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SLC Student Loan Trust 2010-1 – ‘10-K’ for 12/31/23 – ‘EX-33.2’

On:  Thursday, 3/28/24, at 5:17pm ET   ·   For:  12/31/23   ·   Accession #:  1140361-24-16268   ·   File #:  333-164557-01

Previous ‘10-K’:  ‘10-K’ on 3/31/23 for 12/31/22   ·   Latest ‘10-K’:  This Filing   ·   3 References:   

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

 3/28/24  SLC Student Loan Trust 2010-1     10-K       12/31/23    8:898K                                   Broadridge Fin’l So… Inc

Asset-Backed Securities (ABS)

Asset Class:  Student loans   ·   Sponsor:  Student Loan Corp.   ·   Depositor:  SLC Student Loan Receivables I Inc.

Annual Report   —   Form 10-K   —   SEA’34

Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: 10-K        Annual Report                                       HTML     76K 
 3: EX-33.1     Report of Compliance with Servicing Criteria        HTML    653K 
 4: EX-33.2     Report of Compliance with Servicing Criteria        HTML    135K 
 5: EX-34.1     Attestation Report on Assessment of Compliance      HTML     11K 
                with Servicing Criteria                                          
 6: EX-34.2     Attestation Report on Assessment of Compliance      HTML     11K 
                with Servicing Criteria                                          
 7: EX-35.1     Servicer Compliance Statement                       HTML      9K 
 8: EX-35.2     Servicer Compliance Statement                       HTML      9K 
 2: EX-31       Certification -- §302 - SOA'02                      HTML     11K

‘EX-33.2’   —   Report of Compliance with Servicing Criteria

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

 C: 
Exhibit 33.2

Assertion on Compliance with Regulation AB Criteria

Navient Solutions, LLC (formerly, Navient Solutions, Inc.), (the “Asserting Party”), a direct wholly owned subsidiary of Navient Corporation, is responsible for assessing compliance as of December 31, 2023 and for the period from January 1, 2023 through December 31, 2023 (the “Reporting Period”), with the servicing criteria set forth in Item 1122(d) of Regulation AB related to its servicing of student loan asset-backed securities transactions that were outstanding during the Reporting Period (collectively, the “Platform” and each such trust is a “Platform trust”), to the extent required by the related transaction agreements as to any transaction, except for servicing criteria Items 1122(d)(1)(iii), 1122(d)(2)(ii), 1122(d)(2)(iii), 1122(d)(2)(vi), 1122(d)(3)(iii) and 1122(d)(4)(x)-1122(d)(4)(xiii), which the Asserting Party has concluded were not required of the Asserting Party under the related transaction agreements with respect to any Platform trust during the Reporting Period.  Appendix A attached hereto identifies the servicing criteria, after giving effect to the exclusions identified herein, that are applicable to the Platform (the “Applicable Servicing Criteria”).  Appendix B attached hereto identifies the outstanding student loan asset-backed securities transactions defined by the Asserting Party as constituting the Platform for which the Asserting Party acted as administrator or sub-administrator, as applicable (collectively, the “Administrator”) and servicer or subservicer, as applicable (collectively, the “Servicer”) during the Reporting Period.
 
With respect to servicing criteria Items 1122(d)(1)(i), 1122(d)(2)(iv), 1122(d)(2)(v), 1122(d)(2)(vii), 1122(d)(3)(i), 1122(d)(3)(ii), 1122(d)(3)(iv), 1122(d)(4)(iii) and 1122 (d)(4)(xv), the Asserting Party has concluded that such criteria are not applicable under the related transaction agreements for the SMB Private Education Loan Trust 2014-A transaction and the Goal Structured Solutions Trust 2016-B transaction.
 
The Asserting Party has assessed compliance with the Applicable Servicing Criteria and has concluded that it has complied, in all material respects, with the Applicable Servicing Criteria as of December 31, 2023 and for the Reporting Period with respect to the Platform as a whole.
 
KPMG LLP, an independent registered public accounting firm, has issued an attestation report on the Asserting Party’s assessment of compliance with the Applicable Servicing Criteria as of December 31, 2023 and for the Reporting Period.
 
