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: 333-206847-10

 Central Index Key Number of the issuing entity:
0001756271

 BANK 2018-BNK15

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

 Central Index Key Number of the depositor: 0001005007

 Banc of America Merrill Lynch
Commercial Mortgage Inc.

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

 Central Index Key Number of the sponsor: 0001102113

 Bank of America, National
Association

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

 Central Index Key Number of the sponsor: 0001541557

 Morgan Stanley Mortgage Capital
Holdings LLC

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

 Central Index Key Number of the sponsor: 0000740906

 Wells Fargo Bank, National
Association

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

 Central Index Key Number of the sponsor: 0001577313

 National Cooperative Bank, N.A.

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

 New York

 (State or other jurisdiction of

 incorporation or organization of

 the issuing entity)

 38-4096495

 38-4096496

 38-7206265

 (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:

 (646) 855-3953

 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 685 Fifth Avenue Retail Mortgage Loan,
which constituted approximately 5.5% of the asset pool of the issuing entity as
of its cut-off date, is an asset of the issuing entity and is part of a loan
combination that includes the 685 Fifth Avenue Retail Mortgage Loan and one
other pari passu loan, which is not an asset of the issuing entity. This
loan combination, including the 685 Fifth Avenue Retail Mortgage Loan, is 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 Aventura Mall Mortgage Loan, which
constituted approximately 9.2% of the asset pool of the issuing entity as of
its cut-off date. The Aventura Mall Mortgage Loan is an asset of the
issuing entity and is part of a loan combination that includes the Aventura
Mall Mortgage Loan, twenty-four other pari passu loans and four
subordinate companion loans, which are not assets of the issuing entity. A pari
passu portion of the loan combination was securitized in the Aventura Mall
Trust 2018-AVM transaction (the " Aventura Mall Trust 2018-AVM Transaction ").
This loan combination, including the Aventura Mall Mortgage Loan, is being
serviced and administered pursuant to the trust and servicing agreement for the
Aventura Mall Trust 2018-AVM Transaction, which is incorporated by reference as
Exhibit 4.2 to this Annual Report on Form 10-K.

Exhibit Index) with respect to the Pfizer Building Mortgage Loan, which
constituted approximately 2.7% of the asset pool of the issuing entity as of
its cut-off date. The Pfizer Building Mortgage Loan is an asset of the
issuing entity and is part of a loan combination that includes the Pfizer
Building Mortgage Loan and four other pari passu loans, which are not
assets of the issuing entity. A pari passu portion of the loan
combination was securitized in the BANK 2018-BNK13 transaction, Commission File
Number 333-206677-26 (the " BANK 2018-BNK13 Transaction "). This loan
combination, including the Pfizer Building Mortgage Loan, is being serviced and
administered pursuant to the pooling and servicing agreement for the BANK
2018-BNK13 Transaction, which is incorporated by reference as Exhibit 4.3 to
this Annual Report on Form 10-K.

Exhibit Index) with respect to the Millennium Partners Portfolio Mortgage Loan,
which constituted approximately 6.9% of the asset pool of the issuing entity as
of its cut-off date. The Millennium Partners Portfolio Mortgage Loan is
an asset of the issuing entity and is part of a loan combination that includes
the Millennium Partners Portfolio Mortgage Loan, six other pari passu
loans and six subordinate companion loans, which are not assets of the issuing
entity. A pari passu portion of the loan combination was securitized in
the Morgan Stanley Capital I Trust 2018-MP transaction (the " MSC 2018-MP
Transaction "). This loan combination, including the Millennium Partners
Portfolio Mortgage Loan, is being serviced and administered pursuant to the
trust and servicing agreement for the MSC 2018-MP Transaction, which is incorporated
by reference as Exhibit 4.4 to this Annual Report on Form 10-K.

Exhibit Index) with respect to the Plaza Frontenac Mortgage Loan, which constituted
approximately 1.8% of the asset pool of the issuing entity as of its cut-off
date. The Plaza Frontenac Mortgage Loan is an asset of the issuing entity
and is part of a loan combination that includes the Plaza Frontenac Mortgage
Loan and two other pari passu loans, which are not assets of the issuing
entity. A pari passu portion of the loan combination was securitized in
the Morgan Stanley Capital I Trust 2018-L1 transaction, Commission File Number
333-206582-17 (the " MSC 2018-L1 Transaction "). This loan combination,
including the Plaza Frontenac Mortgage Loan, is being serviced and administered
pursuant to the pooling and servicing agreement for the MSC 2018-L1
Transaction, which is incorporated by reference as Exhibit 4.5 to this Annual
Report on Form 10-K.

Exhibit Index) with respect to the Starwood Hotel Portfolio Mortgage Loan,
which constituted approximately 9.2% of the asset pool of the issuing entity as
of its cut-off date. The Starwood Hotel Portfolio Mortgage Loan is an
asset of the issuing entity and is part of a loan combination that includes the
Starwood Hotel Portfolio Mortgage Loan and three other pari passu loans,
which are not assets of the issuing entity. A pari passu portion of the
loan combination was securitized in the Wells Fargo Commercial Mortgage Trust
2018-C47 transaction, Commission File Number 333-226486-01 (the " WFCM
2018-C47 Transaction "). This loan combination, including the Starwood Hotel
Portfolio Mortgage Loan, is being serviced and administered pursuant to the
pooling and servicing agreement for the WFCM 2018-C47 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 - Buildings E, F, G Mortgage
Loan, which constituted approximately 5.2% of the asset pool of the issuing
entity as of its cut-off date. The Moffett Towers - Buildings E, F, G
Mortgage Loan is an asset of the issuing entity and is part of a loan
combination that includes the Moffett Towers - Buildings E, F, G 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 DBGS 2018-C1 Mortgage Trust transaction, Commission File Number
333-206705-16 (the " DBGS 2018-C1 Transaction "). This loan combination,
including the Moffett Towers - Buildings E, F, G Mortgage Loan, is being
serviced and administered pursuant to the pooling and servicing agreement for
the DBGS 2018-C1 Transaction, which is incorporated by reference as Exhibit 4.7
to this Annual Report on Form 10-K.

