BANK 2019-BNK23 Annual Report - How They Did This Year (for the year ending December 31, 2025)

What does this company do and how did they perform this year?

BANK 2019-BNK23 is a special type of investment fund. It holds commercial mortgage loans. It doesn't sell products or services like a regular company. Instead, its only job is to hold a fixed group of commercial property loans. When you invest, you're buying a share of the payments from these loans. The fund offers different types of shares, called "certificates" or "notes." Each type has different payment rules and risks. This lets you pick how much risk you want from the property loans.

This annual report details how this mortgage pool was managed and run for the year ending December 31, 2025.

The specific commercial mortgage loans in this fund are:

• The Century Plaza Towers mortgage loan
• The Jackson Park mortgage loan
• The Park Tower at Transbay mortgage loan
• The National Anchored Retail Portfolio mortgage loan
• The ILPT Industrial Portfolio mortgage loan
• The 360 North Crescent Drive loan
• The Sacramento Office Portfolio loan

Banks like Morgan Stanley and Wells Fargo first made these loans. Then they put them into this fund. Often, several banks hold parts of a large commercial loan. They do this before it goes into a fund like BANK 2019-BNK23. This can make the setup complex. This setup helps spread risk and offers more investment chances.

This investment's success depends on the loans. It needs these commercial property loans to be healthy. They must make their payments and eventually be repaid. So, the financial health of these properties and their borrowers is key to the fund's success.

Key risks that could hurt the stock price

This report shares important details about lawsuits. These involve key companies that manage and service CMBS funds. Some of these companies work, or used to work, with BANK 2019-BNK23. These lawsuits aren't directly against our fund. But they can create wider risks. They might harm reputations or cause operational problems. This could indirectly affect the stability and value of all CMBS investments. That includes BANK 2019-BNK23.

Here's an analysis of the legal landscape:

• Past Lawsuits Against Wells Fargo Bank (for other funds): Wells Fargo used to play big roles in our fund. It has faced many lawsuits as a trustee for other residential mortgage funds (RMBS). Investors like Phoenix Light sued Wells Fargo. They claimed the bank failed its duties. They said it didn't enforce loan rules or protect investor interests in those RMBS funds. RMBS funds are like CMBS funds in structure. But they hold home loans. They often had different problems after the 2008 financial crisis.

  • Resolution Status: Most of these cases ended well for Wells Fargo or were settled. For example, Phoenix Light dropped its appeal in May 2023. Commerzbank AG's appeal was denied in October 2024. IKB's claims were resolved in November 2023. This means these past legal challenges are mostly over.
  • What This Means for Investors: These cases didn't directly involve our fund. But they show that big banks acting as trustees face constant legal checks. They also face possible lawsuits. Such lawsuits can use up a lot of money and time. They might distract management. They could also set examples for future claims. This is true even if these specific cases ended well.

• Lawsuits Against CWCapital Asset Management (CWCAM): CWCAM is a "special servicer" for some loans in CMBS funds. This includes the Century Plaza Towers loan in BANK 2019-BNK23. A special servicer steps in when a loan is late or defaults. Their job is to get the most money back for the fund. They do this through loan changes, foreclosure, or selling the property. Their work directly affects how well troubled loans perform.

  • CWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al.: This lawsuit started in 2017. It was complex and long-running. It claimed CWCAM broke contracts and duties. It also said CWCAM helped others do so.
    • Resolution Status: After many legal steps, the court dismissed two claims against CWCAM. This happened on January 13, 2026. CWCAM is no longer a defendant in this case. This is good news for CWCAM. It settles these claims and removes a big legal burden.
  • ROC Debt Strategies II Bond Investments LLC v. CWCAM: This lawsuit started on January 13, 2025. It claimed CWCAM was negligent. It said CWCAM poorly managed a group of loans.
    • Resolution Status: The parties settled this business dispute. The lawsuit was permanently dismissed on January 22, 2026. This means the case is definitely closed.
  • What This Means for Investors: CWCAM winning these lawsuits is good news. It helps stabilize loan servicing across the CMBS market. It makes CWCAM's ability to do its job clearer. They can focus on special servicing without legal distractions or costs. This stability matters to investors. Good special servicing can greatly improve how much money is recovered from bad loans.

