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Rating Action:

Moody's concludes reviews of 12 student loan ABS securitizations following the update of its approach to assessing counterparty risks in structured finance

11 Jan 2018

Approximately $9.6 billion securities affected.

NOTE: On January 15, 2018, the press release was corrected as follows: in the third paragraph of the RATINGS RATIONALE section, the sponsor was corrected to “Navient Solutions, LLC”. Revised release follows.

New York, January 11, 2018 -- Moody's Investors Service ("Moody's") has upgraded three classes, downgraded 26 classes and confirmed eight classes of notes from 12 student loan-backed transactions backed by loans originated under the Federal Family Education Loan Program (FFELP). The loans are guaranteed by the US government for a minimum of 97% of defaulted principal and accrued interest. 10 securitizations have outstanding currency swaps and two securitizations have outstanding fixed floating swaps.

The complete rating actions are as follows:

Issuer: Education Loan Asset-Backed Trust I (2003 Trust Indenture)

Senior Ser. 2003-1A-2, Downgraded to Aa3 (sf); previously on Jul 26, 2017 Aa1 (sf) Placed Under Review for Possible Downgrade

Senior Ser. 2003-1A-7, Downgraded to Aa3 (sf); previously on Jul 26, 2017 Aa1 (sf) Placed Under Review for Possible Downgrade

Senior Ser. 2003-1A-8, Downgraded to Aa3 (sf); previously on Jul 26, 2017 Aa1 (sf) Placed Under Review for Possible Downgrade

Sr Ser. 03-1A10, Downgraded to Aa3 (sf); previously on Jul 26, 2017 Aa1 (sf) Placed Under Review for Possible Downgrade

Sr Ser. 03-1A11, Downgraded to Aa3 (sf); previously on Jul 26, 2017 Aa1 (sf) Placed Under Review for Possible Downgrade

2003-2A-1, Downgraded to Aa3 (sf); previously on Jul 26, 2017 Aa1 (sf) Placed Under Review for Possible Downgrade

2003-2A-2, Downgraded to Aa3 (sf); previously on Jul 26, 2017 Aa1 (sf) Placed Under Review for Possible Downgrade

2003-2A-3, Downgraded to Aa3 (sf); previously on Jul 26, 2017 Aa1 (sf) Placed Under Review for Possible Downgrade

2003-2A-5, Downgraded to Aa3 (sf); previously on Jul 26, 2017 Aa1 (sf) Placed Under Review for Possible Downgrade

2003-2A-8, Downgraded to Aa3 (sf); previously on Jul 26, 2017 Aa1 (sf) Placed Under Review for Possible Downgrade

2003-2A-11, Downgraded to Aa3 (sf); previously on Jul 26, 2017 Aa1 (sf) Placed Under Review for Possible Downgrade

2003-2A-13, Downgraded to Aa3 (sf); previously on Jul 26, 2017 Aa1 (sf) Placed Under Review for Possible Downgrade

Series 2013-1 A2 Senior Notes, Upgraded to Aaa (sf); previously on Nov 10, 2016 Downgraded to Aa1 (sf)

Series 2013-1 B1 Sub. Notes, Upgraded to Aaa (sf); previously on Nov 10, 2016 Confirmed at Aa1 (sf)

Issuer: Goal Capital Funding Trust 2006-1

Cl. A-5, Confirmed at Aa1 (sf); previously on Jul 26, 2017 Aa1 (sf) Placed Under Review for Possible Downgrade

Cl. A-6, Downgraded to A1 (sf); previously on Jul 26, 2017 Aa2 (sf) Placed Under Review for Possible Downgrade

Cl. B, Confirmed at A2 (sf); previously on Jul 26, 2017 A2 (sf) Placed Under Review for Possible Downgrade

Issuer: SLC Student Loan Trust 2008-1

Cl. A-4A, Downgraded to Aa1 (sf); previously on Jul 26, 2017 Aaa (sf) Placed Under Review for Possible Downgrade

Cl. A-4B, Downgraded to Aa1 (sf); previously on Jul 26, 2017 Aaa (sf) Placed Under Review for Possible Downgrade

Cl. B, Downgraded to A3 (sf); previously on Jul 26, 2017 Aa2 (sf) Placed Under Review for Possible Downgrade

Issuer: SLM Student Loan Trust 2003-10

Cl. A-4, Downgraded to A2 (sf); previously on Jul 26, 2017 A1 (sf) Placed Under Review for Possible Upgrade

Issuer: SLM Student Loan Trust 2003-12

Cl. A-6, Downgraded to A1 (sf); previously on Jul 26, 2017 Aa2 (sf) Placed Under Review for Possible Downgrade

