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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 |
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
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):
|
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)
|
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),
|
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:
|
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.
|
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.
|
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;
|
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
|
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);
|
We compared the Recomputed Remaining Term to the “REM_TERM” field in the Data File.
|
#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”;
|
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
|
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.
|
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
|
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
|
This ‘ABS-15G’ Filing | Date | Other Filings | ||
---|---|---|---|---|
Filed on / For Period end: | 1/13/20 | None on these Dates | ||
1/9/20 | ||||
12/11/19 | ||||
12/8/19 | ||||
List all Filings |