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: 333-228375-02

 Central Index Key Number of the issuing entity:
0001787490

 BANK 2019-BNK21

 (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)

 New York

 (State or other jurisdiction of

 incorporation or organization of

 the issuing entity)

 38-4128706

 38-4128707

 38-7235580

 (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 Park Tower at Transbay Mortgage Loan, the
230 Park Avenue South Mortgage Loan, the Storage Post Portfolio Mortgage Loan,
the 105 East 17th Street Mortgage Loan, the National Anchored Retail Portfolio
Mortgage Loan, the Tysons Tower Mortgage Loan and the Landing at Fancher Creek
Mortgage Loan, which constituted approximately 9.7%, 9.3%, 7.2%, 5.1%, 4.2%,
4.2% and 1.7%, respectively, of the asset pool of the issuing entity as of its
cut-off date, are each an asset of the issuing entity and are each part of a
loan combination that includes (a) with respect to the Park Tower at Transbay
Mortgage Loan, eight other pari passu loans, which are not assets of the
issuing entity, (b) with respect to the 230 Park Avenue South Mortgage Loan,
five other pari passu loans, which are not assets of the issuing entity,
(c) with respect to the Storage Post Portfolio Mortgage Loan, two other pari
passu loans, which are not assets of the issuing entity, (d) with respect
to the 105 East 17th Street Mortgage Loan, one other pari passu loan,
which is not an asset of the issuing entity, (e) with respect to the National
Anchored Retail Portfolio Mortgage Loan, two other pari passu loans,
which are not assets of the issuing entity, (f) with respect to the Tysons
Tower Mortgage Loan, six other pari passu loans, which are not assets of
the issuing entity and (g) with respect to the Landing at Fancher Creek
Mortgage Loan, one other pari passu loan, which is not an asset of the
issuing entity. These loan combinations, including the Park Tower at Transbay
Mortgage Loan, the 230 Park Avenue South Mortgage Loan, the Storage Post
Portfolio Mortgage Loan, the 105 East 17th Street Mortgage Loan, the National
Anchored Retail Portfolio Mortgage Loan, the Tysons Tower Mortgage Loan and the
Landing at Fancher Creek 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 Exhibit Index describes
exhibits provided by certain parties (in their capacities indicated on the
Exhibit Index) with respect to the Grand Canal Shoppes Mortgage Loan, which
constituted approximately 3.4% of the asset pool of the issuing entity as of
its cut-off date. The Grand Canal Shoppes Mortgage Loan is an asset of
the issuing entity and is part of a loan combination that includes the Grand
Canal Shoppes Mortgage Loan, twenty-three other pari passu loans and one
subordinate companion loan, which are not assets of the issuing entity. A pari
passu portion of the loan combination was securitized in the Morgan Stanley
Capital I Trust 2019-H7 transaction, Commission File Number 333-227446-05 (the
" MSC 2019-H7 Transaction "). This loan combination, including the Grand
Canal Shoppes Mortgage Loan, is being serviced and administered pursuant to the
pooling and servicing agreement for the MSC 2019-H7 Transaction, which is
incorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K.

 The Exhibit Index describes
exhibits provided by certain parties (in their capacities indicated on the
Exhibit Index) with respect to The Tower at Burbank Mortgage Loan, which
constituted approximately 5.9% of the asset pool of the issuing entity as of
its cut-off date. The Tower at Burbank Mortgage Loan is an asset of the
issuing entity and is part of a loan combination that includes 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 BANK 2019-BNK20
transaction, Commission File Number 333-227446-06 (the " BANK 2019-BNK20
Transaction "). This loan combination, including The Tower at Burbank
Mortgage Loan, is being serviced and administered pursuant to the pooling and
servicing agreement for the BANK 2019-BNK20 Transaction, which is incorporated
by reference as Exhibit 4.3 to this Annual Report on Form 10-K. The NKX
Multifamily Portfolio Mortgage Loan, previously an asset of the issuing entity being
serviced under the pooling and servicing agreement for the BANK 2019-BNK20
Transaction, 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 Exhibit Index describes
exhibits provided by certain parties (in their capacities indicated on the
Exhibit Index) with respect to the Global Data Center Mortgage Loan, which
constituted approximately 1.0% of the asset pool of the issuing entity as of
its cut-off date. The Global Data Center Mortgage Loan is an asset of the
issuing entity and is part of a loan combination that includes the Global Data
Center 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 UBS Commercial Mortgage Trust 2019-C17
transaction, Commission File Number 333-227784-04 (the " UBS 2019-C17
Transaction "). This loan combination, including the Global Data Center
Mortgage Loan, is being serviced and administered pursuant to the pooling and
servicing agreement for the UBS 2019-C17 Transaction, which is incorporated by
reference as Exhibit 4.4 to this Annual Report on Form 10-K.

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

 Wells Fargo Bank, National
Association is the master servicer and certificate administrator of the
mortgage loans serviced under the Pooling and Servicing Agreement and the
primary servicer of The Tower at Burbank Mortgage Loan and the Global Data
Center 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 Tower at Burbank Mortgage Loan, the Grand Canal
Shoppes Mortgage Loan and the Global Data Center Mortgage Loan. As a
result, Wells Fargo Bank, National Association is a servicing function
participant in the capacities described above, because it is servicing mortgage
loans that constituted 5% or more of the assets of the issuing entity as of its
cut-off date. The assessments of compliance with applicable servicing criteria
and accountants' attestation reports delivered by Wells Fargo Bank, National
Association in the capacities described above are listed in the Exhibit Index.

 Rialto Capital Advisors, LLC is
the special servicer of the mortgage loans serviced under the Pooling and
Servicing Agreement and the Global Data Center 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.

 Midland Loan Services, a Division
of PNC Bank, National Association is the primary servicer of the Storage Post
Portfolio Mortgage Loan and the Grand Canal Shoppes Mortgage Loan. As a result,
Midland Loan Services, a Division of PNC Bank, National Association is a
"servicer" as defined in Item 1108(a)(2)(iii) of Regulation AB, in the
capacities described above, because it is servicing mortgage loans that
constituted 10% or more of the assets of the issuing entity as of its cut-off
date. The assessments of compliance with applicable servicing criteria,
accountants' attestation reports and servicer compliance statements delivered
by Midland Loan Services, a Division of PNC Bank, National Association in the
capacities described above are listed in the Exhibit Index.

 Wells Fargo Bank, National
Association acts as trustee of the Grand Canal Shoppes Mortgage Loan.
Pursuant to the pooling and servicing agreement for the MSC 2019-H7
Transaction, the trustee is required to provide an assessment of compliance
with applicable servicing criteria solely with respect to Item 1122(d)(2)(iii)
of Regulation AB (regarding advances of funds or guarantees regarding
collections, cash flows or distributions, and any interest or other fees
charged for such advances, are made, reviewed and approved as specified in the
transaction agreements). However, during the reporting period, the trustee did
not perform any servicing function with respect to the servicing criteria
specified in Item 1122(d)(2)(iii) of Regulation AB. The master servicer
or the special servicer, to the extent required, performed the servicing
function identified with respect to Item 1122(d)(2)(iii) of Regulation AB, and
each such party included Item 1122(d)(2)(iii) of Regulation AB in the
assessment of compliance with applicable servicing criteria and accountant's
attestation report for the subject transaction. As a result, this Annual
Report on Form 10-K does not include an assessment of compliance with
applicable servicing criteria of the trustee. One or more other servicers of
the Grand Canal Shoppes 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 Tower at Burbank Mortgage Loan and the Global Data
Center Mortgage Loan. Pursuant to the Pooling and Servicing Agreement,
the pooling and servicing agreement for the BANK 2019-BNK20 Transaction and the
pooling and servicing agreement for the UBS 2019-C17 Transaction, the trustee
is required to provide an assessment of compliance with applicable servicing
criteria solely with respect to Item 1122(d)(2)(iii) of Regulation AB
(regarding advances of funds or guarantees regarding collections, cash flows or
distributions, and any interest or other fees charged for such advances, are
made, reviewed and approved as specified in the transaction agreements).
However, during the reporting period, the trustee did not perform any servicing
function with respect to the servicing criteria specified in Item
1122(d)(2)(iii) of Regulation AB. The master servicer or the special
servicer, to the extent required, performed the servicing function identified
with respect to Item 1122(d)(2)(iii) of Regulation AB, and each such party
included Item 1122(d)(2)(iii) of Regulation AB in the assessment of compliance
with applicable servicing criteria and accountant's attestation report for the
subject transaction. As a result, this Annual Report on Form 10-K does
not include an assessment of compliance with applicable servicing criteria of
the trustee. One or more other servicers of the mortgage loans serviced under
the Pooling and Servicing Agreement, The Tower at Burbank Mortgage Loan and the
Global Data Center Mortgage Loan have delivered one or more assessments of
compliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

