UNITED STATES
SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM 10-K

(Mark One)

x ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended December 31, ~~2024~~2025 or

o TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from _____ to _____

Commission file number of the issuing entity: 333-206847-01

Central Index Key Number of the issuing entity: 0001665081

Morgan Stanley Bank of America Merrill Lynch Trust 2016-C28

(exact name of the issuing entity as specified in its charter)

Central Index Key Number of the depositor: 0001005007

Banc of America Merrill Lynch Commercial Mortgage Inc.

(exact name of the depositor as specified in its charter)

Central Index Key Number of the sponsor: 0001102113

Bank of America, National Association

(exact name of the sponsor as specified in its charter)

Central Index Key Number of the sponsor: 0001541557

Morgan Stanley Mortgage Capital Holdings LLC

(exact name of the sponsor as specified in its charter)

Central Index Key Number of the sponsor: 0001548567

CIBC Inc.

(exact name of the sponsor as specified in its charter)

Central Index Key Number of the sponsor: 0001682532

Starwood Mortgage Funding III LLC

(exact name of the sponsor as specified in its charter)

New York
(State or other jurisdiction of
incorporation or organization of

the issuing entity)

38-3991327

38-3991328

38-7145089

(I.R.S. Employer

Identification Numbers)

c/o Computershare Trust Company, National Association, as agent for

Wells Fargo Bank, National Association

as Certificate Administrator

9062 Old Annapolis Road

Columbia, MD

(Address of principal executive offices of the issuing entity)

21045

(Zip Code)

Registrant’s telephone number, including area code:

(646) 855-3953

Securities registered pursuant to Section 12(b) of the Act:

Title of each class	Trading Symbol(s)	Name of each exchange on which registered
None

Securities registered pursuant to Section 12(g) of the Act: None.

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. o Yes ⌧ No

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act. o Yes ⌧ No

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days. ⌧ Yes o No

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (Section 232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).

Not applicable.

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company, or an emerging growth company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company,” and “emerging growth company” in Rule 12b-2 of the Exchange Act.

Large accelerated filer o Accelerated filer o

Non-accelerated filer ⌧ Smaller reporting company o

Emerging growth company o

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act. o

Indicate by check mark whether the registrant has filed a report on and attestation to its management’s assessment of the effectiveness of its internal control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or issued its audit report. o

If securities are registered pursuant to Section 12(b) of the Act, indicate by check mark whether the financial statements of the registrant included in the filing reflect the correction of an error to previously issued financial statements. o

Indicate by check mark whether any of those error corrections are restatements that required a recovery analysis of incentive-based compensation received by any of the registrant’s executive officers during the relevant recovery period pursuant to §240.10D-1(b). o

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Act). o Yes ⌧ No

State the aggregate market value of the voting and non-voting common equity held by non-affiliates computed by reference to the price at which the common equity was last sold, or the average bid and asked price of such common equity, as of the last business day of the registrant’s most recently completed second fiscal quarter.

Not applicable.

Indicate by check mark whether the registrant has filed all documents and reports required to be filed by Section 12, 13 or 15(d) of the Securities Exchange Act of 1934 subsequent to the distribution of securities under a plan confirmed by a court. o Yes o No

Not applicable.

Indicate the number of shares outstanding of each of the registrant’s classes of common stock, as of the latest practicable date.

Not applicable.

DOCUMENTS INCORPORATED BY REFERENCE

List hereunder the following documents if incorporated by reference and the Part of the Form 10-K (e.g., Part I, Part II, etc.) into which the document is incorporated: (1) Any annual report to security holders; (2) Any proxy or information statement; and (3) Any prospectus filed pursuant to Rule 424(b) or (c) under the Securities Act of 1933. The listed documents should be clearly described for identification purposes (e.g., annual report to security holders for fiscal year ended December 24, 1980).

Not applicable.

EXPLANATORY NOTES

The Princeton Pike Corporate Center Mortgage Loan, which constituted approximately 5.2% of the asset pool of the issuing entity as of its cut-off date, is an asset of the issuing entity and is part of a loan combination that includes the Princeton Pike Corporate Center Mortgage Loan and two other pari passu loans, which are not assets of the issuing entity. This loan combination, including the Princeton Pike Corporate Center Mortgage Loan, is being serviced and administered pursuant to the Pooling and Servicing Agreement, which is incorporated by reference as Exhibit 4.1 to this Annual Report on Form 10-K.

The Exhibit Index describes exhibits provided by certain parties (in their capacities indicated on the Exhibit Index) with respect to the University West Apartments Mortgage Loan, which constituted approximately 1.9% of the asset pool of the issuing entity as of its cut-off date. The University West Apartments Mortgage Loan is an asset of the issuing entity and is part of a loan combination that includes the University West Apartments Mortgage Loan and one other pari passu loan, which is not an asset of the issuing entity. The other pari passu portion of the loan combination was securitized in the Morgan Stanley Bank of America Merrill Lynch Trust 2015-C27 transaction, Commission File Number 333-180779-20 (the “MSBAM 2015-C27 Transaction”). This loan combination, including the University West Apartments Mortgage Loan, is being serviced and administered pursuant to the pooling and servicing agreement for the MSBAM 2015-C27 Transaction, which is incorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K.

The Exhibit Index describes exhibits provided by certain parties (in their capacities indicated on the Exhibit Index) with respect to the Ellenton Premium Outlets Mortgage Loan, which constituted approximately 7.5% of the asset pool of the issuing entity as of its cut-off date. The Ellenton Premium Outlets Mortgage Loan is an asset of the issuing entity and is part of a loan combination that includes the Ellenton Premium Outlets Mortgage Loan and three other pari passu loans, which are not assets of the issuing entity. A pari passu portion of the loan combination was securitized in the Morgan Stanley Capital I Trust 2015-UBS8 transaction, Commission File Number 333-180779-21 (the “MSC 2015-UBS8 Transaction”). This loan combination, including the Ellenton Premium Outlets Mortgage Loan, is being serviced and administered pursuant to the pooling and servicing agreement for the MSC 2015-UBS8 Transaction, which is incorporated by reference as Exhibit 4.3 to this Annual Report on Form 10-K.

The Exhibit Index describes exhibits provided by certain parties (in their capacities indicated on the Exhibit Index) with respect to the Penn Square Mall Mortgage Loan, which constituted approximately 9.4% of the asset pool of the issuing entity as of its cut-off date. The Penn Square Mall Mortgage Loan is an asset of the issuing entity and is part of a loan combination that includes the Penn Square Mall Mortgage Loan and two other pari passu loans and one subordinate companion loan, which are not assets of the issuing entity. A pari passu portion of the loan combination was securitized in the Morgan Stanley Capital I Trust 2016-PSQ transaction (the “MSC 2016-PSQ Transaction”). This loan combination, including the Penn Square Mall Mortgage Loan, is being serviced and administered pursuant to the trust and servicing agreement for the MSC 2016-PSQ Transaction, which is incorporated by reference as Exhibit 4.4 to this Annual Report on Form 10-K.

The master servicer of a pooling and servicing agreement or trust and servicing agreement also functions as the primary servicer of the related mortgage loans serviced and administered pursuant to such agreement unless a separate primary servicer is identified herein. If this report does not identify a separate primary servicer, the servicer compliance statement provided by the master servicer under any such agreement also encompasses its responsibilities as primary servicer of the related mortgage loan or mortgage loans.

Wells Fargo Bank, National Association is the ~~master~~certificate ~~servicer~~administrator of the mortgage loans serviced under the Pooling and ~~certificate~~Servicing ~~administrator~~Agreement, the master servicer of the mortgage loans serviced under the Pooling and Servicing Agreement prior to March 1, 2025, the primary servicer of the University West Apartments Mortgage Loan prior to March 1, 2025 and the primary servicer and special servicer of the Penn Square Mall Mortgage Loan prior to March 1, 2025. As a result, Wells Fargo Bank, National Association is a “servicer” as defined in ~~Item~~ Item 1108(a)(2)(iii) of Regulation AB, in the capacities described above, because it is servicing mortgage loans that constituted 10% or more of the assets of the issuing entity as of its cut-off date. The assessments of compliance ~~with~~ with applicable servicing criteria, accountants’ attestation reports and ~~servicer~~ servicer compliance statements delivered by Wells Fargo Bank, National Association in the capacities described above are listed in the Exhibit Index.

