as Asset Representations Reviewer (filed as
Exhibit 4.8 to the registrant's Current Report on Form 8-K filed on August 28,

 4.9
and Servicing Agreement, dated as of July 1, 2019, among 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 Asset Representations
Reviewer (filed as Exhibit 4.7 to the registrant's Current Report on Form 8-K

 4.10
and Servicing Agreement, dated as of August 1, 2019, among Citigroup Commercial
Mortgage Securities Inc., as Depositor, Midland Loan Services, a Division of
PNC Bank, National Association, as Master Servicer, Midland Loan Services, a
Division of PNC Bank, National Association, Pacific Life Insurance Company and
Trimont Real Estate Advisors, LLC, each as Special Servicer, Pentalpha
Surveillance LLC, as Operating Advisor and Asset Representations Reviewer,
Citibank, N.A., as Certificate Administrator, and Wilmington Trust, National
Association, as Trustee (filed as Exhibit 4.11 to the registrant's Current
Report on Form 8-K filed on August 28, 2019 under Commission File No.
333-226850-03 and incorporated by reference herein).

 4.11
and Servicing Agreement, dated as of August 1, 2019, among Wells Fargo
Commercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, National
Association, as Master Servicer, LNR Partners, LLC, as Special Servicer, Wells
Fargo Bank, National Association, as Certificate Administrator, Wilmington
Trust, National Association, as Trustee, and Pentalpha Surveillance LLC, as
Operating Advisor and as Asset Representations Reviewer (filed as Exhibit 4.4
to the registrant's Current Report on Form 8-K filed on August 28, 2019 under

 4.12
and Servicing Agreement, dated as of October 1, 2019, among UBS Commercial
Mortgage Securitization Corp., as Depositor, Wells Fargo Bank, National
Association, as Master Servicer, Rialto Capital Advisors, LLC, as Special
Servicer, Wells Fargo Bank, National Association, as Certificate Administrator,
Wilmington Trust, National Association, as Trustee, and Pentalpha Surveillance
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 October 18,

 4.13
and Servicing Agreement, dated as of October 1, 2019, among CCRE Commercial
Mortgage Securities, L.P., as Depositor, KeyBank National Association, as
Master Servicer, KeyBank National Association and LNR Partners, LLC, each as a
Special Servicer, Citibank, N.A., as Trustee, Citibank, N.A., as Certificate
Administrator, Paying Agent and Custodian, Park Bridge Lender Services LLC, as
Operating Advisor, and Park Bridge Lender Services LLC, as Asset
Representations Reviewer (filed as Exhibit 4.2 to the registrant's Current
Report on Form 8-K filed on October 18, 2019 under Commission File No.
333-226850-03 and incorporated by reference herein).

 4.14
 Primary
Servicing Agreement, dated as of August 1, 2019, between Wells Fargo Bank,
National Association, as Master Servicer, and Midland Loan Services, a Division
of PNC Bank, National Association, as Primary Servicer (filed as Exhibit 4.32
to the registrant's Current Report on Form 8-K filed on August 28, 2019 under

 4.15
Agreement, dated as of July 11, 2019, by and among Barclays Bank PLC, as Note
A-1-A and Note B-1 Holder, Barclays Capital Real Estate Inc., as Initial Note
A-1-B Holder, Initial Note A-1-D Holder and Initial Note A-1-E Holder, Bank of
America, N.A., as Note A-1-C Holder, Deutsche Bank AG, New York Branch, as
Initial Note A-2-A Holder, Initial Note A-2-B Holder, Initial Note A-2-C Holder
and Initial Note B-2 Holder, and Goldman Sachs Bank USA, as Initial Note A-3-A
Holder, Initial Note A-3-B Holder, Initial Note A-3-C Holder and Initial Note
B-3 Holder (filed as Exhibit 4.12 to the registrant's Current Report on Form
8-K filed on August 28, 2019 under Commission File No. 333-226850-03 and

 4.16
Between Note Holders, dated as of June 14, 2019, by and between Barclays
Capital Real Estate Inc., as Initial Note A-1 Holder, Barclays Capital Real
Estate Inc., as Initial Note A-2 Holder and Barclays Capital Real Estate Inc.,
as Initial Note A-3 Holder (filed as Exhibit 4.13 to the registrant's Current
Report on Form 8-K filed on August 28, 2019 under Commission File No.
333-226850-03 and incorporated by reference herein).

 4.17
 Amended
and Restated Co-Lender Agreement, dated as of June 11, 2019, by and among
Natixis Real Estate Capital LLC, as Note A-1 Holder, Natixis Real Estate
Capital LLC, as Note A-2 Holder, Natixis Real Estate Capital LLC, as Note A-3
Holder, Natixis Real Estate Capital LLC, as Note A-4 Holder, Natixis Real
Estate Capital LLC, as Note A-5 Holder, Natixis Real Estate Capital LLC, as
Note A-6 Holder, and TCM CRE REIT LLC, as Note B Holder (filed as Exhibit 4.14
to the registrant's Current Report on Form 8-K filed on August 28, 2019 under

