Fitch Ratings has downgraded eight and affirmed 65 classes of five U.S. CMBS transactions from the 2014, 2016, 2017 and 2019 vintages.

Five classes were assigned a Negative Rating Outlook following their downgrades, and the Rating Outlooks on 10 classes were revised to Negative from Stable in connection with the correction of errors.

This rating action commentary corrects errors with respect to the rating and/or Rating Outlook for 17 classes, originally published between May 23, 2023 and Nov. 17, 2023, caused by incorrect analytical loan-level inputs or modeling adjustment mismatches to pari passu loans.

Additionally, this rating action commentary also corrects an error with respect to the rating for class X-C in CGCMT 2014-GC21, which incorrectly assigned a rating that was inconsistent with the lowest rated reference class E whose payable interest has an impact on the payment to the interest-only class.

RATING ACTIONS

Entity / Debt

Rating

Prior

CGCMT 2014-GC21

A-4 17322MAV8

LT

AAAsf

Affirmed

AAAsf

A-5 17322MAW6

LT

AAAsf

Affirmed

AAAsf

A-AB 17322MAX4

LT

AAAsf

Affirmed

AAAsf

A-S 17322MAY2

LT

AAAsf

Affirmed

AAAsf

B 17322MAZ9

LT

Asf

Affirmed

Asf

C 17322MBA3

LT

BBBsf

Affirmed

BBBsf

D 17322MAA4

LT

CCCsf

Affirmed

CCCsf

E 17322MAC0

LT

CCsf

Affirmed

CCsf

F 17322MAE6

LT

Csf

Affirmed

Csf

Page

of 8

VIEW ADDITIONAL RATING DETAILS

KEY RATING DRIVERS

Criteria Update; 'Bsf' Loss Expectations: The rating actions reflect the impact of the updated U.S. and Canadian Multiborrower CMBS Rating Criteria, published on May 22, 2023, and incorporate any changes in loan performance and/or credit enhancement (CE) since Fitch's prior rating action.

Deal-level 'Bsf' rating case losses are as follows:

MSCI 2016-UBS9: 6.8%;

GSMS 2019-GC42: 5.0%;

CSAIL 2017-CX9: 4.8%;

BANK 2017-BNK9: 6.8%;

CGCMT 2014-GC21: 8.7%.

MSCI 2016-UBS9: The downgrades to classes D, X-D, E, X-E and F in MSCI 2016-UBS9 reflect higher overall pool loss expectations, driven primarily by the 2100 Ross office loan, and including the correction of the error.

The Negative Outlook revisions on classes B, X-B and C, and assignment of Negative Outlooks on classes D, X-D, E and X-E following their downgrades, reflect performance and refinance concerns on two office loans in the top 15, 2100 Ross and Princeton Pike Corporate Center, and three retail outlet loans, Grove City Premium Outlets, Gulfport Premium Outlets and Ellenton Premium Outlets.

The largest contributor to overall loss expectations, 2100 Ross, is secured by a 33-story, 843,728-sf office building located in the Arts District of downtown Dallas, TX. The property's largest tenants include Lockton Companies (11.7% of NRA; leased through March 2026), Netherland, Sewell & Associates (7.3%; September 2025), Prudential Mortgage Capital (6.5%, April 2027) and Merrill Lynch, Pierce, Fenner and Smith (5.6%, July 2027).

Occupancy for the property was 63.5% as of the March 2023 rent roll, compared with 63% at YE 2022, 81% at YE 2020 and 2021 and 82% at YE 2019. The largest tenant, CBRE (15% of NRA, 20% base rent), vacated at lease expiration in March 2022, relocating to an office tower in the uptown area of Dallas. The vacant CBRE space has yet to be backfilled. The servicer-reported NOI debt service coverage ratio (DSCR) as of March 2023 was 1.29x, down from 1.35x at YE 2022, 1.52x at YE 2021, 1.56x at YE 2020 and 1.39x at YE 2019. According to CoStar as of 2Q23, the Dallas CBD office submarket had a vacancy rate of 26.3% with an elevated availability rate of 30.2% and a market rent of $28.76 psf.

Fitch's 'Bsf' rating case loss of 24% prior to concentration adjustments is based on a 10% cap rate and 25% stress to the YE 2021 NOI, and incorporates a 100% probability of default to account for heightened default risk due to loss of the largest tenant, lack of leasing momentum and weak submarket fundamentals.

GSMS 2019-GC42: The downgrades to classes F-RR and G-RR in GSMS 2019-GC42 reflect increased pool loss expectations, driven primarily by the Northpoint Tower office loan, since Fitch's prior rating action and including the correction of the error.

The Negative Outlook revisions on classes E and X-D, and assignment of a Negative Outlook on class F-RR following its downgrade, reflect their limited ratings cushion and refinance concerns with the Northpoint Tower loan, secured by an 873,335-sf office property in Cleveland, OH, that matures in September 2024.

Fitch's 'Bsf' rating case loss of 12% prior to concentration adjustments on the Northpoint Tower loan is based on a 10% cap rate and 5% stress to YE 2021 NOI, and incorporates an increased probability of default due to heightened maturity default risk.

