OREANDA-NEWS. Fitch Ratings has maintained the Rating Watch on 106 tranches currently on Rating Watch Negative.

See the research attached for a full list of rating actions.

KEY RATING DRIVERS
The Rating Watch Negative actions are based on analysis conducted by Fitch that identified trusts with tranches that have heightened risk of missing legal final maturity dates. The scale of the possible rating actions on those bonds on Rating Watch Negative could vary significantly depending on remaining time to maturity, recent payment trends, issuer actions such as loan purchases, or other external factors. Absent any issuer actions, or structural or other mitigants, it is possible that 'AAA' ratings could be lowered to non-investment-grade rating categories.

In taking today's action, Fitch identified trusts with one or more individual tranches most at risk of missing their legal final maturities under various stressed rating scenarios. In an event of default scenario where a bond is not paid in full by legal final, Fitch would expect ultimate repayment of full principal and interest on all tranches after the legal final. Tripping an event of default, however, could have adverse rating implications for additional tranches. The rating implications will depend on the waterfall mechanics and voting rights and actions of investors. When an event of default occurs, it is highly likely that the class B notes will not receive timely interest, as the principal for the class A notes must be paid in full prior to the class B notes receiving interest. Therefore, Fitch will not rate subordinate notes higher than any senior notes in the same trust.

The main drivers of the heightened maturity risk are prepayments and principal repayment rates coming in more slowly than initial expectations. The decline in prepayment rates has followed the consolidation wave and a slow recovery in the job market for graduates during and after the recession. The growth of government-sponsored student loan payment plans, such as the Income Based Repayment Plan has also resulted in slower overall repayment speeds. Helping offset these declines more recently are an improving labor market, expansion of debt consolidation programs, seasoning of portfolios, and recent issuer actions to address this risk.

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 transactions under both the existing and proposed criteria.

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 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.

See the full list of affected deals in the accompanying Rating Action Report, available at www.fitchratings.com.