Common use of Credit Risk Retention Clause in Contracts

Credit Risk Retention. An economic interest in the credit risk of the Mortgage Loan is expected to be retained pursuant to the Credit Risk Retention Rules as an “eligible vertical interest” (as defined in the Credit Risk Retention Rules) in the form of the Combined VRR Interest. CREFI will act as “retaining sponsor” under, and as defined in, the Credit Risk Retention Rules. On the Closing Date, pursuant to the CREFI Trust Loan Purchase Agreement, CREFI shall receive, as partial consideration for its sale to the Depositor of 40% of the Mortgage Loan, Class VRR Certificates with an initial aggregate Certificate Balance of $4,284,000, representing approximately 40% (by principal balance) of the entire Combined VRR Interest as of the Closing Date (the “CREFI VRR Interest Portion”). On the Closing Date, pursuant to the GSMC Trust Loan Purchase Agreement, GS Bank, an “originator” (within the meaning of the Credit Risk Retention Rules) of the Mortgage Loan, shall receive, as partial consideration for its sale (through GSMC) to the Depositor of 20% of the Mortgage Loan, Uncertificated VRR Interest with an initial principal balance of $2,142,000, representing approximately 20% (by principal balance) of the entire Combined VRR Interest as of the Closing Date (the “GS Bank VRR Interest Portion”). On the Closing Date, pursuant to the BCREI Trust Loan Purchase Agreement, Barclays Bank PLC (“BBPLC”), a “majority-owned affiliate” (within the meaning of the Credit Risk Retention Rules) of BCREI (an “originator” within the meaning of the Credit Risk Retention Rules of the Mortgage Loan), shall receive, as partial consideration for BCREI’s sale to the Depositor of 20% of the Mortgage Loan, Class VRR Certificates with an initial aggregate Certificate Balance of $2,142,000, representing approximately 20% (by principal balance) of the entire Combined VRR Interest as of the Closing Date (the “BCREI VRR Interest Portion”). On the Closing Date, pursuant to the BMO Hxxxxx Trust Loan Purchase Agreement, BMO Hxxxxx, an “originator” (within the meaning of the Credit Risk Retention Rules) of the Mortgage Loan, shall receive, as partial consideration for its sale to the Depositor of 20% of the Mortgage Loan, Class VRR Certificates with an initial aggregate Certificate Balance of $2,142,000, representing approximately 20% (by principal balance) of the entire Combined VRR Interest as of the Closing Date (the “BMO Hxxxxx VRR Interest Portion”). All covenants and agreements made by the Depositor herein are for the benefit and security of the Trust Interest Owners and the Trustee as holder of the Uncertificated Lower-Tier Interests. The Depositor, the Servicer, the Special Servicer, the Trustee and the Certificate Administrator are entering into this Agreement, and the Trustee is accepting the trusts created hereby, for good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged.

Credit Risk Retention. An economic interest in the credit risk of the Mortgage Loan is expected to be retained pursuant to the Credit Risk Retention Rules as an “eligible vertical interest” (as defined in the Credit Risk Retention Rules) in the form of the Combined VRR Interest. CREFI will act as “retaining sponsor” under, and as defined in, the Credit Risk Retention Rules. On the Closing Date, pursuant to the CREFI Trust Mortgage Loan Purchase Agreement, CREFI shall receive, as partial consideration for its sale to the Depositor of 40% of the Mortgage Loan, Class VRR Certificates with an initial aggregate Certificate Balance of $4,284,000, representing approximately 40% (by principal balance) of the entire Combined VRR Interest as of the Closing Date (the “CREFI VRR Interest Portion”). On the Closing Date, pursuant to the GSMC Trust Loan Purchase Agreement, GS BankCREFI, an “originator” (within the meaning of the Credit Risk Retention RulesRegulation RR) of Mortgage Loans and/or portions thereof representing approximately 49.9% of the aggregate Cut-off Date Balance of all the Mortgage LoanLoans, shall receivewill receive from the Depositor $22,063,870 of the VRR Interest (such portion of the VRR Interest, as partial consideration the “VRR1 Interest”), in exchange for a reduction in the price that CREFI is to receive for its sale (through GSMC) to the Depositor of 20% of