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Navient Credit Funding, LLC, et al. – ‘ABS-15G’ for 1/13/20 – ‘EX-99.1’

On:  Monday, 1/13/20, at 1:36pm ET   ·   For:  1/13/20   ·   Accession #:  929638-20-40   ·   File #:  25-00456

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  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

 1/13/20  Navient Credit Funding, LLC       ABS-15G:2   1/13/20    2:228K                                   Bingham McCutchen LLP/FA
          Navient Credit Funding, LLC - Depositor

Asset-Backed Securities (ABS)

Asset Class:  Other   ·   Rule:  15Ga-2   ·   Depositor:  Navient Credit Funding, LLC   ·   Issuer:  Navient Private Education Loan Trust 2020-A   ·   Registered Entity?  No


Asset-Backed Securitizer Report   —   Sect. 15G – SEA’34
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: ABS-15G     Asset-Backed Securitizer Report                     HTML     13K 
 2: EX-99.1     Kpmg Agreed-Upon Procedures Report                  HTML    113K 


‘EX-99.1’   —   Kpmg Agreed-Upon Procedures Report


This Exhibit is an HTML Document rendered as filed.  [ Alternative Formats ]



 C: 
Exhibit 99.1

Suite 700
I20 Pacifica




Independent Accountants’ Report on Applying Agreed-Upon Procedures
 
Navient Credit Funding, LLC (the “Company”)
Navient Corporation
Navient Solutions, LLC
J.P. Morgan Securities LLC
Credit Suisse Securities (USA) LLC
(together, the “Specified Parties”)
 
Re: Navient Private Education Loan Trust 2020-A – Data File Procedures
 
We have performed the procedures described below, which were agreed to by the Specified Parties, on the specified attributes identified by the Company in an electronic data file entitled “CO191210151456_ UPDATED.TXT,” provided by the Company on December 11, 2019, containing certain information related to 82,035 student loans (the “Student Loans”) as of December 8, 2019 (the “Data File”), which we were informed are intended to be included as collateral in the offering of Navient Private Education Loan Trust 2020-A. The Company is responsible for the specified attributes identified by the Company in the Data File. The sufficiency of these procedures is solely the responsibility of the Specified Parties. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose.
 
We are independent certified public accountants with respect to the Company and its affiliates under Rule 1.200.001 of the AICPA’s Code of Professional Conduct.
 
Unless otherwise indicated, the following definitions have been adopted in presenting our procedures and findings:
 
The term “compared” means compared to the information shown and found it to be in agreement, unless otherwise noted. Such compared information was deemed to be in agreement if differences were within the materiality threshold.
 
The term “recomputed” means recalculated and compared the result to the information shown and found it to be in agreement, unless otherwise noted. Such recomputed information was deemed to be in agreement if differences were within the materiality threshold.
 
The term “materiality threshold” means that dollar amounts related to Current Principal Balance and numbers of months related to Remaining Term were within $1.00 and one (1) month, respectively.
 
The term “Cutoff Date” means December 8, 2019.
 
The terms “CLASS System,” “ENCORE System,” and “FDR System” mean the Company’s servicing systems.
 
The term “Loan File” means any file containing the following documents, as applicable, for each Selected
 

KPMG LLP is a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.




Student Loan (defined below):
 

Promissory Note, Truth in Lending Disclosure, Loan Application, Loan Credit Agreement, Application Summary, and NRI Origination Disclosure in the Encore System;
 

#BS1 Screen, #BS3 Screen, #BS5 Screen, #CSS Screen, #CDS Screen, #NM CR Screen, #NM CC Screen, #NM AF Screen, #EDH Screen, #ED2 Screen, #CIS Screen, #NPO Screen, #HDI Screen, and Enterprise Data Warehouse (“EDW”) query in the FDR System; and,
 

Loan Disbursement Data Screen (#113 Screen), Loan Disbursement Data Screen (#115 Screen), and School Profile Screen (#728 Screen) in the CLASS System.
 
The Loan File, furnished by the Company, was represented to be either the original Loan File, a copy of the original Loan File, or electronic records contained within the ENCORE System, FDR System, and/or CLASS System.
 