Trimont LLC is the master servicer of the mortgage loans serviced under the Pooling and Servicing Agreement on and after March 1, 2025, the primary servicer of the University West Apartments Mortgage Loan on and after March 1, 2025 and the primary servicer and special servicer of the Penn Square Mall Mortgage Loan on and after March 1, 2025. As a result, Trimont LLC is a “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities described above, because it is servicing mortgage loans that constituted 10% or more of the assets of the issuing entity as of its cut-off date. The assessments of compliance with applicable servicing criteria, accountants’ attestation reports and servicer compliance statements delivered by Trimont LLC in the capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian of the mortgage loans serviced under the Pooling and Servicing Agreement, the Penn Square Mall Mortgage Loan, the Ellenton Premium Outlets Mortgage Loan and the University West Apartments Mortgage Loan. As a result, Wells Fargo Bank, National Association is a servicing function participant in the capacities described above, because it is servicing mortgage loans that constituted 5% or more of the assets of the issuing entity as of its cut-off date. The assessments of compliance with applicable servicing criteria and accountants’ attestation reports delivered by Wells Fargo Bank, National Association in the capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, National Association acts as trustee of the Ellenton Premium Outlets Mortgage Loan. Pursuant to the pooling and servicing agreement for the MSC 2015-UBS8 Transaction, the trustee is required to provide an assessment of compliance with applicable servicing criteria solely with respect to Item 1122(d)(2)(iii) of Regulation AB (regarding 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). However, during the reporting period, the trustee did not perform any servicing function with respect to the servicing criteria specified in Item 1122(d)(2)(iii) of Regulation AB. The master servicer or the special servicer, to the extent required, performed the servicing function identified with respect to Item 1122(d)(2)(iii) of Regulation AB, and each such party included Item 1122(d)(2)(iii) of Regulation AB in the assessment of compliance with applicable servicing criteria and accountant’s attestation report for the subject transaction. As a result, this Annual Report on Form 10-K does not include an assessment of compliance with applicable servicing criteria of the trustee. One or more other servicers of the Ellenton Premium Outlets Mortgage Loan have delivered one or more assessments of compliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

U.S. Bank National Association acts as trustee of the mortgage loans serviced under the Pooling and Servicing Agreement. Pursuant to the Pooling and Servicing Agreement, the trustee is required to provide an assessment of compliance with applicable servicing criteria solely with respect to Item 1122(d)(2)(iii) of Regulation AB (regarding 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). However, during the reporting period, the trustee did not perform any servicing function with respect to the servicing criteria specified in Item 1122(d)(2)(iii) of Regulation AB. The master servicer or the special servicer, to the extent required, performed the servicing function identified with respect to Item 1122(d)(2)(iii) of Regulation AB, and each such party included Item 1122(d)(2)(iii) of Regulation AB in the assessment of compliance with applicable servicing criteria and accountant’s attestation report for the subject transaction. As a result, this Annual Report on Form 10-K does not include an assessment of compliance with applicable servicing criteria of the trustee. One or more other servicers of the mortgage loans serviced under the Pooling and Servicing Agreement have delivered one or more assessments of compliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, National Association acts as trustee of the University West Apartments Mortgage Loan and the Penn Square Mall Mortgage Loan. Pursuant to the pooling and servicing agreement for the MSBAM 2015-C27 Transaction and the trust and servicing agreement for the MSC 2016-PSQ Transaction, the trustee is required to provide an assessment of compliance with applicable servicing criteria solely with respect to Item 1122(d)(2)(iii) of Regulation AB (regarding 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). However, during the reporting period, the trustee did not perform any servicing function with respect to the servicing criteria specified in Item 1122(d)(2)(iii) of Regulation AB. The master servicer or the special servicer, to the extent required, performed the servicing function identified with respect to Item 1122(d)(2)(iii) of Regulation AB, and each such party included Item 1122(d)(2)(iii) of Regulation AB in the assessment of compliance with applicable servicing criteria and accountant’s attestation report for the subject transaction. As a result, this Annual Report on Form 10-K does not include an assessment of compliance with applicable servicing criteria of the trustee. One or more other servicers of the University West Apartments Mortgage Loan and the Penn Square Mall Mortgage Loan have delivered one or more assessments of compliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-K includes assessments of compliance with applicable servicing criteria and accountants’ attestation reports from CoreLogic Solutions, LLC. This entity was engaged by ~~the~~each master servicer under the Pooling and Servicing Agreement and ~~the~~each primary servicer of the University West Apartments Mortgage Loan and the Penn Square Mall Mortgage Loan to remit tax payments received from the escrow accounts of borrowers to local taxing authorities, to report tax amounts due, to verify tax parcel information, and to verify non-escrow tax payments. These servicing functions are included within the servicing criteria set forth in Item 1122(d)(4)(xi) of Regulation AB. Therefore, under the principles-based definition of “servicer” set forth in Item 1101(j) of Regulation AB that looks to the functions that an entity performs, this vendor is a “servicer” for the purposes of Item 1122 of Regulation AB. See Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

This Annual Report on Form 10-K includes an assessment of compliance with applicable servicing criteria, accountants’ attestation report and servicer compliance statement from Computershare Trust Company, National Association (“CTCNA”). CTCNA was engaged by Wells Fargo Bank, National Association (“Wells Fargo”), in its capacity as certificate administrator and custodian, to perform certain specified servicing functions identified in the assessment of compliance with applicable servicing criteria and accountants’ attestation reports. Wells Fargo engaged CTCNA in connection with the sale of Wells Fargo’s corporate trust services business to CTCNA and its affiliates. Further, under the principles-based definition of “servicer” set forth in Item 1101(j) of Regulation AB that looks to the functions that an entity performs, this party is a “servicer” for the purposes of Item 1123 of Regulation AB. See Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

The assessments of compliance with applicable servicing criteria, accountants’ attestation reports and servicer compliance statements of the certificate administrator of the University West Apartments Mortgage Loan, the Ellenton Premium Outlets Mortgage Loan and the Penn Square Mall Mortgage Loan are omitted from this Annual Report on Form 10-K as the certificate administrator pursuant to the related pooling and servicing agreement or trust and servicing agreement does not perform any activities that address servicing criteria with respect to the issuing entity and because they are each not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

With respect to the pari passu loan combinations that include the University West Apartments Mortgage Loan and the Ellenton Premium Outlets Mortgage Loan, (i) the reports on assessment of compliance with servicing criteria and attestation reports on assessment of compliance with servicing criteria of CWCapital Asset Management LLC as special servicer of the University West Apartments Mortgage Loan and Situs Holdings, LLC as trust advisor of the University West Apartments Mortgage Loan, listed on the Exhibit Index are omitted from this Annual Report on Form 10-K as they are not required to be included on this Annual Report on Form 10-K per Instruction 3 to Item 1122 of Regulation AB because they are parties performing activities that address servicing criteria relating to 5% or less of the assets of the issuing entity; and (ii) the servicer compliance statements of CWCapital Asset Management LLC as special servicer of the University West Apartments Mortgage Loan, Midland Loan Services, a Division of PNC Bank, National Association as primary servicer of the Ellenton Premium Outlets Mortgage Loan and Rialto Capital Advisors, LLC as special servicer of the Ellenton Premium Outlets Mortgage Loan, listed on the Exhibit Index are omitted from this Annual Report on Form 10-K as they are not required by Item 1123 of Regulation AB to be included on this Annual Report on Form 10-K because they are each an unaffiliated party that is not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

PART I

Item 1. Business.

Omitted.

Item 1A. Risk Factors.

Omitted.

Item 1B. Unresolved Staff Comments.

None.

Item 1C. Cybersecurity.

Omitted.

Item 2. Properties.

Omitted.

Item 3. Legal Proceedings.

Omitted.

Item 4. Mine Safety Disclosures.

Not applicable.

PART II

Omitted.

Item 6.

[Reserved]

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations.

Omitted.

Item 7A. Quantitative and Qualitative Disclosures About Market Risk.

Omitted.

Item 8. Financial Statements and Supplementary Data.

Omitted.

Item 9. Changes in and Disagreements With Accountants on Accounting and Financial Disclosure.

Omitted.

Item 9A. Controls and Procedures.

Omitted.

Item 9B. Other Information.

None.

Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections.

None.

PART III

Item 10. Directors, Executive Officers and Corporate Governance.

Omitted.

Item 11. Executive Compensation.

Omitted.

Item 12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters.

Omitted.

Item 14. Principal Accountant Fees and Services.

Omitted.

ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB

Item 1112(b) of Regulation AB, Significant Obligor Financial Information.

No single obligor represents 10% or more of the pool assets held by the issuing entity.

Item 1114(b)(2) of Regulation AB, Significant Enhancement Provider Financial Information.

No entity or group of affiliated entities provides any external credit enhancement or other support for the certificates within this transaction as described under Item 1114(a) of Regulation AB.

Item 1115(b) of Regulation AB, Certain Derivatives Instruments (Financial Information).

No entity or group of affiliated entities provides any derivative instruments or other support for the certificates within this transaction as described under Item 1115 of Regulation AB.