Exhibit Index) with respect to the 2020 Fifth Avenue Mortgage Loan, which
constituted approximately 2.2% of the asset pool of the issuing entity as of its
cut-off date. The 2020 Fifth Avenue Mortgage Loan is an asset of the
issuing entity and is part of a loan combination that includes the 2020 Fifth
Avenue 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 CSAIL 2018-C14 Commercial Mortgage Trust
transaction, Commission File Number 333-207361-10 (the " CSAIL 2018-C14
Transaction "). This loan combination, including the 2020 Fifth Avenue Mortgage
Loan, is being serviced and administered pursuant to the pooling and servicing
agreement for the CSAIL 2018-C14 Transaction, which is incorporated by
reference as Exhibit 4.8 to this Annual Report on Form 10-K.

Exhibit Index) with respect to the Carriage Place Mortgage Loan, which
constituted approximately 0.9% of the asset pool of the issuing entity as of
its cut-off date. The Carriage Place Mortgage Loan is an asset of the
issuing entity and is part of a loan combination that includes the Carriage
Place Mortgage Loan and one other pari passu loan, which is not an asset
of the issuing entity. This loan combination, including the Carriage Place
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 Carriage Place loan combination in the BANK 2019-BNK16
transaction, Commission File Number 333-226486-03 (the " BANK 2019-BNK16
Transaction "). After the closing of the BANK 2019-BNK16 Transaction
on February 21, 2019, this loan combination, including the Carriage Place
Mortgage Loan was, and will continue to be, serviced and administered pursuant
to the pooling and servicing agreement with respect to the BANK 2019-BNK16
Transaction, which is incorporated by reference as Exhibit 4.9 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 general master servicer and certificate administrator of the
mortgage loans serviced under the Pooling and Servicing Agreement, the primary
servicer of the Starwood Hotel Portfolio Mortgage Loan, the Aventura Mall
Mortgage Loan, the Moffett Towers - Buildings E, F, G Mortgage Loan, the Pfizer
Building Mortgage Loan, the 2020 Fifth Avenue Mortgage Loan and the Carriage
Place Mortgage Loan and the primary servicer and special servicer of the
Millennium Partners Portfolio 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 Starwood Hotel Portfolio Mortgage Loan, the
Aventura Mall Mortgage Loan, the Millennium Partners Portfolio Mortgage Loan,
the Moffett Towers - Buildings E, F, G Mortgage Loan, the Pfizer Building
Mortgage Loan, the 2020 Fifth Avenue Mortgage Loan, the Plaza Frontenac
Mortgage Loan and the Carriage Place 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.

 Park Bridge Lender Services LLC is
the operating advisor of the mortgage loans serviced under the Pooling and Servicing
Agreement, the Starwood Hotel Portfolio Mortgage Loan, the Aventura Mall
Mortgage Loan, the Moffett Towers - Buildings E, F, G Mortgage Loan and the
Carriage Place 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.

 Pentalpha Surveillance LLC is the
operating advisor of the Pfizer Building Mortgage Loan, the 2020 Fifth Avenue
Mortgage Loan and the Plaza Frontenac 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.

 Rialto Capital Advisors, LLC is
the special servicer of the Moffett Towers - Buildings E, F, G Mortgage Loan
and the 2020 Fifth Avenue 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 Rialto
Capital Advisors, LLC and an accountants' attestation report pursuant to Item
1122 of Regulation AB because Rialto Capital Advisors, LLC 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 Rialto Capital Advisors, LLC because
Rialto Capital Advisors, LLC is an unaffiliated servicer servicing less than
10% of pool assets.

 Midland Loan Services, a Division
of PNC Bank, National Association is the special servicer of the Starwood Hotel
Portfolio Mortgage Loan and the primary servicer and special servicer of the
Plaza Frontenac Mortgage Loan, which constituted approximately 9.2% and 1.8%,
respectively, of the asset pool of the issuing entity as of its cut-off date.
In accordance with the Compliance and Disclosure Interpretations, Section 200.03
(Rules 13a-18 and 15d-18, Servicer's Assessment of Compliance), this percentage
must be reduced pro rata because it was only acting as special servicer of the
Starwood Hotel Portfolio Mortgage Loan from January 1, 2023 to April 23, 2023
and the special servicer of the Plaza Frontenac Mortgage Loan from January 1,
2023 to April 26, 2023. As a result, it falls below the de minimis requirements
in Item 1122 of Regulation AB and no such assessment or attestation is
required. In addition, Midland Loan Services, a Division of PNC Bank, National
Association is an unaffiliated party that, as a result of such pro rata
reduction of such percentage, is not a "servicer" that meets the criteria in
Item 1108(a)(2)(i) through (iii) of Regulation AB and so no servicer compliance
statement is required.