A.
We randomly selected a sample of Student Loans from the Data File, utilizing a confidence level of 95.0%, an expected error rate of 3.0%, and a maximum estimated error occurrence rate (the upper error limit) for each of the attributes not to exceed 5.0%, as instructed by the Company. The selection criteria resulted in a sample of 361 Student Loans (the “Selected Student Loans,” as listed in Exhibit A attached hereto).
 
B.
For each Selected Student Loan, we compared the specified attributes in the Data File to the corresponding information in the respective Loan File. The Specified Parties indicated that the absence of any of the noted documents or the inability to agree the indicated information from the Data File to the Loan File for each of the attributes identified, utilizing instructions provided by the Company (as applicable) indicated below, constituted an exception, except for certain procedures related to School Type 1, School Type 2, and Recent FICO, as detailed below. The Loan File documents are listed in the order of priority until such attribute was agreed.
 
 
Attributes
Loan File/Company’s Instructions
     
 
Social Security Number
Promissory Note, Loan Application, Loan Credit Agreement, Loan Amount on the Promissory Note, Refinance Total on Application Summary, Total Loan Amount on Truth in Lending Disclosure and Total Loan Amount on NRI Origination Disclosure, Insurance Premium amount in “INS PREM” field on Loan Disbursement Data Screen (#113 Screen), and instructions provided by the Company described below
     
 
Signature(s) on the Promissory Note, Loan Application or Loan Credit Agreement
Promissory Note, Loan Application, Loan Credit Agreement, and instructions provided by the Company described below. We performed no procedures with regard to any signatory requirements on the Promissory Note, Loan Application, or Loan Credit Agreement, or to confirm the authenticity of the signature(s).
     
 
Disbursement Year
“1ST ACTIVE DATE” field on #BS5 Screen, Loan Disbursement Data Screen (#115 Screen “1st DISB” field)
     
 
Original Principal Balance
“TOTALDISB” field within the “DISBMNTS” tab of #HDI Screen, Loan Disbursement Data Screen (#115 Screen “DISB PRIN” field)


2


 
  Attributes
Loan File/Company’s Instructions
     
 
Current Principal Balance/Recomputed Current Principal Balance
“ACCOUNT BALANCE” field on #CSS Screen, documentation of change that affects the current principal balance on #CIS Screen, “RPMT FEE” field or “CAP INT” field on #ED2 Screen, “LATE FEE” field, “RETRO PROCESSING” field , or Interest Rate on #CSS Screen, “CYCLE DATE” on #EDH Screen, first “PAYMENT” of the cycle on #CSS Screen or #CDS Screen, and instructions provided by the Company described below
     
 
Loan Type
“#14” field on #NM CC Screen
     
 
Loan Status
“CURR LOAN STATUS” field on #EDH Screen and “MISC FIELD 2” field on the #BS3 Screen, notation of status change on #CIS Screen,  “ORIG STMT STATUS” field on #ED2 Screen, and instructions provided by the Company described below
     
 
Current Status End Date
“CYCLE DATE,” “CURR:GRAD/SEP DT,” or “MATURITY DT” fields on #EDH Screen, “ORIG: GRAD/ SEP DT” field on #ED2 Screen, “METHOD OVERRIDE END DATE” field using the “RULS MIN PAY (CP PO RM)” field on #NPO Screen, notation of status change on #CIS Screen, date in the “MIN PAY DUE”  field on #EDH Screen, EDW query, and instructions provided by the Company described below
     
 
Remaining Term (Recomputed Remaining Term)
“CYCLE DATE,” “MATURITY DT,” “DUE DATE,” and “CURR LOAN STATUS” fields on #EDH Screen, “METHOD OVERRIDE END DATE” using the “RULS MIN PAY (CP PO RM)” field on the #NPO Screen, “MISC FIELD 2” field on #BS3 Screen, “#9” field on #NM CC Screen, and instructions provided by the Company described below
     
 
Repayment Schedule Type
“CYCLE DATE” or “CURR LOAN STATUS” field on #EDH Screen, “MISC FIELD 2” field on #BS3 Screen, “METHOD OVERRIDE ID” using the “RULS MIN PAY (CP PO RM)” field on #NPO Screen, and instructions provided by the Company described below
     