 This Annual Report on Form 10-K
includes assessments of compliance with applicable servicing criteria and
accountants' attestation reports from CoreLogic Solutions, LLC This
entity was engaged by the master servicer under the Pooling and Servicing
Agreement (except with respect to those mortgage
loans for which Midland Loan Services, a Division of PNC Bank, National
Association is the primary servicer) and the primary servicer of The
Tower at Burbank Mortgage Loan and the Global Data Center 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 Grand Canal Shoppes Mortgage Loan, The Tower at Burbank
Mortgage Loan and the Global Data Center 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 Grand Canal Shoppes Mortgage Loan, The Tower
at Burbank Mortgage Loan and the Global Data Center Mortgage Loan, (i) the
reports on assessment of compliance with servicing criteria and attestation
reports on assessment of compliance with servicing criteria of Situs Holdings,
LLC as special servicer of the Grand Canal Shoppes Mortgage Loan and Pentalpha
Surveillance LLC as operating advisor of the Grand Canal Shoppes Mortgage Loan
and the Global Data Center Mortgage Loan, listed on the Exhibit Index are
omitted from this Annual Report on Form 10-K as they are not required to be
included on this Annual Report on Form 10-K per Instruction 3 to Item 1122 of
Regulation AB because they are parties performing activities that address
servicing criteria relating to 5% or less of the assets of the issuing entity;
and (ii) the servicer compliance statements of Situs Holdings, LLC as special
servicer of the Grand Canal Shoppes Mortgage Loan and LNR Partners, LLC as
special servicer of The Tower at Burbank Mortgage Loan, listed on the Exhibit
Index are omitted from this Annual Report on Form 10-K as they are not required
by Item 1123 of Regulation AB to be included on this Annual Report on Form 10-K
because they are each an unaffiliated party that is not a "servicer" that meets
the criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

 Item 1. Business.

 Item 1A. Risk Factors.

 Item 1B. Unresolved Staff Comments.

 None.

 Item 1C. Cybersecurity.

 Item 2. Properties.

 Item 3. Legal Proceedings.

 Item 4. Mine Safety Disclosures.

 Item 5. Market for Registrant's Common Equity,
Related Stockholder Matters and Issuer Purchases of Equity Securities.

 Item 6.

 [Reserved]

 Item 7. Management's Discussion and Analysis of
Financial Condition and Results of Operations.

 Item 7A. Quantitative and Qualitative Disclosures
About Market Risk.

 Item 8. Financial Statements and Supplementary Data.

 Item 9. Changes in and Disagreements With
Accountants on Accounting and Financial Disclosure.

 Item 9A. Controls and Procedures.

 Item 9B. Other Information.

 None.

 Item 9C. Disclosure Regarding Foreign Jurisdictions
that Prevent Inspections.

 None.

 Item 10. Directors, Executive Officers and Corporate
Governance.

 Item 11. Executive Compensation.

 Item 12. Security Ownership of Certain Beneficial
Owners and Management and Related Stockholder Matters.

 Item 13. Certain Relationships and Related
Transactions, and Director Independence.

 Item 14. Principal Accountant Fees and Services.

 ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB

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

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

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

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

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

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

 Item 1117 of Regulation AB, Legal Proceedings.

 The registrant knows of no material
pending legal proceeding involving the trust or any party related to the trust,
other than routine litigation incidental to the duties of those respective
parties, and the following, with respect to Wells Fargo Bank, National
Association, as certificate administrator, 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 October 23, 2019 pursuant to Rule 424(b)(2).

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

 The reports on assessments of compliance with the servicing
criteria for asset-backed securities and related attestation reports on such
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).

 The reports on assessments of compliance with the servicing
criteria for asset-backed securities and related attestation reports on such
assessments of compliance with respect to the Grand Canal Shoppes Mortgage
Loan, which is being serviced and administered pursuant to the pooling and
servicing agreement for the MSC 2019-H7 Transaction, are attached hereto under
Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to the
pooling and servicing agreement for the MSC 2019-H7 Transaction incorporated by
reference as Exhibit 4.2 to this Annual Report on Form 10-K is a chart
identifying the entities participating in a servicing function for the MSC
2019-H7 Transaction responsible for each applicable servicing criteria set
forth in Item 1122(d).

 The reports on assessments of compliance with the servicing
criteria for asset-backed securities and related attestation reports on such
assessments of compliance with respect to The Tower at Burbank Mortgage Loan,
which is being serviced and administered pursuant to the pooling and servicing
agreement for the BANK 2019-BNK20 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-BNK20 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
2019-BNK20 Transaction responsible for each applicable servicing criteria set
forth in Item 1122(d).

 The reports on assessments of compliance with the servicing
criteria for asset-backed securities and related attestation reports on such
assessments of compliance with respect to the Global Data Center Mortgage Loan,
which is being serviced and administered pursuant to the pooling and servicing
agreement for the UBS 2019-C17 Transaction, are attached hereto under Item 15
to this Annual Report on Form 10-K. Attached as Exhibit Z to the pooling and
servicing agreement for the UBS 2019-C17 Transaction incorporated by reference
as Exhibit 4.4 to this Annual Report on Form 10-K is a chart identifying the
entities participating in a servicing function for the UBS 2019-C17 Transaction
responsible for each applicable servicing criteria set forth in Item 1122(d).

 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 October 1,
2019, by and among Banc of America Merrill Lynch Commercial Mortgage Inc., as
Depositor, Wells Fargo Bank, National Association, as Master Servicer, Rialto
Capital Advisors, LLC, as Special Servicer, Wells Fargo Bank, National
Association, as Certificate Administrator, Wilmington Trust, National
Association, as Trustee, and Park Bridge Lender Services LLC, as Operating
Advisor and Asset Representations Reviewer (filed as Exhibit 4.1 to the

 4.2
 Pooling and Servicing Agreement, dated as of July 1,
2019, by and among Morgan Stanley Capital I Inc., as Depositor, Midland Loan
Services, a Division of PNC Bank, National Association, as Master Servicer, LNR
Partners, LLC, as Special Servicer, Wells Fargo Bank, National Association, as
Certificate Administrator and Trustee, and Pentalpha Surveillance LLC, as
Operating Advisor and Asset Representations Reviewer (filed as Exhibit 4.3 to
the registrant's Current Report on Form 8-K filed on October 23, 2019 under

 4.3
 Pooling and Servicing Agreement, dated as of September 1,
2019, by and among Morgan Stanley Capital I Inc., as Depositor, Wells Fargo
Bank, National Association, as General Master Servicer, Midland Loan Services,
a Division of PNC Bank, National Association, as General Special Servicer,
National Cooperative Bank, N.A., as NCB Master Servicer and as NCB Special
Servicer, Wells Fargo Bank, National Association, as Certificate Administrator,
Wilmington Trust, National Association, as Trustee, and Park Bridge Lender
Services LLC, as Operating Advisor and Asset Representations Reviewer (filed as
Exhibit 4.2 to the registrant's Current Report on Form 8-K filed on October 23,
2019 under Commission File No. 333-228375-02 and incorporated by reference
herein).

