SEC Comment Letter 0000000000-25-001703 to DEUTSCHE MORTGAGE & ASSET RECEIVING CORP (CIK 0001013454)
DEUTSCHE MORTGAGE & ASSET RECEIVING CORP (CIK 0001013454)
Date: Feb. 14, 2025 · CIK: 0001013454 · Accession: 0000000000-25-001703
AI Filing Summary & Sentiment
File numbers found in text: 333-283864
Letter
February 13, 2025 Helaine Kaplan President and Managing Director Deutsche Mortgage & Asset Receiving Corporation 1 Columbus Circle New York, New York 10019 Re:Deutsche Mortgage & Asset Receiving Corporation Amendment No. 1 to Registration Statement on Form SF-3 Filed January 29, 2025 File No. 333-283864 Dear Helaine Kaplan: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe this comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our January 14, 2025 letter. Amendment No. 1 to Registration Statement on Form SF-3 Form 8-K of Benchmark 2023-B38 Mortgage Trust (Filed May 3, 2023), page 2 1.We note your response to prior comment 8 and reissue in part. Please explain why you believe K-Star would not satisfy clause (iv) of Item 1108(a)(2). In your response, please address how K-Star's contemplated responsibilities as special servicer align with the Commission's statements in Section III.B.3.d. of Release No. 33-8419 (the "2004 Regulation AB Proposing Release") (stating that the proposed disclosure requirements would apply to any servicer, such as a special servicer, that performs work-outs, foreclosures or other material aspects of the servicing of the pool assets upon which the performance of the pool assets or the asset-backed securities is materially dependent).
February 13, 2025 Page 2 Please contact Hodan Siad at 202-679-7829 or Benjamin Meeks at 202-551-7146 with any questions. Sincerely, Division of Corporation Finance Office of Structured Finance
Show Raw Text
February 13, 2025
Helaine Kaplan
President and Managing Director
Deutsche Mortgage & Asset Receiving Corporation
1 Columbus Circle
New York, New York 10019
Re:Deutsche Mortgage & Asset Receiving Corporation
Amendment No. 1 to Registration Statement on Form SF-3
Filed January 29, 2025
File No. 333-283864
Dear Helaine Kaplan:
We have reviewed your amended registration statement and have the following
comment.
Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe this comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our January 14, 2025 letter.
Amendment No. 1 to Registration Statement on Form SF-3
Form 8-K of Benchmark 2023-B38 Mortgage Trust (Filed May 3, 2023), page 2
1.We note your response to prior comment 8 and reissue in part. Please explain why you
believe K-Star would not satisfy clause (iv) of Item 1108(a)(2). In your response,
please address how K-Star's contemplated responsibilities as special servicer align
with the Commission's statements in Section III.B.3.d. of Release No. 33-8419 (the
"2004 Regulation AB Proposing Release") (stating that the proposed disclosure
requirements would apply to any servicer, such as a special servicer, that performs
work-outs, foreclosures or other material aspects of the servicing of the pool assets
upon which the performance of the pool assets or the asset-backed securities is
materially dependent).
February 13, 2025
Page 2
Please contact Hodan Siad at 202-679-7829 or Benjamin Meeks at 202-551-7146 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Structured Finance