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: 333-226850-04

 Central Index Key Number of the issuing entity:
0001790441

 BBCMS Mortgage Trust 2019-C5

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

 Central Index Key Number of the depositor: 0001541480

 Barclays Commercial Mortgage
Securities LLC

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

 Central Index Key Number of the sponsor: 0001549574

 Barclays Capital Real Estate Inc.

 Central Index Key Number of the sponsor: 0001089877

 KeyBank National Association

 Central Index Key Number of the sponsor: 0001542256

 Natixis Real Estate Capital LLC

 Central Index Key Number of the sponsor: 0001755531

 Societe Generale Financial
Corporation

 Central Index Key Number of the sponsor: 0001592182

 LMF Commercial, LLC

 (formerly known as Rialto
Mortgage Finance, LLC)

 Central Index Key Number of the sponsor: 0001722518

 BSPRT CMBS Finance, LLC

 New York

 (State or other jurisdiction of

 incorporation or organization of

 the issuing entity)

 38-4128798

 38-4128799

 38-7235613

 (I.R.S. Employer

 Identification Numbers)

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

 Wells Fargo Bank, National Association

 as Certificate Administrator

 9062 Old Annapolis Road

 Columbia, MD

 (Address of principal
executive offices of the issuing entity)

 21045

 (Zip Code)

 Registrant's telephone number,
including area code:

 (212) 412-4000

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

 Title of each class

 Trading Symbol(s)

 Name of each exchange on which registered

 None

 Securities registered pursuant to Section 12(g) of the
Act: None.

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

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

 Indicate by check mark whether the registrant (1) has filed
all reports required to be filed by Section 13 or 15(d) of the Securities
Exchange Act of 1934 during the preceding 12 months (or for such shorter period
that the registrant was required to file such reports), and (2) has been
subject to such filing requirements for the past 90 days. Yes o No

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

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

 Large accelerated
filer o
Accelerated filer
o

 Non-accelerated
filer
Smaller reporting
company
o

Emerging growth
company
o

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

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

 If securities are registered pursuant to Section 12(b) of the
Act, indicate by check mark whether the financial statements of the registrant
included in the filing reflect the correction of an error to previously issued
financial statements. o

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

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

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

 Indicate by check mark whether the registrant has filed all
documents and reports required to be filed by Section 12, 13 or 15(d) of the
Securities Exchange Act of 1934 subsequent to the distribution of securities
under a plan confirmed by a court. o
Yes o
No

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

 DOCUMENTS INCORPORATED BY REFERENCE

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

 EXPLANATORY NOTES

Exhibit Index) with respect to the NEMA San Francisco Mortgage Loan, which
constituted approximately 4.0% of the asset pool of the issuing entity as of
its cut-off date. The NEMA San Francisco Mortgage Loan is an asset of the
issuing entity and is part of a loan combination that includes the NEMA San
Francisco Mortgage Loan, three other pari passu loans and three
subordinate companion loans, which are not assets of the issuing entity. A pari
passu portion of the loan combination was securitized in the Natixis
Commercial Mortgage Securities Trust 2019-NEMA transaction (the " NCMS
2019-NEMA Transaction "). This loan combination, including the NEMA San
Francisco Mortgage Loan, is being serviced and administered pursuant to the
trust and servicing agreement for the NCMS 2019-NEMA Transaction, which is
incorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K.

Exhibit Index) with respect to the 10000 Santa Monica Boulevard Mortgage Loan,
which constituted approximately 3.5% of the asset pool of the issuing entity as
of its cut-off date. The 10000 Santa Monica Boulevard Mortgage Loan is an
asset of the issuing entity and is part of a loan combination that includes the
10000 Santa Monica Boulevard Mortgage Loan, seven other pari passu loans
and one subordinate companion loan, which are not assets of the issuing entity.
A pari passu portion of the loan combination was securitized in the
Natixis Commercial Mortgage Securities Trust 2019-10K transaction (the " NCMS
2019-10K Transaction "). This loan combination, including the 10000 Santa
Monica Boulevard Mortgage Loan, is being serviced and administered pursuant to
the trust and servicing agreement for the NCMS 2019-10K Transaction, which is
incorporated by reference as Exhibit 4.3 to this Annual Report on Form 10-K.

Exhibit Index) with respect to the Vanguard Portfolio Mortgage Loan, which
constituted approximately 0.5% of the asset pool of the issuing entity as of
its cut-off date. The Vanguard Portfolio Mortgage Loan is an asset of the
issuing entity and is part of a loan combination that includes the Vanguard
Portfolio Mortgage Loan, five 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 BBCMS Mortgage Trust
2019-C3 transaction, Commission File Number 333-226850-02 (the " BBCMS
2019-C3 Transaction "). This loan combination, including the Vanguard
Portfolio Mortgage Loan, is being serviced and administered pursuant to the
pooling and servicing agreement for the BBCMS 2019-C3 Transaction, which is
incorporated by reference as Exhibit 4.4 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 Moffett Towers II –
Buildings 3 & 4 Mortgage Loan, which constituted approximately 2.5% of the
asset pool of the issuing entity as of its cut-off date. The Moffett
Towers II – Buildings 3 & 4 Mortgage Loan is an asset of the issuing entity
and is part of a loan combination that includes the Moffett Towers II –
Buildings 3 & 4 Mortgage Loan, ten other pari passu loans and three
subordinate companion loans, which are not assets of the issuing entity. A pari
passu portion of the loan combination was securitized in the MFTII
2019-B3B4 Mortgage Trust transaction (the " MFTII 2019-B3B4 Transaction ").
This loan combination, including the Moffett Towers II – Buildings 3 & 4
Mortgage Loan, is being serviced and administered pursuant to the trust and
servicing agreement for the MFTII 2019-B3B4 Transaction, which is incorporated
by reference as Exhibit 4.5 to this Annual Report on Form 10-K.

Exhibit Index) with respect to the Uline Arena Mortgage Loan, which constituted
approximately 3.6% of the asset pool of the issuing entity as of its cut-off
date. The Uline Arena Mortgage Loan is an asset of the issuing entity and
is part of a loan combination that includes the Uline Arena Mortgage Loan and
five other pari passu loans, which are not assets of the issuing entity.
A pari passu portion of the loan combination was securitized in the CD
2019-CD8 Mortgage Trust transaction, Commission File Number 333-226943-03 (the
" CD 2019-CD8 Transaction "). This loan combination, including the Uline
Arena Mortgage Loan, is being serviced and administered pursuant to the pooling
and servicing agreement for the CD 2019-CD8 Transaction, which is incorporated
by reference as Exhibit 4.6 to this Annual Report on Form 10-K.

Exhibit Index) with respect to the Bison Portfolio Mortgage Loan, which
constituted approximately 2.0% of the asset pool of the issuing entity as of
its cut-off date. The Bison Portfolio Mortgage Loan is an asset of the
issuing entity and is part of a loan combination that includes the Bison
Portfolio Mortgage Loan and one other pari passu loan, which is not an
asset of the issuing entity. The other pari passu portion of the loan
combination was securitized in the CSAIL 2019-C17 Commercial Mortgage Trust
transaction, Commission File Number 333-227081-03 (the " CSAIL 2019-C17
Transaction "). This loan combination, including the Bison Portfolio
Mortgage Loan, is being serviced and administered pursuant to the pooling and
servicing agreement for the CSAIL 2019-C17 Transaction, which is incorporated
by reference as Exhibit 4.7 to this Annual Report on Form 10-K.

Exhibit Index) with respect to the Presidential City Mortgage Loan, which
constituted approximately 4.5% of the asset pool of the issuing entity as of
its cut-off date. The Presidential City Mortgage Loan is an asset of the
issuing entity and is part of a loan combination that includes the Presidential
City Mortgage Loan, two 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 SG Commercial Mortgage
Securities Trust 2019-PREZ transaction (the " SGCMS 2019-PREZ Transaction ").
This loan combination, including the Presidential City Mortgage Loan, is being
serviced and administered pursuant to the trust and servicing agreement for the
SGCMS 2019-PREZ Transaction, which is incorporated by reference as Exhibit 4.8
to this Annual Report on Form 10-K.