Item 1117 of Regulation AB, Legal Proceedings.

The registrant knows of no material pending legal proceeding involving the trust or any party related to the trust, other than routine litigation incidental to the duties of those respective parties, and the following, with respect to CWCapital Asset Management LLC, as as special servicer, and U.S. Bank ~~Trust Company,~~ National ~~Associate, as trustee, and Wells Fargo Bank, National~~ Association, as ~~certificate administrator,~~ trustee~~, and custodian~~.

~~On December~~From ~~17, 2015, U.S. Bank National Association, the trustee under five~~time ~~pooling~~to ~~and servicing agreements for (i) Wachovia Bank Commercial Mortgage Trust 2007-C30~~time, ~~(ii)~~CWCapital ~~COBALT~~Asset ~~CMBS~~Management ~~Commercial Trust 2007-C2~~LLC, ~~(iii) Wachovia Bank Commercial Mortgage Trust 2007-C31, (iv) ML-CFC Commercial Mortgage Trust 2007-5 and (v) ML-CFC Commercial Mortgage Trust 2007-6 commenced~~ a ~~proceeding with~~Delaware ~~the~~limited ~~Second~~liability ~~Judicial District Court of Ramsey County, Minnesota (the “State~~company ~~Court”) for a declaratory judgment as to the proper allocation of certain proceeds~~ (“~~Disputed Proceeds~~CWCAM”) ~~received by CWCAM in connection with the sale of the Peter Cooper Village and Stuyvesant Town property in New York~~, ~~New York~~is ~~securing~~a ~~loans~~party ~~held by those trusts. CWCAM was the special servicer of such property. The petition requests the State Court~~ to ~~instruct~~lawsuits ~~the trustee, the trust beneficiaries,~~ and ~~any~~ other ~~interested~~legal ~~parties~~proceedings as topart ~~the amount~~ of ~~the~~ ~~Disputed Proceeds, if any, that constitute penalty interest and/or the~~its ~~amount~~duties ofas ~~the Disputed Proceeds, if any, that constitute gain-on-sale proceeds, with respect to each trust. On February 24, 2016, CWCAM made~~ a ~~limited appearance~~special ~~with~~servicer ~~the State Court to file a motion to dismiss this proceeding based on lack of jurisdiction, mootness, standing and forum non conveniens~~(e. ~~On July 19, 2016, the State Court denied CWCAM’s motion to dismiss~~g. ~~On July 22~~, ~~2016,~~ ~~the~~enforcement action was removed to federal court in Minnesota (“Federal Court”). On October 21, 2016, the Federal Court held a hearing on the motion to transfer the action to the United States District Court for the Southern District of ~~New York~~loan ~~(“SDNY Court”~~obligations), ~~a motion to remand to state court~~ and ~~a motion to~~/or ~~hear~~arising CWCAM’s request for reconsideration of the motion to dismiss. On March 14, 2017, the Federal Court reserved the determination on the motion to hear CWCAM’s request for reconsideration of the motion to dismiss, denied the motion to remand the matter to state court and granted the motion to transfer the proceeding to the SDNY Court. Cross motions for judgment on the pleadings were filed but the SDNY Court was unable to decide the case based on the pleadings and the SDNY Court ordered discovery. All fact discovery was completed in ~~December,~~ ~~2018 and expert discovery was completed on March 15, 2019. The parties submitted cross motions for summary judgment, and on March 19, 2020,~~ the ~~SDNY Court~~ordinary ~~entered~~course ~~an opinion and order in which it granted summary judgment in CWCAM’s favor and held that CWCAM was entitled to the entire amount~~ of ~~penalty interest and that CWCAM’s determination of Yield Maintenance was correct~~business. ~~In the~~Other ~~127-page~~than ~~opinion,~~as ~~the~~set ~~SDNY~~forth ~~Court found for CWCAM on every issue presented by the trustee’s petition, namely, that the funds~~ in ~~dispute constitute penalty interest and yield maintenance, not gain-on-sale proceeds, and that~~ the ~~amount~~ offollowing ~~penalty interest and yield maintenance was correctly calculated. An appeal of the SDNY Court’s decision was taken on April 29~~paragraphs, ~~2020.~~there Oral argument on the appeal occurred on June 21, 2021. On July 14, 2022, the Second Circuit entered a decision affirming in part and reversing in part the SDNY Court’s decision and remanding to the SDNY Court for further proceedings. The Second Circuit affirmed the SDNY’s Court holding that Penalty Interest and Yield Maintenance are ~~paid~~currently ~~before~~no ~~Gain-On-Sale~~legal ~~Proceeds. The Second Circuit reversed and remanded for further~~ proceedings ~~that portion of the SDNY Court’s decision related to approximately $67.2 million in interest on advances. On January 13~~pending, 2023, the parties entered into a settlement agreement, in which (among other things) they agreed to stipulate that the amount of Interest on advances that accrued on or before June 3, 2014 is $27.5 million, and ~~that CWCAM would pay that amount into~~no ~~escrow~~legal ~~for~~proceedings ~~distribution~~known to ~~certificateholders~~be ~~upon~~contemplated ~~the entry of an order~~ by ~~the Court~~governmental ~~approving the settlement. U.S. Bank National Association~~authorities, ~~as Trustee for~~against ~~the~~CWCAM ~~trusts,~~or ~~provided notice~~ of ~~the~~which ~~settlement~~any to all parties in interest via a notice program approved by the Court. A hearing on the settlement was scheduled for March 16, 2023 and was continued to May 5, 2023. The court approved the settlement in a decision dated April 8, 2024. An appeal of ~~the~~its ~~Court’s~~property ~~decision was filed by one party, Cobalt LLC, which~~ is ~~believed to be focused solely on~~ the ~~timing~~subject, ofthat ~~the~~are ~~distribution~~material ~~of the $27.5 million and not with respect~~ to ~~CWCAM’s~~ ~~liability or~~ the ~~amount paid. The appeal brief is due on September 1,~~ ~~2024~~certificateholders. ~~The matter was subsequently resolved by the parties and approved by the Court and no further proceedings are required. The matter is closed.~~

