0001140361-24-016080.txt : 20240328 0001140361-24-016080.hdr.sgml : 20240328 20240328151809 ACCESSION NUMBER: 0001140361-24-016080 CONFORMED SUBMISSION TYPE: 10-K PUBLIC DOCUMENT COUNT: 9 CONFORMED PERIOD OF REPORT: 20231231 0000949114 0001601725 FILED AS OF DATE: 20240328 DATE AS OF CHANGE: 20240328 ABS ASSET CLASS: Student loans FILER: COMPANY DATA: COMPANY CONFORMED NAME: SLM Student Loan Trust 2013-1 CENTRAL INDEX KEY: 0001565531 STANDARD INDUSTRIAL CLASSIFICATION: ASSET-BACKED SECURITIES [6189] ORGANIZATION NAME: Office of Structured Finance IRS NUMBER: 043480392 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: 10-K SEC ACT: 1934 Act SEC FILE NUMBER: 333-166301-11 FILM NUMBER: 24798239 BUSINESS ADDRESS: STREET 1: 13865 SUNRISE VALLEY DRIVE CITY: HERNDON STATE: VA ZIP: 20171 BUSINESS PHONE: 703-984-6578 MAIL ADDRESS: STREET 1: 13865 SUNRISE VALLEY DRIVE CITY: HERNDON STATE: VA ZIP: 20171 10-K 1 ef20023719_10k.htm 10-K
ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(D)

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, DC 20549



FORM 10-K

(Mark One)

Annual report pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934

For the fiscal year ended December 31, 2023 or

Transition report pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934

For the transition period from                     to__________

Commission File Number of issuing entity: 333-166301-11

Central Index Key of issuing entity: 0001565531

SLM STUDENT LOAN TRUST 2013-1
(Exact name of issuing entity as specified in its charter)

Commission File Number of depositor: 333-166301

Central Index Key of depositor: 0000949114

NAVIENT FUNDING, LLC
(Exact name of depositor as specified in its charter)

Central Index Key of sponsor: 0001601725

NAVIENT SOLUTIONS, LLC
(Exact name of sponsor as specified in its charter)

   
04-3480392
   
04-3480392
DELAWARE
 
54-1843973
 (State or other Jurisdiction of Incorporation)
 
 (I.R.S. Employer Identification Nos.)

c/o Deutsche Bank Trust Company Delaware
111 Continental Drive, Suite 102
Newark, DE 19713
(Address of principal executive offices of issuing entity)

(703) 984-6890
Registrant’s telephone number, including area code

Securities registered pursuant to Section 12(b) of the Act: None

Securities registered pursuant to Section 12(g) of the Act: None

Indicate by check mark if registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.  Yes ☐ No ☑

Indicate by check mark if registrant is not required to file reports pursuant to Section 13 or 15(d) of the Act.  Yes ☐ No ☑

Indicate by check mark whether the registrant: (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.  Yes ☑ No ☐

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulations S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).  Yes ☑ No ☐

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company, or an emerging growth company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company” and “emerging growth company” in Rule 12b-2 of the Exchange Act:

Large accelerated filer
 
Accelerated filer
Non-accelerated filer
 
Smaller reporting company
     
Emerging growth company

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Act. ☐

Indicate by check mark whether the registrant has filed a report on and attestation to its management’s assessment of the effectiveness of its internal control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or issued its audit report. ☐

If securities are registered pursuant to Section 12(b) of the Act, indicate by check mark whether the financial statements of the registrant included in the filing reflect the correction of an error to previously issued financial statements. ☐

Indicate by check mark whether any of those error corrections are restatements that required a recovery analysis of incentive-based compensation received by any of the registrant’s executive officers during the relevant recovery period pursuant to §240.10D-1(b). ☐

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Act).  Yes ☐ No ☑

State the aggregate market value of the voting and non-voting common equity held by non-affiliates computed by reference to the price at which the common equity was last sold, or the average bid and asked price of such common equity, as of the last business day of the registrant’s most recently completed second fiscal quarter.

Not applicable.



PART I

The following Items have been omitted in accordance with General Instruction J to Form 10–K:

Item 1.
Business

Item 1A.
Risk Factors

Item 1C.
Cybersecurity

Item 2.
Properties

Item 3.
Legal Proceedings

Item 1B.
Unresolved Staff Comments

Not Applicable.

Item 4.
Mine Safety Disclosures.

Not Applicable.

The following information is substitute information provided in accordance with General Instruction J to Form 10-K:

Item 1112(b) of Regulation AB. Significant Obligor Financial Information

No single obligor represents more than 10% of the pool assets held by the Issuing Entity.

Items 1114(b)(2) of Regulation AB. Credit Enhancement and Other Support, Except for Certain Derivatives

No entity or group of affiliated entities provides external credit enhancement or other support with respect to payments on the notes issued by the Issuing Entity.

Items 1115(b) of Regulation AB. Credit Derivatives Instruments

No entity or group of affiliated entities provides derivative instruments with respect to payments on the notes issued by the Issuing Entity.

Item 1117 of Regulation AB. Legal Proceedings

Other than as stated in the following paragraphs, no legal proceedings are pending against the Issuing Entity, Navient Solutions, LLC (formerly, Navient Solutions, Inc.) (“Navient Solutions”), as the Sponsor, the Servicer and the Administrator, Navient Funding, LLC, as the Depositor (the “Depositor”) and registrant under Registration Statement Number 333-190926 (the “Registrant”) or to the Registrant’s knowledge, Deutsche Bank National Trust Company, as the Indenture Trustee that are or would be material to the holders of the notes issued by the Issuing Entity, nor does the Registrant know of any such proceeding contemplated by any governmental authorities.

The following four paragraphs are disclosure received from Navient Solutions, the servicer for this transaction.

Navient Corporation (“Navient”) has been named as defendant in a number of putative class action and other cases alleging violations of various state and federal consumer protection laws including the Telephone Consumer Protection Act, the Consumer Financial Protection Act of 2010 (CFPA), the Fair Credit Reporting Act (FCRA), the Fair Debt Collection Practices Act (FDCPA), in adversarial proceedings under the United States Bankruptcy Code, and various state consumer protection laws. At this point in time, Navient is unable to anticipate the timing of a resolution or the impact that these legal proceedings may have on its consolidated financial position, liquidity, results of operation or cash flows. As a result, it is not possible at this time to estimate a range of potential exposure, if any, for amounts that may be payable in connection with these matters and loss contingency accruals have not been established. It is possible that an adverse ruling or rulings may have a material adverse impact on Navient, Navient Solutions and/or their affiliates or on the financial ability of the depositor, the servicer or a seller to fulfill an obligation to purchase or repurchase trust student loans in connection with a breach of representation, warranty or covenant.

2

In January 2017, the Consumer Financial Protection Bureau (the CFPB) and Attorneys General for the State of Illinois and the State of Washington initiated civil actions naming Navient and several of its subsidiaries (including Navient Solutions) as defendants alleging violations of certain Federal and State consumer protection statutes, including the CFPA, FCRA, FDCPA and various state consumer protection laws. The Attorneys General for the States of Pennsylvania, California, Mississippi, and New Jersey also initiated actions against Navient and certain subsidiaries alleging violations of various state and federal consumer protection laws based upon similar alleged acts or failures to act. In addition to these matters, a number of lawsuits have been filed by nongovernmental parties or, in the future, may be filed by additional governmental or nongovernmental parties seeking damages or other remedies related to similar issues raised by the CFPB and the State Attorneys General. In January 2022, Navient entered into a series of Consent Judgment and Orders (the “Agreements”) with 40 State Attorneys General to resolve all matters in dispute related to the State Attorneys General cases as well as the related investigations, subpoenas, civil investigative demands and inquiries from various other state regulators. These Agreements do not resolve the litigation involving Navient and the CFPB. Navient has cancelled the loan balance of approximately 66,000 borrowers with qualifying Private Education Loans that were originated largely between 2002 and 2010 and later defaulted and charged off. The loans cancelled have aggregate outstanding balances of approximately $1.7 billion. The expense to Navient to cancel these loans was approximately $50 million which represents the amount of expected future recoveries of these charged-off loans on the balance sheet. In addition, Navient agreed to make a one-time payment of approximately $145 million to the states. In the fourth quarter of 2021 when such loss became probable, Navient recognized total regulatory expenses of approximately $205 million related to this matter.

As Navient has previously stated, Navient believes the allegations in the CFPB suit are false and that they improperly seek to impose penalties on Navient based on new, previously unannounced servicing standards applied retroactively against only one servicer. Navient therefore has denied these allegations and is vigorously defending against the allegations in that case. Due to recent developments in connection with the CFPB case, Navient increased its accrual for probable incurred loss in this matter to $72.5 million in the fourth quarter of 2023.  The litigation process is not predictable and can lead to unexpected results and therefore it is reasonably possible that Navient’s exposure to loss may exceed any amounts accrued.

On April 12, 2023, Navient reached an agreement in principle (“Settlement”) with certain plaintiffs for a nationwide settlement of claims raised in the following bankruptcy adversary actions: Coyle v. Navient Solutions, LLC, No. 22-80018 (Bankr. W.D. Mich.); Homaidan v. SLM Corp., No. 1:17-ap-01085 (Bankr. E.D.N.Y.); Mazloom v. Navient Solutions, LLC, No. 20-80033-6 (Bankr. N.D.N.Y.); and Woodard v. Navient Solutions, LLC, No. 08-81442 (Bankr. D. Neb.) collectively referred to as the “Bankruptcy Cases.” The Settlement has received final court approval. Under the Settlement, Navient will forego the collection of defined balances for borrowers or co-borrowers of certain private loans — all of which were originated prior to Navient’s separation — who have received a discharge in bankruptcy during the periods covered by the agreements. As a result, Navient recorded a $23 million additional private loan provision for loan losses in the first quarter of 2023 related to the estimated future charge offs that are expected to occur. Navient has also agreed to fund settlement funds. Navient anticipates that any cash contribution it will be required to make to these funds will not exceed $44 million in the aggregate and will be fully covered by insurance. The net impact to operating expense for this element of the settlement for the first quarter of 2023 was $0 due to the accrual of the offsetting insurance reimbursements.

The following three paragraphs are disclosure received from Deutsche Bank National Trust Company and Deutsche Bank Trust Company Americas. Deutsche Bank National Trust Company (“DBNTC”) and Deutsche Bank Trust Company Americas (“DBTCA”) have been sued by investors in civil litigation concerning their role as trustees of certain residential mortgage-backed securities (“RMBS”) trusts.

On December 23, 2014, certain special purpose entities including Phoenix Light SF Limited that held RMBS certificates issued by 21 RMBS trusts filed a complaint in the U.S. District Court for the Southern District of New York against DBNTC as trustee of the trusts, asserting claims for violation of the TIA and the Streit Act, breach of contract, breach of fiduciary duty, negligence, gross negligence, and negligent misrepresentation, based on DBNTC’s alleged failure to perform its duties as trustee for the trusts.  On April 10, 2015, plaintiffs filed an amended complaint relating to an additional 34 trusts (for a total of 55 trusts) and amended their complaint for a second time on July 15, 2015 to include additional allegations and to drop their claim for negligent misrepresentation.  In that complaint, plaintiffs alleged damages of over U.S. $527 million.  On February 2, 2016, the court entered a stipulation signed by the parties to dismiss with prejudice claims relating to four of the 55 trusts, leaving 51 trusts at issue.  DBNTC filed a motion to dismiss.  On March 29, 2016, the court granted in part and denied in part DBNTC’s motion to dismiss.  The court allowed the majority of plaintiffs’ breach of contract claims to proceed.  The court denied DBNTC’s motion to dismiss breach of fiduciary duty claims.  The court granted the motion to dismiss to the extent that negligence claims were duplicative of breach of contract claims but denied the motion to dismiss to the extent plaintiffs alleged DBNTC violated extra-contractual duties.  In addition, the court dismissed breach of the implied covenant of good faith and fair dealing claims.  The court also denied the motion to dismiss claims for alleged violations of Sections 315(b) and 315(c) of the TIA, but dismissed claims under 316(b).  Finally, the court dismissed plaintiffs’ Streit Act claim.  Following the court’s decision on the motion to dismiss, 46 trusts remained at issue.  On May 13, 2016, DBNTC filed an answer to the amended complaint.  On December 20, 2016, the court ordered the parties’ stipulation dismissing plaintiffs’ claims relating to three trusts, leaving 43 trusts at issue.  On September 27, 2017, plaintiffs filed a third amended complaint that names DBTCA as a defendant in addition to DBNTC.  DBTCA serves as trustee for one of the 43 trusts at issue.  DBNTC serves as trustee for the other 42 trusts at issue.  Plaintiffs’ third amended complaint brings claims for violation of the TIA; breach of contract; breach of fiduciary duty; negligence and gross negligence; violation of the Streit Act; and breach of the covenant of good faith.  However, in the third amended complaint, plaintiffs acknowledge that the court previously dismissed plaintiffs’ TIA Act claims, negligence and gross negligence claims, Streit Act claims, claims for breach of the covenant of good faith, and certain theories of plaintiffs’ breach of contract claims, and plaintiffs only include these claims to preserve any rights on appeal.  Plaintiffs allege damages of “hundreds of millions of dollars.”  On November 13, 2017, DBNTC and DBTCA filed an answer to the third amended complaint.  On December 7, 2018, DBNTC and DBTCA filed a motion for summary judgment.  Also on December 7, 2018, plaintiffs, jointly with Commerzbank AG (see description of Commerzbank case below), filed a motion for partial summary judgment.  On October 27, 2021, DBNTC and DBTCA filed a supplemental motion for summary judgment relating to plaintiffs’ standing.  On February 8, 2022, the court issued an order in which it granted DBNTC and DBTCA’s supplemental motion for summary judgment, granted in part DBNTC and DBTCA’s initial motion for summary judgment, and denied plaintiffs’ motion for partial summary judgment.  As a result of that order, all of plaintiffs’ claims were dismissed with prejudice.  On April 26, 2023, the United States Court of Appeals for the Second Circuit affirmed the court’s summary judgment order.