CSAIL 2017-CX9: The affirmations reflect the impact of the updated criteria and generally stable pool loss expectations since Fitch's prior rating action. The pool is concentrated with only 24 loans remaining, of which 65% is secured by office properties, many of which are underperforming. Six loans (31%) were flagged as Fitch Loans of Concern (FLOCs), which includes one REO asset (6.4%) and three loans (9.6%) in special servicing.

The Negative Outlook revisions on classes A-S, X-A and V1-A, and maintenance of Negative Outlooks on classes B, X-B, C, V1-B, D, V1-D, E, V1-E and X-E reflect an additional sensitivity analysis that incorporates an increased probability of default assumption on the Center 78, Keystone 200 & 300 and Apex Fort Washington loans.

The Center 78 loan is secured by a 372,672-sf suburban office building in Warren, NJ. Performance continues to deteriorate, with occupancy falling to 68% due to the second largest tenant (13.6% NRA) vacating at lease expiration in October 2023. With the tenant's departure, cash flow is insufficient to cover debt service. Fitch's 'Bsf' rating case loss of 10% prior to concentration adjustments reflects a 10% cap rate and 20% stress to the YE 2022 NOI. Fitch also conducted an additional scenario that applies a 'Bsf' sensitivity case loss of 29% on this loan which factors a higher probability of default given the occupancy declines and elevated vacancy in the submarket.

BANK 2017-BNK9: The affirmations reflect the impact of the updated criteria and generally stable pool loss expectations since Fitch's prior rating action. Seven loans (19.8%) were flagged as FLOCs, which includes two loans (6%) in special servicing.

The Negative Outlook revisions on classes B and X-B, and maintenance of Negative Outlooks on classes C, D, X-D, E and X-E are due to the pool's elevated level of FLOCs, including exposure to underperforming office properties facing declining occupancy and high submarket vacancy rates. Approximately 27% of the remaining pool is secured by office assets. The Negative Outlooks also reflect an additional sensitivity analysis that incorporates a 100% probability of default on the Warwick Mall loan, secured by an approximately 588,000-sf regional mall located in Warwick, RI, flagged for its secondary market regional mall location, lagged recovery post-pandemic and refinance concerns.

CGCMT 2014-GC21: The downgrade of class X-C to 'CCsf' from 'CCCsf' in CGCMT 2014-GC21 is tied to its lowest rated reference class E (rated CCsf) whose payable interest has an impact on the payment to the interest-only class.

Changes to CE: These pools' aggregate balance has been reduced by an average of 20.4% (ranging from 1.0% to 35.9%) since issuance.

RATING SENSITIVITIES

Factors that Could, Individually or Collectively, Lead to Negative Rating Action/Downgrade

The Negative Outlooks reflect possible future downgrades stemming from concerns with potential further declines in performance that could result in higher expected losses on FLOCs. If expected losses increase, downgrades to these classes are anticipated.

Downgrades to 'AAAsf' rated classes could occur if deal-level expected losses increase significantly and/or interest shortfalls occur. For 'AAAsf' rated bonds, additional stresses applied to defeased collateral as the U.S. sovereign rating is lower than 'AAA' could also contribute to downgrades.

Downgrades to 'AAsf', 'Asf' and 'BBBsf' category rated classes could occur if deal-level losses increase significantly on non-defeased loans in the transactions and with outsized losses on larger FLOCs.

Downgrades to 'BBsf' and 'Bsf' category rated classes are possible with higher expected losses from continued performance of the FLOCs and with greater certainty of near-term losses on specially serviced assets and other FLOCs.

Downgrades to distressed ratings of 'CCCsf' through 'Csf' would occur as losses become more certain and/or as losses are incurred.

Factors that Could, Individually or Collectively, Lead to Positive Rating Action/Upgrade

Upgrades to 'AAsf' category rated classes are possible with significantly increased CE from paydowns, coupled with stable-to-improved pool-level loss expectations and performance stabilization of FLOCs. Upgrades of these classes to 'AAAsf' will also consider the concentration of defeased loans in the transaction.

Upgrades to the 'Asf' and 'BBBsf' category rated classes would be limited based on sensitivity to concentrations or the potential for future concentration. Classes would not be upgraded above 'AA+sf' if there is likelihood for interest shortfalls.

Upgrades to 'BBsf' and 'Bsf' category rated classes are not likely until the later years in a transaction and only if the performance of the remaining pool is stable and there is sufficient CE to the classes.

Upgrades to distressed ratings of 'CCCsf' through 'Csf' are not expected, but possible with better than expected recoveries on specially serviced loans or significantly higher values on FLOCs.

USE OF THIRD PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G -10

Form ABS Due Diligence-15E was not provided to, or reviewed by, Fitch in relation to this rating action.

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF RATING

The principal sources of information used in the analysis are described in the Applicable Criteria.

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless otherwise disclosed in this section. A score of '3' means ESG issues are credit-neutral or have only a minimal credit impact on the entity, either due to their nature or the way in which they are being managed by the entity. Fitch's ESG Relevance Scores are not inputs in the rating process; they are an observation on the relevance and materiality of ESG factors in the rating decision. For more information on Fitch's ESG Relevance Scores, visit https://www.fitchratings.com/topics/esg/products#esg-relevance-scores.

Additional information is available on www.fitchratings.com

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