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, 2023

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: 333-226123-03

 Central Index Key Number of the issuing entity:
0001775756

 Benchmark 2019-B11 Mortgage Trust

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

 Central Index Key Number of the depositor: 0001013611

 J.P. Morgan Chase Commercial
Mortgage Securities Corp.

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

 Central Index Key Number of the sponsor: 0000835271

 JPMorgan Chase Bank, National
Association

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

 Central Index Key Number of the sponsor: 0001541294

 German American Capital Corporation

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

 Central Index Key Number of the sponsor: 0001701238

 Citi Real Estate Funding Inc.

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

 New York

 (State or other jurisdiction of

 incorporation or organization of

 the issuing entity)

 38-4117359

 38-4117360

 38-7221329

 (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) 834-5467

 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 Green Hills Corporate Center Mortgage Loan, the Western
Digital R&D Campus Mortgage Loan and the Greenleaf at Howell Mortgage Loan,
which constituted approximately 4.5%, 3.5% and 2.4%, 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 the Green
Hills Corporate Center Mortgage Loan, the Western Digital R&D Campus
Mortgage Loan or the Greenleaf at Howell Mortgage Loan and one other pari
passu loan, which is not an asset of the issuing entity. These loan
combinations, including the Green Hills Corporate Center Mortgage Loan, the
Western Digital R&D Campus Mortgage Loan and the Greenleaf at Howell
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.

the ILPT Hawaii Portfolio Mortgage Loan, which constituted approximately 7.1%
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
fifteen 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.

the 101 California Mortgage Loan, which constituted approximately 4.5% of the
asset pool of the issuing entity as of its cut-off date. The 101
California Mortgage Loan is an asset of the issuing entity and is part of a
loan combination that includes the 101 California Mortgage Loan, seven 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 CALI Mortgage Trust 2019-101C transaction (the " CALI
2019-101C Transaction "). This loan combination, including the 101
California Mortgage Loan, is being serviced and administered pursuant to the
trust and servicing agreement for the CALI 2019-101C Transaction, which is
incorporated by reference as Exhibit 4.3 to this Annual Report on Form 10-K.

the 3 Columbus Circle Mortgage Loan, which constituted approximately 9.1% of
the asset pool of the issuing entity as of its cut-off date. The 3
Columbus Circle Mortgage Loan is an asset of the issuing entity and is part of
a loan combination that includes the 3 Columbus Circle Mortgage Loan, thirteen
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 Benchmark 2019-B10 Mortgage Trust
transaction, Commission File Number 333-226943-02 (the " Benchmark 2019-B10
Transaction "). This loan combination, including the 3 Columbus Circle
Mortgage Loan, is being serviced and administered pursuant to the pooling and
servicing agreement for the Benchmark 2019-B10 Transaction, which is
incorporated by reference as Exhibit 4.4 to this Annual Report on Form 10-K.

 The Heartland Dental Medical Office Portfolio Mortgage Loan,
previously an asset of the issuing entity, was not an asset of the issuing
entity during the reporting period and is omitted from this Annual Report on
Form 10-K and will be omitted from subsequent Annual Reports on Form 10-K.

the 59 Maiden Lane Mortgage Loan, the Arbor Hotel Portfolio Mortgage Loan, the
Moffett Towers II - Building V Mortgage Loan and the Lakeside Apartments
Mortgage Loan, which constituted approximately 6.8%, 4.5%, 3.9% and 3.2%,
respectively, of the asset pool of the issuing entity as of its cut-off
date. The 59 Maiden Lane Mortgage Loan, the Arbor Hotel Portfolio
Mortgage Loan, the Moffett Towers II - Building V Mortgage Loan and the
Lakeside Apartments 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 59 Maiden
Lane Mortgage Loan, two other pari passu loans, which are not assets of
the issuing entity, (b) with respect to the Arbor Hotel Portfolio Mortgage
Loan, one other pari passu loan, which is not an asset of the issuing
entity, (c) with respect to the Moffett Towers II - Building V Mortgage Loan,
three other pari passu loans and four subordinate companion loans, which
are not assets of the issuing entity or (d) with respect to the Lakeside
Apartments Mortgage Loan, one other pari passu loan, which is not an
asset of the issuing entity. A pari passu portion of each loan
combination was securitized in the GS Mortgage Securities Trust 2019-GC39
transaction, Commission File Number 333-226082-02 (the " GSMS 2019-GC39
Transaction "). These loan combinations, including the 59 Maiden Lane
Mortgage Loan, the Arbor Hotel Portfolio Mortgage Loan, the Moffett Towers II -
Building V Mortgage Loan and the Lakeside Apartments Mortgage Loan, are being
serviced and administered pursuant to the pooling and servicing agreement for
the GSMS 2019-GC39 Transaction, which is incorporated by reference as Exhibit
4.5 to this Annual Report on Form 10-K.

parties (in their capacities indicated on the Exhibit Index) with respect to the
Newport Corporate Center Mortgage Loan and the Central Tower Office Mortgage
Loan, which constituted approximately 3.7% and 3.1%, respectively, of the asset
pool of the issuing entity as of its cut-off date. The Newport Corporate
Center Mortgage Loan and the Central Tower Office 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 Newport Corporate Center Mortgage Loan, three
other pari passu loans and ten subordinate companion loans, which are
not assets of the issuing entity or (b) with respect to the Central Tower
Office Mortgage Loan, one other pari passu loan, which is not an asset
of the issuing entity. A pari passu portion of each loan combination was
securitized in the BANK 2019-BNK18 transaction, Commission File Number
333-228375-01 (the " BANK 2019-BNK18 Transaction "). These loan
combinations, including the Newport Corporate Center Mortgage Loan and the
Central Tower Office Mortgage Loan, are being serviced and administered
pursuant to the pooling and servicing agreement for the BANK 2019-BNK18
Transaction, which is incorporated by reference as Exhibit 4.6 to this Annual
Report on Form 10-K.