3

On December 30, 2015, IKB International, S.A. in Liquidation and IKB Deutsche Industriebank A.G. (collectively, “IKB”), as an investor in 37 RMBS trusts, filed a summons with notice in the Supreme Court of the State of New York, New York County, against DBNTC and DBTCA as trustees of the trusts.  On May 27, 2016, IKB served its complaint asserting claims for breach of contract, breach of fiduciary duty, breach of duty to avoid conflicts of interest, violation of the Streit Act, violation of the TIA, violation of Regulation AB, and violation of Section 9 of the Uniform Commercial Code.  IKB alleges that DBNTC and DBTCA are liable for over U.S. $268 million in damages.  On October 5, 2016, DBNTC and DBTCA, together with several other trustees defending lawsuits by IKB, filed a joint motion to dismiss.  On January 6, 2017 and June 20, 2017, IKB voluntarily dismissed with prejudice all claims as to seven trusts.  On January 27, 2021, the court granted in part and denied in part DBNTC and DBTCA’s motion to dismiss.  The court granted the motion to dismiss with respect to IKB’s claims for violations of the Streit Act, Regulation AB, and Section 9 of the Uniform Commercial Code, as well as certain aspects of IKB’s claims for breach of contract, breach of fiduciary duty, and violation of the TIA.  The court denied the remainder of the motion to dismiss.  IKB’s remaining claims for breach of contract, breach of fiduciary duty, breach of duty to avoid conflicts of interest, and violation of the TIA will proceed.  On May 10, 2021, DBNTC and DBTCA filed a notice of appeal with the New York Supreme Court Appellate Division, First Department, regarding certain aspects of the court’s order on the motion to dismiss.  On May 20, 2021, IKB filed a notice of cross appeal with respect to other aspects of that order.  On August 30, 2022, the New York Supreme Court, Appellate Division, First Department affirmed in part and reversed in part the court’s order on the motion to dismiss.  After DBNTC and DBTCA appealed the First Department’s decision, on June 15, 2023, the New York Court of Appeals reversed the First Department’s decision in part, dismissing certain additional contract claims, as well as IKB’s claims for breach of fiduciary duty and breach of duty to avoid conflicts of interest.  On June 2, 2021, IKB filed a motion for re-argument regarding certain aspects of the court’s order on the motion to dismiss, which the court denied on August 3, 2021.  On May 13, 2021, DBNTC and DBTCA filed an answer to the complaint.  On October 28, 2021, the parties filed a stipulation, voluntarily dismissing with prejudice all claims as to seven additional trusts.  On December 29, 2021, the parties filed a stipulation, voluntarily dismissing with prejudice all claims as to one additional trust.  On April 22, 2022, the parties filed a stipulation, voluntarily dismissing with prejudice all claims as to 17 certificates at issue, including all claims as to 5 trusts.  On February 28, 2023, the parties filed a stipulation, voluntarily dismissing with prejudice all claims as to two trusts, leaving 15 trusts at issue.  On November 21, 2023, the parties filed a stipulation, voluntarily dismissing with prejudice all claims as to three trusts, leaving 12 trusts at issue.  Discovery is ongoing.

It is DBTCA’s and DBNTC’s belief that they have no pending legal proceedings, including, based on DBTCA’s and DBNTC’s present evaluation, the litigation disclosed in the immediately preceding two paragraphs that would materially affect their ability to perform their duties under the Indenture for this transaction.

4

PART II

The following Items have been omitted in accordance with General Instruction J to Form 10–K:

Item 5.
Market for Registrant’s Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities

Item 7.
Management’s Discussion and Analysis of Financial Condition and Results of Operation

Item 7A.
Quantitative and Qualitative Disclosures about Market Risk

Item 8.
Financial Statements and Supplementary Data

Item 9.
Changes in and Disagreements With Accountants on Accounting and Financial Disclosure

Item 9A.
Controls and Procedures

Item 9B.
Other Information

Item 9C.
Disclosure Regarding Foreign Jurisdictions that Prevent Inspections.

Not applicable.

5

PART III

The following Items have been omitted in accordance with General Instruction J to Form 10-K:

Item 10.
Directors, Executive Officers, and Corporate Governance

Item 11.
Executive Compensation

Item 12.
Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters

Item 13.
Certain Relationships, Related Transactions, and Director Independence

Item 14.
Principal Accountant Fees and Services

The following information is substitute information provided in accordance with General Instruction J to Form 10-K:

Item 1119 of Regulation AB. Affiliations and Certain Relationships and Related Transactions

Pursuant to the Instruction to Item 1119 of Regulation AB, information required by Item 1119 has been omitted from this Report because substantially the same information related to affiliates of the Issuing Entity and certain relationships and related transactions is provided in the section titled “The Sponsor, Servicer and Administrator” of the base prospectus, previously filed with the SEC on February 7, 2013 pursuant to Securities Act Rule 424, file number 333-166301.

Item 1122 of Regulation AB. Compliance with Applicable Servicing Criteria

Navient Solutions, LLC, as the Servicer, Navient Solutions, LLC, as the Administrator and Deutsche Bank National Trust Company, as the Indenture Trustee (collectively, the “Servicing Parties”) have each been identified by the Depositor as parties participating in the servicing function with respect to the asset pool held by the Issuing Entity. Each of the Servicing Parties has completed a report on assessment of compliance with the servicing criteria applicable to it (each a “Servicing Report”), which Servicing Reports are attached as exhibits to this Form 10-K. Each of the Servicing Parties have provided an attestation report (each an “Attestation Report”) by one or more public accounting firms, which reports are also attached as exhibits to this Report. None of the Servicing Reports or Attestation Reports has identified any material instance of noncompliance with the servicing criteria as applicable to the respective Servicing Party. There have been no material instances of noncompliance with the servicing criteria for the period of this Report.

Item 1123 of Regulation AB. Servicer Compliance Statement

A Servicer Compliance Statement for each of Navient Solutions, LLC, as Servicer, and Navient Solutions, LLC, as Administrator, is included as an exhibit to this Report.

6

PART IV

Item 15.
Exhibit  and Financial Statement Schedules

  (a)
List of Documents Filed as Part of this Annual Report on Form 10-K

  (1)
Not applicable.


(2)
Not applicable.


(3)
See Item 15 (b) below.


(b)
Exhibits Required by Item 601 of Regulation S-K

EXHIBIT
DESCRIPTION
   
4.1
Indenture dated as of February 14, 2013 among SLM Student Loan Trust 2013-1, Deutsche Bank National Trust Company, as indenture trustee, and Deutsche Bank Trust Company Americas, as eligible lender trustee, which is incorporated by reference from Exhibit 4.7 of the Current Report on Form 8-K of the registrant, as filed with the Commission on February 14, 2013, with a file number of 333-166301-11.
   
10.1
Indenture dated as of February 14, 2013 among SLM Student Loan Trust 2013-1, Deutsche Bank National Trust Company, as indenture trustee, and Deutsche Bank Trust Company Americas, as eligible lender trustee, which is incorporated by reference from Exhibit 4.7 of the Current Report on Form 8-K of the registrant, as filed with the Commission on February 14, 2013, with a file number of 333-166301-11.
   
10.2
Servicing Agreement dated as of February 14, 2013 among SLM Student Loan Trust 2013-1, Deutsche Bank National Trust Company, as indenture trustee, Deutsche Bank Trust Company Americas, as eligible lender trustee, and Navient Solutions, LLC (formerly, Navient Solutions, Inc.), as servicer and as administrator, which is incorporated by reference from Exhibit 99.8 of the Current Report on Form 8-K of the registrant, as filed with the Commission on February 14, 2013, with a file number of 333-166301-11.
   
10.3
Administration Agreement dated as of February 14, 2013 among SLM Student Loan Trust 2013-1, Deutsche Bank National Trust Company, as indenture trustee, Deutsche Bank Trust Company Americas, as eligible lender trustee, Navient Funding, LLC, as depositor, and Navient Solutions, LLC (formerly, Navient Solutions, Inc.), as servicer and as administrator, which is incorporated by reference from Exhibit 99.7 of the Current Report on Form 8-K of the registrant, as filed with the Commission on February 14, 2013, with a file number of 333-166301-11.
   
31.1*
Rule 13a-14(d)/15d-14(d) Certification (Section 302 Certification).
   
33.1*
Report on Assessment of Compliance with Servicing Criteria concerning servicing activities Navient Solutions, LLC (formerly, Navient Solutions, Inc.), as Servicer and Administrator, as of and for the year ended December 31, 2023.
   
33.2*
Report on Assessment of Compliance with Servicing Criteria concerning servicing activities of Deutsche Bank National Trust Company, as Indenture Trustee, as of and for the year ended December 31, 2023.
   
34.1*
Independent Accountants’ Attestation Report concerning servicing activities of Navient Solutions, LLC (formerly, Navient Solutions, Inc.), as Servicer and Administrator, as of and for the year ended December 31, 2023.
   
34.2*
Independent Accountants’ Attestation Report concerning servicing activities of Deutsche Bank National Trust Company, as Indenture Trustee, as of and for the year ended December 31, 2023.
   
35.1*
Statement of Compliance of Navient Solutions, LLC (formerly, Navient Solutions, Inc.), as Servicer and Administrator for the year ended December 31, 2023.
   
 
* Filed herewith.


(c)
Not Applicable.

7

SIGNATURES

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, as amended, the Registrant has duly caused this report to be signed, on its behalf by the undersigned hereunto duly authorized.

Dated: March 28, 2024
NAVIENT FUNDING, LLC, the Depositor for itself as Registrant
and on behalf of SLM Student Loan Trust 2013-1
       
 
By:
/s/ JOE FISHER
 
   
Name:
Joe Fisher
 
   
Title:
President and Chief Financial Officer
(Senior Securitization Officer)
 
       

SUPPLEMENTAL INFORMATION TO BE FURNISHED WITH REPORTS FILED PURSUANT TO SECTION 15(d) OF THE ACT BY REGISTRANTS WHICH HAVE NOT REGISTERED SECURITIES PURSUANT TO SECTION 12 OF THE ACT.

No annual report, proxy statement, form of proxy or other proxy soliciting material has been sent to holders of the notes issued by the Issuing Entity during the period covered by this Annual Report on Form 10-K and the Registrant does not intend to furnish such materials subsequent to the filing of the report.

8

INDEX TO EXHIBITS

Exhibit
Number
 
Exhibit
     
 
Indenture dated as of February 14, 2013 among SLM Student Loan Trust 2013-1, Deutsche Bank National Trust Company, as indenture trustee, and Deutsche Bank Trust Company Americas, as eligible lender trustee, which is incorporated by reference from Exhibit 4.7 of the Current Report on Form 8-K of the registrant, as filed with the Commission on February 14, 2013, with a file number of 333-166301-11.
     
 
Indenture dated as of February 14, 2013 among SLM Student Loan Trust 2013-1, Deutsche Bank National Trust Company, as indenture trustee, and Deutsche Bank Trust Company Americas, as eligible lender trustee, which is incorporated by reference from Exhibit 4.7 of the Current Report on Form 8-K of the registrant, as filed with the Commission on February 14, 2013, with a file number of 333-166301-11.
     
 
Servicing Agreement dated as of February 14, 2013 among SLM Student Loan Trust 2013-1, Deutsche Bank National Trust Company, as indenture trustee, Deutsche Bank Trust Company Americas, as eligible lender trustee, and Navient Solutions, LLC (formerly, Navient Solutions, Inc.), as servicer and as administrator, which is incorporated by reference from Exhibit 99.8 of the Current Report on Form 8-K of the registrant, as filed with the Commission on February 14, 2013, with a file number of 333-166301-11.
     
 
Administration Agreement dated as of February 14, 2013 among SLM Student Loan Trust 2013-1, Deutsche Bank National Trust Company, as indenture trustee, Deutsche Bank Trust Company Americas, as eligible lender trustee, Navient Funding, LLC, as depositor, and Navient Solutions, LLC (formerly, Navient Solutions, Inc.), as servicer and as administrator, which is incorporated by reference from Exhibit 99.7 of the Current Report on Form 8-K of the registrant, as filed with the Commission on February 14, 2013, with a file number of 333-166301-11.
     
 
Rule 13a-14(d)/15d-14(d) Certification (Section 302 Certification).
     
 
Report on Assessment of Compliance with Servicing Criteria concerning servicing activities of Navient Solutions, LLC (formerly, Navient Solutions, Inc.), as Servicer and Administrator, as of and for the year ended December 31, 2023.
     
 
Report on Assessment of Compliance with Servicing Criteria concerning servicing activities of Deutsche Bank National Trust Company, as Indenture Trustee, as of and for the year ended December 31, 2023.
     
 
Independent Accountants’ Attestation Report concerning servicing activities of Navient Solutions, LLC (formerly, Navient Solutions, Inc.), as Servicer and Administrator, as of and for the year ended December 31, 2023.
     
 
Independent Accountants’ Attestation Report concerning servicing activities of Deutsche Bank National Trust Company, as Indenture Trustee, as of and for the year ended December 31, 2023.
     
 
Statement of Compliance of Navient Solutions, LLC (formerly, Navient Solutions, Inc.), as Servicer and Administrator for the year ended December 31, 2023.
     
   
* Filed herewith.


9

EX-31.1 2 ef20023719_ex31-1.htm EXHIBIT 31.1

Exhibit 31.1

CERTIFICATION

I, Joe Fisher, certify that:

1.          I have reviewed this report on Form 10-K and all reports on Form 10-D required to be filed in respect of the period covered by this report on Form 10-K of SLM Student Loan Trust 2013-1 (the “Exchange Act periodic reports”);

2.          Based on my knowledge, the Exchange Act periodic reports, taken as a whole, do not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3.          Based on my knowledge, all of the distribution, servicing and other information required to be provided under Form 10-D for the period covered by this report is included in the Exchange Act periodic reports;

4.          Based on my knowledge and the servicer compliance statements required in this report under Item 1123 of Regulation AB, and except as disclosed in the Exchange Act periodic reports, the servicer and administrator have fulfilled their obligations under the servicing agreement and administration agreement, as applicable, in all material respects; and

5.          All of the reports on assessment of compliance with servicing criteria for asset-backed securities and their related attestation reports on assessment of compliance with servicing criteria for asset-backed securities required to be included in this report in accordance with Item 1122 of Regulation AB and Exchange Act Rules 13a-18 and 15d-18 have been included as an exhibit to this report, except as otherwise disclosed in this report. Any material instances of noncompliance described in such reports have been disclosed in this report on Form 10-K. In giving the certifications above, I have reasonably relied on information provided to me by the following unaffiliated party: Deutsche Bank National Trust Company, as indenture trustee.

[Signature Page Follows]


Date:  March 28, 2024
  
/s/ Joe Fisher
 
Joe Fisher
President and Chief Financial Officer (Senior Securitization Officer)
Navient Funding, LLC



EX-33.1 3 ef20023719_ex33-1.htm EXHIBIT 33.1

Exhibit 33.1

Assertion on Compliance with Regulation AB Criteria

Navient Solutions, LLC (formerly, Navient Solutions, Inc.), (the “Asserting Party”), a direct wholly owned subsidiary of Navient Corporation, is responsible for assessing compliance as of December 31, 2023 and for the period from January 1, 2023 through December 31, 2023 (the “Reporting Period”), with the servicing criteria set forth in Item 1122(d) of Regulation AB related to its servicing of student loan asset-backed securities transactions that were outstanding during the Reporting Period (collectively, the “Platform” and each such trust is a “Platform trust”), to the extent required by the related transaction agreements as to any transaction, except for servicing criteria Items 1122(d)(1)(iii), 1122(d)(2)(ii), 1122(d)(2)(iii), 1122(d)(2)(vi), 1122(d)(3)(iii) and 1122(d)(4)(x)-1122(d)(4)(xiii), which the Asserting Party has concluded were not required of the Asserting Party under the related transaction agreements with respect to any Platform trust during the Reporting Period.  Appendix A attached hereto identifies the servicing criteria, after giving effect to the exclusions identified herein, that are applicable to the Platform (the “Applicable Servicing Criteria”).  Appendix B attached hereto identifies the outstanding student loan asset-backed securities transactions defined by the Asserting Party as constituting the Platform for which the Asserting Party acted as administrator or sub-administrator, as applicable (collectively, the “Administrator”) and servicer or subservicer, as applicable (collectively, the “Servicer”) during the Reporting Period.
 
