OREANDA-NEWS. Fitch Ratings has taken the following rating actions:

SLM Student Loan Trust 2011-3 (SLM 2011-3):

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

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

SLM Student Loan Trust 2012-6 (SLM 2012-6):

--Class A-2 affirmed at 'AAAsf'; Outlook Stable;

--Class A-3 'AAAsf'; Rating Watch Negative maintained;

--Class B 'A+sf'; Rating Watch Negative maintained.

While under Fitch's maturity and credit base case scenarios the SLM 2012-6 class A-3 notes miss their legal final maturity date, and the class B notes suffer an interest shortfall due to default of the class A-3 notes, the Rating Watch status is maintained based on the anticipation of sponsor action, given Navient's historical commitment to the performance of its securitizations. This constitutes a criteria variation, as Fitch is not downgrading the notes to 'CCCsf' or below. Fitch expects to resolve this Rating Watch within six months either through a downgrade of the notes to low speculative grade or an affirmation resulting from sponsor action that remedies the situation.

Additionally, the trusts have entered into a revolving credit agreement with Navient by which it may borrow funds at maturity in order to pay the notes off. Because Navient has the option but not the obligation to lend to the trusts, Fitch cannot give full quantitative credit to this agreement. However, the agreement does provide qualitative comfort that Navient is committed to limiting investors' exposure to maturity risk.

KEY RATING DRIVERS

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 (CE) is provided by excess spread and for the class A notes, subordination provided by the class B notes. As of June 2016, total and senior parity ratios, respectively, are 105.82% (5.50% CE) and 111.41% (10.24% CE) for SLM 2011-3, and 101.01% (1.00% CE) and 106.77% (6.34% CE) for SLM 2012-6. The transactions will continue to release cash as long as the target overcollateralization (OC) amounts for SLM 2011-3 and SLM 2012-6, respectively, of 5.50% (with a floor of $10,000,000) and 1.00% (with a floor of $1,300,000) are maintained.

Liquidity Support: Liquidity support is provided by reserve accounts sized at $1,217,261 and $1,747,485 for the SLM 2011-3 and SLM 2012-6 trusts, respectively.

Servicing Capabilities: Day-to-day servicing is provided by Navient Solutions, Inc. (formerly known as Sallie Mae, Inc.). Fitch believes Navient to be 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 July 18, 2016, 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. Fitch doesn't believe such variation has a measurable impact upon the ratings assigned.

Applicable to SLM 2012-6 only:

Although under Fitch's maturity and credit base case scenarios the SLM 2012-6 class A-3 notes miss their legal final maturity date, and the class B notes suffer an interest shortfall due to default of the class A-3 notes, Fitch is not downgrading the notes to 'CCCsf' or below for the reasons described above, which constitutes a criteria variation.

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.