UNITED STATES
SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM 10-K

(Mark One)

x ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended December 31, ~~2024~~2025 or

o TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from _____ to _____

Commission file number of the issuing entity: 333-226486-16

Central Index Key Number of the issuing entity: 0001822166

BANK 2020-BNK28

(exact name of the issuing entity as specified in its charter)

Central Index Key Number of the depositor: 0000850779

Wells Fargo Commercial Mortgage Securities, Inc.

(exact name of the depositor as specified in its charter)

Central Index Key Number of the sponsor: 0000740906

Wells Fargo Bank, National Association

(exact name of the sponsor as specified in its charter)

Central Index Key Number of the sponsor: 0001541557

Morgan Stanley Mortgage Capital Holdings LLC

(exact name of the sponsor as specified in its charter)

Central Index Key Number of the sponsor: 0001102113

Bank of America, National Association

(exact name of the sponsor as specified in its charter)

New York
(State or other jurisdiction of
incorporation or organization of

the issuing entity)

38-4155239

38-4155240

38-7250431

(I.R.S. Employer

Identification Numbers)

c/o Computershare Trust Company, National Association, as agent for

Wells Fargo Bank, National Association

as Certificate Administrator

9062 Old Annapolis Road

Columbia, MD

(Address of principal executive offices of the issuing entity)

21045

(Zip Code)

Registrant’s telephone number, including area code:

(704) 374-6161

Securities registered pursuant to Section 12(b) of the Act:

Title of each class	Trading Symbol(s)	Name of each exchange on which registered
None

Securities registered pursuant to Section 12(g) of the Act: None.

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. o Yes ⌧ No

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act. o Yes ⌧ No

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days. ⌧ Yes o No

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (Section 232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).

Not applicable.

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company, or an emerging growth company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company,” and “emerging growth company” in Rule 12b-2 of the Exchange Act.

Large accelerated filer o Accelerated filer o

Non-accelerated filer ⌧ Smaller reporting company o

Emerging growth company o

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act. o

Indicate by check mark whether the registrant has filed a report on and attestation to its management’s assessment of the effectiveness of its internal control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or issued its audit report. o

If securities are registered pursuant to Section 12(b) of the Act, indicate by check mark whether the financial statements of the registrant included in the filing reflect the correction of an error to previously issued financial statements. o

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). o

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Act). o Yes ⌧ No

State the aggregate market value of the voting and non-voting common equity held by 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. o Yes o No

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 9th & Thomas Mortgage Loan, the ExchangeRight Net Leased Portfolio #39 Mortgage Loan and the Chasewood Technology Park Mortgage Loan, which constituted approximately 9.7%, 5.2% and 4.2%, respectively, of the asset pool of the issuing entity as of its cut-off date, are each an asset of the issuing entity and are each part of a loan combination that includes the 9th & Thomas Mortgage Loan, the ExchangeRight Net Leased Portfolio #39 Mortgage Loan or the Chasewood Technology Park Mortgage Loan and one other pari passu loan, which is not an asset of the issuing entity. These loan combinations, including the 9th & Thomas Mortgage Loan, the ExchangeRight Net Leased Portfolio #39 Mortgage Loan and the Chasewood Technology Park Mortgage Loan, are being serviced and administered pursuant to the Pooling and Servicing Agreement, which is incorporated by reference as Exhibit 4.1 to this Annual Report on Form 10-K.

The Exhibit Index describes exhibits provided by certain parties (in their capacities indicated on the Exhibit Index) with respect to the 711 Fifth Avenue Mortgage Loan, which constituted approximately 8.3% of the asset pool of the issuing entity as of its cut-off date. The 711 Fifth Avenue Mortgage Loan is an asset of the issuing entity and is part of a loan combination that includes the 711 Fifth Avenue Mortgage Loan and twenty other pari passu loans, which are not assets of the issuing entity. A pari passu portion of the loan combination was securitized in the GS Mortgage Securities Trust 2020-GC47 transaction, Commission File Number 333-226082-07 (the “GSMS 2020-GC47 Transaction”). This loan combination, including the 711 Fifth Avenue Mortgage Loan, is being serviced and administered pursuant to the pooling and servicing agreement for the GSMS 2020-GC47 Transaction, which is incorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K.

The master servicer of a pooling and servicing agreement or trust and servicing agreement also functions as the primary servicer of the related mortgage loans serviced and administered pursuant to such agreement unless a separate primary servicer is identified herein. If this report does not identify a separate primary servicer, the servicer compliance statement provided by the master servicer under any such agreement also encompasses its responsibilities as primary servicer of the related mortgage loan or mortgage loans.

Wells Fargo Bank, National Association is the certificate administrator of the mortgage loans serviced under the Pooling and Servicing Agreement, the general master servicer (except with respect to those mortgage loans for which National Cooperative Bank, N.A. is the master servicer) ~~and certificate administrator~~ of the mortgage loans serviced under the Pooling and Servicing Agreement prior to March 1, 2025 and the primary servicer of the 711 Fifth Avenue Mortgage Loan prior to March 1, 2025. As a result, Wells Fargo Bank, National Association is a “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities described above, because it is servicing mortgage loans that constituted 10% or more of the assets of the issuing entity as of its cut-off date. The assessments of compliance with applicable servicing criteria, accountants’ attestation reports and servicer compliance statements delivered by Wells Fargo Bank, National Association in the capacities described above are listed in the Exhibit Index.

