Servicing Shift, RMBS Litigation Cloud BANK 2024-BNK48 Outlook

TL;DR

This mortgage pool is a non-operating entity, but the ongoing multi-billion dollar RMBS trustee lawsuits against DBNTC are a massive red flag for the entire securitization market.

AI Summary

BANK 2024-BNK48, a non-accelerated filer, reported no revenue or net income as it is a mortgage pool entity, not an operating company, for the fiscal year ended December 31, 2025. 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 the BANK 2024-BNK48 mortgage pool and related Outside Pooling and Servicing Agreements. Key risks include ongoing legal proceedings against Deutsche Bank National Trust Company (DBNTC), a trustee for residential mortgage-backed securities (RMBS) trusts, with the National Credit Union Administration Board (NCUA) alleging $17.2 billion in collateral losses across 97 trusts and Commerzbank AG claiming "hundreds of millions of dollars in losses" across 50 RMBS trusts. The strategic outlook focuses on managing these complex servicing arrangements and potential liabilities from the DBNTC litigation, which could indirectly impact investor confidence in similar securitized products.

Why It Matters

This 10-K reveals a significant operational shift for BANK 2024-BNK48 with Trimont LLC replacing Wells Fargo as servicer, impacting how mortgage loans like Grapevine Mills and Newport Centre are managed. For investors, the ongoing, multi-billion dollar RMBS litigation against Deutsche Bank National Trust Company (DBNTC) highlights systemic risks in securitized products, potentially eroding trust and increasing scrutiny on all trustees and servicers. This competitive context means other financial institutions involved in similar securitizations, like Morgan Stanley and JPMorgan Chase, could face heightened regulatory and investor pressure. Employees at Trimont LLC will see new responsibilities, while customers with loans in these pools will experience a change in their servicing entity.

Risk Assessment

Risk Level: high — The risk level is high due to the extensive legal proceedings detailed in Item 1117 of Regulation AB. Deutsche Bank National Trust Company (DBNTC), a trustee for RMBS trusts, faces claims from the National Credit Union Administration Board (NCUA) alleging $17.2 billion in total realized collateral losses across 97 trusts, and Commerzbank AG claiming "hundreds of millions of dollars in losses" across 50 RMBS trusts. While BANK 2024-BNK48 is not directly named, these cases against a major trustee indicate significant systemic risk and potential liabilities within the broader securitization market.

Analyst Insight

Investors should scrutinize their holdings in any asset-backed securities, particularly those involving trustees like Deutsche Bank National Trust Company, given the ongoing multi-billion dollar RMBS litigation. They should also assess the stability and experience of new servicers like Trimont LLC, which took over from Wells Fargo Bank, National Association on March 1, 2025, to ensure robust loan management.

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

• $17.2 billion — total realized collateral losses (alleged by NCUA in litigation against DBNTC across 97 RMBS trusts)
• 5% — threshold for reporting servicer (Rialto Capital Advisors, LLC serviced less than 5% of the mortgage pool, thus not a reporting servicer)
• March 1, 2025 — effective date of servicing change (Trimont LLC replaced Wells Fargo Bank, National Association as servicer)
• 97 — number of RMBS trusts (initially subject to NCUA's amended complaint against DBNTC)
• 50 — number of RMBS trusts (subject to Commerzbank AG's complaint against DBNTC)

Key Players & Entities

• BANK 2024-BNK48 (company) — issuing entity of the mortgage pool
• Morgan Stanley Capital I Inc. (company) — depositor
• Morgan Stanley Mortgage Capital Holdings LLC (company) — sponsor
• Citi Real Estate Funding Inc. (company) — sponsor
• JPMorgan Chase Bank, National Association (company) — sponsor
• Goldman Sachs Mortgage Company (company) — sponsor
• Wells Fargo Bank, National Association (company) — former master servicer, primary servicer, and special servicer
• Trimont LLC (company) — successor master servicer, primary servicer, and special servicer as of March 1, 2025
• Deutsche Bank National Trust Company (company) — trustee facing significant RMBS litigation
• National Credit Union Administration Board (regulator) — plaintiff in RMBS litigation against DBNTC

FAQ

Risk Factors

• Litigation Against Trustee DBNTC [high — legal]: Deutsche Bank National Trust Company (DBNTC), as trustee for RMBS trusts, faces significant litigation. The NCUA alleges $17.2 billion in collateral losses across 97 trusts, while Commerzbank AG claims hundreds of millions in losses across 50 trusts. These proceedings could impact investor confidence in similar securitized products.
• Servicing Business Acquisition [medium — operational]: Trimont LLC acquired Wells Fargo Bank, National Association's commercial mortgage servicing business on March 1, 2025. Trimont now acts as master, primary, and special servicer for the BANK 2024-BNK48 mortgage pool and related agreements. Managing this transition and ensuring continuity of servicing is critical.
• Compliance with Servicing Regulations [medium — regulatory]: The entity must ensure compliance with regulations pertaining to mortgage servicing, particularly under Regulation AB, Item 1122, which governs the servicing function. The complexity of multiple pooling and servicing agreements adds to the compliance burden.

Industry Context

The mortgage-backed securities (MBS) market, particularly for commercial and residential loans, is complex and heavily reliant on effective servicing and robust legal frameworks. Entities like BANK 2024-BNK48 are passive vehicles, their performance and investor confidence tied to the operational integrity of their servicers and the stability of the underlying assets. Recent shifts in servicing, such as the acquisition by Trimont LLC, introduce new operational dynamics.

Regulatory Implications

The ongoing litigation against DBNTC by entities like the NCUA and Commerzbank AG underscores the regulatory scrutiny and potential liabilities associated with the MBS market. Compliance with Regulation AB, particularly regarding servicing functions (Item 1122), remains a key area for entities involved in securitized products.