 K-Star Asset Management LLC is the
special servicer of the Starwood Hotel Portfolio Mortgage Loan and the Plaza
Frontenac Mortgage Loan, which constituted approximately 9.2% and 1.8%,
respectively, of the asset pool of the issuing entity as of its cut-off date.
In accordance with the Compliance and Disclosure Interpretations, Section
200.03 (Rules 13a-18 and 15d-18, Servicer's Assessment of Compliance), this
percentage must be reduced pro rata because it was only acting as special
servicer of the Starwood Hotel Portfolio Mortgage Loan from April 24, 2023 to
December 31, 2023 and the special servicer of the Plaza Frontenac Mortgage Loan
from April 27, 2023 to December 31, 2023. As a result, K-Star Asset Management
LLC is an unaffiliated party that, as a result of such pro rata reduction of
such percentage, is not a "servicer" that meets the criteria in Item
1108(a)(2)(i) through (iii) of Regulation AB and so no servicer compliance
statement is required.

 Wells Fargo Bank, National
Association acts as trustee of the Plaza Frontenac Mortgage Loan.
Pursuant to the pooling and servicing agreement for the MSC 2018-L1
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 Plaza Frontenac 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 Aventura Mall Mortgage Loan, the Pfizer
Building Mortgage Loan, the Millennium Partners Portfolio Mortgage Loan, the
Starwood Hotel Portfolio Mortgage Loan, the Moffett Towers - Buildings E, F, G
Mortgage Loan, the 2020 Fifth Avenue Mortgage Loan and the Carriage Place
Mortgage Loan. Pursuant to the Pooling and Servicing Agreement, the trust
and servicing agreement for the Aventura Mall Trust 2018-AVM Transaction, the
pooling and servicing agreement for the BANK 2018-BNK13 Transaction, the trust
and servicing agreement for the MSC 2018-MP Transaction, the pooling and
servicing agreement for the WFCM 2018-C47 Transaction, the pooling and
servicing agreement for the DBGS 2018-C1 Transaction, the pooling and servicing
agreement for the CSAIL 2018-C14 Transaction and the pooling and servicing
agreement for the BANK 2019-BNK16 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 Aventura Mall Mortgage Loan, the
Pfizer Building Mortgage Loan, the Millennium Partners Portfolio Mortgage Loan,
the Starwood Hotel Portfolio Mortgage Loan, the Moffett Towers - Buildings E,
F, G Mortgage Loan, the 2020 Fifth Avenue Mortgage Loan and the Carriage Place
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 general master servicer under the Pooling and
Servicing Agreement and the primary servicer of the Aventura Mall Mortgage
Loan, the Pfizer Building Mortgage Loan, the Millennium Partners Portfolio
Mortgage Loan, the Starwood Hotel Portfolio Mortgage Loan, the Moffett Towers -
Buildings E, F, G Mortgage Loan, the 2020 Fifth Avenue Mortgage Loan and the
Carriage Place 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 Aventura Mall
Mortgage Loan, the Pfizer Building Mortgage Loan, the Millennium Partners
Portfolio Mortgage Loan, the Plaza Frontenac Mortgage Loan, the Starwood Hotel
Portfolio Mortgage Loan, the Moffett Towers - Buildings E, F, G Mortgage Loan,
the 2020 Fifth Avenue Mortgage Loan and the Carriage Place 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 Starwood Hotel Portfolio Mortgage Loan, the
Aventura Mall Mortgage Loan, the Pfizer Building Mortgage Loan, the Plaza
Frontenac Mortgage Loan, the Moffett Towers - Buildings E, F, G Mortgage Loan,
the 2020 Fifth Avenue Mortgage Loan and the Carriage Place Mortgage Loan, (i)
the reports on assessment of compliance with servicing criteria and attestation
reports on assessment of compliance with servicing criteria of Mount Street US
(Georgia) LLP as special servicer of the Pfizer Building Mortgage Loan and
KeyBank National Association as special servicer of the Carriage Place 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 the report on assessment of compliance
with servicing criteria and attestation report on assessment of compliance with
servicing criteria of Midland Loan Services, a Division
of PNC Bank, National Association as special servicer of the Starwood Hotel
Portfolio Mortgage Loan prior to April 24, 2023, primary servicer of the Plaza
Frontenac Mortgage Loan and special servicer of the Plaza Frontenac Mortgage
Loan prior to April 27, 2023 listed on the Exhibit Index are omitted from this
Annual Report on Form 10-K for the reasons set forth in the Explanatory Notes
above; and (ii) the servicer compliance statements of CWCapital Asset
Management LLC as special servicer of the Aventura Mall Mortgage Loan, Mount
Street US (Georgia) LLP as special servicer of the Pfizer Building
Mortgage Loan, Rialto Capital Advisors, LLC as special servicer of the Moffett
Towers - Buildings E, F, G Mortgage Loan and the 2020 Fifth Avenue Mortgage
Loan and KeyBank National Association as special servicer of the Carriage Place
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, and the servicer compliance statements
of Midland Loan Services, a Division of PNC Bank, National Association as
special servicer of the Starwood Hotel Portfolio Mortgage Loan prior to April
24, 2023, primary servicer of the Plaza Frontenac Mortgage Loan and special
servicer of the Plaza Frontenac Mortgage Loan prior to April 27, 2023 and
K-Star Asset Management LLC as special servicer of the Starwood Hotel Portfolio
Mortgage Loan on and after April 24, 2023 and special servicer of the Plaza
Frontenac Mortgage Loan on and after April 27, 2023 listed on the Exhibit Index
are omitted from this Annual Report on Form 10-K for the reasons set forth in
the Explanatory Notes above.