 4.4
 Pooling and Servicing Agreement, dated as of October 1,
2019, by and among UBS Commercial Mortgage Securitization Corp., as Depositor,
Wells Fargo Bank, National Association, as Master Servicer, Rialto Capital
Advisors, LLC, as Special Servicer, Wells Fargo Bank, National Association, as
Certificate Administrator, Wilmington Trust, National Association, as Trustee,
and Pentalpha Surveillance LLC, as Operating Advisor and Asset Representations
Reviewer (filed as Exhibit 4.4 to the registrant's Current Report on Form 8-K
filed on October 23, 2019 under Commission File No. 333-228375-02 and
incorporated by reference herein).

 4.5
 Agreement Between Note Holders, dated as of September 16,
2019, 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, and Bank of America, N.A.,
as Initial Note A-3 Holder, and Bank of America, N.A., as Initial Note A-4
Holder, and Bank of America, N.A., as Initial Note A-5 Holder, and Bank of
America, N.A., as Initial Note A-6 Holder, and Bank of America, N.A., as
Initial Note A-7 Holder, and Bank of America, N.A., as Initial Note A-8 Holder,
and Bank of America, N.A., as Initial Note A-9 Holder, and Bank of America,
N.A., as Initial Note A-10 Holder (filed as Exhibit 4.5 to the registrant's
Current Report on Form 8-K filed on October 23, 2019 under Commission File No.
333-228375-02 and incorporated by reference herein).

 4.6
 Agreement Between Note Holders, dated as of October 23,
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, Bank of
America, National Association, as Initial Note A-4 Holder, Bank of America,
National Association, as Initial Note A-5 Holder, Bank of America, National
Association, as Initial Note A-6 Holder, and JPMorgan Chase Bank, National
Association, as Initial Note A-7 Holder (filed as Exhibit 4.6 to the

 4.7
 Agreement Between Note Holders, dated as of October 23,
2019, 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, and Morgan Stanley Mortgage Capital Holdings
LLC, as Initial Agent (filed as Exhibit 4.7 to the registrant's Current Report
on Form 8-K filed on October 23, 2019 under Commission File No. 333-228375-02
and incorporated by reference herein).

 4.8
 Agreement Between Note Holders, dated as of September 26,
A-1 Holder, Wells Fargo Bank, National Association, as Initial Note A-2 Holder,
and Wells Fargo Bank, National Association, as Initial Note A-3 Holder (filed
as Exhibit 4.8 to the registrant's Current Report on Form 8-K filed on October
23, 2019 under Commission File No. 333-228375-02 and incorporated by reference
herein).

 4.9
 Agreement Between Note Holders, dated as of August 22,
2019, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder, DBR
Investments Co. Limited, as Initial Note A-2 Holder, and Morgan Stanley
Mortgage Capital Holdings LLC, as Initial Agent (filed as Exhibit 4.9 to the

 4.10 Agreement Between Note Holders, dated as of October 23,
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, JPMorgan
Chase Bank, National Association, as Initial Note A-4 Holder, JPMorgan Chase
Bank, National Association, as Initial Note A-5 Holder, JPMorgan Chase Bank,
National Association, as Initial Note A-6 Holder, and JPMorgan Chase Bank,
National Association, as Initial Note A-7 Holder (filed as Exhibit 4.10 to the

 4.11 Agreement Between Note Holders, dated as of October 23,
2019, 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, and Morgan Stanley Mortgage Capital Holdings
LLC, as Initial Agent (filed as Exhibit 4.11 to the registrant's Current Report
on Form 8-K filed on October 23, 2019 under Commission File No. 333-228375-02
and incorporated by reference herein).

 4.12 Agreement Between Noteholders, dated as of July 3, 2019,
between Morgan Stanley Bank, N.A., as Note A-1 Holder, Wells Fargo Bank,
National Association, as Note A-2 Holder, JPMorgan Chase Bank, National
Association, as Note A-3 Holder, Goldman Sachs Bank USA, as Note A-4 Holder,
and CPPIB Credit Investments II Inc., as Note B Holder (filed as Exhibit 4.12
to the registrant's Current Report on Form 8-K filed on October 23, 2019 under

 4.13 Agreement Between Note Holders, dated as of October 15,
A-1 Holder, and Wells Fargo Bank, National Association, as Initial Note A-2
Holder (filed as Exhibit 4.14 to the registrant's Current Report on Form 8-K
filed on October 23, 2019 under Commission File No. 333-228375-02 and
incorporated by reference herein).

 4.14 Agreement Between Note Holders, dated as of October 15,
A-1 Holder, and Wells Fargo Bank, National Association, as Initial Note A-2
Holder (filed as Exhibit 4.15 to the registrant's Current Report on Form 8-K
filed on October 23, 2019 under Commission File No. 333-228375-02 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 Master
Servicer

 33.2

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

 33.4
Certificate Administrator

 33.5
Custodian

 33.6
Advisor

 33.7
Participant

 33.8
as Servicing Function Participant for the Certificate Administrator

 33.9
as Servicing Function Participant for the Custodian

 33.10
Servicer of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.1)

 33.11
of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.2)

 33.12
Wilmington Trust, National Association, as Trustee of the Park Tower at
Transbay Mortgage Loan (Omitted. See Explanatory Notes.)

 33.13
Custodian of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.5)

 33.14
 Park Bridge Lender Services LLC, as Operating Advisor
of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.6)

 33.15
Participant of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.7)

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

 33.17
Servicer of the 230 Park Avenue South Mortgage Loan (see Exhibit 33.1)

 33.18
of the 230 Park Avenue South Mortgage Loan (see Exhibit 33.2)

 33.19
Wilmington Trust, National Association, as Trustee of the 230 Park Avenue South

 33.20
Custodian of the 230 Park Avenue South Mortgage Loan (see Exhibit 33.5)

 33.21
Advisor of the 230 Park Avenue South Mortgage Loan (see Exhibit 33.6)

 33.22
Participant of the 230 Park Avenue South Mortgage Loan (see Exhibit 33.7)

 33.23

 33.24
National Association, as Primary Servicer of the Storage Post Portfolio
Mortgage Loan

 33.25
of the Storage Post Portfolio Mortgage Loan (see Exhibit 33.2)

 33.26
Wilmington Trust, National Association, as Trustee of the Storage Post
Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

 33.27
Custodian of the Storage Post Portfolio Mortgage Loan (see Exhibit 33.5)

 33.28
Advisor of the Storage Post Portfolio Mortgage Loan (see Exhibit 33.6)

 33.29
Participant of the Storage Post Portfolio Mortgage Loan (see Exhibit 33.7)

 33.30

 33.31
Servicer of the 105 East 17th Street Mortgage Loan (see Exhibit 33.1)

 33.32
of the 105 East 17th Street Mortgage Loan (see Exhibit 33.2)

 33.33
Wilmington Trust, National Association, as Trustee of the 105 East 17th Street

 33.34
Custodian of the 105 East 17th Street Mortgage Loan (see Exhibit 33.5)

 33.35
Advisor of the 105 East 17th Street Mortgage Loan (see Exhibit 33.6)

 33.36
Participant of the 105 East 17th Street Mortgage Loan (see Exhibit 33.7)

 33.37

 33.38
Servicer of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit
33.1)

 33.39
of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit 33.2)

 33.40
Wilmington Trust, National Association, as Trustee of the National Anchored
Retail Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

 33.41
Custodian of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit
33.5)

 33.42
Advisor of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit
33.6)

 33.43
Participant of the National Anchored Retail Portfolio Mortgage Loan (see
Exhibit 33.7)

 33.44

 33.45
 Wells Fargo Bank, National Association, as Primary Servicer
of the Tysons Tower Mortgage Loan (see Exhibit 33.1)

 33.46
of the Tysons Tower Mortgage Loan (see Exhibit 33.2)

 33.47
Wilmington Trust, National Association, as Trustee of the Tysons Tower Mortgage

 33.48
Custodian of the Tysons Tower Mortgage Loan (see Exhibit 33.5)

 33.49
Advisor of the Tysons Tower Mortgage Loan (see Exhibit 33.6)

 33.50
Participant of the Tysons Tower Mortgage Loan (see Exhibit 33.7)

 33.51

 33.52
Servicer of the Landing at Fancher Creek Mortgage Loan (see Exhibit 33.1)

 33.53
of the Landing at Fancher Creek Mortgage Loan (see Exhibit 33.2)

 33.54
Wilmington Trust, National Association, as Trustee of the Landing at Fancher
Creek Mortgage Loan (Omitted. See Explanatory Notes.)