With respect to servicing criteria Items 1122(d)(1)(i), 1122(d)(2)(iv), 1122(d)(2)(v), 1122(d)(2)(vii), 1122(d)(3)(i), 1122(d)(3)(ii), 1122(d)(3)(iv), 1122(d)(4)(iii) and 1122 (d)(4)(xv), the Asserting Party has concluded that such criteria are not applicable under the related transaction agreements for the SMB Private Education Loan Trust 2014-A transaction and the Goal Structured Solutions Trust 2016-B transaction.
 
The Asserting Party has assessed compliance with the Applicable Servicing Criteria and has concluded that it has complied, in all material respects, with the Applicable Servicing Criteria as of December 31, 2023 and for the Reporting Period with respect to the Platform as a whole.
 
KPMG LLP, an independent registered public accounting firm, has issued an attestation report on the Asserting Party’s assessment of compliance with the Applicable Servicing Criteria as of December 31, 2023 and for the Reporting Period.
 
[Signature Page Follows]

Assertion on Compliance with Regulation AB Criteria


Navient Solutions, LLC, as Administrator and
Servicer for the Platform trusts
 
/s/ Jeffrey Stine
 
Jeffrey Stine
Vice President, Core Processing
Navient Solutions, LLC
March 28, 2024

Assertion on Compliance with Regulation AB Criteria


Appendix A

      SERVICING CRITERIA
APPLICABLE
SERVICING CRITERIA
INAPPLICABLE
SERVICING
CRITERIA1
 
 
Reference
 
 
Criteria
 
Performed
by
Asserting Party2

 
Performed
by
third-party servicers3
 
 
General Servicing Consideration
   
 
 
1122(d)(1)(i)
 
Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreements.
 
X
 
X
 
Y
             
 
 
1122(d)(1)(ii)
 
If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third party’s performance and compliance with such servicing activities.
 
X
 
X
 
             
 
 
1122(d)(1)(iii)
 
Any requirements in the transaction agreements to maintain a back-up servicer for the trust student loans are maintained.
 
 
 
Z
             
 
 
1122(d)(1)(iv)
 
A fidelity bond and errors and omissions policy is in effect on the party participating in the servicing function throughout the reporting period in the amount of coverage required by and otherwise in accordance with the terms of the transaction agreements.
 
X
 
X
 
             
 
 
1122(d)(1)(v)
 
Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.
 
X
 
X
 
             
 
Cash Collection and Administration
   
 
 
1122(d)(2)(i)
 
Payments on trust student loans are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days following receipt, or such other number of days specified in the transaction documents.
 
X
 
X
 
             
 
 
1122(d)(2)(ii)
 
Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.
 
 
X
 
Z
             
 
 
1122(d)(2)(iii)
 
Advances of funds or guarantees regarding collections, cash flows or distributions, and any interest or other fees charged for such advances, are made, reviewed and approved as specified in the transaction agreements.
 
 
 
Z
             
 
 
1122(d)(2)(iv)
 
The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of overcollateralization, are separately maintained (e.g. with respect to commingling of cash) as set forth in the transaction agreements.
 
X
 
X
 
Y
             
 
 
1122(d)(2)(v)
 
Each custodial account is maintained at a federally insured depository institution as set forth in the transaction agreements.  For purposes of this criterion, “federally insured depository institutions” with respect to a foreign financial institution means a foreign financial that meets the requirements of Rule 13k-1(b)(1) of the Securities Exchange Act.
 
X
 
X
 
Y


1 The servicing criteria marked in this column with a “Y” are inapplicable to the Asserting Party in the SMB Private Education Loan Trust 2014-A transaction in and the Goal Structured Solutions Trust 2016-B transaction in its role as subservicer pursuant to the related transaction agreements.  The servicing criteria marked in this column with a “Z” are criteria that the Asserting Party concluded were not required of the Asserting Party under the related transaction agreements for any Platform trust during the Reporting Period.
2 Servicing criteria performed by the Asserting Party.
3 Asserting Party has outsourced certain servicing activities to third parties. Specifically, Nelnet Servicing, LLC (“Nelnet”) performed certain servicing activities for SLM Student Loan Trust 2010-1, SLM Student Loan Trust 2010-2 and Navient Student Loan Trust 2014-2 for the period from January 1,2023 to December 31,2023.  Additionally, for each Platform trust, the related indenture trustee performs certain servicing activities.


 
SERVICING CRITERIA
APPLICABLE
SERVICING CRITERIA
INAPPLICABLE
SERVICING CRITERIA
 
Reference
Criteria
Performed by
Asserting Party
Performed by
third-party servicers
 
 
1122(d)(2)(vi)
 
Un-issued checks are safeguarded so as to prevent unauthorized access.
   
Z
             
 
1122(d)(2)(vii)
 
Reconciliations are prepared on a monthly basis for all asset-backed securities related bank accounts, including custodial accounts and related bank clearing accounts.  These reconciliations are (A) mathematically accurate; (B) prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C) reviewed and approved by someone other than the person who prepared the reconciliation; items are resolved within 90 calendar days of their original identification, or such other number of days specified in the transaction agreements.
X
X
Y
       
 
Investor Remittances and Reporting
   
 
1122(d)(3)(i)
 
Reports to investors, including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements.  Specifically, such reports (A) are prepared in accordance with timeframes and other terms set forth in the transaction agreements; (B) provide information calculated in accordance with the terms specified in the transaction agreements; (C) are filed with the Commission as required by its rules and regulations; and (D) agree with investors’ or the trustee’s records as to the total unpaid principal balance and number of student loans serviced by the Servicer.
X
X
Y
             
 
1122(d)(3)(ii)
 
Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.
X
X
Y
             
 
1122(d)(3)(iii)
 
Disbursements made to an investor are posted within two business days to the Servicer’s investor records, or such other number of days specified in the transaction agreements.
 
X
Z
             
 
1122(d)(3)(iv)
 
Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.
X
X
Y
             


 
SERVICING CRITERIA
APPLICABLE
SERVICING CRITERIA
INAPPLICABLE
SERVICING CRITERIA
 
Reference

 Criteria
Performed by
Asserting Party
Performed by
third-party servicers
 
     
Pool Asset Administration
     
             
 
1122(d)(4)(i)
 
Collateral or security on student loans is maintained as required by the transaction documents or related student loan documents.
X
X
 
             
 
1122(d)(4)(ii)
 
 
Student loan and related documents are safeguarded as required by the transaction documents.
X
X
 
             
 
1122(d)(4)(iii)
 
Any additions, removals or substitutions to the asset pool are made, reviewed and approved in accordance with any conditions or requirements in the transaction documents.
X
X
Y
             
 
1122(d)(4)(iv)
 
Payments on student loans, including any payoffs, made in accordance with the related student loan documents are posted to the Servicer’s obligor records maintained no more than two business days after receipt, or such other number of days specified in the transaction documents, and allocated to principal, interest or other items (e.g., escrow) in accordance with the related student loan documents.
X
X
 
             
 
1122(d)(4)(v)
 
The Servicer’s records regarding the student loans agree with the Servicer’s records with respect to an obligor’s unpaid principal balance.
X
X
 
             
 
1122(d)(4)(vi)
 
Changes with respect to the terms or status of an obligor's student loans (e.g., loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction documents and related pool asset documents.
X
X
 
             
 
1122(d)(4)(vii)
 
Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframes or other requirements established by the transaction documents.
X
X
 
             
 
1122(d)(4)(viii)
 
Records documenting collection efforts are maintained during the period a student loan is delinquent in accordance with the transaction documents. Such records are maintained on at least a monthly basis, or such other period specified in the transaction documents, and describe the entity’s activities in monitoring delinquent student loans including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment).
X
X
 
             
 
1122(d)(4)(ix)
 
Adjustments to interest rates or rates of return for student loans with variable rates are computed based on the related student loan documents.
X
X
 
             


 
SERVICING CRITERIA
APPLICABLE
SERVICING CRITERIA
INAPPLICABLE
SERVICING CRITERIA
 
Reference

 Criteria
Performed by
Asserting Party
Performed by
third-party servicers
 
 
1122(d)(4)(x)
 
Regarding any funds held in trust for an obligor (such as escrow accounts): (A) such funds are analyzed, in accordance with the obligor’s student loan documents, on at least an annual basis, or such other period specified in the transaction documents; (B) interest on such funds is paid, or credited, to obligors in accordance with applicable student loan documents and state laws; and (C) such funds are returned to the obligor within 30 calendar days of full repayment of the related student loans, or such other number of days specified in the transaction documents.
   
Z
             
 
1122(d)(4)(xi)
 
Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that such support has been received by the servicer at least 30 calendar days prior to these dates, or such other number of days specified in the transaction documents.
   
Z
             
 
1122(d)(4)(xii)
 
Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from the servicer’s funds and not charged to the obligor, unless the late payment was due to the obligor’s error or omission.
   
Z
             
 
1122(d)(4)(xiii)
 
Disbursements made on behalf of an obligor are posted within two business days to the obligor’s records maintained by the servicer, or such other number of days specified in the transaction documents.
   
Z
             
 
1122(d)(4)(xiv)
 
Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction documents.
X
X
 
             
 
1122(d)(4)(xv)
 
Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as set forth in the transaction documents.
X
X
Y
             


Appendix B

 
Trust Name:
 
Date of Issuance:
 
SLM Student Loan Trust 2006-2
 
February 23, 2006
 
SLM Student Loan Trust 2006-4
 
April 20, 2006
 
SLM Student Loan Trust 2006-5
 
June 21, 2006
 
SLM Student Loan Trust 2006-6
 
July 20, 2006
 
SLM Student Loan Trust 2006-7
 
August 10, 2006
 
SLM Student Loan Trust 2006-8
 
September 14, 2006
 
SLM Student Loan Trust 2006-9
 
October 12, 2006
 
SLM Student Loan Trust 2006-10
 
November 30, 2006
 
SLM Private Credit Student Loan Trust 2006-A
 
April 6, 2006
 
SLM Private Credit Student Loan Trust 2006-B
 
June 8, 2006
 
SLM Private Credit Student Loan Trust 2006-C
 
September 28, 2006
 
SLM Student Loan Trust 2007-1
 
January 25, 2007
 
SLM Student Loan Trust 2007-4
 
April 5, 2007
 
SLM Student Loan Trust 2007-5
 
July 19, 2007
 
SLM Student Loan Trust 2007-6
 
October 23, 2007
 
SLM Student Loan Trust 2007-7
 
November 8, 2007
 
SLM Student Loan Trust 2007-8
 
December 6, 2007
 
SLM Private Credit Student Loan Trust 2007-A
 
March 29, 2007
 
SLM Student Loan Trust 2008-2
 
February 7, 2008
 
SLM Student Loan Trust 2008-3
 
February 28, 2008
 
SLM Student Loan Trust 2008-4
 
April 17, 2008
 
SLM Student Loan Trust 2008-5
 
April 30, 2008
 
SLM Student Loan Trust 2008-6
 
June 12, 2008
 
SLM Student Loan Trust 2008-7
 
July 2, 2008
 
SLM Student Loan Trust 2009-1
 
April 9, 2009
 
SLM Student Loan Trust 2009-2
 
April 21, 2009
 
SLM Student Loan Trust 2010-1
 
April 15, 2010
 
SLM Student Loan Trust 2010-2
 
August 26, 2010
 
SLM Student Loan Trust 2011-1
 
March 3, 2011
 
SLM Student Loan Trust 2011-2
 
May 26, 2011
 
SLM Student Loan Trust 2011-3
 
November 18, 2011
 
SLM Student Loan Trust 2012-1
 
January 19, 2012
 
SLM Student Loan Trust 2012-2
 
March 15, 2012
 
SLM Student Loan Trust 2012-3
 
May 3, 2012
 
SLM Student Loan Trust 2012-5
 
July 19, 2012
 
SLM Student Loan Trust 2012-6
 
September 20, 2012
 
SLM Student Loan Trust 2012-7
 
November 8, 2012
 
SLM Student Loan Trust 2013-1
 
February 14, 2013
 
SLM Student Loan Trust 2013-2
 
April 11, 2013
 
SLM Student Loan Trust 2013-3
 
June 20, 2013


 
SLM Student Loan Trust 2013-4
 
August 15, 2013
 
SLM Student Loan Trust 2013-5
 
September 19, 2013
 
SLM Student Loan Trust 2013-6
 
November 14, 2013
 
SLM Student Loan Trust 2014-1
 
January 28, 2014
 
SLM Student Loan Trust 2014-2
 
March 27, 2014
 
Navient Student Loan Trust 2014-1
 
May 29, 2014
 
Navient Student Loan Trust 2014-2
 
August 14, 2014
 
Navient Student Loan Trust 2014-3
 
August 14, 2014
 
Navient Student Loan Trust 2014-4
 
August 14, 2014
 
Navient Student Loan Trust 2014-5
 
August 14, 2014
 
Navient Student Loan Trust 2014-6
 
August 14, 2014
 
Navient Student Loan Trust 2014-7
 
August 14, 2014
 
Navient Student Loan Trust 2014-8
 
November 25, 2014
 
Navient Student Loan Trust 2015-1
 
February 26, 2015
 
Navient Student Loan Trust 2015-2
 
April 23, 2015
 
Navient Student Loan Trust 2015-3
 
June 18, 2015
 
SLC Student Loan Trust 2004-1
 
November 23, 2004
 
SLC Student Loan Trust 2005-1
 
June 15, 2005
 
SLC Student Loan Trust 2005-2
 
September 28, 2005
 
SLC Student Loan Trust 2005-3
 
December 15, 2005
 
SLC Student Loan Trust 2006-1
 
June 28, 2006
 
SLC Student Loan Trust 2006-2
 
September 19, 2006
 
SLC Student Loan Trust 2007-1
 
June 26, 2007
 
SLC Student Loan Trust 2007-2
 
November 27, 2007
 
SLC Student Loan Trust 2008-1
 
March 28, 2008
 
SLC Student Loan Trust 2008-2
 
June 26, 2008
 
SLC Student Loan Trust 2009-1
 
February 13, 2009
 
SLC Student Loan Trust 2009-2
 
July 23, 2009
 
SLC Student Loan Trust 2009-3
 
December 22, 2009
 
SLC Student Loan Trust 2010-1
 
July 6, 2010
 
SMB Private Education Loan Trust 2014-A
 
August 7, 2014
 
Goal Structured Solutions Trust 2016-B
 
December 23, 2016



EX-33.2 4 ef20023719_ex33-2.htm EXHIBIT 33.2

Exhibit 33.2
 
MANAGEMENT’S ASSERTION OF COMPLIANCE

Management of the Trust & Agency Services department of Deutsche Bank National Trust Company and Deutsche Bank Trust Company Americas (collectively the “Company”) is responsible for assessing the servicing criteria set forth in Item 1122(d) of Regulation AB promulgated by the Securities and Exchange Commission to determine which criteria are applicable to the Company in respect of the servicing platform described below. Management has determined that the servicing criteria are applicable in regard to the servicing platform as of and for the period as follows:
 
Platform: Publicly-issued (i.e., transaction-level reporting required under the Securities Exchange Act of 1934, as amended) and certain privately-issued (i.e., for which transaction-level reporting is required pursuant to contractual obligation) residential mortgage-backed securities, commercial mortgage-backed securities and other asset-backed securities issued on or after January 1, 2006, for which the Company provides trustee, certificate administrator, securities administration, paying agent or custodian services, as defined in the transaction agreements, excluding publicly-issued securities sponsored or issued by any government sponsored entity (the “Platform”) (see Appendix A).
 