What Investors Should Do

1. Monitor DBNTC Litigation Outcomes
2. Assess Trimont LLC's Servicing Capabilities
3. Review Servicing Agreements

Key Dates

• 2025-03-01: Trimont LLC acquired Wells Fargo's commercial mortgage servicing business — This marks a significant change in the servicing of the BANK 2024-BNK48 mortgage pool, with Trimont LLC taking over as the master, primary, and special servicer.

Glossary

Mortgage Pool Entity

An entity that holds a collection of mortgage loans, typically for the purpose of securitization, rather than operating as a traditional bank. (BANK 2024-BNK48 is structured as a mortgage pool entity, explaining its lack of revenue and net income as it's not an operating company.)

Pooling and Servicing Agreement (PSA)

A legal contract that governs the servicing of mortgage loans within a securitized pool, outlining the rights and responsibilities of the parties involved, including the servicer and trustee. (The entity operates under multiple 'Outside Pooling and Servicing Agreements' which dictate the servicing arrangements for its mortgage loans.)

Master Servicer

The primary entity responsible for overseeing the servicing of a pool of mortgage loans, often managing other servicers. (Trimont LLC is now the master servicer for the BANK 2024-BNK48 mortgage pool.)

Primary Servicer

The servicer responsible for day-to-day loan administration, including collecting payments, managing escrow accounts, and handling customer inquiries. (Trimont LLC has taken over the role of primary servicer for the mortgage pool.)

Special Servicer

A servicer that handles defaulted or specially serviced mortgage loans, often working with borrowers on loan modifications or foreclosure. (Trimont LLC is also acting as the special servicer for the mortgage pool.)

RMBS Trust

Residential Mortgage-Backed Securities Trust, a legal entity that holds a pool of residential mortgage loans, the cash flows from which are used to pay investors in securities backed by these loans. (The litigation against DBNTC involves numerous RMBS trusts, highlighting potential risks in the broader securitization market.)

Regulation AB

SEC regulation that governs the disclosure and reporting requirements for asset-backed securities, including information about the underlying assets and the entities involved in their servicing. (Compliance with Item 1122 of Regulation AB is relevant for parties participating in the servicing function.)

Year-Over-Year Comparison

As BANK 2024-BNK48 is a mortgage pool entity with no operating revenue or net income, direct year-over-year financial comparisons are not applicable. The primary change from a previous period would be the significant business event on March 1, 2025, where Trimont LLC took over servicing responsibilities from Wells Fargo Bank, National Association. New risks have emerged due to ongoing, substantial litigation against the trustee, DBNTC, involving billions in alleged collateral losses across numerous RMBS trusts.

Key Financial Figures

• $17.2 b — otal realized collateral losses of U.S. $17.2 billion, but the complaint did not includ
• $268 million — BNTC and DBTCA are liable for over U.S. $268 million in damages. On October 5, 2016, DBNTC a

Filing Documents

• bak24b48_10k-2025.htm (10-K) — 150KB
• bak24b48_31.htm (EX-31) — 21KB
• bak24b48_33-1.htm (EX-33.1) — 1420KB
• bak24b48_33-2.htm (EX-33.2) — 3113KB
• bak24b48_33-3.htm (EX-33.3) — 600KB
• bak24b48_33-4.htm (EX-33.4) — 626KB
• bak24b48_33-5.htm (EX-33.5) — 118KB
• bak24b48_33-6.htm (EX-33.6) — 177KB
• bak24b48_33-8.htm (EX-33.8) — 992KB
• bak24b48_33-9.htm (EX-33.9) — 172KB
• bak24b48_33-10.htm (EX-33.10) — 86KB
• bak24b48_33-19.htm (EX-33.19) — 289KB
• bak24b48_34-1.htm (EX-34.1) — 11KB
• bak24b48_34-2.htm (EX-34.2) — 11KB
• bak24b48_34-3.htm (EX-34.3) — 13KB
• bak24b48_34-4.htm (EX-34.4) — 10KB
• bak24b48_34-5.htm (EX-34.5) — 9KB
• bak24b48_34-6.htm (EX-34.6) — 9KB
• bak24b48_34-8.htm (EX-34.8) — 693KB
• bak24b48_34-9.htm (EX-34.9) — 9KB
• bak24b48_34-10.htm (EX-34.10) — 8KB
• bak24b48_34-19.htm (EX-34.19) — 9KB
• bak24b48_35-1.htm (EX-35.1) — 999KB
• bak24b48_35-2.htm (EX-35.2) — 1289KB
• bak24b48_35-3.htm (EX-35.3) — 2577KB
• bak24b48_35-4.htm (EX-35.4) — 2224KB
• bak24b48_35-5.htm (EX-35.5) — 79KB
• bak24b48_35-6.htm (EX-35.6) — 191KB
• bak24b48_35-8.htm (EX-35.8) — 290KB
• bak24b48_35-15.htm (EX-35.15) — 109KB
• 0001888524-26-005038.txt ( ) — 16304KB

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 2024-BNK48 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"

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. In 2014 and 2015, several investors sued several trustees of residential mortgage-backed securities ("RMBS") trusts, including Deutsche Bank National Trust Company ("DBNTC"), concerning the trustees' administration of RMBS trusts. These cases generally alleged that the RMBS trustees failed to perform purported duties, as trustees for private-label RMBS trusts, to enforce breaches of representations and warranties as to mortgage loans held by the trusts and to enforce breaches by servicers of their mortgage loan servicing obligations for the trusts. Investors have sued DBNTC in nine of these cases. DBNTC has settled two cases brought by funds managed b

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