 33.55
Custodian of the Landing at Fancher Creek Mortgage Loan (see Exhibit 33.5)

 33.56
Advisor of the Landing at Fancher Creek Mortgage Loan (see Exhibit 33.6)

 33.57
Participant of the Landing at Fancher Creek Mortgage Loan (see Exhibit 33.7)

 33.58

 33.59
National Association, as Primary Servicer of the Grand Canal Shoppes Mortgage
Loan (see Exhibit 33.24)

 33.60
Situs Holdings, LLC, as Special Servicer of the Grand Canal Shoppes Mortgage

 33.61
Wells Fargo Bank, National Association, as Trustee of the Grand Canal Shoppes

 33.62
Custodian of the Grand Canal Shoppes Mortgage Loan (see Exhibit 33.5)

 33.63
Pentalpha Surveillance LLC, as Operating Advisor of the Grand Canal Shoppes

 33.64

 33.65
Servicer of The Tower at Burbank Mortgage Loan (see Exhibit 33.1)

 33.66
 LNR Partners, LLC, as Special Servicer of The
Tower at Burbank Mortgage Loan

 33.67
Wilmington Trust, National Association, as Trustee of The Tower at Burbank Mortgage

 33.68
Custodian of The Tower at Burbank Mortgage Loan (see Exhibit 33.5)

 33.69
Advisor of The Tower at Burbank Mortgage Loan (see Exhibit 33.6)

 33.70
Participant of The Tower at Burbank Mortgage Loan (see Exhibit 33.7)

 33.71

 33.72
Servicer of the Global Data Center Mortgage Loan (see Exhibit 33.1)

 33.73
of the Global Data Center Mortgage Loan (see Exhibit 33.2)

 33.74
Wilmington Trust, National Association, as Trustee of the Global Data Center

 33.75
Custodian of the Global Data Center Mortgage Loan (see Exhibit 33.5)

 33.76
Pentalpha Surveillance LLC, as Operating Advisor of the Global Data Center

 33.77
Participant of the Global Data Center Mortgage Loan (see Exhibit 33.7)

 33.78

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

 34.1
 Wells Fargo Bank, National Association, as Master
Servicer

 34.2

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

 34.4
Certificate Administrator

 34.5
Custodian

 34.6
Advisor

 34.7
Participant

 34.8
as Servicing Function Participant for the Certificate Administrator

 34.9
as Servicing Function Participant for the Custodian

 34.10
Servicer of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.1)

 34.11
of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.2)

 34.12
Wilmington Trust, National Association, as Trustee of the Park Tower at
Transbay Mortgage Loan (Omitted. See Explanatory Notes.)

 34.13
Custodian of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.5)

 34.14
Advisor of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.6)

 34.15
Participant of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.7)

 34.16

 34.17
Servicer of the 230 Park Avenue South Mortgage Loan (see Exhibit 34.1)

 34.18
of the 230 Park Avenue South Mortgage Loan (see Exhibit 34.2)

 34.19
Wilmington Trust, National Association, as Trustee of the 230 Park Avenue South

 34.20
Custodian of the 230 Park Avenue South Mortgage Loan (see Exhibit 34.5)

 34.21
Advisor of the 230 Park Avenue South Mortgage Loan (see Exhibit 34.6)

 34.22
Participant of the 230 Park Avenue South Mortgage Loan (see Exhibit 34.7)

 34.23

 34.24
National Association, as Primary Servicer of the Storage Post Portfolio
Mortgage Loan

 34.25
of the Storage Post Portfolio Mortgage Loan (see Exhibit 34.2)

 34.26
Wilmington Trust, National Association, as Trustee of the Storage Post
Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

 34.27
Custodian of the Storage Post Portfolio Mortgage Loan (see Exhibit 34.5)

 34.28
Advisor of the Storage Post Portfolio Mortgage Loan (see Exhibit 34.6)

 34.29
 CoreLogic Solutions, LLC, as Servicing Function Participant
of the Storage Post Portfolio Mortgage Loan (see Exhibit 34.7)

 34.30

 34.31
Servicer of the 105 East 17th Street Mortgage Loan (see Exhibit 34.1)

 34.32
of the 105 East 17th Street Mortgage Loan (see Exhibit 34.2)

 34.33
Wilmington Trust, National Association, as Trustee of the 105 East 17th Street

 34.34
 Wells Fargo Bank, National Association, as Custodian
of the 105 East 17th Street Mortgage Loan (see Exhibit 34.5)

 34.35
Advisor of the 105 East 17th Street Mortgage Loan (see Exhibit 34.6)

 34.36
Participant of the 105 East 17th Street Mortgage Loan (see Exhibit 34.7)

 34.37

 34.38
Servicer of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit
34.1)

 34.39
of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit 34.2)

 34.40
Wilmington Trust, National Association, as Trustee of the National Anchored
Retail Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

 34.41
Custodian of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit
34.5)

 34.42
Advisor of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit
34.6)

 34.43
Participant of the National Anchored Retail Portfolio Mortgage Loan (see
Exhibit 34.7)

 34.44

 34.45
Servicer of the Tysons Tower Mortgage Loan (see Exhibit 34.1)

 34.46
of the Tysons Tower Mortgage Loan (see Exhibit 34.2)

 34.47
Wilmington Trust, National Association, as Trustee of the Tysons Tower Mortgage

 34.48
Custodian of the Tysons Tower Mortgage Loan (see Exhibit 34.5)

 34.49
Advisor of the Tysons Tower Mortgage Loan (see Exhibit 34.6)

 34.50
Participant of the Tysons Tower Mortgage Loan (see Exhibit 34.7)

 34.51

 34.52
Servicer of the Landing at Fancher Creek Mortgage Loan (see Exhibit 34.1)

 34.53
of the Landing at Fancher Creek Mortgage Loan (see Exhibit 34.2)

 34.54
Wilmington Trust, National Association, as Trustee of the Landing at Fancher
Creek Mortgage Loan (Omitted. See Explanatory Notes.)

 34.55
Custodian of the Landing at Fancher Creek Mortgage Loan (see Exhibit 34.5)

 34.56
Advisor of the Landing at Fancher Creek Mortgage Loan (see Exhibit 34.6)

 34.57
 CoreLogic Solutions, LLC, as Servicing Function Participant
of the Landing at Fancher Creek Mortgage Loan (see Exhibit 34.7)

 34.58

 34.59
National Association, as Primary Servicer of the Grand Canal Shoppes Mortgage
Loan (see Exhibit 34.24)

 34.60
Situs Holdings, LLC, as Special Servicer of the Grand Canal Shoppes Mortgage

 34.61
Wells Fargo Bank, National Association, as Trustee of the Grand Canal Shoppes

 34.62
Custodian of the Grand Canal Shoppes Mortgage Loan (see Exhibit 34.5)

 34.63
Pentalpha Surveillance LLC, as Operating Advisor of the Grand Canal Shoppes

 34.64

 34.65
Servicer of The Tower at Burbank Mortgage Loan (see Exhibit 34.1)

 34.66
 LNR Partners, LLC, as Special Servicer of The
Tower at Burbank Mortgage Loan

 34.67
Wilmington Trust, National Association, as Trustee of The Tower at Burbank

 34.68
Custodian of The Tower at Burbank Mortgage Loan (see Exhibit 34.5)

 34.69
Advisor of The Tower at Burbank Mortgage Loan (see Exhibit 34.6)

 34.70
Participant of The Tower at Burbank Mortgage Loan (see Exhibit 34.7)

 34.71

 34.72
Servicer of the Global Data Center Mortgage Loan (see Exhibit 34.1)

 34.73
of the Global Data Center Mortgage Loan (see Exhibit 34.2)

 34.74
Wilmington Trust, National Association, as Trustee of the Global Data Center

 34.75
Custodian of the Global Data Center Mortgage Loan (see Exhibit 34.5)

 34.76
Pentalpha Surveillance LLC, as Operating Advisor of the Global Data Center

 34.77
Participant of the Global Data Center Mortgage Loan (see Exhibit 34.7)

 34.78

Servicer compliance statements.