On December 1, 2017, a complaint against CWCAM and others was filed in the United States District Court for the Southern District of New York styled as CWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., No. 17-cv-9463 (the “Original Complaint”). The gravamen of the Original Complaint alleged breaches of a contract and fiduciary duties by CWCAM’s affiliate, CWCapital Investments LLC in its capacity as collateral manager for the collateralized debt obligation transaction involving CWCapital Cobalt Vr, Ltd. In total, there are 14 counts pled in the Original Complaint. Of those 14, 5 claims were asserted against CWCAM for aiding and abetting breach of fiduciary duty, conversion and unjust enrichment. On May 23, 2018, the Original Complaint was dismissed for lack of subject matter jurisdiction. On June 28, 2018, CWCapital Cobalt Vr Ltd. filed a substantially similar complaint in the Supreme Court of the State of New York, County of New York styled as CWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., Index No. 653277/2018 (the “New Complaint”). The gravamen of the New Complaint is the same as the previous complaint filed in the United State District Court for the Southern District of New York. In total there are 16 counts pled in the New Complaint. Of those 16 counts, 5 claims were asserted against CWCAM for aiding and abetting breach of fiduciary duty, conversion and unjust enrichment, 1 count seeks a declaratory judgement that the plaintiff has the right to enforce the contracts in question and 1 count seeks an injunction requiring the defendants to recognize the plaintiff as the directing holder for the trusts in question. On January 11, 2019, the plaintiff dismissed with prejudice the declaratory judgment and injunction counts. The New Complaint and related summons was not served on the defendants until July 13, 2018 and July 16, 2018. The plaintiff’s motion for a preliminary injunction was denied by the court on July 31, 2018. On August 3, 2018, the defendants, including CWCAM, filed a motion to dismiss the New Complaint in its entirety. On August 20, 2019, the court entered an order granting defendants’ motion almost in its entirety, dismissing 11 of the 16 counts and partially dismissing 2 additional counts. Of the remaining counts, 2 are asserted against CWCAM for aiding and abetting breach of fiduciary duty and unjust enrichment. On September 19, 2019, CWCapital Cobalt Vr Ltd. filed a notice of appeal relating to the August 20, 2019 dismissal order and on September 26, 2019, filed an amended ~~complaint~~ complaint against CWCI and CWCAM attempting to address deficiencies relating to ~~certain~~ certain of the claims dismissed by the August, 20, 2019 order. CWCI and CWCAM filed its Motion to Dismiss the amended complaint on October 28, 2019. The court heard argument on the Motion to Dismiss the amended complaint on January 22, 2020 and on October 23, 2020, the court granted the motion dismissing the ~~amended~~ amended claims. On November 30, 2020, CWCapital Cobalt Vr Ltd filed a notice of ~~appeal~~ appeal relating to the October 23, 2020 dismissal order. On April 27, 2021, the ~~First~~ First Department affirmed the dismissal as to claims against CWCAM that were part of the August 20, 2019 dismissal, but reversed the dismissal of two counts ~~for~~ for breach of the Collateral Management Agreement against CWCI. CWCI sought ~~leave~~ leave to file an appeal of the decision. The plaintiff also sought leave to ~~appeal~~ appeal the dismissal of the claims against CWCAM. Both requests for leave were ~~denied~~ denied by the First Department. On May 15, 2020, CWCI and CWCAM filed a motion to to renew its motion to dismiss as to 4 of the remaining counts (including the remaining two counts against CWCAM for aiding and abetting breach of fiduciary duty and unjust enrichment), based on a decision entered by Judge Failla in a trust instruction proceeding in the US District Court for the Southern District of New York awarding summary judgment in favor of CWCAM. On September 7, 2021, the court denied the motion to renew. CWCI and CWCAM filed a notice of appeal, which they perfected by the filing of their opening brief on July 1, 2022. On November 15, 2022, the First Department affirmed the court’s denial of the motion to renew. On October 1, 2021, CWCI and CWCAM moved to reargue the denial of the motion to renew (or alternatively, the motion to dismiss) with respect to certain of Cobalt’s claims, including the remaining 2 claims against CWCAM, based on the First Department’s April 27, 2021 decision. On March 24, 2022, the court denied the relief sought in the motion to reargue. CWCI and CWCAM appealed the court’s decision on the motion to reargue and filed their opening brief on July 11, 2022. The appeal was dismissed as being non-appealable on August 30, 2022. Discovery (both fact and expert) concluded on March 1, 2024. CWCAM and CWCI filed a motion for summary judgment on March 29, 2024, seeking dismissal of all the claims in their entirety. On that same date, the plaintiff cross moved for summary judgment on one of the claims asserted against only CWCI. ~~Summary~~Oral ~~judgment~~argument ~~briefing~~on isthe ~~scheduled~~parties’ tosummary ~~conclude~~judgment onmotions ~~June~~were 18heard on October 22, 2024. ~~Oral~~. On January 13, 2026, the court denied plaintiff’s motion for ~~argument~~summary ~~was~~judgment ~~heard~~and ongranted, ~~October~~in 22part, ~~2024~~and denied, in part, the motion filed by CWCI and CWCAM. Specifically, the court ~~has~~dismissed ~~taken~~the remaining two counts against CWCAM for aiding and abetting breach of fiduciary duty and unjust enrichment. With respect to CWCI, the ~~arguments~~court dismissed two counts against CWCI ~~under~~in ~~consideration~~their entirety and dismissed portions of one count against CWCI. The ~~timing~~only three ofcounts athat ~~decision~~survived isand ~~unknown~~remain in the case are against CWCI. The court severed the dismissed claims from the surviving claims. On January 22, 2026, CWCI and CWCAM ~~believes~~submitted an order to the court, requesting that it ~~has~~direct ~~performed~~the clerk’s ~~its~~office ~~obligations~~to ~~under~~enter judgment on the ~~related~~dismissed ~~pooling~~claims and ~~servicing~~that ~~agreements~~CWCAM be indismissed ~~good~~as ~~faith~~a ~~and~~defendant from the ~~remaining~~action. ~~allegations~~CWCAM inbelieves that it has performed its obligations under the ~~New~~related ~~Complaint~~pooling ~~are~~and ~~without~~servicing agreements in good ~~merit~~faith.

On January 13, 2025, in the Supreme Court of the State of New York, ROC Debt Strategies II Bond Investments LLC (“Bridge Investment Group or “Bridge”), as Directing Certificateholder (“DCH”) filed suit against CWCapital Asset Management LLC (“CWCAM”), alleging breach of the subject Pooling and Servicing Agreement (“PSA”) and violation of the Servicing Standard while acting as special servicer for the FREMF 2016-KS06 pool. It is alleged that CWCAM was negligent in the servicing of a portfolio of 9 loans (the “Ranger Portfolio”) that were in special servicing starting in 2022. The suit demands unspecified compensatory damages and a Declaratory Judgment that CWCAM is not entitled to indemnification or payment for expenses from the Trust under the PSA. CWCAM disagrees vehemently with these allegations and a Motion to Dismiss was filed by CWCAM on March 14, 2025. The motion has been fully briefed and a hearing was held on August 25, 2025 While that motion was pending, the parties reached a business resolution and by stipulation the lawsuit was dismissed with prejudice on January 22, 2026.

U.S. Bank National Association (“U.S. Bank”) and other large financial institutions have been sued in their capacity as trustee or successor trustee for certain residential mortgage backed securities ("RMBS") trusts. The complaints, primarily filed by investors or investor groups against U.S. Bank and similar institutions, allege the trustees caused losses to investors as a result of alleged failures by the sponsors, mortgage loan sellers and servicers to comply with the governing agreements for these RMBS trusts. Plaintiffs generally assert causes of action based upon the trustees’ purported failures to enforce repurchase obligations of mortgage loan sellers for alleged breaches of representations and warranties, notify securityholders of purported events of default allegedly caused by breaches of servicing standards by mortgage loan servicers and abide by a heightened standard of care following alleged events of default.

U.S. Bank denies liability and believes that it has performed its obligations under the RMBS trusts in good faith, that its actions were not the cause of losses to investors, that it has meritorious defenses, and it has contested and intends to continue contesting the plaintiffs’ claims vigorously. However, U.S. Bank cannot assure you as to the outcome of any of the litigation, or the possible impact of these litigations on the trustee or the RMBS trusts.

On March 9, 2018, a law firm purporting to represent fifteen Delaware statutory trusts (the “DSTs”) that issued securities backed by student loans (the “Student Loans”) filed a lawsuit in the Delaware Court of Chancery against U.S. Bank National Association (“U.S. Bank”) in its capacities as indenture trustee and successor special servicer, and three other institutions in their respective transaction capacities, with respect to the DSTs and the Student Loans. This lawsuit is captioned The National Collegiate Student Loan Master Trust I, et al. v. U.S. Bank National Association, et al., C.A. No. 2018-0167-JRS (Del. Ch.) (the “NCMSLT Action”). The complaint, as amended on June 15, 2018, alleged that the DSTs have been harmed as a result of purported misconduct or omissions by the defendants concerning administration of the trusts and special servicing of the Student Loans. Since the filing of the NCMSLT Action, certain Student Loan borrowers have made assertions against U.S. Bank concerning special servicing that appear to be based on certain allegations made on behalf of the DSTs in the NCMSLT Action.

U.S. Bank has filed a motion seeking dismissal of the operative complaint in its entirety with prejudice pursuant to Chancery Court Rules 12(b)(1) and 12(b)(6) or, in the alternative, a stay of the case while other prior filed disputes involving the DSTs and the Student Loans are litigated. On November 7, 2018, the Court ruled that the case should be stayed in its entirety pending resolution of the first-filed cases. On January 21, 2020, the Court entered an order consolidating for pretrial purposes the NCMSLT Action and three other lawsuits pending in the Delaware Court of Chancery concerning the DSTs and the Student Loans, which remains pending.

U.S. Bank denies liability in the NCMSLT Action and believes it has performed its obligations as indenture trustee and special servicer in good faith and in compliance in all material respects with the terms of the agreements governing the DSTs and that it has meritorious defenses. It has contested and intends to continue contesting the plaintiffs’ claims vigorously.

In December 2014, Phoenix Light SF Limited (Phoenix Light) and certain related entities filed a complaint in the United States District Court for the Southern District of New York alleging claims against Wells Fargo Bank, N.A., in its capacity as trustee for a number of residential mortgage-backed securities (RMBS) trusts. Complaints raising similar allegations have been filed by Commerzbank AG in the Southern District of New York, IKB International and IKB Deutsche Industriebank (together, IKB) in New York state court, and Park Royal I LLC and Park Royal II LLC in New York state court. In each case, the plaintiffs allege that Wells Fargo Bank, N.A., as trustee, caused losses to investors, and plaintiffs assert causes of action based upon, among other things, the trustee’s alleged failure to notify and enforce repurchase obligations of mortgage loan sellers for purported breaches of representations and warranties, notify investors of alleged events of default, and abide by appropriate standards of care following alleged events of default. In July 2022, the district court dismissed Phoenix Light’s claims and certain of the claims asserted by Commerzbank AG, and subsequently entered judgment in each case in favor of Wells Fargo Bank, N.A. In August 2022, Phoenix Light and Commerzbank AG each appealed the district court’s decision to the United States Court of Appeals for the Second Circuit. Phoenix Light dismissed its appeal in May 2023, terminating its case. In October 2024, the Second Circuit denied Commerzbank AG’s appeal. In November 2023, Wells Fargo Bank, N.A. entered into an agreement with IKB to resolve IKB’s claims. Wells Fargo Bank, N.A. previously settled two class actions filed by institutional investors and an action filed by the National Credit Union Administration with similar allegations.

