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Fitch Rates Dryden 37 Senior Loan Fund/LLC

CHICAGO–(BUSINESS WIRE)–

Fitch Ratings assigns the following rating and Rating Outlook to Dryden 37 Senior Loan Fund/LLC:

–$320,000,000 class A notes ‘AAAsf’; Outlook Stable.

Fitch does not rate the class B, C, D, E, F or subordinated notes.

TRANSACTION SUMMARY

Dryden 37 Senior Loan Fund (the issuer) and Dryden 37 Senior Loan Fund LLC (the co-issuer) represent an arbitrage cash flow collateralized loan obligation (CLO) that will be managed by Prudential Investment Management, Inc. (Prudential). Net proceeds from the issuance of notes will be used to purchase a portfolio of approximately $500 million of leveraged loans. The CLO will have a four-year reinvestment period.

KEY RATING DRIVERS

Sufficient Credit Enhancement: Credit enhancement (CE) of 36% for class A, in addition to excess spread, is sufficient to protect against portfolio default and recovery rate projections in the ‘AAAsf’ stress scenario. The level of CE for the class A notes is below the average for recent CLO issuances; however, cash flow modeling indicates performance in line with other ‘AAAsf’ rated CLO notes.

‘B+/B’ Asset Quality: The average credit quality of the indicative portfolio is ‘B+/B’, which is slightly better than that of recent CLOs. Issuers rated in the ‘B’ rating category denote relatively weak credit quality; however, in Fitch’s opinion, the class A notes are unlikely to be affected by the foreseeable level of defaults. The class A notes are robust against default rates of up to 57.4%.

Strong Recovery Expectations: The indicative portfolio consists of 96.4% first-lien senior-secured loans. Approximately 89.5% of the indicative portfolio has either strong recovery prospects or a Fitch-assigned Recovery Rating of ‘RR2’ or higher, resulting in a base case recovery assumption of 76.1%. In determination of the class A note rating, Fitch stressed the indicative portfolio by assuming a higher portfolio concentration of assets with lower recovery prospects and further reduced recovery assumptions for higher rating stress assumptions. The analysis of Dryden 37 class A notes assumed a 34.7% recovery rate in Fitch’s ‘AAAsf’ scenario.

RATING SENSITIVITIES

Fitch evaluated the structure’s sensitivity to the potential variability of key model assumptions including decreases in weighted average spread or recovery rates and increases in default rates or correlation. Fitch expects the class A notes to remain investment grade even under the most extreme sensitivity scenarios. Results under these sensitivity scenarios ranged between ‘A-sf’ and ‘AAAsf’ for the class A notes.

Sources of information used to assess these ratings were provided by the arranger, J.P. Morgan Securities LLC, and the public domain.

Key Rating Drivers and Rating Sensitivities are further described in the accompanying new issue report, which will be available shortly to investors on Fitch’s website at ‘www.fitchratings.com‘.

For more information about Fitch’s comprehensive subscription service FitchResearch, which includes all presale reports, surveillance and credit reports on more than 20 asset classes, contact product sales at +1-212-908-0800 or at ‘webmaster@fitchratings.com‘.

Additional information is available at ‘www.fitchratings.com‘.

Applicable Criteria & Related Research:

–‘Global Structured Finance Rating Criteria’ (Aug. 4, 2014);

–‘Global Rating Criteria for Corporate CDOs’ (July 25, 2014);

–‘Criteria for Interest Rate Stresses in Structured Finance Transactions and Covered Bonds’ (Dec. 19, 2014);

–‘Counterparty Criteria for Structured Finance and Covered Bonds’ (May 14, 2014).

Applicable Criteria and Related Research:

Global Structured Finance Rating Criteria

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=754389

Global Rating Criteria for Corporate CDOs

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=753057

Criteria for Interest Rate Stresses in Structured Finance Transactions and Covered Bonds

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=838868

Counterparty Criteria for Structured Finance and Covered Bonds

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=744158

Additional Disclosure

Solicitation Status

http://www.fitchratings.com/gws/en/disclosure/solicitation?pr_id=981238

ALL FITCH CREDIT RATINGS ARE SUBJECT TO CERTAIN LIMITATIONS AND DISCLAIMERS. PLEASE READ THESE LIMITATIONS AND DISCLAIMERS BY FOLLOWING THIS LINK: HTTP://FITCHRATINGS.COM/UNDERSTANDINGCREDITRATINGS. IN ADDITION, RATING DEFINITIONS AND THE TERMS OF USE OF SUCH RATINGS ARE AVAILABLE ON THE AGENCY’S PUBLIC WEBSITE ‘WWW.FITCHRATINGS.COM‘. PUBLISHED RATINGS, CRITERIA AND METHODOLOGIES ARE AVAILABLE FROM THIS SITE AT ALL TIMES. FITCH’S CODE OF CONDUCT, CONFIDENTIALITY, CONFLICTS OF INTEREST, AFFILIATE FIREWALL, COMPLIANCE AND OTHER RELEVANT POLICIES AND PROCEDURES ARE ALSO AVAILABLE FROM THE ‘CODE OF CONDUCT’ SECTION OF THIS SITE. FITCH MAY HAVE PROVIDED ANOTHER PERMISSIBLE SERVICE TO THE RATED ENTITY OR ITS RELATED THIRD PARTIES. DETAILS OF THIS SERVICE FOR RATINGS FOR WHICH THE LEAD ANALYST IS BASED IN AN EU-REGISTERED ENTITY CAN BE FOUND ON THE ENTITY SUMMARY PAGE FOR THIS ISSUER ON THE FITCH WEBSITE.

Investment & Company InformationFinanceFitch Ratings Contact:

Fitch Ratings

Primary Analyst

Aaron Hughes

Director

+1-312-368-2074

Fitch Ratings, Inc.

70 West Madison Street

Chicago, IL 60602

or

Secondary Analyst

Cristina Feracota

Associate Director

+1-312-606-2300

or

Committee Chairperson

Derek Miller

Senior Director

+1-312-368-2076

or

Media Relations:

Sandro Scenga, +1-212-908-0278

sandro.scenga@fitchratings.com […]

A Student Loan Repayment Trick That Can Save You Money

It’s common knowledge you can save money by paying off loans and other debts quickly or ahead of schedule. You can also save money by making monthly payments as planned, if you put in a little extra effort and do the math.