 35.1
 Wells Fargo Bank, National Association, as Master
Servicer

 35.2

 35.3
Certificate Administrator

 35.4
as Servicing Function Participant for the Certificate Administrator

 35.5
Servicer of the Park Tower at Transbay Mortgage Loan (see Exhibit 35.1)

 35.6
of the Park Tower at Transbay Mortgage Loan (see Exhibit 35.2)

 35.7
Servicer of the 230 Park Avenue South Mortgage Loan (see Exhibit 35.1)

 35.8
of the 230 Park Avenue South Mortgage Loan (see Exhibit 35.2)

 35.9
National Association, as Primary Servicer of the Storage Post Portfolio
Mortgage Loan

 35.10
of the Storage Post Portfolio Mortgage Loan (see Exhibit 35.2)

 35.11
Servicer of the 105 East 17th Street Mortgage Loan (see Exhibit 35.1)

 35.12
 Rialto Capital Advisors, LLC, as Special Servicer of
the 105 East 17th Street Mortgage Loan (see Exhibit 35.2)

 35.13
Servicer of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit
35.1)

 35.14
of the National Anchored Retail Portfolio Mortgage Loan (see Exhibit 35.2)

 35.15
Servicer of the Tysons Tower Mortgage Loan (see Exhibit 35.1)

 35.16
of the Tysons Tower Mortgage Loan (see Exhibit 35.2)

 35.17
Servicer of the Landing at Fancher Creek Mortgage Loan (see Exhibit 35.1)

 35.18
of the Landing at Fancher Creek Mortgage Loan (see Exhibit 35.2)

 35.19
National Association, as Primary Servicer of the Grand Canal Shoppes Mortgage
Loan (see Exhibit 35.9)

 35.20
Situs Holdings, LLC, as Special Servicer of the Grand Canal Shoppes Mortgage

 35.21
Servicer of The Tower at Burbank Mortgage Loan (see Exhibit 35.1)

 35.22
LNR Partners, LLC, as Special Servicer of The Tower at Burbank Mortgage Loan
(Omitted. See Explanatory Notes.)

 35.23
Servicer of the Global Data Center Mortgage Loan (see Exhibit 35.1)

 35.24
of the Global Data Center Mortgage Loan (see Exhibit 35.2)

 99.1
 Mortgage Loan Purchase Agreement, dated as of September
27, 2019, between Banc of America Merrill Lynch Commercial Mortgage Inc. and
Bank of America, National Association (filed as Exhibit 99.2 to the
Commission File No. 333-228375-02 and incorporated by reference herein)

 99.2
 Mortgage Loan Purchase Agreement, dated as of September
27, 2019, 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. 333-228375-02 and incorporated by reference herein)

 99.3
 Mortgage Loan Purchase Agreement, dated as of September
27, 2019, between Banc of America Merrill Lynch Commercial Mortgage Inc. and
Wells Fargo Bank, National Association (filed as Exhibit 99.3 to the
Commission File No. 333-228375-02 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 13, 2024


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: 333-206677-01

 Central Index Key Number of the issuing entity:
0001659329

 Wells Fargo Commercial Mortgage
Trust 2015-P2

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

 Central Index Key Number of the depositor: 0000850779

 Wells Fargo Commercial Mortgage
Securities, Inc.

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

 Central Index Key Number of the sponsor: 0000740906

 Wells Fargo Bank, National
Association

 Central Index Key Number of the sponsor: 0001634437

 Macquarie US Trading LLC

 d/b/a Principal
Commercial Capital

 Central Index Key Number of the sponsor: 0001541468

 Ladder Capital Finance LLC

 Central Index Key Number of the sponsor: 0001541001

 Citigroup Global Markets Realty
Corp.

 Central Index Key Number of the sponsor: 0001238163

 Soci t G n rale, New York Branch

 New York

 (State or other jurisdiction of

 incorporation or organization of

 the issuing entity)

 38-3984627

 38-3984628

 38-7143660

 (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:

 (704) 374-6161

 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 Exhibit Index describes
exhibits provided by certain parties (in their capacities indicated on the
Exhibit Index) with respect to the Harbor Pointe Apartments Mortgage Loan and
the Anchorage Marriott Downtown Mortgage Loan, which constituted approximately
5.0% and 3.8%, respectively, of the asset pool of the issuing entity as of its
cut-off date. The Harbor Pointe Apartments Mortgage Loan and the
Anchorage Marriott Downtown Mortgage Loan are each an asset of the issuing
entity and are each part of a loan combination that includes the Harbor Pointe
Apartments Mortgage Loan or the Anchorage Marriott Downtown Mortgage Loan and
one other pari passu loan, each of which is not an asset of the issuing
entity. The other pari passu portion of each loan combination was
securitized in the Citigroup Commercial Mortgage Trust 2015-GC35 transaction,
Commission File Number 333-189017-12 (the " CGCMT 2015-GC35 Transaction ").
These loan combinations, including the Harbor Pointe Apartments Mortgage Loan
and the Anchorage Marriott Downtown Mortgage Loan, are being serviced and
administered pursuant to the pooling and servicing agreement for the CGCMT
2015-GC35 Transaction, which is incorporated by reference as Exhibit 4.2 to
this Annual Report on Form 10-K.

 The Exhibit Index describes exhibits
provided by certain parties (in their capacities indicated on the Exhibit
Index) with respect to the Empire Mall Mortgage Loan, which constituted
approximately 7.5% of the asset pool of the issuing entity as of its cut-off
date. The Empire Mall Mortgage Loan is an asset of the issuing entity and
is part of a loan combination that includes the Empire Mall Mortgage Loan and
four other pari passu loans, which are not assets of the issuing entity.
This loan combination, including the Empire Mall Mortgage Loan, was serviced
under the Pooling and Servicing Agreement for the issuing entity prior to the
closing of the securitization of a pari passu portion of the Empire Mall
loan combination in the Citigroup Commercial Mortgage Trust 2016-P3
transaction, Commission File Number 333-207132-02 (the " CGCMT 2016-P3
Transaction "). After the closing of the CGCMT 2016-P3 Transaction on
April 13, 2016, this loan combination, including the Empire Mall Mortgage Loan
was, and will continue to be, serviced and administered pursuant to the pooling
and servicing agreement with respect to the CGCMT 2016-P3 Transaction, which is
incorporated by reference as Exhibit 4.3 to this Annual Report on Form 10-K.

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

 Wells Fargo Bank, National
Association is the master servicer and certificate administrator of the
mortgage loans serviced under the Pooling and Servicing Agreement and the
primary servicer of the Empire Mall 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.

 Park Bridge Lender Services LLC is
the operating advisor of the Empire Mall Mortgage Loan, the Harbor Pointe
Apartments Mortgage Loan and the Anchorage Marriott Downtown Mortgage
Loan. As a result, Park Bridge Lender Services LLC is a servicing
function participant in the capacities described above, because it is servicing
mortgage loans that constituted 5% or more of the assets of the issuing entity
as of its cut-off date. The assessments of compliance with applicable servicing
criteria and accountants' attestation reports delivered by Park Bridge Lender
Services LLC in the capacities described above are listed in the Exhibit Index.

 Midland
Loan Services, a Division of PNC Bank, National Association is the primary
servicer of the Harbor Pointe Apartments Mortgage Loan and the Anchorage
Marriott Downtown 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 Midland Loan Services, a Division of PNC
Bank, National Association and an accountants' attestation report pursuant to
Item 1122 of Regulation AB because Midland Loan Services, a Division of PNC
Bank, National Association 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 Midland Loan Services, a Division of PNC Bank, National
Association because Midland Loan Services, a Division of PNC Bank, National
Association is an unaffiliated servicer servicing less than 10% of pool assets.

