EX-99.1 2 efc21-417_ex991.htm
 
 
KPMG LLP
Suite 1500
550 South Hope Street
Los Angeles, CA 90071-2629



 

 
Independent Accountants’ Report on Applying Agreed-Upon Procedures

 
Nelnet, Inc. (the “Company”) BofA Securities, Inc.
 
(together, the “Specified Parties”)
 
Re: Nelnet Student Loan Trust 2021-B – Data File Procedures
 
We have performed the procedures described below, which were agreed to by the Specified Parties, on the specified attributes identified by the Company in an electronic data file entitled “nslt_2021_b_20210531_v2.xlsx” (the “Data File”), provided by the Company on June 8, 2021, containing certain information related to 160,276 student loans (the “Student Loans”) as of May 31, 2021 (the “Cutoff Date”), which we were informed are intended to be included as collateral in the offering by Nelnet Student Loan Trust 2021-B. The Company is responsible for the specified attributes identified by the Company in the Data File. The sufficiency of these procedures is solely the responsibility of the Specified Parties. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose.
 
Unless otherwise stated, the following definitions have been adopted in presenting our procedures and findings:
The term “compared” means compared to the information shown and found it to be in agreement, unless otherwise stated. Such compared information was deemed to be in agreement if differences were within the materiality threshold.

The term “recomputed” means recalculated and compared the result to the information shown and found it to be in agreement, unless otherwise stated. Such recomputed information was deemed to be in agreement if differences were within the materiality threshold.

The term “materiality threshold” means dollar amounts and percentages were within $1.00 and 0.1%, respectively.

The term “Nelnet Servicing System” means the Company’s servicing system.

The term “Lookup Code Mapping” means loan status descriptions and mapping provided by the Company, attached hereto as Exhibit B.

The term “Sources” means the following information provided by the Company:

Lookup Code Mapping;

Promissory Note; and,

Note Disbursements Screen, Note Detail 1 Screen, Note Detail 2 Screen, Payment History for Current Principal Balance Screen, Payment History for Loan Status and Interest Rate Screen, Repayment Schedule Screen, Servicing History Screen, BLS Main Screen, and Origination Screen within the Nelnet Servicing System.
 

We make no representation regarding the validity, enforceability, or authenticity of such Sources.
 

 
KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with
KPMG International Limited, a private English company limited by guarantee.


 

The term “Instructions” means the instructions provided by the Company pertaining to a procedure, attribute, methodology, or value, as described in Exhibit C.
 
We were instructed by the Company to perform the following agreed-upon procedures on the Student Loans in the Data File.
 
A.
We randomly selected a sample of Student Loans from the Data File, utilizing a confidence level of 95.0%, an expected error rate of 3.0%, and a maximum estimated error occurrence rate (the upper error limit) for each of the attributes not to exceed 5.0%, as instructed by the Company. The selection criteria resulted in a sample of 361 Student Loans (the “Selected Student Loans,” as listed in Exhibit A attached hereto).
 
B.
For each Selected Student Loan, we recomputed or compared the specified attributes listed below contained in the Data File to the corresponding information in the respective Sources, utilizing the Instructions, as applicable. The Specified Parties indicated that the absence of any of the specified Sources or the inability to agree the indicated information from the Data File to the Sources for each of the specified attributes, utilizing the Instructions, constituted an exception. The Sources are listed in the order of priority until such attribute was agreed.
 

Attribute
Sources / Instructions
Disbursement Year
“Act Disb Date” field on Note Disbursements Screen and Instructions
Original Principal Balance
“Orig Note Amt” field on Note Detail 2 Screen
Current Principal Balance
“CPB” field on Note Detail 2 Screen, “End CPB” field on Servicing History Screen, and principal payment amounts on Payment History for Current Principal Balance Screen, and Instructions
Loan Type
“Loan Type” field on Note Detail 2 Screen
Loan Status
“Status” and “Next Pmt Dt” fields on Note Detail 1 Screen, Servicing History Screen, “NPD” field on Payment History for Loan Status and Interest Rate Screen, Lookup Code Mapping, and Instructions
Current Status End Date
“End Dt of Stat” field on Note Detail 1 Screen, Servicing History Screen, “First Pmt Dt” and “Term” fields on Repayment Schedule Screen, and Instructions
Remaining Term
“Remaining Term” field on Note Detail 1 Screen
Interest Rate
“Interest Rate” field on Note Detail 2 Screen, “Int Rate” and “Eff Dt” fields on Payment History for Loan Status and Interest Rate Screen, and Instructions
School Code
“Original School ID” field on Servicing History Screen
State of Residence
“Address” field on BLS Main Screen
Original FICO
“Borrower – Credit Score” field, “Co-Signer – Credit Score” field, “Co-Maker – Credit Score” field on Origination Screen, and
Instructions

C.
For each Selected Student Loan, we observed the presence of a signed Promissory Note in the Sources. The Specified Parties indicated that the absence of a signed Promissory Note constituted an exception. We


 

 
2


 

 
performed no procedures to assess compliance with regard to any signatory requirements or confirm the authenticity of the signature(s). The Promissory Notes were present for all Selected Student Loans.
 