The trick? You can change your repayment period to an extended plan (for example, a 25-year instead of a 10-year repayment period) but continue to pay the amount required to be debt-free within 10 years and request the extra payment go toward the principal balance. The amount you overpay reduces the interest you’ll pay over the life of your loan. Here’s where the extra effort is necessary: You should frequently follow up with your loan servicer and check your statements to make sure the extra payment is applied as you instructed.

Perhaps you’ve heard of this tactic — it’s particularly common among homeowners with mortgages — and wondered if it’s something you could do. A Reddit user recently posted about the strategy, saying, “Am I crazy, or can I actually save money by using the extended payment plan for federal loans?”

Not crazy. It’s a smart plan, you just need to make sure you know what you’re doing.

“That post is completely on target,” said Mitch Weiss, a finance professor at the University of Hartford. He frequently writes about student loan issues for Credit.com and has written about this strategy as a good way to save money but also give yourself flexibility. “You can always fall back on that lower payment when you need it. Managing your cash flow is in your hands, then.”

In the post, the redditor provided a good example. He pays $636 each month on a 10-year repayment plan, and the required monthly payment would drop to $333 a month for a 25-year repayment plan. By continuing to pay $636 a month, the extra money would go toward the principal balance on the loan with the highest interest rate (he checked with his loan servicer, and that’s its policy — you’ll want to check with your own servicer to confirm if this is its policy as well). In the event he can’t afford the $636 some months, he can fall back on the lower required payment, rather than having to go the servicer and explain the hardship and try and work something out (or make a partial payment and get hit with late fees or skip a payment and get a delinquency on his credit report).

The redditor said he used a loan calculator and found that he’d pay off his debt two months faster and save more than $1,000 in interest that the loan would have accrued under the 10-year plan.

“Am I missing something here, or is this a no-risk way of saving $1,100 and 2 months? I mean it gives emergency flexibility AND saves me money?” he wrote.

As dozens of people replied (and Weiss confirmed), the math is correct, but when it comes to student loans, you need to be careful.

“It’s all about execution, and the way that you ensure execution is that you have your directions in writing and you follow up,” Weiss said. Tell your servicer exactly what you want them to do with that extra payment (put it toward the principal balance, and if there are multiple loans, the principal balance of the loan with the highest rate), and make sure they do it. Otherwise, they may take the extra payment as a future payment and just not charge you again until the prepaid amount runs out.

Another Reddit commenter said it took emailing his or her servicer every 48 hours for almost two months to make sure the servicer applied the payment as instructed. Weiss said he’s heard and read about that complaint a lot.

“It was a very constructive string of comments,” Weiss said. “I think this demonstrates how serious an issue this is for so many people and how so many people are taking this so seriously.”

As you pay down your student loans (no matter your strategy), it can help to keep an eye on your credit reports for any inaccuracies or problems that could drag down your credit score. You can get a free credit report summary, updated every 30 days on Credit.com, to track your progress as you get out of debt.

More from Credit.com
How to Consolidate Your Student Loan DebtHow Long Will You Be Paying Your Student Loans?Your Repayment Options for Student LoansFinanceEducationstudent loan […]

Greece to seek help to ‘smooth cash flow hump’ on EU loans

Greek finance minister Yanis Varoufakis has announced he will ask EU partners for further assistance in the coming weeks to “smooth over a cash-flow hump” on Greece’s EU loans.

Days after EU finance ministers agreed a four-month EU/IMF loan-extension to the €240 billion Greek programme, German finance minister Dr Schäuble warned Athens to stick to the agreed conditions for its four-month loan extension or put external funding at risk.

German finance minister issues warning to Greek government Varoufakis highlights battle between rules and macroeconomics at the euro group table Germany supports extension of Greek bailout programme

In an interview marathon over the weekend, both Greek and German finance ministers tried to put very different spins on last week’s deal in Brussels.

Mr Varoufakis vowed to begin work on detailing reforms he has vowed to implement by April, and to repay International Monetary Fund (IMF) loans of €1.5 billion due in March.

Debt rescheduling

But in interviews with the Associated Press and Germany’s Handelsblatt business daily, published today, he said he would ask for debt rescheduling talks with European institutions. “We intend to being the conversation with our partners and institutions regarding debt sustainability and debt rescheduling,” said Mr Varoufakis, saying it was “impossible” for Greece to meet obligations of almost €11.5 billion between June and August.

He said he would not seek a loan write-down or haircut – “haircut is a dirty word” – but would seek flexibility in repayment of its loans to the European Central Bank (ECB).

Mr Varoufakis said he was aware the Frankfurt institution was unlikely to be enthused by such talk, but saw no alternative.

“What we can do is package a deal that makes these repayments palatable and reasonably doable as part of our overall negotiation regarding the Greek debt,” he told the Associated Press. In the Handelsblatt interview, Mr Varoufakis floated the idea of credit swaps: issuing sovereign bonds whose returns were tied to Greece’s GDP figures.

“Then our creditors would also have an interest in Greece’s economy starting to grow again,” he said.

In Berlin, however, German finance minister Wolfgang Schäuble has warned his Greek colleague not to unpick last week’s agreement. It was “not his problem”, he said, how the hard-left Syriza government squared the loan extension it asked for last week with its election promise to do nothing of the sort.

“I have confidence in the Greek government to implement the necessary measures, establish a more efficient tax administration and ultimately to fulfil the conditions,” said Dr Schäuble.

“We made a clear agreement in the Eurogroup. Mr [Alexis] Tsipras made a promise. If Greece doesn’t stick to that, there will be no further aid.”

In an interview with the Bild am Sonntag, however, Dr Schäuble saved his strongest words for the Germany’s leading tabloid, urging it to stop cranking up fear over Greece’s EU/IMF programme.

In recent days Bild has stepped up its five-year-long campaign against Greece, urging MPs not to back a further loan extension for Greece. On Saturday it published a list of how all 587 MPs voted in Friday’s Bundestag vote – in which just 45 voted against or abstained.

Euro area votes

The Bundestag vote was one of several parliamentary votes across the euro area required for a four-month extension of the Greek programme with its 18 eurozone partners.