the SWVP Portfolio Mortgage Loan, which constituted approximately 4.5% of the
asset pool of the issuing entity as of its cut-off date. The SWVP
Portfolio Mortgage Loan is an asset of the issuing entity and is part of a loan
combination that includes the SWVP Portfolio Mortgage Loan and eight other pari
passu loans, which are not assets of the issuing entity. A pari passu
portion of the loan combination was securitized in the BBCMS Mortgage Trust
2019-C3 transaction, Commission File Number 333-226850-02 (the " BBCMS
2019-C3 Transaction "). This loan combination, including the SWVP Portfolio
Mortgage Loan, is being serviced and administered pursuant to the pooling and
servicing agreement for the BBCMS 2019-C3 Transaction, which is incorporated by
reference as Exhibit 4.7 to this Annual Report on Form 10-K.

the 57 East 11th Street Mortgage Loan, which constituted approximately 1.8% of
the asset pool of the issuing entity as of its cut-off date. The 57 East
11th Street Mortgage Loan is an asset of the issuing entity and is part of a
loan combination that includes the 57 East 11th Street Mortgage Loan and two
other pari passu loans, which are not assets of the issuing entity. This
loan combination, including the 57 East 11th Street Mortgage Loan, was serviced
under the pooling and servicing agreement for the GSMS 2019-GC39 Transaction
prior to the closing of the securitization of a pari passu portion of
the 57 East 11th Street loan combination in the GS Mortgage Securities Trust
2019-GC40 transaction, Commission File Number 333-226082-03 (the " GSMS
2019-GC40 Transaction "). After the closing of the GSMS 2019-GC40
Transaction on July 11, 2019, this loan combination, including the 57 East 11th
Street Mortgage Loan was, and will continue to be, serviced and administered
pursuant to the pooling and servicing agreement with respect to the GSMS
2019-GC40 Transaction, which is incorporated by reference as Exhibit 4.8 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.

 Midland Loan Services, a Division of PNC Bank, National
Association is the master servicer of the mortgage loans serviced under the
Pooling and Servicing Agreement, the primary servicer of the 3 Columbus Circle
Mortgage Loan, the ILPT Hawaii Portfolio Mortgage Loan, the 59 Maiden Lane
Mortgage Loan, the Arbor Hotel Portfolio Mortgage Loan, the SWVP Portfolio
Mortgage Loan, the Moffett Towers II - Building V Mortgage Loan and the 57 East
11th Street Mortgage Loan, the primary servicer and special servicer of the 101
California Mortgage Loan and the special servicer of the SWVP Portfolio
Mortgage Loan prior to May 10, 2023. 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.

 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 and the Central Tower Office 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.

 Wells Fargo Bank, National Association is the certificate
administrator of the mortgage loans serviced under the Pooling and Servicing
Agreement and the primary servicer of the Newport Corporate Center Mortgage
Loan and the Central Tower Office 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 3
Columbus Circle Mortgage Loan, the ILPT Hawaii Portfolio Mortgage Loan, the 59
Maiden Lane Mortgage Loan, the SWVP Portfolio Mortgage Loan, the 101 California
Mortgage Loan, the Arbor Hotel Portfolio Mortgage Loan, the Moffett Towers II -
Building V Mortgage Loan, the Newport Corporate Center Mortgage Loan, the
Lakeside Apartments Mortgage Loan, the Central Tower Office Mortgage Loan and
the 57 East 11th Street 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.

 Pentalpha Surveillance LLC is the operating advisor of the
mortgage loans serviced under the Pooling and Servicing Agreement, the 3
Columbus Circle Mortgage Loan, the SWVP Portfolio Mortgage Loan, the 101
California Mortgage Loan, the Newport Corporate Center Mortgage Loan, the
Central Tower Office Mortgage Loan and the 57 East 11th Street 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.

 Park Bridge Lender Services LLC is the operating advisor of
the ILPT Hawaii Portfolio Mortgage Loan, the 59 Maiden Lane Mortgage Loan, the
Arbor Hotel Portfolio Mortgage Loan, the Moffett Towers II - Building V
Mortgage Loan and the Lakeside Apartments 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.

 LNR Partners, LLC is the special servicer of the 3 Columbus
Circle Mortgage Loan and the 57 East 11th Street Mortgage Loan. As a result,
LNR Partners, 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 LNR Partners, LLC in the capacities described above are listed in
the Exhibit Index.

 KeyBank National Association is the special servicer of the
59 Maiden Lane Mortgage Loan, the Arbor Hotel Portfolio Mortgage Loan, the
Moffett Towers II - Building V Mortgage Loan and the Lakeside Apartments 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.