 Greystone Servicing Company LLC
(as successor to C-III Asset Management LLC) is the special servicer of the
Empire Mall Mortgage Loan, the Harbor Pointe Apartments Mortgage Loan and the
Anchorage Marriott Downtown Mortgage Loan. As a result, Greystone Servicing
Company LLC (as successor to C-III Asset Management 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 Greystone Servicing Company LLC
(as successor to C-III Asset Management LLC) in the capacities described above
are listed in the Exhibit Index.

 Deutsche Bank Trust Company
Americas is the custodian of the Harbor Pointe Apartments Mortgage Loan and the
Anchorage Marriott Downtown Mortgage Loan. As a result, Deutsche Bank
Trust Company Americas 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 Deutsche Bank Trust Company Americas in the capacities
described above are listed in the Exhibit Index.

 Wilmington Trust, National
Association acts as trustee of the mortgage loans serviced under the Pooling
and Servicing Agreement and the Empire Mall Mortgage Loan. Pursuant to
the Pooling and Servicing Agreement and the pooling and servicing agreement for
the CGCMT 2016-P3 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 and the
Empire Mall 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 an assessment of compliance with applicable servicing criteria and an
accountant's attestation report from U.S. Bank National Association. This
entity was engaged by Citibank, N.A. as custodian of the Empire Mall Mortgage
Loan to perform certain custodial services. These custodial services are servicing
functions included within the servicing criteria set forth in Items
1122(d)(4)(i) and 1122(d)(4)(ii) of Regulation AB. Therefore, under the
principles-based definition of "servicer" set forth in Item 1101(j) or
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 assessments of compliance with applicable servicing criteria and
accountants' attestation reports from CoreLogic Solutions, LLC. This
entity was engaged by the master servicer under the Pooling and Servicing
Agreement (except with respect to those mortgage loans for which Principal Real
Investors, LLC is the primary servicer) and the primary servicer of the
Empire Mall 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 Harbor Pointe Apartments Mortgage Loan, the Anchorage
Marriott Downtown Mortgage Loan and the Empire Mall 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 Harbor Pointe
Apartments Mortgage Loan and the Anchorage Marriott Downtown Mortgage Loan,
the servicer compliance statements of Midland Loan Services, a Division of PNC
Bank, National Association, as primary servicer of the Harbor Pointe
Apartments Mortgage Loan and the Anchorage Marriott Downtown 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 it is 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 and custodian, and Deutsche Bank Trust Company
Americas, as trustee and custodian.

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

 Deutsche Bank Trust Company Americas
("DBTCA") and Deutsche Bank National Trust Company ("DBNTC") have been sued by
investors in civil litigation concerning their role as trustees of certain
residential mortgage-backed securities ("RMBS") trusts.

 On June 18, 2014, a group of investors, including funds
managed by Blackrock Advisors, LLC, PIMCO-Advisors, L.P., and others, filed an
action against DBNTC and DBTCA in New York State Supreme Court alleging that
DBNTC and DBTCA failed to perform purported duties, as trustees for 544
private-label RMBS trusts, to enforce breaches of representations and
warranties as to mortgage loans held by the trusts and to enforce breaches by
servicers of their mortgage loan servicing obligations for the trusts.
During the course of the litigation, plaintiffs dismissed the case from New
York State Supreme Court and refiled two separate cases, one in the U.S.
District Court for the Southern District of New York (the "BlackRock SDNY
Case") and the other in the Superior Court of California, Orange County (the
"BlackRock California Case"). Pursuant to a settlement among the parties,
the BlackRock SDNY Case was dismissed on December 6, 2018, and the BlackRock
California Case was dismissed on January 11, 2019.

 On September 27, 2017, DBTCA was added as a defendant to a
case brought by certain special purpose entities including Phoenix Light SF
Limited in the U.S. District Court for the Southern District of New York, in
which the plaintiffs previously alleged incorrectly that DBNTC served as
trustee for all 43 of the trusts at issue. On September 27, 2017,
plaintiffs filed a third amended complaint that names DBTCA as a defendant in addition
to DBNTC. DBTCA serves as trustee for one of the 43 trusts at
issue. DBNTC serves as trustee for the other 42 trusts at issue.
Plaintiffs' third amended complaint brings claims for violation of the U.S.
Trust Indenture Act of 1939 ("TIA"); breach of contract; breach of fiduciary
duty; negligence and gross negligence; violation of New York's Streit Act; and
breach of the covenant of good faith. However, in the third amended
complaint, plaintiffs acknowledge that, before DBTCA was added to the case, the
court dismissed plaintiffs' TIA Act claims, negligence and gross negligence
claims, Streit Act claims, claims for breach of the covenant of good faith, and
certain theories of plaintiffs' breach of contract claims, and plaintiffs only
include these claims to preserve any rights on appeal. Plaintiffs allege
damages of "hundreds of millions of dollars." On November 13, 2017, DBNTC
and DBTCA filed an answer to the third amended complaint. On December 7,
2018, DBNTC and DBTCA filed a motion for summary judgment. Also on
December 7, 2018, plaintiffs, jointly with Commerzbank AG (see description of
Commerzbank case below), filed a motion for partial summary judgment. On
October 27, 2021, DBNTC and DBTCA filed a supplemental motion for summary
judgment relating to plaintiffs' standing. On February 8, 2022, the court
issued an order in which it granted DBNTC and DBTCA's supplemental motion for
summary judgment, granted in part DBNTC and DBTCA's initial motion for summary
judgment, and denied plaintiffs' motion for partial summary judgment. As
a result of that order, all of plaintiffs' claims were dismissed with
prejudice. On April 26, 2023, the United States Court of Appeals for the Second
Circuit affirmed the court's summary judgment order.

 On November 30, 2017, DBTCA was added as a defendant to a
case brought by Commerzbank AG ("Commerzbank") in the U.S. District Court for
the Southern District of New York, in which Commerzbank previously alleged
incorrectly that DBNTC served as trustee for all 50 of the trusts at
issue. On November 30, 2017, Commerzbank filed a second amended complaint
that names DBTCA as a defendant in addition to DBNTC. DBTCA serves as
trustee for 1 of the 50 trusts at issue. DBNTC serves as trustee for the
other 49 trusts at issue. Commerzbank's second amended complaint brings
claims for violation of the TIA; breach of contract; breach of fiduciary duty;
negligence; violation of the Streit Act; and breach of the covenant of good
faith. However, in the second amended complaint, Commerzbank acknowledges
that, before DBTCA was added to the case, the court dismissed Commerzbank's TIA
claims for the trusts governed by pooling and servicing agreements, as well as
its Streit Act claims and claims for breach of the covenant of good faith, and
Commerzbank only includes these claims to preserve any rights on appeal.
The second amended complaint alleges that DBNTC and DBTCA caused Commerzbank to
suffer "hundreds of millions of dollars in losses," but the complaint does not
include a demand for money damages in a sum certain. On January 29, 2018,
DBNTC and DBTCA filed an answer to the second amended complaint. On
December 7, 2018, DBNTC and DBTCA filed a motion for summary judgment.
Also on December 7, 2018, Commerzbank, jointly with the Phoenix Light
plaintiffs, filed a motion for partial summary judgment. On February 8,
2022, the court issued an order in which it granted in part DBNTC and DBTCA's
motion for summary judgment and denied plaintiffs' motion for partial summary
judgment. As a result of that order, many of plaintiffs' claims and
theories were dismissed with prejudice. Discovery is ongoing.