Trimont LLC is the general master servicer (except with respect to those mortgage loans for which National Cooperative Bank, N.A. is the master servicer) of the mortgage loans serviced under the Pooling and Servicing Agreement on and after March 1, 2025 and the primary servicer of the 711 Fifth Avenue Mortgage Loan on and after March 1, 2025. As a result, Trimont LLC is a “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities described above, because it is servicing mortgage loans that constituted 10% or more of the assets of the issuing entity as of its cut-off date. The assessments of compliance with applicable servicing criteria, accountants’ attestation reports and servicer compliance statements delivered by Trimont LLC in the capacities described above are listed in the Exhibit Index.

KeyBank National Association is the general special servicer (except with respect to those mortgage loans for which National Cooperative Bank, N.A. is the special servicer) of the mortgage loans serviced under the Pooling and Servicing Agreement and the special servicer of the 711 Fifth Avenue Mortgage Loan. As a result, KeyBank National Association is a “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities described above, because it is servicing mortgage loans that constituted 10% or more of the assets of the issuing entity as of its cut-off date. The assessments of compliance with applicable servicing criteria, accountants’ attestation reports and servicer compliance statements delivered by KeyBank National Association in the capacities described above are listed in the Exhibit Index.

Wilmington Trust, National Association acts as trustee of the mortgage loans serviced under the Pooling and Servicing Agreement and the 711 Fifth Avenue Mortgage Loan. Pursuant to the Pooling and Servicing Agreement and the pooling and servicing agreement for the GSMS 2020-GC47 Transaction, the trustee is required to provide an assessment of compliance with applicable servicing criteria solely with respect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances of funds or guarantees regarding collections, cash flows or distributions, and any interest or other fees charged for such advances, are made, reviewed and approved as specified in the transaction agreements). However, during the reporting period, the trustee did not perform any servicing function with respect to the servicing criteria specified in Item 1122(d)(2)(iii) of Regulation AB. The master servicer or the special servicer, to the extent required, performed the servicing function identified with respect to Item 1122(d)(2)(iii) of Regulation AB, and each such party included Item 1122(d)(2)(iii) of Regulation AB in the assessment of compliance with applicable servicing criteria and accountant’s attestation report for the subject transaction. As a result, this Annual Report on Form 10-K does not include an assessment of compliance with applicable servicing criteria of the trustee. One or more other servicers of the mortgage loans serviced under the Pooling and Servicing Agreement and the 711 Fifth Avenue Mortgage Loan have delivered one or more assessments of compliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-K includes assessments of compliance with applicable servicing criteria and accountants’ attestation reports from CoreLogic Solutions, LLC This entity was engaged by ~~the~~each general master servicer (except with respect to those mortgage loans for which National Cooperative Bank, N.A. is the master servicer) of the mortgage loans serviced under the Pooling and Servicing Agreement and ~~the~~each primary servicer of the 711 Fifth Avenue Mortgage Loan to remit tax payments received from the escrow accounts of borrowers to local taxing authorities, to report tax amounts due, to verify tax parcel information, and to verify non-escrow tax payments. These servicing functions are included within the servicing criteria set forth in 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~~ purposes of Item 1122 of Regulation AB. See Compliance and ~~Disclosure~~ 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)).

The assessment of compliance with applicable servicing criteria, accountants’ attestation report and servicer compliance statement of the certificate administrator of the 711 Fifth Avenue Mortgage Loan is omitted from this Annual Report on Form 10-K as the certificate administrator pursuant to the related pooling and servicing agreement or trust and servicing agreement does not perform any activities that address servicing criteria with respect to the issuing entity and because it is not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

PART I

Item 1. Business.

Omitted.

Item 1A. Risk Factors.

Omitted.

Item 1B. Unresolved Staff Comments.

None.

Item 1C. Cybersecurity.

Omitted.

Item 2. Properties.

Omitted.

Item 3. Legal Proceedings.

Omitted.

Item 4. Mine Safety Disclosures.

Not applicable.

PART II

Omitted.

Item 6.

[Reserved].

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations.

Omitted.

Item 7A. Quantitative and Qualitative Disclosures About Market Risk.

Omitted.

Item 8. 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.

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.

Omitted.

Item 12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters.

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.

No single obligor represents 10% or more of the pool assets held by the issuing entity.

Item 1114(b)(2) of Regulation AB, Significant Enhancement Provider Financial Information.

No entity or group of affiliated entities provides any external credit enhancement or other support for the certificates within this transaction 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 or other support for the certificates within this transaction as described under Item 1115 of Regulation AB.

Item 1117 of Regulation AB, Legal Proceedings.

The registrant knows of no material pending legal proceeding involving the trust or any party related to the trust, other than routine litigation incidental to the duties of those respective parties~~, and the following, with respect to Wells Fargo Bank, National Association, as certificate administrator and custodian~~.

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 Wells Fargo Bank, N.A., as trustee, caused losses to investors, and plaintiffs assert causes of action based upon, among other things, the trustee’s alleged failure to notify and enforce repurchase obligations of mortgage loan sellers for purported breaches of representations and warranties, notify investors of alleged events of default, and abide by appropriate standards of care following alleged events of default. In July 2022, the district court dismissed Phoenix Light’s claims and certain of the claims asserted by Commerzbank AG, and subsequently entered judgment in each case in favor of Wells Fargo Bank, N.A. In August 2022, Phoenix Light and Commerzbank AG each appealed the district court’s decision to the United States Court of Appeals for the Second Circuit. Phoenix Light dismissed its appeal in May 2023, terminating its case. In October 2024, the Second Circuit denied Commerzbank AG’s appeal. In November 2023, Wells Fargo Bank, N.A. entered into an agreement with IKB to resolve IKB’s claims. Wells Fargo Bank, N.A. previously settled two class actions filed by institutional investors and an action filed by the National Credit Union Administration with similar allegations.

