SEC Info - Citigroup Commercial Mortgage Trust 2019-GC43 - ‘10-K’ for 12/31/23

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Citigroup Commercial Mortgage Trust 2019-GC43 – ‘10-K’ for 12/31/23 – ‘EX-33.24B’

On: Thursday, 3/28/24, at 7:13pm ET · As of: 3/29/24 · For: 12/31/23 · Accession #: 950170-24-38278 · File #: 333-228597-03

  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

 3/29/24  Citigroup Com’l Mtge Tr 2019-GC43 10-K       12/31/23   37:14M                                    Donnelley … Solutions/FA

Asset-Backed Securities (ABS)

Asset Class: Commercial mortgages · Sponsor: Citi Real Estate Funding Inc. · Depositor: Citigroup Commercial Mortgage Securities Inc.

Annual Report — Form 10-K — SEA’34

Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: 10-K        Annual Report                                       HTML    238K 
 3: EX-33.1     Report of Compliance with Servicing Criteria        HTML   1.07M 
12: EX-33.10A   Report of Compliance with Servicing Criteria        HTML   1.18M 
13: EX-33.10B   Report of Compliance with Servicing Criteria        HTML   1.55M 
14: EX-33.1A    Report of Compliance with Servicing Criteria        HTML    102K 
 4: EX-33.2     Report of Compliance with Servicing Criteria        HTML    222K 
11: EX-33.20    Report of Compliance with Servicing Criteria        HTML    545K 
15: EX-33.22A   Report of Compliance with Servicing Criteria        HTML    581K 
16: EX-33.22B   Report of Compliance with Servicing Criteria        HTML    634K 
17: EX-33.24B   Report of Compliance with Servicing Criteria        HTML    123K 
 5: EX-33.3     Report of Compliance with Servicing Criteria        HTML   1.00M 
 6: EX-33.4     Report of Compliance with Servicing Criteria        HTML     36K 
 7: EX-33.5     Report of Compliance with Servicing Criteria        HTML     95K 
 8: EX-33.6     Report of Compliance with Servicing Criteria        HTML    140K 
 9: EX-33.7     Report of Compliance with Servicing Criteria        HTML    723K 
10: EX-33.9     Report of Compliance with Servicing Criteria        HTML    670K 
18: EX-34.1     Attestation Report on Assessment of Compliance      HTML     25K 
                with Servicing Criteria                                          
27: EX-34.10A   Attestation Report on Assessment of Compliance      HTML     20K 
                with Servicing Criteria                                          
28: EX-34.10B   Attestation Report on Assessment of Compliance      HTML     22K 
                with Servicing Criteria                                          
29: EX-34.1A    Attestation Report on Assessment of Compliance      HTML     22K 
                with Servicing Criteria                                          
19: EX-34.2     Attestation Report on Assessment of Compliance      HTML     21K 
                with Servicing Criteria                                          
26: EX-34.20    Attestation Report on Assessment of Compliance      HTML     19K 
                with Servicing Criteria                                          
30: EX-34.22A   Attestation Report on Assessment of Compliance      HTML     21K 
                with Servicing Criteria                                          
31: EX-34.22B   Attestation Report on Assessment of Compliance      HTML     21K 
                with Servicing Criteria                                          
32: EX-34.24B   Attestation Report on Assessment of Compliance      HTML     18K 
                with Servicing Criteria                                          
20: EX-34.3     Attestation Report on Assessment of Compliance      HTML    881K 
                with Servicing Criteria                                          
21: EX-34.4     Attestation Report on Assessment of Compliance      HTML     20K 
                with Servicing Criteria                                          
22: EX-34.5     Attestation Report on Assessment of Compliance      HTML     19K 
                with Servicing Criteria                                          
23: EX-34.6     Attestation Report on Assessment of Compliance      HTML     23K 
                with Servicing Criteria                                          
24: EX-34.7     Attestation Report on Assessment of Compliance      HTML     20K 
                with Servicing Criteria                                          
25: EX-34.9     Attestation Report on Assessment of Compliance      HTML     23K 
                with Servicing Criteria                                          
33: EX-35.1     Servicer Compliance Statement                       HTML   1.69M 
37: EX-35.1A    Servicer Compliance Statement                       HTML    243K 
34: EX-35.2     Servicer Compliance Statement                       HTML    472K 
35: EX-35.3     Servicer Compliance Statement                       HTML     80K 
36: EX-35.5     Servicer Compliance Statement                       HTML    543K 
 2: EX-31       Certification -- §302 - SOA'02                      HTML     17K