 4.18
Between Note Holders, dated as of August 28, 2019 by and among, Societe
Generale Financial Corporation, as Initial Note A-1 Holder, Societe Generale
Financial Corporation, as Initial Note A-2 Holder, and Societe Generale
Financial Corporation, as Initial Note A-3 Holder (filed as Exhibit 4.15 to the

 4.19
Between Note Holders, dated as of July 2, 2019 by and between, KeyBank National
Association, as Initial Note A-1-A Holder, Initial Note A-1-B Holder and
Initial Note A-1-C Holder, and Barclays Capital Real Estate Inc., as Initial
Note A-2-A Holder and Initial Note A-2-B Holder (filed as Exhibit 4.16 to the

 4.20
 Amended
and Restated Co-Lender Agreement, dated as of February 11, 2019, by and among
Natixis Real Estate Capital LLC, as Note A-1 Holder, Natixis Real Estate
Capital LLC, as Note A-2 Holder, Natixis Real Estate Capital LLC, as Note A-3
Holder, Natixis Real Estate Capital LLC, as Note A-B Holder and John Hancock
Life Insurance Company (U.S.A.), as Note B Holder (filed as Exhibit 4.17 to the

 4.21
Between Note Holders, dated as of March 7, 2019, by and between Morgan Stanley
Bank, N.A., as Initial Note A-1 Holder, Initial Note A-5-1 Holder, Initial Note
A-5-2 Holder, Initial Note A-5-3 Holder and Initial Note A-5-4 Holder, Citi
Real Estate Funding Inc., as Initial Note A-2 Holder, Initial Note A-6-1
Holder, Initial Note A-6-2 Holder and Initial Note A-6-3 Holder, UBS AG, New
York Branch, as Initial Note A-3 Holder, Initial Note A-7-1 Holder, Initial
Note A-7-2 Holder, Initial Note A-9 Holder, Initial Note A-10 Holder and
Initial Note A-11 Holder, and JPMorgan Chase Bank, National Association, as
Initial Note A-4 Holder, Initial Note A-8-1 Holder and Initial Note A-8-2
Holder (filed as Exhibit 4.18 to the registrant's Current Report on Form 8-K

 4.22
Between Note Holders, dated as of August 28, 2019, by and between UBS AG, by
and through its branch office at 1285 Avenue of the Americas, New York, New
York, as Initial Note A-1 Holder, and UBS AG, by and through its branch office
at 1285 Avenue of the Americas, New York, New York, as Initial Note A-2 Holder
(filed as Exhibit 4.19 to the registrant's Current Report on Form 8-K filed on

 4.23
Agreement, dated as of May 31, 2019, by and between Starwood Mortgage Capital
LLC, as Initial Note A-1 Holder, and Starwood Mortgage Capital LLC, as Initial
Note A-2 Holder (filed as Exhibit 4.20 to the registrant's Current Report on
Form 8-K filed on August 28, 2019 under Commission File No. 333-226850-03 and

 4.24
Agreement, dated as of June 11, 2019, by and between Starwood Mortgage Capital
LLC, as Initial Note A-1 Holder, Starwood Mortgage Capital LLC, as Initial Note
A-2 Holder, and Starwood Mortgage Capital LLC, as Initial Note A-3 Holder
(filed as Exhibit 4.21 to the registrant's Current Report on Form 8-K filed on

 4.25
Between Note Holders, dated as of August 28, 2019, by and between UBS AG, by
and through its branch office at 1285 Avenue of the Americas, New York, New
York, as Initial Note A-1 Holder, and UBS AG, by and through its branch office
at 1285 Avenue of the Americas, New York, New York, as Initial Note A-2 Holder
(filed as Exhibit 4.22 to the registrant's Current Report on Form 8-K filed on

 4.26
Agreement, dated as of June 11, 2019, by and between Societe Generale Financial
Corporation and JPMorgan Chase Bank, National Association (filed as Exhibit
4.23 to the registrant's Current Report on Form 8-K filed on August 28, 2019
under Commission File No. 333-226850-03 and incorporated by reference herein).

 4.27
Agreement, dated as of July 25, 2019, by and between BSPRT Finance Sub-Lender
II, LLC, as Note A-1 Holder, and BSPRT Finance Sub-Lender II, LLC, as Note A-2
Holder (filed as Exhibit 4.24 to the registrant's Current Report on Form 8-K

 4.28
Agreement, dated as of July 25, 2019, by and between BSPRT Finance Sub-Lender
I, LLC, as Note A-1 Holder, and BSPRT Finance Sub-Lender I, LLC, as Note A-2
Holder (filed as Exhibit 4.25 to the registrant's Current Report on Form 8-K

 4.29
Agreement, dated as of June 6, 2019, by and between Starwood Mortgage Capital
LLC, as Initial Note A-1 Holder, and Starwood Mortgage Capital LLC, as Initial
Note A-2 Holder (filed as Exhibit 4.26 to the registrant's Current Report on
Form 8-K filed on August 28, 2019 under Commission File No. 333-226850-03 and

 4.30
Between Note Holders, dated as of June 14, 2019, by and between Barclays
Capital Real Estate Inc., as Initial Note A-1 Holder, and Barclays Capital Real
Estate Inc., as Initial Note A-2 Holder (filed as Exhibit 4.27 to the