Exhibit Index) with respect to the GNL Office and Industrial Portfolio Mortgage
Loan, the Inland Life Storage Portfolio Mortgage Loan and the Ocean Edge Resort
& Golf Club Mortgage Loan, which constituted approximately 6.6%, 3.7% and
3.0%, respectively, of the asset pool of the issuing entity as of its cut-off
date. The GNL Office and Industrial Portfolio Mortgage Loan, the Inland
Life Storage Portfolio Mortgage Loan and the Ocean Edge Resort & Golf Club
Mortgage Loan are each an asset of the issuing entity and are each part of a
loan combination that includes (a) with respect to the GNL Office and
Industrial Portfolio Mortgage Loan, five other pari passu loans, which
are not assets of the issuing entity, (b) with respect to the Inland Life
Storage Portfolio Mortgage Loan, three other pari passu loans, which are
not assets of the issuing entity or (c) with respect to the Ocean Edge Resort
& Golf Club Mortgage Loan, one other pari passu loan, which is not
an asset of the issuing entity. A pari passu portion of each loan
combination was securitized in the CF 2019-CF2 Mortgage Trust transaction, Commission
File Number 333-228697-02 (the " CF 2019-CF2 Transaction "). These loan
combinations, including the GNL Office and Industrial Portfolio Mortgage Loan,
the Inland Life Storage Portfolio Mortgage Loan and the Ocean Edge Resort &
Golf Club Mortgage Loan, are being serviced and administered pursuant to the
pooling and servicing agreement for the CF 2019-CF2 Transaction, which is
incorporated by reference as Exhibit 4.9 to this Annual Report on Form 10-K.

Exhibit Index) with respect to the Ceasar's Bay Shopping Center Mortgage Loan
and the Equinix Data Center Mortgage Loan, which constituted approximately 4.2%
and 4.0%, respectively, of the asset pool of the issuing entity as of its
cut-off date. The Ceasar's Bay Shopping Center Mortgage Loan and the
Equinix Data Center Mortgage Loan are each an asset of the issuing entity and
are each part of a loan combination that includes (a) with respect to the
Ceasar's Bay Shopping Center Mortgage Loan, one other pari passu loan,
which is not an asset of the issuing entity or (b) with respect to the Equinix
Data Center Mortgage Loan, two other pari passu loans, which are not
assets of the issuing entity. A pari passu portion of each loan
combination was securitized in the Wells Fargo Commercial Mortgage Trust
2019-C53 transaction, Commission File Number 333-226486-09 (the " WFCM
2019-C53 Transaction "). These loan combinations, including the Ceasar's Bay
Shopping Center Mortgage Loan and the Equinix Data Center Mortgage Loan, are
being serviced and administered pursuant to the pooling and servicing agreement
for the WFCM 2019-C53 Transaction, which is incorporated by reference as
Exhibit 4.10 to this Annual Report on Form 10-K.

Exhibit Index) with respect to the NMR Pharmacy Portfolio Mortgage Loan, which
constituted approximately 1.4% of the asset pool of the issuing entity as of
its cut-off date. The NMR Pharmacy Portfolio Mortgage Loan is an asset of
the issuing entity and is part of a loan combination that includes the NMR
Pharmacy Portfolio Mortgage Loan and one other pari passu loan, which is
not an asset of the issuing entity. This loan combination, including the NMR
Pharmacy Portfolio Mortgage Loan, was serviced under the Pooling and Servicing
Agreement for the issuing entity prior to the closing of the securitization of
the other pari passu portion of the NMR Pharmacy Portfolio loan
combination in the Wells Fargo Commercial Mortgage Trust 2019-C54 transaction,
Commission File Number 333-226486-11 (the " WFCM 2019-C54 Transaction ").
After the closing of the WFCM 2019-C54 Transaction on December 3, 2019, this
loan combination, including the NMR Pharmacy Portfolio Mortgage Loan was, and
will continue to be, serviced and administered pursuant to the pooling and
servicing agreement with respect to the WFCM 2019-C54 Transaction, which is
incorporated by reference as Exhibit 4.11 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.

 KeyBank National Association is
the master servicer and special servicer of the mortgage loans serviced under
the Pooling and Servicing Agreement, the primary servicer of the GNL Office and
Industrial Portfolio Mortgage Loan, the Presidential City Mortgage Loan, the
NEMA San Francisco Mortgage Loan, the Inland Life Storage Portfolio Mortgage
Loan, the Ocean Edge Resort & Golf Club Mortgage Loan and the Moffett
Towers II – Buildings 3 & 4 Mortgage Loan and the primary servicer and
special servicer of the 10000 Santa Monica Boulevard Mortgage Loan. As a
result, KeyBank National Association is a "servicer" as defined in Item
1108(a)(2)(iii) of Regulation AB, in the capacities described above, because it
is servicing mortgage loans that constituted 10% or more of the assets of the
issuing entity as of its cut-off date. The assessments of compliance with
applicable servicing criteria, accountants' attestation reports and servicer
compliance statements delivered by KeyBank National Association in the
capacities described above are listed in the Exhibit Index.

 Wells Fargo Bank, National
Association is the certificate administrator of the mortgage loans serviced
under the Pooling and Servicing Agreement and the primary servicer of the
Ceasar's Bay Shopping Center Mortgage Loan, the Equinix Data Center Mortgage
Loan and the NMR Pharmacy Portfolio Mortgage Loan. As a result, Wells Fargo
Bank, National Association is a "servicer" as defined in Item 1108(a)(2)(iii)
of Regulation AB, in the capacities described above, because it is servicing
mortgage loans that constituted 10% or more of the assets of the issuing entity
as of its cut-off date. The assessments of compliance with applicable servicing
criteria, accountants' attestation reports and servicer compliance statements
delivered by Wells Fargo Bank, National Association in the capacities described
above are listed in the Exhibit Index.

 Wells Fargo Bank, National
Association is the custodian of the mortgage loans serviced under the Pooling
and Servicing Agreement, the Presidential City Mortgage Loan, the Ceasar's Bay
Shopping Center Mortgage Loan, the Equinix Data Center Mortgage Loan, the NEMA
San Francisco Mortgage Loan, the Uline Arena Mortgage Loan, the 10000 Santa
Monica Boulevard Mortgage Loan, the Moffett Towers II – Buildings 3 & 4
Mortgage Loan, the Bison Portfolio Mortgage Loan, the NMR Pharmacy Portfolio
Mortgage Loan and the Vanguard Portfolio Mortgage Loan. As a result,
Wells Fargo Bank, National Association is a servicing function participant in
the capacities described above, because it is servicing mortgage loans that
constituted 5% or more of the assets of the issuing entity as of its cut-off
date. The assessments of compliance with applicable servicing criteria and
accountants' attestation reports delivered by Wells Fargo Bank, National
Association in the capacities described above are listed in the Exhibit Index.

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

 Situs Holdings, LLC is the special
servicer of the Presidential City Mortgage Loan, the NEMA San Francisco
Mortgage Loan and the Moffett Towers II – Buildings 3 & 4 Mortgage Loan. As
a result, Situs Holdings, 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 Situs Holdings, LLC in the capacities
described above are listed in the Exhibit Index.

 Midland Loan Services, a Division
of PNC Bank, National Association is the special servicer of the Ceasar's Bay
Shopping Center Mortgage Loan and the Equinix Data Center Mortgage Loan, the
primary servicer of the Uline Arena Mortgage Loan and the Bison Portfolio
Mortgage Loan and the primary servicer and special servicer of the Vanguard
Portfolio Mortgage Loan, which constituted approximately 4.2%, 4.0%, 3.6%, 2.0%
and 0.5%, respectively, of the asset pool of the issuing entity as of its
cut-off date. In accordance with the Compliance and Disclosure Interpretations,
Section 200.03 (Rules 13a-18 and 15d-18, Servicer's Assessment of Compliance),
this percentage must be reduced pro rata because it was only acting as
special servicer of the Ceasar's Bay Shopping Center Mortgage Loan and the
Equinix Data Center Mortgage Loan from January 1, 2023 to April 23, 2023. As a
result, Midland Loan Services, a Division of PNC Bank, National Association is
an unaffiliated party that, as a result of such pro rata reduction of
such percentage, is not a "servicer" that meets the criteria in Item
1108(a)(2)(i) through (iii) of Regulation AB and so no servicer compliance
statement is required.

