Ratings Affirmed On 26 Classes Of Bonds From Nine FFELP Student Loan ABS Transactions

NEW YORK (S&P Global Ratings) March 7, 2017--S&P Global Ratings today affirmedits ratings on 26 classes of bonds issued from nine student loan asset-backedsecurities (ABS) transactions (see list). These transactions are primarilybacked by a pool of Stafford and Consolidation student loans originatedthrough the U.S. Department of Education's (ED's) Federal Family EducationLoan Program (FFELP).

The affirmations on these classes reflect our expectation regarding collateralperformance as well as the current credit enhancement available to supportthem. This includes overcollateralization (parity), subordination (in certaincases), the reserve account, and excess spread. It also reflects our view that

the current credit enhancement levels are sufficient to absorb the 15% haircutto the cash inflows received under a 'AAA' stress scenario per our criteria.We also considered secondary credit factors, such as credit stability, paymentpriority, and issuer-specific analyses. Based on the current payment priority,we expect parity for the notes to remain stable or to increase.

These transactions primarily comprise Stafford, Consolidation, and Parent Loanfor Undergraduate Student (PLUS) loans that are supported by a guaranty fromthe ED of at least 97%. Accordingly, net losses are expected to be minimal.

For all the transactions, the amount of loans in nonpaying status (inschool/grace, deferment, delinquency, and forbearance) has declined sinceinception. Given the high levels of overcollateralization, the percentage ofloans in nonpaying status has minimal effect on these transactions.

Both of these transactions are sequential-pay structures, which benefit from aturbo feature that prevents the excess spread from being released until all ofthe notes have been repaid in full. Credit enhancement, as measured by parity,has grown since our last review. As a result of the full turbo feature, weexpect that parity levels for these trusts will continue to grow.

The senior LIBOR notes and subordinate auction notes for this trust have beenpaid in full, with only the senior auction notes remaining. The notes arecurrently allocated amounts equal to the change in the pool balance. The trustmay release available funds after senior fees and principal to the notes are

paid, as long as the trust maintains required parity ratios of at least 105.0%senior parity and 101.5% total parity. The transaction is required to paycarryover interest on the auction-rate notes and subordinate administrativefees prior to releasing excess funds.

Credit enhancement for the class A notes, as measured through parity,decreased as expected while the subordinate notes were receiving payments.Because the notes receive principal payments equal to the amount that the poolbalance decreases, we do not expect this trust to release to theabove-mentioned parity levels.

The auction-rate notes continue to be paid at the maximum auction-ratedefinition. This definition is based on the LIBOR or Treasury bill rate plus arating-dependent margin. We view this definition favorably compared with thosewe have seen in other structures, which contain a multiplier that allows themaximum rate to rapidly escalate in a higher interest rate environment,therefore stressing excess interest.

The Utah 1993 Indenture comprises class I and II priority bonds. Series 2011-1and 2010EE are the class I bonds, and the remaining bonds are class II bonds.The general indenture prohibits the release of funds while the series 2011-1notes are outstanding. Once the series 2011-1 notes have been paid in full,the trust is allowed to release funds as long as class II parity is above107%, total parity is above 103% (if subordinate notes are outstanding), and acash flow statement demonstrates that the parity levels are reasonablyexpected to continue to exceed the above-referenced parity thresholds during

As a result, we expect the class I and II parity will continue to grow whilethe series 2011-1 notes are outstanding. However, once the series 2011-1 notesare paid in full, class I and II parity could begin to decrease if the issuerelects to release funds--or the class I parity could decrease if the issuer