 On December 30, 2015, IKB International, S.A. in Liquidation
and IKB Deutsche Industriebank A.G. (collectively, "IKB"), as an investor in 37
RMBS trusts, filed a summons with notice in the Supreme Court of the State of
New York, New York County, against DBNTC and DBTCA as trustees of the
trusts. On May 27, 2016, IKB served its complaint asserting claims for
breach of contract, breach of fiduciary duty, breach of duty to avoid conflicts
of interest, violation of the Streit Act, violation of the TIA, violation of
Regulation AB, and violation of Section 9 of the Uniform Commercial Code.
IKB alleges that DBNTC and DBTCA are liable for over U.S. $268 million in
damages. On October 5, 2016, DBNTC and DBTCA, together with several other
trustees defending lawsuits by IKB, filed a joint motion to dismiss. On
January 6, 2017 and June 20, 2017, IKB voluntarily dismissed with prejudice all
claims as to seven trusts. On January 27, 2021, the court granted in part
and denied in part DBNTC and DBTCA's motion to dismiss. The court granted
the motion to dismiss with respect to IKB's claims for violations of the Streit
Act, Regulation AB, and Section 9 of the Uniform Commercial Code, as well as
certain aspects of IKB's claims for breach of contract, breach of fiduciary
duty, and violation of the TIA. The court denied the remainder of the
motion to dismiss. IKB's remaining claims for breach of contract, breach
of fiduciary duty, breach of duty to avoid conflicts of interest, and violation
of the TIA will proceed. On May 10, 2021, DBNTC and DBTCA filed a notice
of appeal with the New York Supreme Court Appellate Division, First Department,
regarding certain aspects of the court's order on the motion to dismiss.
On May 20, 2021, IKB filed a notice of cross appeal with respect to other
aspects of that order. On August 30, 2022, the New York Supreme Court,
Appellate Division, First Department affirmed in part and reversed in part the
court's order on the motion to dismiss. After DBNTC and DBTCA appealed
the First Department's decision, on June 15, 2023, the New York Court of
Appeals reversed the First Department's decision in part, dismissing certain additional
contract claims, as well as IKB's claims for breach of fiduciary duty and
breach of duty to avoid conflicts of interest. On June 2, 2021, IKB filed
a motion for re-argument regarding certain aspects of the court's order on the
motion to dismiss, which the court denied on August 3, 2021. On May 13,
2021, DBNTC and DBTCA filed an answer to the complaint. On October 28,
2021, the parties filed a stipulation, voluntarily dismissing with prejudice
all claims as to seven additional trusts. On December 29, 2021, the
parties filed a stipulation, voluntarily dismissing with prejudice all claims
as to one additional trust. On April 22, 2022, the parties filed a
stipulation, voluntarily dismissing with prejudice all claims as to 17
certificates at issue, including all claims as to 5 trusts. On February
28, 2023, the parties filed a stipulation, voluntarily dismissing with
prejudice all claims as to two trusts, leaving 15 trusts at issue. On
November 21, 2023, the parties filed a stipulation, voluntarily dismissing with
prejudice all claims as to three trusts, leaving 12 trusts at issue.
Discovery is ongoing.

 It is DBTCA's belief that it has no pending legal proceedings
(including, based on DBTCA's present evaluation, the litigation disclosed in
the foregoing paragraphs) that would materially affect its ability to perform
its duties under the related servicing agreement for this transaction.

 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 December 23, 2015 pursuant to Rule 424(b)(2).

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

 The reports on assessments of compliance with the servicing
criteria for asset-backed securities and related attestation reports on such
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).

 The reports on assessments of compliance with the servicing
criteria for asset-backed securities and related attestation reports on such
assessments of compliance with respect to the Harbor Pointe Apartments Mortgage
Loan and the Anchorage Marriott Downtown Mortgage Loan, which are being
serviced and administered pursuant to the pooling and servicing agreement for
the CGCMT 2015-GC35 Transaction, are attached hereto under Item 15 to this
Annual Report on Form 10-K. Attached as Exhibit O to the pooling and servicing
agreement for the CGCMT 2015-GC35 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 CGCMT 2015-GC35
Transaction responsible for each applicable servicing criteria set forth in
Item 1122(d).

 The reports on assessments of compliance with the servicing
criteria for asset-backed securities and related attestation reports on such
assessments of compliance with respect to the Empire Mall Mortgage Loan, which
is being serviced and administered pursuant to the pooling and servicing
agreement for the CGCMT 2016-P3 Transaction, are attached hereto under Item 15
to this Annual Report on Form 10-K. Attached as Exhibit O to the pooling and
servicing agreement for the CGCMT 2016-P3 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 CGCMT 2016-P3
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 December 1, 2015, by and among Wells Fargo
Commercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, National
Association, as Master Servicer, C-III Asset Management LLC, as Special
Servicer, Wells Fargo Bank, National Association, as Certificate Administrator,
Wilmington Trust, National Association, as Trustee, and Pentalpha Surveillance
LLC, as Operating Advisor and Asset Representations Reviewer (filed as Exhibit
4.1 to the registrant's Current Report on Form 8-K/A filed on January 6, 2016
under Commission File No. 333-206677-01 and incorporated by reference herein).

 4.2
 Pooling
and Servicing Agreement, dated as of December 1, 2015, by and among Citigroup
Commercial Mortgage Securities Inc., as Depositor, Midland Loan Services, a
Division of PNC Bank, National Association, as Master Servicer, C-III Asset
Management LLC, as Special Servicer, Park Bridge Lender Services LLC, as
Operating Advisor, Deutsche Bank Trust Company Americas, as Trustee, and
Citibank, N.A., as Certificate Administrator (filed as Exhibit 4.2 to the

 4.3
 Pooling
and Servicing Agreement, dated as of April 1, 2016, by and among Citigroup
Commercial Mortgage Securities Inc., as Depositor, Wells Fargo Bank, National
Association, as Master Servicer, C-III Asset Management LLC, as Special
Servicer, Park Bridge Lender Services LLC, as Operating Advisor and Asset
Representations Reviewer, Wilmington Trust, National Association, as Trustee,
and Citibank, N.A., as Certificate Administrator (filed as Exhibit 4.1 to the
registrant's Current Report on Form 8-K filed on April 15, 2016 under

 4.4
 Co-Lender
Agreement, dated as of December 1, 2015, by and between Citigroup Global
Markets Realty Corp., as Initial Note A-1 Holder, and Citigroup Global Markets
Realty Corp., as Initial Note A-2 Holder (filed as Exhibit 4.4 to the

 4.5
 Co-Lender
Agreement, dated as of December 1, 2015, by and between Citigroup Global
Markets Realty Corp., as Initial Note A-1 Holder, and Citigroup Global Markets
Realty Corp., as Initial Note A-2 Holder (filed as Exhibit 4.5 to the

 4.6
 Co-Lender
Agreement, dated as of December 1, 2015, by and between Citigroup Global
Markets Realty Corp., as Initial Note A-1 Holder, and Citigroup Global Markets
Realty Corp., as Initial Note A-2 Holder (filed as Exhibit 4.7 to the

 4.7
 Co-Lender
Agreement, dated as of December 23, 2015, by and between Soci t G n rale, as
Initial Note A-1 Holder, Soci t G n rale, as Initial Note A-2 Holder, Soci t
G n rale, as Initial Note A-3 Holder, Soci t G n rale, as Initial Note A-4
Holder, and Soci t G n rale, as Initial Note A-5 Holder (filed as Exhibit 4.8
to the registrant's Current Report on Form 8-K filed on December 23, 2015 under

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

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

 33.1
 Wells Fargo Bank, National Association, as Master

 33.2
 Rialto Capital Advisors, LLC, as Special Servicer

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

 33.4
Certificate Administrator

 33.5
Custodian

 33.6
 Pentalpha Surveillance LLC, as Operating Advisor

 33.7
 CoreLogic Solutions, LLC, as Servicing Function
Participant

 33.8
 Principal Global Investors, LLC, as Primary

 33.9
as Servicing Function Participant for the Certificate Administrator

 33.10
as Servicing Function Participant for the Custodian

 33.11 Midland Loan Services, a Division of PNC Bank,
National Association, as Primary Servicer of the Harbor Pointe Apartments
Mortgage Loan