Applicable Servicing Criteria: All servicing criteria set forth in Item 1122(d), to the extent required by Item 1122(d) servicing criteria in regards to the activities performed by the Company with respect to the Platform as to any transaction, except for the following criteria: 1122(d)(4)(iv) – 1122(d)(4)(xiv), which management has determined are not applicable to the activities the Company performs with respect to the Platform (the “Applicable Servicing Criteria”). With respect to Applicable Servicing Criteria 1122(d)(1)(ii), 1122(d)(1)(iii), 1122(d)(2)(iii) and 1122(d)(4)(iii) there were no activities performed during the year ended December 31, 2023 with respect to the Platform, because there were no occurrences of events that would require the Company to perform such activities.
 
Period: Year ended December 31, 2023 (the “Period”).
 
Management's interpretation of Applicable Servicing Criteria: The Company’s management has determined that servicing criterion 1122(d)(1)(iii) is applicable only with respect to its continuing obligation to act as, or locate a, successor servicer under the circumstances referred to in certain transaction agreements. It is management's interpretation that the Company has no other active back-up servicing responsibilities in regards to servicing criterion 1122(d)(1)(iii) as of and for the Period. The Company’s management has determined that servicing criterion 1122(d)(1)(v) is applicable only to the activities the Company performs related to the mathematically accurate aggregation of information received from servicers and the accurate conveyance of such information within reports to investors. The Company’s management has determined that servicing criterion 1122(d)(4)(iii) is applicable to the activities the Company performs with respect to the Platform only as it relates to the Company’s obligation to report additions, removals or substitutions on reports to investors in accordance with the transaction agreements.
 
With respect to the Platform as of and for the Period, the Company’s management provides the following assertion of compliance with respect to the Applicable Servicing Criteria:
 

The Company’s management is responsible for assessing the Company’s compliance with the Applicable Servicing Criteria.
 

The Company’s management has assessed compliance with the Applicable Servicing Criteria. In making this assessment, management used the criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB.
 

Based on such assessment, the Company has complied, in all material respects with the Applicable Servicing Criteria.
 
Ernst & Young LLP, an independent registered public accounting firm, has issued an attestation report with respect to management’s assertion of compliance with the Applicable Servicing Criteria as of and for the Period.


 
DEUTSCHE BANK NATIONAL TRUST COMPANY
       
 
By:
/s/ Matt Bowen  
   
Name: Matt Bowen  
   
Its: Managing Director
 
       
 
By:
/s/ Christopher Corcoran  
   
Name: Christopher Corcoran
 
   
Its: Director
 
       
 
By:
/s/ Ronaldo Reyes  
   
Name: Ronaldo Reyes
 
   
Its: Vice President
 
 
 
DEUTSCHE BANK TRUST COMPANY AMERICAS
       
 
By:
/s/ Ronaldo Reyes  
   
Name: Ronaldo Reyes  
   
Its: Vice President
 
       
 
By:
 /s/ Christopher Corcoran  
   
Name: Christopher Corcoran
 
   

Its: Director
 
     
Dated: February 29, 2024
 
 

Appendix A
 
I - Mortgage-backed transactions and securities constituting the platform - MBS deals
 
Deal ID
Deal Name
Series
AA0601
AAMES MORTGAGE INVESTMENT TRUST
2006-1
AB07O1
Alliance Bancorp Trust
2007-OA1
AC0601
Accredited Mortgage Loan Trust
2006-1
AC0602
Accredited Mortgage Loan Trust
2006-2
AC0701
Accredited Home Loan Trust
2007-1
AG0601
Aegis
2006-1
AH0601
American Home Mortgage Investment Trust
2006-1
AH0602
American Home Mortgage Investment Trust
2006-2
AH0603
American Home Mortgage Investment Trust
2006-3
AH06A1
American Home Mortgage Assets
2006-1
AH06A2
American Home Mortgage Assets Trust
2006-2
AH06A5
American Home Mortgage Assets Trust
2006-5
AH06A6
American Home Mortgage Assets
2006-6
AH0701
American Home Mortgage Investment Trust
2007-1
AH0702
American Home Mortgage Inv Trust
2007-2
AH07A1
American Home Mortgage Assets Trust
2007-1
AH07A2
American Home Mortgage Assets Trust
2007-2
AH07A3
American Home Mortgage Assets Trust
2007-3
AH07A4
American Home Mortgage Assets Trust
2007-4
AH07A5
American Home Mortgage Assets Trust
2007-5
AQ0601
Ameriquest
2006-R1
AQ0602
AMERIQUEST MORTGAGE SECURITIES, INC.
2006-R2
AQ06M3
Ameriquest Mortgage Securities
2006-M3
AR0601
Argent
2006-1
AR0602
Ameriquest / Argent
2006-2
AR0603
ARGENT SECURITIES INC
2006-W3
AR0604
ARGENT SECURITIES INC
2006-W4
AR0605
ARGENT SECURITIES INC
2006-W5
AR06M1
Ameriquest / Argent
2006-M1
AR06M2
Argent Securities Trust
2006-M2
BA15SK
SFAVE
2015-5AVE
BC0601
Securitized Asset Backed Receivables (SABR)
2006-WM3
BC06F4
Securitized Asset Backed Receivables (SABR)
2006-FR4
BC06W4
Securitized Asset Backed Receivables (SABR)
2006-WM4
BC0701
BCAP LLC TRUST
2007-AA1
BC0702
BCAP LLC TRUST
2007-AA2
BC0703
BCAP LLC TRUST
2007-AA3
BC0704
BCAP LLC TRUST
2007-AA4
BC0705
BCAPB LLC TRUST
2007-AB1
BC07B1
Securitized Asset Backed Receivables (SABR)
2007-BR1
BC07B2
Securitized Asset Backed Receivables (SABR)
2007-BR2
BC07B3
Securitized Asset Backed Receivables LLC Trust (SABR)
2007-BR3
BC07B4
Securitized Asset Backed Receivables LLC Trust (SABR)
2007-BR4
BC07B5
Securitized Asset Backed Receivables LLC Trust (SABR)
2007-BR5


Deal ID
Deal Name
Series
BC07C1
Securitized Asset Backed Receivables (SABR)
2007-NC1
BC07C2
Securitized Asset Backed Receivables (SABR)
2007-NC2
BC07E1
EquiFirst Loan Securitization Trust
2007-1
BC07H1
Securitized Asset Backed Receivables (SABR)
2007-HE1
CD07C5
CD 2007-CD5 Mortgage Trust
2007-CD5
CI1423
CGCMT
2014-23
CI1425
CGCMT
2014-GC25
CI14F1
CG-CCRE
2014-FL1
CI14F2
CG-CCRE
2014-FL2
CI1527
CGCMT
2015-GC27
CI1529
CGCMT
2015-GC29
CI1531
CGCMT
2015-GC31
CI1533
CGCMT
2015-GC33
CI1535
Citigroup Commercial Series
2015-GC35
CI15P1
CGCMT
2015-P1
CI1637
CGCMT
2016-GC37
CI16C1
Citigroup Commercial Mortgage Trust
2016-C1
CI16C2
Citigroup Commercial Mortgage Trust
2016-C2
CI16C3
CGCMT
2016-C3
CI16P4
CGCMT
2016-P4
CI16P5
CGCMT
2016-P5
CI16P6
CGCMT
2016-P6
CI17B1
CGCMT
2017-B1
CI17P7
Citigroup Commercial Mortgage Trust
2017-P7
DB06G1
DB / ACE Securities Corp.
2006-GP1
DB07C9
COMM 2007-C9 Mortgage Trust
2007-C9
DB11L2
DBUBS 2011-LC2 Mortgage Trust
2011-LC2
DB12C3
COMM 2012-CCRE3 Mortgage Trust
2012-CCRE3
DB12L4
COMM
2012-LC4
DB12LT
COMM 2012-LTRT Mortgage Trust
2012-LTRT
DB1311
COMM
2013-CCRE11
DB1313
COMM
2013-LC13
DB133P
COMM 2013-300P Mortgage Trust
2013-300P
DB13BW
BWAY 2013-1515 MORTGAGE TRUST
2013-1515
DB13C6
COMM
2013-CCRE6
DB13C8
COMM 2013-CCRE8 Mortgage Trust
2013-CCRE8
DB13C9
COMM 2013-CCRE9 Mortgage Trust
2013-CCRE9
DB13CC
COMM
2013-CCRE13
DB13SF
COMM
2013-SFS
DB1414
COMM
2014-CCRE14
DB1417
COMM
2014-CCRE17
DB14AR
DBCCRE
2014-ARCP
DB14U2
COMM
2014-UBS2
DB14U4
COMM 2014-UBS4 Mortgage Trust
2014-UBS4
DB1521
COMM
2015-LC21
DB1522
COMM
2015-CCRE22
DB1525
COMM
2015-CCRE25
DB15LC
DBWF
2015-LCM
DB1678
COMM 2016-787S Mortgage Trust
2016-787S


Deal ID
Deal Name
Series
DB1685
DBWF
2016-85T
DB16D2
COMM 2016-DC2 Mortgage Trust
2016-DC2
DB16SF
DBJPM 2016-SFC Mortgage Trust
2016-SFC
FF0603
Goldman / First Franklin
2006-FF3
FF0604
Goldman / FFMLT
2006-FF4
FF0606
Goldman / FFMLT
2006-FF6
FF0613
FFMLT Trust
2006-FF13
FF06F1
HSBC / First Franklin
2006-FF1
FF06F5
HSBC / FFMLT
2006-FF5
FF06F7
HSBC / FFMLT
2006-FF7
FF06FB
HSBC/First Franklin
2006-FF11
FF07S1
FFMLT
2007-FFB-SS
GC0613
Harborview Mortgage Loan Trust
2006-13
GC0614
Harborview Mortgage Loan Trust
2006-14
GC06B1
Greenwich / Harborview Trust MPTC
2006-BU1
GC06D1
Greenwich / DSLA MTGE PASS-THRU CERTS
2006-AR1
GC06D2
DSLA Mortgage Loan Trust
2006-AR2
GC06E1
Soundview Home Loan Trust
2006-EQ1
GC06E2
Soundview Home Loan Trust
2006-EQ2
GC06F1
GREENWICH / FREMONT HOME LOAN TRUST
2006-1
GC06F2
FREMONT HOME LOAN TRUST
2006-2
GC06F3
Fremont Home Loan Trust
2006-3
GC06H2
Greenwich / Harborview Trust MPTC
2006-2
GC06H3
GREENWICH / Harborview Mortgage Loan Trust
2006-3
GC06H5
Greenwich / Harborview
2006-5
GC06H6
Greenwich / Harborview
2006-6
GC06H7
Greenwich / Harborview Mortgage Loan Trust
2006-7
GC06H8
Greenwich / Harborview Mortgage Loan Trust
2006-8
GC06H9
Harborview Mortgage Loan Trust
2006-9
GC06O1
Greenwich / Soundview Home Loan Trust
2006-OPT1
GC06O2
Greenwich / Soundview Home Loan Trust
2006-OPT2
GC06O3
Greenwich / Soundview Home Loan Trust
2006-OPT3
GC06O4
Greenwich / Soundview Home Loan Trust
2006-OPT4
GC06O5
Greenwich / Soundview HEL
2006-OPT5
GC06S1
Greenwich / Soundview HEL
2006-1
GC06S2
GREENWICH / SOUNDVIEW HOME LOAN TRUST
2006-2
GC06S3
Greenwich / Soundview Home Loan Trust
2006-3
GC06SA
Greenwich / Soundview Home Loan Trust
2006-A
GC06W1
Soundview Home Loan Trust
2006-WF1
GC06W2
Soundview Home Loan Trust
2006-WF2
GC06X1
Harborview Mortgage Loan Trust
2006-SB1
GC06Z8
Greenwich / First Franklin
2006-FF8
GC06ZA
FIRST FRANKLIN
2006-FF16
GC070A
RBSGC Mortgage Loan Trust
2007-A
GC070B
RBSGC Mortgage Loan Trust
2007-B
GC071W
Soundview Home Loan Trust
2007-WMC1
GC07D1
DSLA MORTGAGE LOAN TRUST
2007-AR1
GC07H2
Harborview Mortgage Loan Trust
2007-2
GC07H4
Harborview Mortgage Loan Trust
2007-4


