Servicing Shake-Up, Legal Battles Mark MSBAM 2015-C22 10-K

TL;DR

**This CMBS trust is undergoing a major servicing overhaul and navigating a complex legal landscape, making it a high-risk hold for investors.**

AI Summary

The Morgan Stanley Bank of America Merrill Lynch Trust 2015-C22 10-K filing for the fiscal year ended December 31, 2025, primarily details changes in servicing parties and compliance with Regulation AB, rather than providing traditional financial metrics like revenue or net income. 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 MSBAM 2015-C22 pooling and servicing agreement and related Outside Pooling and Servicing Agreements. This transition also involved Trimont LLC engaging CoreLogic Solutions, LLC as a servicing function participant. The filing highlights ongoing legal proceedings against Wells Fargo Bank, N.A. related to residential mortgage-backed securities (RMBS) trusts, with Phoenix Light's appeal dismissed in May 2023 and Commerzbank AG's appeal denied in October 2024. Additionally, Wilmington Trust, National Association (WTNA) was served with a civil complaint on February 3, 2026, for alleged breaches of contract and duties concerning Tricolor Holdings, LLC asset-backed securitization transactions, for an unspecified amount of damages. The strategic outlook emphasizes adherence to servicing criteria under Regulation AB, with various parties submitting compliance and attestation reports.

Why It Matters

This 10-K is crucial for investors in the MSBAM 2015-C22 trust as it details significant changes in the entities responsible for servicing the underlying mortgage loans, directly impacting operational efficiency and risk management. The transition of servicing functions from Wells Fargo Bank, National Association to Trimont LLC on March 1, 2025, introduces a new key player, potentially altering servicing performance and investor confidence. Ongoing legal challenges against Wells Fargo Bank, N.A. and Wilmington Trust, National Association, while not directly against the trust, highlight broader systemic risks within the securitization market and could affect the reputation and operational stability of key service providers. These changes and legal exposures are vital for assessing the trust's stability and the competitive landscape of commercial mortgage-backed securities (CMBS) servicing.

Risk Assessment

Risk Level: high — The risk level is high due to the significant changes in servicing parties, with Trimont LLC replacing Wells Fargo Bank, National Association as master, primary, and special servicer effective March 1, 2025, which introduces operational transition risk. Furthermore, the ongoing legal proceedings against Wells Fargo Bank, N.A. concerning RMBS trusts, and the new civil complaint against Wilmington Trust, National Association on February 3, 2026, for an unspecified amount of damages, indicate potential systemic risks and liabilities for key participants in the securitization structure.

Analyst Insight

Investors should closely monitor the performance of Trimont LLC as the new servicer following its March 1, 2025, takeover, and assess any potential impact on loan performance and distributions. Given the legal challenges against other key entities like Wells Fargo Bank, N.A. and Wilmington Trust, National Association, investors should scrutinize the trust's exposure to these parties and consider the broader implications for the stability of the securitization market.

Financial Highlights

debt To Equity

0.0

revenue

$0

operating Margin

0%

total Assets

$0

total Debt

$0

net Income

$0

eps

$0

gross Margin

0%

cash Position

$0

revenue Growth

N/A

Key Numbers

• 2025-12-31 — Fiscal Year End (The reporting period for this 10-K filing.)
• 2026-03-24 — Filing Date (The date the 10-K was filed with the SEC.)
• 2025-03-01 — Servicer Transition Date (Effective date when Trimont LLC replaced Wells Fargo Bank, National Association as servicer.)
• 2026-02-03 — WTNA Complaint Date (Date Wilmington Trust, National Association was served with a civil complaint.)
• 2024-10 — Commerzbank Appeal Denial (Month and year the Second Circuit denied Commerzbank AG's appeal against Wells Fargo Bank, N.A.)
• 2023-05 — Phoenix Light Appeal Dismissal (Month and year Phoenix Light SF Limited dismissed its appeal against Wells Fargo Bank, N.A.)
• 2022-09-28 — LNR Partners Appointment Date (Date LNR Partners, LLC succeeded Midland Loan Services as special servicer for MSBAM 2015-C22.)
• 2021-08-16 — Mount Street US Appointment Date (Date Mount Street US (Georgia) LLP replaced LNR Partners, LLC and CWCapital Asset Management LLC as general special servicer for MSBAM 2015-C21.)
• 2021-11-01 — Computershare Engagement Date (Date Computershare Trust Company, National Association was engaged for various roles.)
• 5% — Mortgage Pool Threshold (The 555 11th Street NW mortgage loan constitutes greater than 5% but less than 10% of the mortgage pool.)