‘EX-33.24B’ — Report of Compliance with Servicing Criteria

This Exhibit is an HTML Document rendered as filed. [ Alternative Formats ]

EX-33.24b

MANAGEMENT’S REPORT ON ASSESSMENT OF COMPLIANCE WITH THE SECURITIES AND EXCHANGE COMMISSION’S REGULATION AB SERVICING CRITERIA

March 13, 2024

K-Star Asset Management LLC (“K-Star”) is responsible for assessing compliance with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, as of and for the year ended December 31, 2023 (the “Reporting Period”). The transactions covered by this report include all transactions for which K-Star acted as special servicer (the “Platform”).

Except as set forth in paragraph 3 below, K-Star used criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess the compliance with the applicable servicing criteria.

The criteria listed in the column title “Inapplicable Servicing Criteria” on Appendix A hereto are not applicable to K-Star based on the activities it performs with respect to the Platform.

K-Star has complied in all material respects with the applicable servicing criteria as of December 31, 2023 and for the Reporting Period with respect to the Platform taken as a whole.

FORVIS, LLP, an independent registered public accounting firm, has issued an attestation report on K-Star’s assessment of compliance with the applicable servicing criteria for the Reporting Period.

K-Star Asset Management LLC

/s/ Elizabeth Luther

Elizabeth Luther, Chief Operations Officer

/s/ Angela Johnson

Angela Johnson, Head of Special Servicing

APPENDIX A


SERVICING CRITERIA		APPLICABLE SERVICING CRITERIA		INAPPLICABLE SERVICING CRITERIA
Reference	Criteria	Performed Directly by K-Star	Performed by Vendor(s) for which K-Star is the Responsible Party	Performed by subservicer(s) or vendor(s) for which K-Star is NOT the Responsible Party	NOT performed by K-Star or by subservicer(s) or vendor(s) retained by K- Star
General Servicing Considerations
1122(d)(1)(i)	Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreements.	X
1122(d)(1)(ii)	If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third party’s performance and compliance with such servicing activities.	Xi
1122(d)(1)(iii)	Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.				X
1122(d)(1)(iv)	A fidelity bond and errors and omissions policy is in effect on the party participating in the servicing function throughout the reporting period in the amount of coverage required by and otherwise in accordance with the terms of the transaction agreements.	X
1122(d)(1)(v)	Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.	Xi
Cash Collection and Administration
1122(d)(2)(i)	Payments on pool assets are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days following receipt, or such other number of days specified in the transaction agreements.	Xi
1122(d)(2)(ii)	Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.				X
1122(d)(2)(iii)	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.	Xi
1122(d)(2)(iv)	The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of overcollateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements.	Xi
1122(d)(2)(v)	Each custodial account is maintained at a federally insured depository institution as set forth in the transaction agreements. For purposes of this criterion, “federally insured depository institution” with respect to a foreign financial institution means a foreign financial	Xi


SERVICING CRITERIA		APPLICABLE SERVICING CRITERIA		INAPPLICABLE SERVICING CRITERIA
Reference	Criteria	Performed Directly by K-Star	Performed by Vendor(s) for which K-Star is the Responsible Party	Performed by subservicer(s) or vendor(s) for which K-Star is NOT the Responsible Party	NOT performed by K-Star or by subservicer(s) or vendor(s) retained by K- Star
	institution that meets the requirements of Rule 13k- 1(b)(1) of the Securities Exchange Act.
1122(d)(2)(vi)	Unissued checks are safeguarded so as to prevent unauthorized access.	X
1122(d)(2)(vii)	Reconciliations are prepared on a monthly basis for all asset-backed securities related bank accounts, including custodial accounts and related bank clearing accounts. These reconciliations are (A) mathematically accurate; (B) prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C) reviewed and approved by someone other than the person who prepared the reconciliation; and (D) contain explanations for reconciling items. These reconciling items are resolved within 90 calendar days of their original identification, or such other number of days specified in the transaction agreements.	Xi
Investor Remittances and Reporting
1122(d)(3)(i)	Reports to investors, including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements. Specifically, such reports (A) are prepared in accordance with timeframes and other terms set forth in the transaction agreements; (B) provide information calculated in accordance with the terms specified in the transaction agreements; (C) are filed with the Commission as required by its rules and regulations; and (D) agree with investors’ or the trustee’s records as to the total unpaid principal balance and number of pool assets serviced by the Servicer.				X
1122(d)(3)(ii)	Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.				X
1122(d)(3)(iii)	Disbursements made to an investor are posted within two business days to the Servicer’s investor records, or such other number of days specified in the transaction agreements.				X
1122(d)(3)(iv)	Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.				X
Pool Asset Administration
1122(d)(4)(i)	Collateral or security on pool assets is maintained as required by the transaction agreements or related mortgage loan documents.	X


