EX-99.1 2 a16-16640_1ex99d1.htm EX-99.1

Exhibit 99.1

 

 

 

KPMG LLP

 

Suite 700

 

20 Pacifica

 

Irvine, CA 92618-3391

 

Independent Accountants’ Report on Applying Agreed-Upon Procedures

 

ECMC Group, Inc. (the “Company”)

J.P. Morgan Securities LLC

(together, the “Specified Parties”)

 

Re: ECMC Group Student Loan Trust 2016-1, Student Loan-Backed Notes (the “Notes”)

 

We have performed the procedures described below, which were agreed to by the Specified Parties, solely to assist the Specified Parties with certain information pertaining to a pool of student loans which we were informed are intended to be included as collateral in the offering of the Notes. This agreed-upon procedures engagement was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants. The sufficiency of these procedures is solely the responsibility of the Specified Parties. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose.

 

Unless otherwise indicated, the following definitions have been adopted in presenting our procedures and findings:

 

·                  The term “compared” means compared to the information shown and found it to be in agreement, unless otherwise noted.  Such compared information was deemed to be in agreement if differences were attributable to rounding.

 

·                  The term “recomputed” means recalculated and compared the result to the information shown and found it to be in agreement, unless otherwise noted. Such recomputed information was deemed to be in agreement if differences were attributable to rounding.

 

·                  The term “Cutoff Date” means May 31, 2016.

 

·                  The term “Data File” means an electronic data file provided to us by the Company on July 5, 2016 containing certain information related to 47,942 student loans as of the Cutoff Date.

 

·                  The term “Navient Student Loans” means loans with a value of “700191” within the “SERVICER” field in the Data File.

 

·                  The term “TruStudent Student Loans” means loans with a value of “700209” within the

 

KPMG LLP is a Delaware limited liability partnership, the
U.S. member firm of KPMG International Cooperative
(“KPMG International”), a Swiss entity.

 


 

 

ECMC Group Student Loan Trust 2016-1, Student Loan-Backed Notes

August 10, 2016

Page 2

 

“SERVICER” field in the Data File.

 

·                  The term “Supplemental Data File” means an electronic data file provided to us by the Company on August 8, 2016, containing certain Payoff Date information related to 40,954 Navient Student Loans as of the Cutoff Date.

 

·                  The term “GUARANTEE System” means the Company’s servicing system.

 

·                  The term “CLASS System” means Navient’s servicing system.

 

·                  The term “COMPASS System” means TruStudent’s servicing system.

 

·                  The term “Loan File” means any file containing some or all of the following documents:

 

·     #113 LOAN DISBURSEMENT DATA Screen

 

·     #111 ACCT BALANCE Screen

 

·     133 MONETARY HISTORY Screen

 

·     #122 PAYMENT SCHEDULE Screen

 

·     #135 EFFECTIVE STATUS HISTORY Screen

 

·     TruStudent Loan Detail Information Screenshot 

 

·     TruStudent Interest Rate Change/History Screenshot

 

·     TruStudent Student Demographic Screenshot

 

·     TruStudent Loan Financial Activity Screenshot

 

·     TruStudent Repayment Schedule Detail Screenshot

 

·     ECMC Loan Collection Summary Screenshot

 

·     ECMC SQL Query Screenshot 

 

·     ECMC Lookup Code Document

 

·     ECMC Address Group Summary Screenshot

 

·     ECMC History Screenshot

 

·     ECMC Guarantee Screenshot

 

The Loan File, provided to us by the Company, was represented to be electronic records contained within the GUARANTEE System, CLASS System or COMPASS System. We make no representation regarding the validity or accuracy of these documents.

 


 

 

ECMC Group Student Loan Trust 2016-1, Student Loan-Backed Notes

August 10, 2016

Page 3

 

The Company is responsible for the Data File and the Supplemental Data File.

 

We were instructed by the Company to select a random sample of 85 Navient Student Loans and a random sample of 15 TruStudent Student Loans from the Data File. The selection criteria resulted in a sample of 100 student loans (the “Selected Student Loans” as listed in Exhibit A attached hereto). For the purpose of this procedure, the Company did not inform us as to the basis for how they selected the number of Navient Student Loans or TruStudent Student Loans that we were instructed to randomly select from the Data File.

 

At the request of the Specified Parties, we performed the following procedures with respect to the Selected Student Loans. For each Selected Student Loan, we compared the information in the Data File or Supplemental Data File (as applicable) to the corresponding information in the respective Loan File. The Specified Parties indicated that the absence of any of the noted documents or the inability to agree the indicated information from the Data File or the Supplemental Data File to the Loan File for each of the attributes identified constituted an exception. The Loan File documents are listed in the order of priority until such attribute was compared.

