BANK 2021-BNK32 Details Major Servicing Overhaul, Legal Risks

TL;DR

**This CMBS issuer is undergoing a major servicing shake-up and facing persistent legal headwinds, signaling potential operational risks for bondholders.**

AI Summary

BANK 2021-BNK32, a mortgage pool, filed its 10-K for the fiscal year ended December 31, 2025, primarily detailing changes in its servicing structure rather than financial performance. The filing indicates no revenue or net income figures, as it is an issuing entity for asset-backed securities. A significant business change occurred on March 1, 2025, when Trimont LLC acquired Wells Fargo Bank, National Association's commercial mortgage servicing business, taking over as master, primary, and special servicer for BANK 2021-BNK32 and its associated mortgage loans like the Miami Design District and 605 Third Avenue. Additionally, Midland Loan Services, a Division of PNC Bank, National Association, became the general special servicer for the BANK 2020-BNK30 pooling and servicing agreement on February 27, 2025, and for the Benchmark 2021-B24 agreement on March 4, 2025. Key risks include ongoing legal proceedings against Wells Fargo Bank, N.A. related to its trustee role in other RMBS trusts, with Phoenix Light's appeal dismissed in May 2023 and Commerzbank AG's appeal denied in October 2024. A new legal action was served on Wilmington Trust, National Association on February 3, 2026, for alleged breaches related to Tricolor Holdings, LLC asset-backed securitization transactions. The strategic outlook focuses on maintaining compliance with Regulation AB, with reports on servicing criteria and servicer compliance statements attached.

Why It Matters

This 10-K reveals a significant shift in the servicing landscape for BANK 2021-BNK32's mortgage pool, with Trimont LLC replacing Wells Fargo Bank, N.A. as the primary servicer. For investors, understanding these servicing changes is crucial as it impacts loan administration, potential default management, and ultimately, the performance of the underlying asset-backed securities. The ongoing legal challenges faced by Wells Fargo Bank, N.A. and the new complaint against Wilmington Trust, National Association highlight systemic risks within the securitization market, potentially affecting investor confidence and the operational stability of key market participants. This competitive context underscores the importance of robust servicing and trustee oversight in the complex world of commercial mortgage-backed securities.

Risk Assessment

Risk Level: medium — The risk level is medium due to significant changes in servicing parties, including Trimont LLC replacing Wells Fargo Bank, N.A. as master, primary, and special servicer effective March 1, 2025, which introduces operational transition risk. Furthermore, the filing details ongoing legal proceedings against Wells Fargo Bank, N.A. regarding its trustee role in other RMBS trusts, and a new civil complaint served on Wilmington Trust, National Association on February 3, 2026, for unspecified damages related to alleged breaches in other asset-backed securitization transactions, indicating potential systemic legal and reputational risks for key participants in the securitization ecosystem.

Analyst Insight

Investors should closely monitor the performance of Trimont LLC in its new servicing capacities for BANK 2021-BNK32, particularly regarding loan delinquencies and resolutions. Given the legal challenges against other trustees and servicers, investors should also scrutinize the indemnification provisions and potential liabilities within the pooling and servicing agreements to assess their exposure to similar future litigation.

Financial Highlights

debt To Equity

N/A

revenue

$0

operating Margin

N/A

total Assets

N/A

total Debt

N/A

net Income

$0

eps

N/A

gross Margin

N/A

cash Position

N/A

revenue Growth

N/A

Key Numbers

• 2025-12-31 — Fiscal Year End (Reporting period for the 10-K filing.)
• 2026-03-23 — Filing Date (Date the 10-K was filed with the SEC.)
• 2025-03-01 — Effective Date (Date Trimont LLC replaced Wells Fargo Bank, N.A. as servicer.)
• 2025-02-27 — Effective Date (Date Midland Loan Services became general special servicer for BANK 2020-BNK30.)
• 2025-03-04 — Effective Date (Date Midland Loan Services became general special servicer for Benchmark 2021-B24.)
• 2026-02-03 — Service Date (Date Wilmington Trust, National Association was served with a civil complaint.)
• 2023-05 — Dismissal Date (Phoenix Light dismissed its appeal against Wells Fargo Bank, N.A.)
• 2024-10 — Denial Date (Second Circuit denied Commerzbank AG's appeal against Wells Fargo Bank, N.A.)
• 2023-11 — Settlement Date (Wells Fargo Bank, N.A. settled with IKB.)
• 5% — Mortgage Pool Threshold (Midland Loan Services services less than 5% of the mortgage pool as Benchmark 2021-B24 master servicer.)