The information regarding the Selected Student Loans was found to be in agreement with the respective information contained in the Sources. Based on the results of the procedures performed, there is a 95.0% confidence level that the maximum estimated error occurrence rate for each of the attributes across the entire population of 160,276 Student Loans does not exceed 5.0%. Because we are not engaged to express a conclusion, we do not offer a conclusion based on the application of a sampling technique.
 

This agreed-upon procedures engagement was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants. We were not engaged to, and did not, conduct an examination or review, the objective of which would be the expression of an opinion or conclusion, respectively, on the specified attributes identified by the Company in the Data File. Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to the Specified Parties.
 

The procedures performed were applied based on the information contained in the Data File, Sources, and Instructions, without verification or evaluation of such information or Instructions by us; therefore, we express no opinion or any other form of assurance regarding (i) the physical existence of the Student Loans, (ii) the reasonableness of the Sources and Instructions, (iii) the reliability or accuracy of the Sources, which were used in our procedures, or (iv) matters of legal interpretation.
 

The procedures performed were not intended to address, nor did they address: (i) the conformity of the origination of the Student Loans to stated underwriting or credit extension guidelines, standards, criteria or other requirements, (ii) the value of collateral securing any such Student Loans being securitized, (iii) the compliance of the originator of the Student Loans with federal, state, and local laws and regulations, or (iv) any other factor or characteristic of the Student Loans that would be material to the likelihood that the issuer of the asset-backed security will pay interest and principal in accordance with applicable terms and conditions. The procedures performed were not intended to satisfy any criteria for due diligence published by a nationally recognized statistical rating organization (“NRSRO”).

The terms of our engagement are such that we have no obligation to update this report because of events and transactions that may subsequently occur.
 

 
This report is intended solely for the information and use of the Specified Parties. It is not intended to be and should not be used by any other person or entity, including investors or the NRSROs, who are not identified in the report as the Specified Parties but may have access to this report as required by law or regulation.
 

 
/s/ KPMG LLP
 

 
Los Angeles, California June 15, 2021












 

 
3


 
Exhibit A
 
The Selected Student Loans

 

Selected Student
Loan
Number
 
Student Loan
Number
Selected Student
Loan
Number
 
Student Loan
Number

Selected Student Loan
Number
 
Student Loan
Number
Selected Student
Loan
Number
 
Student Loan
Number
1
2021B001
51
2021B051
101
2021B101
151
2021B151
2
2021B002
52
2021B052
102
2021B102
152
2021B152
3
2021B003
53
2021B053
103
2021B103
153
2021B153
4
2021B004
54
2021B054
104
2021B104
154
2021B154
5
2021B005
55
2021B055
105
2021B105
155
2021B155
6
2021B006
56
2021B056
106
2021B106
156
2021B156
7
2021B007
57
2021B057
107
2021B107
157
2021B157
8
2021B008
58
2021B058
108
2021B108
158
2021B158
9
2021B009
59
2021B059
109
2021B109
159
2021B159
10
2021B010
60
2021B060
110
2021B110
160
2021B160
11
2021B011
61
2021B061
111
2021B111
161
2021B161
12
2021B012
62
2021B062
112
2021B112
162
2021B162
13
2021B013
63
2021B063
113
2021B113
163
2021B163
14
2021B014
64
2021B064
114
2021B114
164
2021B164
15
2021B015
65
2021B065
115
2021B115
165
2021B165
16
2021B016
66
2021B066
116
2021B116
166
2021B166
17
2021B017
67
2021B067
117
2021B117
167
2021B167
18
2021B018
68
2021B068
118
2021B118
168
2021B168
19
2021B019
69
2021B069
119
2021B119
169
2021B169
20
2021B020
70
2021B070
120
2021B120
170
2021B170
21
2021B021
71
2021B071
121
2021B121
171
2021B171
22
2021B022
72
2021B072
122
2021B122
172
2021B172
23
2021B023
73
2021B073
123
2021B123
173
2021B173
24
2021B024
74
2021B074
124
2021B124
174
2021B174
25
2021B025
75
2021B075
125
2021B125
175
2021B175
26
2021B026
76
2021B076
126
2021B126
176
2021B176
27
2021B027
77
2021B077
127
2021B127
177
2021B177
28
2021B028
78
2021B078
128
2021B128
178
2021B178
29
2021B029
79
2021B079
129
2021B129
179
2021B179
30
2021B030
80
2021B080
130
2021B130
180
2021B180
31
2021B031
81
2021B081
131
2021B131
181
2021B181
32
2021B032
82
2021B082
132
2021B132
182
2021B182
33
2021B033
83
2021B083
133
2021B133
183
2021B183
34
2021B034
84
2021B084
134
2021B134
184
2021B184
35
2021B035
85
2021B085
135
2021B135
185
2021B185
36
2021B036
86
2021B086
136
2021B136
186
2021B186
37
2021B037
87
2021B087
137
2021B137
187
2021B187
38
2021B038
88
2021B088
138
2021B138
188
2021B188
39
2021B039
89
2021B089
139
2021B139
189
2021B189
40
2021B040
90
2021B090
140
2021B140
190
2021B190
41
2021B041
91
2021B091
141
2021B141
191
2021B191
42
2021B042
92
2021B092
142
2021B142
192
2021B192
43
2021B043
93
2021B093
143
2021B143
193
2021B193
44
2021B044
94
2021B094
144
2021B144
194
2021B194
45
2021B045
95
2021B095
145
2021B145
195
2021B195
46
2021B046
96
2021B096
146
2021B146
196
2021B196
47
2021B047
97
2021B097
147
2021B147
197
2021B197
48
2021B048
98
2021B098
148
2021B148
198
2021B198
49
2021B049
99
2021B099
149
2021B149
199
2021B199
50
2021B050
100
2021B100
150
2021B150
200
2021B200