Item 1119 of Regulation AB, Affiliations and Certain Relationships and Related Transactions.

The information regarding this Item has been previously provided in the prospectus of the Registrant relating to the issuing entity filed on September 30, 2020 pursuant to Rule 424(b)(2).

Item 1122 of Regulation AB, Compliance with Applicable Servicing Criteria.

The reports on assessments of compliance with the servicing criteria for asset-backed securities and related attestation reports on such assessments of compliance with respect to the mortgage loans are attached hereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to the Pooling and Servicing Agreement incorporated by reference as Exhibit 4.1 to this Annual Report on Form 10-K is a chart identifying the entities participating in a servicing function for the transaction responsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicing criteria for asset-backed securities and related attestation reports on such assessments of compliance with respect to the 711 Fifth Avenue Mortgage Loan, which is being serviced and administered pursuant to the pooling and servicing agreement for the GSMS 2020-GC47 Transaction, are attached hereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to the pooling and servicing agreement for the GSMS 2020-GC47 Transaction incorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K is a chart identifying the entities participating in a servicing function for the GSMS 2020-GC47 Transaction responsible for each applicable servicing criteria set forth in Item 1122(d).

Item 1123 of Regulation AB, Servicer Compliance Statement.

The servicer compliance statements are attached as Exhibits to this Annual Report on Form 10-K.

PART IV

Item 15. Exhibits and Financial Statement Schedules.

(a) The following is a list of documents filed as part of this Annual Report on Form 10-K:

(1) Not applicable

(2) Not applicable

(3) See below

4.1 Pooling and Servicing Agreement, dated as of September 1, 2020, among Wells Fargo Commercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, National Association, as General Master Servicer, KeyBank National Association, as General Special Servicer, National Cooperative Bank, N.A., as Co-op Master Servicer and as Co-op Special Servicer, Wells Fargo Bank, National Association, as Certificate Administrator, Wilmington Trust, National Association, as Trustee, and Park Bridge Lender Services LLC, as Operating Advisor and Asset Representations Reviewer (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-K filed on September 30, 2020 under Commission File No. 333-226486-16 and incorporated by reference herein).

4.2 Pooling and Servicing Agreement, dated as of May 1, 2020, by and among GS Mortgage Securities Corporation II, as Depositor, Wells Fargo Bank, National Association, as Master Servicer, KeyBank National Association, as Special Servicer, Wilmington Trust, National Association, as Trustee, Wells Fargo Bank, National Association, as Certificate Administrator, and Park Bridge Lender Services LLC, as Operating Advisor and as Asset Representations Reviewer (filed as Exhibit 4.2 to the registrant’s Current Report on Form 8-K filed on September 30, 2020 under Commission File No. 333-226486-16 and incorporated by reference herein).

4.3 Agreement Between Note Holders, dated as of September 4, 2020, by and between Bank of America, N.A., as Initial Note A-1 Holder, Bank of America, N.A., as Initial Note A-2 Holder, Bank of America, N.A., as Initial Note A-3 Holder, Bank of America, N.A., as Initial Note A-4 Holder, and Bank of America, N.A., Initial Note A-5 Holder (filed as Exhibit 4.3 to the registrant’s Current Report on Form 8-K filed on September 30, 2020 under Commission File No. 333-226486-16 and incorporated by reference herein)

4.5 Agreement Between Note Holders, dated as of September 3, 2020, by and between Bank of America, N.A., as Initial Note A-1 Holder, and Bank of America, N.A., as Initial Note A-2 Holder (filed as Exhibit 4.5 to the registrant’s Current Report on Form 8-K filed on September 30, 2020 under Commission File No. 333-226486-16 and incorporated by reference herein)

4.6 Agreement Between Note Holders, dated as of September 30, 2020, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder, Morgan Stanley Bank, N.A., as Initial Note A-2 Holder, and Morgan Stanley Mortgage Capital Holdings LLC, as Initial Agent (filed as Exhibit 4.6 to the registrant’s Current Report on Form 8-K filed on September 30, 2020 under Commission File No. 333-226486-16 and incorporated by reference herein)

31 Rule 13a-14(d)/15d-14(d) Certifications.

33 Reports on assessment of compliance with servicing criteria for asset-backed securities.

33.1 Wells Fargo Bank, National Association, as General Master Servicer prior to March 1, 2025

33.2 ~~National~~Trimont ~~Cooperative Bank~~LLC, ~~N.A.,~~ as ~~Co-op~~General Master Servicer on and after March 1, 2025

33.3 ~~KeyBank~~ National ~~Association~~Cooperative Bank, N.A., as ~~General~~Co-op ~~Special~~Master Servicer

33.4 KeyBank National ~~Cooperative Bank~~Association, ~~N.A.,~~ as ~~Co-op~~General Special Servicer ~~(see Exhibit 33.2)~~

33.5 ~~Wilmington~~National ~~Trust~~Cooperative Bank, ~~National Association~~N.A., as ~~Trustee~~Co-op Special Servicer (~~Omitted.~~see ~~See~~Exhibit ~~Explanatory Notes~~33.3)

33.6 ~~Wells~~Wilmington ~~Fargo Bank~~Trust, National Association, as ~~Certificate~~ ~~Administrator~~Trustee (Omitted. See Explanatory Notes.)