 
Interest Rate
“INT RT” field on #EDH Screen, “INT 1%” field and “INT 2%” field in “ORIG STMT VALUES” section on #ED2 Screen, “AUTO PAY FLAG” field on #NM AF Screen,  and #HDI Screen for Interest Rate with borrower benefit related information
     
 
School Type 1
“MISC FIELD 5” field on #BS3 Screen and instructions provided by the Company described below
     
 
School Type 2 (Title IV)
“SCHL CODE” field and “SCHL TYPE” field on School Profile Screen (#728 Screen), Loan Disbursement Data Screen (#115 Screen field “SCHL CODE”), “SCHOOL BRANCH” field on School Profile Screen (#728 Screen), 

3


 
  Attributes
Loan File/Company’s Instructions
     
    and instructions provided by the Company described below
     
 
State of Residence
#BS1 Screen, documentation of change that affects the state of residence on #CIS Screen
     
 
Recent FICO
“DATE CB SCORE GENERATED” and “CREDIT BUREAU SCORE” field on #NM CR Screen, and instructions provided by the Company described below
     
 
Original FICO
“EDS SCR01” or “EDS SCR02” field in “FICO INFO” tab on #HDI Screen
     

1.
For purposes of comparing the Social Security Number and Signature(s) on the Promissory Note, Loan Application, or Loan Credit Agreement, in order to identify if the Promissory Note, Loan Application, or Loan Credit Agreement corresponded to the Selected Student Loan, we were instructed by the Company to compare the requested Loan Amount plus any origination fee indicated on the Promissory Note, Loan Application, or Loan Credit Agreement, or the Total Loan Amount indicated on the Truth in Lending Disclosure or the NRI Origination Disclosure, or the Refinance Total indicated on the Application Summary, to the Original Principal Balance of the Selected Student Loan set forth in the Data File. In the event the Promissory Note was not present, the Company instructed us to observe the Signature(s) on the Loan Application or the Loan Credit Agreement. In the event the Loan Amount on the Promissory Note, Loan Application, or Loan Credit Agreement was lower than the Original Principal Balance, the Company instructed us to observe if the difference was attributable to the Insurance Premium amount in the “INS PREM” field on the Loan Disbursement Data Screen (#113 Screen). If the difference was attributable to the Insurance Premium amount, such difference was not considered an exception. The Promissory Note, Loan Application, or Loan Credit Agreement was available for all Selected Student Loans.
 

2.
For purposes of comparing Current Principal Balance, we were instructed by the Company to compare the “ACCOUNT BALANCE” field on the #CSS Screen or documentation of a change that affects the current principal balance on the #CIS Screen. In the event the “ACCOUNT BALANCE” field on the #CSS Screen or documentation of change that affects the current principal balance on the #CIS Screen did not agree to the “BAL_CURR” field in the Data File, we were instructed by the Company to recompute the Current Principal Balance (the “Recomputed Current Principal Balance”) as follows:
 

a)
To the “ACCOUNT BALANCE” field on the #CSS Screen, add any applicable Repayment Fee (shown as “RPMT FEE” on the #ED2 Screen) or applicable Capitalized Interest (shown as “CAP INT” on the #ED2 Screen) or applicable Late Fee (shown as “LATE FEE” on the #CSS Screen); and,
 

b)
Subtract any amount indicated in the “RETRO PROCESSING” field on the #CSS Screen and any additional principal payment applied after the Cutoff Date, which was identified by subtracting the recalculated accrued interest (Interest Rate on #CSS Screen multiplied by the number of days from the start of the “CYCLE DATE” on the #EDH Screen to the day before the date of the first PAYMENT on the #CSS Screen or the #CDS Screen, multiplied by the “ACCOUNT BALANCE” field on the #CSS Screen) from the first PAYMENT made.
 


We compared the Recomputed Current Principal Balance to the “BAL_CURR” field in the Data File.


