S&P Global Ratings assigns servicer evaluations rankings across various industries and underlying collateral types. These rankings provide investors, lenders, and other market participants with insight into the capabilities of the servicers that manage their portfolios. They also serve as a useful tool for servicers, enabling them to identify operational strengths and weaknesses, performance opportunities, and benchmarking against applicable peers and industry standards.

The analytical approach applied reflects our comprehensive assessment of a servicer's operational capabilities, accompanied by a financial position assessment. We consider, among other factors, an organization's operating history and market position, management experience, control environment, staffing and training, systems and technology, key asset administration functions, and compliance with applicable laws, regulations, and industry standards to derive an overall ranking.

S&P Global Ratings also assigns rankings to trustees and common representatives in certain regions. See appendix for further discussion on the analytical approach for assigning these rankings.

The Servicer Ranking Process

We assign rankings to express our overall opinion of a servicer's key strengths and weaknesses and overall performance compared to its applicable peers and industry standards. We assess and assign subrankings in two key areas: "management and organization" and "loan/asset administration." Overall rankings also include a ranking outlook, in most cases, to report our opinion on the potential direction of the ranking over the intermediate term (typically six months to two years), or alternatively may include a RankingWatch placement. We also assess a servicer's financial position.

Ranking classifications by asset type

We assign rankings for servicers of loans, mortgages, receivables, leases, and other assets. The following are some examples of different servicer classifications and ranking categories.

Asset-backed classifications 

• Consumer finance. This category comprises performing and nonperforming credit cards, tax liens, installment loans, manufactured housing, auto loans and leases, unsecured loans, student loans, and other types of consumer receivables or repossessed assets.
• Commercial finance. This category comprises performing and nonperforming equipment leases, franchise businesses, small business commercial loans, small balance commercial loans, aircraft and aviation leases, business-based loans, and other types of commercial receivables or repossessed assets.

Commercial mortgage loan classifications 

• Commercial mortgage. This category comprises performing and nonperforming commercial and multifamily mortgage loans, and other types of debt secured by commercial real estate, held by a variety of investor types, including, but not limited to, commercial mortgage-backed securities (CMBS), government sponsored enterprises (GSEs), commercial real estate collateralized debt obligations (CRE-CDOs), commercial real estate collateralized loan obligations (CRE-CLOs), life insurance companies, balance sheet lenders, conduit originators, investment funds, and real estate investment trusts (REITs).

Residential mortgage loan classifications 

• Residential mortgage. This category comprises performing and nonperforming residential mortgage loans and other types of debt secured by residential real estate held by a variety of investor types, including, but not limited to, residential mortgage-backed securities (RMBS), government-sponsored enterprises (GSEs), Federal Housing Administration, and Ginnie Mae.

Ranking categories and ranking levels

Rankings are also categorized, depending on the particular role the servicer performs and the class or classes of assets or receivables the servicer is servicing. These categories include the following:

• Primary servicers. These servicers typically perform the loan administration duties for performing loans that involve direct borrower contact, with or without advancing responsibilities.
• Master servicers. These servicers typically address those skill sets required to appropriately monitor loans serviced by other servicers, also known as a subservicing portfolio. The master servicer typically does not have direct borrower contact but rather oversees the quality of information provided by its subservicers to ensure accurate investor reporting and compliance with servicing agreements and regulatory requirements.
• Special servicers. These servicers have expertise in handling assets that are nonperforming (e.g., monetary default), have covenant issues (e.g., nonmonetary default), or are repossessed. Special servicers may also handle other credit sensitive matters pertaining to performing commercial mortgage loans.
• Subprime servicers. These servicers perform primary servicing for residential borrowers with nonprime credit characteristics.
• Subordinate-lien servicers. These servicers perform primary servicing for residential home equity lines of credit, closed-end, or second-lien products and loans with high loan-to-value ratios.

We may assign rankings in other categories, depending on the class or classes of assets or receivables serviced, as well as their servicer function.

Ranking levels

S&P Global Ratings assigns subrankings of STRONG, ABOVE AVERAGE, AVERAGE, BELOW AVERAGE, or WEAK to each of two key areas: "management and organization" and "loan administration." We assign subrankings using the factors described below. We use the lower of the two subrankings to determine the overall ranking for each servicer category (see table 1).