33.7 Wells Fargo Bank, National Association, as ~~Custodian~~Certificate Administrator

33.8 ~~Park~~Wells ~~Bridge~~Fargo ~~Lender~~Bank, ~~Services~~National ~~LLC~~Association, as ~~Operating~~ ~~Advisor~~Custodian

33.9 ~~CoreLogic~~Park ~~Solutions,~~Bridge Lender Services LLC, as ~~Servicing Function~~Operating ~~Participant~~Advisor

33.10 ~~Computershare~~CoreLogic ~~Trust Company~~Solutions, ~~National Association~~LLC, as Servicing Function Participant ~~for the Certificate Administrator~~

33.11 Computershare Trust Company, National Association, as Servicing Function Participant for the ~~Custodian~~Certificate Administrator

33.12 ~~Wells~~Computershare ~~Fargo~~Trust ~~Bank~~Company, National Association, as ~~Primary Servicer~~Servicing ofFunction ~~the~~Participant ~~9th~~for &the ~~Thomas Mortgage Loan (see Exhibit 33.1)~~Custodian

33.13 ~~KeyBank~~Wells Fargo Bank, National Association, as ~~Special Servicer~~Primary Servicer of the 9th & Thomas Mortgage Loan prior to March 1, 2025 (see Exhibit 33.31)

33.14 ~~Wilmington~~Trimont ~~Trust~~LLC, ~~National Association,~~ as ~~Trustee~~Primary Servicer of the 9th & ~~Thomas~~ Thomas Mortgage Loan ~~(Omitted.~~on ~~See~~and ~~Explanatory~~after ~~Notes~~March 1, 2025 (see Exhibit 33.2)

33.15 ~~Wells~~KeyBank ~~Fargo Bank,~~ National Association, as ~~Custodian~~ Special Servicer of the 9th & Thomas Mortgage Loan (see Exhibit 33.74)

33.16 ~~Park~~Wilmington ~~Bridge~~Trust, ~~Lender~~National ~~Services LLC~~Association, as ~~Operating Advisor~~Trustee of the 9th & Thomas Mortgage Loan (~~see~~Omitted. ~~Exhibit~~See 33Explanatory Notes.8)

33.17 ~~CoreLogic~~Wells ~~Solutions,~~Fargo ~~LLC~~Bank, asNational ~~Servicing~~Association, ~~Function~~as ~~Participant~~Custodian of the 9th & Thomas Mortgage Loan (see Exhibit 33.98)

33.18 ~~Computershare~~Park ~~Trust~~Bridge ~~Company,~~Lender ~~National~~Services ~~Association~~LLC, as ~~Servicing~~Operating Advisor ~~Function~~of ~~Participant~~the ~~for~~9th ~~the~~& ~~Custodian~~Thomas Mortgage Loan (see Exhibit 33.119)

33.19 ~~Wells~~CoreLogic ~~Fargo Bank~~Solutions, ~~National Association~~LLC, as ~~Primary~~Servicing Function ~~Servicer~~Participant of the ~~ExchangeRight~~9th ~~Net~~& ~~Leased~~Thomas ~~Portfolio #39~~ Mortgage Loan (see Exhibit 33.110)

33.20 ~~KeyBank~~Computershare Trust Company, National Association, as ~~Special~~Servicing ~~Servicer of~~Function ~~the~~Participant ~~ExchangeRight~~for ~~Net~~the ~~Leased~~Custodian ~~Portfolio #39 Mortgage Loan~~ (see Exhibit 33.312)

33.21 ~~Wilmington~~Wells ~~Trust~~Fargo Bank, National Association, as ~~Trustee~~Primary Servicer of the ExchangeRight Net Leased Portfolio #39 Mortgage Loan ~~(Omitted.~~prior ~~See~~to March ~~Explanatory~~1, ~~Notes~~2025 (see Exhibit 33.1)

33.22 ~~Wells~~Trimont ~~Fargo Bank~~LLC, ~~National~~as ~~Association,~~Primary ~~as Custodian~~Servicer of the ExchangeRight Net Leased Portfolio #39 Mortgage Loan on and after March 1, 2025 (see Exhibit 33.72)

33.23 ~~Park~~KeyBank ~~Bridge~~National ~~Lender Services LLC~~Association, as ~~Operating Advisor~~Special Servicer of the ExchangeRight Net Leased Portfolio #39 Mortgage Loan (see Exhibit 33.84)

33.24 ~~CoreLogic~~Wilmington ~~Solutions~~Trust, ~~LLC~~National Association, as ~~Servicing~~Trustee ~~Function Participant~~ of the ExchangeRight Net Leased Portfolio #39 Mortgage Loan (~~see Exhibit~~Omitted. 33See Explanatory Notes.9)

33.25 ~~Computershare~~Wells ~~Trust~~Fargo ~~Company~~Bank, National Association, as Custodian ~~Servicing~~of ~~Function~~the ~~Participant~~ExchangeRight ~~for~~Net ~~the~~Leased ~~Custodian~~Portfolio #39 Mortgage Loan (see Exhibit 33.118)