3.
For purposes of comparing Loan Status, we were instructed by the Company to compare Loan Status as follows:
 
4


 

If the “CURR LOAN STATUS” field on the #EDH Screen indicated “RPMT,” “F***,” “SSFP,” “SSP*,” or “FORP” the Loan Status was “In-Repayment”;
 

If the “CURR LOAN STATUS” field on the #EDH Screen indicated “SSF*,” the Loan Status was “Forbearance”;
 

If the “CURR LOAN STATUS” field on the #EDH Screen indicated “D***,” and the Repayment Type on the “MISC FIELD 2” on the #BS3 Screen was not “F0025” or “FX025,” the Loan Status was “In-Repayment”;
 

If the “CURR LOAN STATUS” field on the #EDH Screen was other than “DMIP” or “F***,” and the Repayment Type in the “MISC FIELD 2” field on the #BS3 Screen was either “F0025” or “FX025,” “SOIOP” or blank, the Loan Status was  “In-Repayment”;
 

If the “CURR LOAN STATUS” field on the #EDH Screen indicated “SCHL,” or “GRCE,” and the Repayment Type in the “MISC FIELD 2” field on the #BS3 Screen was not “D000*,” the Loan Status was “In-Repayment”;
 

To the status contained in the “CURR LOAN STATUS” field on the #EDH Screen. In the event the Loan Status did not agree, the Company instructed us to identify a notation of status change on the #CIS Screen or “ORIG STMT STATUS” field on the #ED2 Screen.
 

4.
For purposes of comparing the Current Status End Date, we were instructed by the Company to compare the “CUR_STATUS_END_DT” field in the Data File to the “CURR: GRAD/SEP DT” or “MATURITY DT” field on the #EDH Screen, or the “ORIG: GRAD/SEP DT” field on the #ED2 Screen plus one month, or to the “METHOD OVERRIDE END DATE” field after the Cutoff Date using the “RULS MIN PAY (CP PO RM)” field on the #NPO Screen. In the event the Selected Student Loan was updated after the Cutoff Date, we were instructed by the Company to view the #CIS Screen to identify if any change was made to the Current Status End Date after the Cutoff Date or if any change was made to the “MIN PAY DUE” field corresponding to the ”CYCLE DATE” prior to the Cutoff Date on the #EDH Screen.
 

5.
For purposes of comparing Remaining Term, we were instructed by the Company to recompute the Remaining Term (“Recomputed Remaining Term”) as follows:
 

a)
For Selected Student Loans for which the “CURR LOAN STATUS” field on the #EDH Screen indicated as “GRCE,” “RPMT,” “SSP*,” “SSF*,” “SCHL,” all “F” repayment types, all “D” repayment types in the “MISC FIELD 2” field on #BS3 Screen (except for “DSCH”/“F0025,” “DSCH”/“SOIOP,” “DSCH”/“PPIOP,” “SCHL”/ repayment type not “D****” or “GRCE”/ repayment type not “D****”), we were instructed by the Company to subtract the Cutoff Date from the “CYCLE DATE” after the “MATURITY DT” (one month after the “MATURITY DT”), both on the #EDH Screen, and divide the result by the average number of days in a month (i.e., 30.4375).  The Company instructed us to consider repayment type “P0000” to be the same as “D0000” and repayment type “PPIOP” to be the same as “SOIOP.” If the Cutoff Date was later than the “DUE DATE” on the #EDH Screen, we were instructed by the Company to subtract one month from the calculation;
 

b)
The Company informed us that the day of the “CYCLE DATE” and the day of the “MATURITY DT” both on the #EDH Screen should agree.  In certain instances where the days did not agree, we were instructed by the Company to utilize the “CYCLE DATE” for purposes of recomputing the Remaining Term;
 

c)
For 13 Selected Student Loans for which the “CURR LOAN STATUS” field on the #EDH Screen indicated “DSCH,” “SCHL,” or “GRCE,” and the “MISC FIELD 2” field on the #BS3 Screen was either “F0025,” “SOIOP,” or “PPIOP,” we were instructed by the Company to recompute the Remaining Term as the sum of (1) the difference greater than zero between the Cutoff Date and
 
5


 


the “METHOD OVERRIDE END DATE” field using the “RULS MIN PAY (CP PO RM)” field on the #NPO Screen, divided by the average number of days in a month (i.e., 30.4375), and (2) the difference between the Cutoff Date and the “CYCLE DATE” after the “MATURITY DATE” on the #EDH Screen, divided by the average number of days in a month (i.e., 30.4375);
 

d)
For Selected Student Loans for which the “CURR LOAN STATUS” field on the #EDH Screen indicated “GRCE” or “SCHL” and the “MISC FIELD 2” field on the #BS3 Screen was “D0000,” we were instructed by the Company to compare the Remaining Term to the “#9” field on the #NM CC Screen.
 


