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

SLM Student Loan Trust 2005-3 (SLM 2005-3):

--Class A-5 affirmed at 'AAAsf'; Outlook Stable;

--Class A-5 affirmed at 'AAAsf'; Outlook Stable;

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

SLM Student Loan Trust 2005-4 (SLM 2005-4):

--Class A-3 affirmed at 'AAAsf'; removed from Rating Watch Negative and assigned Outlook Stable;

--Class A-4 affirmed at 'AAAsf'; Outlook Stable;

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

SLM Student Loan Trust 2005-5 (SLM 2005-5):

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

--Class A-4 affirmed at 'AAAsf'; removed from Rating Watch Negative and assigned Outlook Stable;

--Class A-5 affirmed at 'AAAsf'; Outlook Stable;

--Class B downgraded to 'BBBsf' from 'Asf'; Outlook Stable.

The downgrade of the SLM 2005-5 class B notes results from the notes failing Fitch's 'Asf' credit stresses with principal and interest shortfalls. The affirmations listed above result from the affirmed notes passing both the credit and maturity stresses at the commensurate rating level.

KEY RATING DRIVERS

U. S. Sovereign Risk: The trust collateral comprises Federal Family Education Loan Program (FFELP) loans 100% of which are 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. The U. S. sovereign rating is currently 'AAA'/Outlook Stable by Fitch.

Collateral Performance: For SLM 2005-3, SLM 2005-4, and SLM 2005-5, respectively, Fitch assumes 18.75%, 16%, and 15.5% base case default rates (CDRs) and 56%, 47.75%, and 46.5% default rates under the 'AAA' credit stress scenario. The claim reject rate is assumed to be 0.50% in the base case and 3% in the 'AAA' case for all three trusts. Fitch applies the standard default timing curve, with the trailing 12-month CDR and prepayment levels as assumptions for FFELP loans in its cash flow analysis. Current levels of deferment, forbearance and income-based repayment (IBR) are 4.33%, 6.27%, and 6.24%, respectively, for SLM 2005-3; 5.20%, 8.31%, and 7.16%, respectively, for SLM 2005-4; 6.11%, 9.80%, and 6.73%, respectively, for SLM 2005-5, which are used as the starting point in cash flow modelling. Subsequent declines or increases are modelled as per criteria. The borrower benefit is assumed to be approximately 0.39%, 0.28%, and 0.22% for SLM 2005-3, SLM 2005-4, and SLM 2005-5, respectively, based on information provided by the sponsor.

Basis and Interest Rate Risk: Fitch applies its standard basis and interest rate stresses to this transaction as per criteria.

Payment Structure: As of June 2016, respective total and senior parity ratios are 100% and 104.22% (4.05% credit enhancement [CE]) for SLM 2005-3; 100% and 104.68% (4.47% ) for SLM 2005-4; 100% and 105.02% (4.78% CE) for SLM 2005-5. Liquidity support is provided by reserve accounts sized at their floors of $2,260,922 for SLM 2005-3, $3,773,732 for SLM 2005-4, and $3,353,244 for SLM 2005-5. Cash will continue to be released as long as the target parity ratio of 100% for all three trusts is maintained.

Maturity Risk: Fitch's SLABS cash flow model indicates that the notes are paid in full on or prior to the legal final maturity dates under the commensurate rating scenario.

Operational 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. 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 does not 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.

USE OF THIRD-PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G-10

Form ABS Due Diligence-15E was not provided to, or reviewed by, Fitch in relation to this rating action.