33.26 ~~Wells~~Park ~~Fargo~~Bridge ~~Bank,~~Lender ~~National~~Services ~~Association~~LLC, as ~~Primary~~Operating ~~Servicer~~Advisor of the ~~Chasewood~~ExchangeRight ~~Technology~~Net ~~Park~~Leased Portfolio #39 Mortgage Loan (see Exhibit 33.19)

33.27 ~~KeyBank~~CoreLogic ~~National~~Solutions, ~~Association~~LLC, as ~~Special~~Servicing ~~Servicer~~Function Participant of the ~~Chasewood~~ExchangeRight ~~Technology~~Net ~~Park~~Leased Portfolio #39 Mortgage Loan (see Exhibit 33.310)

33.28 ~~Wilmington~~Computershare Trust Company, National Association, as ~~Trustee~~Servicing ofFunction ~~the~~Participant ~~Chasewood~~for ~~Technology Park~~the ~~Mortgage~~Custodian ~~Loan~~ (~~Omitted.~~see ~~See~~Exhibit ~~Explanatory Notes~~33.12)

33.29 Wells Fargo Bank, National Association, as Primary ~~Custodian~~Servicer of the Chasewood Technology Park Mortgage Loan prior to March 1, 2025 (see Exhibit 33.71)

33.30 ~~Park~~Trimont ~~Bridge Lender Services~~ LLC, as ~~Operating Advisor~~Primary Servicer of the Chasewood Technology Park Mortgage Loan on and after March 1, 2025 (see Exhibit 33.82)

33.31 ~~CoreLogic~~KeyBank ~~Solutions,~~National ~~LLC~~Association, as ~~Servicing~~Special ~~Function~~Servicer ~~Participant~~ of the Chasewood Technology Park Mortgage Loan (see Exhibit 33.94)

33.32 ~~Computershare~~Wilmington Trust ~~Company~~, National Association, as ~~Servicing~~Trustee ~~Function~~of ~~Participant~~the ~~for~~Chasewood ~~the~~Technology Park ~~Custodian~~Mortgage Loan (~~see~~Omitted. ~~Exhibit~~See 33Explanatory Notes.11)

33.33 Wells Fargo Bank, National Association, as ~~Primary~~ ~~Servicer~~Custodian of the ~~711~~Chasewood ~~Fifth~~Technology ~~Avenue~~Park Mortgage Loan (see Exhibit 33.18)

33.34 ~~KeyBank~~Park ~~National~~Bridge ~~Association~~Lender Services LLC, as ~~Special Servicer~~Operating Advisor of the ~~711~~Chasewood ~~Fifth~~Technology ~~Avenue~~Park Mortgage Loan (see Exhibit 33.39)

33.35 ~~Wilmington~~CoreLogic ~~Trust~~Solutions, ~~National Association~~LLC, as ~~Trustee~~Servicing Function Participant of the ~~711~~Chasewood ~~Fifth~~Technology ~~Avenue~~ Park Mortgage Loan (~~Omitted.~~see ~~See~~Exhibit ~~Explanatory Notes~~33.10)

33.36 ~~Wells~~Computershare ~~Fargo~~Trust ~~Bank~~Company, National Association, as ~~Custodian~~as ofServicing ~~the~~Function ~~711~~Participant ~~Fifth~~for ~~Avenue~~the ~~Mortgage~~Custodian ~~Loan~~ (see Exhibit 33.712)

33.37 ~~Park~~Wells ~~Bridge~~Fargo ~~Lender~~Bank, ~~Services~~National ~~LLC~~Association, as ~~Operating~~Primary ~~Advisor~~Servicer of the 711 Fifth Avenue Mortgage Loan prior to March 1, 2025 (see Exhibit 33.81)

33.38 ~~CoreLogic~~Trimont ~~Solutions,~~ LLC, as ~~Servicing~~Primary ~~Function Participant~~Servicer of the 711 Fifth Avenue Mortgage Loan on and after March 1, 2025 (see Exhibit 33.92)

33.39 ~~Computershare~~KeyBank ~~Trust Company,~~ National Association, as ~~Servicing~~Special ~~Function~~Servicer of ~~Participant~~the ~~for~~711 ~~the~~Fifth ~~Custodian~~Avenue Mortgage Loan (see Exhibit 33.114)

33.40 Wilmington Trust, National Association, as Trustee of the 711 Fifth Avenue Mortgage Loan (Omitted. See Explanatory Notes.)

33.41 Wells Fargo Bank, National Association, as Custodian of the 711 Fifth Avenue Mortgage Loan (see Exhibit 33.8)

33.42 Park Bridge Lender Services LLC, as Operating Advisor of the 711 Fifth Avenue Mortgage Loan (see Exhibit 33.9)

33.43 CoreLogic Solutions, LLC, as Servicing Function Participant of the 711 Fifth Avenue Mortgage Loan (see Exhibit 33.10)

33.44 Computershare Trust Company, National Association, as Servicing Function Participant for the Custodian (see Exhibit 33.12)

34 Attestation reports on assessment of compliance with servicing criteria for asset-backed securities.

34.1 Wells Fargo Bank, National Association, as General Master Servicer prior to March 1, 2025

34.2 ~~National~~Trimont ~~Cooperative Bank~~LLC, ~~N.A.,~~ as ~~Co-op~~General Master Servicer on and after March 1, 2025

34.3 ~~KeyBank~~ National ~~Association~~Cooperative Bank, N.A., as ~~General~~Co-op ~~Special~~Master Servicer

34.4 KeyBank National ~~Cooperative Bank~~Association, ~~N.A.,~~ as ~~Co-op~~General Special Servicer ~~(see Exhibit 34.2)~~

34.5 ~~Wilmington~~National ~~Trust~~Cooperative Bank, ~~National Association~~N.A., as ~~Trustee~~Co-op Special Servicer (~~Omitted.~~see ~~See~~Exhibit ~~Explanatory Notes~~34.3)

34.6 ~~Wells~~Wilmington ~~Fargo Bank~~Trust, National Association, as ~~Certificate~~ ~~Administrator~~Trustee (Omitted. See Explanatory Notes.)