We compared the Recomputed Remaining Term to the “REM_TERM” field in the Data File.
 

6.
For purpose of comparing Repayment Schedule Type, we were instructed by the Company to compare Repayment Schedule Type as follows:
 

If the “MISC FIELD 2” field on the #BS3 Screen indicated the Repayment Type as either “D0000,” “F0025,” “FX025,” “SOIOP,” “PPIOP,” “D000E,” “P0000,” “PPIOE,” “FX02E,” or blank and the “CYCLE DATE” was before the Cutoff Date, the Repayment Schedule Type was “V”;
 

If the “MISC FIELD 2” field on the #BS3 Screen indicated the Repayment Type as either “F0025” or “FX025” and the “CYCLE DATE” was on or after the Cutoff Date, the Repayment Schedule Type was “W”;
 

If the “MISC FIELD 2” field on the #BS3 Screen indicated the Repayment Type as either blank, “PPIOP” or “SOIOP” and the “CYCLE DATE” was on or after the Cutoff Date, the Repayment Schedule Type was “Z”;
 

If the “MISC FIELD 2” field on the #BS3 Screen indicated the Repayment Type as “D0000” and the “CYCLE DATE” was on or after the Cutoff Date, the Repayment Schedule Type was “N”;
 

If the “CURR LOAN STATUS” field on the #EDH Screen indicated “DMIP,” GRPM,” “F***” (excluding “FORP”) or “SSF*,”  the Repayment Schedule Type was “N”;
 

If the “CURR LOAN STATUS” field on the #EDH Screen indicated “DSCH” and the Repayment Type on the “MISC FIELD 2” on the #BS3 Screen was either “F0025” or “FX025,” the Repayment Schedule Type was “E”;
 

If the “CURR LOAN STATUS” field on the #EDH Screen indicated “DSCH” and the Repayment Type on the “MISC FIELD 2” field on the #BS3 Screen was “SOIOP,” “PPIOP” or blank, the Repayment Schedule Type was “D”;
 

If the “CURR LOAN STATUS” field on the #EDH Screen indicated “SS**,” the Repayment Schedue Type was the last character in the “CURR LOAN STATUS” field on the #EDH Screen;
 

If the “MISC FIELD 2” field on the #BS3 Screen indicated a Repayment Type which had an “E” in the fifth character, the Repayment Schedule Type was “V.”
 

If none of the criteria above applied, we were instructed by the Company to identify the “METHOD OVERRIDE ID” using the “RULS MIN PAY (CP PO RM)” field on the #NPO Screen and:
 

i.
If the “METHOD OVERRIDE ID” on the #NPO Screen began with “FBSS**,” the Repayment Schedule Type was the last character of the “METHOD OVERRIDE ID”;
 

ii.
If (1) the “METHOD OVERRIDE ID” on the #NPO Screen began with either “DFDMIP” or “DFGRPM,” or “FB*,” but was not “FBFORP,” (2) the “METHOD OVERRIDE ID” on the
 
6

 



#NPO Screen began with “DF*” and the “MISC FIELD 2” field on the #BS3 Screen indicated the Repayment Type as “D*,” “P0000,” or “P000L,” or (3) the “METHOD OVERRIDE ID” on the #NPO Screen began with “FBFORP” and the “MISC FIELD 2” field on the #BS3 Screen indicated the Repayment Type as “D*,” “P0000,” or “P000L, the Repayment Schedule Type was “N”;
 

iii.
If the “METHOD OVERRIDE ID” on the #NPO Screen began with “DF*” and the “MISC FIELD 2” field on the #BS3 Screen indicated the Repayment Type as “F*,” “CT010,” or “CT01L,” the Repayment Schedule Type was “E”;
 

iv.
If the “METHOD OVERRIDE ID” on the #NPO Screen began with “DF*” and the “MISC FIELD 2” field on the #BS3 Screen indicated no Repayment Type, the Repayment Schedule Type was “D”;
 

v.
If the “METHOD OVERRIDE ID” on the #NPO Screen began with “FBFORP” and the “MISC FIELD 2” field on the #BS3 Screen indicated the Repayment Type as “F*,” “CT0010,” or “CT01L,” the Repayment Schedule Type was “W”; or,
 

vi.
If the “METHOD OVERRIDE ID” on the #NPO Screen was blank and the “MISC FIELD 2” field on the #BS3 Screen indicated the Repayment Type as blank, “CTIOP,” “CTIOL,” “LGIOP,” “LGIOL,” “PPIOP,” “PPIOL,” “SOIOP,” or “SOIOL,” the Repayment Schedule Type was “Z.”
 

