Fitch Takes Various Actions on Two SLM Student Loan Trusts

Fitch Ratings has taken the following rating actions:

SLM Student Loan Trust 2007-6 (SLM 2007-6):

--Class A-4 'AAAsf'; Rating Watch Negative maintained;

--Class A-5 'AAAsf'; Rating Watch Negative maintained;

--Class B affirmed at 'Asf; Outlook Stable.

SLM Student Loan Trust 2007-8 (SLM 2007-8):

--Class A-3 affirmed at 'AAAsf'; Outlook Stable;

--Class A-4 downgraded to 'AAsf' from 'AAAsf'; removed from Rating Watch Negative and assigned Outlook Stable;

--Class A-5 'AAAsf'; Rating Watch Negative maintained;

--Class B affirmed at 'Asf'; Outlook Stable.

The downgrade of SLM 2007-8 class A-4 is due to its failure to pass Fitch's 'AAA' maturity cash flow scenario. The SLM 2007-6 A-4 and A-5 notes and SLM 2007-8 A-5 notes are maintained on rating watch due to heightened liquidity risk if defaults rise significantly in an interest-rate up scenario. Fitch expects the watch to be resolved in three months.

KEY RATING DRIVERS

Collateral Quality: The trusts' collateral are comprised 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 'AAA' with a Stable Outlook.

Credit Enhancement (CE): CE is provided by excess spread and for the class A notes, subordination of the class B notes. As of March 2016, total and senior parity ratios are 100% and 104.20% (4.03%), respectively, for both SLM 2007-6 and SLM 2007-8. Cash will continue to be released as long as the target parity ratios of 100% are maintained.

Liquidity Support: Liquidity support is provided by reserve accounts sized at 0.25% of the pool balance, with floors of $2,250,000 and $2,257,045 for the SLM 2007-6 and SLM 2007-8 trusts, respectively.

Servicing Capabilities: Day to day servicing is provided by Navient Solutions, Inc. (formerly known as Sallie Mae, Inc.), In Fitch's opinion, Navient is an acceptable servicer of FFELP student loans.

CRITERIA VARIATIONS

For transactions in surveillance, Fitch will treat certain assets such as claims filed as short-term assets in its cash flow analysis. Given that Fitch's current criteria is silent on the treatment of such assets, this treatment is considered a criteria variation.

Under the 'Counterparty Criteria for Structured Finance and Covered Bonds', dated May 14, 2014, Fitch looks to its own ratings in analyzing counterparty risk and assessing a counterparty's creditworthiness. The definition of permitted investments for this deal allows for the possibility of using investments not rated by Fitch, which represents a criteria variation. Since the only available funds to invest in are those held in the Collection Account, and the funds can only be invested for a short duration of three months given the payment frequency of the notes, Fitch doesn't believe such variation has a measurable impact upon the ratings assigned.

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, basis risk, and loan extension risk account for the majority of the risk embedded in FFELP student loan transactions. Additional defaults, basis shock beyond Fitch's published stresses, lower than expected payment speed, and other factors 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.

DUE DILIGENCE USAGE

No third party due diligence was provided or reviewed in relation to this rating action.

Additional information is available at www.fitchratings.com.

Applicable Criteria

Counterparty Criteria for Structured Finance and Covered Bonds (pub. 18 Jul 2016)

https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=884963

Criteria for Interest Rate Stresses in Structured Finance Transactions and Covered Bonds (pub. 17 May 2016)

https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=879815

Criteria for Servicing Continuity Risk in Structured Finance (pub. 17 Dec 2015)

https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=875586

Global Structured Finance Rating Criteria (pub. 27 Jun 2016)

https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=883130

Rating U.S. Federal Family Education Loan Program Student Loan ABS Criteria (pub. 26 Jul 2016)

https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=881705

Additional Disclosures

Dodd-Frank Rating Information Disclosure Form

https://www.fitchratings.com/creditdesk/press_releases/content/ridf_frame.cfm?pr_id=1009738

Solicitation Status

https://www.fitchratings.com/gws/en/disclosure/solicitation?pr_id=1009738

Endorsement Policy

https://www.fitchratings.com/jsp/creditdesk/PolicyRegulation.faces?context=2&detail=31

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