 

Attributes

 

Loan File document(s)

 

 

 

Origination Date

 

“1STDISB” field on #113 LOAN DISBURSEMENT DATA Screen within the CLASS System for the Navient Student Loans or “Guarantee Date” field on ECMC Guarantee Screenshot within the GUARANTEE System for the TruStudent Student Loans and instructions provided by the Company described below

 

 

 

Loan Type

 

“PROG,” “PRIN SUB,” “PRIN NSUB,” and “BRNCH ID” fields on #111 ACCT BALANCE Screen within the CLASS System for the Navient Student Loans or “LOAN PGM” field on TruStudent Loan Detail Information Screenshot within the COMPASS System for the TruStudent Student Loans, the ECMC Lookup Code Document, and instructions provided by the Company described below

 

 

 

Current Statutory Borrower Interest Rate

 

“INT RATE” field on #111 ACCT BALANCE Screen within the CLASS System for the Navient Student Loans, “INTEREST RATE” field on TruStudent Interest Rate Change/History Screenshot within the COMPASS System for the TruStudent Student Loans, “Interest Rate” field on ECMC Loan Collection Summary Screenshot within the GUARANTEE System and instructions provided by the Company described below

 

 

 

Current Loan Balance

 

“AMT OUT” field on #111 ACCT BALANCE Screen and “DECLINING BALANCE” field and “EFF DATE” field on #133 MONETARY HISTORY Screen within the CLASS System for the Navient Student Loans, “CUR PRIN” field on the TruStudent Loan Detail Information

 


 

 

ECMC Group Student Loan Trust 2016-1, Student Loan-Backed Notes

August 10, 2016

Page 4

 

Attributes

 

Loan File document(s)

 

 

 

 

 

Screen within the COMPASS System, “EFFECTIVE DATE” field and “PRINCIPAL BALANCE” field on the TruStudent Loan Financial Activity Screenshot within the COMPASS System for the TruStudent Student Loans and instructions provided by the Company described below

 

 

 

Recomputed Remaining Term

 

“Payoff Date” field on #122 PAYMENT SCHEDULE Screen within CLASS System for the Navient Student Loans, “BEG DUE DATE” field and “REPAY TERM” field on TruStudent Repayment Schedule Detail Screenshot within the COMPASS System for the TruStudent Student Loans and instructions provided by the Company described below

 

 

 

First Disbursement Date

 

“1STDISB” field on #113 LOAN DISBURSEMENT DATA Screen within the CLASS System for the Navient Student Loans and “1ST DISB DATE” field on TruStudent Loan Detail Information Screenshot within the COMPASS System for TruStudent Student Loans

 

 

 

Loan Status

 

“STATUS” field on #113 LOAN DISBURSEMENT DATA Screen within the CLASS System for the Navient Student Loans, “STAT” field on #135 EFFECTIVE STATUS HISTORY Screen, “STATUS” field on TruStudent Loan Detail Information Screenshot within the COMPASS System for the TruStudent Student Loans, ECMC History Screenshot within the GUARANTEE System, ECMC Lookup Code Document, and instructions provided by the Company described below

 

 

 

Original School Type

 

“Original School” field on ECMC Guarantee Screenshot within the GUARANTEE System for the Navient Student Loans and the TruStudent Student Loans, ECMC Lookup Code Document and instructions provided by the Company described below

 

 

 

First Repayment Date

 

“RPMT BEG DT” field on #111 ACCT BALANCE Screen within the CLASS System for the Navient Student Loans or “REPAYMENT START” field on TruStudent Loan Detail Information Screenshot within the COMPASS System for the TruStudent Student Loans

 

 

 

Last Payment Date

 

“LAST BR PMT RECVD” field on #111 ACCT BALANCE Screen, “TRAN” field and “EFF DATE” field on #133 MONETARY HISTORY Screen within the CLASS System for Navient Student Loans, “TRAN TYPE” field and “EFFECTIVE DATE” field on TruStudent Loan

 


 

 

ECMC Group Student Loan Trust 2016-1, Student Loan-Backed Notes

August 10, 2016

Page 5

 

Attributes

 

Loan File document(s)

 

 

 

 

 

Financial Activity Screenshot within the COMPASS System for TruStudent Student Loans and instructions provided by the Company described below

 

 

 

Anticipated Payoff Date (Navient Student Loans only)

 

“PAYOFF DATE” field on #122 PAYMENT SCHEDULE Screen within the CLASS System for Navient Student Loans, “antic_payoff_dt” field in the ECMC SQL Query Screenshot and instructions provided by the Company described below

 

 

 

Guarantor

 

“GUARANTOR” field on ECMC Guarantee Screenshot within the GUARANTEE System and instructions provided by the Company described below

 

 

 

State

 