Table 1

Subranking And Ranking Levels
Subranking/ranking	Definition
STRONG	The servicer demonstrates what we consider to be the highest ability, efficiency, and competence in managing large and often diverse asset portfolios, as well as a proven track record of strong and stable management, performance that meets regulatory standards and exceeds industry averages, state-of-the-art computer technology, and excellent internal controls, policies, and procedures.
ABOVE AVERAGE	The servicer demonstrates what we consider to be very high ability, efficiency, and competence in managing medium- to large-size portfolios, as well as solid management experience, an acceptable track record, internal practices and policies that meet industry or regulatory standards, and a managed portfolio performance history similar to or better than industry averages.
AVERAGE	The servicer demonstrates what we consider to be an acceptable track record, internal practices and policies that meet industry or regulatory standards, and a managed portfolio performance history similar to industry averages.
BELOW AVERAGE	The servicer demonstrates what we consider to be a lack of ability, efficiency, or competence; an unfavorable track record; or below-standard internal controls or computer systems.
WEAK	The servicer demonstrates what we consider to be a poor servicing track record, evidenced by recurring losses and a serious lack of internal controls.

Ranking outlook categories

We also assign a ranking outlook to a servicer's overall ranking category to provide our view of the stability of the assigned ranking over the intermediate term (typically six months to two years). In determining a ranking outlook, we consider any changes in economic or fundamental business conditions. The ranking outlooks assigned are stable, positive, negative, or developing (see table 2). A ranking outlook is not necessarily a precursor of a ranking change or future RankingWatch action.

Table 2

Ranking Outlook Categories
Ranking outlook	Definition
Stable	The ranking is unlikely to change.
Positive	The ranking may be raised.
Negative	The ranking may be lowered.
Developing	The ranking may be raised, lowered, or remain unchanged.
N.M.	Not meaningful--occurs when a servicer ranking is placed on RankingWatch.

RankingWatch categories

We may also place each overall ranking category on RankingWatch to highlight the potential for a ranking change if there is an identifiable event we believe may have an impact on the servicer in the short-term, typically over the upcoming six months. Certain identifiable events that may trigger the RankingWatch action include, but are not limited to, a merger, sale, recapitalization, deterioration in operating conditions, regulatory matters, or other factors that may result in material changes in a servicer's operations.

A RankingWatch may be either positive, negative or developing (see table 3). In the event we place a ranking on RankingWatch, we would remove the prior ranking outlook until the RankingWatch is resolved. We generally seek to resolve the RankingWatch following our assessment of these events or material changes to determine the impact, if any, on our assigned rankings. We may also choose to maintain the RankingWatch placement if conditions that resulted in the RankingWatch placement are not resolved within six months. Notwithstanding the above, ranking changes may occur without the ranking(s) being first placed on RankingWatch.

Table 3

RankingWatch Categories
RankingWatch placement	Definition
Positive	The ranking may be raised.
Negative	The ranking may be lowered.
Developing	The ranking may be raised, lowered or affirmed.

Financial position

S&P Global Ratings assigns a financial position that can be either SUFFICIENT or INSUFFICIENT. This encompasses a review of current and historical audited financial statements, and typically includes financial projections, loan covenant compliance, along with any regulatory reporting, as required. We typically would assess the audited financial statements of the servicing entity (or, alternatively, we may assess the audited financial statements of a parent company or related entity that we expect will provide financial support) over the near term (typically at least 12 months).

How does the evaluation process work?

In broad terms, the servicer evaluations process involves the following steps:

• The servicer provides information relating to its servicing platform and operations to S&P Global Ratings for review, consistent with S&P Global Ratings' data requirements.
• We conduct an on-site operational review of the servicer.
• The primary analyst presents a recommendation for each servicer to an internal committee, based on an analysis of the full set of data and accompanying information. The internal committee assigns servicer subrankings, overall ranking(s), and a ranking outlook or RankingWatch placement, along with the financial position assessment.

S&P Global Ratings continues to monitor the servicer after assigning, modifying, or affirming the subrankings, overall ranking, ranking outlook, RankingWatch status, and financial position assessment, including gathering ongoing data from the servicer, assessing material company events, and participating in periodic on-site operational reviews to determine if any ranking changes are necessary. We also consider the timeliness of servicer responses and the accuracy of servicer data in our ongoing assessment.

Factors Considered For Assigning Subrankings And Rankings

Management and organization (M&O)

The M&O assessment focuses on the servicing organization's senior and middle-level managers and overall staff, coupled with the operational structure used to perform and monitor the various activities. We generally assess the areas listed below.