34.7 Wells Fargo Bank, National Association, as ~~Custodian~~Certificate Administrator

34.8 ~~Park~~Wells ~~Bridge~~Fargo ~~Lender~~Bank, ~~Services~~National ~~LLC~~Association, as ~~Operating~~ ~~Advisor~~Custodian

34.9 ~~CoreLogic~~Park ~~Solutions,~~Bridge Lender Services LLC, as ~~Servicing Function~~Operating ~~Participant~~Advisor

34.10 ~~Computershare~~CoreLogic ~~Trust Company~~Solutions, ~~National Association~~LLC, as Servicing Function Participant ~~for the Certificate Administrator~~

34.11 Computershare Trust Company, National Association, as Servicing Function Participant for the ~~Custodian~~Certificate Administrator

34.12 ~~Wells~~Computershare ~~Fargo~~Trust ~~Bank~~Company, National Association, as ~~Primary Servicer~~Servicing ofFunction ~~the~~Participant ~~9th~~for &the ~~Thomas Mortgage Loan (see Exhibit 34.1)~~Custodian

34.13 ~~KeyBank~~Wells Fargo Bank, National Association, as ~~Special Servicer~~Primary Servicer of the 9th & Thomas Mortgage Loan prior to March 1, 2025 (see Exhibit 34.31)

34.14 ~~Wilmington~~Trimont ~~Trust~~LLC, ~~National Association,~~ as ~~Trustee~~Primary Servicer of the 9th & ~~Thomas~~ Thomas Mortgage Loan ~~(Omitted.~~on ~~See~~and ~~Explanatory~~after ~~Notes~~March 1, 2025 (see Exhibit 34.2)

34.15 ~~Wells~~KeyBank ~~Fargo Bank,~~ National Association, as ~~Custodian~~ Special Servicer of the 9th & Thomas Mortgage Loan (see Exhibit 34.74)

34.16 ~~Park~~Wilmington ~~Bridge~~Trust, ~~Lender~~National ~~Services LLC~~Association, as ~~Operating Advisor~~Trustee of the 9th & Thomas Mortgage Loan (~~see~~Omitted. ~~Exhibit~~See 34Explanatory Notes.8)

34.17 ~~CoreLogic~~Wells ~~Solutions,~~Fargo ~~LLC~~Bank, asNational ~~Servicing~~Association, ~~Function~~as ~~Participant~~Custodian of the 9th & Thomas Mortgage Loan (see Exhibit 34.98)

34.18 ~~Computershare~~Park ~~Trust~~Bridge ~~Company,~~Lender ~~National~~Services ~~Association~~LLC, as ~~Servicing~~Operating Advisor ~~Function~~of ~~Participant~~the ~~for~~9th ~~the~~& ~~Custodian~~Thomas Mortgage Loan (see Exhibit 34.119)

34.19 ~~Wells~~CoreLogic ~~Fargo Bank~~Solutions, ~~National Association~~LLC, as ~~Primary~~Servicing Function ~~Servicer~~Participant of the ~~ExchangeRight~~9th ~~Net~~& ~~Leased~~Thomas ~~Portfolio #39~~ Mortgage Loan (see Exhibit 34.110)

34.20 ~~KeyBank~~Computershare Trust Company, National Association, as ~~Special~~Servicing ~~Servicer of~~Function ~~the~~Participant ~~ExchangeRight~~for ~~Net~~the ~~Leased~~Custodian ~~Portfolio #39 Mortgage Loan~~ (see Exhibit 34.312)

34.21 ~~Wilmington~~Wells ~~Trust~~Fargo Bank, National Association, as ~~Trustee~~Primary Servicer of the ExchangeRight Net Leased Portfolio #39 Mortgage Loan ~~(Omitted.~~prior ~~See~~to March ~~Explanatory~~1, ~~Notes~~2025 (see Exhibit 34.1)

34.22 ~~Wells~~Trimont ~~Fargo Bank~~LLC, ~~National~~as ~~Association,~~Primary ~~as Custodian~~Servicer of the ExchangeRight Net Leased Portfolio #39 Mortgage Loan on and after March 1, 2025 (see Exhibit 34.72)

34.23 ~~Park~~KeyBank ~~Bridge~~National ~~Lender Services LLC~~Association, as ~~Operating Advisor~~Special Servicer of the ExchangeRight Net Leased Portfolio #39 Mortgage Loan (see Exhibit 34.84)

34.24 ~~CoreLogic~~Wilmington ~~Solutions~~Trust, ~~LLC~~National Association, as ~~Servicing~~Trustee ~~Function Participant~~ of the ExchangeRight Net Leased Portfolio #39 Mortgage Loan (~~see Exhibit~~Omitted. 34See Explanatory Notes.9)

