OREANDA-NEWS. Fitch Ratings has taken the following rating actions on SLM Student Loan Trust 2003-11 and SLM Student Loan Trust 2006-10, administered by Navient:

SLM Student Loan Trust 2003-11:
--Class A-5 affirmed at 'AAAsf'; Outlook Stable;
--Class A-6 'AAAsf' placed on Rating Watch Negative;
--Class A-7 affirmed at 'AAAsf'; Outlook Stable;
--Class B affirmed at 'Asf'; Outlook Stable.

SLM Student Loan Trust 2006-10:
--Class A-4 affirmed at 'AAAsf'; Outlook Stable;
--Class A-5A affirmed at 'AAAsf'; Outlook Stable;
--Class A-5B affirmed at 'AAAsf'; Outlook Stable;
--Class A-6 'AAAsf' placed on Rating Watch Negative;
--Class B affirmed at 'Asf'; Outlook Stable.

KEY RATING DRIVERS
Maturity Risk: The Rating Watch Negative action is based on the heightened risk of SLM 2003-11 class A-6 and SLM 2006-10 class A-6 notes missing their respective legal final maturities of Dec. 15, 2025 and March 25, 2044, which would result in an event of default. In an event of such technical default, Fitch would expect ultimate repayment of full principal and interest after the legal final maturity. The magnitude of the rating action could vary depending on remaining time to maturity, recent payment trends, issuer actions such as loan purchases, or other external factors. Absent any issuer actions, structural or other mitigants, it is possible that 'AAA' ratings could be downgraded one to two rating categories. Fitch expects to complete its review and resolve the Rating Watch status over the next three to six months.

Collateral Quality: SLM 2003-11 and SLM 2006-10 are backed by 100% 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 for the FFELP loans. The U.S. is currently rated 'AAA'; Outlook Stable.

Credit Enhancement (CE): CE is provided by excess spread, and for the class A notes, subordination of the class B notes. As of August 2015, senior and total parity ratios for SLM 2003-11 are 104.76% (4.54% CE) and 100.00%, respectively. The trusts will continue to release cash as long as the target total parity ratio of 100% (excluding the reserve account, as pool factor is below 40%) is maintained. Including the reserve account, senior and total effective parity ratios are 105.17% and 100.39%. As of September 2015, senior and total parity ratios for SLM 2006-10 are 105.06% (4.82% CE) and 100.00%, respectively. The trust will continue to release cash as long as the target total parity ratio of 100% is maintained.

Liquidity support: Liquidity support for the series 2003-11 and series 2006-10 notes is provided by reserve accounts, sized at 0.25% of the adjusted pool balance, with floors of $3,008,024 for SLM 2003-11 and $6,034,845 for SLM 2006-10. The reserve accounts for both trusts are currently equal to their respective floors.

Servicing Capabilities: Navient Solutions, Inc. (formerly known as Sallie Mae, Inc.) is the servicer of the trusts' student loan pools. In Fitch's opinion, Navient Solutions, Inc. is an acceptable servicer of FFELP student loans.

On Nov. 18, 2015, Fitch released its exposure draft which delineates revisions it plans to make to the 'Rating U.S. Federal Family Education Loan Program Student Loan ABS Criteria', dated June 23, 2014. Fitch has reviewed this transaction under both the existing and proposed criteria, which has resulted in placing the SLM 2003-11 class A-6 notes and the SLM 2006-10 class A-6 notes on Rating Watch Negative.

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 credit enhancement 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.