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Re:
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UBS Commercial Mortgage Trust 2017-C4 (“UBS 2017-C4”)
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UBS Commercial Mortgage Trust 2017-C5 (“UBS 2017-C5”)
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UBS Commercial Mortgage Trust 2017-C6 (“UBS 2017-C6”)
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UBS Commercial Mortgage Trust 2018-C8 (“UBS 2018-C8”)
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UBS Commercial Mortgage Trust 2018-C9 (“UBS 2018-C9”)
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UBS Commercial Mortgage Trust 2018-C10 (“UBS 2018-C10”)
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UBS Commercial Mortgage Trust 2018-C12 (“UBS 2018-C12”)
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CCUBS 2017-C1 Mortgage Trust (“CCUBS 2017-C1”)
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Forms 10-K for Fiscal Year Ended December 31, 2018
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Filed March 25, 2019 (except with respect to UBS 2018-C8, which was filed March 22, 2019)
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File Nos. 333-207340-04, 333-207340-05, 333-207340-07, 333-207340-09, 333-207340-10, 333-207340-11, 333-207340-13 and 333-207340-06
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We note that the attestation reports prepared by NDNB for Rialto state that “the examination was conducted in accordance with attestation standards
of AICPA” without referencing the standards of the PCAOB. We also note that NDNB is not registered with the PCAOB. With respect to each assessment report for asset-backed securities, Form 10-K must include a report by a registered
public accounting firm that also attests to and reports on the assessment in accordance with standards for attestation engagements issued or adopted by the PCAOB. Refer to Exchange Act Rule 15d-18(c) and Item 1122(b) of Regulation AB.
Please revise your Form 10-K to include compliant attestation reports for Rialto.
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In responding to the Staff’s comments with respect to the Filing, UBS has authorized us to acknowledge on their
behalf, and we hereby acknowledge, that: |
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UBS is responsible for the adequacy and accuracy of the disclosure in the Filing;
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Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the
Filing; and
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UBS may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the
United States.
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Very truly yours, |
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/s/ Frank Polverino |
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Frank Polverino |
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cc: |
Chad Eisenberger
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Nick Galeone
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David Schell
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