Company strategy

We review the company's operating history, including its number of years of experience servicing the asset type classification subject to our ranking. We also assess senior management's commitment to providing strategic direction to execute the company's business plan. We further consider, as applicable, parental support, strategic alliances, merger and acquisition activity, or intentions to exit from specific business lines and their anticipated impact on the servicers' operating capabilities. S&P Global Ratings also reviews the servicer's current and historical portfolio statistics to understand historical volume fluctuations, portfolio complexity, and management's plans for expansion (or contraction).

Organizational structure

We review the servicer's corporate ownership, internal governance, and operational structure. We expect servicers to design operational structures that support servicing requirements, the organization's growth and continuation, segregation of duties, and monitoring all aspects of performance. We also consider the strength of any corporate-level groups that may support the servicing organization, including compliance, human resources, information technology, and legal services, among other areas.

Staffing

We assess management and staff experience, including tenure within the company and experience within the industry, allowing for performance meeting generally accepted industry procedures, regulations, and efficiencies in performing servicing activities. We assess staff levels relative to the portfolio size to gauge staffing adequacy and efficiency. We examine employee turnover as an indicative measure of the stability and general management of a company. We expect a certain level of turnover to occur in any organization, but frequent rates of high turnover can be detrimental to performance, efficiency, and profitability, while excessively low turnover can indicate other issues.

Training

Training is a key indicator of a servicer's commitment to improving and maintaining staff knowledge of company procedures, industry techniques, and regulatory and compliance requirements. The method and level of training often depend primarily on two factors: the size of the company (based on number of employees) and the level of industry experience. We consider both formal and on-the-job training in our assessment. We also consider fundamental course work that develops technical knowledge, as well as soft skills training, which generally develop management and leadership skills, improve communication techniques, and enhance other nonservicing areas of training. We also consider the oversight of training, as we believe tracking completed courses is a measure of a company's attention to detail and helps guide an individual's personal development.

Systems and technology

We review the main servicing system, ancillary systems, databases, and system controls, along with security to determine how a company utilizes automation in addressing its servicing functions. Sophisticated technology with robust functionality can bring efficiencies to the servicing operations, which we view favorably. We consider investments in systems, including maintenance, development, and enhancement. We also evaluate a firm's disaster recovery and business continuity plans as components of a company's technology. We assess whether they are sufficiently documented, readily accessible to all staff, and provide for alternate work location(s) to support business continuity with a minimum staff level necessary to process daily transactions while the main facility is offline or other alternative long-term arrangements are evaluated or implemented. We consider best practices to include testing of system recovery and business continuity plans at least annually to ensure workability and recoverability of the operations. We also review how servicers manage cybersecurity risks, including employee awareness training and technology to detect and prevent phishing and other hacking attempts, cybersecurity insurance, and incident response plans, in the event of a breach.

Internal controls

We assess an organization's internal controls by examining the servicer's control environment, structure and design, processes and procedures, risk-management culture, and compliance with investor requirements, as well as external and internal regulations. Our assessment typically includes a review of the servicer's policies and procedures manual(s), along with the internal audit, quality assurance, and external audit reports.

Policies and procedures manual(s)  

We expect policies and procedures manuals to include written statements of policy, detailed instructions on how to perform a particular task's procedures, and references/exhibits to forms or computer input and output screens used to accomplish the relevant task. S&P Global Ratings believes well-structured manuals are a good source of training material for education and cross training of staff that promote consistency and adds to employee competence and business continuity in the event of turnover.

S&P Global Ratings analysts review the material for:

• Clarity of content, ease of understanding, and consistency of structure;
• Completeness in describing each operation or procedure;
• Compliance with, and explanation of, regulatory and industry standards and requirements; and
• Frequency and responsibility for reviews or updates.

Internal audit and quality assurance  

We typically review the work performed by the company or servicer's internal audit department. We consider it to be best practice for the internal audit function to report directly to the executive or board level to enhance its independence. We review these operational audit reports for the adequacy of the breadth and frequency of the audited areas, completeness of resulting reports, summary of findings, and management's response and implementation of corrective action. We also may consider any independent self-monitoring quality assurance or quality control programs, key performance indicators, and other control reports in our review.

External audits 

We typically review the results of work performed by external auditors, regulators, or other interested parties, as applicable, including assessments of compliance with its servicing agreements. Our assessment also considers the breadth and frequency of such audits.

