[August 06, 2014]

Fitch Take Various Actions on Pacific Life Insurance Company's Commercial Servicer Ratings

Fitch Ratings has taken the following actions for Pacific Life Insurance Company (Pacific Life):

--Commercial master servicer rating affirmed at 'CMS2+' and withdrawn;

--Commercial special servicer rating affirmed at 'CSS2' and withdrawn;

--Commercial loan level special rating assigned at 'CLLSS2+';

--Commercial primary servicer rating affirmed at 'CPS1'.

The withdrawal of the master servicer rating is due to insufficient information necessary to maintain it, as Pacific Life has elected not to maintain its master servicer rating. Pacific Life is no longer acting as master servicer for any Fitch rated transactions and has no plans to perform master servicing in the future, as such, it is no longer considered by Fitch to be relevant to the agency's coverage.

The assignment of a loan level special servicer rating and simultaneous affirmation and withdrawal of the conduit special servicer rating reflects Pacific Life's special servicing infrastructure which, while appropriate for its current portfolio and business plan, is focused on special servicing individual loans rather than securitized transactions of multiple loans. Fitch's loan level special servicer rating is assigned to special servicers typically engaged to manage individual loans (vs. portfolio or multiborrower CMBS transactions), have smaller, specialized staff and portfolio or workout volumes that do not require the staff and technology infrastructure associated with special servicing large pools of loans. Fitch believes the loan level special servicer rating, rather than conduit, better reflects the company's small group of tenured and experienced asset managers, technology infrastructure for special servicing and business plan.

The affirmation of the primary servicer ratings reflect Fitch's assessment of the company's ability to effectively service commercial mortgage loans, technology, and its robust internal control environment. Each of the ratings take into consideration the company's highly experienced and tenured servicing management and staff, $1 billion - $2 billion per year of new, directly serviced commercial mortgages loan origination, and the investment grade financial strength of the company.

As of March 31, 2014, Pacific Life was servicing 629 commercial real estate loans totaling $17.8 billion in outstanding balance. As of the same date the company was named special servicer for 533 loans totaling $10.1 billion of whih five loans totaling $113.3 million were in default and Pacific Life was managing three foreclosed properties in real estate owned inventory representing $3.0 million in outstanding balance. The company's legacy conduit CMBS transactions, which represent 11% of its total named special servicing portfolio, continue to payoff and new CMBS special servicing assignments are loan level assignments in conjunction with mezzanine and B-note investments. Non-securitized loans, which represent a majority of Pacific Life's named special servicing portfolio, are balance sheet loans originated by Pacific Life and private client loans.

The servicer rating is based on the methodology described in Fitch's reports 'U.S. Commercial Mortgage Servicer Rating Criteria,' dated Feb. 14, 2014, and 'Rating Criteria for Structured Finance Servicers,' dated Jan. 30, 2014, available on Fitch's web site www.fitchratings.com.

Additional information is available at 'www.fitchratings.com'.

Applicable Criteria and Related Research:

--'U.S. Commercial Mortgage Servicer Rating Criteria' (Feb. 14, 2014);

--'Rating Criteria for Structured Finance Servicers' (Jan. 30, 2014).

Applicable Criteria and Related Research:

Rating Criteria for Structured Finance Servicers

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=731750

Rating Criteria for U.S. Commercial Mortgage Servicers

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=735382

Additional Disclosure

Solicitation Status

http://www.fitchratings.com/gws/en/disclosure/solicitation?pr_id=846274

ALL FITCH CREDIT RATINGS ARE SUBJECT TO CERTAIN LIMITATIONS AND DISCLAIMERS. PLEASE READ THESE LIMITATIONS AND DISCLAIMERS BY FOLLOWING THIS LINK: HTTP://FITCHRATINGS.COM/UNDERSTANDINGCREDITRATINGS. IN ADDITION, RATING DEFINITIONS AND THE TERMS OF USE OF SUCH RATINGS ARE AVAILABLE ON (News - Alert) THE AGENCY'S PUBLIC WEBSITE 'WWW.FITCHRATINGS.COM'. PUBLISHED RATINGS, CRITERIA AND METHODOLOGIES ARE AVAILABLE FROM THIS SITE AT ALL TIMES. FITCH'S CODE OF CONDUCT, CONFIDENTIALITY, CONFLICTS OF INTEREST, AFFILIATE FIREWALL, COMPLIANCE AND OTHER RELEVANT POLICIES AND PROCEDURES ARE ALSO AVAILABLE FROM THE 'CODE OF CONDUCT' SECTION OF THIS SITE. FITCH MAY HAVE PROVIDED ANOTHER PERMISSIBLE SERVICE TO THE RATED ENTITY OR ITS RELATED THIRD PARTIES. DETAILS OF THIS SERVICE FOR RATINGS FOR WHICH THE LEAD ANALYST IS BASED IN AN EU-REGISTERED ENTITY CAN BE FOUND ON THE ENTITY SUMMARY PAGE FOR THIS ISSUER ON THE FITCH WEBSITE.

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