 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 November 29, 2018 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 Z
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 Aventura Mall Mortgage Loan,
which is being serviced and administered pursuant to the trust and servicing
agreement for the Aventura Mall Trust 2018-AVM 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 Aventura Mall Trust 2018-AVM 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
Aventura Mall Trust 2018-AVM Transaction responsible for each applicable
servicing criteria set forth in Item 1122(d).

assessments of compliance with respect to the Pfizer Building Mortgage Loan,
which is being serviced and administered pursuant to the pooling and servicing
agreement for the BANK 2018-BNK13 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 BANK 2018-BNK13 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 BANK 2018-BNK13
Transaction responsible for each applicable servicing criteria set forth in
Item 1122(d).

assessments of compliance with respect to the Millennium Partners Portfolio
Mortgage Loan, which is being serviced and administered pursuant to the trust
and servicing agreement for the MSC 2018-MP 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 MSC 2018-MP 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 MSC
2018-MP Transaction responsible for each applicable servicing criteria set
forth in Item 1122(d).

assessments of compliance with respect to the Plaza Frontenac Mortgage Loan,
which is being serviced and administered pursuant to the pooling and servicing
agreement for the MSC 2018-L1 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 2018-L1 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 MSC 2018-L1 Transaction
responsible for each applicable servicing criteria set forth in Item 1122(d).

assessments of compliance with respect to the Starwood Hotel Portfolio Mortgage
Loan, which is being serviced and administered pursuant to the pooling and
servicing agreement for the WFCM 2018-C47 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 2018-C47 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 WFCM
2018-C47 Transaction responsible for each applicable servicing criteria set
forth in Item 1122(d).

assessments of compliance with respect to the Moffett Towers - Buildings E, F,
G Mortgage Loan, which is being serviced and administered pursuant to the
pooling and servicing agreement for the DBGS 2018-C1 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 DBGS 2018-C1 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
DBGS 2018-C1 Transaction responsible for each applicable servicing criteria set
forth in Item 1122(d).

assessments of compliance with respect to the 2020 Fifth Avenue Mortgage Loan,
which is being serviced and administered pursuant to the pooling and servicing
agreement for the CSAIL 2018-C14 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 CSAIL 2018-C14 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 CSAIL
2018-C14 Transaction responsible for each applicable servicing criteria set
forth in Item 1122(d).

criteria for asset-backed securities and related attestation reports on such assessments
of compliance with respect to the Carriage Place Mortgage Loan, which is being
serviced and administered pursuant to the pooling and servicing agreement for
the BANK 2019-BNK16 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 BANK 2019-BNK16 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 BANK 2019-BNK16
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 November 1,
2018, by and among Banc of America Merrill Lynch Commercial Mortgage Inc., as
Depositor, Wells Fargo Bank, National Association, as General Master Servicer,
Midland Loan Services, a Division of PNC Bank, National Association, as General
Special Servicer, National Cooperative Bank, N.A., as NCB Master Servicer and
as NCB Special Servicer, Wells Fargo Bank, National Association, as Certificate
Administrator, Wilmington Trust, National Association, as Trustee, and Park
Bridge Lender Services LLC, as Operating Advisor and as Asset Representations
Reviewer (filed as Exhibit 4.1 to the registrant's Current Report on Form 8-K
filed on November 29, 2018 under Commission File No. 333-206847-10 and
incorporated by reference herein).

 4.2
 Trust and Servicing Agreement, dated as of June 29, 2018,
by and among J.P. Morgan Chase Commercial Mortgage Securities Corp., as
Depositor, Wells Fargo Bank, National Association, as Servicer, CWCapital Asset
Management 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 (filed as Exhibit 4.2
to the registrant's Current Report on Form 8-K filed on November 29, 2018 under

 4.3
 Pooling and Servicing Agreement, dated as of August 1,
2018, by and among Wells Fargo Commercial Mortgage Securities, Inc., as
Depositor, Wells Fargo Bank, National Association, as General Master Servicer,
Torchlight Loan Services, LLC, as General Special Servicer, National
Cooperative Bank, N.A., as NCB Master Servicer and as NCB Special Servicer,
Wells Fargo Bank, National Association, as Certificate Administrator,
Wilmington Trust, National Association, as Trustee, and Pentalpha Surveillance
LLC, as Operating Advisor and as Asset Representations Reviewer (filed as
Exhibit 4.6 to the registrant's Current Report on Form 8-K filed on November
29, 2018 under Commission File No. 333-206847-10 and incorporated by reference
herein).

 4.4
 Trust and Servicing Agreement, dated as of August 7,
2018, by and among Morgan Stanley Capital I Inc., as Depositor, Wells Fargo
Bank, National Association, as Servicer and Special Servicer, Wilmington Trust,
National Association, as Trustee, and Wells Fargo Bank, National Association,
as Certificate Administrator and Custodian, (filed as Exhibit 4.4 to the

 4.5
 Pooling and Servicing Agreement, dated as of October 1,
2018, by and among Morgan Stanley Capital I Inc., 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 4.9 to the registrant's
Current Report on Form 8-K filed on November 29, 2018 under Commission File No.
333-206847-10 and incorporated by reference herein).