Key Players & Entities

• BANK 2021-BNK32 (company) — issuing entity of mortgage pool
• Trimont LLC (company) — successor master, primary, and special servicer as of March 1, 2025
• Wells Fargo Bank, National Association (company) — former master, primary, and special servicer; sponsor; defendant in legal proceedings
• Midland Loan Services, a Division of PNC Bank, National Association (company) — general special servicer for BANK 2020-BNK30 and Benchmark 2021-B24
• Wilmington Trust, National Association (company) — defendant in new civil complaint as of February 3, 2026
• Morgan Stanley Capital I Inc. (company) — depositor
• Bank of America, National Association (company) — sponsor
• Morgan Stanley Mortgage Capital Holdings LLC (company) — sponsor
• National Cooperative Bank, N.A. (company) — sponsor
• CoreLogic Solutions, LLC (company) — servicing function participant

FAQ

Risk Factors

• Ongoing Legal Proceedings Against Wells Fargo [medium — legal]: Wells Fargo Bank, N.A. faces ongoing legal challenges related to its trustee role in other RMBS trusts. Phoenix Light's appeal was dismissed in May 2023, and Commerzbank AG's appeal was denied in October 2024. These proceedings highlight potential reputational and operational risks associated with past servicing roles.
• New Legal Action Against Wilmington Trust [medium — legal]: Wilmington Trust, National Association was served with a civil complaint on February 3, 2026, alleging breaches related to Tricolor Holdings, LLC asset-backed securitization transactions. This new action introduces fresh legal scrutiny and potential financial liabilities for the trustee.
• Servicing Structure Changes [medium — operational]: The fiscal year ended December 31, 2025, saw significant changes in the servicing structure. Trimont LLC acquired Wells Fargo Bank, N.A.'s commercial mortgage servicing business on March 1, 2025, becoming the master, primary, and special servicer for BANK 2021-BNK32. Midland Loan Services also became a general special servicer for related agreements on February 27, 2025, and March 4, 2025. These transitions introduce operational risks and require careful management to ensure continuity.

Industry Context

The commercial mortgage-backed securities (CMBS) market is characterized by complex securitization structures and a reliance on specialized servicers. Changes in servicing roles, especially involving large institutions like Wells Fargo, can create ripple effects across multiple trusts. The industry is also subject to evolving regulatory scrutiny, as evidenced by the focus on Regulation AB compliance.

Regulatory Implications

The filing highlights the importance of adhering to Regulation AB, which mandates detailed disclosures about servicing operations and compliance. The ongoing legal actions against Wells Fargo and Wilmington Trust underscore the potential for regulatory and legal repercussions stemming from past or present roles in RMBS trusts.

What Investors Should Do

1. Monitor Trimont LLC's performance as the new master, primary, and special servicer for BANK 2021-BNK32 to ensure smooth transition and effective loan management.
2. Assess the potential impact of ongoing legal proceedings against Wells Fargo and Wilmington Trust on the stability and reputation of the underlying mortgage pool and related entities.
3. Review the attached servicing criteria and servicer compliance statements to confirm adherence to Regulation AB requirements and understand operational controls.

Key Dates

• 2025-12-31: Fiscal Year End — This marks the end of the reporting period for the 10-K filing, providing the latest snapshot of the entity's status.
• 2026-03-23: 10-K Filing Date — Indicates when the annual report was officially submitted to the SEC, making the information publicly available.
• 2025-03-01: Trimont LLC Acquires Servicing Business — This date signifies a major change in the servicing structure for BANK 2021-BNK32, with Trimont LLC taking over from Wells Fargo Bank, N.A. as master, primary, and special servicer.
• 2025-02-27: Midland Loan Services Appointed General Special Servicer — Midland Loan Services became the general special servicer for the BANK 2020-BNK30 pooling and servicing agreement, indicating a shift in specialized servicing roles.
• 2025-03-04: Midland Loan Services Appointed General Special Servicer — Midland Loan Services also became the general special servicer for the Benchmark 2021-B24 pooling and servicing agreement, reflecting further changes in servicing responsibilities.
• 2026-02-03: Wilmington Trust Served Civil Complaint — This date marks the initiation of new legal action against the trustee, Wilmington Trust, National Association, concerning alleged breaches in asset-backed securitization transactions.

Glossary

Issuing Entity

An entity created specifically to issue asset-backed securities, pooling underlying assets like mortgages. (BANK 2021-BNK32 is an issuing entity, meaning it does not generate revenue or net income in the traditional sense but facilitates securitization.)