 4.31
Agreement, dated as of June 4, 2019, by and among Natixis Real Estate Capital
LLC, as Note A-1 Holder, Natixis Real Estate Capital LLC, as Note A-2 Holder,
Natixis Real Estate Capital LLC, as Note A-3 Holder, Natixis Real Estate
Capital LLC, as Note A-4 Holder, Natixis Real Estate Capital LLC, as Note A-5
Holder, Natixis Real Estate Capital LC, as Note A-6 Holder, Natixis Real Estate
Capital LLC, as Note A-7 Holder, and Natixis Real Estate Capital LLC, as Note
A-B Holder (filed as Exhibit 4.28 to the registrant's Current Report on Form
8-K filed on August 28, 2019 under Commission File No. 333-226850-03 and

 4.32
Agreement, dated as of April 12, 2019, by and between BSPRT Finance Sub-Lender
I, LLC, as Note A-1 Holder, and BSPRT Finance Sub-Lender I, LLC, as Note A-2
Holder (filed as Exhibit 4.29 to the registrant's Current Report on Form 8-K

 4.33
Between Note Holders, dated as of August 28, 2019, by and between UBS AG, by
and through its branch office at 1285 Avenue of the Americas, New York, New
York, as Initial Note A-1 Holder, and UBS AG, by and through its branch office
at 1285 Avenue of the Americas, New York, New York, as Initial Note A-2 Holder
(filed as Exhibit 4.30 to the registrant's Current Report on Form 8-K filed on

 4.34
Between Noteholders, dated as of July 11, 2019, by and between Deutsche Bank
AG, New York Branch, as Initial Note A-1 Holder, Deutsche Bank AG, New York
Branch, as Initial Note A-2 Holder, Deutsche Bank AG, New York Branch, as
Initial Note A-3 Holder, UBS AG, by and through its branch office at 1285
Avenue of the Americas, New York, New York, as Initial Note A-4 Holder, UBS AG,
by and through its branch office at 1285 Avenue of the Americas, New York, New
York, as Initial Note A-5 Holder, and UBS AG, by and through its branch office
at 1285 Avenue of the Americas, New York, New York, as Initial Note A-6 Holder
(filed as Exhibit 4.31 to the registrant's Current Report on Form 8-K filed on

 Rule 13a-14(d)/15d-14(d) Certifications.

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

 33.1
 Wells Fargo Bank, National Association, as Master
Servicer

 33.2

 33.3
Wilmington Trust, National Association, as Trustee (Omitted. See Explanatory
Notes.)

 33.4
Certificate Administrator

 33.5
Custodian

 33.6
Advisor

 33.7
Participant

 33.8
as Servicing Function Participant for the Certificate Administrator

 33.9
as Servicing Function Participant for the Custodian

 33.10
National Association, as Primary Servicer

 33.11
Servicer of the 188 Spear Street Mortgage Loan (see Exhibit 33.1)

 33.12
of the 188 Spear Street Mortgage Loan (see Exhibit 33.2)

 33.13
Wilmington Trust, National Association, as Trustee of the 188 Spear Street

 33.14
Custodian of the 188 Spear Street Mortgage Loan (see Exhibit 33.5)

 33.15
Advisor of the 188 Spear Street Mortgage Loan (see Exhibit 33.6)

 33.16
Participant of the 188 Spear Street Mortgage Loan (see Exhibit 33.7)

 33.17 Computershare Trust Company, National Association, as
Servicing Function Participant for the Custodian (see Exhibit 33.9)

 33.18
Servicer of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see
Exhibit 33.1)

 33.19
of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see Exhibit 33.2)

 33.20
Wilmington Trust, National Association, as Trustee of the ExchangeRight Net
Leased Portfolio 28 Mortgage Loan (Omitted. See Explanatory Notes.)

 33.21
Custodian of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see
Exhibit 33.5)

 33.22
Advisor of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see Exhibit
33.6)

 33.23
Participant of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see
Exhibit 33.7)

 33.24

 33.25
National Association, as Primary Servicer of the Meidinger Tower Mortgage Loan
(see Exhibit 33.10)

 33.26
of the Meidinger Tower Mortgage Loan (see Exhibit 33.2)

 33.27
Wilmington Trust, National Association, as Trustee of the Meidinger Tower

 33.28
Custodian of the Meidinger Tower Mortgage Loan (see Exhibit 33.5)

 33.29
Advisor of the Meidinger Tower Mortgage Loan (see Exhibit 33.6)

 33.30

 33.31
National Association, as Primary Servicer of the Maui Portfolio Mortgage Loan
(see Exhibit 33.10)

 33.32
of the Maui Portfolio Mortgage Loan (see Exhibit 33.2)

 33.33
Wilmington Trust, National Association, as Trustee of the Maui Portfolio

 33.34
Custodian of the Maui Portfolio Mortgage Loan (see Exhibit 33.5)

 33.35
Advisor of the Maui Portfolio Mortgage Loan (see Exhibit 33.6)

 33.36

 33.37
Servicer of the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan
(see Exhibit 33.1)

 33.38
of the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan (see
Exhibit 33.2)

 33.39
Wilmington Trust, National Association, as Trustee of the Marriott SpringHill
Suites and Towneplace Suites Mortgage Loan (Omitted. See Explanatory Notes.)