Deal ID
Deal Name
Series
GC07H5
Harborview Mortgage Loan Trust
2007-5
GC07H6
Harborview Mortgage Loan Trust
2007-6
GC07H7
Harborview Mortgage Loan Trust
2007-7
GC07S1
Soundview Home Loan Trust
2007-1
GC07V1
Soundview Home Loan Trust
2007-NS1
GS0602
Goldman GSAA
2006-2
GS0604
GSAA TRUST
2006-4
GS0607
GSAA HOME EQUITY TRUST
2006-7
GS0608
GSAA HOME EQUITY TRUST
2006-8
GS0610
Goldman / GSAA
2006-10
GS0611
Goldman / GSAA
2006-I1
GS0613
Goldman / GSAA Home Equity Trust
2006-13
GS0615
GSAA
2006-15
GS0616
GSAA
2006-16
GS0617
GSAA
2006-17
GS0618
GSAA
2006-18
GS061S
GSAA Home Equity Trust 2006-S1 (private issue id GS06AS)
2006-S1
GS062S
Goldman / GSAMP
2006-S2
GS063S
GSAMP Trust
2006-S3
GS064S
Goldman / GSAMP
2006-S4
GS065S
Goldman / GSAMP Trust
2006-S5
GS066S
GSAMP Trust
2006-S6
GS06C2
Goldman / GSAMP Trust
2006-NC2
GS06F1
GSAMP Trust
2006-FM1
GS06F2
GSAMP TRUST
2006-FM2
GS06F3
GSAMP
2006-F3
GS06G1
Greenpoint Mortgage Funding Trust
2006-OH1
GS06H1
Goldman / GSAMP
2006-HE1
GS06L1
Goldman / GSAMP Trust
2006-S1
GS06O1
Goldman / GSR Mortgage Loan Trust
2006-OA1
GS0702
GSAA TRUST
2007-2
GS0704
GSAA TRUST
2007-4
GS0705
GSAA HOME EQUITY TRUST
2007-5
GS0706
GSAA TRUST
2007-6
GS071H
Gsamp Trust
2007-HSBC1
GS071S
GSAA Home Equity Trust
2007-S1
GS07A1
GSR
2007-AR1
GS07A2
GSR Mortgage Loan Trust
2007-AR2
GS07F1
GSAMP
2007-FM1
GS07F2
GSAMP Trust
2007-FM2
GS07H1
GSR Trust
2007-HEL1
GS07O1
GSR TRUST
2007-OA1
GS07O2
GSR Mortgage Loan Trust
2007-QA2
GS07T1
STARM Mortgage Loan Trust
2007-1
GS07T4
STARM
2007-4
GS11C5
GS Mortgage Securities Trust
2011-GC5
GS12C7
GS Mortgage Securities Corporation II
2012-GCJ7
GS1312
GS Mortgage Securities Corp Commercial Mtg
2013-GCJ12
GS1314
GS Mortgage Securities Trust
2013-GCJ14


Deal ID
Deal Name
Series
GS1418
GS Mortgage Securities
2014-GC18
GS1422
GSMS
2014-GC22
HB0601
HSBC / HASCO
2006-OPT1
HB0602
HSBC / HASCO
2006-OPT2
HB0603
HSI ASSET SECURITIZATION TRUST
2006-OPT3
HB0604
HSI ASSET SECURITIZATION TRUST
2006-OPT4
HB06C1
HASCO
2006-NC1
HB06H1
HASCO
2006-HE1
HB06H2
HASCO
2006-HE2
HB06L2
HALO
2006-2
HB06W1
HSI ASSET SECURITIZATION TRUST
2006-WMC1
HB0701
HASCO
2007-OPT1
HB07A1
HALO
2007-1
HB07A2
HSI Asset Loan Obligations
2007-2
HB07C1
HSI Asset Securitization
2007-NC1
HB07F1
HSIAsset Securitization Corporation Trust
2007-WF1
HB07H1
HASCO
2007-HE1
HB07H2
HASCO
2007-HE2
HB07L1
HALO
2007-AR1
HB07L2
HSIAsset Loan Obligation Trusts
2007-AR2
HB07W1
HALO
2007-WF1
IM06S1
IMPAC Secured Assets
2006-1
IM06S2
Impac Secured Assets Corp
2006-2
IM06S3
IMPAC SECURED ASSETS
2006-3
IM06S4
IMPAC SECURED ASSETS
2006-4
IM06S5
IMPAC SECURED ASSETS
2006-5
IM07S1
IMPAC SECURED ASSETS
2007-1
IM07S2
IMPAC SECURED ASSETS
2007-2
IM07S3
IMPAC SECURED ASSETS
2007-3
IN0601
IndyMac Bank RAST
2006-A1
IN0602
INDYMAC RAST
2006-A2
IN0603
IndyMac RAST
2006-A3CB
IN0605
IndyMac RAST
2006-A5CB
IN0606
IndyMac RAST
2006-A6
IN0607
IndyMac RAST
2006-A7CB
IN0608
IndyMac RAST
2006-A8
IN0609
INDYMAC RAST
2006-A9CB
IN060A
IndyMac INDS Mortgage Loan Asset-Backed Trust
2006-A
IN0610
INDYMAC RAST
2006-A10
IN0612
IndyMac RAST
2006-A12
IN0613
IndyMac RAST
2006-A13
IN0614
INDYMAC RESIDENTIAL ASSET SECURITIZATION TRUST
2006-A14CB
IN0615
IndyMac RAST
2006-A15
IN0616
IndyMac RAST
2006-A16
IN06A2
IndyMac Bank INDX
2006-AR2
IN06A3
IndyMac Bank INDX
2006-AR3
IN06A4
INDYMAC INDX MORTGAGE LOAN TRUST
2006-AR4
IN06A5
IndyMac INDX Mortgage Loan Trust
2006-AR5
IN06A6
IndyMac INDX Mortgage Loan Trust
2006-AR6


Deal ID
Deal Name
Series
IN06A7
INDYMAC INDX MORTGAGE LOAN TRUST
2006-AR7
IN06A8
IndyMac INDX Mortgage Loan Trust
2006-AR8
IN06A9
IndyMac INDX Mortgage Loan Trust
2006-AR9
IN06AB
IndyMac INDX Mortgage Loan Trust
2006-AR11
IN06AC
INDYMAC INDX
2006-AR12
IN06AD
IndyMac INDX Mortgage Loan Trust
2006-AR13
IN06AE
INDYMAC INDX
2006-AR14
IN06AF
IndyMac INDX Mortgage Loan Trust
2006-AR15
IN06AJ
IndyMac INDX
2006-AR19
IN06AL
IndyMac INDX
2006-AR21
IN06AN
INDYMAC INDX
2006-AR23
IN06AP
INDYMAC INDX
2006-AR25
IN06AR
IndyMac INDX
2006-AR27
IN06AT
IndyMac INDX
2006-AR29
IN06AV
INDYMAC INDX MORTGAGE LOAN TRUST
2006-AR31
IN06AX
INDYMAC INDX MORTGAGE LOAN TRUST
2006-AR33
IN06AZ
INDYMAC INDX MORTGAGE LOAN TRUST
2006-AR35
IN06B1
IndyMac INDB
2006-1
IN06D1
IndyMac INDA
2006-1
IN06D2
IndyMac INDA
2006-AR2
IN06D3
IndyMac INDA
2006-AR3
IN06F1
IndyMac INDX
2006-FLX1
IN06G1
INDYMAC INDS MORTGAGE LOAN TRUST
2006-1
IN06G2
INDYMAC INDS
2006-2B
IN06G3
Home Equity Mortgage Loan Asset-Backed Trust INDS
2006-3
IN06H1
IndyMac Home Equity Mortgage Loan Trust
2006-H1
IN06H2
IndyMac INABS
2006-H2
IN06H3
IndyMac Home Equity Mortgage Loan Asset-Backed Trust
2006-H3
IN06L1
INDYMAC Loan Trust
2006-L1
IN06L2
IndyMac Loan Trust
2006-L2
IN06L3
INDYMAC LOT LOAN
2006-L3
IN06L4
IndyMac Residential Mortgage Backed Trust
2006-L4
IN06R1
IndyMac RAST
2006-R1
IN06R2
IndyMac INDX
2006-R1
IN06S1
IndyMac Bank INABS
2006-A
IN06S2
INDYMAC INABS
2006-B
IN06S3
IndyMac INABS
2006-C
IN06S4
INDYMAC INABS
2006-D
IN06S5
Home Equity Mortgage Loan Asset-Backed Trust INABS
2006-E
IN06Z1
IndyMac INDX
2006-AR37
IN06Z2
IndyMac INDX
2006-AR39
IN06Z3
IndyMac INDX
2006-AR41
IN0701
INDYMAC RESIDENTIAL ASSET SECURITIZATION TRUST
2007-A1
IN0702
INDYMAC RAST
2007-A2
IN0703
IndyMac RAST
2007-A3
IN0705
INDYMAC RESIDENTIAL ASSET SECURITIZATION TRUST
2007-A5
IN0706
RESIDENTIAL ASSET SECURITIZATION TRUST
2007-A6
IN0707
INDYMAC RAST
2007-A7
IN0708
INDYMAC RAST
2007-A8


Deal ID
Deal Name
Series
IN0709
Residential Asset Securitization Trust
2007-A9
IN07A1
INDYMAC INDX MORTGAGE LOAN TRUST
2007-AR1
IN07A5
IndyMac MBS, Inc.
2007-AR5
IN07A7
INDYMAC INDX MORTGAGE LOAN TRUST
2007-AR7
IN07A9
INDYMAC INDX MORTGAGE LOAN TRUST
2007-AR9
IN07AB
INDYMAC INDX MORTGAGE LOAN TRUST
2007-AR11
IN07AD
INDYMAC INDX MORTGAGE LOAN TRUST
2007-AR13
IN07AF
INDYMAC INDX MORTGAGE LOAN TRUST
2007-AR15
IN07AH
INDYMAC INDX MORTGAGE LOAN TRUST
2007-AR17
IN07AJ
INDYMAC INDX MORTGAGE LOAN TRUST
2007-AR19
IN07AL
INDYMAC INDX MORTGAGE LOAN TRUST
2007-AR21IP
IN07C1
INDYMAC IMSC Mortgage Loan Trust
2007-AR1
IN07D1
INDYMAC INDA MORTGAGE LOAN TRUST
2007-AR1
IN07D2
INDYMAC INDA MORTGAGE LOAN TRUST
2007-AR2
IN07D3
INDYMAC INDA MORTGAGE LOAN TRUST
2007-AR3
IN07D4
INDYMAC INDA MORTGAGE LOAN TRUST
2007-AR4
IN07D5
INDYMAC INDA MORTGAGE LOAN TRUST
2007-AR5
IN07D6
IndyMac INDA Mortgage Loan Trust
2007-AR6
IN07D7
IndyMac INDA Mortgage Loan Trust
2007-AR7
IN07D8
INDYMAC INDA MORTGAGE LOAN TRUST
2007-AR8
IN07D9
IndyMac INDA Mortgage Loan Trust
2007-AR9
IN07F1
INDYMAC INDX MORTGAGE LOAN TRUST
2007-FLX1
IN07F2
INDYMAC INDX MORTGAGE LOAN TRUST
2007-FLX2
IN07F3
INDYMAC INDX MORTGAGE LOAN TRUST
2007-FLX3
IN07F4
INDYMAC INDX MORTGAGE LOAN TRUST
2007-FLX4
IN07F5
INDYMAC INDX MORTGAGE LOAN TRUST
2007-FLX5
IN07F6
INDYMAC INDX MORTGAGE LOAN TRUST
2007-FLX6
IN07J1
INDYMAC IMJA MORTGAGE LOAN TRUST
2007-A1
IN07J2
IndyMac IMJA Mortgage Loan Trust
2007-A2
IN07J3
IndyMac IMJA Mortgage Loan Trust
2007-A3
IN07J4
IndyMac IMJA Mortgage Loan Trust
2007-A4
IN07L1
INDYMAC RMBT
2007-L1
IN07M1
INDYMAC IMSC MORTGAGE LOAN TRUST
2007-F1
IN07M2
INDYMAC IMSC Mortgage Loan Trust
2007-F2
IN07M3
INDYMAC IMSC MORTGAGE LOAN TRUST
2007-AR2
IN07M4
IndyMac IMSC Mortgage Loan Trust
2007-F3
IN07MH
INDYMAC IMSC Mortgage Loan Trust
2007-HOA1
IN07R1
Residential Asset Securitization Trust
2007-R1
IN07S1
INDYMAC HOME EQUITY TRUST INABS
2007-A
IN07S2
INDYMAC INABS
2007-B
IX0601
IXIS Real Estate Capital Trust
2006-HE1
IX0602
IXIS REAL ESTATE CAPITAL TRUST
2006-HE2
IX0603
IXIS REAL ESTATE CAPITAL TRUST
2006-HE3
IX0701
IXIS REAL ESTATE CAPITAL TRUST
2007-HE1
IX0702
MORGAN STANLEY ABS CAPITAL I INC
2007-HE2
JP07C1
J.P. Morgan Mortgage Acquisition Trust
2007-CH1
JP07C2
J.P. Morgan Mortgage Acquisition Trust
2007-CH2
JP07C3
J.P. Morgan Mortgage Acquisition Trust
2007-CH3
JP07C4
J.P. MORGAN MORTGAGE ACQUISITION TRUST
2007-CH4


Deal ID
Deal Name
Series
JP07C5
J.P. Morgan Mortgage Acquisition Trust
2007-CH5
JP07H1
J.P. Morgan Mortgage Acquisition Trust
2007-HE1
JP1317
JPMBB Commercial Mortgage Securities Trust
2013-C17
JP1420
J.P. Morgan Chase Commercial Mortgage Securities Trust
2014-C20
LB0601
Long Beach
2006-1
LB0602
Long Beach Mortgage Loan Trust
2006-2
LB0603
Long Beach Mortgage Trust
2006-3
LB0604
Long Beach Mortgage Trust
2006-4
LB0605
Long Beach
2006-5
LB0606
Long Beach Mortgage Loan Trust
2006-6
LB0607
Long Beach Mortgage Loan Trust
2006-7
LB0608
Long Beach Mortgage Loan Trust
2006-8
LB0609
Long Beach Mortgage Loan Trust
2006-9
LB060A
Long Beach Mortgage Trust
2006-A
LB0610
Long Beach Mortgage Loan Trust
2006-10
LB0611
Long Beach Mortgage Loan Trust
2006-11
LB06W1
Long Beach
2006-WL1
LB06W2
Long Beach
2006-WL2
LB06W3
Long Beach
2006-WL3
ML07M1
Merrill Lynch Mortgage Investors Trust
2007-MLN1
MS06C1
Morgan Stanley
2006-NC1
MS06C2
Morgan Stanley Capital I Inc. Trust
2006-NC2
MS06C3
Morgan Stanley ABS Capital I Inc. Trust
2006-NC3
MS06C4
Morgan Stanley ABS Capital
2006-NC4
MS06C5
Morgan Stanley ABS Capital I Inc. Trust Series
2006-NC5
MS06H2
Morgan Stanley ABS Capital I Inc. Trust
2006-HE2
MS06H3
Morgan Stanley ABS Capital I Inc.Trust
2006-HE3
MS06H4
Morgan Stanley ABS Capital
2006-HE4
MS06H5
Morgan Stanley ABS Capital Trust
2006-HE5
MS06H6
Morgan Stanley ABS Capital I Inc. Trust
2006-HE6
MS06H7
Morgan Stanley ABS Capital I Inc. Trust
2006-HE7
MS06H8
Morgan Stanley ABS Capital I Inc. Trust
2006-HE8
MS06I1
Morgan Stanley IXIS Real Estate Capital
2006-1
MS06I2
Morgan Stanley IXIS Real Estate Capital Trust Series
2006-2
MS06R2
IndyMac RAST
2006-R2
MS06W2
Morgan Stanley ABS Capital Trust
2006-WMC2
MS06X2
Morgan Stanley Home Equity LoanTrust (HEL line)
2006-2
MS06X3
Morgan Stanley Home Equity LoanTrust (HEL line)
2006-3
MS07B1
Morgan Stanley Structured Trust I
2007-1
MS07C1
Morgan Stanley ABS Capital I Inc. Trust
2007-NC1
MS07C2
Morgan Stanley ABS Capital I Inc.
2007-2
MS07C3
Morgan Stanley ABS Capital I Inc.
2007-3
MS07C4
MORGAN STANLEY ABS CAPITAL I INC TRUST
2007-NC4
MS07H1
Morgan Stanley ABS Capital I Inc. Trust
2007-HE1
MS07H2
Morgan Stanley ABS Capital I Inc. Trust
2007-HE2
MS07H3
Morgan Stanley ABS Capital I Inc. Trust
2007-HE3
MS07H5
MORGAN STANLEY ABS CAPITAL I INC
2007-HE5
MS07H6
Morgan Stanley ABS Capital I Inc.
2007-6
MS07H7
Morgan Stanley ABS Capital I Inc.
2007-HE7