Pooling and Servicing Agreement (PSA)

A legal contract that governs the terms under which a pool of assets (like mortgages) is securitized and serviced. (The filing details changes in PSAs and the parties involved in servicing the mortgage loans under these agreements.)

Master Servicer

The primary servicer responsible for overseeing the mortgage loans in a securitized pool, including collecting payments and managing the loan lifecycle. (Trimont LLC's appointment as master servicer for BANK 2021-BNK32 signifies a key operational change.)

Primary Servicer

A servicer responsible for day-to-day loan administration, including collecting payments, handling escrow, and managing delinquencies. (Trimont LLC's role as primary servicer indicates direct management of the mortgage loans.)

Special Servicer

A servicer appointed to manage defaulted or specially serviced mortgage loans, often involving loan modifications, foreclosure, or other loss mitigation strategies. (The changes in special servicing roles, involving Trimont LLC and Midland Loan Services, are a central theme of the filing.)

Regulation AB

SEC rules governing the disclosure requirements for asset-backed securities, including information on the underlying assets, servicers, and risks. (The filing emphasizes compliance with Regulation AB, particularly regarding servicing criteria and servicer compliance statements.)

Year-Over-Year Comparison

As BANK 2021-BNK32 is an issuing entity without traditional financial performance metrics, a direct comparison of revenue or net income is not applicable. The primary focus of this 10-K filing is on significant changes in the servicing structure, specifically the acquisition of Wells Fargo's commercial mortgage servicing business by Trimont LLC. This represents a material operational shift compared to previous filings, which would have detailed Wells Fargo's role. Additionally, new legal actions have emerged, indicating a potential increase in legal risks since the last reporting period.

Filing Documents

• msc21b32_10k-2025.htm (10-K) — 136KB
• msc21b32_31.htm (EX-31) — 22KB
• msc21b32_33-1.htm (EX-33.1) — 357KB
• msc21b32_33-2.htm (EX-33.2) — 1420KB
• msc21b32_33-3.htm (EX-33.3) — 702KB
• msc21b32_33-4.htm (EX-33.4) — 3113KB
• msc21b32_33-5.htm (EX-33.5) — 600KB
• msc21b32_33-6.htm (EX-33.6) — 626KB
• msc21b32_33-7.htm (EX-33.7) — 118KB
• msc21b32_33-8.htm (EX-33.8) — 439KB
• msc21b32_33-10.htm (EX-33.10) — 992KB
• msc21b32_33-11.htm (EX-33.11) — 86KB
• msc21b32_33-19.htm (EX-33.19) — 264KB
• msc21b32_33-20.htm (EX-33.20) — 172KB
• msc21b32_34-1.htm (EX-34.1) — 14KB
• msc21b32_34-2.htm (EX-34.2) — 11KB
• msc21b32_34-3.htm (EX-34.3) — 14KB
• msc21b32_34-4.htm (EX-34.4) — 11KB
• msc21b32_34-5.htm (EX-34.5) — 13KB
• msc21b32_34-6.htm (EX-34.6) — 10KB
• msc21b32_34-7.htm (EX-34.7) — 9KB
• msc21b32_34-8.htm (EX-34.8) — 9KB
• msc21b32_34-10.htm (EX-34.10) — 693KB
• msc21b32_34-11.htm (EX-34.11) — 8KB
• msc21b32_34-19.htm (EX-34.19) — 89KB
• msc21b32_34-20.htm (EX-34.20) — 9KB
• msc21b32_35-1.htm (EX-35.1) — 1896KB
• msc21b32_35-2.htm (EX-35.2) — 2593KB
• msc21b32_35-3.htm (EX-35.3) — 1558KB
• msc21b32_35-4.htm (EX-35.4) — 1806KB
• msc21b32_35-5.htm (EX-35.5) — 2577KB
• msc21b32_35-6.htm (EX-35.6) — 2224KB
• msc21b32_35-7.htm (EX-35.7) — 79KB
• msc21b32_35-8.htm (EX-35.8) — 546KB
• msc21b32_35-15.htm (EX-35.15) — 102KB
• 0001888524-26-005029.txt ( ) — 23318KB

financial statements

financial statements. Not applicable. 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). Not applicable. Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Act). Yes ___ No X 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. 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 BANK 2021-BNK32 mortgage pool includes the following mortgage loans, each of which is serviced pursuant to a separate pooling and servicing agreement (each, an "Outside Pooling and Servicing Agreement"