Item 1119 of Regulation AB, Affiliations and Certain Relationships and Related Transactions.

The information regarding this Item has been previously provided in the prospectus of the Registrant relating to the issuing entity filed on February 25, 2016 pursuant to Rule 424(b)(2).

Item 1122 of Regulation AB, Compliance with Applicable Servicing Criteria.

The reports on assessments of compliance with the servicing criteria for asset-backed securities and related attestation reports on such assessments of compliance with respect to the mortgage loans are attached hereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to the Pooling and Servicing Agreement incorporated by reference as Exhibit 4.1 to this Annual Report on Form 10-K is a chart identifying the entities participating in a servicing function for the transaction responsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicing criteria for asset-backed securities and related attestation reports on such assessments of compliance with respect to the University West Apartments Mortgage Loan, which is being serviced and administered pursuant to the pooling and servicing agreement for the MSBAM 2015-C27 Transaction, are attached hereto under Item 15 to this Annual Report on Form 10-K. Attached as Schedule X to the pooling and servicing agreement for the MSBAM 2015-C27 Transaction incorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K is a chart identifying the entities participating in a servicing function for the MSBAM 2015-C27 Transaction responsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicing criteria for asset-backed securities and related attestation reports on such assessments of compliance with respect to the Ellenton Premium Outlets Mortgage Loan, which is being serviced and administered pursuant to the pooling and servicing agreement for the MSC 2015-UBS8 Transaction, are attached hereto under Item 15 to this Annual Report on Form 10-K. Attached as Schedule X to the pooling and servicing agreement for the MSC 2015-UBS8 Transaction incorporated by reference as Exhibit 4.3 to this Annual Report on Form 10-K is a chart identifying the entities participating in a servicing function for the MSC 2015-UBS8 Transaction responsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicing criteria for asset-backed securities and related attestation reports on such assessments of compliance with respect to the Penn Square Mall Mortgage Loan, which is being serviced and administered pursuant to the trust and servicing agreement for the MSC 2016-PSQ Transaction, are attached hereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit L to the trust and servicing agreement for the MSC 2016-PSQ Transaction incorporated by reference as Exhibit 4.4 to this Annual Report on Form 10-K is a chart identifying the entities participating in a servicing function for the MSC 2016-PSQ Transaction responsible for each applicable servicing criteria set forth in Item 1122(d).

Item 1123 of Regulation AB, Servicer Compliance Statement.

The servicer compliance statements are attached as Exhibits to this Annual Report on Form 10-K.

PART IV

Item 15. Exhibits and Financial Statement Schedules

(a) The following is a list of documents filed as part of this Annual Report on Form 10-K:

(1) Not applicable

(2) Not applicable

(3) See below

4.1 Pooling and Servicing Agreement, dated as of February 1, 2016, by and among Banc of America Merrill Lynch Commercial Mortgage Inc., as Depositor, Wells Fargo Bank, National Association, as Master Servicer, C-III Asset Management LLC, as Special Servicer, Wells Fargo Bank, National Association, as Certificate Administrator, U.S. Bank National Association, as Trustee, Park Bridge Lender Services LLC, as Operating Advisor, and Park Bridge Lender Services LLC, as Asset Representations Reviewer (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-K/A filed on March 8, 2016 under Commission File No. 333-206847-01 and incorporated by reference herein).

4.2 Pooling and Servicing Agreement, dated as of November 1, 2015, by and among Morgan Stanley Capital I Inc., as Depositor, Wells Fargo Bank, National Association, as Master Servicer, CWCapital Asset Management LLC, as Special Servicer, Situs Holdings, LLC, as Trust Advisor, Wilmington Trust, National Association, as Trustee, and Wells Fargo Bank, National Association, as Certificate Administrator, Certificate Registrar, Authenticating Agent and Custodian (filed as Exhibit 4.5 to the registrant’s Current Report on Form 8-K filed on February 25, 2016 under Commission File No. 333-206847-01 and incorporated by reference herein).

4.3 Pooling and Servicing Agreement, dated as of December 1, 2015, by and among Morgan Stanley Capital I Inc., as Depositor, Midland Loan Services, a Division of PNC Bank, National Association, as Master Servicer, Rialto Capital Advisors, LLC, as Special Servicer, Situs Holdings, LLC, Trust Advisor, and Wells Fargo Bank, National Association, as Trustee, Certificate Administrator, Certificate Registrar, Authenticating Agent and Custodian (filed as Exhibit 4.3 to the registrant’s Current Report on Form 8-K filed on February 25, 2016 under Commission File No. 333-206847-01 and incorporated by reference herein).

4.4 Trust and Servicing Agreement, dated as of February 1, 2016, by and among Morgan Stanley Capital I Inc., as Depositor, Wells Fargo Bank, National Association, as Servicer and Special Servicer, Wilmington Trust, National Association, as Trustee and Wells Fargo Bank, National Association, as Certificate Administrator (filed as Exhibit 4.2 to the registrant’s Current Report on Form 8-K filed on February 25, 2016 under Commission File No. 333-206847-01 and incorporated by reference herein).

4.5 Amended And Restated Agreement Between Note Holders, dated as of April 21, 2016, by and between U.S. Bank National Association, as Trustee for Morgan Stanley Bank of America Merrill Lynch Trust 2016-C28, Commercial Mortgage Pass-Through Certificates, Series 2016-C28, as Note A-1 Holder, Wells Fargo Bank, National Association, as Trustee for Morgan Stanley Capital I Trust 2016-UBS9, Commercial Mortgage Pass-Through Certificates, Series 2016-UBS9, as Note A-2 Holder, Morgan Stanley Bank, N.A., as Note A-3 Holder, and Morgan Stanley Bank, N.A., as Note A-4 Holder (filed as Exhibit 4.12 to the registrant’s Current Report on Form 8-K filed on April 27, 2016 under Commission File No. 333-206847-01 and incorporated by reference herein).

4.6 Agreement Between Note Holders, dated as of October 28, 2015, by and between Bank of America, N.A., as Initial Note A-1 Holder, and Bank of America, N.A., as Initial Note A-2 Holder (filed as Exhibit 4.11 to the registrant’s Current Report on Form 8-K filed on February 25, 2016 under Commission File No. 333-206847-01 and incorporated by reference herein).

4.7 Agreement Between Note Holders, dated as of November 5, 2015, by and between UBS Real Estate Securities Inc., as Initial Note A-1 Holder, UBS Real Estate Securities Inc., as Initial Note A-2 Holder, UBS Real Estate Securities Inc., as Initial Note A-3 Holder, and Bank of America, N.A., as Initial Note A-4 Holder (filed as Exhibit 4.9 to the registrant’s Current Report on Form 8-K filed on February 25, 2016 under Commission File No. 333-206847-01 and incorporated by reference herein).

4.8 Agreement Between Note Holders, dated as of February 11, 2016, by and between Morgan Stanley Bank, N.A., as Initial Note A-1A Holder, Morgan Stanley Bank, N.A., as Initial Note A-1B Holder, Morgan Stanley Bank, N.A., as Initial Note A-1C Holder, and Morgan Stanley Bank, N.A., as Initial Note A-2 Holder (filed as Exhibit 4.8 to the registrant’s Current Report on Form 8-K filed on February 25, 2016 under Commission File No. 333-206847-01 and incorporated by reference herein).

31 Rule 13a-14(d)/15d-14(d) Certifications.

33 Reports on assessment of compliance with servicing criteria for asset-backed securities.

33.1 Wells Fargo Bank, National Association, as Master Servicer prior to March 1, 2025

33.2 ~~Greystone~~Trimont ~~Servicing Company~~ LLC, (as ~~successor~~Master ~~to C-III~~Servicer ~~Asset~~on ~~Management~~and ~~LLC)~~after March 1, ~~as Special Servicer~~2025

33.3 ~~U.S.~~Greystone ~~Bank~~Servicing ~~National~~Company ~~Association,~~LLC (as ~~Trustee~~successor ~~(Omitted.~~to C-III ~~See~~Asset ~~Explanatory~~Management ~~Notes.~~LLC), as Special Servicer

33.4 ~~Wells~~U.S. ~~Fargo~~ Bank, National Association, as ~~Certificate~~ ~~Administrator~~Trustee (Omitted. See Explanatory Notes.)