Exhibit A
The Selected Student Loans (Cont.)
 

Selected Student
Loan
Number
 Student
Loan
Number
Selected Student
Loan
Number
 
Student Loan
Number
Selected Student
Loan
Number
Student
Loan
Number
Selected Student
Loan
Number
Student
Loan
Number
201
2021B201
242
2021B242
283
2021B283
324
2021B324
202
2021B202
243
2021B243
284
2021B284
325
2021B325
203
2021B203
244
2021B244
285
2021B285
326
2021B326
204
2021B204
245
2021B245
286
2021B286
327
2021B327
205
2021B205
246
2021B246
287
2021B287
328
2021B328
206
2021B206
247
2021B247
288
2021B288
329
2021B329
207
2021B207
248
2021B248
289
2021B289
330
2021B330
208
2021B208
249
2021B249
290
2021B290
331
2021B331
209
2021B209
250
2021B250
291
2021B291
332
2021B332
210
2021B210
251
2021B251
292
2021B292
333
2021B333
211
2021B211
252
2021B252
293
2021B293
334
2021B334
212
2021B212
253
2021B253
294
2021B294
335
2021B335
213
2021B213
254
2021B254
295
2021B295
336
2021B336
214
2021B214
255
2021B255
296
2021B296
337
2021B337
215
2021B215
256
2021B256
297
2021B297
338
2021B338
216
2021B216
257
2021B257
298
2021B298
339
2021B339
217
2021B217
258
2021B258
299
2021B299
340
2021B340
218
2021B218
259
2021B259
300
2021B300
341
2021B341
219
2021B219
260
2021B260
301
2021B301
342
2021B342
220
2021B220
261
2021B261
302
2021B302
343
2021B343
221
2021B221
262
2021B262
303
2021B303
344
2021B344
222
2021B222
263
2021B263
304
2021B304
345
2021B345
223
2021B223
264
2021B264
305
2021B305
346
2021B346
224
2021B224
265
2021B265
306
2021B306
347
2021B347
225
2021B225
266
2021B266
307
2021B307
348
2021B348
226
2021B226
267
2021B267
308
2021B308
349
2021B349
227
2021B227
268
2021B268
309
2021B309
350
2021B350
228
2021B228
269
2021B269
310
2021B310
351
2021B351
229
2021B229
270
2021B270
311
2021B311
352
2021B352
230
2021B230
271
2021B271
312
2021B312
353
2021B353
231
2021B231
272
2021B272
313
2021B313
354
2021B354
232
2021B232
273
2021B273
314
2021B314
355
2021B355
233
2021B233
274
2021B274
315
2021B315
356
2021B356
234
2021B234
275
2021B275
316
2021B316
357
2021B357
235
2021B235
276
2021B276
317
2021B317
358
2021B358
236
2021B236
277
2021B277
318
2021B318
359
2021B359
237
2021B237
278
2021B278
319
2021B319
360
2021B360
238
2021B238
279
2021B279
320
2021B320
361
2021B361
239
2021B239
280
2021B280
321
2021B321
   
240
2021B240
281
2021B281
322
2021B322
   
241
2021B241
282
2021B282
323
2021B323
   


 
Note: The Company has assigned a unique Loan ID number to each Student Loan in the Data File. The Student Loan Numbers referred to in this Exhibit are not the Loan ID numbers.