“ST” field on #111 ACCT BALANCE Screen within the CLASS System for Navient Student Loans, “ST” field on TruStudent Student Demographic Screenshot within the COMPASS System for the TruStudent Student Loans, ECMC History Screenshot within the GUARANTEE System, ECMC Address Group Summary Screenshot within the GUARANTEE System and instructions provided by the Company described below

 

 

 

Subsidy Indicator

 

“PRIN SUB” and “PRIN NSUB” fields on #111 ACCT BALANCE Screen within the CLASS System for Navient Student Loans, “LOAN PGM” field on TruStudent Loan Detail Information Screenshot within the COMPASS System for TruStudent Student Loans, ECMC Lookup Code Document and instructions provided by the Company described below

 

 

 

Interest Rate Type

 

“Current Int Rate Type” field on ECMC Guarantee Screenshot within the GUARANTEE System for the Navient Student Loans and TruStudent Loans and instructions provided by the Company described below

 

For purposes of comparing Origination Date, we were instructed by the Company to compare the Origination Date as follows:

 

1.              For Navient Student Loans, we were instructed by the Company to compare the “1STDISB” field on the #113 LOAN DISBURSEMENT DATA Screen within the CLASS System to the corresponding information contained in the “ORIGINATION_DATE” field in the Data File.

 

2.              For TruStudent Student Loans, we were instructed by the Company to compare the “Guarantee Date” field on the ECMC Guarantee Screenshot within the GUARANTEE System to the corresponding information contained in the “ORIGINATION_DATE” field in the Data File. For TruStudent Student Loans that were consolidation loans, we were instructed by the Company to

 


 

 

ECMC Group Student Loan Trust 2016-1, Student Loan-Backed Notes

August 10, 2016

Page 6

 

compare the “1ST DISB DATE” field on the TruStudent Loan Detail Information Screenshot within the COMPASS System to the corresponding information contained in the “ORIGINATION_DATE” field in the Data File.

 

For purposes of comparing Loan Type, we were instructed by the Company to compare the Loan Type as follows:

 

1.              For Navient Student Loans, we were instructed by the Company to compare the “PROG,” “PRIN SUB,” “PRIN NSUB” and “BRNCH ID” field on the #111 ACCT BALANCE Screen within the CLASS System to the corresponding Loan Type Description in the ECMC Lookup Code Document. If the amount in the “PRIN SUB” field was greater than $0.00, the loan was considered to be subsidized and if the amount in the “PRIN NSUB” field was greater than $0.00, the loan was considered to be non-subsidized. The Company further instructed us to compare the Loan Type Description stated in the ECMC Lookup Code Document to the corresponding information contained in the “LOAN_TYPE” field in the Data File. Refer to Exhibit C for a list of ECMC Lookup Codes and the corresponding “Navient Student Loan Type” table provided by the Company.

 

2.              For TruStudent Student Loans, we were instructed by the Company to compare the “LOAN PGM” field on the TruStudent Loan Detail Information Screenshot within the COMPASS System to the corresponding Loan Type Description in the ECMC Lookup Code Document. The Company further instructed us to compare the Loan Type Description stated in the ECMC Lookup Code Document to the corresponding information contained in the “LOAN_TYPE” field in the Data File. Refer to Exhibit C for a list of ECMC Lookup Codes and the corresponding “TruStudent Student Loan Type” table provided by the Company.

 

For purposes of comparing Current Statutory Borrower Interest Rate, we were instructed by the Company to compare the Current Statutory Borrower Interest rate as follows:

 

1.              For Navient Student Loans, we were instructed by the Company to compare the “INT RATE” field on the #111 ACCT BALANCE Screen within the CLASS System to the corresponding information contained in the “STATED_RATE” field in the Data File. In the event the “INT RATE” field on the #111 ACCT BALANCE Screen did not agree with the “STATED_RATE” field in the Data File, we were instructed by the Company to compare the latest interest rate before the Cutoff Date in the “Interest Rate” field on the ECMC Loan Collection Summary Screenshot within the GUARANTEE System to the corresponding information contained in the “STATED_RATE” field in the Data File.

 

2.              For TruStudent Student Loans, we were instructed by the Company to compare the latest interest rate before the Cutoff Date contained in the “INTEREST RATE” field on the TruStudent Interest Rate Change/History Screenshot within the COMPASS System to the corresponding information contained in the “STATED_RATE” field in the Data File.