33.5 Wells Fargo Bank, National Association, as ~~Custodian~~Certificate Administrator

33.6 ~~Park~~Wells ~~Bridge~~Fargo ~~Lender~~Bank, ~~Services~~National ~~LLC~~Association, as ~~Operating~~ ~~Advisor~~Custodian

33.7 ~~CoreLogic~~Park ~~Solutions,~~Bridge Lender Services LLC, as ~~Servicing Function~~Operating ~~Participant~~Advisor

33.8 ~~Computershare~~CoreLogic ~~Trust Company~~Solutions, ~~National Association~~LLC, as Servicing Function Participant ~~for the Certificate Administrator~~

33.9 Computershare Trust Company, National Association, as Servicing Function Participant for the ~~Custodian~~Certificate Administrator

33.10 ~~Wells~~ Computershare ~~Fargo~~Trust ~~Bank~~Company, National Association, as ~~Primary~~ ~~Servicer~~Servicing ofFunction ~~the~~Participant ~~Princeton~~for ~~Pike~~the ~~Corporate Center Mortgage Loan (see Exhibit 33.1)~~Custodian

33.11 ~~Greystone~~Wells ~~Servicing~~Fargo ~~Company~~Bank, ~~LLC~~National ~~(as successor to C-III Asset Management LLC)~~Association, as ~~Special~~ Primary Servicer of the Princeton Pike Corporate Center Mortgage Loan prior to March 1, 2025 (see Exhibit 33.21)

33.12 ~~U.S.~~Trimont ~~Bank National Association~~LLC, as ~~Trustee~~Primary Servicer of the Princeton Pike Corporate Center Mortgage Loan ~~(Omitted.~~on ~~See~~and ~~Explanatory~~after ~~Notes~~March 1, 2025 (see Exhibit 33.2)

33.13 ~~Wells~~Greystone ~~Fargo~~Servicing ~~Bank,~~Company ~~National~~LLC ~~Association~~(as successor to C-III Asset Management LLC), as ~~Custodian~~ Special Servicer of the Princeton Pike Corporate Center Mortgage Loan (see Exhibit 33.53)

33.14 ~~Park~~U.S. ~~Bridge~~Bank ~~Lender~~National ~~Services LLC~~Association, as ~~Operating Advisor~~Trustee of the Princeton Pike Corporate Center Mortgage Loan (~~see~~Omitted. ~~Exhibit~~See 33Explanatory Notes.6)

33.15 ~~CoreLogic~~Wells ~~Solutions,~~Fargo ~~LLC~~Bank, asNational ~~Servicing~~Association, ~~Function~~as ~~Participant~~Custodian of the Princeton Pike Corporate Center Mortgage Loan (see Exhibit 33.76)

33.16 ~~Computershare~~Park ~~Trust~~Bridge ~~Company,~~Lender ~~National~~Services ~~Association~~LLC, as ~~Servicing~~Operating Advisor ~~Function~~of ~~Participant~~the ~~for~~Princeton ~~the~~Pike ~~Custodian~~Corporate Center Mortgage Loan (see Exhibit 33.97)

33.17 ~~Wells~~CoreLogic ~~Fargo Bank~~Solutions, ~~National Association~~LLC, as ~~Primary~~Servicing Function ~~Servicer~~Participant of the ~~University~~Princeton ~~West~~Pike ~~Apartments~~Corporate Center Mortgage Loan (see Exhibit 33.18)

33.18 ~~CWCapital~~Computershare ~~Asset~~Trust ~~Management LLC~~Company, National Association, as ~~Special~~Servicing ~~Servicer~~Function ofParticipant for the ~~University~~Custodian ~~West Apartments Mortgage Loan~~ (~~Omitted.~~see ~~See~~Exhibit ~~Explanatory Notes~~33.10)

33.19 ~~Wilmington~~Wells ~~Trust~~Fargo Bank, National Association, as ~~Trustee~~Primary Servicer of the University West Apartments Mortgage Loan ~~(Omitted.~~prior ~~See~~to ~~Explanatory~~March ~~Notes~~1, 2025 (see Exhibit 33.1)

33.20 ~~Wells~~Trimont ~~Fargo Bank~~LLC, ~~National~~as ~~Association,~~Primary ~~as Custodian~~Servicer of the University West Apartments Mortgage Loan on and after March 1, 2025 (see Exhibit 33.52)

33.21 ~~Situs~~CWCapital ~~Holdings,~~Asset Management LLC, as ~~Trust~~Special ~~Advisor~~Servicer of the University West ~~Apartments~~ Apartments Mortgage Loan (Omitted. See Explanatory Notes.)

33.22 ~~CoreLogic~~Wilmington ~~Solutions~~Trust, ~~LLC~~National Association, as ~~Servicing~~Trustee ~~Function Participant~~ of the University West Apartments Mortgage Loan (~~see~~Omitted. ~~Exhibit~~See 33Explanatory Notes.7)

33.23 ~~Computershare~~Wells ~~Trust~~Fargo ~~Company~~Bank, National Association, as Custodian ~~Servicing~~of ~~Function~~the ~~Participant~~University ~~for~~West ~~the~~Apartments ~~Custodian~~Mortgage Loan (see Exhibit 33.96)

33.24 ~~Midland~~Situs ~~Loan Services~~Holdings, ~~a Division of PNC Bank~~LLC, ~~National~~ ~~Association,~~ as ~~Primary~~Trust ~~Servicer~~Advisor of the ~~Ellenton~~University ~~Premium~~West ~~Outlets~~Apartments Mortgage Loan (Omitted. See Explanatory Notes.)

33.25 ~~Rialto~~CoreLogic ~~Capital Advisors~~Solutions, LLC, as ~~Special~~Servicing ~~Servicer~~Function Participant of the ~~Ellenton~~University ~~Premium~~West ~~Outlets~~Apartments Mortgage Loan (see Exhibit 33.8)

33.26 ~~Wells~~Computershare ~~Fargo~~Trust ~~Bank~~Company, National Association, as ~~Trustee~~Servicing ofFunction ~~the~~Participant ~~Ellenton~~for ~~Premium Outlets~~the ~~Mortgage~~Custodian ~~Loan~~ (~~Omitted.~~see ~~See~~Exhibit ~~Explanatory Notes~~33.10)

33.27 ~~Wells~~Midland ~~Fargo~~Loan ~~Bank~~Services, a Division of PNC Bank, National Association, as ~~Custodian~~ Primary Servicer of the Ellenton Premium Outlets Mortgage Loan ~~(see Exhibit 33.5)~~

33.28 ~~Park~~Rialto ~~Bridge~~Capital ~~Lender~~Advisors, ~~Services~~ LLC, as ~~Operating Advisor~~Special Servicer of the Ellenton Premium Outlets Mortgage Loan ~~(see Exhibit 33.6)~~

33.29 ~~Computershare~~Wells ~~Trust~~Fargo ~~Company~~Bank, National Association, as ~~Servicing~~Trustee ~~Function~~of ~~Participant~~the ~~for~~Ellenton ~~the~~Premium Outlets ~~Custodian~~Mortgage Loan (~~see~~Omitted. ~~Exhibit~~See 33Explanatory Notes.9)

33.30 Wells Fargo Bank, National Association, as ~~Primary~~ ~~Servicer~~Custodian of the ~~Penn~~Ellenton ~~Square~~Premium ~~Mall~~Outlets Mortgage Loan (see Exhibit 33.16)

33.31 ~~Wells~~Park ~~Fargo~~Bridge ~~Bank,~~Lender ~~National~~Services ~~Association~~LLC, as ~~Special~~Operating ~~Servicer~~Advisor of the ~~Penn~~Ellenton ~~Square~~Premium ~~Mall~~Outlets Mortgage Loan (see Exhibit 33.17)

33.32 ~~Wilmington~~Computershare Trust Company, National Association, as ~~Trustee~~Servicing ofFunction ~~the~~Participant ~~Penn~~for ~~Square~~the ~~Mall Mortgage~~Custodian ~~Loan~~ (~~Omitted.~~see ~~See~~Exhibit ~~Explanatory Notes~~33.10)

33.33 Wells Fargo Bank, National Association, as Primary ~~Custodian~~Servicer of the Penn Square Mall Mortgage Loan prior to March 1, 2025 (see Exhibit 33.51)

33.34 ~~CoreLogic~~Trimont ~~Solutions,~~ LLC, as ~~Servicing~~Primary ~~Function Participant~~Servicer of the Penn Square Mall Mortgage Loan on and after March 1, 2025 (see Exhibit 33.72)

33.35 ~~Computershare~~Wells ~~Trust~~Fargo ~~Company~~Bank, National Association, as ~~Servicing~~Special Servicer ~~Function~~of ~~Participant~~the ~~for~~Penn ~~the~~Square ~~Custodian~~Mall Mortgage Loan prior to March 1, 2025 (see Exhibit 33.91)

33.36 Trimont LLC, as Special Servicer of the Penn Square Mall Mortgage Loan on and after March 1, 2025 (see Exhibit 33.2)

33.37 Wilmington Trust, National Association, as Trustee of the Penn Square Mall Mortgage Loan (Omitted. See Explanatory Notes.)

