Fitch Ratings has upgraded and assigned Stable Outlooks to seven classes of COMM 2013-GAM Mortgage Trust.

RATING ACTIONS

Entity / Debt

Rating

Prior

COMM 2013-GAM Mortgage Trust

A-2 12624UAC8

LT

AAAsf

Upgrade

AAsf

B 12624UAJ3

LT

AA-sf

Upgrade

Asf

C 12624UAL8

LT

Asf

Upgrade

BBBsf

D 12624UAN4

LT

BBBsf

Upgrade

BBsf

E 12624UAQ7

LT

BBB-sf

Upgrade

BB-sf

F 12624UAS3

LT

BB-sf

Upgrade

B-sf

X-A 12624UAE4

LT

AAAsf

Upgrade

AAsf

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VIEW ADDITIONAL RATING DETAILS

KEY RATING DRIVERS

Improved Performance; Cash Flow, Occupancy and Sales: The upgrades and Stable Outlooks are the result of post-pandemic performance improvement and greater clarity on the sponsor's longer-term business plan that is expected to increase the refinanceability of the loan. Since the prior rating action, Fitch's net cash flow (NCF) has improved to expectations at issuance, sales now exceed issuance levels, the loan has continued to amortize and the sponsor has successfully leased or renewed two of the three anchor spaces: Primark leased 49k sf of the former JCPenney's vacant space and Sears extended their lease for five years to 2028. Per the servicer, the borrower has leasing prospects for additional vacant space. The Fitch NCF is $26.9 million compared to $25.8 million at the last rating action and is considered in-line with the Fitch NCF at issuance of $27.9 million. Fitch's NCF is based on the annualized September 2022 income adjusted to remove rental income from the vacant Kohl's and Sears space. The servicer reported YE 2021 NCF was $26.4 million compared to $27.5 million at YE 2020, and $31.9 million at YE 2019.

Total mall physical occupancy has improved to 79.2% (including Primark which is expected to open in early 2023) from 73.4% as of September 2021, 77.1% in April 2021, 86% in May 2020, and 97.8% in March 2019. The decline in physical occupancy since 2019 is due to the departure of Kohl's in April 2019, JC Penney in April 2020 and Sears in April 2021. Kohl's and Sears continue to pay rent with lease expirations in January 2031 and October 2028, respectively. Sears recently extended their lease and, per the servicer, is considering subleasing the space. The former 72,795 sf Century 21 space has been tenanted by Shoppers World on a lease that commenced June 2021; however, at an annual rental rate of $8.24psf which is lower than the former Century 21 lease payment. Economic occupancy is now 90.8%.

Post-pandemic sales at the property have rebounded to above issuance levels. Comparable in- line sales were $727psf as of TTM September 2022 compared to $453psf as of TTM February 2021 (which includes pandemic-related closures), $672psf as of TTM February 2020, $650psf as of TTM March 2019, $635psf as of TTM March 2018, and $501psf at issuance. Macy's sales increased to $201 psf as of September 2022 from $113psf as of February 2021, $186psf in 2019, $177psf as of TTM September 2018, $204psf at YE 2015 and $225psf at issuance, while Macy's Men's & Furniture also increased to $160psf from $82psf as of February 2021, $143psf in 2019, $140psf as of TTM September 2018, and $173psf at issuance.

Maturity Date Extension: The loan transferred to special servicing in December 2020 due to the imminent loan maturity in February 2021 and the borrower's initial request for relief due to the pandemic. The borrower rescinded the relief request but negotiated a maturity extension to February 2022 with one additional extension until February 2023 which the borrower previously exercised. The loan is set to mature in February 2023.

Amortization: As of the December 2022 distribution date, the pool's aggregate certificate balance has paid down approximately 26.8% as a result of scheduled amortization and a principal curtailment of $9 million prior to the loan extension.

Fitch Leverage: The Fitch debt service coverage ratio (DSCR) and loan to value (LTV) for the asset is 1.08x and 83.7%, respectively. The Fitch debt yield is 11.3%.

Single Asset Concentration: The Green Acres Mall loan was originally an eight-year amortizing, fixed-rate loan (3.4325%) secured by a 1,811,441-sf enclosed two-level regional mall located in a densely populated area on Sunrise Highway in Valley Stream, NY. The mall was built in 1956 and has been expanded several times with the latest in 2007 and 2015. The transaction is secured by the single property and, therefore, is more susceptible to single-event risk related to the market, sponsor, or the largest tenants occupying the property. The loan sponsor is an entity controlled by Macerich Company, an experienced owner of regional shopping centers and malls. The sponsor acquired the property in January 2013 at a cost of $507 million.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to negative rating action/downgrade:

Downgrades to all classes would occur with declines in occupancy, cash flow and sales, and/or a default at the upcoming maturity in February 2023 combined with lack of favorable resolution information. Downgrades to the senior classes A-2 and X-A would be downgraded to 'Asf' should interest shortfalls be incurred.

Factors that could, individually or collectively, lead to positive rating action/upgrade:

Upgrades are not expected; however, factors that lead to upgrades would include significantly improved asset performance.

Best/Worst Case Rating Scenario

International scale credit ratings of Structured Finance transactions have a best-case rating upgrade scenario (defined as the 99th percentile of rating transitions, measured in a positive direction) of seven notches over a three-year rating horizon; and a worst-case rating downgrade scenario (defined as the 99th percentile of rating transitions, measured in a negative direction) of seven notches over three years. The complete span of best- and worst-case scenario credit ratings for all rating categories ranges from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings are based on historical performance. For more information about the methodology used to determine sector-specific best- and worst-case scenario credit ratings, visit https://www.fitchratings.com/site/re/10111579.

USE OF THIRD PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G -10

Form ABS Due Diligence-15E was not provided to, or reviewed by, Fitch in relation to this rating action.

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF RATING

The principal sources of information used in the analysis are described in the Applicable Criteria.

ESG Considerations

Unless otherwise disclosed in this section, the highest level of ESG credit relevance is a score of '3'. This means ESG issues are credit-neutral or have only a minimal credit impact on the entity, either due to their nature or the way in which they are being managed by the entity. For more information on Fitch's ESG Relevance Scores, visit www.fitchratings.com/esg

Additional information is available on www.fitchratings.com

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