Cl. B, Confirmed at Baa3 (sf); previously on Jul 26, 2017 Baa3 (sf) Placed Under Review for Possible Downgrade

Issuer: SLM Student Loan Trust 2004-2

Cl. B, Confirmed at A3 (sf); previously on Jul 26, 2017 A3 (sf) Placed Under Review for Possible Downgrade

Cl. A-5, Confirmed at Aaa (sf); previously on Jul 26, 2017 Aaa (sf) Placed Under Review for Possible Downgrade

Cl. A-6, Downgraded to Aa3 (sf); previously on Jul 26, 2017 Aaa (sf) Placed Under Review for Possible Downgrade

Issuer: SLM Student Loan Trust 2004-5

Cl. A-6, Confirmed at Aa3 (sf); previously on Jul 26, 2017 Aa3 (sf) Placed Under Review for Possible Downgrade

Issuer: SLM Student Loan Trust 2004-10

Cl. B, Confirmed at Ba1 (sf); previously on Jul 26, 2017 Ba1 (sf) Placed Under Review for Possible Downgrade

Issuer: SLM Student Loan Trust 2006-4

Cl. A-6, Downgraded to A1 (sf); previously on Jul 26, 2017 Aa1 (sf) Placed Under Review for Possible Downgrade

Cl. B, Upgraded to A3 (sf); previously on Jul 26, 2017 Baa2 (sf) Placed Under Review for Possible Upgrade

Issuer: SLM Student Loan Trust 2006-10

Cl. A-6, Downgraded to Aa3 (sf); previously on Jul 26, 2017 Aa1 (sf) Placed Under Review for Possible Downgrade

Cl. B, Downgraded to Baa1 (sf); previously on Jul 26, 2017 A3 (sf) Placed Under Review for Possible Downgrade

Issuer: SLM Student Loan Trust 2007-4

Cl. A-5, Downgraded to A2 (sf); previously on Jul 26, 2017 A1 (sf) Placed Under Review for Possible Downgrade

Cl. B-1, Downgraded to A2 (sf); previously on Jul 26, 2017 A1 (sf) Placed Under Review for Possible Downgrade

Cl. B-2A, Downgraded to Ba1 (sf); previously on Jul 26, 2017 Baa3 (sf) Placed Under Review for Possible Downgrade

Cl. B-2B, Downgraded to Ba1 (sf); previously on Jul 26, 2017 Baa3 (sf) Placed Under Review for Possible Downgrade

Issuer: New Mexico Educational Assistance Foundation - Education Loan Bonds (2010 Indenture)

Series 2010-1 A-3, Confirmed at Aaa; previously on Jul 26, 2017 Aaa Placed Under Review for Possible Downgrade

RATINGS RATIONALE

The primary rationale for the rating action is the update to Moody's structured finance rating methodologies with respect to assessing exposure to swap counterparties, Moody's Approach to Assessing Counterparty Risks in Structured Finance, published on 26 July 2017. Moody's reduced the value of certain notching uplifts in connection with swaps that would become subject to margining requirements upon counterparty replacement. Under new swap margin rules, certain structured finance swaps entered into or transferred after 1 March 2017 must include collateral posting obligations for both parties (two-way posting). The requirement for two-way posting reduces the likelihood of counterparty replacement for existing structured finance swaps, and therefore increases the probability that affected securitization issuers will become unhedged following counterparty default. Consequently, we generally apply no notching uplifts relating to (1) any transfer trigger or collateral provisions; or (2) the issuer's ability to replace a defaulting out-the-money swap.

On 27 October 2017, the US Commodity Futures Trading Commission (CFTC) announced a no-action position with respect to variation margin requirements applicable to legacy swaps with special purpose vehicles (SPVs). Although it increases the likelihood that a downgraded counterparty will procure a novation to a replacement counterparty, in our view, it does not materially increase the likelihood that, if a counterparty defaults, the SPV will enter into a new swap with a replacement counterparty. Moreover, the relief does not affect initial margin requirements.

As a result, in today's action we applied notching uplifts for the swap transfer triggers benefiting Education Loan Asset-Backed Trust I (2003 Trust Indenture), Goal Capital Funding Trust 2006-1 and New Mexico Educational Assistance Foundation - Education Loan Bonds (2010 Indenture), as they together with their affiliates do not have material swap exposure thus they are not affected by the initial margin requirement. However, for other securitizations sponsored or owned by Navient Solutions, LLC, we assumed initial margin requirement apply and provided no notching uplifts for transfer triggers because Navient and its affiliates will likely to have certain derivative exposures in excess of $8 billion on 1 September 2020. For each of the securitizations in today's action, we applied no notching uplifts relating to (1) any swap collateral provisions; or (2) the issuer's ability to replace a defaulting out-the-money swap.