 LNR Partners, LLC is the special
servicer of the GNL Office and Industrial Portfolio Mortgage Loan, the Inland
Life Storage Portfolio Mortgage Loan, the Uline Arena Mortgage Loan and the
Ocean Edge Resort & Golf Club Mortgage Loan. As a result, LNR Partners, LLC
is a "servicer" as defined in Item 1108(a)(2)(iii) of Regulation AB, in the
capacities described above, because it is servicing mortgage loans that constituted
10% or more of the assets of the issuing entity as of its cut-off date. The
assessments of compliance with applicable servicing criteria, accountants'
attestation reports and servicer compliance statements delivered by LNR
Partners, LLC in the capacities described above are listed in the Exhibit
Index.

 Park Bridge Lender Services LLC is
the operating advisor of the GNL Office and Industrial Portfolio Mortgage Loan,
the Ceasar's Bay Shopping Center Mortgage Loan, the Equinix Data Center
Mortgage Loan, the Inland Life Storage Portfolio Mortgage Loan, the Uline Arena
Mortgage Loan, the Ocean Edge Resort & Golf Club Mortgage Loan, the Bison
Portfolio Mortgage Loan and the NMR Pharmacy Portfolio 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.

 Citibank, N.A. is the custodian of
the GNL Office and Industrial Portfolio Mortgage Loan, the Inland Life Storage
Portfolio Mortgage Loan and the Ocean Edge Resort & Golf Club Mortgage
Loan. As a result, Citibank, N.A. 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 Citibank, N.A. in the capacities
described above are listed in the Exhibit Index, and exclude the servicing
criteria set forth in Items 1122(d)(4)(i) and 1122(d)(4)(ii) of Regulation
AB, relating to the maintenance of collateral or security on pool assets
as required by the pooling and servicing agreement for the CF 2019-CF2 Transaction
and the safeguarding of pool assets and related documents as required by the
pooling and servicing agreement for the CF 2019-CF2 Transaction which servicing
criteria have been assessed by U.S. Bank National Association, as a servicing
function participant, as described below in these Explanatory Notes.

 K-Star Asset Management LLC is the
special servicer of the Ceasar's Bay Shopping Center Mortgage Loan on and after
April 24, 2023 and the Equinix Data Center Mortgage Loan on
and after April 24, 2023. 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 K-Star Asset
Management LLC and an accountants' attestation report pursuant to Item 1122 of
Regulation AB because K-Star Asset Management LLC is servicing more than 5% of
the pool assets. However, the Depositor is not required to include in
this Annual Report on Form 10-K a servicer compliance statement pursuant to
Item 1123 of Regulation AB of K-Star Asset Management LLC because K-Star Asset
Management LLC is an unaffiliated servicer servicing less than 10% of pool
assets.

 Wells Fargo Bank, National
Association acts as trustee of the mortgage loans serviced under the Pooling
and Servicing Agreement, the NEMA San Francisco Mortgage Loan, the 10000 Santa
Monica Boulevard Mortgage Loan, the Vanguard Portfolio Mortgage Loan, the
Moffett Towers II – Buildings 3 & 4 Mortgage Loan, the Uline Arena Mortgage
Loan, the Bison Portfolio Mortgage Loan and the Presidential City Mortgage
Loan. Pursuant to the Pooling and Servicing Agreement, the trust and
servicing agreement for the NCMS 2019-NEMA Transaction, the trust and servicing
agreement for the NCMS 2019-10K Transaction, the pooling and servicing
agreement for the BBCMS 2019-C3 Transaction, the trust and servicing agreement
for the MFTII 2019-B3B4 Transaction, the pooling and servicing agreement for
the CD 2019-CD8 Transaction, the pooling and servicing agreement for the CSAIL
2019-C17 Transaction and the trust and servicing agreement for the SGCMS
2019-PREZ 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 NEMA
San Francisco Mortgage Loan, the 10000 Santa Monica Boulevard Mortgage Loan,
the Vanguard Portfolio Mortgage Loan, the Moffett Towers II – Buildings 3 &
4 Mortgage Loan, the Uline Arena Mortgage Loan, the Bison Portfolio Mortgage
Loan and the Presidential City Mortgage Loan have delivered one or more
assessments of compliance with respect to Item 1122(d)(2)(iii) of Regulation
AB.

 Citibank, N.A. acts as trustee of
the GNL Office and Industrial Portfolio Mortgage Loan, the Inland Life Storage
Portfolio Mortgage Loan and the Ocean Edge Resort & Golf Club Mortgage
Loan. Pursuant to the pooling and servicing agreement for the CF 2019-CF2
Transaction, the trustee is required to provide an assessment of compliance
with applicable servicing criteria solely with respect to Item 1122(d)(2)(iii)
of Regulation AB (regarding advances of funds or guarantees regarding
collections, cash flows or distributions, and any interest or other fees
charged for such advances, are made, reviewed and approved as specified in the
transaction agreements). However, during the reporting period, the trustee did
not perform any servicing function with respect to the servicing criteria
specified in Item 1122(d)(2)(iii) of Regulation AB. The master servicer
or the special servicer, to the extent required, performed the servicing
function identified with respect to Item 1122(d)(2)(iii) of Regulation AB, and
each such party included Item 1122(d)(2)(iii) of Regulation AB in the assessment
of compliance with applicable servicing criteria and accountant's attestation
report for the subject transaction. As a result, this Annual Report on
Form 10-K does not include an assessment of compliance with applicable
servicing criteria of the trustee. One or more other servicers of the GNL
Office and Industrial Portfolio Mortgage Loan, the Inland Life Storage
Portfolio Mortgage Loan and the Ocean Edge Resort & Golf Club 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 Ceasar's Bay Shopping Center Mortgage Loan,
the Equinix Data Center Mortgage Loan and the NMR Pharmacy Portfolio Mortgage
Loan. Pursuant to the pooling and servicing agreement for the WFCM
2019-C53 Transaction and the pooling and servicing agreement for the WFCM
2019-C54 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 Ceasar's
Bay Shopping Center Mortgage Loan, the Equinix Data Center Mortgage Loan and
the NMR Pharmacy Portfolio Mortgage Loan have delivered one or more assessments
of compliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

 This Annual Report on Form 10-K
includes 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 trustee and custodian of the GNL
Office and Industrial Portfolio Mortgage Loan, the Inland Life Storage
Portfolio Mortgage Loan and the Ocean Edge Resort & Golf Club 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 primary servicer of the Ceasar's Bay Shopping Center
Mortgage Loan, the Equinix Data Center Mortgage Loan and the NMR Pharmacy
Portfolio 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 NEMA San
Francisco Mortgage Loan, the 10000 Santa Monica Boulevard Mortgage Loan, the
Vanguard Portfolio Mortgage Loan, the Moffett Towers II – Buildings 3 & 4
Mortgage Loan, the Uline Arena Mortgage Loan, the Bison Portfolio Mortgage
Loan, the Presidential City Mortgage Loan, the Ceasar's Bay Shopping Center
Mortgage Loan, the Equinix Data Center Mortgage Loan, the NMR Pharmacy
Portfolio Mortgage Loan, the GNL Office and Industrial Portfolio Mortgage Loan,
the Inland Life Storage Portfolio Mortgage Loan and the Ocean Edge Resort &
Golf Club 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 Vanguard Portfolio Mortgage Loan, the Uline
Arena Mortgage Loan, the Bison Portfolio Mortgage Loan, the Ceasar's Bay
Shopping Center Mortgage Loan, the Equinix Data Center Mortgage Loan and the
NMR Pharmacy Portfolio Mortgage Loan, (i) the reports on assessment of
compliance with servicing criteria and attestation reports on assessment of
compliance with servicing criteria of 3650 REIT Loan Servicing LLC as special
servicer of the Bison Portfolio Mortgage Loan and Argentic Services Company LP
as special servicer of the NMR Pharmacy Portfolio Mortgage Loan, listed on the
Exhibit Index are omitted from this Annual Report on Form 10-K as they are not
required to be included on this Annual Report on Form 10-K per Instruction 3 to
Item 1122 of Regulation AB because they are parties performing activities that
address servicing criteria relating to 5% or less of the assets of the issuing
entity; and (ii) the servicer compliance statements of 3650 REIT Loan Servicing
LLC as special servicer of the Bison Portfolio Mortgage Loan, K-Star Asset
Management LLC as special servicer of the Ceasar's Bay Shopping Center Mortgage
Loan on and after April 24, 2023 and the Equinix Data Center Mortgage Loan on
and after April 24, 2023 and Argentic Services Company LP as special servicer
of the NMR Pharmacy Portfolio Mortgage Loan, listed on the Exhibit Index are
omitted from this Annual Report on Form 10-K as they are not required by Item
1123 of Regulation AB to be included on this Annual Report on Form 10-K because
they are each an unaffiliated party that is not a "servicer" that meets the
criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB, and the servicer
compliance statement of Midland Loan Services, a Division of PNC Bank, National
Association as special servicer of the Ceasar's Bay Shopping Center Mortgage
Loan and the Equinix Data Center Mortgage Loan prior to April 24, 2023, primary
servicer of the Uline Arena Mortgage Loan and the Bison Portfolio Mortgage Loan
and primary servicer and special servicer of the Vanguard Portfolio Mortgage
Loan listed on the Exhibit Index is omitted from this Annual Report on Form
10-K for the reasons set forth in the Explanatory Notes above.