 Wells Fargo Bank, National Association acts as trustee of the
Green Hills Corporate Center Mortgage Loan, the Western Digital R&D Campus
Mortgage Loan, the Greenleaf at Howell Mortgage Loan, the ILPT Hawaii Portfolio
Mortgage Loan, the 101 California Mortgage Loan, the 3 Columbus Circle Mortgage
Loan, the 59 Maiden Lane Mortgage Loan, the Arbor Hotel Portfolio Mortgage
Loan, the Moffett Towers II - Building V Mortgage Loan, the Lakeside Apartments
Mortgage Loan, the SWVP Portfolio Mortgage Loan and the 57 East 11th Street
Mortgage Loan. Pursuant to the Pooling and Servicing Agreement, the trust
and servicing agreement for the ILPT 2019-SURF Transaction, the trust and
servicing agreement for the CALI 2019-101C Transaction, the pooling and servicing
agreement for the Benchmark 2019-B10 Transaction, the pooling and servicing
agreement for the GSMS 2019-GC39 Transaction, the pooling and servicing
agreement for the BBCMS 2019-C3 Transaction and the pooling and servicing
agreement for the GSMS 2019-GC40 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 Green Hills Corporate Center
Mortgage Loan, the Western Digital R&D Campus Mortgage Loan, the Greenleaf
at Howell Mortgage Loan, the ILPT Hawaii Portfolio Mortgage Loan, the 101
California Mortgage Loan, the 3 Columbus Circle Mortgage Loan, the 59 Maiden
Lane Mortgage Loan, the Arbor Hotel Portfolio Mortgage Loan, the Moffett Towers
II - Building V Mortgage Loan, the Lakeside Apartments Mortgage Loan, the SWVP
Portfolio Mortgage Loan and the 57 East 11th Street 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
Newport Corporate Center Mortgage Loan and the Central Tower Office Mortgage
Loan. Pursuant to the pooling and servicing agreement for the BANK
2019-BNK18 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
Newport Corporate Center Mortgage Loan and the Central Tower Office 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
primary servicer of the Newport Corporate Center Mortgage Loan and the Central
Tower Office 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
Items 1122(d)(4)(xi) and 1122(d)(4)(xii) 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 101 California Mortgage Loan, the 3 Columbus Circle Mortgage Loan, the 59
Maiden Lane Mortgage Loan, the Arbor Hotel Portfolio Mortgage Loan, the Moffett
Towers II - Building V Mortgage Loan, the Lakeside Apartments Mortgage Loan,
the Newport Corporate Center Mortgage Loan, the Central Tower Office Mortgage
Loan, the SWVP Portfolio Mortgage Loan and the 57 East 11th Street 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 Lakeside Apartments Mortgage Loan, the Newport Corporate Center
Mortgage Loan and the SWVP Portfolio Mortgage Loan, (i) the reports on
assessment of compliance with servicing criteria and attestation reports on
assessment of compliance with servicing criteria of Berkadia Commercial
Mortgage LLC as primary servicer of the Lakeside Apartments Mortgage Loan,
Situs Holdings, LLC as special servicer of the Newport Corporate Center
Mortgage Loan and K-Star Asset Management LLC as special servicer of the SWVP
Portfolio Mortgage Loan on and after May 10, 2023, 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 Berkadia Commercial Mortgage LLC as
primary servicer of the Lakeside Apartments Mortgage Loan, Situs Holdings, LLC
as special servicer of the Newport Corporate Center Mortgage Loan and K-Star
Asset Management LLC as special servicer of the SWVP Portfolio Mortgage Loan on
and after May 10, 2023, 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, as trustee and as 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 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 June 17, 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
applicable servicing criteria set forth in Item 1122(d).

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 101 California Mortgage Loan,
which is being serviced and administered pursuant to the trust and servicing
agreement for the CALI 2019-101C 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 CALI 2019-101C 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 CALI
2019-101C Transaction responsible for each applicable servicing criteria set
forth in Item 1122(d).

assessments of compliance with respect to the 3 Columbus Circle Mortgage Loan,
which is being serviced and administered pursuant to the pooling and servicing
agreement for the Benchmark 2019-B10 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 Benchmark 2019-B10 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
Benchmark 2019-B10 Transaction responsible for each applicable servicing
criteria set forth in Item 1122(d).

assessments of compliance with respect to the 59 Maiden Lane Mortgage Loan, the
Arbor Hotel Portfolio Mortgage Loan, the Moffett Towers II - Building V
Mortgage Loan and the Lakeside Apartments Mortgage Loan, which are being
serviced and administered pursuant to the pooling and servicing agreement for
the GSMS 2019-GC39 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 GSMS 2019-GC39 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 GSMS 2019-GC39 Transaction
responsible for each applicable servicing criteria set forth in Item 1122(d).

assessments of compliance with respect to the Newport Corporate Center Mortgage
Loan and the Central Tower Office Mortgage Loan, which are being serviced and
administered pursuant to the pooling and servicing agreement for the BANK
2019-BNK18 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 BANK 2019-BNK18 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 BANK 2019-BNK18 Transaction
responsible for each applicable servicing criteria set forth in Item 1122(d).

assessments of compliance with respect to the SWVP Portfolio Mortgage Loan,
which is 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 4.7 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 applicable servicing criteria set forth in
Item 1122(d).

assessments of compliance with respect to the 57 East 11th Street Mortgage
Loan, which is being serviced and administered pursuant to the pooling and
servicing agreement for the GSMS 2019-GC40 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 GSMS 2019-GC40 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 GSMS
2019-GC40 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. Exhibit 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
 Pooling and Servicing Agreement, dated as of June 1,
2019, by and among J.P. Morgan Chase Commercial Mortgage Securities Corp., as
Depositor, Midland Loan Services, a Division of PNC Bank, National Association,
as Master Servicer, Rialto Capital Advisors, LLC, 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 Asset Representations Reviewer (filed as Exhibit 4.1 to

 4.2
 Trust and Servicing Agreement, dated as of March 7, 2019,
by and 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, Custodian and Trustee, and Park
Bridge Lender Services LLC, as Operating Advisor (filed as Exhibit 4.3 to the
registrant's Current Report on Form 8-K filed on June 17, 2019 under Commission
File No. 333-226123-03 and incorporated by reference herein).

 4.3
 Trust and Servicing Agreement, dated as of March 6, 2019,
by and among GS Mortgage Securities Corporation II, as Depositor, Midland Loan
Services, a Division of PNC Bank, National Association, as Servicer, Midland
Loan Services, a Division of PNC Bank, National Association, as Special
Servicer, Wells Fargo Bank, National Association, as Certificate Administrator,
Custodian and Trustee, and Pentalpha Surveillance LLC, as Operating Advisor
(filed as Exhibit 4.5 to the registrant's Current Report on Form 8-K filed on

 4.4
 Pooling and Servicing Agreement, dated as of April 1,
2019, by and among Deutsche Mortgage & Asset Receiving Corporation, as
Depositor, KeyBank National Association, as Master Servicer, LNR Partners, LLC,
as Special Servicer, Wells Fargo Bank, National Association, as Trustee,
Certificate Administrator, Paying Agent and Custodian, and Pentalpha
Surveillance LLC, as Operating Advisor and Asset Representations Reviewer
(filed as Exhibit 4.2 to the registrant's Current Report on Form 8-K filed on