The upgrades and confirmations are the result of Moody's analysis that indicates that the negative impact from reducing notching uplifts in connection with swaps subject to margining requirements did not outweigh the maturity extension for Class B in SLM Student Loan Trust 2006-4 and the performance of other affected tranches.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings "Moody's Approach to Rating Securities Backed by FFELP Student Loans" published in August 2016. Please see the Rating Methodologies page on www.moodys.com for a copy of this methodology.

Factors that would lead to an upgrade or downgrade of the ratings:

Up

Moody's could upgrade the ratings if the paydown speed of the loan pool increases as a result of declining borrower usage of deferment, forbearance and IBR, increasing voluntary prepayment rates, or prepayments with proceeds from sponsor repurchases of student loan collateral. Moody's could also upgrade the rating owing to a build-up in credit enhancement and upgrades of ratings or CR Assessments on the swap counterparties. In addition, Moody's could upgrade the ratings if CFTC extends the scope of its no action relief to swaps executed in response to counterparty default, or Moody's receives new information showing that new swaps executed by Navient's SPVs will not be subject to initial margin requirements.

Down

Moody's could downgrade the ratings if the paydown speed of the loan pool declines as a result of low voluntary prepayments, and high deferment, forbearance and IBR rates, which would threaten full repayment of the classes by their final maturity dates. In addition, because the US Department of Education guarantees at least 97% of principal and accrued interest on defaulted loans, Moody's could downgrade the ratings of the notes if it were to downgrade the rating on the United States government. Moody's could also downgrade the rating owing to downgrades of ratings or CR Assessments on the swap counterparties.

REGULATORY DISCLOSURES

For further specification of Moody's key rating assumptions and sensitivity analysis, see the sections Methodology Assumptions and Sensitivity to Assumptions of the disclosure form.

The following disclosure applies only to credit ratings carrying the (sf) indicator: In rating this transaction, Moody's used a cash flow model to model cash flow stress scenarios to determine the extent to which investors would receive timely payments of interest and principal in the stress scenarios, given the transaction structure and collateral composition.

Moody's quantitative analysis entails an evaluation of scenarios that stress factors contributing to sensitivity of ratings and take into account the likelihood of severe collateral losses or impaired cash flows. Moody's weights the impact on the rated instruments based on its assumptions of the likelihood of the events in such scenarios occurring.

For ratings issued on a program, series or category/class of debt, this announcement provides certain regulatory disclosures in relation to each rating of a subsequently issued bond or note of the same series or category/class of debt or pursuant to a program for which the ratings are derived exclusively from existing ratings in accordance with Moody's rating practices. For ratings issued on a support provider, this announcement provides certain regulatory disclosures in relation to the credit rating action on the support provider and in relation to each particular credit rating action for securities that derive their credit ratings from the support provider's credit rating. For provisional ratings, this announcement provides certain regulatory disclosures in relation to the provisional rating assigned, and in relation to a definitive rating that may be assigned subsequent to the final issuance of the debt, in each case where the transaction structure and terms have not changed prior to the assignment of the definitive rating in a manner that would have affected the rating. For further information please see the ratings tab on the issuer/entity page for the respective issuer on www.moodys.com.

For any affected securities or rated entities receiving direct credit support from the primary entity(ies) of this credit rating action, and whose ratings may change as a result of this credit rating action, the associated regulatory disclosures will be those of the guarantor entity. Exceptions to this approach exist for the following disclosures, if applicable to jurisdiction: Ancillary Services, Disclosure to rated entity, Disclosure from rated entity.

Regulatory disclosures contained in this press release apply to the credit rating and, if applicable, the related rating outlook or rating review.

Please see www.moodys.com for any updates on changes to the lead rating analyst and to the Moody's legal entity that has issued the rating.

Please see the ratings tab on the issuer/entity page on www.moodys.com for additional regulatory disclosures for each credit rating.

Jinwen Chen
Asst Vice President - Analyst
Structured Finance Group
Moody's Investors Service, Inc.
250 Greenwich Street
New York, NY 10007
U.S.A.
JOURNALISTS: 1 212 553 0376
Client Service: 1 212 553 1653

Caroline Pichon
Vice President - Senior Analyst
Structured Finance Group
JOURNALISTS: 1 212 553 0376
Client Service: 1 212 553 1653

Releasing Office:
Moody's Investors Service, Inc.
250 Greenwich Street
New York, NY 10007
U.S.A.
JOURNALISTS: 1 212 553 0376
Client Service: 1 212 553 1653

No Related Data.
© 2022 Moody’s Corporation, Moody’s Investors Service, Inc., Moody’s Analytics, Inc. and/or their licensors and affiliates (collectively, “MOODY’S”). All rights reserved.

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