Key Players & Entities

• Morgan Stanley Bank of America Merrill Lynch Trust 2015-C22 (company) — issuing entity
• 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; defendant in RMBS lawsuits
• CoreLogic Solutions, LLC (company) — servicing function participant
• LNR Partners, LLC (company) — special servicer for MSBAM 2015-C22 and 555 11th Street NW mortgage loan
• Wilmington Trust, National Association (company) — defendant in a civil complaint filed February 3, 2026
• KeyBank National Association (company) — master servicer for MSBAM 2015-C21 and 555 11th Street NW mortgage loan
• Midland Loan Services, a Division of PNC Bank, National Association (company) — special servicer for Hilton Garden Inn W 54th Street mortgage loan
• Phoenix Light SF Limited (company) — plaintiff in dismissed RMBS lawsuit against Wells Fargo Bank, N.A.
• Commerzbank AG (company) — plaintiff in denied RMBS appeal against Wells Fargo Bank, N.A.

Forward-Looking Statements

• The trust will continue to file annual 10-K reports for subsequent fiscal years. (Morgan Stanley Bank of America Merrill Lynch Trust 2015-C22) — high confidence, target: 2027-03-31
• The underlying commercial mortgage-backed securities will continue to be monitored by investors. (Asset-Backed Securities) — high confidence, target: 2026-12-31

FAQ

Risk Factors

• Ongoing RMBS Litigation [medium — legal]: Wells Fargo Bank, N.A. is involved in ongoing legal proceedings related to RMBS trusts. Phoenix Light's appeal was dismissed in May 2023, and Commerzbank AG's appeal was denied in October 2024, indicating potential liabilities and costs associated with past RMBS activities.
• Wilmington Trust Civil Complaint [medium — legal]: Wilmington Trust, National Association (WTNA) was served with a civil complaint on February 3, 2026, alleging breaches of contract and duties concerning Tricolor Holdings, LLC asset-backed securitization transactions. The unspecified damages highlight potential financial exposure for WTNA.
• Servicer Transition Complexity [medium — operational]: A significant business change occurred on March 1, 2025, with Trimont LLC acquiring Wells Fargo Bank, National Association's commercial mortgage servicing business. This transition involved engaging CoreLogic Solutions, LLC as a servicing function participant, introducing potential operational risks during integration.
• Regulation AB Compliance [high — regulatory]: The filing emphasizes adherence to servicing criteria under Regulation AB, with various parties submitting compliance and attestation reports. Failure to meet these criteria could result in regulatory scrutiny and penalties.

Industry Context

The commercial mortgage-backed securities (CMBS) market continues to navigate significant operational shifts, particularly concerning servicing roles. Increased regulatory scrutiny under frameworks like Regulation AB necessitates robust compliance and transparent reporting from all parties involved in the securitization process. Ongoing litigation related to legacy RMBS transactions also casts a shadow, highlighting potential risks and the importance of experienced legal and operational management.

Regulatory Implications

The primary regulatory focus for MSBAM 2015-C22 is adherence to Regulation AB servicing criteria. Any non-compliance by the various servicers or trustees could lead to significant penalties and reputational damage. The ongoing legal actions against Wells Fargo and Wilmington Trust underscore the persistent legal risks associated with mortgage-backed securities.

What Investors Should Do

1. Monitor Servicer Performance
2. Assess Legal Contingencies
3. Review Regulation AB Compliance Reports

Key Dates

• 2025-12-31: Fiscal Year End — Marks the end of the reporting period for the 10-K filing.
• 2026-03-24: Filing Date — The date the 10-K was officially submitted to the SEC.
• 2025-03-01: Servicer Transition Date — Trimont LLC officially took over as master, primary, and special servicer, replacing Wells Fargo Bank, National Association.
• 2026-02-03: WTNA Complaint Date — Wilmington Trust, National Association was served with a civil complaint, indicating new legal challenges.
• 2024-10-XX: Commerzbank Appeal Denial — The Second Circuit denied Commerzbank AG's appeal against Wells Fargo Bank, N.A., concluding a phase of RMBS-related litigation.
• 2023-05-XX: Phoenix Light Appeal Dismissal — Phoenix Light SF Limited dismissed its appeal against Wells Fargo Bank, N.A., resolving another RMBS litigation matter.

Glossary

Regulation AB

A regulation by the U.S. Securities and Exchange Commission (SEC) that governs the disclosure and reporting requirements for asset-backed securities transactions. (The filing heavily emphasizes compliance with Regulation AB's servicing criteria (Items 1122 and 1123), which is crucial for investor confidence and regulatory adherence.)

Pooling and Servicing Agreement (PSA)

A legal contract that outlines the terms and conditions under which a pool of assets (like mortgages) is securitized and serviced. (The filing references multiple PSAs, including the MSBAM 2015-C22 PSA and Outside Pooling and Servicing Agreements, detailing the servicing responsibilities and transitions.)

Master Servicer

The primary entity responsible for the day-to-day administration of a pool of loans, including collecting payments, managing escrows, and reporting to investors. (Trimont LLC's appointment as master servicer signifies a major operational change for the trust.)

Special Servicer

An entity responsible for managing defaulted or specially serviced loans, often involving loan modifications, foreclosure, or other loss mitigation strategies. (The transition of special servicing roles, including past appointments of LNR Partners and Mount Street US, highlights the dynamic nature of loan management within the trust.)