Dr Schäuble agreed in the Bild interview that German loans and guarantees top €60 billion to Greece, leaving each German citizen liable for €1,000 per head. But he pointed out that the lifespan of the liabilities was up to 32 years.

“Abstract calculations are misleading. You are a reputable newspaper and I am trying to do serious politics,” he said. “We Germans are better off than most people in the planet and most people who lived before us … your readers shouldn’t let their joy for life be ruined.”

[…]

Fitch Affirms Ratings for SLM Student Loan Trust 2012-3 Notes

NEW YORK–(BUSINESS WIRE)–

Fitch Ratings affirms the senior notes and subordinate notes issued by SLM Student Loan Trust 2012-3 at ‘AAAsf’ and ‘AAsf’, respectively. The Rating Outlook remains Stable for the senior and subordinate notes. A detailed list of rating actions follows at the end of this press release.

KEY RATING DRIVERS

High Collateral Quality

The collateral consists of 100% of Federal Family Education Loan Program (FFELP) loans. The credit quality of the trust collateral is high, in Fitch’s opinion, based on the guarantees provided by the transaction’s eligible guarantors and reinsurance provided by the U.S. Department of Education (ED) for at least 97% of principal and accrued interest. Fitch currently rates the U.S. sovereign at “AAA”, outlook stable.

Sufficient Credit Enhancement

While both the senior and subordinate notes will benefit from overcollateralization (OC; the excess of trust’s asset balance over bond balance) and excess spread, the senior notes also benefit from subordination provided by the class B note. As of January 2015, total parity is 101.01% (1.00% CE) and senior parity is 105.54% (5.25% CE). Cash is being released from the trust, given the specified OC amount, which is equal to the greater of 1.00% of the current adjustable pool balance and $1,300,000, has been achieved.

Adequate Liquidity Support

Liquidity support is provided by a Debt Service Reserve Fund sized at the greater of 0.25% of the pool balance and $1,249,353.

Acceptable Servicing Capabilities

Navient, formerly Sallie Mae, Inc., is responsible for day-to-day servicing of the trust. Fitch believes Navient is an acceptable servicer of FFELP student loans.

RATING SENSITIVITIES

Since FFELP student loan ABS rely on the U.S. government to reimburse defaults, ‘AAAsf’ FFELP ABS ratings will likely move in tandem with the ‘AAA’ U.S. sovereign rating. Aside from the U.S. sovereign rating, defaults and basis risk account for the majority of the risk embedded in FFELP student loan transactions. Additional defaults and basis shock beyond Fitch’s published stresses could result in future downgrades. Likewise, a buildup of CE driven by positive excess spread given favorable basis factor conditions could lead to future upgrades.

Initial Key Rating Drivers and Rating Sensitivity further described in the Presale report published on April 24, 2012.

Fitch has affirmed the following:

SLM Student Loan Trust 2012-3:

–Class A notes at ‘AAAsf’; Outlook Stable;

–Class B notes at ‘AAsf’; Outlook Stable.

A comparison of the transaction’s Representations, Warranties, and Enforcement Mechanisms (RW&Es) to those of typical RW&Es for student loans is available by accessing the reports and links below:

–‘SLM Student Loan Trust 2012-3 – Appendix’, dated April 24, 2012;

–‘Representations, Warranties, and Enforcement Mechanisms in Global Structured Finance Transactions — Amended’, dated April 17, 2013.

Additional information is available at ‘www.fitchratings.com‘.

Applicable Criteria and Related Research:

–‘Global Structured Finance Rating Criteria’ (August 2014);

–‘Rating U.S. Federal Family Education Loan Program Student Loan ABS Criteria’ (June 2014).

Applicable Criteria and Related Research:

Global Structured Finance Rating Criteria

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=754389

Rating U.S. Federal Family Education Loan Program Student Loan ABS Criteria

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=750530

Additional Disclosure

Solicitation Status

http://www.fitchratings.com/gws/en/disclosure/solicitation?pr_id=980252

ALL FITCH CREDIT RATINGS ARE SUBJECT TO CERTAIN LIMITATIONS AND DISCLAIMERS. PLEASE READ THESE LIMITATIONS AND DISCLAIMERS BY FOLLOWING THIS LINK: HTTP://FITCHRATINGS.COM/UNDERSTANDINGCREDITRATINGS. IN ADDITION, RATING DEFINITIONS AND THE TERMS OF USE OF SUCH RATINGS ARE AVAILABLE ON THE AGENCY’S PUBLIC WEBSITE ‘WWW.FITCHRATINGS.COM‘. PUBLISHED RATINGS, CRITERIA AND METHODOLOGIES ARE AVAILABLE FROM THIS SITE AT ALL TIMES. FITCH’S CODE OF CONDUCT, CONFIDENTIALITY, CONFLICTS OF INTEREST, AFFILIATE FIREWALL, COMPLIANCE AND OTHER RELEVANT POLICIES AND PROCEDURES ARE ALSO AVAILABLE FROM THE ‘CODE OF CONDUCT’ SECTION OF THIS SITE. FITCH MAY HAVE PROVIDED ANOTHER PERMISSIBLE SERVICE TO THE RATED ENTITY OR ITS RELATED THIRD PARTIES. DETAILS OF THIS SERVICE FOR RATINGS FOR WHICH THE LEAD ANALYST IS BASED IN AN EU-REGISTERED ENTITY CAN BE FOUND ON THE ENTITY SUMMARY PAGE FOR THIS ISSUER ON THE FITCH WEBSITE.

FinanceInvestment & Company InformationFitch Ratings Contact:

Fitch Ratings

Primary Analyst

Jeffrey Prackup

Director

+1 212-908-0839

Fitch Ratings, Inc.

33 Whitehall Street

New York, NY 10004

or

Secondary Analyst

Paul Jiang

Analyst

+1 212-908-9120

or

Committee Chairperson

Tracy Wan

Senior Director

+1 212-908-9171

or

Media Relations:

Sandro Scenga, +1 212-908-0278

sandro.scenga@fitchratings.com […]

Fitch to Rate Navient Student Loan Trust 2015-1; Presale Issued

NEW YORK–(BUSINESS WIRE)–

Fitch Ratings expects to rate Navient Student Loan Trust 2015-1 as follows:

–$257,400,000 class A-1 notes ‘AAAsf(exp)’; Outlook Stable;

–$472,600,000 class A-2 notes ‘AAAsf(exp)’; Outlook Stable;

–$20,000,000 class B notes ‘A+sf(exp)’; Outlook Stable.