If none of the criteria above regarding the “METHOD OVERRIDE ID” applied, we were instructed by the Company as follows:
 

i.
If the CURR LOAN STATUS” field on the #EDH Screen indicated either “SCHL” or “GRCE” and the “MISC FIELD 2” field on the #BS3 Screen indicated the Repayment Type as “D*” “P0000” or “P000L,” the Repayment Schedule Type was “N”;
 

ii.
If the CURR LOAN STATUS” field on the #EDH Screen indicated either “SCHL” or “GRCE” and the “MISC FIELD 2” field on the #BS3 Screen indicated the Repayment Type as “F*,” “CT010,” or “CT01L,” the Repayment Schedule Type was “W”; or,
 

iii.
If the CURR LOAN STATUS” field on the #EDH Screen indicated either “SCHL” or “GRCE” and the “MISC FIELD 2” field on the #BS3 Screen indicated the Repayment Type as blank, the Repayment Schedule Type was “Z.”
 

If none of the criteria above applied, we were instructed by the Company that the Repayment Schedule Type was “V.”
 

7.
For purposes of comparing School Type 1 and School Type 2, we were informed by the Company that if the “SCHOOL_CODE” in the Data File was “000000,” there was no single school code associated with the Selected Student Loan. In such situations, we were instructed by the Company to not perform procedures related to School Type 1 and School Type 2.  No such situations were found for the Selected Student Loans.
 

8.
For purposes of comparing School Type 2, in the event the last two numbers of the “SCHOOL_CODE” in the Data File were not “00,” we were instructed by the Company to enter the last two numbers of the school code into the “SCHOOL BRANCH” field on the School Profile Screen (#728 Screen) to retrieve the “SCHL TYPE” field.  We compared the retrieved “SCHL TYPE” field to the “TITLE_IV_SCH_CODE” field on the Data File.
 

9.
For purposes of comparing Recent FICO, we were informed by the Company that if the “DATE CB SCORE GENERATED” on the #NM CR Screen was either after the Cutoff Date or within six (6) months
 
7

 
 


prior to the Cutoff Date, the “CREDIT BUREAU SCORE” field on the #NM CR Screen would display a more recent FICO than the one listed in the “REC_FICO” field in the Data File, and instructed not to consider such differences to be exceptions. No such situations were found for the Selected Student Loans.
 
Based on the results of the procedures performed, there is a 95.0% confidence level that the maximum estimated error occurrence rate for each of the attributes across the entire population of 82,035 Student Loans does not exceed 5.0%. Because we are not engaged to express a conclusion, we do not offer a conclusion based on the application of a sampling technique.
 
This agreed-upon procedures engagement was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants. We were not engaged to, and did not, conduct an examination or review, the objective of which would be the expression of an opinion or conclusion, respectively, on the specified attributes identified by the Company in the Data File. Accordingly, we do not express such an opinion or conclusion.  Had we performed additional procedures, other matters might have come to our attention that would have been reported to the Specified Parties.
 
The procedures performed were applied based on information included in the Data File, the Loan Files and instructions provided by the Company, without verification or evaluation of such information, or instructions by us; therefore, we express no opinion or any other form of assurance regarding (i) the physical existence of the Student Loans, (ii) the reasonableness of the instructions provided by the Company, (iii) the reliability or accuracy of the Loan Files which were used in our procedures, or (iv) matters of legal interpretation.
 