Deal ID
Deal Name
Series
MS07X1
Morgan Stanley Home Equity Loan Trust
2007-1
MS07X2
Morgan Stanley Home Equity Loan Trust
2007-2
MS1311
MSBAM
2013-C11
MS1415
MSBAM
2014-C15
NC0601
New Century HELT
2006-1
NC0602
New Century HEL Trust
2006-2
NC06A1
New Century Alternative Mortgage Trust
2006-ALT1
NC06S1
New Century HEL
2006-S1
NS0604
Novastar Mortgage Funding Trust
2006-4
NS0605
Novastar Mortgage Funding Trust
2006-5
NS0606
Novastar Mortgage Funding Trust
2006-6
NS0701
Novastar Mortgage Funding Trust
2007-1
NS0702
Novastar Mortgage Funding Trust
2007-2
PO0701
Popular
2007-A
RB13GS
RBS Commercial Funding Inc. 2013-GSP Trust
2013-GSP
RF06A1
RFC RALI
2006-QA1
RF06A3
RESIDENTIAL ACCREDIT LOANS, INC.
2006-QA3
RF06A4
RESIDENTIAL ACCREDIT LOANS, INC.
2006-QA4
RF06A5
RFC RALI
2006-QA5
RF06A6
RESIDENTIAL ACCREDIT LOANS, INC.
2006-QA6
RF06A7
RESIDENTIAL ACCREDIT LOANS, INC.
2006-QA7
RF06A8
Residential Accredit Loans, Inc.
2006-QA8
RF06A9
Residential Accredit Loans, Inc.
2006-QA9
RF06AA
Residential Accredit Loans, Inc.
2006-QA10
RF06AB
Residential Accredit Loans, Inc.
2006-QA11
RF06H1
Residential Accredit Loans, Inc.
2006-QH1
RF06O1
RFC RALI
2006-QO1
RF06O3
RFC / RESIDENTIAL ACCREDIT LOANS, INC.
2006-QO3
RF06O4
RESIDENTIAL ACCREDIT LOANS, INC.
2006-QO4
RF06O5
RESIDENTIAL ACCREDIT LOANS, INC.
2006-QO5
RF06O6
RFC RALI
2006-QO6
RF06O7
Residential Accredit Loans, Inc.
2006-QO7
RF06O8
Residential Accredit Loans, Inc.
2006-QO8
RF06O9
Residential Accredit Loans, Inc.
2006-QO9
RF06OA
Residential Accredit Loans, Inc.
2006-QO10
RF06Q1
RFC RALI
2006-QS1
RF06Q3
RFC / RESIDENTIAL ACCREDIT LOANS, INC.
2006-QS3
RF06Q4
RESIDENTIAL ACCREDIT LOANS, INC.
2006-QS4
RF06Q5
RESIDENTIAL ACCREDIT LOANS, INC.
2006-QS5
RF06Q6
RFC RALI
2006-QS6
RF06Q7
RFC RALI
2006-QS7
RF06Q8
RESIDENTIAL ACCREDIT LOANS, INC.
2006-QS8
RF06Q9
RESIDENTIAL ACCREDIT LOANS, INC.
2006-QS9
RF06QA
RESIDENTIAL ACCREDIT LOANS, INC.
2006-QS10
RF06QB
RESIDENTIAL ACCREDIT LOANS, INC.
2006-QS11
RF06QC
Residential Accredit Loans, Inc.
2006-QS12
RF06QD
Residential Accredit Loans, Inc.
2006-QS13
RF06QE
Residential Accredit Loans, Inc.
2006-QS14
RF06QF
Residential Accredit Loans, Inc.
2006-QS15


Deal ID
Deal Name
Series
RF06QG
Residential Accredit Loans, Inc.
2006-QS16
RF06QH
Residential Accredit Loans, Inc.
2006-QS17
RF06QI
Residential Accredit Loans, Inc.
2006-QS18
RF07A1
Residential Accredit Loans, Inc.
2007-QA1
RF07A2
Residential Accredit Loans, Inc.
2007-QA2
RF07A3
Residential Accredit Loans, Inc.
2007-QA3
RF07A4
Residential Accredit Loans, Inc.
2007-QA4
RF07A5
Residential Accredit Loans, Inc.
2007-QA5
RF07H1
Residential Accredit Loans, Inc.
2007-QH1
RF07H2
Residential Accredit Loans, Inc.
2007-QH2
RF07H3
Residential Accredit Loans, Inc.
2007-QH3
RF07H4
Residential Accredit Loans, Inc.
2007-QH4
RF07H5
Residential Accredit Loans, Inc.
2007-QH5
RF07H6
Residential Accredit Loans, Inc.
2007-QH6
RF07H7
Residential Accredit Loans, Inc.
2007-QH7
RF07H8
Residential Accredit Loans, Inc.
2007-QH8
RF07H9
Residential Accredit Loans, Inc.
2007-QH9
RF07O1
Residential Accredit Loans, Inc.
2007-QO1
RF07O2
Residential Accredit Loans, Inc.
2007-QO2
RF07O3
Residential Accredit Loans, Inc.
2007-QO3
RF07O4
Residential Accredit Loans, Inc.
2007-QO4
RF07O5
Residential Accredit Loans, Inc.
2007-QO5
RF07Q1
Residential Accredit Loans, Inc.
2007-QS1
RF07Q2
Residential Accredit Loans, Inc.
2007-QS2
RF07Q3
Residential Accredit Loans, Inc.
2007-QS3
RF07Q4
Residential Accredit Loans, Inc.
2007-QS4
RF07Q5
Residential Accredit Loans, Inc.
2007-QS5
RF07Q6
Residential Accredit Loans, Inc.
2007-QS6
RF07Q7
Residential Accredit Loans, Inc.
2007-QS7
RF07Q8
Residential Accredit Loans, Inc.
2007-QS8
RF07Q9
Residential Accredit Loans, Inc.
2007-QS9
RF07QA
Residential Accredit Loans, Inc.
2007-QS10
RF07QB
Residential Accredit Loans, Inc.
2007-QS11
RF07S4
Residential Funding Mortgage Securities I -
2007-S4
RF07S5
Residential Funding Mortgage Securities I,
2007-S5
RF08R1
RFC RALI
2008-QR1
SX0601
Saxon
2006-1
SX0602
Saxon
2006-2
SX0603
Saxon Asset Trust
2006-3
SX0701
SAXON ASSET SECURITIES COMPANY
2007-1
SX0702
SAXON ASSET SECURITIES COMPANY
2007-2
SX0703
SAXON ASSET SECURITIES CO.
2007-3
UB11C1
UBS-Citigroup Commercial Mortgage Trust
2011-C1
UB12C1
UBS Commercial Mortgage Trust
2012-C1
UB12C3
UBS-Barclays Commercial Mortgage Trust
2012-C3
UB13C5
UBS-Barclays Commercial Mortgage Trust
2013-C5
WA06A1
Washington Mutual
2006-AR1
WA06A3
Washington Mutual
2006-AR3
WA06A4
WASHINGTON MUTUAL
2006-AR4


Deal ID
Deal Name
Series
WA06A5
Washington Mutual Acceptance Corp.
2006-AR5
WA07H1
Wamu
2007-HE1
WF11C5
WF RBS Commercial Trust
2011-C5
WF12C7
WFRBS CMT
2012-C7
WF12C8
WFRBS CMT
2012-C8
WF1318
WFRBS Commercial Mtg Loan Trust
2013-C18
WF13U1
WFRBS Commercial Mtg Loan Trust
2013-UBS1
WF1414
WFRBS
2014-LC14
WF1419
WFRBS
2014-C19
 
II - Asset-backed transactions and securities constituting the platform - ABS deals
 
Deal ID
Deal Name
Series
GM1903
Ally Auto Receivables Trust
2019-3
GM1904
Ally Auto Receivables Trust
2019-4
GM1902
Ally Auto Receivables Trust
2019-2
BW191T
Bank of the West
2019-1
CTBCIV
Centerpoint Energy Transition Bond Company IV, LLC
 
CFS07A
Chase Education Loan Trust
2007-A
MCITICCIT2000
Citibank Credit Card Issuance Trust
2000
CCC7A3
Citibank Credit Card Issuance Trust
2007-A3
CCC7A4
Citibank Credit Card Issuance Trust
2007-A4
CCIT13A9
Citibank Credit Card Issuance Trust
2013-A9
CCIT17A5
Citibank Credit Card Issuance Trust
2017-A5
CCIT17A6
Citibank Credit Card Issuance Trust
2017-A6
CCIT18A2
Citibank Credit Card Issuance Trust
2018-A2
CCIT18A3
Citibank Credit Card Issuance Trust
2018-A3
CCIT18A4
Citibank Credit Card Issuance Trust
2018-A4
CCIT18A5
Citibank Credit Card Issuance Trust
2018-A5
CCIT18A7
Citibank Credit Card Issuance Trust
2018-A7
CCIT23A1
Citibank Credit Card Issuance Trust
2023-A1
CCIT23A2
Citibank Credit Card Issuance Trust
2023-A2
CLC071
College Loan Corp Trust I
2007-1
CLC072
College Loan Corp Trust II
2007-2
CLC061
College Loan Corporation Trust I
2006-1
GMI110191
Juniper Receivables DAC
2019-1
GMI110192
Juniper Receivables DAC
2019-2
GMI110201
Juniper Receivables DAC
2020-1
KSL06A
KeyCorp Student Loan Trust
2006-A
MAEN16A
Navient Private Education Loan Trust
2016-A
MAEN18B
Navient Private Education Loan Trust
2018-B
MAEN18D
Navient Private Education Loan Trust
2018-D
MAEN19E
Navient Private Education LoanTrust
2019-E
MAEN19D
Navient Private Education LoanTrust
2019-D
MAEN19F
Navient Private Education REFI LoanTrust
2019-F
MAEN19PTA
Navient Private Education REFI LoanTrust
2019-PT-A
MAEN19C
Navient Private Education REFI LoanTrust
2019-C
MAEN141
Navient Student Loan Trust
2014-1
MAEN142
Navient Student Loan Trust
2014-2


Deal ID
Deal Name
Series
MAEN143
Navient Student Loan Trust
2014-3
MAEN144
Navient Student Loan Trust
2014-4
MAEN145
Navient Student Loan Trust
2014-5
MAEN146
Navient Student Loan Trust
2014-6
MAEN147
Navient Student Loan Trust
2014-7
MAEN148
Navient Student Loan Trust
2014-8
SLC061
SLC Student Loan Trust
2006-1
SLC062
SLC Student Loan Trust
2006-2
SLC071
SLC Student Loan Trust
2007-1
SLC072
SLC Student Loan Trust
2007-2
SLC081
SLC Student Loan Trust
2008-1
SLC082
SLC Student Loan Trust
2008-2
SLC091
SLC Student Loan Trust
2009-1
SLC092
SLC Student Loan Trust
2009-2
SLC093
SLC Student Loan Trust
2009-3
SLC101
SLC Student Loan Trust
2010-1
MAE610
SLM Student Loan Trust
2006-10
MAE062
SLM Student Loan Trust
2006-2
MAE064
SLM Student Loan Trust
2006-4
MAE065
SLM Student Loan Trust
2006-5
MAE066
SLM Student Loan Trust
2006-6
MAE067
SLM Student Loan Trust
2006-7
MAE068
SLM Student Loan Trust
2006-8
MAE069
SLM Student Loan Trust
2006-9
MAE071
SLM Student Loan Trust
2007-1
MAE074
SLM Student Loan Trust
2007-4
MAE075
SLM Student Loan Trust
2007-5
MAE076
SLM Student Loan Trust
2007-6
MAE077
SLM Student Loan Trust
2007-7
MAE078
SLM Student Loan Trust
2007-8
MAE082
SLM Student Loan Trust
2008-2
MAE083
SLM Student Loan Trust
2008-3
MAE084
SLM Student Loan Trust
2008-4
MAE085
SLM Student Loan Trust
2008-5
MAE086
SLM Student Loan Trust
2008-6
MAE087
SLM Student Loan Trust
2008-7
MAE088
SLM Student Loan Trust
2008-8
MAE089
SLM Student Loan Trust
2008-9
MAE901
SLM Student Loan Trust
2009-1
MAE902
SLM Student Loan Trust
2009-2
MAE101
SLM Student Loan Trust
2010-1
MAE102
SLM Student Loan Trust
2010-2
MAE111
SLM Student Loan Trust
2011-1
MAE112
SLM Student Loan Trust
2011-2
MAE113
SLM Student Loan Trust
2011-3
MAE121
SLM Student Loan Trust
2012-1
MAE122
SLM Student Loan Trust
2012-2
MAE123
SLM Student Loan Trust
2012-3
MAE124
SLM Student Loan Trust
2012-4