34.25 ~~Computershare~~Wells ~~Trust~~Fargo ~~Company~~Bank, National Association, as Custodian ~~Servicing~~of ~~Function~~the ~~Participant~~ExchangeRight ~~for~~Net ~~the~~Leased ~~Custodian~~Portfolio #39 Mortgage Loan (see Exhibit 34.118)

34.26 ~~Wells~~Park ~~Fargo~~Bridge ~~Bank,~~Lender ~~National~~Services ~~Association~~LLC, as ~~Primary~~Operating ~~Servicer~~Advisor of the ~~Chasewood~~ExchangeRight ~~Technology~~Net ~~Park~~Leased Portfolio #39 Mortgage Loan (see Exhibit 34.19)

34.27 ~~KeyBank~~CoreLogic ~~National~~Solutions, ~~Association~~LLC, as ~~Special~~Servicing ~~Servicer~~Function Participant of the ~~Chasewood~~ExchangeRight ~~Technology~~Net ~~Park~~Leased Portfolio #39 Mortgage Loan (see Exhibit 34.310)

34.28 ~~Wilmington~~Computershare Trust Company, National Association, as ~~Trustee~~Servicing ofFunction ~~the~~Participant ~~Chasewood~~for ~~Technology Park~~the ~~Mortgage~~Custodian ~~Loan~~ (~~Omitted.~~see ~~See~~Exhibit ~~Explanatory Notes~~34.12)

34.29 Wells Fargo Bank, National Association, as Primary ~~Custodian~~Servicer of the Chasewood Technology Park Mortgage Loan prior to March 1, 2025 (see Exhibit 34.71)

34.30 ~~Park~~Trimont ~~Bridge Lender Services~~ LLC, as ~~Operating Advisor~~Primary Servicer of the Chasewood Technology Park Mortgage Loan on and after March 1, 2025 (see Exhibit 34.82)

34.31 ~~CoreLogic~~KeyBank ~~Solutions,~~National ~~LLC~~Association, as ~~Servicing~~Special ~~Function~~Servicer ~~Participant~~ of the Chasewood Technology Park Mortgage Loan (see Exhibit 34.94)

34.32 ~~Computershare~~Wilmington Trust ~~Company~~, National Association, as ~~Servicing~~Trustee ~~Function~~of ~~Participant~~the ~~for~~Chasewood ~~the~~Technology Park ~~Custodian~~Mortgage Loan (~~see~~Omitted. ~~Exhibit~~See 34Explanatory Notes.11)

34.33 Wells Fargo Bank, National Association, as ~~Primary~~ ~~Servicer~~Custodian of the ~~711~~Chasewood ~~Fifth~~Technology ~~Avenue~~Park Mortgage Loan (see Exhibit 34.18)

34.34 ~~KeyBank~~Park ~~National~~Bridge ~~Association~~Lender Services LLC, as ~~Special Servicer~~Operating Advisor of the ~~711~~Chasewood ~~Fifth~~Technology ~~Avenue~~Park Mortgage Loan (see Exhibit 34.39)

34.35 ~~Wilmington~~CoreLogic ~~Trust~~Solutions, ~~National Association~~LLC, as ~~Trustee~~Servicing Function Participant of the ~~711~~Chasewood ~~Fifth~~Technology ~~Avenue~~ Park Mortgage Loan (~~Omitted.~~see ~~See~~Exhibit ~~Explanatory Notes~~34.10)

34.36 ~~Wells~~Computershare ~~Fargo~~Trust ~~Bank~~Company, National Association, as ~~Custodian~~as ofServicing ~~the~~Function ~~711~~Participant ~~Fifth~~for ~~Avenue~~the ~~Mortgage~~Custodian ~~Loan~~ (see Exhibit 34.712)

34.37 ~~Park~~Wells ~~Bridge~~Fargo ~~Lender~~Bank, ~~Services~~National ~~LLC~~Association, as ~~Operating~~Primary ~~Advisor~~Servicer of the 711 Fifth Avenue Mortgage Loan prior to March 1, 2025 (see Exhibit 34.81)

34.38 ~~CoreLogic~~Trimont ~~Solutions,~~ LLC, as ~~Servicing~~Primary ~~Function Participant~~Servicer of the 711 Fifth Avenue Mortgage Loan on and after March 1, 2025 (see Exhibit 34.92)

34.39 ~~Computershare~~KeyBank ~~Trust Company,~~ National Association, as ~~Servicing~~Special ~~Function~~Servicer of ~~Participant~~the ~~for~~711 ~~the~~Fifth ~~Custodian~~Avenue Mortgage Loan (see Exhibit 34.114)

34.40 Wilmington Trust, National Association, as Trustee of the 711 Fifth Avenue Mortgage Loan (Omitted. See Explanatory Notes.)