 4.5
 Pooling and Servicing Agreement, dated as of May 1, 2019,
by and among GS Mortgage Securities Corporation II, as Depositor, Midland Loan
Services, a Division of PNC Bank, National Association, as Master Servicer,
KeyBank National Association, as Special Servicer, Wells Fargo Bank, National
Association, as Certificate Administrator and as Trustee, and Park Bridge
Lender Services 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

 4.6
 Pooling and Servicing Agreement, dated as of May 1, 2019,
by and among Banc of America Merrill Lynch Commercial Mortgage Inc., as
Depositor, Wells Fargo Bank, National Association, as General Master Servicer,
Rialto Capital Advisors, LLC, as General Special Servicer, National Cooperative
Bank, N.A., as NCB Master Servicer and NCB Special Servicer, Situs Holdings,
LLC, as Newport Corporate Center Special Servicer, Wells Fargo Bank, National
Association, as Certificate Administrator, Wilmington Trust, National
Association, as 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 filed on June 17, 2019 under Commission File No.

 4.7
 Pooling and Servicing Agreement, dated as of June 1,
2019, by and 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 Asset Representations
Reviewer (filed as Exhibit 4.6 to the registrant's Current Report on Form 8-K
filed on June 17, 2019 under Commission File No. 333-226123-03 and incorporated
by reference herein).

 4.8
 Pooling and Servicing Agreement, dated as of July 1,
2019, by and among GS Mortgage Securities Corporation II, as Depositor, Midland
Loan Services, a Division of PNC Bank, National Association, as Master Servicer
and 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 4.1 to the registrant's
Current Report on Form 8-K filed on July 12, 2019 under Commission File No.

 4.9
 Agreement Between Noteholders, dated as of March 13,
2019, by and between, JPMorgan Chase Bank, National Association, as Initial
Note A-1-1 Holder, Initial Note A-1-2 Holder, Initial Note A-1-3 Holder,
Initial Note A-1-4 Holder, Initial Note A-1-5 Holder, Initial Note A-1-6
Holder, Initial Note A-1-7 Holder and Initial Note A-1-8 Holder, Deutsche Bank
AG, acting through its New York Branch, as Note A-2-1 Holder, Note A-2-2
Holder, Note A-2-3 Holder, Note A-2-4 Holder and Note A-2-5 Holder, JPMorgan
Chase Bank, National Association, as Initial Note B-1 Holder, and Deutsche Bank
AG, acting through its New York Branch, as Note B-2 Holder (filed as Exhibit
4.9 to the registrant's Current Report on Form 8-K filed on June 17, 2019 under

 4.10 Agreement 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, 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 4.10 to the registrant's Current Report on
Form 8-K filed on June 17, 2019 under Commission File No. 333-226123-03 and
incorporated by reference herein).

 4.11 Agreement Between Note Holders, dated as of April 11,
2019, by and between Citi Real Estate Funding Inc., as Initial Note A-1 Holder,
Citi Real Estate Funding Inc., as Initial Note A-2 Holder, and Citi Real Estate
Funding Inc., as Initial Note A-3 Holder (filed as Exhibit 4.11 to the
registrant's Current Report on Form 8-K filed on June 17, 2019 under Commission
File No. 333-226123-03 and incorporated by reference herein).

 4.12 Amended and Restated Co-Lender Agreement, dated as of May
3, 2019, by and among, Wells Fargo Bank, National Association, as Trustee for
the Benefit of the Registered Holders of the CALI 2019-101C Mortgage Trust,
Commercial Mortgage Pass-Through Certificates, Series 2019-101C, as Note A-1
Holder, Note A-2 Holder, Note B-1 Holder and Note B-2 Holder, Wells Fargo Bank,
National Association, as Trustee for the Benefit of the Registered Holders of
the Benchmark 2019-B10 Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 2019-B10, as Note A-8 Holder and Note A-9 Holder, Goldman
Sachs Mortgage Company, as Initial Note A-3 Holder, Initial Note A-4 Holder and
Initial Note A-5 Holder, and JPMorgan Chase Bank, National Association, as
Initial Note A-6 Holder and Initial Note A-7 Holder (filed as Exhibit 4.12 to

 4.13 Co-Lender Agreement, dated as of June 11, 2019, by and
between Societe Generale Financial Corporation and JPMorgan Chase Bank,
National Association (filed as Exhibit 4.13 to the registrant's Current Report
on Form 8-K filed on June 17, 2019 under Commission File No. 333-226123-03 and
incorporated by reference herein).

 4.14 Co-Lender Agreement, dated as of April 17, 2019, by and
between Citi Real Estate Funding Inc., as Initial Note A-1 Holder, and Citi
Real Estate Funding Inc., as Initial Note A-2 Holder (filed as Exhibit 4.14 to

 4.15 Co-Lender Agreement, dated as of June 17, 2019, by and
between Citi Real Estate Funding Inc., as Initial Note A-1 Holder, and Citi
Real Estate Funding Inc., as Initial Note A-2 Holder (filed as Exhibit 4.15 to

 4.16 Agreement Between Noteholders, dated as of March 8, 2019,
by and between Goldman Sachs Bank USA, as Initial Note A-2 Holder, Initial Note
A-3 Holder, Initial Note A-4 Holder, Initial Note B-2 Holder and Initial Note
C-2 Holder, and Deutsche Bank AG, New York Branch, as Initial Note A-1 Holder,
Initial Note B-1 Holder and Initial Note C-1 Holder (filed as Exhibit 4.16 to