Deal ID
Deal Name
Series
MAE125
SLM Student Loan Trust
2012-5
MAE126
SLM Student Loan Trust
2012-6
MAE127
SLM Student Loan Trust
2012-7
MAE128
SLM Student Loan Trust
2012-8
MAE131
SLM Student Loan Trust
2013-1
MAE132
SLM Student Loan Trust
2013-2
MAE133
SLM Student Loan Trust
2013-3
MAE134
SLM Student Loan Trust
2013-4
MAE135
SLM Student Loan Trust
2013-5
MAE136
SLM Student Loan Trust
2013-6
MAE041
SLM Student Loan Trust
2014-1
MAE142
SLM Student Loan Trust
2014-2
MAEB14A
SMB Private Education Loan Trust
2014-A
MAEB15A
SMB Private Education Loan Trust
2015-A
MAEB15B
SMB Private Education Loan Trust
2015-B
MAEB15C
SMB Private Education Loan Trust
2015-C
MAEB16A
SMB Private Education Loan Trust
2016-A
MAEB16B
SMB Private Education Loan Trust
2016-B
MAEB16C
SMB Private Education Loan Trust
2016-C
MAEB17A
SMB Private Education Loan Trust
2017-A
MAEB17B
SMB Private Education Loan Trust
2017-B
MAEB18A
SMB Private Education Loan Trust
2018-A
MAEB18B
SMB Private Education Loan Trust
2018-B
MAEB18C
SMB Private Education Loan Trust
2018-C
MAEB19A
SMB Private Education Loan Trust
2019-A
MAEB19B
SMB Private Education Loan Trust
2019-B
GEMN144
Synchrony Credit Card Master Note Trust
2014-VFN4
GEMN145
Synchrony Credit Card Master Note Trust
2014-VFN5
SYNMN182
Synchrony Credit Card Master Note Trust
2018-2
SYNMN20VF1
Synchrony Credit Card Master Note Trust
2020-VFN1
SYNMN21VF1
Synchrony Credit Card Master Note Trust
2021-VFN1
GES12A
Synchrony Sales Finance Master Trust
2012-A
GES12D
Synchrony Sales Finance Master Trust
2012-D
GESFM14C
Synchrony Sales Finance Master Trust
2014-C
SYNSFT15B
Synchrony Sales Finance Master Trust
2015-B
SYNSFT20A
Synchrony Sales Finance Master Trust
2020-A
VART211
Veros Auto Receivables Trust
2021-1
VALET182
Volkswagen Auto Loan Enhanced Trust
2018-2
VALET201
Volkswagen Auto Loan Enhanced Trust
2020-1

III - Mortgaged-backed transactions constituting the Platform - Document custody only deals
 
Deal ID
Deal Name
Series
AH066C
Citi/ Wells Fargo American Home Mortgage Assets
2006-4
BC061C
Wells Fargo/ SABR
2006-NC2
BC062C
Wells Fargo/ SABR
2006-NC3


Deal ID
Deal Name
Series
BC081C
BCAP
2008-IND1
BC083C
BCAP
2008-IND2
CA061C
Carrington
2006-NC1
CA062C
Wells Fargo/ Carrington Mortgage Loan Trust
2006-NC2
CA063C
Wells Fargo/ Carrington Mortgage Loan Trust
2006-NC3
CA064C
Wells Fargo/ Carrington Mortgage Loan Trust
2006-NC4
CI225C
BOCA Commercial Mortgage Trust
2022-BOCA
DB061C
ACE
2006-NC1
DB061Z
DBALT 2006-AR6 Wells Fargo/ Deutsche Bank custody
2006-AR6
DB062C
ACE 2006 ASAP1 HSBC/WELLS FARGO/DB
2006ASAP1
DB062Z
DBALT 2006-OA1 Wells Fargo/ Deutsche Bank custody
2006-OA1
DB063C
ACE
2006-SL1
DB064C
DBALT 2006-AB1/WELLS FARGO/DB
2006-AB1
DB065C
DBALT 2006-AR1 HSBC/ Wells Fargo/Deutsche Bank
2006-AR1
DB066C
DB ACE
2006-HE1
DB067C
Ace 2006-SD1 HSBC/ Wells Fargo/ Deutsche
2006-SD1
DB069C
DBALT Series
2006-AF1
DB06AC
DB Ace Series
2006-SL2
DB06DC
Ace 2006-ASL1 HSBC/ Wells Fargo/ Deutsche Bank custody
2006-ASL1
DB06EC
DBALT 2006-AB2 HSBC/ Wells Fargo/ Deutsche Bank custody
2006-AB2
DB06FC
Ace 2006-ASAP3 HSBC/ Wells Fargo/ Deutsche Bank custody
2006-ASAP3
DB06HC
Ace 2006-HE3 HSBC/ Wells Fargo/ Deutsche Bank custody
2006-HE3
DB06JC
Ace 2006-SD2 HSBC/ Wells Fargo/ Deutsche Bank custody
2006-SD2
DB06LC
DBALT 2006-AB3 HSBC/ Wells Fargo/ Deutsche Bank custody
2006-AB3
DB06MC
DB ALT 2006-AR2 HSBC/ Wells Fargo/ Deutsche Bank custody
2006-AR2
DB06PC
ACE 2006-SL4 HSBC/ Wells Fargo/ Deutsche Bank custody
2006-SL4
DB06QC
ACE 2006-NC2 HSBC/ Wells Fargo/ Deutsche Bank custody
2006-NC2
DB06SC
DBALT 2006-AB4 HSBC/ Wells Fargo/ Deutsche Bank custody
2006-AB4
DB06TC
Ace 2006-ASAP5 HSBC/ Wells Fargo/ Deutsche Bank custody
2006-ASAP5
DB06UC
DBALT 2006-AR4 HSBC/ Wells Fargo/ Deutsche Bank custody
2006-AR4
DB06WC
DBALT 2006-AR5 Wells Fargo/ Deutsche Bank custody
2006-AR5
DB06XC
Ace 2006-NC3 Wells Fargo/ Deutsche Bank custody
2006-NC3
DB06YC
Ace 2006-ASAP6 Wells Fargo/ Deutsche Bank custody
2006-ASAP6
DB071C
DBALT 2007-AR1Wells Fargo/ Deutsche Bank custody
2007-AR1
DB073C
Ace 2007-ASL1Wells Fargo/ Deutsche Bank custody
2007-ASL1
DB074C
DBALT 2007-AR2 Wells Fargo/ Deutsche Bank custody
2007-AR2
DB075C
DBALT 2007-BAR1 Wells Fargo/ Deutsche Bank custody
2007-BAR1
DB077C
ACE 2007-SL1 Wells Fargo/ Deutsche Bank custody
2007-SL1
DB078C
ACE 2007-HE2 Wells Fargo/ Deutsche Bank custody
2007-HE2
DB07AC
ACE 2007-ASAP1 Wells Fargo/ Deutsche Bank custody
2007-ASAP1
DB07CC
DBALT 2007-OA2 Wells Fargo/ Deutsche Bank custody
2007-OA2
DB07DC
DBALT 2007-AB1 Wells Fargo/ Deutsche Bank custody
2007-AB1
DB07EC
Ace 2007-HE4 Wells Fargo/ Deutsche Bank custody
2007-HE4
DB07FC
DBALT 2007-AR3 Wells Fargo/ Deutsche Bank custody
2007-AR3
DB07GC
ACE 2007-ASAP2 Wells Fargo/ Deutsche Bank custody
2007-ASAP2
DB07HC
Wells Fargo/ Deutsche Alt-A Securities
2007-OA3
DB07JC
Ace 2007-HE5/ Wel
2007-HE5
DB07LC
DBALT 2007-OA4/ Wel
2007-OA4
DB07MC
DBALT 2007-1/ Wells
2007-1


Deal ID
Deal Name
Series
DB07NC
DBALT 2007-OA5/ Wel
2007-OA5
DB07PC
Ace 2007-SL2/ Wel
2007-SL2
DB07QC
DBALT 2007-2/ Wells
2007-2
DB07TC
DBALT 2007-3/ Wells Fargo
2007-3
FB061C
ABSC
2006-AG1
FB071C
CSMC 2007-5/Wells Fargo custody
2007-5
FB072C
CSMC 2007-NC1 custody
2007-NC1
FB073C
CSMC 2007-6 custody
2007-6
FB075C
CSMC 2007-7 custody
2007-7
GC069C
HarborView Mortgage Loan Trust
2006-10
GC07AC
HarborView Mortgage Loan Trust
2007-3
GS061C
US Bank/Wells Fargo GSR 2006-1F Custody
2006-1F
GS062C
WELLS FARGO/GSR 2006-AR1 CUSTODY
2006-AR1
GS063C
JP Morgan/ US Bank GSAA 2006-1 Custody
2006-1
GS066C
GSAA
2006-3
GS067C
GSR
2006-2F
GS068C
Wells Fargo/US BankGSR
2006-3F
GS069C
JP Morgan/ US Bank GSAA
2006-5
GS06AC
JP Morgan/ US Bank GSAA 2006-6 custody
2006-6
GS06BC
Wells Fargo/ US Bank GSR 2006-AR2 custody
2006-AR2
GS06CC
JP Morgan/ US Bank GSR 2006-4F custody
2006-4F
GS06DC
Wells Fargo/ US Bank GSAMP 2006-HE3 custody
2006-HE3
GS06EC
JP Morgan/ US Bank GSAA 2006-9 custody
2006-9
GS06FC
Wells Fargo/ US Bank GSR 2006-5F custody
2006-5F
GS06GC
Wells Fargo/ GSAMP 2006-HE4 custody
2006-HE4
GS06HC
Wells Fargo/ GSR 2006-6F custody
2006-6F
GS06JC
Wells Fargo/ GSR 2006-7F custody
2006-7F
GS06KC
Wells Fargo/ GSAA 2006-12 custody
2006-12
GS06LC
Wells Fargo/ GSAMP 2006-HE5 custody
2006-HE5
GS06MC
Wells Fargo/ GSR 2006-8F custody
2006-8F
GS06OC
Wells Fargo/ GSAA 2006-14 custody
2006-14
GS06PC
Goldman Sachs/ US Bank/NCAMLT
2006-ALT2
GS06QC
GSAMP 2006-HE7 Goldman Sachs/ LaSalle/ Wells Fargo
2006-HE7
GS06RC
GSR 2006-9F Goldman Sachs/ US Bank/ Wells Fargo
2006-9F
GS06SC
GSAA 2006-19 Goldman Sachs/ US Bank/ Wells Fargo
2006-19
GS06TC
GSR 2006-10F Goldman Sachs/ US Bank/ Wells Fargo
2006-10F
GS06UC
GSAA 2006-20 Goldman Sachs/ US Bank/ Wells Fargo
2006-20
GS06VC
GSAMP 2006-HE8 Goldman Sachs/ LaSalle/ Wells Fargo
2006-HE8
GS072C
GSAA 2007-1 Goldman Sachs/ US Bank/ Wells Fargo
2007-1
GS073C
GSAMP 2007-H1 Goldman Sachs/ LaSalle/Wells Fargo custod
2007-H1
GS074C
GSR 2007-1F Goldman Sachs/ Wells Fargo custody
2007-1F
GS075C
GSAMP 2007-NC1 Goldman Sachs/ Wells Fargo custody
2007-NC1
GS076C
GSAA 2007-3 Goldman Sachs/ Wells Fargo custody
2007-3
GS077C
GSAMP 2007-HE1 Goldman Sachs/ Wells Fargo custody
2007-HE1
GS078C
GSR 2007-2F Goldman Sachs/ Wells Fargo custody
2007-2F
GS07AC
GSAMP 2007-HE2 Goldman Sachs/ Wells Fargo custody
2007-HE2
GS07BC
GSR 2007-3F Goldman Sachs/ Wells Fargo custody
2007-3F
GS07DC
GSAA 2007-7/ Wells Fargo
2007-7
GS07EC
GSR 2007-4F/ Wells Fargo
2007-4F


Deal ID
Deal Name
Series
GS07FC
GSAA 2007-8/ Wells Fargo
2007-8
GS07GC
GSAA 2007-9/ Wells Fargo
2007-9
GS07HC
GSAA 2007-10/ Wells Fargo
2007-10
GS07KC
GSR 2007-5F/ Wells Fargo
2007-5F
LH061Z
SASCO 2006-BC2 custody only
2006-BC2
LH062Z
LXS 2006-13 custody only
2006-13
LH063C
Lehman SAIL
2006-1
LH063Z
SAIL 2006-BNC3 custody only
2006-BNC3
LH064C
Lehman LXS
2006-2N
LH064Z
LXS 2006-14N DB custody only
2006-14N
LH065C
Lehman SARM
2006-1
LH065Z
Lehman mortgage trust 2006-5 custody only
2006-5
LH066Z
Greenpoint 2006-HE1 DB custody only
2006-HE1
LH067C
Lehman SASCO
2006-BNC1
LH067Z
LXS 2006-15 DB custody only
2006-15
LH068C
Lehman SARM
2006-2
LH068Z
LXS 2006-16H DB custody only
2006-16H
LH069C
Lehman SAIL
2006-2
LH069Z
SARM 2006-9 DB custody only
2006-9
LH06AC
Lehman SARM
2006-3
LH06AZ
BNC 2006-1 DB custody only
2006-1
LH06BC
Lehman LXS
2006-5
LH06BZ
LMT 2006-6 DB custody only
2006-6
LH06CZ
SASCO 2006-BC3 DB custody only
2006-BC3
LH06DC
SAIL
2006-BNC2
LH06DZ
LMT 2006-7 DB custody only
2006-7
LH06EC
SASCO
2006-BC1
LH06FC
SASCO
2006-AM1
LH06FZ
LXS 2006-17 DB custody only
2006-17
LH06GC
SARM
2006-4
LH06GZ
BNC 2006-10 DB custody only
2006-10
LH06HC
LXS
2006-7
LH06IZ
SASCO 2006-BC4 DB custody only
2006-BC4
LH06JZ
LXS 2006-19 custody only
2006-19
LH06KC
SAIL 2006-3 custody only
2006-3
LH06KZ
LXS
2006-18N
LH06LC
LXS 2006-8 custody only
2006-8
LH06MC
SARM 2006-5 custody only
2006-5
LH06MZ
SASCO 2006-BC5 custody only
2006-BC5
LH06NC
SASCO 2006-NC1 custody only
2006-NC1
LH06NZ
LMT 2006-8 custody only
2006-8
LH06PC
SAIL 2006-4 custody only
2006-4
LH06QC
SASCO 2006-ARS1 custody only
2006-ARS1
LH06QZ
SASCO 2006-BC6 custody only
2006-BC6
LH06RC
LXS 2006-10N custody only
2006-10
LH06RZ
LMT 2006-9 custody only
2006-9
LH06SC
LXS 2006-9 custody only
2006-9
LH06SZ
SARM 2006-12 custody only
2006-12
LH06UC
SARM 2006-7 custody only
2006-7