 33.12
C-III Asset Management LLC), as Special Servicer of the Harbor Pointe
Apartments Mortgage Loan

 33.13
 Deutsche Bank Trust Company Americas, as Trustee
and Custodian of the Harbor Pointe Apartments Mortgage Loan

 33.14
Advisor of the Harbor Pointe Apartments Mortgage Loan

 33.15
 Midland Loan Services, a Division of PNC Bank,
National Association, as Primary Servicer of the Anchorage Marriott Downtown
Mortgage Loan (see Exhibit 33.11)

 33.16
 Greystone Servicing Company LLC (as successor to C-III
Asset Management LLC), as Special Servicer of the Anchorage Marriott Downtown
Mortgage Loan (see Exhibit 33.12)

 33.17
 Deutsche Bank Trust Company Americas, as Trustee
and Custodian of the Anchorage Marriott Downtown Mortgage Loan (see Exhibit
33.13)

 33.18
Advisor of the Anchorage Marriott Downtown Mortgage Loan (see Exhibit 33.14)

 33.19
 Wells Fargo Bank, National Association, as Primary
Servicer of the Empire Mall Mortgage Loan (see Exhibit 33.1)

 33.20
C-III Asset Management LLC), as Special Servicer of the Empire Mall Mortgage Loan
(see Exhibit 33.12)

 33.21
Wilmington Trust, National Association, as Trustee of the Empire Mall Mortgage
Loan (Omitted. See Explanatory Notes.)

 33.22
 Citibank, N.A., as Custodian of the Empire Mall
Mortgage Loan

 33.23
Advisor of the Empire Mall Mortgage Loan (see Exhibit 33.14)

 33.24
 CoreLogic Solutions, LLC, as Servicing Function
Participant of the Empire Mall Mortgage Loan (see Exhibit 33.7)

 33.25
 U.S. Bank National Association, as Servicing
Function Participant of the Empire Mall Mortgage Loan

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

 34.1
 Wells Fargo Bank, National Association, as Master

 34.2
 Rialto Capital Advisors, LLC, as Special Servicer

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

 34.4
Certificate Administrator

 34.5
Custodian

 34.6
 Pentalpha Surveillance LLC, as Operating Advisor

 34.7
 CoreLogic Solutions, LLC, as Servicing Function
Participant

 34.8
 Principal Global Investors, LLC, as Primary Servicer

 34.9
as Servicing Function Participant for the Certificate Administrator

 34.10
as Servicing Function Participant for the Custodian

 34.11
 Midland Loan Services, a Division of PNC Bank,
National Association, as Primary Servicer of the Harbor Pointe Apartments
Mortgage Loan

 34.12
C-III Asset Management LLC), as Special Servicer of the Harbor Pointe
Apartments Mortgage Loan

 34.13
 Deutsche Bank Trust Company Americas, as Trustee
and Custodian of the Harbor Pointe Apartments Mortgage Loan

 34.14
Advisor of the Harbor Pointe Apartments Mortgage Loan

 34.15
 Midland Loan Services, a Division of PNC Bank,
National Association, as Primary Servicer of the Anchorage Marriott Downtown
Mortgage Loan (see Exhibit 34.11)

 34.16
C-III Asset Management LLC), as Special Servicer of the Anchorage Marriott
Downtown Mortgage Loan (see Exhibit 34.12)

 34.17
 Deutsche Bank Trust Company Americas, as Trustee
and Custodian of the Anchorage Marriott Downtown Mortgage Loan (see Exhibit
34.13)

 34.18
Advisor of the Anchorage Marriott Downtown Mortgage Loan (see Exhibit 34.14)

 34.19
 Wells Fargo Bank, National Association, as Primary
Servicer of the Empire Mall Mortgage Loan (see Exhibit 34.1)

 34.20
C-III Asset Management LLC), as Special Servicer of the Empire Mall Mortgage
Loan (see Exhibit 34.12)

 34.21
Wilmington Trust, National Association, as Trustee of the Empire Mall Mortgage
Loan (Omitted. See Explanatory Notes.)

 34.22
 Citibank, N.A., as Custodian of the Empire Mall
Mortgage Loan

 34.23
Advisor of the Empire Mall Mortgage Loan (see Exhibit 34.14)

 34.24
 CoreLogic Solutions, LLC, as Servicing Function
Participant of the Empire Mall Mortgage Loan (see Exhibit 34.7)

 34.25
 U.S. Bank National Association, as Servicing
Function Participant of the Empire Mall Mortgage Loan

Servicer compliance statements.

 35.1
 Wells Fargo Bank, National Association, as Master

 35.2
 Rialto Capital Advisors, LLC, as Special Servicer

 35.3
Certificate Administrator

 35.4
 Principal Global Investors, LLC, as Primary

 35.5
as Servicing Function Participant for the Certificate Administrator

 35.6
Midland Loan Services, a Division of PNC Bank, National Association, as Primary
Servicer of the Harbor Pointe Apartments Mortgage Loan (Omitted. See
Explanatory Notes.)

 35.7
C-III Asset Management LLC), as Special Servicer of the Harbor Pointe
Apartments Mortgage Loan

 35.8
Midland Loan Services, a Division of PNC Bank, National Association, as Primary
Servicer of the Anchorage Marriott Downtown Mortgage Loan (Omitted. See
Explanatory Notes.)

 35.9
C-III Asset Management LLC), as Special Servicer of the Anchorage Marriott
Downtown Mortgage Loan (see Exhibit 35.7)

 35.10
 Wells Fargo Bank, National Association, as Primary
Servicer of the Empire Mall Mortgage Loan (see Exhibit 35.1)

 35.11
C-III Asset Management LLC), as Special Servicer of the Empire Mall Mortgage
Loan (see Exhibit 35.7)

 99.1
Loan Purchase Agreement, dated as of December 8, 2015, between Wells Fargo
Commercial Mortgage Securities, Inc. and Wells Fargo Bank, National Association
(filed as Exhibit 99.4 to the registrant's Current Report on Form 8-K filed on
December 23, 2015 under Commission File No. 333-206677-01 and incorporated by
reference herein)

 99.2
Loan Purchase Agreement, dated as of December 8, 2015, between Wells Fargo
Commercial Mortgage Securities, Inc. and Macquarie US Trading LLC d/b/a
Principal Commercial Capital (filed as Exhibit 99.1 to the registrant's Current
Report on Form 8-K filed on December 23, 2015 under Commission File No.
333-206677-01 and incorporated by reference herein)

 99.3
Loan Purchase Agreement, dated as of December 8, 2015, among Wells Fargo
Commercial Mortgage Securities, Inc., Ladder Capital Finance LLC, Ladder Capital
Finance Holdings LLLP, Series REIT of Ladder Capital Finance Holdings LLLP, and
Series TRS of Ladder Capital Finance Holdings LLLP (filed as Exhibit 99.2 to
the registrant's Current Report on Form 8-K filed on December 23, 2015 under
Commission File No. 333-206677-01 and incorporated by reference herein)

 99.4
Loan Purchase Agreement, dated as of December 8, 2015, between Wells Fargo
Commercial Mortgage Securities, Inc. and Citigroup Global Markets Realty Corp
(filed as Exhibit 99.3 to the registrant's Current Report on Form 8-K filed on
December 23, 2015 under Commission File No. 333-206677-01 and incorporated by
reference herein)

 99.5
Loan Purchase Agreement, dated as of December 8, 2015, between Wells Fargo Commercial
Mortgage Securities, Inc. and Soci t G n rale (filed as Exhibit 99.5 to the
Commission File No. 333-206677-01 and incorporated by reference herein)

 99.6
 Sub-Servicing
Agreement, dated as of December 1, 2015, between Wells Fargo Bank, National
Association, as Master Servicer and Principal Global Investors, LLC, as
Sub-Servicer (filed as Exhibit 99.1 to the registrant's Current Report on Form
8-K/A filed on January 6, 2016 under Commission File No. 333-206677-01 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.

 Wells Fargo Commercial Mortgage
Securities, Inc.

(Depositor)

 /s/ Anthony
Sfarra

 Anthony
Sfarra, President

 (senior officer in charge of
securitization of the depositor)

 Date: March 13, 2024