the Mortgage Loan, Uncertificated VRR Interest with an initial principal balance of $2,142,000, representing approximately 20% (by principal balance) of Loans and/or portions thereof that it is transferring to the entire Combined VRR Interest as of the Closing Date (the “GS Bank VRR Interest Portion”)Depositor. On the Closing Date, pursuant to the BCREI Trust GACC Mortgage Loan Purchase Agreement, Barclays Bank PLC (“BBPLC”)DBNY, a “majority-owned affiliate” (within the meaning of the Credit Risk Retention RulesRegulation RR) of BCREI (an “originator” within the meaning of the Credit Risk Retention Rules of the Mortgage Loan)GACC, shall will receive, as partial consideration for BCREI’s sale the Mortgage Loans and/or portions thereof that GACC is transferring to the Depositor of 20% Depositor, $12,750,016 of the Mortgage Loan, Class VRR Certificates with an initial aggregate Certificate Balance of $2,142,000, representing approximately 20% Interest (by principal balance) such portion of the entire Combined VRR Interest as of the Closing Date (Interest, the “BCREI VRR Interest PortionVRR2 Interest”). On the Closing Date, pursuant to the BMO Hxxxxx Trust JPMCB Mortgage Loan Purchase Agreement, BMO HxxxxxJPMCB, an “originator” (within the meaning of the Credit Risk Retention RulesRegulation RR) of Mortgage Loans and/or portions thereof representing approximately 21.2% of the aggregate Cut-off Date Balance of all the Mortgage LoanLoans, shall receivewill receive from the Depositor $9,362,005 of the VRR Interest (such portion of the VRR Interest, as partial consideration the “VRR3 Interest”), in exchange for a reduction in the price that JPMCB is to receive for its sale to the Depositor of 20% the Mortgage Loans and/or portions thereof that it is transferring to the Depositor. As of the Cut-Off Date, the Mortgage Loan, Class VRR Certificates with Loans have an initial aggregate Certificate Stated Principal Balance of equal to approximately $2,142,000, representing approximately 20% (by principal balance) 883,517,820. In consideration of the entire Combined VRR Interest as of mutual agreements herein contained, the Closing Date (the “BMO Hxxxxx VRR Interest Portion”). All covenants and agreements made by the Depositor herein are for the benefit and security of the Trust Interest Owners and the Trustee as holder of the Uncertificated Lower-Tier Interests. The Depositor, the Master Servicer, the Special Servicer, the Trustee and Operating Advisor, the Asset Representations Reviewer, the Certificate Administrator are entering into this Agreement, and the Trustee is accepting the trusts created hereby, for good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged.agree as follows:

Credit Risk Retention. An economic interest in the credit risk of the Mortgage Trust Loan is expected to be retained pursuant to the U.S. Credit Risk Retention Rules as an “eligible vertical interest” (as defined in the U.S. Credit Risk Retention Rules) in the form of the Combined VRR Interest. CREFI will act as “retaining sponsor” under, and as defined in, the U.S. Credit Risk Retention Rules. On the Closing Date, pursuant to the CREFI Trust Loan Purchase Agreement, CREFI shall receive, as partial consideration for its sale to the Depositor of approximately 40% of the Mortgage Trust Loan, Class VRR Certificates with an initial aggregate Certificate Balance of $4,284,0005,000,000, representing approximately 40% (by principal balance) of the entire Combined VRR Interest as of the Closing Date (the “CREFI VRR Interest Portion”). On the Closing Date, pursuant to the GSMC BANA Trust Loan Purchase Agreement, GS Bank, an “originator” (within the meaning of the Credit Risk Retention Rules) of the Mortgage Loan, BANA shall receive, as partial consideration for its sale (through GSMC) to the Depositor of 20approximately 30% of the Mortgage Loan, Uncertificated VRR Interest with an initial principal balance of $2,142,000, representing approximately 20% (by principal balance) of the entire Combined VRR Interest as of the Closing Date (the “GS Bank VRR Interest Portion”). On the Closing Date, pursuant to the BCREI Trust Loan Purchase Agreement, Barclays Bank PLC (“BBPLC”), a “majority-owned affiliate” (within the meaning of the Credit Risk Retention Rules) of BCREI (an “originator” within the meaning of the Credit