[Signature Page Follows]

Assertion on Compliance with Regulation AB Criteria

Navient Solutions, LLC, as Administrator and
  
Servicer for the Platform trusts
  
   
/s/ Jeffrey Stine
 
 
Vice President, Core Processing
  
Navient Solutions, LLC
  
 

Assertion on Compliance with Regulation AB Criteria

Appendix A

SERVICING CRITERIA
APPLICABLE
SERVICING CRITERIA
INAPPLICABLE
SERVICING CRITERIA1
Reference
Criteria
Performed
by
Asserting Party2
Performed by
third-party servicers3
  
 
General Servicing Consideration
      
1122(d)(1)(i)
Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreements.
 
X
 
X
 
Y
 
       
1122(d)(1)(ii)
If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third party’s performance and compliance with such servicing activities.
 
X
 
X
  
 
       
1122(d)(1)(iii)
Any requirements in the transaction agreements to maintain a back-up servicer for the trust student loans are maintained.
    
Z
 
       
1122(d)(1)(iv)
A fidelity bond and errors and omissions policy is in effect on the party participating in the servicing function throughout the reporting period in the amount of coverage required by and otherwise in accordance with the terms of the transaction agreements.
 
X
 
X
  
 
       
1122(d)(1)(v)
Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.
X
X
  
 
       
Cash Collection and Administration
      
1122(d)(2)(i)
  
Payments on trust student loans are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days following receipt, or such other number of days specified in the transaction documents.
 
X
 
X
  
           
1122(d)(2)(ii)
  
Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.
  
X
Z
           
1122(d)(2)(iii)
  
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.
    
Z
           
1122(d)(2)(iv)
  
The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of overcollateralization, are separately maintained (e.g. with respect to commingling of cash) as set forth in the transaction agreements.
 
X
 
X
 
 
Y
           
1122(d)(2)(v)
  
Each custodial account is maintained at a federally insured depository institution as set forth in the transaction agreements.  For purposes of this criterion, “federally insured depository institutions” with respect to a foreign financial institution means a foreign financial that meets the requirements of Rule 13k-1(b)(1) of the Securities Exchange Act.
 
X
 
X
 
Y

1 The servicing criteria marked in this column with a “Y” are inapplicable to the Asserting Party in the SMB Private Education Loan Trust 2014-A transaction in and the Goal Structured Solutions Trust 2016-B transaction in its role as subservicer pursuant to the related transaction agreements.  The servicing criteria marked in this column with a “Z” are criteria that the Asserting Party concluded were not required of the Asserting Party under the related transaction agreements for any Platform trust during the Reporting Period.
2 Servicing criteria performed by the Asserting Party.
3 Asserting Party has outsourced certain servicing activities to third parties. Specifically, Nelnet Servicing, LLC (“Nelnet”) performed certain servicing activities for SLM Student Loan Trust 2010-1, SLM Student Loan Trust 2010-2 and Navient Student Loan Trust 2014-2 for the period from January 1,2023 to December 31,2023.  Additionally, for each Platform trust, the related indenture trustee performs certain servicing activities.

SERVICING CRITERIA
APPLICABLE
SERVICING CRITERIA
INAPPLICABLE
SERVICING CRITERIA
Reference
Criteria
Performed by
Asserting Party
Performed by
third-party servicers
  
1122(d)(2)(vi)
  
Un-issued checks are safeguarded so as to prevent unauthorized access.
    
Z
           
1122(d)(2)(vii)
  
Reconciliations are prepared on a monthly basis for all asset-backed securities related bank accounts, including custodial accounts and related bank clearing accounts.  These reconciliations are (A) mathematically accurate; (B) prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C) reviewed and approved by someone other than the person who prepared the reconciliation; items are resolved within 90 calendar days of their original identification, or such other number of days specified in the transaction agreements.
X
X
Y
           
       
Investor Remittances and Reporting
      
1122(d)(3)(i)
  
Reports to investors, including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements.  Specifically, such reports (A) are prepared in accordance with timeframes and other terms set forth in the transaction agreements; (B) provide information calculated in accordance with the terms specified in the transaction agreements; (C) are filed with the Commission as required by its rules and regulations; and (D) agree with investors’ or the trustee’s records as to the total unpaid principal balance and number of student loans serviced by the Servicer.
X
X
Y
           
1122(d)(3)(ii)
  
Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.
X
X
Y
           
1122(d)(3)(iii)
  
Disbursements made to an investor are posted within two business days to the Servicer’s investor records, or such other number of days specified in the transaction agreements.
  