 Item 1. Business.

 Item 1A. Risk Factors.

 Item 1B. Unresolved Staff Comments.

 None.

 Item 1C. Cybersecurity.

 Item 2. Properties.

 Item 3. Legal Proceedings.

 Item 4. Mine Safety Disclosures.

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

 Item 6. [Reserved]

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

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

 Item 8. Financial Statements and Supplementary Data.

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

 Item 9A. Controls and Procedures.

 Item 9B. Other Information.

 None.

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

 None.

 Item 10. Directors, Executive Officers and Corporate
Governance.

 Item 11. Executive Compensation.

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

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

 Item 14. Principal Accountant Fees and Services.

 ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB

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

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

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

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

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

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

 Item 1117 of Regulation AB, Legal Proceedings.

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

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

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

 The information regarding this Item has been previously
provided in the prospectus of the Registrant relating to the issuing entity
filed on November 26, 2019 pursuant to Rule 424(b)(2).

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

assessments of compliance with respect to the mortgage loans are attached
hereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA
to the Pooling and Servicing Agreement incorporated by reference as Exhibit 4.1
to this Annual Report on Form 10-K is a chart identifying the entities
participating in a servicing function for the transaction responsible for each
applicable servicing criteria set forth in Item 1122(d).

assessments of compliance with respect to the NEMA San Francisco Mortgage Loan,
which is being serviced and administered pursuant to the trust and servicing agreement
for the NCMS 2019-NEMA Transaction, are attached hereto under Item 15 to this
Annual Report on Form 10-K. Attached as Exhibit K to the trust and servicing
agreement for the NCMS 2019-NEMA 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 NCMS 2019-NEMA
Transaction responsible for each applicable servicing criteria set forth in
Item 1122(d).

assessments of compliance with respect to the 10000 Santa Monica Boulevard
Mortgage Loan, which is being serviced and administered pursuant to the trust
and servicing agreement for the NCMS 2019-10K Transaction, are attached hereto
under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit K to the
trust and servicing agreement for the NCMS 2019-10K Transaction incorporated by
reference as Exhibit 4.3 to this Annual Report on Form 10-K is a chart
identifying the entities participating in a servicing function for the NCMS
2019-10K Transaction responsible for each applicable servicing criteria set
forth in Item 1122(d).

assessments of compliance with respect to the Vanguard Portfolio Mortgage Loan,
which is being serviced and administered pursuant to the pooling and servicing
agreement for the BBCMS 2019-C3 Transaction, are attached hereto under Item 15
to this Annual Report on Form 10-K. Attached as Exhibit AA to the pooling and
servicing agreement for the BBCMS 2019-C3 Transaction incorporated by reference
as Exhibit 4.4 to this Annual Report on Form 10-K is a chart identifying the
entities participating in a servicing function for the BBCMS 2019-C3
Transaction responsible for each applicable servicing criteria set forth in
Item 1122(d).

assessments of compliance with respect to the Moffett Towers II – Buildings 3
& 4 Mortgage Loan, which is being serviced and administered pursuant to the
trust and servicing agreement for the MFTII 2019-B3B4 Transaction, are attached
hereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit L
to the trust and servicing agreement for the MFTII 2019-B3B4 Transaction
incorporated by reference as Exhibit 4.5 to this Annual Report on Form 10-K is
a chart identifying the entities participating in a servicing function for the
MFTII 2019-B3B4 Transaction responsible for each applicable servicing criteria
set forth in Item 1122(d).

assessments of compliance with respect to the Uline Arena Mortgage Loan, which
is being serviced and administered pursuant to the pooling and servicing
agreement for the CD 2019-CD8 Transaction, are attached hereto under Item 15 to
this Annual Report on Form 10-K. Attached as Schedule II to the pooling and
servicing agreement for the CD 2019-CD8 Transaction incorporated by reference as
Exhibit 4.6 to this Annual Report on Form 10-K is a chart identifying the
entities participating in a servicing function for the CD 2019-CD8 Transaction
responsible for each applicable servicing criteria set forth in Item 1122(d).

assessments of compliance with respect to the Bison Portfolio Mortgage Loan,
which is being serviced and administered pursuant to the pooling and servicing
agreement for the CSAIL 2019-C17 Transaction, are attached hereto under Item 15
to this Annual Report on Form 10-K. Attached as Exhibit AA to the pooling and
servicing agreement for the CSAIL 2019-C17 Transaction incorporated by
reference as Exhibit 4.7 to this Annual Report on Form 10-K is a chart
identifying the entities participating in a servicing function for the CSAIL
2019-C17 Transaction responsible for each applicable servicing criteria set
forth in Item 1122(d).

assessments of compliance with respect to the Presidential City Mortgage Loan,
which is being serviced and administered pursuant to the trust and servicing
agreement for the SGCMS 2019-PREZ Transaction, are attached hereto under Item
15 to this Annual Report on Form 10-K. Attached as Exhibit L to the trust and
servicing agreement for the SGCMS 2019-PREZ Transaction incorporated by
reference as Exhibit 4.8 to this Annual Report on Form 10-K is a chart
identifying the entities participating in a servicing function for the SGCMS
2019-PREZ Transaction responsible for each applicable servicing criteria set
forth in Item 1122(d).

assessments of compliance with respect to the GNL Office and Industrial
Portfolio Mortgage Loan, the Inland Life Storage Portfolio Mortgage Loan and
the Ocean Edge Resort & Golf Club Mortgage Loan, which are being serviced
and administered pursuant to the pooling and servicing agreement for the CF
2019-CF2 Transaction, are attached hereto under Item 15 to this Annual Report
on Form 10-K. Attached as Schedule II to the pooling and servicing agreement
for the CF 2019-CF2 Transaction incorporated by reference as Exhibit 4.9 to
this Annual Report on Form 10-K is a chart identifying the entities
participating in a servicing function for the CF 2019-CF2 Transaction
responsible for each applicable servicing criteria set forth in Item 1122(d).

assessments of compliance with respect to the Ceasar's Bay Shopping Center
Mortgage Loan and the Equinix Data Center Mortgage Loan, which are being
serviced and administered pursuant to the pooling and servicing agreement for
the WFCM 2019-C53 Transaction, are attached hereto under Item 15 to this Annual
Report on Form 10-K. Attached as Exhibit AA to the pooling and servicing
agreement for the WFCM 2019-C53 Transaction incorporated by reference as
Exhibit 4.10 to this Annual Report on Form 10-K is a chart identifying the
entities participating in a servicing function for the WFCM 2019-C53
Transaction responsible for each applicable servicing criteria set forth in
Item 1122(d).

assessments of compliance with respect to the NMR Pharmacy Portfolio Mortgage
Loan, which is being serviced and administered pursuant to the pooling and
servicing agreement for the WFCM 2019-C54 Transaction, are attached hereto
under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to the
pooling and servicing agreement for the WFCM 2019-C54 Transaction incorporated
by reference as Exhibit 4.11 to this Annual Report on Form 10-K is a chart
identifying the entities participating in a servicing function for the WFCM
2019-C54 Transaction responsible for each applicable servicing criteria set
forth in Item 1122(d).