34.41 Wells Fargo Bank, National Association, as Custodian of the 711 Fifth Avenue Mortgage Loan (see Exhibit 34.8)

34.42 Park Bridge Lender Services LLC, as Operating Advisor of the 711 Fifth Avenue Mortgage Loan (see Exhibit 34.9)

34.43 CoreLogic Solutions, LLC, as Servicing Function Participant of the 711 Fifth Avenue Mortgage Loan (see Exhibit 34.10)

34.44 Computershare Trust Company, National Association, as Servicing Function Participant for the Custodian (see Exhibit 34.12)

35 Servicer compliance statements.

35.1 Wells Fargo Bank, National Association, as General Master Servicer prior to March 1, 2025

35.2 ~~National~~Trimont ~~Cooperative Bank~~LLC, ~~N.A.,~~ as ~~Co-op~~General Master Servicer on and after March 1, 2025

35.3 ~~KeyBank~~ National ~~Association~~Cooperative Bank, N.A., as ~~General~~Co-op ~~Special~~Master Servicer

35.4 KeyBank National ~~Cooperative Bank~~Association, ~~N.A.,~~ as ~~Co-op~~General Special Servicer ~~(see Exhibit 35.2)~~

35.5 ~~Wells~~National ~~Fargo~~Cooperative Bank, ~~National Association~~N.A., as Co-op Special ~~Certificate~~Servicer ~~Administrator~~(see Exhibit 35.3)

35.6 ~~Computershare~~Wells ~~Trust~~Fargo ~~Company~~Bank, National Association, as ~~Servicing Function Participant for the~~ as Certificate Administrator

35.7 ~~Wells~~Computershare ~~Fargo~~Trust ~~Bank~~Company, National Association, as ~~Primary Servicer~~Servicing ofFunction ~~the~~Participant ~~9th~~for &the ~~Thomas~~Certificate ~~Mortgage Loan (see Exhibit 35.1)~~Administrator

35.8 ~~KeyBank~~Wells Fargo Bank, National Association, as ~~Special Servicer~~Primary Servicer of the 9th & Thomas Mortgage Loan prior to March 1, 2025 (see Exhibit 35.31)

35.9 ~~Wells~~Trimont ~~Fargo Bank~~LLC, ~~National Association,~~ as Primary Servicer of the ~~ExchangeRight~~9th ~~Net~~& Thomas ~~Leased~~Mortgage ~~Portfolio~~Loan ~~#39~~on ~~Mortgage~~and ~~Loan~~after March 1, 2025 (see Exhibit 35.12)

35.10 KeyBank National Association, as Special Servicer of the ~~ExchangeRight~~9th ~~Net~~& ~~Leased~~Thomas ~~Portfolio #39~~ Mortgage Loan (see Exhibit 35.34)

35.11 Wells Fargo Bank, National Association, as Primary Servicer of the ~~Chasewood~~ExchangeRight ~~Technology~~Net ~~Park~~Leased Portfolio #39 Mortgage Loan prior to March 1, 2025 (see Exhibit 35.1)

35.12 ~~KeyBank~~Trimont ~~National Association~~LLC, as ~~Special~~Primary Servicer of the ExchangeRight ~~Chasewood~~Net ~~Technology~~Leased ~~Park~~Portfolio #39 Mortgage Loan on and after March 1, 2025 (see Exhibit 35.32)

35.13 ~~Wells~~KeyBank ~~Fargo Bank,~~ National Association, as ~~Primary Servicer~~Special Servicer of the ~~711~~ExchangeRight ~~Fifth~~Net ~~Avenue~~Leased Portfolio #39 Mortgage Loan (see Exhibit 35.14)

35.14 ~~KeyBank~~Wells Fargo Bank, National Association, as ~~Special Servicer~~Primary Servicer of the ~~711~~Chasewood ~~Fifth~~Technology ~~Avenue~~Park Mortgage Loan prior to March 1, 2025 (see Exhibit 35.31)

35.15 Trimont LLC, as Primary Servicer of the Chasewood Technology Park Mortgage Loan on and after March 1, 2025 (see Exhibit 35.2)

35.16 KeyBank National Association, as Special Servicer of the Chasewood Technology Park Mortgage Loan (see Exhibit 35.4)

35.17 Wells Fargo Bank, National Association, as Primary Servicer of the 711 Fifth Avenue Mortgage Loan prior to March 1, 2025 (see Exhibit 35.1)

35.18 Trimont LLC, as Primary Servicer of the 711 Fifth Avenue Mortgage Loan on and after March 1, 2025 (see Exhibit 35.2)

35.19 KeyBank National Association, as Special Servicer of the 711 Fifth Avenue Mortgage Loan (see Exhibit 35.4)

99.1 Mortgage Loan Purchase Agreement, dated as of September 21, 2020, between Wells Fargo Bank, National Association and Wells Fargo Commercial Mortgage Securities, Inc. (filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-K filed on September 30, 2020 under Commission File No. 333-226486-16 and incorporated by reference herein)

99.2 Mortgage Loan Purchase Agreement, dated as of September 21, 2020, between Morgan Stanley Mortgage Capital Holdings LLC and Wells Fargo Commercial Mortgage Securities, Inc. (filed as Exhibit 99.2 to the registrant’s Current Report on Form 8-K filed on September 30, 2020 under Commission File No. 333-226486-16 and incorporated by reference herein)

99.3 Mortgage Loan Purchase Agreement, dated as of September 21, 2020, between Bank of America, National Association and Wells Fargo Commercial Mortgage Securities, Inc. (filed as Exhibit 99.3 to the registrant’s Current Report on Form 8-K filed on September 30, 2020 under Commission File No. 333-226486-16 and incorporated by reference herein)

(b) The exhibits required to be filed by the Registrant pursuant to Item 601 of Regulation S-K are listed above.

SIGNATURES

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

Wells Fargo Commercial Mortgage Securities, Inc.
(Depositor)

/s/ Anthony Sfarra

Anthony Sfarra, President

(senior officer in charge of securitization of the depositor)

Date: March 1017, ~~2025~~2026

Filing Compare · BANK 2020-BNK28