 4.6
 Pooling and Servicing Agreement, dated as of October 1,
2018, by and among Wells Fargo Commercial Mortgage Securities, Inc., as
Depositor, Wells Fargo 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,
Wilmington Trust, National Association, as Trustee, and Park Bridge Lender
Services LLC, as Operating Advisor and as Asset Representations Reviewer (filed
as Exhibit 4.3 to the registrant's Current Report on Form 8-K filed on November
29, 2018 under Commission File No. 333-206847-10 and incorporated by reference
herein).

 4.7
 Pooling and Servicing Agreement, dated as of October 1,
2018, by and among Deutsche Mortgage & Asset Receiving Corporation, as
Depositor, Wells Fargo Bank, National Association, as Master Servicer, Rialto
Capital Advisors, LLC, as Special Servicer, Wilmington Trust, National Association,
as Trustee, Wells Fargo Bank, National Association, as Certificate
Administrator, Paying Agent and Custodian, and Park Bridge Lender Services LLC,
as Operating Advisor and Asset Representations Reviewer (filed as Exhibit 4.5
to the registrant's Current Report on Form 8-K filed on November 29, 2018 under

 4.8
 Pooling and Servicing Agreement, dated as of November 1,
2018, by and among Credit Suisse Commercial Mortgage Securities 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 4.8 to the registrant's
Current Report on Form 8-K filed on November 29, 2018 under Commission File No.
333-206847-10 and incorporated by reference herein).

 4.9
 Pooling and Servicing Agreement, dated as of February 1,
2019, among Wells Fargo Commercial Mortgage Securities, Inc., as Depositor,
Wells Fargo Bank, National Association, as General Master Servicer, KeyBank
National Association, as General Special Servicer, National Cooperative Bank,
N.A., as NCB Master Servicer and as NCB Special Servicer, Wells Fargo Bank,
National Association, as Certificate Administrator, Wilmington Trust, National
Association, as Trustee, and Park Bridge Lender Services LLC, as Operating
Advisor and as Asset Representations Reviewer (filed as Exhibit 4.1 to the
registrant's Current Report on Form 8-K/A filed on March 18, 2019 under

 4.10 Co-Lender Agreement, dated as of June 7, 2018, by and
among JPMorgan Chase Bank, National Association, Deutsche Bank, AG, New York
Branch, Wells Fargo Bank, National Association and Morgan Stanley Bank, N.A.
(filed as Exhibit 4.10 to the registrant's Current Report on Form 8-K filed on
November 29, 2018 under Commission File No. 333-206847-10 and incorporated by
reference herein).

 4.11 Agreement Between Note Holders, dated as of September 27,
2018, by and between Wells Fargo Bank, National Association, as Initial Note
A-1 Holder, Wells Fargo Bank, National Association, as Initial Note A-2 Holder,
Wells Fargo Bank, National Association, as Initial Note A-3 Holder, and Wells
Fargo Bank, National Association, as Initial Note A-4 Holder (filed as Exhibit
4.11 to the registrant's Current Report on Form 8-K filed on November 29, 2018
under Commission File No. 333-206847-10 and incorporated by reference herein).

 4.12 Agreement Between Note Holders, dated as of August 9,
2018, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder,
Initial Note A-2 Holder, Initial Note A-3 Holder, Initial Note A-4 Holder,
Initial Note A-5 Holder and Initial Note A-6 Holder, Morgan Stanley Bank, N.A.,
as Initial Note B-1 Holder, Initial Note B-2 Holder, Initial Note B-3 Holder,
Initial Note B-4 Holder, Initial Note B-5 Holder and Initial Note B-6 Holder,
and Morgan Stanley Bank, N.A., as Initial Note C Holder (filed as Exhibit 4.12
to the registrant's Current Report on Form 8-K filed on November 29, 2018 under

 4.13 Amended and Restated Agreement Between Note Holders,
dated as of September 26, 2018, by and between Bank of America, N.A., as
Initial Note A-1 Holder, and Bank of America, N.A., as Initial Note A-2 Holder
(filed as Exhibit 4.13 to the registrant's Current Report on Form 8-K filed on
November 29, 2018 under Commission File No. 333-206847-10 and incorporated by
reference herein).

 4.14 Co-Lender Agreement, dated as of October 30, 2018, by and
among Deutsche Bank AG, acting through its New York Branch, as Note A-1-1
Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-1-2
Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-1-3 Holder,
Deutsche Bank AG, acting through its New York Branch, as Note A-1-4 Holder,
Deutsche Bank AG, acting through its New York Branch, as Note A-2 Holder,
Deutsche Bank AG, acting through its New York Branch, as Note A-3 Holder,
Deutsche Bank AG, acting through its New York Branch, as Note A-4 Holder,
Goldman Sachs Mortgage Company, as Note A-5 Holder, Wells Fargo Bank, National
Association, as Note A-6 Holder, and Wells Fargo Bank, National Association, as
Note A-7 Holder (filed as Exhibit 4.14 to the registrant's Current Report on
Form 8-K filed on November 29, 2018 under Commission File No. 333-206847-10 and
incorporated by reference herein).

 4.15 Agreement Between Note Holders, dated as of July 27,
2018, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder,
Morgan Stanley Bank, N.A., as Initial Note A-2 Holder, Morgan Stanley Bank,
N.A., as Initial Note A-3 Holder, Morgan Stanley Bank, N.A., as Initial Note
A-4 Holder, and Morgan Stanley Bank, N.A., as Initial Note A-5 Holder (filed as
Exhibit 4.15 to the registrant's Current Report on Form 8-K filed on November
29, 2018 under Commission File No. 333-206847-10 and incorporated by reference
herein).