X
Z
           
1122(d)(3)(iv)
  
Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.
X
X
Y
           

SERVICING CRITERIA
APPLICABLE
SERVICING CRITERIA
INAPPLICABLE
SERVICING CRITERIA
Reference
Criteria
Performed by
Asserting Party
Performed by
third-party servicers
  
 
Pool Asset Administration
      
         
1122(d)(4)(i)
  
Collateral or security on student loans is maintained as required by the transaction documents or related student loan documents.
X
X
  
           
1122(d)(4)(ii)
 
  
Student loan and related documents are safeguarded as required by the transaction documents.
X
X
  
           
1122(d)(4)(iii)
  
Any additions, removals or substitutions to the asset pool are made, reviewed and approved in accordance with any conditions or requirements in the transaction documents.
X
X
Y
           
1122(d)(4)(iv)
  
Payments on student loans, including any payoffs, made in accordance with the related student loan documents are posted to the Servicer’s obligor records maintained no more than two business days after receipt, or such other number of days specified in the transaction documents, and allocated to principal, interest or other items (e.g., escrow) in accordance with the related student loan documents.
X
X
  
           
1122(d)(4)(v)
  
The Servicer’s records regarding the student loans agree with the Servicer’s records with respect to an obligor’s unpaid principal balance.
X
X
  
           
1122(d)(4)(vi)
  
Changes with respect to the terms or status of an obligor’s student loans (e.g., loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction documents and related pool asset documents.
X
X
  
           
1122(d)(4)(vii)
  
Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframes or other requirements established by the transaction documents.
X
X
  
           
1122(d)(4)(viii)
  
Records documenting collection efforts are maintained during the period a student loan is delinquent in accordance with the transaction documents. Such records are maintained on at least a monthly basis, or such other period specified in the transaction documents, and describe the entity’s activities in monitoring delinquent student loans including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment).
X
X
  
           
1122(d)(4)(ix)
  
Adjustments to interest rates or rates of return for student loans with variable rates are computed based on the related student loan documents.
X
X
  
           

SERVICING CRITERIA
APPLICABLE
SERVICING CRITERIA
INAPPLICABLE
SERVICING CRITERIA
Reference
Criteria
Performed by
Asserting Party
Performed by
third-party servicers
  
1122(d)(4)(x)
  
Regarding any funds held in trust for an obligor (such as escrow accounts): (A) such funds are analyzed, in accordance with the obligor’s student loan documents, on at least an annual basis, or such other period specified in the transaction documents; (B) interest on such funds is paid, or credited, to obligors in accordance with applicable student loan documents and state laws; and (C) such funds are returned to the obligor within 30 calendar days of full repayment of the related student loans, or such other number of days specified in the transaction documents.
    
Z
           
1122(d)(4)(xi)
  
Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that such support has been received by the servicer at least 30 calendar days prior to these dates, or such other number of days specified in the transaction documents.
    
Z
           
1122(d)(4)(xii)
  
Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from the servicer’s funds and not charged to the obligor, unless the late payment was due to the obligor’s error or omission.
    
Z
           
1122(d)(4)(xiii)
  
Disbursements made on behalf of an obligor are posted within two business days to the obligor’s records maintained by the servicer, or such other number of days specified in the transaction documents.
    
Z
           
1122(d)(4)(xiv)
  
Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction documents.
X
X
  
           
1122(d)(4)(xv)
  
Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as set forth in the transaction documents.
X
X
Y
           

Appendix B

 
Trust Name:
  
Date of Issuance:
 