 4.17 Agreement Between Noteholders, dated as of May 16, 2019,
by and between Deutsche Bank AG, New York Branch, as Initial Note A-1-A Holder,
Initial Note A-1-B Holder, Initial Note A-1-C Holder, Initial Note B-1-A
Holder, Initial Note B-1-B Holder, Initial Note C-1-A Holder, Initial Note
C-1-B Holder and Initial Note D-1 Holder, and Wells Fargo Bank, National
Association, as Initial Note A-2-A Holder, Initial Note A-2-B Holder, Initial
Note A-2-C Holder, Initial Note B-2-A Holder, Initial Note B-2-B Holder,
Initial Note C-2-A Holder, Initial Note C-2-B Holder and Initial Note D-2 Holder
(filed as Exhibit 4.17 to the registrant's Current Report on Form 8-K filed on

 4.18 Co-Lender Agreement, dated as of June 17, 2019, by and
between Citi Real Estate Funding Inc., as Initial Note A-1 Holder, and Citi
Real Estate Funding Inc., as Initial Note A-2 Holder (filed as Exhibit 4.18 to

 4.19 Co-Lender Agreement, dated as of March 1, 2019, by and
between Citi Real Estate Funding Inc., as Initial Note A-1 Holder, and Citi
Real Estate Funding Inc., as Initial Note A-2 Holder (filed as Exhibit 4.19 to

 4.20 Agreement Between Note Holders, dated as of April 26,
2019, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder, and
Deutsche Bank AG, New York Branch, as Initial Note A-2 Holder (filed as Exhibit
4.20 to the registrant's Current Report on Form 8-K filed on June 17, 2019
under Commission File No. 333-226123-03 and incorporated by reference herein).

 4.21 Co-Lender Agreement, dated as of June 17, 2019, by and
between JPMorgan Chase Bank, National Association, as Initial Note A-1 Holder,
and JPMorgan Chase Bank, National Association, as Initial Note A-2 Holder
(filed as Exhibit 4.21 to the registrant's Current Report on Form 8-K filed on

 4.22 Co-Lender Agreement, dated as of May 15, 2019, by and
between Citi Real Estate Funding Inc., as Initial Note A-1 Holder, Citi Real
Estate Funding Inc., as Initial Note A-2 Holder, and Citi Real Estate Funding
Inc., as Initial Note A-3 Holder (filed as Exhibit 4.22 to the registrant's
Current Report on Form 8-K filed on June 17, 2019 under Commission File No.

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

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

 33.1
National Association, as Master Servicer

 33.2

 33.3
 Wells Fargo Bank, National Association, as Trustee
and Certificate Administrator

 33.4
Custodian

 33.5
 Pentalpha Surveillance LLC, as Operating Advisor

 33.6
 Situs Real LLC, as EU Reporting Administrator

 33.7
as Servicing Function Participant for the Certificate Administrator

 33.8
as Servicing Function Participant for the Custodian

 33.9
National Association, as Primary Servicer of the Green Hills Corporate Center
Mortgage Loan (see Exhibit 33.1)

 33.10
of the Green Hills Corporate Center Mortgage Loan (see Exhibit 33.2)

 33.11
Wells Fargo Bank, National Association, as Trustee of the Green Hills Corporate
Center Mortgage Loan (Omitted. See Explanatory Notes.)

 33.12
Custodian of the Green Hills Corporate Center Mortgage Loan (see Exhibit 33.4)

 33.13
the Green Hills Corporate Center Mortgage Loan (see Exhibit 33.5)

 33.14

 33.15
National Association, as Primary Servicer of the Western Digital R&D Campus
Mortgage Loan (see Exhibit 33.1)

 33.16
of the Western Digital R&D Campus Mortgage Loan (see Exhibit 33.2)

 33.17
Wells Fargo Bank, National Association, as Trustee of the Western Digital
R&D Campus Mortgage Loan (Omitted. See Explanatory Notes.)

 33.18
Custodian of the Western Digital R&D Campus Mortgage Loan (see Exhibit
33.4)

 33.19
the Western Digital R&D Campus Mortgage Loan (see Exhibit 33.5)

 33.20

 33.21
National Association, as Primary Servicer of the Greenleaf at Howell Mortgage

 33.22
of the Greenleaf at Howell Mortgage Loan (see Exhibit 33.2)

 33.23
Wells Fargo Bank, National Association, as Trustee of the Greenleaf at Howell

 33.24
Custodian of the Greenleaf at Howell Mortgage Loan (see Exhibit 33.4)

 33.25
the Greenleaf at Howell Mortgage Loan (see Exhibit 33.5)

 33.26

 33.27
National Association, as Primary Servicer of the ILPT Hawaii Portfolio Mortgage

 33.28
of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 33.2)

 33.29
Wells Fargo Bank, National Association, as Trustee of the ILPT Hawaii Portfolio

 33.30
Custodian of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 33.4)

 33.31
Advisor of the ILPT Hawaii Portfolio Mortgage Loan

 33.32

 33.33
National Association, as Primary Servicer of the 101 California Mortgage Loan
(see Exhibit 33.1)

 33.34
National Association, as Special Servicer of the 101 California Mortgage Loan
(see Exhibit 33.1)

 33.35
Wells Fargo Bank, National Association, as Trustee of the 101 California

 33.36
Custodian of the 101 California Mortgage Loan (see Exhibit 33.4)

 33.37
the 101 California Mortgage Loan (see Exhibit 33.5)

 33.38

 33.39
National Association, as Primary Servicer of the 3 Columbus Circle Mortgage

 33.40
 LNR Partners, LLC, as Special Servicer of the 3
Columbus Circle Mortgage Loan

 33.41
Wells Fargo Bank, National Association, as Trustee of the 3 Columbus Circle

 33.42
Custodian of the 3 Columbus Circle Mortgage Loan (see Exhibit 33.4)

 33.43
the 3 Columbus Circle Mortgage Loan (see Exhibit 33.5)

 33.44

 33.45 Midland Loan Services, a Division of PNC Bank,
National Association, as Primary Servicer of the 59 Maiden Lane Mortgage Loan
(see Exhibit 33.1)