Key Rating Drivers

High Collateral Quality: The trust collateral consists of Federal Family Education Loan Program (FFELP) loans, including approximately 15.1% of rehab loans, with guaranties provided by eligible guarantors and reinsurance provided by the U.S. Department of Education (ED) for at least 97% of principal and accrued interest. Fitch currently rates the U.S. at ‘AAA’/Stable Outlook.

Sufficient Credit Enhancement: Cash flow scenarios for the class A and B notes were satisfactory under Fitch’s ‘AAAsf’ and ‘A+sf’ stresses, respectively. Credit enhancement (CE) is provided by overcollateralization (OC), excess spread and, for the class A notes, approximately 2.67% of subordination provided by the class B notes. A target OC amount equal to the greater of 1.50% of the adjusted pool balance and $3 million must be met before excess cash can be released.

Adequate Liquidity Support: Liquidity support is provided by a reserve account sized at 1.65% of the initial student loan balance which is funded at closing. The required reserve account balance for any distribution dates prior to May 25, 2016 (the step-down date) is 1.65% of the current student loan balance. Thereafter, the requirement will be the greater of 0.25% of the current student loan balance and 0.10% of the initial student loan balance.

Acceptable Servicing Capabilities: Navient Solutions, Inc. (formerly known as Sallie Mae, Inc.) will service 100% of the trust’s student loan pool. In Fitch’s opinion, Navient Solutions, Inc. is an acceptable servicer of FFELP student loans.

RATING SENSITIVITIES

Since FFELP student loan ABS rely on the U.S. government to reimburse defaults, ‘AAAsf’ FFELP ABS ratings will likely move in tandem with the ‘AAA’ U.S. sovereign rating. Aside from the U.S. sovereign rating, defaults and basis risk account for the majority of the risk embedded in FFELP student loan transactions. Additional defaults and basis shock beyond Fitch’s published stresses could result in future downgrades. Likewise, a buildup of CE driven by positive excess spread given favorable basis factor conditions could lead to future upgrades.

Key Rating Drivers and Rating Sensitivities are further described in the pre-sale report titled ‘Navient Student Loan Trust 2015-1’, and for a further discussion on the representations, warranties, and enforcement mechanisms available to investors in this transaction, please see the related presale appendix, dated Feb. 12, 2015, available on www.fitchratings.com, or by clicking on the link.

Additional information is available at ‘www.fitchratings.com‘.

Applicable Criteria and Related Research:

–‘Global Structured Finance Rating Criteria’ (August, 2014);

–‘Rating U.S. Federal Family Education Loan Program Student Loan ABS Criteria’ (June, 2014).

–‘Representations, Warranties, and Enforcement Mechanisms in Global Structured Finance Transactions’ (October, 2014).

Applicable Criteria and Related Research: Navient Student Loan Trust 2015-1 (US ABS)

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=861944

Representations, Warranties and Enforcement Mechanisms in Global Structured Finance Transactions

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=799248

Rating U.S. Federal Family Education Loan Program Student Loan ABS Criteria

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=750530

Global Structured Finance Rating Criteria

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=754389

Additional Disclosure

Solicitation Status

http://www.fitchratings.com/gws/en/disclosure/solicitation?pr_id=979603

ALL FITCH CREDIT RATINGS ARE SUBJECT TO CERTAIN LIMITATIONS AND DISCLAIMERS. PLEASE READ THESE LIMITATIONS AND DISCLAIMERS BY FOLLOWING THIS LINK: HTTP://FITCHRATINGS.COM/UNDERSTANDINGCREDITRATINGS. IN ADDITION, RATING DEFINITIONS AND THE TERMS OF USE OF SUCH RATINGS ARE AVAILABLE ON THE AGENCY’S PUBLIC WEBSITE ‘WWW.FITCHRATINGS.COM‘. PUBLISHED RATINGS, CRITERIA AND METHODOLOGIES ARE AVAILABLE FROM THIS SITE AT ALL TIMES. FITCH’S CODE OF CONDUCT, CONFIDENTIALITY, CONFLICTS OF INTEREST, AFFILIATE FIREWALL, COMPLIANCE AND OTHER RELEVANT POLICIES AND PROCEDURES ARE ALSO AVAILABLE FROM THE ‘CODE OF CONDUCT’ SECTION OF THIS SITE. FITCH MAY HAVE PROVIDED ANOTHER PERMISSIBLE SERVICE TO THE RATED ENTITY OR ITS RELATED THIRD PARTIES. DETAILS OF THIS SERVICE FOR RATINGS FOR WHICH THE LEAD ANALYST IS BASED IN AN EU-REGISTERED ENTITY CAN BE FOUND ON THE ENTITY SUMMARY PAGE FOR THIS ISSUER ON THE FITCH WEBSITE.

Security Upgrades & DowngradesFinanceFitch Ratingsstudent loan Contact:

Fitch Ratings

Primary Analyst

Nicole Edwards

Director

+1-212-908-9114

Fitch Ratings, Inc.

33 Whitehall Street

New York, NY 10004

or

Secondary Analyst

Victoria Ohorodnyk

Director

+1-212-908-0866

or

Committee Chairperson

Tracy Wan

Senior Director

+1-212-908-9171

or

Media Relations:

Sandro Scenga, New York, +1 212-908-0278

Email:

sandro.scenga@fitchratings.com […]

Payday Loan Rules from CFPB Receiving Increased Chatter; Could …

Image payday-loan-cash-advance.jpg


Payday Loan Rules from CFPB Receiving Increased Chatter; Could be Announced Soon


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February 9, 2015http://www.insidearm.com/daily/collection-laws-regulations/collection-laws-and-regulations/payday-loan-rules-from-cfpb-receiving-increased-chatter-could-be-announced-soon/

The media chatter regarding the CFPB’s imminent rules for payday lenders was significantly ramped up early Monday as both The New York Times and the Associated Press ran separate but similar stories detailing what is likely to be in the rules.