Risk Retention Rules of the Mortgage Loan), shall receive, as partial consideration for BCREI’s sale to the Depositor of 20% of the Mortgage Loan, Class VRR Certificates with an initial aggregate Certificate Balance of $2,142,0003,750,000, representing approximately 2030% (by principal balance) of the entire Combined VRR Interest as of the Closing Date (the “BCREI BANA VRR Interest Portion”). On the Closing Date, pursuant to the BMO Hxxxxx Xxxxxx Trust Loan Purchase Agreement, BMO Hxxxxx, an “originator” (within the meaning of the Credit Risk Retention Rules) of the Mortgage Loan, Xxxxxx shall receive, as partial consideration for its sale to the Depositor of 20approximately 30% of the Mortgage Trust Loan, Class VRR Certificates with an initial aggregate Certificate Balance of $2,142,0003,750,000, representing approximately 2030% (by principal balance) of the entire Combined VRR Interest as of the Closing Date (the “BMO Hxxxxx Xxxxxx VRR Interest Portion”). All covenants and agreements made by the Depositor herein are for the benefit and security of the Trust Interest Owners Certificateholders and the Trustee as holder of the Uncertificated Lower-Tier Interests. The Depositor, the Servicer, the Special Servicer, the Trustee and the Certificate Administrator are entering into this Agreement, and the Trustee is accepting the trusts created hereby, for good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged.

Credit Risk Retention. An economic interest in the credit risk of the Mortgage Loan is expected to be retained pursuant to the Credit Risk Retention Rules as an “eligible vertical interest” (as defined in the Credit Risk Retention Rules) in the form of the Combined VRR Interest. CREFI will act as “retaining sponsor” under, and as defined in, the Credit Risk Retention Rules. On the Closing Date, pursuant to the CREFI Trust Loan Purchase Agreement, CREFI shall receive, as partial consideration for its sale to the Depositor of 40% of the Mortgage Loan, Class VRR Certificates with an initial aggregate Certificate Balance of $4,284,000, representing approximately 40% (by principal balance) of the entire Combined VRR Interest as of the Closing Date (the “CREFI VRR Interest Portion”). On the Closing Date, pursuant to the GSMC Trust Loan Purchase Agreement, GS Bank, an “originator” (within the meaning of the Credit Risk Retention Rules) of the Mortgage Loan, shall receive, as partial consideration for its sale (through GSMC) to the Depositor of 20% of the Mortgage Loan, Uncertificated VRR Interest with an initial principal balance of $2,142,000, representing approximately 20% (by principal balance) of the entire Combined VRR Interest as of the Closing Date (the “GS Bank VRR Interest Portion”). On the Closing Date, pursuant to the BCREI Trust Loan Purchase Agreement, Barclays Bank PLC (“BBPLC”), a “majority-owned affiliate” (within the meaning of the Credit Risk Retention Rules) of BCREI (an “originator” within the meaning of the Credit Risk Retention Rules of the Mortgage Loan), shall receive, as partial consideration for BCREI’s sale to the Depositor of 20% of the Mortgage Loan, Class VRR Certificates with an initial aggregate Certificate Balance of $2,142,000, representing approximately 20% (by principal balance) of the entire Combined VRR Interest as of the Closing Date (the “BCREI VRR Interest Portion”). On the Closing Date, pursuant to the BMO Hxxxxx Xxxxxx Trust Loan Purchase Agreement, BMO HxxxxxXxxxxx, an “originator” (within the meaning of the Credit Risk Retention Rules) of the Mortgage Loan, shall receive, as partial consideration for its sale to the Depositor of 20% of the Mortgage Loan, Class VRR Certificates with an initial aggregate Certificate Balance of $2,142,000, representing approximately 20% (by principal balance) of the entire Combined VRR Interest as of the Closing Date (the “BMO Hxxxxx Xxxxxx VRR Interest Portion”). All covenants and agreements made by the Depositor herein are for the benefit and security of the Trust Interest Owners and the Trustee as holder of the Uncertificated Lower-Tier Interests. The Depositor, the Servicer, the Special Servicer, the Trustee and the Certificate Administrator are entering into this Agreement, and the Trustee is accepting the trusts created hereby, for good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged.