Benchmark 2021-B24 Details Complex CMBS Servicing Landscape

TL;DR

**This CMBS trust's 10-K reveals a highly fragmented and complex servicing structure, increasing operational risk for investors.**

AI Summary

Benchmark 2021-B24 Mortgage Trust, a securitization entity, filed its 10-K for the fiscal year ended December 31, 2025. The trust's asset pool includes various commercial mortgage loans, with significant concentrations in the 141 Livingston Mortgage Loan (6.5%), MGM Grand & Mandalay Bay Mortgage Loan (6.9%), and 410 Tenth Avenue Mortgage Loan (6.9%) as of its cut-off date. The filing details the complex servicing arrangements for these loans, involving multiple servicers and trustees across several securitization transactions like BX 2020-VIVA and Benchmark 2021-B23. Key servicers such as Midland Loan Services, Wells Fargo Bank, KeyBank National Association, and Situs Holdings, LLC are identified for their roles in managing loans constituting 10% or more of the asset pool. The report also notes that trustees, including Wells Fargo Bank and Wilmington Trust, National Association, did not perform certain servicing functions related to Item 1122(d)(2)(iii) of Regulation AB during the reporting period, with these functions instead handled by master or special servicers.

Why It Matters

This 10-K provides critical transparency into the operational structure of a significant Commercial Mortgage-Backed Securities (CMBS) trust, Benchmark 2021-B24. Investors need to understand the intricate web of servicers and trustees, like Midland Loan Services and Wells Fargo Bank, as their performance directly impacts the cash flow and risk profile of the underlying mortgage loans. The detailed breakdown of loan combinations and cross-transaction servicing, such as with the BX 2020-VIVA Transaction, highlights the interconnectedness of the CMBS market and potential contagion risks. For employees of these servicing entities, it clarifies their specific responsibilities and compliance requirements under Regulation AB, while customers (borrowers) are indirectly affected by the efficiency and oversight of these servicing operations. The competitive landscape among CMBS servicers is underscored by the numerous entities involved, each with distinct roles and compliance obligations.

Risk Assessment

Risk Level: medium — The filing indicates a medium risk level due to the highly fragmented and complex servicing structure involving numerous entities like Midland Loan Services, Wells Fargo Bank, and KeyBank National Association, each with specific roles across multiple loan combinations and securitization transactions. This complexity, coupled with the note that trustees did not perform certain required servicing functions under Item 1122(d)(2)(iii) of Regulation AB, could lead to potential operational inefficiencies or gaps in oversight, increasing the risk of miscommunication or delayed action on distressed assets.

Analyst Insight

Investors should meticulously review the compliance statements and attestation reports from all identified servicers and servicing function participants to assess the robustness of the operational controls. Given the complexity, consider the potential for increased servicing costs or delays in resolution for underperforming loans, and factor this into valuation models for the trust's certificates.

Key Numbers

• 6.5% — 141 Livingston Mortgage Loan (percentage of asset pool as of cut-off date)
• 5.6% — The Galleria Office Towers Mortgage Loan (percentage of asset pool as of cut-off date)
• 5.2% — U.S. Industrial Portfolio VI Mortgage Loan (percentage of asset pool as of cut-off date)
• 4.3% — Boca Office Portfolio Mortgage Loan (percentage of asset pool as of cut-off date)
• 3.9% — 30 Hudson Yards 67 Mortgage Loan (percentage of asset pool as of cut-off date)
• 6.9% — MGM Grand & Mandalay Bay Mortgage Loan (percentage of asset pool as of cut-off date)
• 2.3% — 711 Fifth Avenue Mortgage Loan (percentage of asset pool as of cut-off date)
• 1.5% — Willoughby Commons Mortgage Loan (percentage of asset pool as of cut-off date)
• 6.5% — Phillips Point Mortgage Loan (percentage of asset pool as of cut-off date)
• 6.9% — 410 Tenth Avenue Mortgage Loan (percentage of asset pool as of cut-off date)

Key Players & Entities

• Benchmark 2021-B24 Mortgage Trust (company) — issuing entity
• J.P. Morgan Chase Commercial Mortgage Securities Corp. (company) — depositor
• JPMorgan Chase Bank, National Association (company) — sponsor
• Citi Real Estate Funding Inc. (company) — sponsor
• Goldman Sachs Mortgage Company (company) — sponsor
• German American Capital Corporation (company) — sponsor
• Midland Loan Services, a Division of PNC Bank, National Association (company) — master servicer and special servicer for various loans
• Wells Fargo Bank, National Association (company) — certificate administrator, custodian, and trustee for various loans
• KeyBank National Association (company) — primary servicer and special servicer for various loans
• Situs Holdings, LLC (company) — special servicer for various loans

FAQ

Risk Factors

• Complex Servicing Arrangements [medium — operational]: The trust utilizes multiple servicers and trustees across various securitization transactions. Key servicers include Midland Loan Services, Wells Fargo Bank, KeyBank National Association, and Situs Holdings, LLC. Trustees, such as Wells Fargo Bank and Wilmington Trust, National Association, did not perform certain servicing functions related to Item 1122(d)(2)(iii) of Regulation AB, with these functions delegated to master or special servicers.
• Concentration Risk in Top Loans [medium — market]: The asset pool exhibits concentration risk with significant portions tied to specific loans. The MGM Grand & Mandalay Bay Mortgage Loan (6.9%), 410 Tenth Avenue Mortgage Loan (6.9%), and 141 Livingston Mortgage Loan (6.5%) represent substantial individual exposures as of the cut-off date.
• Loan Combination Complexity [medium — market]: Several key loans are part of larger loan combinations where only a portion is an asset of the issuing entity. For example, the MGM Grand & Mandalay Bay Mortgage Loan is part of a combination with 47 other pari passu loans and 24 subordinate companion loans not held by the trust, increasing complexity in management and recovery.

Industry Context

The commercial mortgage-backed securities (CMBS) market involves pooling various commercial real estate loans into trusts, which then issue securities to investors. This sector is sensitive to real estate market performance, interest rate changes, and economic conditions. The complexity of loan structures and servicing arrangements is typical in this industry.

Regulatory Implications

The filing highlights compliance with Regulation AB, particularly concerning the division of servicing responsibilities between trustees and master/special servicers. Investors should be aware of the specific reporting and disclosure requirements applicable to asset-backed securities.

What Investors Should Do

1. Review the specific Pooling and Servicing Agreements (PSAs) for key loans.
2. Analyze the concentration risk associated with the top loans.
3. Assess the performance and capabilities of the identified servicers.

Glossary

Securitization Entity

A legal entity created to pool assets and issue securities backed by the cash flows from those assets. (Benchmark 2021-B24 Mortgage Trust is a securitization entity holding commercial mortgage loans.)

Cut-off Date

The date as of which the assets are determined for inclusion in a securitization trust and the allocation of principal and interest. (Key loan concentrations are reported as percentages of the asset pool as of the cut-off date.)

Pari Passu Loan

Loans that have equal priority of payment and security interest in the collateral. (Many of the trust's loans are part of larger 'loan combinations' with other pari passu loans not held by the trust, indicating shared collateral and payment streams.)

Pooling and Servicing Agreement (PSA)

The contract that governs the terms under which mortgage loans are pooled and serviced for a securitization. (The PSA is referenced as the governing document for servicing and administration of several key loans and loan combinations.)

Regulation AB

SEC rules governing the registration, reporting, and disclosure requirements for asset-backed securities. (Specific servicing functions under Item 1122(d)(2)(iii) of Regulation AB were not performed by trustees but by master or special servicers.)

Year-Over-Year Comparison

This filing for the fiscal year ended December 31, 2025, does not provide comparative financial data from the prior year's 10-K within the provided text. Therefore, a direct comparison of revenue growth, margin changes, or new risks cannot be made based solely on this excerpt. The structure of the trust and its asset pool, including the identification of key loans and servicers, appears consistent with typical CMBS reporting.

Filing Documents

• jpc21b24_10k-2025.htm (10-K) — 218KB
• jpc21b24_31.htm (EX-31) — 14KB
• jpc21b24_33-1.htm (EX-33.1) — 172KB
• jpc21b24_33-2.htm (EX-33.2) — 264KB
• jpc21b24_33-4.htm (EX-33.4) — 357KB
• jpc21b24_33-5.htm (EX-33.5) — 703KB
• jpc21b24_33-6.htm (EX-33.6) — 992KB
• jpc21b24_33-7.htm (EX-33.7) — 1420KB
• jpc21b24_33-8.htm (EX-33.8) — 3113KB
• jpc21b24_33-44.htm (EX-33.44) — 2773KB
• jpc21b24_33-45.htm (EX-33.45) — 991KB
• jpc21b24_33-47.htm (EX-33.47) — 17KB
• jpc21b24_33-48.htm (EX-33.48) — 137KB
• jpc21b24_33-49.htm (EX-33.49) — 626KB
• jpc21b24_33-55.htm (EX-33.55) — 86KB
• jpc21b24_33-64.htm (EX-33.64) — 118KB
• jpc21b24_34-1.htm (EX-34.1) — 9KB
• jpc21b24_34-2.htm (EX-34.2) — 89KB
• jpc21b24_34-4.htm (EX-34.4) — 14KB
• jpc21b24_34-5.htm (EX-34.5) — 14KB
• jpc21b24_34-6.htm (EX-34.6) — 693KB
• jpc21b24_34-7.htm (EX-34.7) — 11KB
• jpc21b24_34-8.htm (EX-34.8) — 11KB
• jpc21b24_34-44.htm (EX-34.44) — 10KB
• jpc21b24_34-45.htm (EX-34.45) — 9KB
• jpc21b24_34-47.htm (EX-34.47) — 10KB
• jpc21b24_34-48.htm (EX-34.48) — 7KB
• jpc21b24_34-49.htm (EX-34.49) — 10KB
• jpc21b24_34-55.htm (EX-34.55) — 8KB
• jpc21b24_34-64.htm (EX-34.64) — 7KB
• jpc21b24_35-1.htm (EX-35.1) — 460KB
• jpc21b24_35-2.htm (EX-35.2) — 102KB
• jpc21b24_35-4.htm (EX-35.4) — 1896KB
• jpc21b24_35-5.htm (EX-35.5) — 2593KB
• jpc21b24_35-21.htm (EX-35.21) — 1086KB
• jpc21b24_35-22.htm (EX-35.22) — 359KB
• jpc21b24_35-23.htm (EX-35.23) — 2224KB
• jpc21b24_35-29.htm (EX-35.29) — 232KB
• 0001888524-26-005098.txt ( ) — 21856KB

(d)(4)(xi) of Regulation AB. Therefore, under the

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)). This Annual Report on Form 10-K includes assessments of compliance with applicable servicing criteria and accountant's attestation reports from U.S. Bank National Association. This entity was engaged by Citibank, N.A., as custodian of the MGM Grand & Mandalay Bay Mortgage Loan, the Phillips Point Mortgage Loan, the Pittock Block Mortgage Loan, the JW Marriott Nashville Mortgage Loan, The Village at Meridian Mortgage Loan and the Millennium Corporate Park Mortgage Loan to perform certain custodial services. These custodial services are servicing functions included within the servicing criteria set forth in Items 1122(d)(4)(i) and 1122(d)(4)(ii) of Re

of Regulation AB because it is a party performing activities that

Item 1122 of Regulation AB because it is a party performing activities that address servicing criteria relating to 5% or less of the assets of the issuing entity; and (ii) the servicer compliance statement of LNR Partners, LLC as special servicer of the Willoughby Commons Mortgage Loan, listed

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View this 10-K filing on SEC EDGAR