 Item 1123 of Regulation AB, Servicer Compliance Statement.

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

 Item 15. Exhibit and Financial Statement Schedules

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

 (1) Not applicable

 (2) Not applicable

 (3) See below

 4.1
 Pooling and Servicing Agreement, dated as of November 1,
2019, by and among Barclays Commercial Mortgage Securities LLC, as Depositor,
KeyBank National Association, as Master Servicer and as Special Servicer, Wells
Fargo Bank, National Association, as Certificate Administrator and as Trustee,
and Pentalpha Surveillance LLC, as Operating Advisor and as Asset Representations
Reviewer (filed as Exhibit 4.1 to the registrant's Current Report on Form 8-K
filed on November 26, 2019 under Commission File No. 333-226850-04 and

 4.2
 Trust and Servicing Agreement, dated as of March 29,
2019, by and among Natixis Commercial Mortgage Securities LLC, as Depositor,
KeyBank National Association, as Servicer, Situs Holdings, LLC, as Special
Servicer, and Wells Fargo Bank, National Association, as Trustee, Certificate
Administrator and Custodian (filed as Exhibit 4.5 to the registrant's Current
Report on Form 8-K filed on November 26, 2019 under Commission File No.
333-226850-04 and incorporated by reference herein).

 4.3
 Trust and Servicing Agreement, dated as of June 4, 2019,
by and among Natixis Commercial Mortgage Securities LLC, as Depositor, KeyBank
National Association, as Servicer, KeyBank National Association, as Special
Servicer, and Wells Fargo Bank, National Association, as Trustee and
Certificate Administrator (filed as Exhibit 4.7 to the registrant's Current
Report on Form 8-K filed on November 26, 2019 under Commission File No.
333-226850-04 and incorporated by reference herein).

 4.4
 Pooling and Servicing Agreement, dated as of June 1,
2019, by and among Barclays Commercial Mortgage Securities LLC, as Depositor,
Midland Loan Services, a Division of PNC Bank, National Association, as Master
Servicer, Midland Loan Services, a Division of PNC Bank, National Association,
as Special Servicer, Wells Fargo Bank, National Association, as Certificate
Administrator, Wells Fargo Bank, National Association, as Trustee, and
Pentalpha Surveillance LLC, as Operating Advisor and as Asset Representations
Reviewer (filed as Exhibit 4.10 to the registrant's Current Report on Form 8-K
filed on November 26, 2019 under Commission File No. 333-226850-04 and

 4.5
 Trust and Servicing Agreement, dated as of July 11, 2019,
by and among Barclays Commercial Mortgage Securities LLC, as Depositor, KeyBank
National Association, as Servicer, Situs Holdings, LLC, as Special Servicer,
and Wells Fargo Bank, National Association, as Certificate Administrator and
Trustee (filed as Exhibit 4.8 to the registrant's Current Report on Form 8-K
filed on November 26, 2019 under Commission File No. 333-226850-04 and

 4.6
 Pooling and Servicing Agreement, dated as of August 1,
2019, by and among Deutsche Mortgage & Asset Receiving Corporation, as
Depositor, Midland Loan Services, a Division of PNC Bank, National Association,
as Master Servicer, Midland Loan Services, a Division of PNC Bank, National
Association, as Special Servicer, Wells Fargo Bank, National Association, as
Trustee, Wells Fargo Bank, National Association, Certificate Administrator,
Paying Agent and Custodian, and Park Bridge Lender Services LLC, as Operating
Advisor and Asset Representations Reviewer (filed as Exhibit 4.6 to the

 4.7
 Pooling and Servicing Agreement, dated as of September 1,
2019, by and among Credit Suisse Commercial Mortgage Securities Corp., as
Depositor, Midland Loan Services, a Division of PNC Bank, National Association,
as Master Servicer and as Special Servicer, Wells Fargo Bank, National
Association, as Certificate Administrator and as Trustee, and Park Bridge
Lender Services LLC, as Operating Advisor and Asset Representations Reviewer
(filed as Exhibit 4.9 to the registrant's Current Report on Form 8-K filed on
November 26, 2019 under Commission File No. 333-226850-04 and incorporated by
reference herein).

 4.8
 Trust and Servicing Agreement, dated as of September 6,
2019, by and among SG Commercial Mortgage Securities, LLC, as Depositor,
KeyBank National Association, as Servicer, AEGON USA Realty Advisors, LLC, as
Special Servicer, Wells Fargo Bank, National Association, as Certificate
Administrator, Wells Fargo Bank, National Association, as Trustee (filed as
Exhibit 4.3 to the registrant's Current Report on Form 8-K filed on November
26, 2019 under Commission File No. 333-226850-04 and incorporated by reference
herein).

 4.9
 Pooling and Servicing Agreement, dated as of October 1,
2019, by and among CCRE Commercial Mortgage Securities, L.P., as Depositor,
KeyBank National Association, as Master Servicer, LNR Partners, LLC and KeyBank
National Association, each as a Special Servicer, Citibank, N.A., as Trustee,
Citibank, N.A., as Certificate Administrator, Paying Agent and Custodian, Park
Bridge Lender Services LLC, as Operating Advisor, and Park Bridge Lender
Services LLC, as Asset Representations Reviewer (filed as Exhibit 4.2 to the

 4.10
 Pooling and Servicing Agreement, dated as of November 1,
2019, by and among Wells Fargo Commercial Mortgage Securities, Inc., as
Depositor, Wells Fargo Bank, National Association, as Master Servicer, Midland
Loan Services, a Division of PNC Bank, National Association, as Special
Servicer, Wells Fargo Bank, National Association, as Certificate Administrator,
Wilmington Trust, National Association, as Trustee, and Park Bridge Lender
Services LLC, as Operating Advisor and Asset Representations Reviewer (filed as
Exhibit 4.4 to the registrant's Current Report on Form 8-K filed on November
26, 2019 under Commission File No. 333-226850-04 and incorporated by reference
herein).

 4.11
 Pooling and Servicing Agreement, dated as of December 1,
2019, by and among Wells Fargo Commercial Mortgage Securities, Inc., as
Depositor, Wells Fargo Bank, National Association, as Master Servicer, LNR
Partners, LLC, as Special Servicer, Wells Fargo Bank, National Association, as
Certificate Administrator, Wilmington Trust, National Association, as Trustee,
and Park Bridge Lender Services LLC, as Operating Advisor and as Asset Representations
Reviewer (filed as Exhibit 4.1 to the registrant's Current Report on Form 8-K
filed on December 4, 2019 under Commission File No. 333-226850-04 and

 4.12
 Agreement Between Noteholders, dated as of September 12,
2019, by and among KeyBank National Association, as Initial Note A-1 Holder and
KeyBank National Association, as Initial Note A-2, A-3, A-4, A-5, A-6, A-7 and
A-8 Holder (filed as Exhibit 4.11 to the registrant's Current Report on Form
8-K filed on November 26, 2019 under Commission File No. 333-226850-04 and

 4.13
 Agreement Between Noteholders, dated as of September 6,
2019, by and between Societe Generale Financial Corporation, as Initial Note
A-1A Holder, Societe Generale Financial Corporation, as Initial Note A-1B
Holder, Societe Generale Financial Corporation, as Initial Note A-1C Holder,
Societe Generale Financial Corporation, as Initial Note A-1D Holder, Societe
Generale Financial Corporation, as Initial Note A-1E Holder, Societe Generale
Financial Corporation, as Initial Note A-1F Holder and Societe Generale
Financial Corporation, as Initial Note B Holder (filed as Exhibit 4.12 to the

 4.14
 Agreement Between Note Holders, dated as of October 15,
2019, by and between Barclays Capital Real Estate Inc., as Initial Note A-1
Holder and Barclays Capital Real Estate Inc., as Initial Note A-2 Holder (filed
as Exhibit 4.13 to the registrant's Current Report on Form 8-K filed on
November 26, 2019 under Commission File No. 333-226850-04 and incorporated by
reference herein).