Servicing Function Participant

An entity that performs specific servicing functions as part of a larger servicing arrangement, often under contract with the primary or master servicer. (CoreLogic Solutions, LLC's engagement by Trimont LLC indicates a delegation of specific servicing tasks.)

Shell Company

A company that has few or no assets or operations, often created for the purpose of facilitating financial transactions or avoiding regulatory oversight. (The filing explicitly states the registrant is NOT a shell company, which is a standard disclosure point.)

Year-Over-Year Comparison

This 10-K filing for the period ending December 31, 2025, primarily focuses on changes in servicing parties and regulatory compliance rather than traditional financial performance metrics, as financial statements are omitted. The most significant change compared to previous periods is the March 1, 2025, transition of servicing functions from Wells Fargo Bank, National Association to Trimont LLC. Unlike prior filings that might have detailed operational performance, this document highlights legal proceedings and the structural adherence to Regulation AB, indicating a shift in reporting emphasis.

Filing Documents

• msc15c22_10k-2025.htm (10-K) — 97KB
• msc15c22_31.htm (EX-31) — 14KB
• msc15c22_33-1.htm (EX-33.1) — 357KB
• msc15c22_33-2.htm (EX-33.2) — 1420KB
• msc15c22_33-3.htm (EX-33.3) — 702KB
• msc15c22_33-4.htm (EX-33.4) — 3113KB
• msc15c22_33-5.htm (EX-33.5) — 600KB
• msc15c22_33-6.htm (EX-33.6) — 626KB
• msc15c22_33-7.htm (EX-33.7) — 177KB
• msc15c22_33-8.htm (EX-33.8) — 992KB
• msc15c22_33-9.htm (EX-33.9) — 86KB
• msc15c22_33-10.htm (EX-33.10) — 2773KB
• msc15c22_33-11.htm (EX-33.11) — 172KB
• msc15c22_34-1.htm (EX-34.1) — 14KB
• msc15c22_34-2.htm (EX-34.2) — 11KB
• msc15c22_34-3.htm (EX-34.3) — 14KB
• msc15c22_34-4.htm (EX-34.4) — 11KB
• msc15c22_34-5.htm (EX-34.5) — 13KB
• msc15c22_34-6.htm (EX-34.6) — 10KB
• msc15c22_34-7.htm (EX-34.7) — 9KB
• msc15c22_34-8.htm (EX-34.8) — 693KB
• msc15c22_34-9.htm (EX-34.9) — 8KB
• msc15c22_34-10.htm (EX-34.10) — 10KB
• msc15c22_34-11.htm (EX-34.11) — 9KB
• msc15c22_35-1.htm (EX-35.1) — 1896KB
• msc15c22_35-2.htm (EX-35.2) — 2593KB
• msc15c22_35-3.htm (EX-35.3) — 1558KB
• msc15c22_35-4.htm (EX-35.4) — 1806KB
• msc15c22_35-5.htm (EX-35.5) — 2577KB
• msc15c22_35-6.htm (EX-35.6) — 2224KB
• msc15c22_35-7.htm (EX-35.7) — 191KB
• msc15c22_35-8.htm (EX-35.8) — 290KB
• 0001888524-26-005187.txt ( ) — 25065KB

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 MSBAM 2015-C22 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")

of Regulation AB

Item 1123 of Regulation AB. KeyBank National Association is the master servicer under the MSBAM 2015-C21 pooling and servicing agreement, pursuant to which the 555 11th Street NW mortgage loan is serviced. Because KeyBank National Association is not the MSBAM 2015-C22 master servicer, is not affiliated with any sponsor and services only the 555 11th Street NW mortgage loan, which constitutes greater than 5% but less than 10% of the mortgage pool, KeyBank National Association, as MSBAM 2015-C21 master servicer constitutes a reporting "servicing function participant" for purposes of 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. Mount Street US (Georgia) LLP is the current special servicer under the MSBAM 2015-C21 pooling and servicing agreement. On August 16, 2021, LNR Partners, LLC and CWCapital Asset Management LLC were replaced as general special servicer and excluded mortgage loan special servicer, respectively, under the MSBAM 2015-C21 pooling and servicing agreement and were succeeded by Mount Street US (Georgia) LLP. LNR Partners, LLC remains the special servicer under the MSBAM 2015-C21 pooling and servicing agreement solely with respect to the 555 11th Street NW mortgage loan. Mount Street US (Georgia) LLP, as special servicer under the MSBAM 2015-C21 pooling and servicing agreement, has no obligations with respect to the 555 11th Street NW mortgage loan or any mortgage loan included in the MSBAM 2015-C22 mortgage pool and therefore does not constitute a reporting "servicing function participant" for purposes of Item 1122 of Regulation AB, as specified in the Instruction 3 to 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. LNR Partners, LLC is the current special servicer under the MSBAM 201

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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