We also assess a servicer's risk management culture, capability, and infrastructure to ensure compliance with legal and regulatory obligations, as applicable, including complaint management. This area's importance increases for sectors or jurisdictions with extensive legal or regulatory frameworks applicable to servicing functions.

Vendor management

We review key vendor management controls for vendor procurement, contracting, initial and ongoing due diligence, risk assessment, and management oversight of specific functions.

Other matters

We may also consider other matters, including whether the servicer maintains sufficient directors and officers, as well as errors and omissions insurance coverage, the existence of defensive servicing litigation, or any other matters that may affect the management of, or risks associated with, the servicer's operations.

Loan/Asset Administration

The assessment focuses on procedures employed after a loan or asset becomes part of the servicing portfolio. We generally assess the broad areas listed below, as applicable, depending on the servicer's asset class, region, and ranking category.

New loan boarding

We assess the procedures, accuracy, and timeliness of adding new loans onto the servicing system, including controls for testing correctness of all data fields, apprising the necessary party or parties of missing information, and instructing the borrower on their responsibilities. Levels of automated boarding relative to manual boarding are also considered.

Document tracking

We review the procedures for document tracking and steps in place to ensure lien perfection, check the completeness of information (loan file tracking versus document tracking) and storage procedures, and assess the effectiveness of the system used for monitoring and follow-up of missing documents.

Payment processing

We review the design of operations to ensure separation of duties and other appropriate controls exist regarding the movement of funds, examine whether cash balances are reconciled timely, and determine if suspense and aged open reconciling items are problematic. We expect cash to be received primarily via electronic transfer and that adequate cash controls and procedures exist for handling live checks. The level of process automation is also considered.

Property insurance

The insurance function typically provides collateral protection against fire, flood, earthquake, terrorism, and any other perils, depending on asset or collateral type. We look for acceptable procedures for monitoring property insurance policies, coverage levels, carrier ratings, force placed coverage, and loss draft claims, among other factors. We also consider the servicer's management and monitoring controls over any vendors involved in the insurance process.

Taxes

The servicer should maintain acceptable procedures and oversight for ensuring that collateral is not encumbered due to nonpayment of taxes for both escrowed and nonescrowed loans. This includes, but is not limited to, monitoring amounts due and paid, as well as acceptable tax escrow analysis procedures. We also consider the servicer's management and monitoring controls over any vendors involved in the tax process.

Investor/client reporting

We consider the servicer's ability to report on portfolio performance consistent with its servicing agreements. The investor/client reporting function should have proper segregation of duties among reporting, remittance, and reconciliation tasks to minimize risk associated with fraudulent activity. This includes proper bank account titling, appropriate investor reporting formats, timely and accurate payment remittances, separation of duties, and other appropriate controls. We view favorably those servicers that incorporate the investor/client reporting standards instituted by relevant industry organizations.

Advances

We review the procedures for servicer advancing and the recovery of delinquent principal, interest, tax, insurance, and other payments and advances, as applicable. Procedure manuals should outline advancing policies, levels of required authorization for advances, and a description of the recovery process. The servicing system should support automated advancing and recovery reporting with sufficient detail to track entries at the loan, investor, and general ledger levels.

Customer service

We assess whether the servicer has adequate procedures to satisfactorily address resolutions and maintain prompt response times to meet customer needs, while adhering to relevant regulatory and industry standards. We may also consider the suitability of technology used in borrower communications and the quality of contact that servicers have with customers.

Asset/borrower credit reviews

We review the practices for monitoring portfolio performance--mainly pertaining to commercial mortgage loans--and assess the process for commercial mortgage servicers' collection and review of property financial statements. Similarly, we review asset administration practices, including but not limited to property inspections and watchlist maintenance.

Early stage collections

We assess the servicer's policies for generating late notices and attempting borrower contact, beginning in the early stages of delinquency; and evaluate loan delinquency levels in relation to peers and applicable industry averages.

Default management

We assess the collection policies for loans and accounts that are not resolved during early stages of delinquency and review defaulted and delinquent portfolio performance relative to applicable peers.

Loss mitigation, loan recovery, and foreclosure management

We believe dual track efforts of loss mitigation and foreclosure can help mitigate losses or facilitate returning delinquent loans to a performing status where not prohibited by law or regulation. Some areas we may assess to evaluate the servicer's capabilities and efficiency include the following:

• The asset managers' and loss mitigation staff's experience levels;
• The servicer's track record and history of resolution activity, as well as the range of strategies utilized in mitigating losses;
• The control environment over the decision making and approval processes; and
• The timeliness of the servicers' resolution activity relative to applicable peers and governing regulatory requirements.