The procedures performed were not intended to address, nor did they address: (i) the conformity of the origination of the Student Loans to stated underwriting or credit extension guidelines, standards, criteria or other requirements, (ii) the value of collateral securing any such Student Loans being securitized, (iii) the compliance of the originator of the Student Loans with federal, state, and local laws and regulations, or (iv) any other factor or characteristic of the Student Loans that would be material to the likelihood that the issuer of the asset-backed security will pay interest and principal in accordance with applicable terms and conditions.  The procedures performed were not intended to satisfy any criteria for due diligence published by a nationally recognized statistical rating organization (“NRSRO”).
 
The terms of our engagement are such that we have no obligation to update this report because of events and transactions that may subsequently occur.
 
This report is intended solely for the information and use of the Specified Parties, and is not intended to be and should not be used by any other person or entity, including investors and NRSROs, who are not identified in the report as the Specified Parties but may have access to this report as required by law or regulation.
 
 
Irvine, CA
 
8

Exhibit A - The Selected Student Loans

Selected
Student
Loan
Number
Student
Loan
Number*
Selected
Student
Loan
Number
Student
Loan
Number*
Selected
Student
Loan
Number
Student
Loan
Number*
Selected
Student
Loan
Number
Student
Loan
Number*
Selected
Student
Loan
Number
Student
Loan
Number*
1
2020A001
39
2020A039
77
2020A077
115
2020A115
153
2020A153
2
2020A002
40
2020A040
78
2020A078
116
2020A116
154
2020A154
3
2020A003
41
2020A041
79
2020A079
117
2020A117
155
2020A155
4
2020A004
42
2020A042
80
2020A080
118
2020A118
156
2020A156
5
2020A005
43
2020A043
81
2020A081
119
2020A119
157
2020A157
6
2020A006
44
2020A044
82
2020A082
120
2020A120
158
2020A158
7
2020A007
45
2020A045
83
2020A083
121
2020A121
159
2020A159
8
2020A008
46
2020A046
84
2020A084
122
2020A122
160
2020A160
9
2020A009
47
2020A047
85
2020A085
123
2020A123
161
2020A161
10
2020A010
48
2020A048
86
2020A086
124
2020A124
162
2020A162
11
2020A011
49
2020A049
87
2020A087
125
2020A125
163
2020A163
12
2020A012
50
2020A050
88
2020A088
126
2020A126
164
2020A164
13
2020A013
51
2020A051
89
2020A089
127
2020A127
165
2020A165
14
2020A014
52
2020A052
90
2020A090
128
2020A128
166
2020A166
15
2020A015
53
2020A053
91
2020A091
129
2020A129
167
2020A167
16
2020A016
54
2020A054
92
2020A092
130
2020A130
168
2020A168
17
2020A017
55
2020A055
93
2020A093
131
2020A131
169
2020A169
18
2020A018
56
2020A056
94
2020A094
132
2020A132
170
2020A170
19
2020A019
57
2020A057
95
2020A095
133
2020A133
171
2020A171
20
2020A020
58
2020A058
96
2020A096
134
2020A134
172
2020A172
21
2020A021
59
2020A059
97
2020A097
135
2020A135
173
2020A173
22
2020A022
60
2020A060
98
2020A098
136
2020A136
174
2020A174
23
2020A023
61
2020A061
99
2020A099
137
2020A137
175
2020A175
24
2020A024
62
2020A062
100
2020A100
138
2020A138
176
2020A176
25
2020A025
63
2020A063
101
2020A101
139
2020A139
177
2020A177
26
2020A026
64
2020A064
102
2020A102
140
2020A140
178
2020A178
27
2020A027
65
2020A065
103
2020A103
141
2020A141
179
2020A179
28
2020A028
66
2020A066
104
2020A104
142
2020A142
180
2020A180
29
2020A029
67
2020A067
105
2020A105
143
2020A143
181
2020A181
30
2020A030
68
2020A068
106
2020A106
144
2020A144
182
2020A182
31
2020A031
69
2020A069
107
2020A107
145
2020A145
183
2020A183
32
2020A032
70
2020A070
108
2020A108
146
2020A146
184
2020A184
33
2020A033
71
2020A071
109
2020A109
147
2020A147
185
2020A185
34
2020A034
72
2020A072
110
2020A110
148
2020A148
186
2020A186
35
2020A035
73
2020A073
111
2020A111
149
2020A149
187
2020A187
36
2020A036
74
2020A074
112
2020A112
150
2020A150
188
2020A188
37
2020A037
75
2020A075
113
2020A113
151
2020A151
189
2020A189
38
2020A038
76
2020A076
114
2020A114
152
2020A152
190
2020A190


(*)
The Company has assigned a unique Loan ID number to each student loan in the Data File. The Student Loan Numbers referred to in this Exhibit are not the Account Numbers.