, and does not constitute a reporting "servicer" for purposes of Item

Item 1122, and does not constitute a reporting "servicer" for purposes of Item 1123 of Regulation AB, as specified in the Instruction to Item 1123. Midland Loan Services, a Division of PNC Bank, National Association is the current general special servicer under the BANK 2020-BNK30 pooling and servicing agreement, pursuant to which the McClellan Park mortgage loan is serviced, and the current special servicer under the Benchmark 2021-B24 pooling and servicing agreement, pursuant to which the Boca Office Portfolio mortgage loan is serviced. On February 27, 2025, Greystone Servicing Company LLC was replaced as general special servicer under the BANK 2020-BNK30 pooling and servicing agreement (other than with respect to certain mortgage loans, including the 605 Third Avenue mortgage loan, with respect to which Greystone Servicing Company LLC remains the special servicer under the BANK 2020-BNK30 pooling and servicing agreement) and was succeeded by Midland Loan Services, a Division of PNC Bank, National Association. On March 4, 2025, Greystone Servicing Company LLC was replaced as special servicer under the Benchmark 2021-B24 pooling and servicing agreement, pursuant to which the Boca Office Portfolio mortgage loan is serviced, and succeeded by Midland Loan Services, a Division of PNC Bank, National Association. Because Midland Loan Services, a Division of PNC Bank, National Association is not the BANK 2021-BNK32 special servicer, is not affiliated with any sponsor and services only the McClellan Park mortgage loan and the Boca Office Portfolio mortgage loan, which collectively constitute more than 5% but less than 10% of the mortgage pool, Midland Loan Services, a Division of PNC Bank, National Association, as BANK 2020-BNK30 general special servicer and Benchmark 2021-B24 special servicer, does constitute a reporting "servicing function participant" for purposes of

of Regulation AB, as specified in the Instruction 3 to Item 1122, but

Item 1122 of Regulation AB, as specified in the Instruction 3 to Item 1122, but does not constitute a reporting "servicer" for purposes of Item 1123 of Regulation AB, as specified in the Instruction to Item 1123. Effective as of March 1, 2025, Trimont LLC purchased the third party servicing segment of Wells Fargo Bank, National Association's commercial mortgage servicing business and replaced Wells Fargo Bank, National Association in its capacities as master servicer, primary servicer and special servicer, as applicable, under the BANK 2021-BNK32 pooling and servicing agreement and each Outside Pooling and Servicing Agreement. In addition, each of the following parties engaged the services of certain servicing function participants and sub-servicers for the reporting period, as set forth below: Wells Fargo Bank, National Association, as master servicer, engaged the services of CoreLogic Solutions, LLC as a servicing function participant in respect of the entire mortgage pool for the reporting period. Wells Fargo Bank, National Association, as master servicer under the BANK 2021-BNK33 pooling and servicing agreement, pursuant to which the Miami Design District mortgage loan is serviced, engaged the services of CoreLogic Solutions, LLC as a servicing function participant in respect of the Miami Design District mortgage loan for the reporting period. Wells Fargo Bank, National Association, as master servicer under the BANK 2020-BNK30 pooling and servicing agreement, pursuant to which the 605 Third Avenue mortgage loan and the McClellan Park mortgage loan are serviced, engaged the services of CoreLogic Solutions, LLC as a servicing function participant in respect of each such mortgage loan for the reporting period. On November 1, 2021, pursuant to the second amended and restated servicing agreement attached hereto as Exhibit 99.11, Computershare Trust Company, National Association was engaged to perform all or virtually all of Wells Fargo Bank, National Asso

Financial Statements and

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

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

Executive Compensation. Omitted. Item 12.

Security Ownership of

Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters. Omitted. Item 13. Certain Relationships and Related Transactions, and Director Independence. 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. Not applicable. Item 1114(b)(2) of Regulation AB, Significant Enhancement Provider Financial Information. No entity or group of affiliated entities provides any enhancement or other support for the certificates 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 for the certificates as described under Item 1115 of Regulation AB. Item 1117 of Regulation AB, Legal Proceedings. The registrant knows of no legal proceeding pending against the sponsors, depositor, trustee, issuing entity, servicer contemplated by Item 1108(a)(3) of Regulation AB, originator contemplated by Item 1110(b) of Regulation AB, or other party contemplated by Item 1100(d)(1) of Regulation AB, or of which any property of the foregoing is the subject, that is material to security holders, other than as follows: 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 W

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