 33.40
Custodian of the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan
(see Exhibit 33.5)

 33.41
Advisor of the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan
(see Exhibit 33.6)

 33.42
Participant of the Marriott SpringHill Suites and Towneplace Suites Mortgage
Loan (see Exhibit 33.7)

 33.43

 33.44
National Association, as Primary Servicer of the ILPT Hawaii Portfolio Mortgage
Loan (see Exhibit 33.10)

 33.45
of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 33.2)

 33.46
Wells Fargo Bank, National Association, as Trustee of the ILPT Hawaii Portfolio

 33.47
Custodian of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 33.5)

 33.48
Advisor of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 33.6)

 33.49

 33.50
of the 2 North 6th Place Mortgage Loan

 33.51
 Situs Holdings, LLC, as Special Servicer of the 2
North 6th Place Mortgage Loan

 33.52
Wells Fargo Bank, National Association, as Trustee of the 2 North 6th Place

 33.53
Custodian of the 2 North 6th Place Mortgage Loan (see Exhibit 33.5)

 33.54

 33.55
Servicer of the Town Square Mortgage Loan (see Exhibit 33.1)

 33.56
of the Town Square Mortgage Loan (see Exhibit 33.2)

 33.57
Wilmington Trust, National Association, as Trustee of the Town Square Mortgage

 33.58
Custodian of the Town Square Mortgage Loan (see Exhibit 33.5)

 33.59
Advisor of the Town Square Mortgage Loan (see Exhibit 33.6)

 33.60
Participant of the Town Square Mortgage Loan (see Exhibit 33.7)

 33.61

 33.62
of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 33.50)

 33.63
 KeyBank National Association, as Special Servicer
of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 33.50)

 33.64
Wells Fargo Bank, National Association, as Trustee of the 10000 Santa Monica
Boulevard Mortgage Loan (Omitted. See Explanatory Notes.)

 33.65
Custodian of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 33.5)

 33.66

 33.67
National Association, as Primary Servicer of the Vanguard Portfolio Mortgage
Loan (see Exhibit 33.10)

 33.68
National Association, as Special Servicer of the Vanguard Portfolio Mortgage
Loan (see Exhibit 33.10)

 33.69
Wells Fargo Bank, National Association, as Trustee of the Vanguard Portfolio

 33.70
Custodian of the Vanguard Portfolio Mortgage Loan (see Exhibit 33.5)

 33.71
of the Vanguard Portfolio Mortgage Loan

 33.72

 33.73
National Association, as Primary Servicer of the SWVP Portfolio Mortgage Loan
(see Exhibit 33.10)

 33.74
K-Star Asset Management LLC, as Special Servicer of the SWVP Portfolio Mortgage

 33.75
Wells Fargo Bank, National Association, as Trustee of the SWVP Portfolio

 33.76
Custodian of the SWVP Portfolio Mortgage Loan (see Exhibit 33.5)

 33.77
of the SWVP Portfolio Mortgage Loan (see Exhibit 33.71)

 33.78

 33.79
of the Moffett Towers II - Buildings 3 & 4 Mortgage Loan (see Exhibit
33.50)

 33.80
 Situs Holdings, LLC, as Special Servicer of the
Moffett Towers II - Buildings 3 & 4 Mortgage Loan (see Exhibit 33.51)

 33.81
Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II -
Buildings 3 & 4 Mortgage Loan (Omitted. See Explanatory Notes.)

 33.82
Custodian of the Moffett Towers II - Buildings 3 & 4 Mortgage Loan (see
Exhibit 33.5)

 33.83

 33.84
Servicer of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (see
Exhibit 33.1)

 33.85
Greystone Servicing Company LLC (as successor to C-III Asset Management LLC),
as Special Servicer of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan
(Omitted. See Explanatory Notes.)

 33.86
Wilmington Trust, National Association, as Trustee of the ExchangeRight Net
Leased Portfolio #27 Mortgage Loan (Omitted. See Explanatory Notes.)

 33.87
Custodian of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (see
Exhibit 33.5)

 33.88
of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (see Exhibit 33.71)

 33.89
Participant of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (see
Exhibit 33.7)

 33.90

 33.91
National Association, as Primary Servicer of the Visions Hotel Portfolio II
Mortgage Loan (see Exhibit 33.10)

 33.92
of the Visions Hotel Portfolio II Mortgage Loan

 33.93
Wells Fargo Bank, National Association, as Trustee of the Visions Hotel
Portfolio II Mortgage Loan (Omitted. See Explanatory Notes.)