 4.16 Agreement Between Note Holders, dated as of August 22,
2018, by and between Column Financial, Inc., as Initial Note A-1 Holder, and
Wells Fargo Bank, National Association, as Initial Note A-2 Holder (filed as
Exhibit 4.17 to the registrant's Current Report on Form 8-K filed on November
29, 2018 under Commission File No. 333-206847-10 and incorporated by reference
herein).

 4.17 Agreement Between Note Holders, dated as of July 27,
2018, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder, and
Morgan Stanley Bank, as Initial Note A-2 Holder (filed as Exhibit 4.18 to the

 4.18 Agreement Between Note Holders, dated as of November 2,
2018, by and between Bank of America, N.A., as Initial Note A-1 Holder, and
Bank of America, N.A., as Initial Note A-2 Holder (filed as Exhibit 4.19 to the
registrant's Current Report on Form 8-K filed on November 29, 2018 under Commission
File No. 333-206847-10 and incorporated by reference herein).

 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 General
Master Servicer

 33.2
 National Cooperative Bank, N.A., as NCB Master
Servicer

 33.3
 LNR Partners, LLC, as General Special Servicer

 33.4
 National Cooperative Bank, N.A., as NCB Special
Servicer (see Exhibit 33.2)

 33.5
Wilmington Trust, National Association, as Trustee (Omitted. See Explanatory
Notes.)

 33.6
Certificate Administrator

 33.7
Custodian

 33.8
Advisor

 33.9
Participant

 33.10
as Servicing Function Participant for the Certificate Administrator

 33.11
as Servicing Function Participant for the Custodian

 33.12
Servicer of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 33.1)

 33.13
 LNR Partners, LLC, as Special Servicer of the 685
Fifth Avenue Retail Mortgage Loan (see Exhibit 33.3)

 33.14
Wilmington Trust, National Association, as Trustee of the 685 Fifth Avenue
Retail Mortgage Loan (Omitted. See Explanatory Notes.)

 33.15
Custodian of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 33.7)

 33.16
Advisor of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 33.8)

 33.17
Participant of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 33.9)

 33.18

 33.19
Servicer of the Aventura Mall Mortgage Loan (see Exhibit 33.1)

 33.20
 CWCapital Asset Management LLC, as Special
Servicer of the Aventura Mall Mortgage Loan

 33.21
Wilmington Trust, National Association, as Trustee of the Aventura Mall

 33.22
Custodian of the Aventura Mall Mortgage Loan (see Exhibit 33.7)

 33.23
Advisor of the Aventura Mall Mortgage Loan (see Exhibit 33.8)

 33.24
Participant of the Aventura Mall Mortgage Loan (see Exhibit 33.9)

 33.25

 33.26
Servicer of the Pfizer Building Mortgage Loan (see Exhibit 33.1)

 33.27
Mount Street US (Georgia) LLP, as Special Servicer of the Pfizer Building

 33.28
Wilmington Trust, National Association, as Trustee of the Pfizer Building

 33.29
Custodian of the Pfizer Building Mortgage Loan (see Exhibit 33.7)

 33.30
of the Pfizer Building Mortgage Loan

 33.31
Participant of the Pfizer Building Mortgage Loan (see Exhibit 33.9)

 33.32

 33.33
Servicer of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 33.1)

 33.34
 Wells Fargo Bank, National Association, as Special
Servicer of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 33.1)

 33.35
Wilmington Trust, National Association, as Trustee of the Millennium Partners
Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

 33.36
Custodian of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 33.7)

 33.37
Participant of the Millennium Partners Portfolio Mortgage Loan (see Exhibit
33.9)

 33.38

 33.39
Midland Loan Services, a Division of PNC Bank, National Association, as Primary
Servicer of the Plaza Frontenac Mortgage Loan (Omitted. See Explanatory Notes.)

 33.40
 Midland Loan Services, a Division of PNC Bank, National
Association, as Special Servicer of the Plaza Frontenac Mortgage Loan prior
to April 27, 2023 (Omitted. See Explanatory Notes.)

 33.41
 K-Star Asset Management LLC, as Special Servicer
of the Plaza Frontenac Mortgage Loan on and after April 27, 2023

 33.42
Wells Fargo Bank, National Association, as Trustee of the Plaza Frontenac

 33.43
Custodian of the Plaza Frontenac Mortgage Loan (see Exhibit 33.7)

 33.44
of the Plaza Frontenac Mortgage Loan (see Exhibit 33.30)

 33.45 Computershare Trust Company, National Association, as
Servicing Function Participant for the Custodian (see Exhibit 33.11)

 33.46
Servicer of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 33.1)

 33.47
Servicer of the Starwood Hotel Portfolio Mortgage Loan prior to April 24, 2023
(Omitted. See Explanatory Notes.)

 33.48
 K-Star Asset Management LLC, as Special Servicer
of the Starwood Hotel Portfolio Mortgage Loan on and after April 24, 2023 (see
Exhibit 33.41)

 33.49
Wilmington Trust, National Association, as Trustee of the Starwood Hotel
Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

 33.50
Custodian of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 33.7)

 33.51
Advisor of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 33.8)

 33.52
Participant of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 33.9)

 33.53

 33.54
Servicer of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit
33.1)

 33.55
 Rialto Capital Advisors, LLC, as Special Servicer
of the Moffett Towers - Buildings E, F, G Mortgage Loan

 33.56
Wilmington Trust, National Association, as Trustee of the Moffett Towers -
Buildings E, F, G Mortgage Loan (Omitted. See Explanatory Notes.)