Real estate owned (REO) and repossessed assets management

A servicer's ability to manage and liquidate REO properties and repossessed assets consistent with generally accepted servicing standards is critical. We assess the experience levels of asset managers and loss mitigation staff that are responsible for the management and oversight of foreclosed and repossessed assets, and we examine the control environment for approving liquidation strategies. We may also assess the timeliness of sale, as well as the proceeds achieved relative to applicable peers, to evaluate the servicer's efficiency and effectiveness. We further review policies and procedures associated with managing or monitoring third parties involved in the management or liquidation process.

Other loan/asset administration considerations

We may also consider any other matters that may affect the administration and effectiveness of the servicer's operations, including the scale of the servicing platform and the diversity and complexity of the assets in the servicing portfolio. As applicable, we review policies and procedures associated with managing or monitoring third parties, including subservicers. Depending on the servicer classification and ranking category, we may also assess other servicing functions that are unique to certain industries, their underlying collateral, or other factors.

The Select Servicer List

S&P Global Ratings created the Select Servicer List to recognize those servicers that, in our opinion, are able to demonstrate the ability to meet and maintain at least a minimum servicing standard, while also generally having appropriate financial resources for the near term to continue servicing their portfolios in an efficient and effective manner. To be eligible for inclusion on S&P Global Ratings' Select Servicer List, any ranked servicer must meet one of the following conditions for its relevant ranking category (also see chart):

• An AVERAGE ranking with either a stable or positive ranking outlook or is on RankingWatch positive, and a SUFFICIENT financial position.
• An ABOVE AVERAGE or STRONG ranking with a SUFFICIENT financial position.
• An ABOVE AVERAGE ranking and an INSUFFICIENT financial position, provided the servicer has been on the Select Servicer List for at least three consecutive years and the ranking(s) has a stable or positive ranking outlook or is not on RankingWatch negative or developing.
• A STRONG ranking and an INSUFFICIENT financial position, provided the servicer has been on the Select Servicer List for at least three consecutive years.

Appendix: Trustee And Common Representative Evaluation Services Analytical Approach

The trustee and common representative evaluation services analytical approach is designed to provide a comprehensive assessment of an entity's legal and operational capabilities as a provider of trustee and common representative services in Mexico, Argentina, and other regions, as applicable. We provide a public, independent assessment of trustees' and common representatives' overall capacity to provide their services. Examples of some trustee core business functions may include acting as trustee for debt issuances and issuing trustee for securitization programs.

What is a trustee?

A trustee is typically a financial institution that has a general fiduciary duty to act in the best interest of the beneficiaries. The trustee's principal obligations typically include:

• Keep, administer, and maintain the property of the trust's estate;
• Conduct all necessary actions to fulfill the trust objective, in accordance with the applicable laws and legal documentation;
• Oversee the completion of all fiscal obligations generated by the trust's operation; and
• Provide (with the administration trust or other third party) functioning reports to debtholders.

What is a common representative?

A common representative functions in a similar way as any other legal representative under sovereign or local law, such as an institution that oversees the performance of an entity or a trust, with the final objective of protecting the interest of debtholders. The principal responsibilities of a common representative typically may include:

• Authorizing the trust's debt issuance,
• Verifying all authorizations related to the debt issuance,
• Verifying the existence of the trust's assets,
• Overseeing fulfillment of the terms and conditions of the debt issuance,
• Calculating the interest and principal payment for each period,
• Executing the debtholders' rights for the payment of interest and principal,
• Calling and leading debtholders' general assembly for the custody and safekeeping of the trust's assets and the beneficiaries' interest, and
• Providing (with the administration trust or other third party) functioning reports to debtholders.

The Trustee And Common Representative Ranking Process

Ranking levels

S&P Global Ratings assigns subrankings of EXCELLENT, ABOVE STANDARD, STANDARD, BELOW STANDARD, or WEAK to each of two key areas: "management and organization" and "operational capability." We assign subrankings using the factors described below. We use the lower of the two subrankings to determine the overall ranking for each trustee and common representative category (see table below).