Deal ID
Deal Name
Series
LH06UZ
LXS 2006-20 custody only
2006-20
LH06WC
LMT 2006-4 custody only
2006-4
LH06XC
LXS 2006-11 custody only
2006-11N
LH06YC
LXS 2006-12N custody only
2006-12N
LH06ZC
SARM 2006-8 custody only
2006-8
LH071C
SASCO 2007-BC1 custody only
2007-BC1
LH071Z
LXS 2007-18N custody only
2007-18N
LH072Z
SARM 2007-10 custody only
2007-10
LH073C
LMT 2007-1 custody only
2007-1
LH074C
LXS 2007-2N custody only
2007-2N
LH074Z
SASCO 2007-BNC1 custody only
2007-BNC1
LH075C
LXS 2007-1 custody only
2007-1
LH075Z
LMT 2007-10 custody only
2007-10
LH076C
LMT 2007-2 custody only
2007-2
LH076Z
LXS 2007-20N custody only
2007-20N
LH077C
BNC 2007-1 custody only
2007-1
LH077Z
SARM 2007-11 custody only
2007-11
LH078C
LXS 2007-3 custody only
2007-3
LH079C
LXS 2007-4 custody only
2007-4
LH079Z
SASCO 2007-BC4 custody only
2007-BC4
LH07AZ
BNC 2007-4 custody only
2007-4
LH07BC
SARM 2007-3 custody only
2007-3
LH07CC
LMT
2007-4
LH07FC
BNC 2007-2 custody only
2007-2
LH07GC
LXS 2007-6 custody only
2007-6
LH07JC
LMT 2007-5 custody only
2007-5
LH07KC
SASCO 2007-BC3 custody only
2007-BC3
LH07LC
LXS 2007-9 custody only
2007-9
LH07MC
LXS 2007-8h custody only
2007-8h
LH07NC
SASCO 2007-OS1 custody only
2007-OS1
LH07RC
LXS 2007-12N custody only
2007-12N
LH07SC
LXS 2007-11 custody only
2007-11
LH07TC
BNC 2007-3 custody only
2007-3
LH07WC
LMT 2007-7 custody only
2007-7
LH07XC
LXS 2007-15N custody only
2007-15N
LH07ZC
SARM 2007-8 custody only
2007-8
MG071C
MHL 2007-1/Wells custody only
2007-1
MG072C
MHL 2007-2/Wells custody only
2007-2
ML061C
MLMI
2006-AR1
ML072C
MANA 2007-A3/Wells Fargo custody only
2007-A3
ML073C
MANA 2007-AF1/Wells Fargo custody only
2007-AF1
MS064C
MSM custody only
2006-11
SG071C
SG Mortgage Securities Trust
2007-NC1
SU071C
STICS 2007-1/Wells Fargo custody only
2007-1
UB061C
UBS MASTR
2006-AM1
UB062C
UBS MASTR
2006-NC1
UB063C
Wells Fargo/ UBS MASTR
2006HE-2
UB064C
MABS 2006-AM2 custody only
2006-AM2
UB065C
Wells Fargo/ UBS MASTR
2006-NC2


Deal ID
Deal Name
Series
UB066C
Wells Fargo/ US Bank UBS MASTR 2006-AM3
2006-AM3
UB067C
Wells Fargo/ UBS MASTR
2006-NC3
UB068C
Wells Fargo/ UBS MASTR
2006-HE5
WA071C
WaMu 2007-HE2/ Citi custody
2007-HE2
WA072C
WaMu 2007-HE3/ Citi custody
2007-HE3
WA073C
WaMu 2007-HE4/ Citi custody
2007-HE4



EX-34.1 5 ef20023719_ex34-1.htm EXHIBIT 34.1

Exhibit 34.1

Report of Independent Registered Public Accounting Firm

The Board of Directors
Navient Corporation:

We have examined management’s assertion, included in the accompanying Assertion on Compliance with Regulation AB Criteria, that Navient Solutions, LLC (the Company) complied with the servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission’s Regulation AB for its servicing of student loan asset-backed securities transactions that were outstanding during the period January 1, 2023 through December 31, 2023 (the Platform and each such asset-backed securities transaction is a Platform Trust) to the extent required by the related transaction agreements as to any transaction, except for servicing criteria 1122(d)(1)(iii), 1122(d)(2)(ii), 1122(d)(2)(iii), 1122(d)(2)(vi), 1122(d)(3)(iii) and 1122(d)(4)(x) – 1122(d)(4)(xiii), which the Company has concluded were not required by the Company under the related transaction agreements for any Platform Trust (the Servicing Criteria), as of and for the year ended December 31, 2023. With respect to servicing criteria 1122(d)(1)(i), 1122(d)(2)(iv), 1122(d)(2)(v), 1122(d)(2)(vii), 1122(d)(3)(i), 1122(d)(3)(ii), 1122(d)(3)(iv), 1122(d)(4)(iii), and 1122(d)(4)(xv), the Company has concluded that such criteria are not applicable under the related transaction agreements for the SMB Private Education Loan Trust 2014-A transaction and Goal Structured Solutions Trust 2016-B transaction. Appendix B to Assertion on Compliance with Regulation AB Criteria identifies the individual asset-backed transactions and securities defined by management as constituting the Platform for which the Company acted as administrator or sub-administrator, as applicable collectively, the Administrator) and servicer or sub-servicer, as applicable (collectively, the Servicer) during the period from January 1, 2023 through December 31, 2023. Management is responsible for the Company’s compliance with the Servicing Criteria. Our responsibility is to express an opinion on management’s assertion about the Company’s compliance with the Servicing Criteria based on our examination.

Our examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and in accordance with attestation standards established by the American Institute of Certified Public Accountants to obtain reasonable assurance and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the Servicing Criteria and performing such other procedures as we considered necessary in the circumstances. Our examination included testing selected asset-backed transactions and securities that comprise the Platform, testing selected servicing activities related to the Platform, and determining whether the Company processed those selected transactions and performed those selected activities in compliance with the Servicing Criteria. Furthermore, our procedures were limited to the selected transactions and servicing activities performed by the Company during the period covered by this report. Our procedures were not designed to determine whether errors may have occurred either prior to or subsequent to our tests that may have affected the balances or amounts calculated or reported by the Company during the period covered by this report for the selected transactions or any other transactions. We believe that our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the Company’s compliance with the Servicing Criteria.

We are required to be independent and to meet our other ethical responsibilities in accordance with relevant ethical requirements relating to the examination engagement.

In our opinion, management’s assertion that the Company complied with the aforementioned Servicing Criteria as of and for the year ended December 31, 2023 is fairly stated, in all material respects.

/s/ KPMG LLP

McLean, Virginia
March 28, 2024



EX-34.2 6 ef20023719_ex34-2.htm EXHIBIT 34.2

Exhibit 34.2

  
 Ernst & Young LLP
One Manhattan West
New York, NY 10001
 Tel +1 212 773 3000
ey.com

Report of Independent Registered Public Accounting Firm

Deutsche Bank National Trust Company and Deutsche Bank Trust Company Americas
 
We have examined management’s assertion, included in the accompanying Management’s Assertion of Compliance, that Trust & Agency Services department of Deutsche Bank National Trust Company and Deutsche Bank Trust Company Americas (collectively the “Company”) complied with the servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission’s Regulation AB for the publicly-issued (i.e., transaction-level reporting required under the Securities Exchange Act of 1934, as amended) and certain privately-issued (i.e., for which transaction-level reporting is required pursuant to contractual obligation) residential mortgage-backed securities, commercial mortgage-backed securities and other asset-backed securities issued on or after January 1, 2006, for which the Company provides trustee, certificate administrator, securities administration, paying agent or custodian services, as defined in the transaction agreements, excluding publicly-issued securities sponsored or issued by any government sponsored entity (the “Platform”), as of and for the year ended December 31, 2023 except for criteria 1122(d)(4)(iv) – 1122(d)(4)(xiv), which the Company has determined are not applicable to the activities it performs with respect to the servicing platform covered by this report. Refer to Appendix A of Management’s Assertion of Compliance for the asset backed transactions covered by this platform. Management is responsible for the Company’s compliance with those servicing criteria. Our responsibility is to express an opinion on management’s assertion about the Company’s compliance with the servicing criteria based on our examination.
 
Our examination was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants and the Public Company Accounting Oversight Board (United States) and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the applicable servicing criteria and performing such other procedures as we considered necessary in the circumstances. Our examination included testing of less than all of the individual asset backed transactions and securities that comprise the platform, testing of less than all of the servicing activities related to the Platform and determining whether the Company processed those selected transactions and performed those selected activities in compliance with the servicing criteria. Furthermore, our procedures were limited to the selected transactions and servicing activities performed by the Company during the period covered by this report. Our procedures were not designed to determine whether errors may have occurred either prior to or subsequent to our tests that may have affected the balances or amounts calculated or reported by the Company during the period covered by this report for the selected transactions or any other transactions. Although the Company is responsible for assessing compliance with criteria 1122(d)(1)(ii), 1122(d)(1)(iii), 1122(d)(2)(iii) and 1122(d)(4)(iii) of Regulation AB, there were no servicing activities performed by the Company during the year ended December 31, 2023 that required these servicing criteria to be complied with. We believe that the evidence we obtained is sufficient and appropriate to provide a reasonable basis for our opinion.
 
We are required to be independent of the Company and to meet our other ethical responsibilities, in accordance with the relevant ethical requirements related to our examination engagement.
 
Our examination does not provide a legal determination on the Company’s compliance with the servicing criteria.
 
In our opinion, management’s assertion that the Company complied with the aforementioned servicing criteria as of and for the year ended December 31, 2023 for the platform is fairly stated, in all material respects.

 
/s/ Ernst & Young LLP
   
February 29, 2024




EX-35.1 7 ef20023719_ex35-1.htm EXHIBIT 35.1

Exhibit 35.1

Servicer Compliance Statement

The undersigned, a duly authorized officer of Navient Solutions, LLC (formerly, Navient Solutions, Inc.), the Servicer and Administrator for the trusts listed on Appendix A hereto (the “Trusts”), does hereby certify that:

(a)          this certificate is delivered pursuant to Item 1123 of Regulation AB;

(b)          a review of the servicing activities of the Servicer and the Administrator as of December 31, 2023 and for the period January 1, 2023 through December 31, 2023 (the “Reporting Period”) and their performance under the applicable servicing and administration agreements for each of the Trusts has been made under my supervision; and

(c)          to the best of my knowledge, based on such review, the Servicer and the Administrator have fulfilled all of their obligations under the applicable servicing and administration agreements for each of the Trusts in all material respects through the Reporting Period.

[Signature Page Follows]


 
/s/ Jeffrey Stine
Jeffrey Stine
Vice President,
Core Processing
Navient Solutions, LLC
March 28, 2024

Servicer Compliance Statement


Appendix A

 
Trust Name:
 
Date of Issuance:
 
SLM Student Loan Trust 2006-2
 
February 23, 2006
 
SLM Student Loan Trust 2006-4
 
April 20, 2006
 
SLM Student Loan Trust 2006-5
 
June 21, 2006
 
SLM Student Loan Trust 2006-6
 
July 20, 2006
 
SLM Student Loan Trust 2006-7
 
August 10, 2006
 
SLM Student Loan Trust 2006-8
 
September 14, 2006
 
SLM Student Loan Trust 2006-9
 
October 12, 2006
 
SLM Student Loan Trust 2006-10
 
November 30, 2006
 
SLM Private Credit Student Loan Trust 2006-A
 
April 6, 2006
 
SLM Private Credit Student Loan Trust 2006-B
 
June 8, 2006
 
SLM Private Credit Student Loan Trust 2006-C
 
September 28, 2006
 
SLM Student Loan Trust 2007-1
 
January 25, 2007
 
SLM Student Loan Trust 2007-4
 
April 5, 2007
 
SLM Student Loan Trust 2007-5
 
July 19, 2007
 
SLM Student Loan Trust 2007-6
 
October 23, 2007
 
SLM Student Loan Trust 2007-7
 
November 8, 2007
 
SLM Student Loan Trust 2007-8
 
December 6, 2007
 
SLM Private Credit Student Loan Trust 2007-A
 
March 29, 2007
 
SLM Student Loan Trust 2008-2
 
February 7, 2008
 
SLM Student Loan Trust 2008-3
 
February 28, 2008
 
SLM Student Loan Trust 2008-4
 
April 17, 2008
 
SLM Student Loan Trust 2008-5
 
April 30, 2008
 
SLM Student Loan Trust 2008-6
 
June 12, 2008
 
SLM Student Loan Trust 2008-7
 
July 2, 2008
 
SLM Student Loan Trust 2009-1
 
April 9, 2009
 
SLM Student Loan Trust 2009-2
 
April 21, 2009
 
SLM Student Loan Trust 2010-1
 
April 15, 2010
 
SLM Student Loan Trust 2010-2
 
August 26, 2010
 
SLM Student Loan Trust 2011-1
 
March 3, 2011
 
SLM Student Loan Trust 2011-2
 
May 26, 2011
 
SLM Student Loan Trust 2011-3
 
November 18, 2011
 
SLM Student Loan Trust 2012-1
 
January 19, 2012
 
SLM Student Loan Trust 2012-2
 
March 15, 2012
 
SLM Student Loan Trust 2012-3
 
May 3, 2012
 
SLM Student Loan Trust 2012-5
 
July 19, 2012
 
SLM Student Loan Trust 2012-6
 
September 20, 2012
 
SLM Student Loan Trust 2012-7
 
November 8, 2012
 
SLM Student Loan Trust 2013-1
 
February 14, 2013
 
SLM Student Loan Trust 2013-2
 
April 11, 2013
 
SLM Student Loan Trust 2013-3
 
June 20, 2013
 
SLM Student Loan Trust 2013-4
 
August 15, 2013
 
SLM Student Loan Trust 2013-5
 
September 19, 2013

1

 
SLM Student Loan Trust 2013-6
 
November 14, 2013
 
SLM Student Loan Trust 2014-1
 
January 28, 2014
 
SLM Student Loan Trust 2014-2
 
March 27, 2014
 
Navient Student Loan Trust 2014-1

May 29, 2014
 
Navient Student Loan Trust 2014-2
August 14, 2014
 
Navient Student Loan Trust 2014-3
August 14, 2014
 
Navient Student Loan Trust 2014-4
August 14, 2014
 
Navient Student Loan Trust 2014-5
August 14, 2014
 
Navient Student Loan Trust 2014-6
August 14, 2014
 
Navient Student Loan Trust 2014-7
August 14, 2014
 
Navient Student Loan Trust 2014-8
 
November 25, 2014
 
Navient Student Loan Trust 2015-1
 
February 26, 2015
 
Navient Student Loan Trust 2015-2
 
April 23, 2015
 
Navient Student Loan Trust 2015-3
 
June 18, 2015
 
SLC Student Loan Trust 2004-1
 
November 23, 2004
 
SLC Student Loan Trust 2005-1
 
June 15, 2005
 
SLC Student Loan Trust 2005-2
 
September 28, 2005
 
SLC Student Loan Trust 2005-3
 
December 15, 2005
 
SLC Student Loan Trust 2006-1
 
June 28, 2006
 
SLC Student Loan Trust 2006-2
 
September 19, 2006
 
SLC Student Loan Trust 2007-1
 
June 26, 2007
 
SLC Student Loan Trust 2007-2
 
November 27, 2007
 
SLC Student Loan Trust 2008-1
 
March 28, 2008
 
SLC Student Loan Trust 2008-2
 
June 26, 2008
 
SLC Student Loan Trust 2009-1
 
February 13, 2009
 
SLC Student Loan Trust 2009-2
 
July 23, 2009
 
SLC Student Loan Trust 2009-3
 
December 22, 2009
 
SLC Student Loan Trust 2010-1
 
July 6, 2010
 
SMB Private Education Loan Trust 2014-A
 
August 7, 2014
 
Goal Structured Solutions Trust 2016-B
 
December 23, 2016


2

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