 33.57
Custodian of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit
33.7)

 33.58
Advisor of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit
33.8)

 33.59
Participant of the Moffett Towers - Buildings E, F, G Mortgage Loan (see
Exhibit 33.9)

 33.60

 33.61
Servicer of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 33.1)

 33.62
 Rialto Capital Advisors, LLC, as Special Servicer
of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 33.55)

 33.63
Wilmington Trust, National Association, as Trustee of the 2020 Fifth Avenue

 33.64
Custodian of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 33.7)

 33.65
of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 33.30)

 33.66
Participant of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 33.9)

 33.67

 33.68
Servicer of the Carriage Place Mortgage Loan (see Exhibit 33.1)

 33.69
KeyBank National Association, as Special Servicer of the Carriage Place

 33.70
Wilmington Trust, National Association, as Trustee of the Carriage Place

 33.71
Custodian of the Carriage Place Mortgage Loan (see Exhibit 33.7)

 33.72
Advisor of the Carriage Place Mortgage Loan (see Exhibit 33.8)

 33.73
Participant of the Carriage Place Mortgage Loan (see Exhibit 33.9)

 33.74

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

 34.1
 Wells Fargo Bank, National Association, as General
Master Servicer

 34.2
 National Cooperative Bank, N.A., as NCB Master
Servicer

 34.3
 LNR Partners, LLC, as General Special Servicer

 34.4
 National Cooperative Bank, N.A., as NCB Special
Servicer (see Exhibit 34.2)

 34.5
Wilmington Trust, National Association, as Trustee (Omitted. See Explanatory
Notes.)

 34.6
Certificate Administrator

 34.7
Custodian

 34.8
Advisor

 34.9
Participant

 34.10
as Servicing Function Participant for the Certificate Administrator

 34.11
as Servicing Function Participant for the Custodian

 34.12
Servicer of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 34.1)

 34.13
 LNR Partners, LLC, as Special Servicer of the 685
Fifth Avenue Retail Mortgage Loan (see Exhibit 34.3)

 34.14
Wilmington Trust, National Association, as Trustee of the 685 Fifth Avenue
Retail Mortgage Loan (Omitted. See Explanatory Notes.)

 34.15
Custodian of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 34.7)

 34.16
Advisor of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 34.8)

 34.17
Participant of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 34.9)

 34.18

 34.19
Servicer of the Aventura Mall Mortgage Loan (see Exhibit 34.1)

 34.20
 CWCapital Asset Management LLC, as Special
Servicer of the Aventura Mall Mortgage Loan

 34.21
Wilmington Trust, National Association, as Trustee of the Aventura Mall

 34.22
Custodian of the Aventura Mall Mortgage Loan (see Exhibit 34.7)

 34.23
Advisor of the Aventura Mall Mortgage Loan (see Exhibit 34.8)

 34.24
Participant of the Aventura Mall Mortgage Loan (see Exhibit 34.9)

 34.25

 34.26
Servicer of the Pfizer Building Mortgage Loan (see Exhibit 34.1)

 34.27
Mount Street US (Georgia) LLP, as Special Servicer of the Pfizer Building

 34.28
Wilmington Trust, National Association, as Trustee of the Pfizer Building

 34.29
Custodian of the Pfizer Building Mortgage Loan (see Exhibit 34.7)

 34.30
of the Pfizer Building Mortgage Loan

 34.31
Participant of the Pfizer Building Mortgage Loan (see Exhibit 34.9)

 34.32

 34.33
Servicer of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 34.1)

 34.34
 Wells Fargo Bank, National Association, as Special
Servicer of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 34.1)

 34.35
Wilmington Trust, National Association, as Trustee of the Millennium Partners
Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

 34.36
 Wells Fargo Bank, National Association, as Custodian
of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 34.7)

 34.37
Participant of the Millennium Partners Portfolio Mortgage Loan (see Exhibit
34.9)

 34.38

 34.39
Midland Loan Services, a Division of PNC Bank, National Association, as Primary
Servicer of the Plaza Frontenac Mortgage Loan (Omitted. See Explanatory Notes.)

 34.40
Servicer of the Plaza Frontenac Mortgage Loan prior to April 27, 2023 (Omitted.
See Explanatory Notes.)

 34.41
 K-Star Asset Management LLC, as Special Servicer
of the Plaza Frontenac Mortgage Loan on and after April 27, 2023

 34.42
Wells Fargo Bank, National Association, as Trustee of the Plaza Frontenac Mortgage
Loan (Omitted. See Explanatory Notes.)

 34.43
Custodian of the Plaza Frontenac Mortgage Loan (see Exhibit 34.7)

 34.44
of the Plaza Frontenac Mortgage Loan (see Exhibit 34.30)

 34.45

 34.46
Servicer of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 34.1)

 34.47
Servicer of the Starwood Hotel Portfolio Mortgage Loan prior to April 24, 2023
(Omitted. See Explanatory Notes.)

 34.48
 K-Star Asset Management LLC, as Special Servicer
of the Starwood Hotel Portfolio Mortgage Loan on and after April 24, 2023 (see
Exhibit 34.41)

 34.49
Wilmington Trust, National Association, as Trustee of the Starwood Hotel
Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

 34.50
Custodian of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 34.7)

 34.51
Advisor of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 34.8)

 34.52
Participant of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 34.9)

 34.53

 34.54
Servicer of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit
34.1)

 34.55
 Rialto Capital Advisors, LLC, as Special Servicer
of the Moffett Towers - Buildings E, F, G Mortgage Loan

 34.56
Wilmington Trust, National Association, as Trustee of the Moffett Towers -
Buildings E, F, G Mortgage Loan (Omitted. See Explanatory Notes.)