 33.94
Custodian of the Visions Hotel Portfolio II Mortgage Loan (see Exhibit 33.5)

 33.95
of the Visions Hotel Portfolio II Mortgage Loan (see Exhibit 33.71)

 33.96

 33.97
National Association, as Primary Servicer of the 125 Borinquen Place Mortgage
Loan (see Exhibit 33.10)

 33.98
of the 125 Borinquen Place Mortgage Loan (see Exhibit 33.92)

 33.99
Wells Fargo Bank, National Association, as Trustee of the 125 Borinquen Place

 33.100
Custodian of the 125 Borinquen Place Mortgage Loan (see Exhibit 33.5)

 33.101
of the 125 Borinquen Place Mortgage Loan (see Exhibit 33.71)

 33.102

 33.103
National Association, as Primary Servicer of the CIRE Equity Retail &
Industrial Portfolio Mortgage Loan (see Exhibit 33.10)

 33.104
K-Star Asset Management LLC, as Special Servicer of the CIRE Equity Retail

 33.105
Wilmington Trust, National Association, as Trustee of the CIRE Equity Retail

 33.106
Citibank, N.A., as Custodian of the CIRE Equity Retail & Industrial
Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

 33.107
of the CIRE Equity Retail & Industrial Portfolio Mortgage Loan (see Exhibit
33.71)

 33.108
Servicer of the Mount Kemble Mortgage Loan (see Exhibit 33.1)

 33.109
of the Mount Kemble Mortgage Loan (see Exhibit 33.92)

 33.110
Wilmington Trust, National Association, as Trustee of the Mount Kemble Mortgage

 33.111
Custodian of the Mount Kemble Mortgage Loan (see Exhibit 33.5)

 33.112
of the Mount Kemble Mortgage Loan (see Exhibit 33.71)

 33.113
Participant of the Mount Kemble Mortgage Loan (see Exhibit 33.7)

 33.114

 33.115
Servicer of the Renaissance Center VI Mortgage Loan (see Exhibit 33.1)

 33.116
of the Renaissance Center VI Mortgage Loan (see Exhibit 33.92)

 33.117
Wilmington Trust, National Association, as Trustee of the Renaissance Center VI

 33.118
Custodian of the Renaissance Center VI Mortgage Loan (see Exhibit 33.5)

 33.119
of the Renaissance Center VI Mortgage Loan (see Exhibit 33.71)

 33.120
Participant of the Renaissance Center VI Mortgage Loan (see Exhibit 33.7)

 33.121

 33.122
Servicer of the Ambler Yards Mortgage Loan (see Exhibit 33.5)

 33.123
National Association, as Primary Servicer of the Ambler Yards Mortgage Loan
(see Exhibit 33.10)

 33.124
of the Ambler Yards Mortgage Loan (see Exhibit 33.2)

 33.125
Wilmington Trust, National Association, as Trustee of the Ambler Yards Mortgage

 33.126
Custodian of the Ambler Yards Mortgage Loan (see Exhibit 33.5)

 33.127
of the Ambler Yards Mortgage Loan (see Exhibit 33.71)

 33.128

 33.129
of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 33.50)

 33.130
 LNR Partners, LLC, as Special Servicer of the
Inland Life Storage Portfolio Mortgage Loan

 33.131
Citibank, N.A., as Trustee and Custodian of the Inland Life Storage Portfolio

 33.132
Advisor of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 33.6)

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

 34.1
 Wells Fargo Bank, National Association, as Master
Servicer

 34.2

 34.3
Wilmington Trust, National Association, as Trustee (Omitted. See Explanatory
Notes.)

 34.4
Certificate Administrator

 34.5
Custodian

 34.6
Advisor

 34.7
Participant

 34.8
as Servicing Function Participant for the Certificate Administrator

 34.9
as Servicing Function Participant for the Custodian

 34.10
National Association, as Primary Servicer

 34.11
Servicer of the 188 Spear Street Mortgage Loan (see Exhibit 34.1)

 34.12
of the 188 Spear Street Mortgage Loan (see Exhibit 34.2)

 34.13
Wilmington Trust, National Association, as Trustee of the 188 Spear Street

 34.14
Custodian of the 188 Spear Street Mortgage Loan (see Exhibit 34.5)

 34.15
Advisor of the 188 Spear Street Mortgage Loan (see Exhibit 34.6)

 34.16
Participant of the 188 Spear Street Mortgage Loan (see Exhibit 34.7)

 34.17

 34.18
Servicer of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see
Exhibit 34.1)

 34.19
of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see Exhibit 34.2)

 34.20
Wilmington Trust, National Association, as Trustee of the ExchangeRight Net
Leased Portfolio 28 Mortgage Loan (Omitted. See Explanatory Notes.)

 34.21
Custodian of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see
Exhibit 34.5)

 34.22
Advisor of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see Exhibit
34.6)

 34.23
Participant of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see
Exhibit 34.7)

 34.24

 34.25
National Association, as Primary Servicer of the Meidinger Tower Mortgage Loan
(see Exhibit 34.10)

 34.26
of the Meidinger Tower Mortgage Loan (see Exhibit 34.2)

 34.27
Wilmington Trust, National Association, as Trustee of the Meidinger Tower

 34.28
Custodian of the Meidinger Tower Mortgage Loan (see Exhibit 34.5)

 34.29
Advisor of the Meidinger Tower Mortgage Loan (see Exhibit 34.6)

 34.30

 34.31
National Association, as Primary Servicer of the Maui Portfolio Mortgage Loan
(see Exhibit 34.10)

 34.32
of the Maui Portfolio Mortgage Loan (see Exhibit 34.2)

 34.33
Wilmington Trust, National Association, as Trustee of the Maui Portfolio

 34.34
Custodian of the Maui Portfolio Mortgage Loan (see Exhibit 34.5)

 34.35
Advisor of the Maui Portfolio Mortgage Loan (see Exhibit 34.6)

 34.36

 34.37
Servicer of the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan
(see Exhibit 34.1)

 34.38
of the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan (see
Exhibit 34.2)

 34.39
Wilmington Trust, National Association, as Trustee of the Marriott SpringHill
Suites and Towneplace Suites Mortgage Loan (Omitted. See Explanatory Notes.)