Advertisement

The timing of the two stories suggests that both outlets received information from the same sources with the CFPB and from consumer advocacy groups working with federal rules writers. It could signal that an announcement on the rules proposals is imminent.

The Times, in a piece titled “Consumer Protection Agency Seeks Limits on Payday Lenders,” details what those familiar with the discussion will likely be presented to the public. The new rules will focus on short-term loans, many backed by car titles, with annual interest rates over 36 percent.

One of the main new requirements will be that lenders assess whether a borrower can fully repay the loan over two weeks, the typical term for payday loans. Loan writers would be required to review borrower income, other debts, and payment history, similar to standards required by banks.

The Associated Press, in a similar piece titled “Rules readied to shield borrowers from payday loans,” noted that the CFPB is not allowed under law to cap interest rates, but it can use its UDAAP authority to target specific practices.

Similar to the Times piece, AP’s sources say that loan underwriting requirements will be featured in new rules.

The CFPB’s rules on payday lending are very important for the ARM industry. Payday loans are a large market segment for debt buyers and collectors. But it could also signal what kind of disruption is to be expected when the CFPB issues its rules specifically for the debt collection industry.

Debt collection rules, initially expected by the end of 2014, are now expected to be released late in the first quarter of 2015. It could be possible that the recent surge in news about payday lending rules may mean that those rule proposals will come before debt collection rules.

Depending on how far the CFPB rules use UDAAP justification versus statutory language, the ARM industry could also get a glimpse into how far away from the FDCPA new regulations may go.


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Posted in CFPB, Collection Laws and Regulations, Credit Grantors, Featured Post .

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[…]

Fitch Affirms SLM Student Loan Trust 2012-2 Notes

NEW YORK–(BUSINESS WIRE)–

Fitch Ratings affirms the ‘AAAsf’ rating on the senior notes and affirms the subordinate notes at ‘AAsf’ issued by SLM Student Loan Trust 2012-2. The Rating Outlook remains Stable for the senior and subordinate notes. A detailed list of rating actions follows at the end of this press release.

KEY RATING DRIVERS

High Collateral Quality:

The collateral consists of 100% of Federal Family Education Loan Program (FFELP) loans. The credit quality of the trust collateral is high, in Fitch’s opinion, based on the guarantees provided by the transaction’s eligible guarantors and reinsurance provided by the U.S. Department of Education (ED) for at least 97% of principal and accrued interest. Fitch currently rates the U.S. sovereign at “AAA”, outlook stable.

Sufficient Credit Enhancement (CE):

While both the senior and subordinate notes will benefit from overcollateralization (OC; the excess of trust’s asset balance over bond balance) and excess spread, the senior notes also benefit from subordination provided by the class B notes. As of December 2014, total parity is 101.27% (1.25% CE) and senior parity is 105.91% (5.58% CE). Cash is being released from the trust given that the specified OC amount, which is equal to the greater of 1.25 % of the adjusted pool balance and $2,000,000 has been maintained.

Adequate Liquidity Support:

Liquidity support is provided by a debt service reserve fund sized at the greater of 0.25% of the pool balance and $821,986.

Acceptable Servicing Capabilities:

Navient, formerly Sallie Mae, Inc., is responsible for day-to-day servicing of the trust. Fitch believes Navient is an acceptable servicer of FFELP student loans.

RATING SENSITIVITIES

Since FFELP student loan ABS rely on the U.S. government to reimburse defaults, ‘AAAsf’ FFELP ABS ratings will likely move in tandem with the ‘AAA’ U.S. sovereign rating. Aside from the U.S. sovereign rating, defaults and basis risk account for the majority of the risk embedded in FFELP student loan transactions. Additional defaults and basis shock beyond Fitch’s published stresses could result in future downgrades. Likewise, a buildup of CE driven by positive excess spread given favorable basis factor conditions could lead to future upgrades.

Initial Key Rating Drivers and Rating Sensitivity are further described in the Presale report published on Feb. 29, 2012.

Fitch has affirmed the following:

SLM Student Loan Trust 2012-2:

–Class A notes at ‘AAAsf’; Outlook Stable;

–Class B notes at ‘AAsf’; Outlook Stable.

A comparison of the transaction’s RW&Es to those of typical RW&Es for student loans is available by accessing the reports and links below.

Additional information is available at ‘www.fitchratings.com‘.

Applicable Criteria and Related Research:

–‘Global Structured Finance Rating Criteria’ dated August 2014;

–‘Rating U.S. Federal Family Education Loan Program Student Loan ABS Criteria’ dated June 2014

–‘SLM Student Loan Trust 2012-1 – Appendix’, dated Feb. 29, 2012;

–‘Representations, Warranties, and Enforcement Mechanisms in Global Structured Finance Transactions — Amended’, dated April 17, 2012.

Applicable Criteria and Related Research:

Representations, Warranties and Enforcement Mechanisms in Global Structured Finance Transactions

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=799248

Global Structured Finance Rating Criteria

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=754389

Rating U.S. Federal Family Education Loan Program Student Loan ABS Criteria

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=750530

Additional Disclosure

Solicitation Status

http://www.fitchratings.com/gws/en/disclosure/solicitation?pr_id=979352

ALL FITCH CREDIT RATINGS ARE SUBJECT TO CERTAIN LIMITATIONS AND DISCLAIMERS. PLEASE READ THESE LIMITATIONS AND DISCLAIMERS BY FOLLOWING THIS LINK: HTTP://FITCHRATINGS.COM/UNDERSTANDINGCREDITRATINGS. IN ADDITION, RATING DEFINITIONS AND THE TERMS OF USE OF SUCH RATINGS ARE AVAILABLE ON THE AGENCY’S PUBLIC WEBSITE ‘WWW.FITCHRATINGS.COM‘. PUBLISHED RATINGS, CRITERIA AND METHODOLOGIES ARE AVAILABLE FROM THIS SITE AT ALL TIMES. FITCH’S CODE OF CONDUCT, CONFIDENTIALITY, CONFLICTS OF INTEREST, AFFILIATE FIREWALL, COMPLIANCE AND OTHER RELEVANT POLICIES AND PROCEDURES ARE ALSO AVAILABLE FROM THE ‘CODE OF CONDUCT’ SECTION OF THIS SITE. FITCH MAY HAVE PROVIDED ANOTHER PERMISSIBLE SERVICE TO THE RATED ENTITY OR ITS RELATED THIRD PARTIES. DETAILS OF THIS SERVICE FOR RATINGS FOR WHICH THE LEAD ANALYST IS BASED IN AN EU-REGISTERED ENTITY CAN BE FOUND ON THE ENTITY SUMMARY PAGE FOR THIS ISSUER ON THE FITCH WEBSITE.

Security Upgrades & DowngradesFinanceFitch Ratings Contact:

Fitch Ratings

Primary Analyst

Jeffrey Prackup

Director

+1-212-908-0839

Fitch Ratings. Inc.

33 Whitehall Street

New York, NY 10004

or

Committee Chairperson

Tracy Wan

Senior Director

+1-212-908-9171

or

Media Relations

Sandro Scenga, +1 212-908-0278

sandro.scenga@fitchratings.com […]

Fitch Affirms Halycon Loan Advisors Funding 2014-1 Ltd./LLC

NEW YORK–(BUSINESS WIRE)–

Fitch Ratings has affirmed the class X, A-1, A-2 notes and the class A loans issued by Halycon Loan Advisors Funding 2014-1 Ltd./LLC (Halcyon 2014-1) at ‘AAAsf’. The Rating Outlook remains Stable.

KEY RATING DRIVERS

The affirmation is based on the stable performance of the underlying portfolio since the transaction’s inception in March 2014 and the credit enhancement available to the notes. As of the Jan. 5, 2015 trustee report, the transaction continues to pass all of its coverage tests and collateral quality tests, and there have been no defaults in the underlying portfolio to date.

The loan portfolio par amount plus principal cash is approximately $402.4 million, compared to the effective date target par balance of $400 million, resulting in an increase in credit enhancement levels for the notes and the class A loans. The weighted average rating has remained in the ‘B/B-‘ range, and Fitch currently considers 3.1% of the portfolio (including unsettled trades) to be rated in the ‘CCC’ category versus 7.5% in the indicative portfolio at closing, based upon Fitch’s Issuer Default Rating (IDR) Equivalency Map. The weighted average spread (WAS) has increased to 5.7% from 5.1% at closing, relative to the trigger level of 4.4%. The weighted average life (WAL) is 5.0 years, which is below the trigger level of 7.2 years. The portfolio (including unsettled trades) is invested in approximately 96.1% senior secured loans and 3.9% second lien loans. In addition, approximately 91.9% of the portfolio has strong recovery prospects or a Fitch-assigned Recovery Rating of ‘RR2’ or higher.

The Stable Outlooks reflect the expectation that the class X, A-1, and A-2 notes and class A loans have a sufficient level of credit protection to withstand potential deterioration in the credit quality of the portfolio, based on the results of the Fitch sensitivity analysis described below.

RATING SENSITIVITIES

The ratings of the notes may be sensitive to the following: asset defaults, portfolio migration, including assets being downgraded to ‘CCC’, portions of the portfolio being placed on Rating Watch Negative, overcollateralization (OC) or interest coverage (IC) test breaches, or breach of concentration limitations or portfolio quality covenants. Fitch conducted rating sensitivity analysis on the closing date of Halcyon 2014-1, incorporating increased levels of defaults and reduced levels of recovery rates, among other sensitivities.

Halcyon 2014-1 is an arbitrage, cash flow collateralized loan obligation (CLO) managed by Halcyon Loan Advisors 2014-1 LLC (a wholly owned subsidiary of Halcyon Loan Management, LLC). The transaction remains in its reinvestment period, which is scheduled to end in April 2018. During the reinvestment period discretionary sales within a 12-month period are limited to 25% of the portfolio balance, as measured by the balance at the beginning of the preceding 12-month period. Sales of defaulted, credit-risk and credit-improved securities are permitted at any time, including after the reinvestment period, with the sale of credit-improved assets subject to certain restrictions. The manager also has the ability to reinvest unscheduled principal proceeds and sales proceeds from the disposal of credit risk assets after the reinvestment period, subject to certain conditions.

The class A loans were issued at close and include a conversion option to be converted into class A-2 notes. Once the option is exercised, the aggregate outstanding amount of the class A-2 notes will be increased by the outstanding principal amount of the class A loans and the class A loans shall cease to be outstanding. The conversion option may be exercised only once and no class A-2 notes may be converted into class A loans. The class A-2 notes continue to have a zero balance.

This review was conducted under the framework described in the report ‘Global Rating Criteria for Corporate CDOs’ using the Portfolio Credit Model (PCM) for projecting future default and recovery levels for the underlying portfolio. Given the stable performance of the deal since closing, no updated cash flow modeling was completed. The current portfolio’s ‘AAAsf’ Rating Default Rate (RDR) and Rating Recovery Rate (RRR) outputs from PCM are 53.1% and 38.8%, respectively, versus an RDR of 53.6% and RRR of 38.6% for the indicative portfolio at closing.

Initial Key Rating Drivers and Rating Sensitivity are further described in the New Issue Report published on Aug. 6, 2014. A comparison of the transaction’s Representations, Warranties, and Enforcement Mechanisms (RW&Es) to those of typical RW&Es for that asset class is also available by accessing the reports and links indicated below.

Fitch has affirmed the following ratings:

–$1,575,000 class X notes ‘AAAsf’; Outlook Stable;

–$199,000,000 class A-1 notes ‘AAAsf’; Outlook Stable,

–$0 class A-2 notes ‘AAAsf’; Outlook Stable;

–$50,000,000 class A loans ‘AAAsf’; Outlook Stable.

Fitch does not rate the class B-1, B-2, C, D, E, F or subordinated notes.

Additional information is available at ‘www.fitchratings.com‘.

The information used to assess these ratings was sourced from periodic servicer reports, note valuation reports, and the public domain.

Applicable Criteria & Related Research:

–‘Global Structured Finance Rating Criteria’ (Aug. 4, 2014);

–‘Global Rating Criteria for Corporate CDOs’ (July 25, 2014);

–‘Counterparty Criteria for Structured Finance and Covered Bonds’ (May 14, 2014);

–‘Halcyon Loan Advisors Funding 2014-1 Ltd./LLC New Issue Report’ (Aug. 6, 2014)

–‘Halcyon Loan Advisors Funding 2014-1 Ltd./LLC – Appendix’ (Aug. 6, 2014).

Applicable Criteria and Related Research:

Global Structured Finance Rating Criteria

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=754389

Global Rating Criteria for Corporate CDOs

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=753057

Counterparty Criteria for Structured Finance and Covered Bonds

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=744158

Halcyon Loan Advisors Funding 2014-1 Ltd./LLC

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=751434

Halcyon Loan Advisors Funding 2014-1 Ltd./LLC — Appendix

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=753097

Additional Disclosure

Solicitation Status

http://www.fitchratings.com/gws/en/disclosure/solicitation?pr_id=979255

ALL FITCH CREDIT RATINGS ARE SUBJECT TO CERTAIN LIMITATIONS AND DISCLAIMERS. PLEASE READ THESE LIMITATIONS AND DISCLAIMERS BY FOLLOWING THIS LINK: HTTP://FITCHRATINGS.COM/UNDERSTANDINGCREDITRATINGS. IN ADDITION, RATING DEFINITIONS AND THE TERMS OF USE OF SUCH RATINGS ARE AVAILABLE ON THE AGENCY’S PUBLIC WEBSITE ‘WWW.FITCHRATINGS.COM‘. PUBLISHED RATINGS, CRITERIA AND METHODOLOGIES ARE AVAILABLE FROM THIS SITE AT ALL TIMES. FITCH’S CODE OF CONDUCT, CONFIDENTIALITY, CONFLICTS OF INTEREST, AFFILIATE FIREWALL, COMPLIANCE AND OTHER RELEVANT POLICIES AND PROCEDURES ARE ALSO AVAILABLE FROM THE ‘CODE OF CONDUCT’ SECTION OF THIS SITE. FITCH MAY HAVE PROVIDED ANOTHER PERMISSIBLE SERVICE TO THE RATED ENTITY OR ITS RELATED THIRD PARTIES. DETAILS OF THIS SERVICE FOR RATINGS FOR WHICH THE LEAD ANALYST IS BASED IN AN EU-REGISTERED ENTITY CAN BE FOUND ON THE ENTITY SUMMARY PAGE FOR THIS ISSUER ON THE FITCH WEBSITE.

Security Upgrades & DowngradesFinanceFitch Ratings Contact:

Fitch Ratings

Primary Surveillance Analyst:

Christine Choo, +1-212-908-0603

Director

Fitch Ratings, Inc.

33 Whitehall Street

New York, NY 10004

or

Committee Chairperson:

Alina Pak, CFA, +1-312-368-3184

Senior Director

or

Media Relations:

Sandro Scenga, New York, +1-212-908-0278

sandro.scenga@fitchratings.com […]

Fitch Affirms Nelnet Student Loan Trust 2006-3 Notes

NEW YORK–(BUSINESS WIRE)–

Fitch Ratings has affirmed the Nelnet Student Loan Trust 2006-3 senior and subordinate notes at ‘AAAsf’ and ‘A+sf’, respectively. The Rating Outlook remains Stable.

KEY RATING DRIVERS

High Collateral Quality: The trust collateral comprises Federal Family Education Loan Program (FFELP) loans with guaranties provided by eligible guarantors and reinsurance provided by the U.S. Department of Education (ED) for at least 97% of principal and accrued interest. Fitch’s current U.S. sovereign rating is ‘AAA’ with a Stable Outlook.

Credit Enhancement: Credit Enhancement is provided by overcollateralization, excess spread, and for the class A notes, subordination provided by the class B notes. As of November 2014, the senior and total parities are 105.15% and 100.41%, respectively. Excess cash will continue to be released from the trust as long as the overcollateralization level is maintained.

Adequate Liquidity Support: Liquidity support is provided by a reserve account, determined as the greater of 0.25% of the pool balance and $3,294,279.

Acceptable Servicing Capabilities: Nelnet Inc. as the servicer is responsible for the day-to-day servicing of this trust. In Fitch’s opinion, Nelnet is an acceptable servicer of FFELP student loans.

RATING SENSITIVITIES

Since the FFELP student loan ABS relies on the U.S. government to reimburse defaults, ‘AAAsf’ FFELP ABS ratings will likely move in tandem with the ‘AAA’ U.S. sovereign rating. Aside from the U.S. sovereign rating, defaults and basis risk account for the majority of the risk embedded in FFELP student loan transactions. Additional defaults and basis shock beyond Fitch’s published stresses could result in future downgrades. Likewise, a buildup of CE driven by positive excess spread given favorable basis factor conditions could lead to future upgrades.

Fitch has affirmed the following ratings:

Nelnet Student Loan Trust 2006-3:

–Class A-4 at ‘AAAsf’; Outlook Stable;

–Class A-5 at ‘AAAsf’; Outlook Stable;

–Class A-6 at ‘AAAsf’; Outlook Stable;

–Class B at ‘A+sf’; Outlook Stable.

Additional information is available at ‘www.fitchratings.com‘.

Applicable Criteria and Related Research:

–‘Global Structured Finance Rating Criteria’ (Aug. 4, 2014);

–‘Rating U.S. Federal Family Education Loan Program Student Loan ABS Criteria’ (June 23, 2014).

Applicable Criteria and Related Research:

Rating U.S. Federal Family Education Loan Program Student Loan ABS Criteria

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=750530

Global Structured Finance Rating Criteria

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=754389

Additional Disclosure

Solicitation Status

http://www.fitchratings.com/gws/en/disclosure/solicitation?pr_id=979254

ALL FITCH CREDIT RATINGS ARE SUBJECT TO CERTAIN LIMITATIONS AND DISCLAIMERS. PLEASE READ THESE LIMITATIONS AND DISCLAIMERS BY FOLLOWING THIS LINK: HTTP://FITCHRATINGS.COM/UNDERSTANDINGCREDITRATINGS. IN ADDITION, RATING DEFINITIONS AND THE TERMS OF USE OF SUCH RATINGS ARE AVAILABLE ON THE AGENCY’S PUBLIC WEBSITE ‘WWW.FITCHRATINGS.COM‘. PUBLISHED RATINGS, CRITERIA AND METHODOLOGIES ARE AVAILABLE FROM THIS SITE AT ALL TIMES. FITCH’S CODE OF CONDUCT, CONFIDENTIALITY, CONFLICTS OF INTEREST, AFFILIATE FIREWALL, COMPLIANCE AND OTHER RELEVANT POLICIES AND PROCEDURES ARE ALSO AVAILABLE FROM THE ‘CODE OF CONDUCT’ SECTION OF THIS SITE. FITCH MAY HAVE PROVIDED ANOTHER PERMISSIBLE SERVICE TO THE RATED ENTITY OR ITS RELATED THIRD PARTIES. DETAILS OF THIS SERVICE FOR RATINGS FOR WHICH THE LEAD ANALYST IS BASED IN AN EU-REGISTERED ENTITY CAN BE FOUND ON THE ENTITY SUMMARY PAGE FOR THIS ISSUER ON THE FITCH WEBSITE.