 33.46
of the 59 Maiden Lane Mortgage Loan

 33.47
Wells Fargo Bank, National Association, as Trustee of the 59 Maiden Lane

 33.48
Custodian of the 59 Maiden Lane Mortgage Loan (see Exhibit 33.4)

 33.49
Advisor of the 59 Maiden Lane Mortgage Loan (see Exhibit 33.31)

 33.50

 33.51
National Association, as Primary Servicer of the Arbor Hotel Portfolio Mortgage

 33.52
of the Arbor Hotel Portfolio Mortgage Loan (see Exhibit 33.46)

 33.53
Wells Fargo Bank, National Association, as Trustee of the Arbor Hotel Portfolio

 33.54
Custodian of the Arbor Hotel Portfolio Mortgage Loan (see Exhibit 33.4)

 33.55
Advisor of the Arbor Hotel Portfolio Mortgage Loan (see Exhibit 33.31)

 33.56

 33.57
National Association, as Primary Servicer of the Moffett Towers II - Building V
Mortgage Loan (see Exhibit 33.1)

 33.58
of the Moffett Towers II - Building V Mortgage Loan (see Exhibit 33.46)

 33.59
Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II -
Building V Mortgage Loan (Omitted. See Explanatory Notes.)

 33.60
Custodian of the Moffett Towers II - Building V Mortgage Loan (see Exhibit
33.4)

 33.61
Advisor of the Moffett Towers II - Building V Mortgage Loan (see Exhibit 33.31)

 33.62

 33.63
Berkadia Commercial Mortgage LLC, as Primary Servicer of the Lakeside
Apartments Mortgage Loan (Omitted. See Explanatory Notes.)

 33.64
of the Lakeside Apartments Mortgage Loan (see Exhibit 33.46)

 33.65
Wells Fargo Bank, National Association, as Trustee of the Lakeside Apartments

 33.66
Custodian of the Lakeside Apartments Mortgage Loan (see Exhibit 33.4)

 33.67
Advisor of the Lakeside Apartments Mortgage Loan (see Exhibit 33.31)

 33.68

 33.69
Servicer of the Newport Corporate Center Mortgage Loan

 33.70
Situs Holdings, LLC, as Special Servicer of the Newport Corporate Center

 33.71
Wilmington Trust, National Association, as Trustee of the Newport Corporate
Center Mortgage Loan (Omitted. See Explanatory Notes.)

 33.72
Custodian of the Newport Corporate Center Mortgage Loan (see Exhibit 33.4)

 33.73
the Newport Corporate Center Mortgage Loan (see Exhibit 33.5)

 33.74
 CoreLogic Solutions, LLC, as Servicing Function
Participant of the Newport Corporate Center Mortgage Loan

 33.75

 33.76
Servicer of the Central Tower Office Mortgage Loan (see Exhibit 33.69)

 33.77
of the Central Tower Office Mortgage Loan (see Exhibit 33.2)

 33.78
Wilmington Trust, National Association, as Trustee of the Central Tower Office

 33.79
Custodian of the Central Tower Office Mortgage Loan (see Exhibit 33.4)

 33.80
the Central Tower Office Mortgage Loan (see Exhibit 33.5)

 33.81
 CoreLogic Solutions, LLC, as Servicing Function
Participant of the Central Tower Office Mortgage Loan (see Exhibit 33.74)

 33.82

 33.83
National Association, as Primary Servicer of the SWVP Portfolio Mortgage Loan
(see Exhibit 33.1)

 33.84
National Association, as Special Servicer of the SWVP Portfolio Mortgage Loan
prior to May 10, 2023 (see Exhibit 33.1)

 33.85
K-Star Asset Management LLC, as Special Servicer of the SWVP Portfolio Mortgage
Loan on and after May 10, 2023 (Omitted. See Explanatory Notes.)

 33.86
Wells Fargo Bank, National Association, as Trustee of the SWVP Portfolio

 33.87
Custodian of the SWVP Portfolio Mortgage Loan (see Exhibit 33.4)

 33.88
the SWVP Portfolio Mortgage Loan (see Exhibit 33.5)

 33.89

 33.90
National Association, as Primary Servicer of the 57 East 11th Street Mortgage

 33.91
 LNR Partners, LLC, as Special Servicer of the 57
East 11th Street Mortgage Loan (see Exhibit 33.40)

 33.92
Wells Fargo Bank, National Association, as Trustee of the 57 East 11th Street

 33.93
Custodian of the 57 East 11th Street Mortgage Loan (see Exhibit 33.4)

 33.94
the 57 East 11th Street Mortgage Loan (see Exhibit 33.5)

 33.95

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

 34.1
National Association, as Master Servicer

 34.2

 34.3
 Wells Fargo Bank, National Association, as Trustee
and Certificate Administrator

 34.4
Custodian

 34.5
 Pentalpha Surveillance LLC, as Operating Advisor

 34.6
 Situs Real LLC, as EU Reporting Administrator

 34.7
as Servicing Function Participant for the Certificate Administrator

 34.8
as Servicing Function Participant for the Custodian

 34.9
National Association, as Primary Servicer of the Green Hills Corporate Center
Mortgage Loan (see Exhibit 34.1)

 34.10
of the Green Hills Corporate Center Mortgage Loan (see Exhibit 34.2)

 34.11
Wells Fargo Bank, National Association, as Trustee of the Green Hills Corporate
Center Mortgage Loan (Omitted. See Explanatory Notes.)

 34.12
Custodian of the Green Hills Corporate Center Mortgage Loan (see Exhibit 34.4)

 34.13
the Green Hills Corporate Center Mortgage Loan (see Exhibit 34.5)

 34.14

 34.15
National Association, as Primary Servicer of the Western Digital R&D Campus
Mortgage Loan (see Exhibit 34.1)

 34.16
of the Western Digital R&D Campus Mortgage Loan (see Exhibit 34.2)

 34.17
Wells Fargo Bank, National Association, as Trustee of the Western Digital
R&D Campus Mortgage Loan (Omitted. See Explanatory Notes.)