SERVICING CRITERIA		APPLICABLE SERVICING CRITERIA		INAPPLICABLE SERVICING CRITERIA
Reference	Criteria	Performed Directly by K-Star	Performed by Vendor(s) for which K-Star is the Responsible Party	Performed by subservicer(s) or vendor(s) for which K-Star is NOT the Responsible Party	NOT performed by K-Star or by subservicer(s) or vendor(s) retained by K- Star
1122(d)(4)(ii)	Pool asset and related documents are safeguarded as required by the transaction agreements.				X
1122(d)(4)(iii)	Any additions, removals or substitutions to the asset pool are made, reviewed and approved in accordance with any conditions or requirements in the transaction agreements.	X
1122(d)(4)(iv)	Payments on pool assets, including any payoffs, made in accordance with the related pool asset documents are posted to the Servicer’s obligor records maintained no more than two business days after receipt, or such other number of days specified in the transaction agreements, and allocated to principal, interest or other items (e.g., escrow) in accordance with the related pool asset documents.				X
1122(d)(4)(v)	The Servicer’s records regarding the pool assets agree with the Servicer’s records with respect to an obligor’s unpaid principal balance.				X
1122(d)(4)(vi)	Changes with respect to the terms or status of an obligor's pool assets (e.g., loan modifications or re- agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents.	X
1122(d)(4)(vii)	Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframes or other requirements established by the transaction agreements.	X
1122(d)(4)(viii)	Records documenting collection efforts are maintained during the period a pool asset is delinquent in accordance with the transaction agreements. Such records are maintained on at least a monthly basis, or such other period specified in the transaction agreements, and describe the entity’s activities in monitoring delinquent pool assets including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment).	X
1122(d)(4)(ix)	Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.				X
1122(d)(4)(x)	Regarding any funds held in trust for an obligor (such as escrow accounts): (A) such funds are analyzed, in accordance with the obligor’s pool asset documents, on at least an annual basis, or such other period specified in the transaction agreements; (B) interest on such funds is paid, or credited, to obligors in accordance with applicable pool asset documents and state laws; and (C) such funds are returned to the obligor within 30 calendar days of full repayment of the related pool				X


SERVICING CRITERIA		APPLICABLE SERVICING CRITERIA		INAPPLICABLE SERVICING CRITERIA
Reference	Criteria	Performed Directly by K-Star	Performed by Vendor(s) for which K-Star is the Responsible Party	Performed by subservicer(s) or vendor(s) for which K-Star is NOT the Responsible Party	NOT performed by K-Star or by subservicer(s) or vendor(s) retained by K- Star
	assets, or such other number of days specified in the transaction agreements.
1122(d)(4)(xi)	Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that such support has been received by the Servicer at least 30 calendar days prior to these dates, or such other number of days specified in the transaction agreements.				X
1122(d)(4)(xii)	Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from the Servicer’s funds and not charged to the obligor, unless the late payment was due to the obligor’s error or omission.				X
1122(d)(4)(xiii)	Disbursements made on behalf of an obligor are posted within two business days to the obligor’s records maintained by the Servicer, or such other number of days specified in the transaction agreements.				X
1122(d)(4)(xiv)	Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.	X
1122(d)(4)(xv)	Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as set forth in the transaction agreements.				X

i Although K-Star Asset Management LLC is responsible for performing activities under this criteria, no actions were performed with respect to such criteria during the year ended December 31, 2023.

Dates Referenced Herein

This ‘10-K’ Filing	Date	Other Filings

Filed as of:	3/29/24	None on these Dates
Filed on:	3/28/24
	3/13/24
For Period end:	12/31/23
		List all Filings

1 Previous Filing that this Filing References

  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

11/13/19  Citigroup Com’l Mtge Tr 2019-GC43 8-K:8,9    11/13/19   21:48M                                    Nuvo Group, Inc./FA

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Filing Submission 0000950170-24-038278 – Alternative Formats (Word / Rich Text, HTML, Plain Text, et al.)