 34.40
Custodian of the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan
(see Exhibit 34.5)

 34.41
Advisor of the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan
(see Exhibit 34.6)

 34.42
Participant of the Marriott SpringHill Suites and Towneplace Suites Mortgage
Loan (see Exhibit 34.7)

 34.43

 34.44
National Association, as Primary Servicer of the ILPT Hawaii Portfolio Mortgage
Loan (see Exhibit 34.10)

 34.45
of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 34.2)

 34.46
Wells Fargo Bank, National Association, as Trustee of the ILPT Hawaii Portfolio

 34.47
Custodian of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 34.5)

 34.48
Advisor of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 34.6)

 34.49

 34.50
of the 2 North 6th Place Mortgage Loan

 34.51
 Situs Holdings, LLC, as Special Servicer of the 2
North 6th Place Mortgage Loan

 34.52
Wells Fargo Bank, National Association, as Trustee of the 2 North 6th Place

 34.53
Custodian of the 2 North 6th Place Mortgage Loan (see Exhibit 34.5)

 34.54
 Computershare Trust Company, National Association, as
Servicing Function Participant for the Custodian (see Exhibit 34.9)

 34.55
Servicer of the Town Square Mortgage Loan (see Exhibit 34.1)

 34.56
of the Town Square Mortgage Loan (see Exhibit 34.2)

 34.57
Wilmington Trust, National Association, as Trustee of the Town Square Mortgage

 34.58
Custodian of the Town Square Mortgage Loan (see Exhibit 34.5)

 34.59
Advisor of the Town Square Mortgage Loan (see Exhibit 34.6)

 34.60
Participant of the Town Square Mortgage Loan (see Exhibit 34.7)

 34.61

 34.62
of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 34.50)

 34.63
 KeyBank National Association, as Special Servicer
of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 34.50)

 34.64
Wells Fargo Bank, National Association, as Trustee of the 10000 Santa Monica
Boulevard Mortgage Loan (Omitted. See Explanatory Notes.)

 34.65
Custodian of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 34.5)

 34.66

 34.67
National Association, as Primary Servicer of the Vanguard Portfolio Mortgage
Loan (see Exhibit 34.10)

 34.68
National Association, as Special Servicer of the Vanguard Portfolio Mortgage
Loan (see Exhibit 34.10)

 34.69
Wells Fargo Bank, National Association, as Trustee of the Vanguard Portfolio

 34.70
Custodian of the Vanguard Portfolio Mortgage Loan (see Exhibit 34.5)

 34.71
of the Vanguard Portfolio Mortgage Loan

 34.72

 34.73
National Association, as Primary Servicer of the SWVP Portfolio Mortgage Loan
(see Exhibit 34.10)

 34.74
K-Star Asset Management LLC, as Special Servicer of the SWVP Portfolio Mortgage

 34.75
Wells Fargo Bank, National Association, as Trustee of the SWVP Portfolio

 34.76
Custodian of the SWVP Portfolio Mortgage Loan (see Exhibit 34.5)

 34.77
of the SWVP Portfolio Mortgage Loan (see Exhibit 34.71)

 34.78

 34.79
of the Moffett Towers II - Buildings 3 & 4 Mortgage Loan (see Exhibit
34.50)

 34.80
 Situs Holdings, LLC, as Special Servicer of the
Moffett Towers II - Buildings 3 & 4 Mortgage Loan (see Exhibit 34.51)

 34.81
Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II -
Buildings 3 & 4 Mortgage Loan (Omitted. See Explanatory Notes.)

 34.82
Custodian of the Moffett Towers II - Buildings 3 & 4 Mortgage Loan (see
Exhibit 34.5)

 34.83

 34.84
Servicer of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (see
Exhibit 34.1)

 34.85
Greystone Servicing Company LLC (as successor to C-III Asset Management LLC),
as Special Servicer of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan
(Omitted. See Explanatory Notes.)

 34.86
Wilmington Trust, National Association, as Trustee of the ExchangeRight Net
Leased Portfolio #27 Mortgage Loan (Omitted. See Explanatory Notes.)

 34.87
Custodian of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (see
Exhibit 34.5)

 34.88
of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (see Exhibit 34.71)

 34.89
Participant of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (see
Exhibit 34.7)

 34.90

 34.91
National Association, as Primary Servicer of the Visions Hotel Portfolio II
Mortgage Loan (see Exhibit 34.10)

 34.92
of the Visions Hotel Portfolio II Mortgage Loan

 34.93
Wells Fargo Bank, National Association, as Trustee of the Visions Hotel
Portfolio II Mortgage Loan (Omitted. See Explanatory Notes.)