 34.18
Custodian of the Western Digital R&D Campus Mortgage Loan (see Exhibit
34.4)

 34.19
the Western Digital R&D Campus Mortgage Loan (see Exhibit 34.5)

 34.20

 34.21
National Association, as Primary Servicer of the Greenleaf at Howell Mortgage
Loan (see Exhibit 34.1)

 34.22
of the Greenleaf at Howell Mortgage Loan (see Exhibit 34.2)

 34.23
Wells Fargo Bank, National Association, as Trustee of the Greenleaf at Howell

 34.24
Custodian of the Greenleaf at Howell Mortgage Loan (see Exhibit 34.4)

 34.25
the Greenleaf at Howell Mortgage Loan (see Exhibit 34.5)

 34.26

 34.27
National Association, as Primary Servicer of the ILPT Hawaii Portfolio Mortgage
Loan (see Exhibit 34.1)

 34.28
of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 34.2)

 34.29
Wells Fargo Bank, National Association, as Trustee of the ILPT Hawaii Portfolio

 34.30
Custodian of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 34.4)

 34.31
Advisor of the ILPT Hawaii Portfolio Mortgage Loan

 34.32

 34.33
National Association, as Primary Servicer of the 101 California Mortgage Loan

 34.34
National Association, as Special Servicer of the 101 California Mortgage Loan

 34.35
Wells Fargo Bank, National Association, as Trustee of the 101 California

 34.36
 Wells Fargo Bank, National Association, as Custodian
of the 101 California Mortgage Loan (see Exhibit 34.4)

 34.37
the 101 California Mortgage Loan (see Exhibit 34.5)

 34.38

 34.39
National Association, as Primary Servicer of the 3 Columbus Circle Mortgage
Loan (see Exhibit 34.1)

 34.40
 LNR Partners, LLC, as Special Servicer of the 3
Columbus Circle Mortgage Loan

 34.41
Wells Fargo Bank, National Association, as Trustee of the 3 Columbus Circle

 34.42
Custodian of the 3 Columbus Circle Mortgage Loan (see Exhibit 34.4)

 34.43
the 3 Columbus Circle Mortgage Loan (see Exhibit 34.5)

 34.44

 34.45
National Association, as Primary Servicer of the 59 Maiden Lane Mortgage Loan

 34.46
of the 59 Maiden Lane Mortgage Loan

 34.47
Wells Fargo Bank, National Association, as Trustee of the 59 Maiden Lane

 34.48
Custodian of the 59 Maiden Lane Mortgage Loan (see Exhibit 34.4)

 34.49
Advisor of the 59 Maiden Lane Mortgage Loan (see Exhibit 34.31)

 34.50

 34.51
 Midland Loan Services, a Division of PNC Bank, National
Association, as Primary Servicer of the Arbor Hotel Portfolio Mortgage Loan

 34.52
of the Arbor Hotel Portfolio Mortgage Loan (see Exhibit 34.46)

 34.53
Wells Fargo Bank, National Association, as Trustee of the Arbor Hotel Portfolio

 34.54
Custodian of the Arbor Hotel Portfolio Mortgage Loan (see Exhibit 34.4)

 34.55
Advisor of the Arbor Hotel Portfolio Mortgage Loan (see Exhibit 34.31)

 34.56

 34.57
National Association, as Primary Servicer of the Moffett Towers II - Building V
Mortgage Loan (see Exhibit 34.1)

 34.58
of the Moffett Towers II - Building V Mortgage Loan (see Exhibit 34.46)

 34.59
Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II -
Building V Mortgage Loan (Omitted. See Explanatory Notes.)

 34.60
Custodian of the Moffett Towers II - Building V Mortgage Loan (see Exhibit
34.4)

 34.61
Advisor of the Moffett Towers II - Building V Mortgage Loan (see Exhibit 34.31)

 34.62

 34.63
Berkadia Commercial Mortgage LLC, as Primary Servicer of the Lakeside
Apartments Mortgage Loan (Omitted. See Explanatory Notes.)

 34.64
of the Lakeside Apartments Mortgage Loan (see Exhibit 34.46)

 34.65
Wells Fargo Bank, National Association, as Trustee of the Lakeside Apartments

 34.66
Custodian of the Lakeside Apartments Mortgage Loan (see Exhibit 34.4)

 34.67
Advisor of the Lakeside Apartments Mortgage Loan (see Exhibit 34.31)

 34.68
 Computershare Trust Company, National Association, as
Servicing Function Participant for the Custodian (see Exhibit 34.8)

 34.69
Servicer of the Newport Corporate Center Mortgage Loan

 34.70
Situs Holdings, LLC, as Special Servicer of the Newport Corporate Center

 34.71
Wilmington Trust, National Association, as Trustee of the Newport Corporate
Center Mortgage Loan (Omitted. See Explanatory Notes.)

 34.72
Custodian of the Newport Corporate Center Mortgage Loan (see Exhibit 34.4)

 34.73
the Newport Corporate Center Mortgage Loan (see Exhibit 34.5)

 34.74
 CoreLogic Solutions, LLC, as Servicing Function
Participant of the Newport Corporate Center Mortgage Loan

 34.75

 34.76
Servicer of the Central Tower Office Mortgage Loan (see Exhibit 34.69)

 34.77
of the Central Tower Office Mortgage Loan (see Exhibit 34.2)

 34.78
Wilmington Trust, National Association, as Trustee of the Central Tower Office

 34.79
Custodian of the Central Tower Office Mortgage Loan (see Exhibit 34.4)

 34.80
the Central Tower Office Mortgage Loan (see Exhibit 34.5)

 34.81
 CoreLogic Solutions, LLC, as Servicing Function
Participant of the Central Tower Office Mortgage Loan (see Exhibit 34.74)

 34.82

 34.83
National Association, as Primary Servicer of the SWVP Portfolio Mortgage Loan

 34.84
National Association, as Special Servicer of the SWVP Portfolio Mortgage Loan
prior to May 10, 2023 (see Exhibit 34.1)

 34.85
K-Star Asset Management LLC, as Special Servicer of the SWVP Portfolio Mortgage
Loan on and after May 10, 2023 (Omitted. See Explanatory Notes.)