33.38 Wells Fargo Bank, National Association, as Custodian of the Penn Square Mall Mortgage Loan (see Exhibit 33.6)

33.39 CoreLogic Solutions, LLC, as Servicing Function Participant of the Penn Square Mall Mortgage Loan (see Exhibit 33.8)

33.40 Computershare Trust Company, National Association, as Servicing Function Participant for the Custodian (see Exhibit 33.10)

34 Attestation reports on assessment of compliance with servicing criteria for asset-backed securities.

34.1 Wells Fargo Bank, National Association, as Master Servicer prior to March 1, 2025

34.2 ~~Greystone~~Trimont ~~Servicing Company~~ LLC, (as ~~successor~~Master ~~to C-III~~Servicer ~~Asset~~on ~~Management~~and ~~LLC)~~after March 1, ~~as Special Servicer~~2025

34.3 ~~U.S.~~Greystone ~~Bank~~Servicing ~~National~~Company ~~Association,~~LLC (as ~~Trustee~~successor ~~(Omitted.~~to C-III ~~See~~Asset ~~Explanatory~~Management ~~Notes.~~LLC), as Special Servicer

34.4 ~~Wells~~U.S. ~~Fargo~~ Bank, National Association, as ~~Certificate~~ ~~Administrator~~Trustee (Omitted. See Explanatory Notes.)

34.5 Wells Fargo Bank, National Association, as ~~Custodian~~Certificate Administrator

34.6 ~~Park~~Wells ~~Bridge~~Fargo ~~Lender~~Bank, ~~Services~~National ~~LLC~~Association, as ~~Operating~~ ~~Advisor~~Custodian

34.7 ~~CoreLogic~~Park ~~Solutions,~~Bridge Lender Services LLC, as ~~Servicing Function~~Operating ~~Participant~~Advisor

34.8 ~~Computershare~~CoreLogic ~~Trust Company~~Solutions, ~~National Association~~LLC, as Servicing Function Participant ~~for the Certificate Administrator~~

34.9 Computershare Trust Company, National Association, as Servicing Function Participant for the ~~Custodian~~Certificate Administrator

34.10 ~~Wells~~ Computershare ~~Fargo~~Trust ~~Bank~~Company, National Association, as ~~Primary~~ ~~Servicer~~Servicing ofFunction ~~the~~Participant ~~Princeton~~for ~~Pike~~the ~~Corporate Center Mortgage Loan (see Exhibit 34.1)~~Custodian

34.11 ~~Greystone~~Wells ~~Servicing~~Fargo ~~Company~~Bank, ~~LLC~~National ~~(as successor to C-III Asset Management LLC)~~Association, as ~~Special~~ Primary Servicer of the Princeton Pike Corporate Center Mortgage Loan prior to March 1, 2025 (see Exhibit 34.21)

34.12 ~~U.S.~~Trimont ~~Bank National Association~~LLC, as ~~Trustee~~Primary Servicer of the Princeton Pike Corporate Center Mortgage Loan ~~(Omitted.~~on ~~See~~and ~~Explanatory~~after ~~Notes~~March 1, 2025 (see Exhibit 34.2)

34.13 ~~Wells~~Greystone ~~Fargo~~Servicing ~~Bank,~~Company ~~National~~LLC ~~Association~~(as successor to C-III Asset Management LLC), as ~~Custodian~~ Special Servicer of the Princeton Pike Corporate Center Mortgage Loan (see Exhibit 34.53)

34.14 ~~Park~~U.S. ~~Bridge~~Bank ~~Lender~~National ~~Services LLC~~Association, as ~~Operating Advisor~~Trustee of the Princeton Pike Corporate Center Mortgage Loan (~~see~~Omitted. ~~Exhibit~~See 34Explanatory Notes.6)

34.15 ~~CoreLogic~~Wells ~~Solutions,~~Fargo ~~LLC~~Bank, asNational ~~Servicing~~Association, ~~Function~~as ~~Participant~~Custodian of the Princeton Pike Corporate Center Mortgage Loan (see Exhibit 34.76)

34.16 ~~Computershare~~Park ~~Trust~~Bridge ~~Company,~~Lender ~~National~~Services ~~Association~~LLC, as ~~Servicing~~Operating Advisor ~~Function~~of ~~Participant~~the ~~for~~Princeton ~~the~~Pike ~~Custodian~~Corporate Center Mortgage Loan (see Exhibit 34.97)

34.17 ~~Wells~~CoreLogic ~~Fargo Bank~~Solutions, ~~National Association~~LLC, as ~~Primary~~Servicing Function ~~Servicer~~Participant of the ~~University~~Princeton ~~West~~Pike ~~Apartments~~Corporate Center Mortgage Loan (see Exhibit 34.18)

34.18 ~~CWCapital~~Computershare ~~Asset~~Trust ~~Management LLC~~Company, National Association, as ~~Special~~Servicing ~~Servicer~~Function ofParticipant for the ~~University~~Custodian ~~West Apartments Mortgage Loan~~ (~~Omitted.~~see ~~See~~Exhibit ~~Explanatory Notes~~34.10)

34.19 ~~Wilmington~~Wells ~~Trust~~Fargo Bank, National Association, as ~~Trustee~~Primary Servicer of the University West Apartments Mortgage Loan ~~(Omitted.~~prior ~~See~~to ~~Explanatory~~March ~~Notes~~1, 2025 (see Exhibit 34.1)

34.20 ~~Wells~~Trimont ~~Fargo Bank~~LLC, ~~National~~as ~~Association,~~Primary ~~as Custodian~~Servicer of the University West Apartments Mortgage Loan on and after March 1, 2025 (see Exhibit 34.52)

34.21 ~~Situs~~CWCapital ~~Holdings,~~Asset Management LLC, as ~~Trust~~Special ~~Advisor~~Servicer of the University West ~~Apartments~~ Apartments Mortgage Loan (Omitted. See Explanatory Notes.)

34.22 ~~CoreLogic~~Wilmington ~~Solutions~~Trust, ~~LLC~~National Association, as ~~Servicing~~Trustee ~~Function Participant~~ of the University West Apartments Mortgage Loan (~~see~~Omitted. ~~Exhibit~~See 34Explanatory Notes.7)

34.23 ~~Computershare~~Wells ~~Trust~~Fargo ~~Company~~Bank, National Association, as Custodian ~~Servicing~~of ~~Function~~the ~~Participant~~University ~~for~~West ~~the~~Apartments ~~Custodian~~Mortgage Loan (see Exhibit 34.96)

34.24 ~~Midland~~Situs ~~Loan Services~~Holdings, ~~a Division of PNC Bank~~LLC, ~~National~~ ~~Association,~~ as ~~Primary~~Trust ~~Servicer~~Advisor of the ~~Ellenton~~University ~~Premium~~West ~~Outlets~~Apartments Mortgage Loan (Omitted. See Explanatory Notes.)

34.25 ~~Rialto~~CoreLogic ~~Capital Advisors~~Solutions, LLC, as ~~Special~~Servicing ~~Servicer~~Function Participant of the ~~Ellenton~~University ~~Premium~~West ~~Outlets~~Apartments Mortgage Loan (see Exhibit 34.8)

34.26 ~~Wells~~Computershare ~~Fargo~~Trust ~~Bank~~Company, National Association, as ~~Trustee~~Servicing ofFunction ~~the~~Participant ~~Ellenton~~for ~~Premium Outlets~~the ~~Mortgage~~Custodian ~~Loan~~ (~~Omitted.~~see ~~See~~Exhibit ~~Explanatory Notes~~34.10)

34.27 ~~Wells~~Midland ~~Fargo~~Loan ~~Bank~~Services, a Division of PNC Bank, National Association, as ~~Custodian~~ Primary Servicer of the Ellenton Premium Outlets Mortgage Loan ~~(see Exhibit 34.5)~~

34.28 ~~Park~~Rialto ~~Bridge~~Capital ~~Lender~~Advisors, ~~Services~~ LLC, as ~~Operating Advisor~~Special Servicer of the Ellenton Premium Outlets Mortgage Loan ~~(see Exhibit 34.6)~~

34.29 ~~Computershare~~Wells ~~Trust~~Fargo ~~Company~~Bank, National Association, as ~~Servicing~~Trustee ~~Function~~of ~~Participant~~the ~~for~~Ellenton ~~the~~Premium Outlets ~~Custodian~~Mortgage Loan (~~see~~Omitted. ~~Exhibit~~See 34Explanatory Notes.9)