Lookup Code Mapping
 

Loan Status per Sources
Loan Status per Data File
Repayment, Loan Mod, Military Repay
Repayment Current
School, Military School
In-School
Disaster Forb
Forbearance
Deferment
Deferment
Grace
Grace


 
Instructions
 

Attribute
Instructions
Disbursement Year
Compare the “Orig_Vint_Date” field in the Data File to the earliest “Act Disb Date” field on Note Disbursements Screen.
Current Principal Balance
Compare the “Ln_Cur_Bal” field in the Data File to the “CPB” field on Note Detail 2 Screen. In the event the “CPB” field on the Note Detail 2 Screen did not agree with the “Ln_Cur_Bal” field in the Data File, compare the ”End CPB” field as of the Cutoff Date listed on the Servicing History Screen. In the event the ”End CPB” field as of the Cutoff Date listed on the Servicing History Screen did not agree with the “Ln_Cur_Bal” field in the Data File, compare the sum of the “CPB” field and all principal payment amounts on Payment History for Current Principal Balance Screen for which the “Prcs Dt” is after the Cutoff Date to the “Ln_Cur_Bal” field in the Data File.
Loan Status
Compare the “Status” field in the Data File to the “Status” field on the Note Detail 1 Screen based on the Lookup Code Mapping. In the event the “Status” field on the Note Detail 1 Screen did not agree with the “Status” field in the Data File, compare the Loan Status as of the Cutoff Date listed on the Servicing History Screen. In the event the Loan Status as of the Cutoff Date listed on the Servicing History Screen did not agree with the “Status” field in the Data File, perform the following procedures:
 
 
a) If the “Status” field in the Note Detail 1 Screen was “Loan Mod” and the “Next Pmt Dt” field on the Note Detail 1 Screen was prior to the Cutoff Date, we were instructed to consider the Loan Status to be Repay_Delinquent.
 
b) If the “Status” field in the Note Detail 1 Screen was “Repayment,” and the “Next Pmt Dt” on Note Detail 1 Screen or “NPD” field on Payment History for Loan Status and Interest Rate Screen was prior to the Cutoff Date, we were instructed to consider the Loan Status to be Repay_Delinquent.
Current Status End Date
 
a) If the Loan Status of the Selected Student Loan was Repayment Current or Repay_Delinquent, compare the “Curr_Maturity_Date” field in the Data File to the sum of the “First Pmt Dt” field and months in the “Term” field on the Repayment Schedule Screen or to the Current Status End Date as of the Cutoff Date listed on the Servicing History Screen.
 
b) If the Loan Status of the Selected Student Loan was In-School, compare the date one day prior to the “Grace_Begin_Date” field in the Data File to the “End Dt of Stat” field on Note Detail 1 Screen or to the Current Status End Date as of the Cutoff Date listed on the Servicing History Screen.
 
 
c) If the Loan Status of the Selected Student Loan was Grace, compare the “Grace_End_DT” field in the Data File to the “End Dt of Stat” field on Note Detail 1 Screen or to the Current Status End Date as of the Cutoff Date listed on the Servicing History Screen.
 
d) If the Loan Status of the Selected Student Loan was Deferment or Forbearance, compare the “Active_Df_En_Date” field in the Data File to the “End Dt of Stat” field


 

Attribute
Instructions
 
on the Note Detail 1 Screen or to the Current Status End Date as of the Cutoff Date listed on the Servicing History Screen.
Interest Rate
Compare the “Drvd_Ln_Rate” field in the Data File to the “Interest Rate” field on the Note Detail 2 Screen. In the event the “Interest Rate” field on Note Detail 2 Screen did not agree with the “Drvd_Ln_Rate” field in the Data File, compare “Int Rate” field which corresponding “Eff Dt” field was Cutoff Date on Payment History for Loan Status and Interest Rate Screen to the “Drvd_Ln_Rate” field in the Data File.
Original FICO
 
a) Compare the “Borr_Fico” field in the Data File to the “Borrower – Credit Score” field on the Origination Screen. If the “Borr_Fico” field in the Data File did not agree with the “Borrower – Credit Score” field on the Origination Screen, compare the “Cos1_Fico” field in the Data File to the “Co-Signer – Credit Score” field on the Origination Screen. If the “Cos1_Fico” field in the Data File did not agree with the “Co-Signer – Credit Score” field on the Origination Screen, compare the “Cos2_Fico” field in the Data File with the “Co-Maker – Credit Score” field on the Origination Screen.
 
b) If the “Cos2_Fico” field in the Data File was blank, consider the field to be equal to zero.
 
c) Do not consider an Original FICO value of zero to be an exception.