 4.15
 Co-Lender Agreement, dated as of March 27, 2019, by and
among Natixis Real Estate Capital LLC, as Note A-1 Holder, Natixis Real Estate
Capital LLC, as Note A-2 Holder, Natixis Real Estate Capital LLC, as Note A-3
Holder, Natixis Real Estate Capital LLC, as Note A-4 Holder, Natixis Real
Estate Capital LLC, as Note A-5 Holder, Natixis Real Estate Capital LLC, as
Note A-B Holder, Natixis Real Estate Capital LLC, as Note B-1 Holder and
Natixis Real Estate Capital LLC, as Note B-2 Holder (filed as Exhibit 4.14 to
the registrant's Current Report on Form 8-K filed on November 26, 2019 under

 4.16
 Co-Lender Agreement, dated as of September 20, 2019,
between Rialto Mortgage Finance, LLC, as Note A-1 Holder, Rialto Mortgage
Finance, LLC, as Note A-2 Holder, Rialto Mortgage Finance, LLC, as Note A-3
Holder and Rialto Mortgage Finance, LLC, as Note A-4 Holder (filed as Exhibit
4.15 to the registrant's Current Report on Form 8-K filed on November 26, 2019
under Commission File No. 333-226850-04 and incorporated by reference herein).

 4.17
 Agreement Between Note Holders, dated as of July 2, 2019,
by and between KeyBank National Association, as Initial Note A-1-A Holder,
Initial Note A-1-B Holder and Initial Note A-1-C Holder and Barclays Capital
Real Estate Inc., as Initial Note A-2-A Holder and Initial Note A-2-B Holder
(filed as Exhibit 4.16 to the registrant's Current Report on Form 8-K filed on
November 26, 2019 under Commission File No. 333-226850-04 and incorporated by
reference herein).

 4.18
 Agreement Between Noteholders, dated as of July 29, 2019,
by and among Cantor Commercial Real Estate Lending, L.P., as Initial Note A-1
Holder, Initial Note A-2 Holder, Initial Note A-3 Holder, Initial Note A-4
Holder and Initial Note A-5 Holder and Natixis Real Estate Capital LLC, as
Initial Note A-6 Holder and Initial Note A-7 Holder (filed as Exhibit 4.17 to
the registrant's Current Report on Form 8-K filed on November 26, 2019 under

 4.19
 Co-Lender Agreement, dated as of June 4, 2019, by and
among Natixis Real Estate Capital LLC, as Note A-1 Holder, Natixis Real Estate
Capital LLC, as Note A-2 Holder, Natixis Real Estate Capital LLC, as Note A-3
Holder, Natixis Real Estate Capital LLC, as Note A-4 Holder, Natixis Real
Estate Capital LLC, as Note A-5 Holder, Natixis Real Estate Capital LLC, as
Note A-6 Holder, Natixis Real Estate Capital LLC, as Note A-7 Holder and
Natixis Real Estate Capital LLC, as Note A-B Holder (filed as Exhibit 4.18 to
the registrant's Current Report on Form 8-K filed on November 26, 2019 under

 4.20
 Agreement Between Noteholders, dated as of September 6,
2019, by and among KeyBank National Association, as Initial Note A-1 Holder and
KeyBank National Association, as Initial Note A-2 Holder (filed as Exhibit 4.19
to the registrant's Current Report on Form 8-K filed on November 26, 2019 under

 4.21
 Co-Lender Agreement, dated as of July 11, 2019, by and
among Barclays Bank PLC, as Note A-1-A Holder and Note B-1 Holder, Barclays
Capital Real Estate Inc., as Initial Note A-1-B Holder, Initial Note A-1-D Holder
and Initial Note A-1-E Holder, Bank of America, N.A., as Note A-1-C Holder,
Deutsche Bank AG, New York Branch, as Initial Note A-2-A Holder, Initial Note
A-2-B Holder, Initial Note A-2-C Holder and Initial Note B-2 Holder and Goldman
Sachs Bank USA, as Initial Note A-3-A Holder, Initial Note A-3-B Holder,
Initial Note A-3-C Holder and Initial Note B-3 Holder (filed as Exhibit 4.20 to
the registrant's Current Report on Form 8-K filed on November 26, 2019 under

 4.22
 Agreement Between Note Holders, dated as of September 25,
2019, by and among Societe Generale Financial Corporation, as Initial Note A-1
Holder and Societe Generale Financial Corporation, as Initial Note A-2 Holder
(filed as Exhibit 4.21 to the registrant's Current Report on Form 8-K filed on
November 26, 2019 under Commission File No. 333-226850-04 and incorporated by
reference herein).

 4.23
 Co-Lender Agreement, dated as of November 26, 2019, by
and between BSPRT CMBS Finance, LLC, as Note A-1 Holder and BSPRT CMBS Finance,
LLC, as Note A-2 Holder (filed as Exhibit 4.22 to the registrant's Current
Report on Form 8-K filed on November 26, 2019 under Commission File No.
333-226850-04 and incorporated by reference herein).

 4.24
 Amended and Restated Co-Lender Agreement, dated as of
June 11, 2019, by and among Natixis Real Estate Capital LLC, as Note A-1
Holder, Natixis Real Estate Capital LLC, as Note A-2 Holder, Natixis Real
Estate Capital LLC, as Note A-3 Holder, Natixis Real Estate Capital LLC, as
Note A-4 Holder, Natixis Real Estate Capital LLC, as Note A-5 Holder, Natixis
Real Estate Capital LLC, as Note A-6 Holder and TCM CRE REIT LLC, as Note B
Holder (filed as Exhibit 4.23 to the registrant's Current Report on Form 8-K
filed on November 26, 2019 under Commission File No. 333-226850-04 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
 KeyBank National Association, as Master Servicer

 33.2
(see Exhibit 33.1)

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

 33.4
Custodian

 33.5
 Pentalpha Surveillance LLC, as Operating Advisor

 33.6
as Servicing Function Participant for the Certificate Administrator

 33.7
as Servicing Function Participant for the Custodian

 33.8
of the NEMA San Francisco Mortgage Loan (see Exhibit 33.1)

 33.9
NEMA San Francisco Mortgage Loan

 33.10
Wells Fargo Bank, National Association, as Trustee of the NEMA San Francisco

 33.11
Custodian of the NEMA San Francisco Mortgage Loan (see Exhibit 33.4)

 33.12
 Computershare Trust Company, National Association, as
Servicing Function Participant for the Custodian (see Exhibit 33.7)

 33.13
of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 33.1)

 33.14
of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 33.1)

 33.15
Wells Fargo Bank, National Association, as Trustee of the 10000 Santa Monica
Boulevard Mortgage Loan (Omitted. See Explanatory Notes.)

 33.16
Custodian of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 33.4)

 33.17

 33.18
National Association, as Primary Servicer of the Vanguard Portfolio Mortgage
Loan

 33.19
National Association, as Special Servicer of the Vanguard Portfolio Mortgage
Loan (see Exhibit 33.18)

 33.20
Wells Fargo Bank, National Association, as Trustee of the Vanguard Portfolio

 33.21
Custodian of the Vanguard Portfolio Mortgage Loan (see Exhibit 33.4)

 33.22
 Pentalpha Surveillance LLC, as Operating Advisor of
the Vanguard Portfolio Mortgage Loan (see Exhibit 33.5)

 33.23

 33.24
of the Moffett Towers II – Buildings 3 & 4 Mortgage Loan (see Exhibit 33.1)

 33.25
Moffett Towers II – Buildings 3 & 4 Mortgage Loan (see Exhibit 33.9)

 33.26
Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II –
Buildings 3 & 4 Mortgage Loan (Omitted. See Explanatory Notes.)

 33.27
Custodian of the Moffett Towers II – Buildings 3 & 4 Mortgage Loan (see
Exhibit 33.4)

 33.28

 33.29
National Association, as Primary Servicer of the Uline Arena Mortgage Loan (see
Exhibit 33.18)

 33.30
Uline Arena Mortgage Loan

 33.31
Wells Fargo Bank, National Association, as Trustee of the Uline Arena Mortgage
Loan (Omitted. See Explanatory Notes.)

