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KBRA Affirms All Ratings for GSMS 2019-GC38

23 Dec 2025   |   New York

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KBRA affirms all of its outstanding ratings for GSMS 2019-GC38, a $663.2 million CMBS conduit transaction. The affirmations follow a surveillance review of the transaction, which has exhibited an increase in estimated losses since last review. However, the magnitude of the change does not warrant ratings adjustments at this time.

As of the December 2025 remittance period, there is one specially serviced loan (5.1% of the pool balance). KBRA identified seven K-LOCs (17.3%), including the specially serviced loan. Of the K-LOCs, three (6.7%) have estimated losses. The K-LOCs are depicted in the table below.

Loss Given Default (000s) Loss Severity 8 3 Park Avenue OF $34,000 5.1% Y C N DSCR 06/04/2020 - - 15 5444 & 5430 Westheimer OF $21,000 3.2% N C N Occupancy 03/07/2023 $12,319 58.7% 14 Dublin Office Portfolio OF $19,509 2.9% N C N Occupancy 03/26/2024 - - 20 Fairbridge Office Portfolio OF $13,800 2.1% N C N Occupancy 02/09/2023 $4,086 29.6% 25 Franklin Commons RT $9,773 1.5% N C N DSCR 08/08/2024 - - 26 1933 North Meacham OF $9,433 1.4% N C N DSCR 03/10/2025 $1,391 14.7% 29 Church Ranch II OF $7,256 1.1% N C N Tenant Issues 06/05/2024 - - Total K-LOCs $114,770 17.3% $17,796 1. K-LOC Date is the date when the most recent K-LOC was initially determined. 2. Loss Given Default assumes a 100% probability of default (PD). KBRA may determine a lower PD when estimating losses to a transaction. KBRA Estimated 2 K-LOCs Prosp. ID Loan Name Prop Type Current In-Trust Balance (000s) % of Deal Balance SS Loan Status Mod (Y/N) Primary K-LOC Reason K-LOC Date 1
Source: KBRA

Excluding the K-LOCs with estimated losses, the transaction’s WA KLTV is 93.3%, compared to 95.8% at last review and 95.4% at securitization. The KDSC is 1.93x, compared to 1.97x at last review and 1.92x securitization.

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Methodologies

Disclosures

Further information on key credit considerations, sensitivity analyses that consider what factors can affect these credit ratings and how they could lead to an upgrade or a downgrade, and ESG factors (where they are a key driver behind the change to the credit rating or rating outlook) can be found in the full rating report referenced above.

A description of all substantially material sources that were used to prepare the credit rating and information on the methodology(ies) (inclusive of any material models and sensitivity analyses of the relevant key rating assumptions, as applicable) used in determining the credit rating is available in the Information Disclosure Form(s) located here.

Information on the meaning of each rating category can be located here.

Further disclosures relating to this rating action are available in the Information Disclosure Form(s) referenced above. Additional information regarding KBRA policies, methodologies, rating scales and disclosures are available at www.kbra.com.

About KBRA

Kroll Bond Rating Agency, LLC (KBRA), one of the major credit rating agencies (CRA), is a full-service CRA registered with the U.S. Securities and Exchange Commission as an NRSRO. Kroll Bond Rating Agency Europe Limited is registered as a CRA with the European Securities and Markets Authority. Kroll Bond Rating Agency UK Limited is registered as a CRA with the UK Financial Conduct Authority. In addition, KBRA is designated as a Designated Rating Organization (DRO) by the Ontario Securities Commission for issuers of asset-backed securities to file a short form prospectus or shelf prospectus. KBRA is also recognized as a Qualified Rating Agency by Taiwan’s Financial Supervisory Commission and is recognized by the National Association of Insurance Commissioners as a Credit Rating Provider (CRP) in the U.S.

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