 34.94
Custodian of the Visions Hotel Portfolio II Mortgage Loan (see Exhibit 34.5)

 34.95
of the Visions Hotel Portfolio II Mortgage Loan (see Exhibit 34.71)

 34.96

 34.97
National Association, as Primary Servicer of the 125 Borinquen Place Mortgage
Loan (see Exhibit 34.10)

 34.98
of the 125 Borinquen Place Mortgage Loan (see Exhibit 34.92)

 34.99
Wells Fargo Bank, National Association, as Trustee of the 125 Borinquen Place

 34.100
Custodian of the 125 Borinquen Place Mortgage Loan (see Exhibit 34.5)

 34.101
of the 125 Borinquen Place Mortgage Loan (see Exhibit 34.71)

 34.102

 34.103
National Association, as Primary Servicer of the CIRE Equity Retail &
Industrial Portfolio Mortgage Loan (see Exhibit 34.10)

 34.104
K-Star Asset Management LLC, as Special Servicer of the CIRE Equity Retail

 34.105
Wilmington Trust, National Association, as Trustee of the CIRE Equity Retail

 34.106
Citibank, N.A., as Custodian of the CIRE Equity Retail & Industrial
Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

 34.107
of the CIRE Equity Retail & Industrial Portfolio Mortgage Loan (see Exhibit
34.71)

 34.108
Servicer of the Mount Kemble Mortgage Loan (see Exhibit 34.1)

 34.109
of the Mount Kemble Mortgage Loan (see Exhibit 34.92)

 34.110
Wilmington Trust, National Association, as Trustee of the Mount Kemble Mortgage

 34.111
Custodian of the Mount Kemble Mortgage Loan (see Exhibit 34.5)

 34.112
of the Mount Kemble Mortgage Loan (see Exhibit 34.71)

 34.113
Participant of the Mount Kemble Mortgage Loan (see Exhibit 34.7)

 34.114

 34.115
Servicer of the Renaissance Center VI Mortgage Loan (see Exhibit 34.1)

 34.116
of the Renaissance Center VI Mortgage Loan (see Exhibit 34.92)

 34.117
Wilmington Trust, National Association, as Trustee of the Renaissance Center VI

 34.118
Custodian of the Renaissance Center VI Mortgage Loan (see Exhibit 34.5)

 34.119
of the Renaissance Center VI Mortgage Loan (see Exhibit 34.71)

 34.120
Participant of the Renaissance Center VI Mortgage Loan (see Exhibit 34.7)

 34.121

 34.122
Servicer of the Ambler Yards Mortgage Loan (see Exhibit 34.5)

 34.123
National Association, as Primary Servicer of the Ambler Yards Mortgage Loan
(see Exhibit 34.10)

 34.124
of the Ambler Yards Mortgage Loan (see Exhibit 34.2)

 34.125
Wilmington Trust, National Association, as Trustee of the Ambler Yards Mortgage

 34.126
Custodian of the Ambler Yards Mortgage Loan (see Exhibit 34.5)

 34.127
of the Ambler Yards Mortgage Loan (see Exhibit 34.71)

 34.128

 34.129
of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 34.50)

 34.130
 LNR Partners, LLC, as Special Servicer of the
Inland Life Storage Portfolio Mortgage Loan

 34.131
Citibank, N.A., as Trustee and Custodian of the Inland Life Storage Portfolio

 34.132
Advisor of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 34.6)

Servicer compliance statements.

 35.1
 Wells Fargo Bank, National Association, as Master
Servicer

 35.2

 35.3
Certificate Administrator

 35.4
as Servicing Function Participant for the Certificate Administrator

 35.5
National Association, as Primary Servicer

 35.6
Servicer of the 188 Spear Street Mortgage Loan (see Exhibit 35.1)

 35.7
of the 188 Spear Street Mortgage Loan (see Exhibit 35.2)

 35.8
Servicer of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see
Exhibit 35.1)

 35.9
of the ExchangeRight Net Leased Portfolio 28 Mortgage Loan (see Exhibit 35.2)

 35.10
National Association, as Primary Servicer of the Meidinger Tower Mortgage Loan
(see Exhibit 35.5)

 35.11
of the Meidinger Tower Mortgage Loan (see Exhibit 35.2)

 35.12
National Association, as Primary Servicer of the Maui Portfolio Mortgage Loan
(see Exhibit 35.5)

 35.13
of the Maui Portfolio Mortgage Loan (see Exhibit 35.2)

 35.14
Servicer of the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan
(see Exhibit 35.1)

 35.15
of the Marriott SpringHill Suites and Towneplace Suites Mortgage Loan (see
Exhibit 35.2)

 35.16
National Association, as Primary Servicer of the ILPT Hawaii Portfolio Mortgage
Loan (see Exhibit 35.5)

 35.17
of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 35.2)

 35.18
of the 2 North 6th Place Mortgage Loan

 35.19
 Situs Holdings, LLC, as Special Servicer of the 2
North 6th Place Mortgage Loan

 35.20
Servicer of the Town Square Mortgage Loan (see Exhibit 35.1)

 35.21
of the Town Square Mortgage Loan (see Exhibit 35.2)

 35.22
of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 35.18)