SLM Student Loan Trust 2006-2
  
 
SLM Student Loan Trust 2006-4
  
 
SLM Student Loan Trust 2006-5
  
 
SLM Student Loan Trust 2006-6
  
 
SLM Student Loan Trust 2006-7
  
 
SLM Student Loan Trust 2006-8
  
 
SLM Student Loan Trust 2006-9
  
 
SLM Student Loan Trust 2006-10
  
 
SLM Private Credit Student Loan Trust 2006-A
  
 
SLM Private Credit Student Loan Trust 2006-B
  
 
SLM Private Credit Student Loan Trust 2006-C
  
 
SLM Student Loan Trust 2007-1
  
 
SLM Student Loan Trust 2007-4
  
 
SLM Student Loan Trust 2007-5
  
 
SLM Student Loan Trust 2007-6
  
 
SLM Student Loan Trust 2007-7
  
 
SLM Student Loan Trust 2007-8
  
 
SLM Private Credit Student Loan Trust 2007-A
  
 
SLM Student Loan Trust 2008-2
  
 
SLM Student Loan Trust 2008-3
  
 
SLM Student Loan Trust 2008-4
  
 
SLM Student Loan Trust 2008-5
  
 
SLM Student Loan Trust 2008-6
  
 
SLM Student Loan Trust 2008-7
  
 
SLM Student Loan Trust 2009-1
  
 
SLM Student Loan Trust 2009-2
  
 
SLM Student Loan Trust 2010-1
  
 
SLM Student Loan Trust 2010-2
  
 
SLM Student Loan Trust 2011-1
  
 
SLM Student Loan Trust 2011-2
  
 
SLM Student Loan Trust 2011-3
  
 
SLM Student Loan Trust 2012-1
  
 
SLM Student Loan Trust 2012-2
  
 
SLM Student Loan Trust 2012-3
  
 
SLM Student Loan Trust 2012-5
  
 
SLM Student Loan Trust 2012-6
  
 
SLM Student Loan Trust 2012-7
  
 
SLM Student Loan Trust 2013-1
  
 
SLM Student Loan Trust 2013-2
  
 
SLM Student Loan Trust 2013-3
  

 
SLM Student Loan Trust 2013-4
  
 
SLM Student Loan Trust 2013-5
  
 
SLM Student Loan Trust 2013-6
  
 
SLM Student Loan Trust 2014-1
  
 
SLM Student Loan Trust 2014-2
  
 
Navient Student Loan Trust 2014-1
  
 
Navient Student Loan Trust 2014-2
  
 
Navient Student Loan Trust 2014-3
  
 
Navient Student Loan Trust 2014-4
  
 
Navient Student Loan Trust 2014-5
  
 
Navient Student Loan Trust 2014-6
  
 
Navient Student Loan Trust 2014-7
  
 
Navient Student Loan Trust 2014-8
  
 
Navient Student Loan Trust 2015-1
  
 
Navient Student Loan Trust 2015-2
  
 
Navient Student Loan Trust 2015-3
  
 
SLC Student Loan Trust 2004-1
  
 
SLC Student Loan Trust 2005-1
  
 
SLC Student Loan Trust 2005-2
  
 
SLC Student Loan Trust 2005-3
  
 
SLC Student Loan Trust 2006-1
  
 
SLC Student Loan Trust 2006-2
  
 
SLC Student Loan Trust 2007-1
  
 
SLC Student Loan Trust 2007-2
  
 
SLC Student Loan Trust 2008-1
  
 
SLC Student Loan Trust 2008-2
  
 
SLC Student Loan Trust 2009-1
  
 
SLC Student Loan Trust 2009-2
  
 
SLC Student Loan Trust 2009-3
  
 
SLC Student Loan Trust 2010-1
  
 
SMB Private Education Loan Trust 2014-A
  
 
Goal Structured Solutions Trust 2016-B
  


Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘10-K’ Filing    Date    Other Filings
Filed on:3/28/24
For Period end:12/31/23
1/1/23
12/23/16
6/18/15
4/23/15
2/26/15
11/25/14
8/14/14
8/7/14
5/29/14
3/27/14
1/28/14
11/14/13
9/19/13
8/15/13
6/20/13
4/11/13
2/14/13
11/8/12
9/20/12
7/19/12
5/3/12
3/15/12
1/19/12
11/18/11
5/26/11
3/3/11
8/26/10
7/6/10424B5,  8-K,  FWP
4/15/10
12/22/09
7/23/09
4/21/09
4/9/09
2/13/09
7/2/08
6/26/08
6/12/08
4/30/08
4/17/08
3/28/08
2/28/08
2/7/08
12/6/07
11/27/07
11/8/07
10/23/07
7/19/07
6/26/07
4/5/07
3/29/07
1/25/07
11/30/06
10/12/06
9/28/06
9/19/06
9/14/06
8/10/06
7/20/06
6/28/06
6/21/06
6/8/06
4/20/06
4/6/06
2/23/06
12/15/05
9/28/05
6/15/05
11/23/04
 List all Filings 

3 Previous Filings that this Filing References

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

 1/05/11  SLC Student Loan Trust 2010-1     8-K:1,9    12/31/10    2:485K                                   Skadden/FA
 7/06/10  SLC Student Loan Trust 2010-1     8-K:1,2,9   7/06/10   12:1.6M                                   Bingham McCutchen LLP/FA
 3/17/10  SLC Student Loan Recs I Inc.      S-3/A®                17:4.1M                                   Bingham McCutchen LLP/FA
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Filing Submission 0001140361-24-016268   –   Alternative Formats (Word / Rich Text, HTML, Plain Text, et al.)
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