• New Lawsuit Against Wilmington Trust (WTNA): On February 3, 2026, WTNA received a new lawsuit. WTNA isn't a main player for BANK 2019-BNK23. But it is a major trustee and custodian in the wider asset-backed securities market. This lawsuit claims WTNA broke contracts and duties. This relates to its roles for other asset-backed deals. Specifically, it involves Tricolor Holdings, LLC. The plaintiffs say WTNA didn't follow rules for "payment waterfalls." This is the order cash goes to different investors. They also cite servicing transition costs and post-default duties. They claim WTNA neglected some custodial tasks for related payments. An indenture trustee holds assets for bondholders. They make sure the fund follows its rules.

  • What This Means for Investors: This new lawsuit doesn't directly involve our fund. But it highlights constant legal checks on trustees and custodians. This is true across the asset-backed securities market. Claims about payment waterfalls and post-default duties are very serious. They challenge how investors are protected. They also question the integrity of the entire securitization system. Such lawsuits can increase regulatory oversight. They can also raise compliance costs for everyone in the market. They might even change future legal rules. This could affect how CMBS funds like ours operate. This is true even if the lawsuits are against other funds. WTNA says it will strongly fight these claims.

Leadership or strategy changes

In 2025, there were several important changes. These affected how BANK 2019-BNK23's mortgage loans are managed and overseen:

• Trimont LLC Takes Over Main Servicing: On March 1, 2025, Trimont LLC bought Wells Fargo's commercial mortgage servicing business. This was a big operational change. Because of this, Trimont LLC took over key roles. They became the master, primary, and special servicer for BANK 2019-BNK23. This also covered related agreements. Before March 1, 2025, Wells Fargo handled all these servicing jobs. This move puts many servicing jobs under Trimont LLC. This could make operations smoother. But it also concentrates operational risk. The master servicer watches the primary servicer. They ensure rules are followed and reports are made. The primary servicer handles daily loan tasks like collections. The special servicer manages loans that are behind or in trouble.

• CoreLogic Solutions, LLC Provides Steady Support: CoreLogic Solutions, LLC remained a "servicing function participant" all through 2025. This means CoreLogic offered special support services. They helped Wells Fargo, then Trimont LLC. These services included data processing, reporting, and analysis. CoreLogic's continuous involvement ensures steady administrative and data support. This is especially helpful when servicers change.

• Special Servicers for 2025 Loans: The fund uses different special servicers for different loans. This is due to their expertise or old contracts. A special servicer's job is vital. They manage loans that are defaulting or at high risk. They often negotiate, change loans, or foreclose. Their goal is to get the most money back for the fund. Their choices can greatly affect what investors earn.

  • CWCapital Asset Management LLC served the Century Plaza Towers loan all year.
  • Situs Holdings, LLC served the Jackson Park and ILPT Industrial Portfolio loans. This was for all of 2025. They had served Jackson Park since May 21, 2021.
  • Rialto Capital Advisors, LLC served the Park Tower at Transbay loan. They also served the National Anchored Retail Portfolio loan all year.
  • KeyBank National Association was also a general Special Servicer for the fund. This suggests they might serve other loans or act as a backup.

• Operating Advisor Role: Park Bridge Lender Services LLC remained the Operating Advisor for the fund all through 2025. The Operating Advisor provides independent oversight. They especially watch the special servicer's actions and decisions. Their job is to ensure the special servicer acts in the best interest of all investors. This includes those with lower-priority shares. They also mediate disputes or review proposed actions.

• Custodian and Certificate Administrator Roles Clarified:

  • Wells Fargo Bank kept its key roles all through 2025. They were the Custodian for mortgage loan documents. They also served as the fund's Certificate Administrator. The Custodian holds original loan documents. They ensure these documents are sound and have a clear history. This is crucial for enforcing the loans. The Certificate Administrator manages the fund's share records. They process payments to investors. They also handle investor communications.
  • Computershare Trust Company helped Wells Fargo all year. They acted as a "Servicing Function Participant" for both roles. This means Computershare offered support. But Wells Fargo kept the main legal responsibility for these roles all year.

• Servicer Compliance: The report confirms all servicers followed the rules. This includes Trimont, Wells Fargo, Computershare, KeyBank, Park Bridge, CoreLogic, CWCapital, Situs, and Rialto. They all reported compliance with asset-backed securities standards. Following these rules is essential. It keeps the fund operating correctly. It also assures investors that regulations are met.

These changes mostly affect the fund's operations and administration. They do not change the investment strategy. They also don't change the loans in the fund.