 34.57
Custodian of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit
34.7)

 34.58
Advisor of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit
34.8)

 34.59
Participant of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit
34.9)

 34.60

 34.61
Servicer of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 34.1)

 34.62
 Rialto Capital Advisors, LLC, as Special Servicer
of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 34.55)

 34.63
Wilmington Trust, National Association, as Trustee of the 2020 Fifth Avenue

 34.64
Custodian of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 34.7)

 34.65
of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 34.30)

 34.66
Participant of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 34.9)

 34.67

 34.68
Servicer of the Carriage Place Mortgage Loan (see Exhibit 34.1)

 34.69
KeyBank National Association, as Special Servicer of the Carriage Place

 34.70
Wilmington Trust, National Association, as Trustee of the Carriage Place

 34.71
Custodian of the Carriage Place Mortgage Loan (see Exhibit 34.7)

 34.72
Advisor of the Carriage Place Mortgage Loan (see Exhibit 34.8)

 34.73
Participant of the Carriage Place Mortgage Loan (see Exhibit 34.9)

 34.74

Servicer compliance statements.

 35.1
 Wells Fargo Bank, National Association, as General
Master Servicer

 35.2
 National Cooperative Bank, N.A., as NCB Master
Servicer

 35.3
 LNR Partners, LLC, as General Special Servicer

 35.4
 National Cooperative Bank, N.A., as NCB Special
Servicer (see Exhibit 35.2)

 35.5
 Wells Fargo Bank, National Association, as Certificate
Administrator

 35.6
as Servicing Function Participant for the Certificate Administrator

 35.7
Servicer of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 35.1)

 35.8
 LNR Partners, LLC, as Special Servicer of the 685
Fifth Avenue Retail Mortgage Loan (see Exhibit 35.3)

 35.9
Servicer of the Aventura Mall Mortgage Loan (see Exhibit 35.1)

 35.10
CWCapital Asset Management LLC, as Special Servicer of the Aventura Mall

 35.11
Servicer of the Pfizer Building Mortgage Loan (see Exhibit 35.1)

 35.12
Mount Street US (Georgia) LLP, as Special Servicer of the Pfizer Building

 35.13
Servicer of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 35.1)

 35.14
 Wells Fargo Bank, National Association, as Special
Servicer of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 35.1)

 35.15
Midland Loan Services, a Division of PNC Bank, National Association, as Primary
Servicer of the Plaza Frontenac Mortgage Loan (Omitted. See Explanatory
Notes.)

 35.16
Servicer of the Plaza Frontenac Mortgage Loan prior to April 27, 2023 (Omitted.
See Explanatory Notes.)

 35.17
K-Star Asset Management LLC, as Special Servicer of the Plaza Frontenac
Mortgage Loan on and after April 27, 2023 (Omitted. See Explanatory Notes.)

 35.18
Servicer of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 35.1)

 35.19
Servicer of the Starwood Hotel Portfolio Mortgage Loan prior to April 24, 2023
(Omitted. See Explanatory Notes.)

 35.20
K-Star Asset Management LLC, as Special Servicer of the Starwood Hotel
Portfolio Mortgage Loan on and after April 24, 2023 (Omitted. See Explanatory
Notes.)

 35.21
Servicer of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit
35.1)

 35.22
Rialto Capital Advisors, LLC, as Special Servicer of the Moffett Towers -
Buildings E, F, G Mortgage Loan (Omitted. See Explanatory Notes.)

 35.23
Servicer of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 35.1)

 35.24
Rialto Capital Advisors, LLC, as Special Servicer of the 2020 Fifth Avenue

 35.25
Servicer of the Carriage Place Mortgage Loan (see Exhibit 35.1)

 35.26
KeyBank National Association, as Special Servicer of the Carriage Place

 99.1 Mortgage Loan Purchase Agreement, dated as of November
16, 2018, between Banc of America Merrill Lynch Commercial Mortgage Inc. and
Bank of America, National Association (filed as Exhibit 99.3 to the
Commission File No. 333-206847-10 and incorporated by reference herein)

 99.2 Mortgage Loan Purchase Agreement, dated as of November
16, 2018, between Banc of America Merrill Lynch Commercial Mortgage Inc. and
Morgan Stanley Mortgage Capital Holdings LLC (filed as Exhibit 99.1 to the
Commission File No. 333-206847-10 and incorporated by reference herein)

 99.3 Mortgage Loan Purchase Agreement, dated as of November
16, 2018, between Banc of America Merrill Lynch Commercial Mortgage Inc. and
Wells Fargo Bank, National Association (filed as Exhibit 99.2 to the
Commission File No. 333-206847-10 and incorporated by reference herein)

 99.4 Mortgage Loan Purchase Agreement, dated as of November 16,
2018, between Banc of America Merrill Lynch Commercial Mortgage Inc. and
National Cooperative Bank, N.A. (filed as Exhibit 99.4 to the registrant's
Current Report on Form 8-K filed on November 29, 2018 under Commission File No.
333-206847-10 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.

 Banc of America Merrill Lynch
Commercial Mortgage Inc.

(Depositor)

 /s/ Leland
F. Bunch, III

 Leland F.
Bunch, III, President and Chief Executive Officer

 (senior officer in charge of
securitization of the depositor)

 Date: March 15, 2024