 34.86
Wells Fargo Bank, National Association, as Trustee of the SWVP Portfolio

 34.87
Custodian of the SWVP Portfolio Mortgage Loan (see Exhibit 34.4)

 34.88
the SWVP Portfolio Mortgage Loan (see Exhibit 34.5)

 34.89

 34.90
National Association, as Primary Servicer of the 57 East 11th Street Mortgage
Loan (see Exhibit 34.1)

 34.91
 LNR Partners, LLC, as Special Servicer of the 57
East 11th Street Mortgage Loan (see Exhibit 34.40)

 34.92
Wells Fargo Bank, National Association, as Trustee of the 57 East 11th Street

 34.93
Custodian of the 57 East 11th Street Mortgage Loan (see Exhibit 34.4)

 34.94
the 57 East 11th Street Mortgage Loan (see Exhibit 34.5)

 34.95

Servicer compliance statements.

 35.1
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 of the Green Hills Corporate Center
Mortgage Loan (see Exhibit 35.1)

 35.6
of the Green Hills Corporate Center Mortgage Loan (see Exhibit 35.2)

 35.7
National Association, as Primary Servicer of the Western Digital R&D Campus
Mortgage Loan (see Exhibit 35.1)

 35.8
of the Western Digital R&D Campus Mortgage Loan (see Exhibit 35.2)

 35.9
National Association, as Primary Servicer of the Greenleaf at Howell Mortgage

 35.10
of the Greenleaf at Howell Mortgage Loan (see Exhibit 35.2)

 35.11
National Association, as Primary Servicer of the ILPT Hawaii Portfolio Mortgage

 35.12
of the ILPT Hawaii Portfolio Mortgage Loan (see Exhibit 35.2)

 35.13
National Association, as Primary Servicer of the 101 California Mortgage Loan
(see Exhibit 35.1)

 35.14
National Association, as Special Servicer of the 101 California Mortgage Loan
(see Exhibit 35.1)

 35.15
National Association, as Primary Servicer of the 3 Columbus Circle Mortgage

 35.16
 LNR Partners, LLC, as Special Servicer of the 3
Columbus Circle Mortgage Loan

 35.17
National Association, as Primary Servicer of the 59 Maiden Lane Mortgage Loan
(see Exhibit 35.1)

 35.18
of the 59 Maiden Lane Mortgage Loan

 35.19
National Association, as Primary Servicer of the Arbor Hotel Portfolio Mortgage

 35.20
of the Arbor Hotel Portfolio Mortgage Loan (see Exhibit 35.18)

 35.21
National Association, as Primary Servicer of the Moffett Towers II - Building V
Mortgage Loan (see Exhibit 35.1)

 35.22
of the Moffett Towers II - Building V Mortgage Loan (see Exhibit 35.18)

 35.23
Berkadia Commercial Mortgage LLC, as Primary Servicer of the Lakeside
Apartments Mortgage Loan (Omitted. See Explanatory Notes.)

 35.24
of the Lakeside Apartments Mortgage Loan (see Exhibit 35.18)

 35.25
 Wells Fargo Bank, National Association, as General
Master Servicer of the Newport Corporate Center Mortgage Loan

 35.26
Situs Holdings, LLC, as Special Servicer of the Newport Corporate Center

 35.27
Servicer of the Central Tower Office Mortgage Loan (see Exhibit 35.25)

 35.28
of the Central Tower Office Mortgage Loan (see Exhibit 35.2)

 35.29
National Association, as Primary Servicer of the SWVP Portfolio Mortgage Loan
(see Exhibit 35.1)

 35.30
National Association, as Special Servicer of the SWVP Portfolio Mortgage Loan
prior to May 10, 2023 (see Exhibit 35.1)

 35.31
K-Star Asset Management LLC, as Special Servicer of the SWVP Portfolio Mortgage
Loan on and after May 10, 2023 (Omitted. See Explanatory Notes.)

 35.32
National Association, as Primary Servicer of the 57 East 11th Street Mortgage

 35.33
 LNR Partners, LLC, as Special Servicer of the 57
East 11th Street Mortgage Loan (see Exhibit 35.16)

 99.1
 Mortgage Loan Purchase Agreement, dated as of June 17,
2019, between J.P. Morgan Chase Commercial Mortgage Securities Corp. and
JPMorgan Chase Bank, National Association (filed as Exhibit 99.1 to the
registrant's Current Report on Form 8-K filed on June 17, 2019 under Commission
File No. 333-226123-03 and incorporated by reference herein).

 99.2 Mortgage Loan Purchase Agreement, dated as of June 17,
2019, between J.P. Morgan Chase Commercial Mortgage Securities Corp. and German
American Capital Corporation (filed as Exhibit 99.2 to the registrant's Current
Report on Form 8-K filed on June 17, 2019 under Commission File No.

 99.3 Mortgage Loan Purchase Agreement, dated as of June 17,
2019, between J.P. Morgan Chase Commercial Mortgage Securities Corp. and Citi
Real Estate Funding Inc. (filed as Exhibit 99.3 to the registrant's Current
Report on Form 8-K filed on June 17, 2019 under Commission File No.

 99.4 Primary Servicing Agreement, dated as of May 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 99.4 to the registrant's Current Report on Form
8-K/A filed on February 11, 2020 under Commission File No. 333-226123-03 and
incorporated by reference herein).

 (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.

 J.P. Morgan Chase Commercial
Mortgage Securities Corp.

(Depositor)

 /s/ Kunal
K. Singh

 Kunal K.
Singh, President and Chief Executive Officer

 (senior officer in charge of
securitization of the depositor)

 Date: March 13, 2024