34.30 Wells Fargo Bank, National Association, as ~~Primary~~ ~~Servicer~~Custodian of the ~~Penn~~Ellenton ~~Square~~Premium ~~Mall~~Outlets Mortgage Loan (see Exhibit 34.16)

34.31 ~~Wells~~Park ~~Fargo~~Bridge ~~Bank,~~Lender ~~National~~Services ~~Association~~LLC, as ~~Special~~Operating ~~Servicer~~Advisor of the ~~Penn~~Ellenton ~~Square~~Premium ~~Mall~~Outlets Mortgage Loan (see Exhibit 34.17)

34.32 ~~Wilmington~~Computershare Trust Company, National Association, as ~~Trustee~~Servicing ofFunction ~~the~~Participant ~~Penn~~for ~~Square~~the ~~Mall Mortgage~~Custodian ~~Loan~~ (~~Omitted.~~see ~~See~~Exhibit ~~Explanatory Notes~~34.10)

34.33 Wells Fargo Bank, National Association, as Primary ~~Custodian~~Servicer of the Penn Square Mall Mortgage Loan prior to March 1, 2025 (see Exhibit 34.51)

34.34 ~~CoreLogic~~Trimont ~~Solutions,~~ LLC, as ~~Servicing~~Primary ~~Function Participant~~Servicer of the Penn Square Mall Mortgage Loan on and after March 1, 2025 (see Exhibit 34.72)

34.35 ~~Computershare~~Wells ~~Trust~~Fargo ~~Company~~Bank, National Association, as ~~Servicing~~Special Servicer ~~Function~~of ~~Participant~~the ~~for~~Penn ~~the~~Square ~~Custodian~~Mall Mortgage Loan prior to March 1, 2025 (see Exhibit 34.91)

34.36 Trimont LLC, as Special Servicer of the Penn Square Mall Mortgage Loan on and after March 1, 2025 (see Exhibit 34.2)

34.37 Wilmington Trust, National Association, as Trustee of the Penn Square Mall Mortgage Loan (Omitted. See Explanatory Notes.)

34.38 Wells Fargo Bank, National Association, as Custodian of the Penn Square Mall Mortgage Loan (see Exhibit 34.6)

34.39 CoreLogic Solutions, LLC, as Servicing Function Participant of the Penn Square Mall Mortgage Loan (see Exhibit 34.8)

34.40 Computershare Trust Company, National Association, as Servicing Function Participant for the Custodian (see Exhibit 34.10)

35 Servicer compliance statements.

35.1 Wells Fargo Bank, National Association, as Master Servicer prior to March 1, 2025

35.2 ~~Greystone~~Trimont ~~Servicing Company~~ LLC, (as ~~successor~~Master ~~to C-III~~Servicer ~~Asset~~on ~~Management~~and ~~LLC)~~after March 1, ~~as Special Servicer~~2025

35.3 ~~Wells~~Greystone ~~Fargo~~Servicing ~~Bank,~~Company ~~National~~LLC ~~Association~~(as successor to C-III Asset Management LLC), as ~~Certificate Administrator~~Special Servicer

35.4 ~~Computershare~~Wells ~~Trust~~Fargo ~~Company~~Bank, National Association, as ~~Servicing Function Participant for the~~ as Certificate Administrator

35.5 ~~Wells~~Computershare ~~Fargo~~Trust ~~Bank~~Company, National Association, as ~~Primary Servicer~~Servicing ofFunction ~~the~~Participant ~~Princeton~~for ~~Pike~~the ~~Corporate~~Certificate ~~Center Mortgage Loan (see Exhibit 35.1)~~Administrator

35.6 ~~Greystone~~Wells ~~Servicing~~Fargo ~~Company~~Bank, ~~LLC~~National ~~(as successor to C-III Asset Management LLC)~~Association, as ~~Special~~ Primary Servicer of the Princeton Pike Corporate Center Mortgage Loan prior to March 1, 2025 (see Exhibit 35.21)

35.7 ~~Wells~~Trimont ~~Fargo Bank~~LLC, ~~National Association,~~ as Primary Servicer of the ~~University~~Princeton Pike ~~West~~Corporate ~~Apartments~~Center Mortgage Loan on and after March 1, 2025 (see Exhibit 35.12)

35.8 ~~CWCapital~~Greystone Servicing Company LLC (as successor to C-III Asset Management LLC), as Special Servicer of the ~~University~~Princeton ~~West~~Pike ~~Apartments~~Corporate Center Mortgage Loan (~~Omitted.~~see ~~See~~Exhibit ~~Explanatory Notes~~35.3)

35.9 ~~Midland~~Wells ~~Loan~~Fargo ~~Services, a Division of PNC~~ Bank, National Association, as Primary Servicer of the ~~Ellenton~~University ~~Premium~~West ~~Outlets~~Apartments Mortgage Loan ~~(Omitted.~~prior ~~See~~to March 1, 2025 ~~Explanatory~~(see ~~Notes~~Exhibit 35.1)

35.10 ~~Rialto~~Trimont ~~Capital Advisors,~~ LLC, as ~~Special~~Primary Servicer of the ~~Ellenton Premium~~University ~~Outlets~~West Apartments Mortgage Loan ~~(Omitted.~~on ~~See~~and ~~Explanatory~~after ~~Notes~~March 1, 2025 (see Exhibit 35.2)

35.11 ~~Wells~~CWCapital ~~Fargo~~Asset ~~Bank,~~Management ~~National Association~~LLC, as ~~Primary~~ Special Servicer of the ~~Penn~~University ~~Square~~West Apartments ~~Mall~~ Mortgage Loan (~~see~~Omitted. ~~Exhibit~~See 35Explanatory Notes.1)

35.12 ~~Wells~~Midland ~~Fargo~~Loan Services, a Division of PNC Bank, National Association, as ~~Special~~Primary Servicer of the ~~Penn~~Ellenton ~~Square~~Premium ~~Mall~~Outlets Mortgage Loan (~~see~~Omitted. ~~Exhibit~~See Explanatory 35Notes.1)

35.13 Rialto Capital Advisors, LLC, as Special Servicer of the Ellenton Premium Outlets Mortgage Loan (Omitted. See Explanatory Notes.)

35.14 Wells Fargo Bank, National Association, as Primary Servicer of the Penn Square Mall Mortgage Loan prior to March 1, 2025 (see Exhibit 35.1)

35.15 Trimont LLC, as Primary Servicer of the Penn Square Mall Mortgage Loan on and after March 1, 2025 (see Exhibit 35.2)

35.16 Wells Fargo Bank, National Association, as Special Servicer of the Penn Square Mall Mortgage Loan prior to March 1, 2025 (see Exhibit 35.1)

35.17 Trimont LLC, as Special Servicer of the Penn Square Mall Mortgage Loan on and after March 1, 2025 (see Exhibit 35.2)

99.1 Mortgage Loan Purchase Agreement, dated as of February 12, 2016, between Banc of America Merrill Lynch Commercial Mortgage Inc. and Bank of America, National Association (filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-K filed on February 25, 2016 under Commission File No. 333-206847-01 and incorporated by reference herein)

99.2 Mortgage Loan Purchase Agreement, dated as of February 12, 2016, between Banc of America Merrill Lynch Commercial Mortgage Inc. and Morgan Stanley Mortgage Capital Holdings LLC (filed as Exhibit 99.2 to the registrant’s Current Report on Form 8-K filed on February 25, 2016 under Commission File No. 333-206847-01 and incorporated by reference herein)

99.3 Mortgage Loan Purchase Agreement, dated as of February 12, 2016, between Banc of America Merrill Lynch Commercial Mortgage Inc. and CIBC Inc. (filed as Exhibit 99.3 to the registrant’s Current Report on Form 8-K filed on February 25, 2016 under Commission File No. 333-206847-01 and incorporated by reference herein)

99.4 Mortgage Loan Purchase Agreement, dated as of February 12, 2016, between Banc of America Merrill Lynch Commercial Mortgage Inc., Starwood Mortgage Funding III LLC, and Starwood Mortgage Capital LLC (filed as Exhibit 99.4 to the registrant’s Current Report on Form 8-K filed on February 25, 2016 under Commission File No. 333-206847-01 and incorporated by reference herein)

(b) The exhibits required to be filed by the Registrant pursuant to Item 601 of Regulation S-K are listed above.

SIGNATURES

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

Banc of America Merrill Lynch Commercial Mortgage Inc.
(Depositor)

/s/ Leland F. Bunch, III

Leland F. Bunch, III, President and Chief Executive Officer

(senior officer in charge of securitization of the depositor)

Date: March 1016, ~~2025~~2026

Filing Compare · Morgan Stanley Bank of America Merrill Lynch Trust 2016-C28