Selected
Student
Loan
Number
Student
Loan
Number*
Selected
Student
Loan
Number
Student
Loan
Number*
Selected
Student
Loan
Number
Student
Loan
Number*
Selected
Student
Loan
Number
Student
Loan
Number*
Selected
Student
Loan
Number
Student
Loan
Number*
191
2020A191
229
2020A229
267
2020A267
305
2020A305
343
2020A343
192
2020A192
230
2020A230
268
2020A268
306
2020A306
344
2020A344
193
2020A193
231
2020A231
269
2020A269
307
2020A307
345
2020A345
194
2020A194
232
2020A232
270
2020A270
308
2020A308
346
2020A346
195
2020A195
233
2020A233
271
2020A271
309
2020A309
347
2020A347
196
2020A196
234
2020A234
272
2020A272
310
2020A310
348
2020A348
197
2020A197
235
2020A235
273
2020A273
311
2020A311
349
2020A349
198
2020A198
236
2020A236
274
2020A274
312
2020A312
350
2020A350
199
2020A199
237
2020A237
275
2020A275
313
2020A313
351
2020A351
200
2020A200
238
2020A238
276
2020A276
314
2020A314
352
2020A352
201
2020A201
239
2020A239
277
2020A277
315
2020A315
353
2020A353
202
2020A202
240
2020A240
278
2020A278
316
2020A316
354
2020A354
203
2020A203
241
2020A241
279
2020A279
317
2020A317
355
2020A355
204
2020A204
242
2020A242
280
2020A280
318
2020A318
356
2020A356
205
2020A205
243
2020A243
281
2020A281
319
2020A319
357
2020A357
206
2020A206
244
2020A244
282
2020A282
320
2020A320
358
2020A358
207
2020A207
245
2020A245
283
2020A283
321
2020A321
359
2020A359
208
2020A208
246
2020A246
284
2020A284
322
2020A322
360
2020A360
209
2020A209
247
2020A247
285
2020A285
323
2020A323
361
2020A361
210
2020A210
248
2020A248
286
2020A286
324
2020A324
   
211
2020A211
249
2020A249
287
2020A287
325
2020A325
   
212
2020A212
250
2020A250
288
2020A288
326
2020A326
   
213
2020A213
251
2020A251
289
2020A289
327
2020A327
   
214
2020A214
252
2020A252
290
2020A290
328
2020A328
   
215
2020A215
253
2020A253
291
2020A291
329
2020A329
   
216
2020A216
254
2020A254
292
2020A292
330
2020A330
   
217
2020A217
255
2020A255
293
2020A293
331
2020A331
   
218
2020A218
256
2020A256
294
2020A294
332
2020A332
   
219
2020A219
257
2020A257
295
2020A295
333
2020A333
   
220
2020A220
258
2020A258
296
2020A296
334
2020A334
   
221
2020A221
259
2020A259
297
2020A297
335
2020A335
   
222
2020A222
260
2020A260
298
2020A298
336
2020A336
   
223
2020A223
261
2020A261
299
2020A299
337
2020A337
   
224
2020A224
262
2020A262
300
2020A300
338
2020A338
   
225
2020A225
263
2020A263
301
2020A301
339
2020A339
   
226
2020A226
264
2020A264
302
2020A302
340
2020A340
   
227
2020A227
265
2020A265
303
2020A303
341
2020A341
   
228
2020A228
266
2020A266
304
2020A304
342
2020A342
   


 
(*)
The Company has assigned a unique Loan ID number to each student loan in the Data File. The Student Loan Numbers referred to in this Exhibit are not the Account Numbers.
 

Dates Referenced Herein

This ‘ABS-15G’ Filing    Date    Other Filings
Filed on / For Period end:1/13/20None on these Dates
1/9/20
12/11/19
12/8/19
 List all Filings 
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Filing Submission 0000929638-20-000040   –   Alternative Formats (Word / Rich Text, HTML, Plain Text, et al.)

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