Security Upgrades & DowngradesFinanceFitch RatingsFFELP Contact:

Fitch Ratings

Media Relations

Sandro Scenga, New York, +1-212-908-0278

sandro.scenga@fitchratings.com

or

Primary Analyst

Harry Kohl, +1-212-908-0837

Associate Director

Fitch Ratings, Inc.

33 Whitehall Street

New York, NY 10004

or

Committee Chairperson

Tracy Wan, +1-212-908-9171

Senior Director

[…]

Fitch Affirms Kentucky Higher Education Student Loan Corp 2010 Trust

NEW YORK–(BUSINESS WIRE)–

Fitch Ratings has affirmed the class A-2 bond issued by Kentucky Higher Education Student Loan Corp 2010 Trust at ‘AAAsf’. The Rating Outlook remains Stable.

KEY RATING DRIVERS

High Collateral Quality: The trust collateral consists of 100% Federal Family Education Loan Program (FFELP) loans. The credit quality of the trust collateral is high, in Fitch’s opinion, based on the guarantees provided by the transaction’s eligible guarantors and reinsurance provided by the U.S. Department of Education (ED) for at least 97% of principal and accrued interest. The current U.S. sovereign rating is ‘AAA’ with a Stable Outlook.

Sufficient Credit Enhancement: Credit Enhancement (CE) is provided by overcollateralization (OC) and future excess spread. As of September 2014, total parity is 110% (9.09% CE). The trust is releasing cash as long as the specified OC (110% total parity) is maintained.

Adequate Liquidity Support: Liquidity support for the note is provided by a reserve account (0.25% of pool balance or $350,000).

Acceptable Servicing Capabilities: Kentucky Higher Education Student Loan Corp (KHESLC) is responsible for servicing the trust. Fitch believes KHESLC is an acceptable servicer of FFELP student loans.

RATING SENSITIVITIES

Since FFELP student loan ABS rely on the U.S. government to reimburse defaults, ‘AAAsf’ FFELP ABS ratings will likely move in tandem with the ‘AAA’ U.S. sovereign rating. Aside from the U.S. sovereign rating, defaults and basis risk account for the majority of the risk embedded in FFELP student loan transactions. Additional defaults and basis shock beyond Fitch’s published stresses could result in future downgrades. Likewise, a buildup of CE driven by positive excess spread given favorable basis factor conditions could lead to future upgrades.

Fitch has taken the following rating action:

Kentucky Higher Education Student Loan Corp 2010 Trust:

–Class A-2 affirmed at ‘AAAsf’; Outlook Stable.

Additional information is available at ‘www.fitchratings.com‘.

Applicable Criteria and Related Research:

–‘Global Structured Finance Rating Criteria’ (May 20, 2014);

–‘Rating U.S. Federal Family Education Loan Program Student Loan ABS Criteria’ (June 23, 2014);

–‘Representations, Warranties, and Enforcement Mechanisms in Global Structured Finance Transactions’ (Oct. 31, 2014).

Applicable Criteria and Related Research:

Global Structured Finance Rating Criteria

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=754389

Rating U.S. Federal Family Education Loan Program Student Loan ABS Criteria

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=750530

Representations, Warranties and Enforcement Mechanisms in Global Structured Finance Transactions

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=799248

Additional Disclosure

Solicitation Status

http://www.fitchratings.com/gws/en/disclosure/solicitation?pr_id=979160

ALL FITCH CREDIT RATINGS ARE SUBJECT TO CERTAIN LIMITATIONS AND DISCLAIMERS. PLEASE READ THESE LIMITATIONS AND DISCLAIMERS BY FOLLOWING THIS LINK: HTTP://FITCHRATINGS.COM/UNDERSTANDINGCREDITRATINGS. IN ADDITION, RATING DEFINITIONS AND THE TERMS OF USE OF SUCH RATINGS ARE AVAILABLE ON THE AGENCY’S PUBLIC WEBSITE ‘WWW.FITCHRATINGS.COM‘. PUBLISHED RATINGS, CRITERIA AND METHODOLOGIES ARE AVAILABLE FROM THIS SITE AT ALL TIMES. FITCH’S CODE OF CONDUCT, CONFIDENTIALITY, CONFLICTS OF INTEREST, AFFILIATE FIREWALL, COMPLIANCE AND OTHER RELEVANT POLICIES AND PROCEDURES ARE ALSO AVAILABLE FROM THE ‘CODE OF CONDUCT’ SECTION OF THIS SITE. FITCH MAY HAVE PROVIDED ANOTHER PERMISSIBLE SERVICE TO THE RATED ENTITY OR ITS RELATED THIRD PARTIES. DETAILS OF THIS SERVICE FOR RATINGS FOR WHICH THE LEAD ANALYST IS BASED IN AN EU-REGISTERED ENTITY CAN BE FOUND ON THE ENTITY SUMMARY PAGE FOR THIS ISSUER ON THE FITCH WEBSITE.

Security Upgrades & DowngradesFinanceFitch RatingsStudent Loan Contact:

Fitch Ratings

Primary Analyst

Paul Jiang

Analyst

+1-212-908-9120

Fitch Ratings, Inc.

33 Whitehall St.

New York, NY 10004

or

Committee Chairperson

Kevin Corrigan

Senior Director

+1-212-908-9156

or

Media Relations:

Sandro Scenga, New York, +1 212-908-0278

Email:

sandro.scenga@fitchratings.com […]