 33.32
Custodian of the Uline Arena Mortgage Loan (see Exhibit 33.4)

 33.33
Advisor of the Uline Arena Mortgage Loan

 33.34

 33.35
 Midland Loan Services, a Division of PNC Bank, National
Association, as Primary Servicer of the Bison Portfolio Mortgage Loan (see
Exhibit 33.18)

 33.36
3650 REIT Loan Servicing LLC, as Special Servicer of the Bison Portfolio

 33.37
Wells Fargo Bank, National Association, as Trustee of the Bison Portfolio

 33.38
Custodian of the Bison Portfolio Mortgage Loan (see Exhibit 33.4)

 33.39
Advisor of the Bison Portfolio Mortgage Loan (see Exhibit 33.33)

 33.40

 33.41
of the Presidential City Mortgage Loan (see Exhibit 33.1)

 33.42
Presidential City Mortgage Loan (see Exhibit 33.9)

 33.43
Wells Fargo Bank, National Association, as Trustee of the Presidential City

 33.44
Custodian of the Presidential City Mortgage Loan (see Exhibit 33.4)

 33.45

 33.46
of the GNL Office and Industrial Portfolio Mortgage Loan (see Exhibit 33.1)

 33.47
 LNR Partners, LLC, as Special Servicer of the GNL
Office and Industrial Portfolio Mortgage Loan (see Exhibit 33.30)

 33.48
GNL Office and Industrial Portfolio Mortgage Loan

 33.49
Advisor of the GNL Office and Industrial Portfolio Mortgage Loan (see Exhibit
33.33)

 33.50
Function Participant of the GNL Office and Industrial Portfolio Mortgage Loan

 33.51
of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 33.1)

 33.52
Inland Life Storage Portfolio Mortgage Loan (see Exhibit 33.30)

 33.53
Inland Life Storage Portfolio Mortgage Loan (see Exhibit 33.48)

 33.54
Advisor of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 33.33)

 33.55
Function Participant of the Inland Life Storage Portfolio Mortgage Loan (see
Exhibit 33.50)

 33.56
of the Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit 33.1)

 33.57
Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit 33.30)

 33.58
Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit 33.48)

 33.59
Advisor of the Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit
33.33)

 33.60
Function Participant of the Ocean Edge Resort & Golf Club Mortgage Loan
(see Exhibit 33.50)

 33.61
Servicer of the Ceasar's Bay Shopping Center Mortgage Loan

 33.62
National Association, as Special Servicer of the Ceasar's Bay Shopping Center
Mortgage Loan prior to April 24, 2023 (see Exhibit 33.18)

 33.63
 K-Star Asset Management LLC, as Special Servicer
of the Ceasar's Bay Shopping Center Mortgage Loan on and after April 24, 2023

 33.64
Wilmington Trust, National Association, as Trustee of the Ceasar's Bay Shopping
Center Mortgage Loan (Omitted. See Explanatory Notes.)

 33.65
Custodian of the Ceasar's Bay Shopping Center Mortgage Loan (see Exhibit 33.4)

 33.66
Advisor of the Ceasar's Bay Shopping Center Mortgage Loan (see Exhibit 33.33)

 33.67
Participant of the Ceasar's Bay Shopping Center Mortgage Loan

 33.68

 33.69
Servicer of the Equinix Data Center Mortgage Loan (see Exhibit 33.61)

 33.70
National Association, as Special Servicer of the Equinix Data Center Mortgage
Loan prior to April 24, 2023 (see Exhibit 33.18)

 33.71
 K-Star Asset Management LLC, as Special Servicer
of the Equinix Data Center Mortgage Loan on and after April 24, 2023 (see
Exhibit 33.63)

 33.72
Wilmington Trust, National Association, as Trustee of the Equinix Data Center

 33.73
Custodian of the Equinix Data Center Mortgage Loan (see Exhibit 33.4)

 33.74
Advisor of the Equinix Data Center Mortgage Loan (see Exhibit 33.33)

 33.75
Participant of the Equinix Data Center Mortgage Loan (see Exhibit 33.67)

 33.76

 33.77
Servicer of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 33.61)

 33.78
Argentic Services Company LP, as Special Servicer of the NMR Pharmacy Portfolio

 33.79
Wilmington Trust, National Association, as Trustee of the NMR Pharmacy
Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

 33.80
 Wells Fargo Bank, National Association, as Custodian
of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 33.4)

 33.81
Advisor of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 33.33)

 33.82
Participant of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 33.67)

 33.83

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

 34.1
 KeyBank National Association, as Master Servicer

 34.2
(see Exhibit 34.1)

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

 34.4
Custodian

 34.5
 Pentalpha Surveillance LLC, as Operating Advisor

 34.6 Computershare Trust Company, National Association, as
Servicing Function Participant for the Certificate Administrator

 34.7
as Servicing Function Participant for the Custodian

 34.8
of the NEMA San Francisco Mortgage Loan (see Exhibit 34.1)

 34.9
NEMA San Francisco Mortgage Loan

 34.10
Wells Fargo Bank, National Association, as Trustee of the NEMA San Francisco

 34.11
Custodian of the NEMA San Francisco Mortgage Loan (see Exhibit 34.4)

 34.12
 Computershare Trust Company, National Association, as
Servicing Function Participant for the Custodian (see Exhibit 34.7)

 34.13
of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 34.1)

 34.14
 KeyBank National Association, as Special Servicer of
the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 34.1)

 34.15
Wells Fargo Bank, National Association, as Trustee of the 10000 Santa Monica
Boulevard Mortgage Loan (Omitted. See Explanatory Notes.)

 34.16
Custodian of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 34.4)

 34.17

 34.18
National Association, as Primary Servicer of the Vanguard Portfolio Mortgage
Loan

 34.19
National Association, as Special Servicer of the Vanguard Portfolio Mortgage
Loan (see Exhibit 34.18)

 34.20
Wells Fargo Bank, National Association, as Trustee of the Vanguard Portfolio

 34.21
Custodian of the Vanguard Portfolio Mortgage Loan (see Exhibit 34.4)

 34.22
 Pentalpha Surveillance LLC, as Operating Advisor of
the Vanguard Portfolio Mortgage Loan (see Exhibit 34.5)

 34.23

 34.24
of the Moffett Towers II – Buildings 3 & 4 Mortgage Loan (see Exhibit 34.1)

 34.25
Moffett Towers II – Buildings 3 & 4 Mortgage Loan (see Exhibit 34.9)

 34.26
Wells Fargo Bank, National Association, as Trustee of the Moffett Towers II –
Buildings 3 & 4 Mortgage Loan (Omitted. See Explanatory Notes.)

 34.27
Custodian of the Moffett Towers II – Buildings 3 & 4 Mortgage Loan (see
Exhibit 34.4)

 34.28

 34.29
National Association, as Primary Servicer of the Uline Arena Mortgage Loan (see
Exhibit 34.18)

 34.30
Uline Arena Mortgage Loan

 34.31
Wells Fargo Bank, National Association, as Trustee of the Uline Arena Mortgage
Loan (Omitted. See Explanatory Notes.)

 34.32
Custodian of the Uline Arena Mortgage Loan (see Exhibit 34.4)

 34.33
Advisor of the Uline Arena Mortgage Loan

 34.34

 34.35
National Association, as Primary Servicer of the Bison Portfolio Mortgage Loan
(see Exhibit 34.18)

 34.36
3650 REIT Loan Servicing LLC, as Special Servicer of the Bison Portfolio

 34.37
Wells Fargo Bank, National Association, as Trustee of the Bison Portfolio Mortgage
Loan (Omitted. See Explanatory Notes.)

