Fitch Ratings has affirmed 12 classes of COMM 2015-CCRE22 Mortgage Trust commercial mortgage pass-through certificates, series 2015-CCRE22.

RATING ACTIONS

Entity / Debt

Rating

Prior

COMM 2015-CCRE22

A-3 12592XBA3

LT

AAAsf

Affirmed

AAAsf

A-4 12592XBC9

LT

AAAsf

Affirmed

AAAsf

A-5 12592XBD7

LT

AAAsf

Affirmed

AAAsf

A-M 12592XBF2

LT

AAAsf

Affirmed

AAAsf

A-SB 12592XBB1

LT

AAAsf

Affirmed

AAAsf

B 12592XBG0

LT

AA-sf

Affirmed

AA-sf

C 12592XBJ4

LT

A-sf

Affirmed

A-sf

D 12592XAG1

LT

BBB-sf

Affirmed

BBB-sf

E 12592XAJ5

LT

BB-sf

Affirmed

BB-sf

Page

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VIEW ADDITIONAL RATING DETAILS

KEY RATING DRIVERS

Stable Loss Expectations: Overall loss expectations have slightly improved since Fitch's prior rating action and the performance of properties previously impacted by the pandemic have generally improved. Eight loans are considered Fitch Loans of Concern (FLOCs -- 18.6% of the pool) including two properties within the top 15 with declining performance, occupancy and/or upcoming rollover concerns. Fitch's current ratings reflect a base case loss of 5.70%.

The largest increase in loss since the last rating action is the Wells Fargo Portfolio (8.5%), which comprises a group of six crossed loans secured by six single-tenant, office properties totaling 1,636,299-sf located in Virginia, Georgia, North Carolina, and South Carolina.

Occupancy for the portfolio as of March 2022 was 74%, down from 91% at YE 2021 and 100% at YE 2020. Occupancy declined after Wells Fargo gave notice of its intent not to renew its lease at the Wells Fargo Winston-Salem West End II location. According to the servicer, the space is currently dark, and a broker is currently marketing the space. In addition, Wells Fargo exercised an option to downsize their space at the Wells Fargo Atlanta property in 2018.

As of March 2022, the Wells Fargo Atlanta property reported an occupancy of 46.1% and all the former Wells Fargo space remained vacant. Fitch requested a leasing update from the master servicer, but has not received a response. As of the October 2022 reserve report, $31.9 million of tenant reserves was reported for the portfolio.

According to the third-quarter 2022 CoStar, market rents in the Airport/South Atlanta office submarket average $21.22 psf and the submarket vacancy rate is 8.8%. Market rents in the St. Andrews office submarket in the Columbia market average $17.20 psf and the submarket vacancy rate is 11.2%. Market rents in the Roanoke market area average $15.99 psf and the market vacancy rate is 16.2%. Market rents in the Greensboro/Winston-Salem office market average $18.21 psf and the market vacancy rate is 10.0%. As of March 2022, the weighted average in-place gross rent of the portfolio was $7.76 psf.

The largest decrease in loss since the last rating action is Wonderbread (3.0%), which is secured by an 82,132-sf office building located in Washington, D.C. The property was built in 1919 and renovated in 2014. As of the June 2022 rent roll, occupancy was 99.4%, up from 59.3% at YE 2021, 100% at YE 2020 and 100% at YE 2019. Occupancy declined to 59.3% as of YE 2021 due to major tenant WeWork previously (40.7% of NRA) vacating prior to the September 2026 lease expiry. Per the June 2022 rent roll, the vacant space was subsequently backfilled by Douglas Wonderbread LLC, Douglas Wonderbread LLC which operates a co-working space at the property and pays a rental rate in excess of that paid by WeWork.

The property's major tenants include, Douglas Wonderbread, LLC (40.0% NRA; 5/2031), Children's Hospital (39.0% NRA; 6/2034), and Streetsense DC LLC (20.3% NRA; 10/2026). Per CoStar, the property is located in the Shaw Office Submarket of the Washington D.C. market, submarket asking rents average $44.79 psf and the submarket vacancy rate is 6.0%. As of the June 2022 rent roll, the average in-place gross rent of the property was $45.

Increased Credit Enhancement: As of the October 2022 distribution date, the pool's aggregate principal balance has paid down by 25.6% to $964.9 million from $1.3 billion at issuance. Since the prior rating action, one loan has been defeased (0.5% of the pool) and two loans ($6.0 million) have prepaid ahead of their scheduled maturity dates. The pool has experienced $253,055 (0.02% of the original pool balance) in realized losses since issuance.

RATING SENSITIVITIES

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

Factors that lead to downgrades include an increase in pool level losses from underperforming loans.

Downgrades would occur with an increase in pool-level losses from underperforming or specially serviced loans. Downgrades to classes A-3, A-4, A-5, A-SB, A-M and X-A are not likely due to the position in the capital structure, but may occur should interest shortfalls affect these classes. Downgrades to classes B, C, D, E and X-B may occur should expected pool losses increase significantly and/or the FLOCs and/or loans susceptible to the pandemic suffer losses.

Fitch has identified both a baseline and a worse-than-expected, adverse stagflation scenario based on fallout from the Russia-Ukraine war whereby growth is sharply lower amid higher inflation and interest rates; even if the adverse scenario should play out, Fitch expects virtually no impact on ratings performance, indicating very few rating or Outlook changes. However, for some transactions with concentrations in underperforming retail exposure, the ratings impact may be mild to modest, indicating some changes on sub-investment grade notes.

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

Factors that could lead to upgrades would include stable to improved asset performance, coupled with additional paydown and/or defeasance. Upgrades to the 'A-sf' and 'AA-sf' rated classes are not expected, but may occur with significant improvement in CE and/or defeasance, in addition to the stabilization of properties impacted from the coronavirus pandemic.

Upgrades of the 'BBB-sf' category rated classes are considered unlikely, until the later years in the transaction and only if the performance of the remaining pool is stable and there is sufficient CE to the class. Classes would not be upgraded above 'Asf' if there is a likelihood of interest shortfalls.

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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