 35.23
 KeyBank National Association, as Special Servicer
of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 35.18)

 35.24
National Association, as Primary Servicer of the Vanguard Portfolio Mortgage
Loan (see Exhibit 35.5)

 35.25
National Association, as Special Servicer of the Vanguard Portfolio Mortgage
Loan (see Exhibit 35.5)

 35.26
National Association, as Primary Servicer of the SWVP Portfolio Mortgage Loan
(see Exhibit 35.5)

 35.27
K-Star Asset Management LLC, as Special Servicer of the SWVP Portfolio Mortgage

 35.28
of the Moffett Towers II - Buildings 3 & 4 Mortgage Loan (see Exhibit
35.18)

 35.29
 Situs Holdings, LLC, as Special Servicer of the
Moffett Towers II - Buildings 3 & 4 Mortgage Loan (see Exhibit 35.19)

 35.30
Servicer of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan (see
Exhibit 35.1)

 35.31
Greystone Servicing Company LLC (as successor to C-III Asset Management LLC),
as Special Servicer of the ExchangeRight Net Leased Portfolio #27 Mortgage Loan
(Omitted. See Explanatory Notes.)

 35.32
National Association, as Primary Servicer of the Visions Hotel Portfolio II
Mortgage Loan (see Exhibit 35.5)

 35.33
Argentic Services Company LP, as Special Servicer of the Visions Hotel
Portfolio II Mortgage Loan (Omitted. See Explanatory Notes.)

 35.34
National Association, as Primary Servicer of the 125 Borinquen Place Mortgage
Loan (see Exhibit 35.5)

 35.35
Argentic Services Company LP, as Special Servicer of the 125 Borinquen Place

 35.36
National Association, as Primary Servicer of the CIRE Equity Retail &
Industrial Portfolio Mortgage Loan (see Exhibit 35.5)

 35.37
K-Star Asset Management LLC, as Special Servicer of the CIRE Equity Retail

 35.38
Servicer of the Mount Kemble Mortgage Loan (see Exhibit 35.1)

 35.39
Argentic Services Company LP, as Special Servicer of the Mount Kemble Mortgage

 35.40
Servicer of the Renaissance Center VI Mortgage Loan (see Exhibit 35.1)

 35.41
Argentic Services Company LP, as Special Servicer of the Renaissance Center VI

 35.42
Servicer of the Ambler Yards Mortgage Loan (see Exhibit 35.1)

 35.43
National Association, as Primary Servicer of the Ambler Yards Mortgage Loan
(see Exhibit 35.5)

 35.44
of the Ambler Yards Mortgage Loan (see Exhibit 35.2)

 35.45
of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 35.18)

 35.46
 LNR Partners, LLC, as Special Servicer of the
Inland Life Storage Portfolio Mortgage Loan

 99.1
Loan Purchase Agreement, dated as of August 9, 2019, among Barclays Capital
Real Estate Inc., Barclays Capital Holdings Inc., and Barclays Commercial
Mortgage Securities LLC (filed as Exhibit 99.1 to the registrant's Current
Report on Form 8-K filed on August 28, 2019 under Commission File No.
333-226850-03 and incorporated by reference herein).

 99.2
Loan Purchase Agreement, dated as of August 9, 2019, among Societe Generale
Financial Corporation, Soci t G n rale and Barclays Commercial Mortgage
Securities LLC (filed as Exhibit 99.2 to the registrant's Current Report on
Form 8-K filed on August 28, 2019 under Commission File No. 333-226850-03 and

 99.3
Loan Purchase Agreement, dated as of August 9, 2019, between UBS AG, by and
through its branch office at 1285 Avenue of the Americas, New York, New York
and Barclays Commercial Mortgage Securities LLC (filed as Exhibit 99.3 to the

 99.4
Loan Purchase Agreement, dated as of August 9, 2019, between Starwood Mortgage
Capital LLC and Barclays Commercial Mortgage Securities LLC (filed as Exhibit
99.4 to the registrant's Current Report on Form 8-K filed on August 28, 2019
under Commission File No. 333-226850-03 and incorporated by reference herein).

 99.5
Loan Purchase Agreement, dated as of August 9, 2019, between Rialto Real Estate
Fund III – Debt, LP and Barclays Commercial Mortgage Securities LLC (filed as
Exhibit 99.5 to the registrant's Current Report on Form 8-K filed on August 28,

 99.6
Loan Purchase Agreement, dated as of August 9, 2019, between CIBC Inc. and
Barclays Commercial Mortgage Securities LLC (filed as Exhibit 99.6 to the

 99.7
Loan Purchase Agreement, dated as of August 9, 2019, between Natixis Real
Estate Capital LLC and Barclays Commercial Mortgage Securities LLC (filed as
Exhibit 99.7 to the registrant's Current Report on Form 8-K filed on August 28,

 (b)
The exhibits required to be filed by the Registrant pursuant to Item 601 of
Regulation S-K are listed 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.

 Barclays Commercial Mortgage
Securities LLC

(Depositor)

 /s/ Daniel Schmidt

 Daniel
Schmidt, Chief Executive Officer

 (senior officer in charge of
securitization of the depositor)

 Date: March 13, 2025