 34.38
Custodian of the Bison Portfolio Mortgage Loan (see Exhibit 34.4)

 34.39
Advisor of the Bison Portfolio Mortgage Loan (see Exhibit 34.33)

 34.40

 34.41
of the Presidential City Mortgage Loan (see Exhibit 34.1)

 34.42
Presidential City Mortgage Loan (see Exhibit 34.9)

 34.43
Wells Fargo Bank, National Association, as Trustee of the Presidential City

 34.44
Custodian of the Presidential City Mortgage Loan (see Exhibit 34.4)

 34.45

 34.46
of the GNL Office and Industrial Portfolio Mortgage Loan (see Exhibit 34.1)

 34.47
 LNR Partners, LLC, as Special Servicer of the GNL
Office and Industrial Portfolio Mortgage Loan (see Exhibit 34.30)

 34.48
GNL Office and Industrial Portfolio Mortgage Loan

 34.49
Advisor of the GNL Office and Industrial Portfolio Mortgage Loan (see Exhibit
34.33)

 34.50
Function Participant of the GNL Office and Industrial Portfolio Mortgage Loan

 34.51
of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 34.1)

 34.52
Inland Life Storage Portfolio Mortgage Loan (see Exhibit 34.30)

 34.53
Inland Life Storage Portfolio Mortgage Loan (see Exhibit 34.48)

 34.54
Advisor of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 34.33)

 34.55
Function Participant of the Inland Life Storage Portfolio Mortgage Loan (see
Exhibit 34.50)

 34.56
of the Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit 34.1)

 34.57
Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit 34.30)

 34.58
Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit 34.48)

 34.59
Advisor of the Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit
34.33)

 34.60
Function Participant of the Ocean Edge Resort & Golf Club Mortgage Loan
(see Exhibit 34.50)

 34.61
Servicer of the Ceasar's Bay Shopping Center Mortgage Loan

 34.62
National Association, as Special Servicer of the Ceasar's Bay Shopping Center
Mortgage Loan prior to April 24, 2023 (see Exhibit 34.18)

 34.63
 K-Star Asset Management LLC, as Special Servicer
of the Ceasar's Bay Shopping Center Mortgage Loan on and after April 24, 2023

 34.64
Wilmington Trust, National Association, as Trustee of the Ceasar's Bay Shopping
Center Mortgage Loan (Omitted. See Explanatory Notes.)

 34.65
Custodian of the Ceasar's Bay Shopping Center Mortgage Loan (see Exhibit 34.4)

 34.66
Advisor of the Ceasar's Bay Shopping Center Mortgage Loan (see Exhibit 34.33)

 34.67
Participant of the Ceasar's Bay Shopping Center Mortgage Loan

 34.68

 34.69
Servicer of the Equinix Data Center Mortgage Loan (see Exhibit 34.61)

 34.70
National Association, as Special Servicer of the Equinix Data Center Mortgage
Loan prior to April 24, 2023 (see Exhibit 34.18)

 34.71
 K-Star Asset Management LLC, as Special Servicer
of the Equinix Data Center Mortgage Loan on and after April 24, 2023 (see
Exhibit 34.63)

 34.72
Wilmington Trust, National Association, as Trustee of the Equinix Data Center

 34.73
Custodian of the Equinix Data Center Mortgage Loan (see Exhibit 34.4)

 34.74
Advisor of the Equinix Data Center Mortgage Loan (see Exhibit 34.33)

 34.75
Participant of the Equinix Data Center Mortgage Loan (see Exhibit 34.67)

 34.76

 34.77
Servicer of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 34.61)

 34.78
Argentic Services Company LP, as Special Servicer of the NMR Pharmacy Portfolio

 34.79
Wilmington Trust, National Association, as Trustee of the NMR Pharmacy
Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

 34.80
Custodian of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 34.4)

 34.81
Advisor of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 34.33)

 34.82
Participant of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 34.67)

 34.83

Servicer compliance statements.

 35.1
 KeyBank National Association, as Master Servicer

 35.2
(see Exhibit 35.1)

 35.3
Certificate Administrator

 35.4
as Servicing Function Participant for the Certificate Administrator

 35.5
of the NEMA San Francisco Mortgage Loan (see Exhibit 35.1)

 35.6
NEMA San Francisco Mortgage Loan

 35.7
of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 35.1)

 35.8
of the 10000 Santa Monica Boulevard Mortgage Loan (see Exhibit 35.1)

 35.9
Midland Loan Services, a Division of PNC Bank, National Association, as Primary
Servicer of the Vanguard Portfolio Mortgage Loan (Omitted. See Explanatory

 35.10
Midland Loan Services, a Division of PNC Bank, National Association, as Special
Servicer of the Vanguard Portfolio Mortgage Loan (Omitted. See Explanatory

 35.11
of the Moffett Towers II – Buildings 3 & 4 Mortgage Loan (see Exhibit 35.1)

 35.12
Moffett Towers II – Buildings 3 & 4 Mortgage Loan (see Exhibit 35.6)

 35.13
Midland Loan Services, a Division of PNC Bank, National Association, as Primary
Servicer of the Uline Arena Mortgage Loan (Omitted. See Explanatory

 35.14
Uline Arena Mortgage Loan

 35.15
Midland Loan Services, a Division of PNC Bank, National Association, as Primary
Servicer of the Bison Portfolio Mortgage Loan (Omitted. See Explanatory

 35.16
3650 REIT Loan Servicing LLC, as Special Servicer of the Bison Portfolio Mortgage
Loan (Omitted. See Explanatory Notes.)

 35.17
of the Presidential City Mortgage Loan (see Exhibit 35.1)

 35.18
Presidential City Mortgage Loan (see Exhibit 35.6)

 35.19
of the GNL Office and Industrial Portfolio Mortgage Loan (see Exhibit 35.1)

 35.20
 LNR Partners, LLC, as Special Servicer of the GNL
Office and Industrial Portfolio Mortgage Loan (see Exhibit 35.14)

 35.21
of the Inland Life Storage Portfolio Mortgage Loan (see Exhibit 35.1)

 35.22
Inland Life Storage Portfolio Mortgage Loan (see Exhibit 35.14)

 35.23
of the Ocean Edge Resort & Golf Club Mortgage Loan (see Exhibit 35.1)

 35.24
 LNR Partners, LLC, as Special Servicer of the Ocean
Edge Resort & Golf Club Mortgage Loan (see Exhibit 35.14)

 35.25
Servicer of the Ceasar's Bay Shopping Center Mortgage Loan

 35.26
Midland Loan Services, a Division of PNC Bank, National Association, as Special
Servicer of the Ceasar's Bay Shopping Center Mortgage Loan prior to April 24,
2023 (Omitted. See Explanatory Notes.)

 35.27
K-Star Asset Management LLC, as Special Servicer of the Ceasar's Bay Shopping
Center Mortgage Loan on and after April 24, 2023 (Omitted. See Explanatory

 35.28
Servicer of the Equinix Data Center Mortgage Loan (see Exhibit 35.25)

 35.29
Midland Loan Services, a Division of PNC Bank, National Association, as Special
Servicer of the Equinix Data Center Mortgage Loan prior to April 24, 2023
(Omitted. See Explanatory Notes.)

 35.30
K-Star Asset Management LLC, as Special Servicer of the Equinix Data Center
Mortgage Loan on and after April 24, 2023 (Omitted. See Explanatory Notes.)

 35.31
Servicer of the NMR Pharmacy Portfolio Mortgage Loan (see Exhibit 35.25)

 35.32
Argentic Services Company LP, as Special Servicer of the NMR Pharmacy Portfolio

 99.1
2019, among Barclays Capital Real Estate Inc., Barclays Capital Holdings Inc. and
Barclays Commercial Mortgage Securities LLC (filed as Exhibit 99.1 to the

 99.2
2019, between KeyBank National Association and Barclays Commercial Mortgage
Securities LLC (filed as Exhibit 99.2 to the registrant's Current Report on
Form 8-K filed on November 26, 2019 under Commission File No. 333-226850-04 and

 99.3
2019, between Natixis Real Estate Capital LLC and Barclays Commercial Mortgage
Securities LLC (filed as Exhibit 99.3 to the registrant's Current Report on
Form 8-K filed on November 26, 2019 under Commission File No. 333-226850-04 and

 99.4
2019, among Societe Generale Financial Corporation, Soci t G n rale and
Barclays Commercial Mortgage Securities LLC (filed as Exhibit 99.4 to the

 99.5
2019, between Rialto Mortgage Finance, LLC and Barclays Commercial Mortgage
Securities LLC (filed as Exhibit 99.5 to the registrant's Current Report on
Form 8-K filed on November 26, 2019 under Commission File No. 333-226850-04 and

 99.6
2019, among BSPRT CMBS Finance, LLC, Benefit Street Partners Realty Trust, Inc.
and Barclays Commercial Mortgage Securities LLC (filed as Exhibit 99.6 to the

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

 (c) Not Applicable.

 SIGNATURES

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

 Barclays Commercial Mortgage
Securities LLC

(Depositor)

 /s/ Daniel
Vinson

 Daniel
Vinson, Chief Executive Officer

 (senior officer in charge of
securitization of the depositor)

 Date: March 15, 2024