Trustee And Common Representative Evaluation Services Subranking And Ranking Levels
Subranking/ranking	Definition
EXCELLENT	Indicates a very strong ability to provide trustee or common representative services through strong and stable management and business profile, strong legal capabilities, and excellent policies, procedures, and systems.
ABOVE STANDARD	Indicates a strong ability to provide trustee or common representative services through solid management experience and business profile, sound legal capabilities, and strong procedures, policies, and systems.
STANDARD	Indicates an adequate ability to provide trustee or common representative services through satisfactory management and business profile, legal capabilities, and policies, procedures, and systems.
BELOW STANDARD	Indicates an inability to provide adequate trustee or common representative services due to weak management, business profile, legal capabilities, and policies, procedures, and systems.
WEAK	Indicates a poor track record in providing trustee or common representative services through poor management, business profile, legal capabilities, and policies, procedures, and systems.

Ranking outlook categories

We also assign a ranking outlook to provide our view of the stability of the assigned ranking over the intermediate term (typically six months to two years), as described in The Ranking Process section above.

RankingWatch categories

We may also place each overall ranking category on RankingWatch to highlight the potential for a ranking change if there is an identifiable event we believe may have an impact on the servicer in the short-term, typically over the upcoming six months, as described in The Ranking Process section above.

Factors Considered For Assigning Subrankings And Rankings

The analytical approach for determining subrankings and the overall ranking are similar to the approach used for assigning subrankings and rankings to servicers, as described below.

Management and organization (M&O)

The M&O assessment generally focuses on organizational structure, staffing, training, and turnover as it relates to the trustee and common representative duties and responsibilities, as described in The Ranking Process section above.

Operational capability

The operational capability assessment generally focuses on systems and internal controls as described in The Ranking Process section above, as well as in performing necessary trustee obligations, including registry, payment, accounting, reporting, and taxation returns services for the trust. We typically assess systems, internal controls, investor/client reporting, and any other relevant operational processes as it relates to the trustee and common representative duties. Certain responsibilities that are unique to trustees and common representatives may include:

• Calculation of interest rate and debt service, and any other payment;
• Control of servicer representations and warranties and servicer replacement;
• Calculation of floors, triggers, and prepayments; and
• Determination and reporting of an acceleration event, specified events, and events of default.

The ranked entity is also responsible for discharging its legal obligations under the relevant transaction documents for a debt issue. This usually includes understanding the terms of the trust deed, monitoring compliance of the issuer with its various obligations under the trust deed and other documents, monitoring reporting requirements on the issuer (e.g., maintenance of financial ratios and other covenants), scrutinizing reports and certificates timely according to trust deed obligations, and ensuring the wording complies with the trust deed and the calculations are correct and received on time.

Legal capability

S&P Global Ratings' review of legal capability assesses whether the trustee or the common representative has all the necessary business licenses, approvals, and insurance required by law to conduct its business.

Our evaluation ascertains the legal obligation and role of a trustee or a common representative under relevant legal documentation. Specifically, S&P Global Ratings reviews legal requirements of responsibilities stemming typically from two principal sources:

• The operating document(s), and
• The relevant legislation governing the trustee's or common representative's role.

S&P Global Ratings will closely review the quality of the documentation of the transactions in which trustees and common representatives participate, including the mechanisms that trustees and common representatives have in place to cope with deficient documentation and still be able to perform satisfactory.

Financial position

As described above in this analytical approach.

The Select Servicer List (Trustees And Common Representatives)

S&P Global Ratings created the Select Servicer List to recognize those trustees and common representatives that, in our opinion, are able to demonstrate the ability to meet and maintain at least a minimum performance standard, while also generally having appropriate financial resources for the near term to continue performing their duties in an efficient and effective manner. To be eligible for inclusion on this list, any ranked trustee or common representative must be assigned a ranking of STANDARD or higher, provided the financial position is considered sufficient.

Related Research

• Select Servicer List

Analytical Contacts:	Robert J Radziul, Analytical Contacts, New York + 1 (212) 438 1051; robert.radziul@spglobal.com
	Steven Altman, New York (1) 212-438-5042; steven.altman@spglobal.com
	Steven L Frie, New York (1) 212-438-2458; steven.frie@spglobal.com
	Mark J Shannon, New York + (404) 989-7655; mark.shannon@spglobal.com
	Chiara Sardelli, London (44) 20-7176-3878; chiara.sardelli@spglobal.com
	Mei Lee Da Silva, Melbourne (61) 3-9631-2053; mei.dasilva@spglobal.com
	Antonio Zellek, CFA, Mexico City + 52 55 5081 4484; antonio.zellek@spglobal.com
	Yuji Hashimoto, Tokyo (81) 3-4550-8275; yuji.hashimoto@spglobal.com