 

For purposes of comparing Current Loan Balance, we were instructed by the Company to compare the Current Loan Balance as follows:

 

1.              For Navient Student Loans, we were instructed by the Company to compare the “AMT OUT” field on the #111 ACCT BALANCE Screen within the CLASS System to the corresponding

 


 

 

ECMC Group Student Loan Trust 2016-1, Student Loan-Backed Notes

August 10, 2016

Page 7

 

information contained in the “PRINCIPAL_BALANCE” field in the Data File. In the event the “AMT OUT” field on the #111 ACCT BALANCE Screen did not agree with the “PRINCIPAL_BALANCE” field in the Data File, we were instructed by the Company to compare the “DECLINING BALANCE” field corresponding to the latest “EFF DATE” before the Cutoff Date on the #133 MONETARY HISTORY Screen within the CLASS System to the corresponding information contained in the “PRINCIPAL_BALANCE” field in the Data File.

 

2.              For TruStudent Student Loans, we were instructed by the Company to compare “CUR PRIN” field on the TruStudent Loan Detail Information Screen within the COMPASS System to the corresponding information contained in the “PRINCIPAL_BALANCE” field in the Data File. In the event the “CUR PRIN” field on the TruStudent Loan Detail Information Screen did not agree with the “PRINCIPAL_BALANCE” field in the Data File, we were instructed by the Company to compare the “PRINCIPAL BALANCE” field corresponding to the latest “EFFECTIVE DATE” before the Cutoff Date on the TruStudent Loan Financial Activity Screenshot within the COMPASS System to the corresponding information contained in the “PRINCIPAL_BALANCE” field in the Data File.

 

For purposes of comparing Remaining Term, we were instructed by the Company to recompute the Remaining Term (the “Recomputed Remaining Term”), as follows:

 

1.              For Navient Student Loans, we were instructed by the Company to recompute the difference in months between the Cutoff Date and the “Payoff Date” field on the #122 PAYMENT SCHEDULE Screen within CLASS System.

 

2.              For TruStudent Student Loans, we were instructed by the Company to recompute the difference in months between the “BEG DUE DATE” field on the TruStudent Repayment Schedule Detail Screenshot within the COMPASS System and the Cutoff Date and subtract the result from the total “REPAY TERM” field on the TruStudent Repayment Schedule Detail Screenshot within the COMPASS System.

 

For purposes of comparing Loan Status, we were instructed by the Company to compare the Loan Status as follows:

 

1.              For Navient Student Loans, we were instructed by the Company to compare the “STATUS” field on the #113 LOAN DISBURSEMENT DATA Screen within the CLASS System to the corresponding Loan Status Description in the ECMC Lookup Code Document. The Company further instructed us to compare the Loan Status Description stated in the ECMC Lookup Code Document to the corresponding information contained in the “LOAN_STATUS” field in the Data File. Refer to Exhibit C for a list of ECMC Lookup Codes and corresponding “Navient Student Loan Status Code” table provided by the Company. In the event the Loan Status Description did not agree with the corresponding information contained in the “LOAN_STATUS” field in the Data File, we were instructed by the Company to compare the latest loan status change information before the Cutoff Date on the ECMC History Screenshot within the GUARANTEE System or the “STAT” field on the #135 EFFECTIVE STATUS HISTORY Screen within the CLASS System to the corresponding information contained in the “LOAN_STATUS” field in the Data File.

 

2.              For TruStudent Student Loans, we were instructed by the Company to compare the “STATUS”

 


 

 

ECMC Group Student Loan Trust 2016-1, Student Loan-Backed Notes

August 10, 2016

Page 8

 

field on the TruStudent Loan Detail Information Screenshot within the COMPASS System to the corresponding Loan Status Description in the ECMC Lookup Code Document. The Company further instructed us to compare the Loan Status Description stated in the ECMC Lookup Code Document to the corresponding information contained in the “LOAN_STATUS” field in the Data File. Refer to Exhibit C for a list of ECMC Lookup Codes and corresponding “TruStudent Student Loan Status Code” table provided by the Company. In the event the Loan Status Description did not agree with the corresponding information contained in the “Loan_STATUS” field in the Data File, we were instructed by the Company to compare the latest loan status change information before the Cutoff Date on the ECMC History Screenshot within the GUARANTEE System to the corresponding information contained in the “LOAN_STATUS” field in the Data File.

 

For purposes of comparing Original School Type, we were instructed by the Company to compare the School ID in the “Original School” field on the ECMC Guarantee Screenshot within the GUARANTEE System to the “School Code” field in the ECMC Lookup Code Document and to the corresponding “School_Type” information contained in the Data File.  Refer to Exhibit C for a list of ECMC Lookup Codes and the corresponding “School Code” tables for the Navient Student Loan School Type and TruStudent Student Loan School Type provided by the Company.

 

For purposes of comparing Last Payment Date, we were instructed by the Company to compare Last Payment Date as follows:

 

1.              For Navient Student Loans, we were instructed by the Company to compare the “LAST BR PMT RECVD” field on the #111 ACCT BALANCE Screen within the CLASS System to the corresponding information contained in the “LAST_PAYMENT_DATE” field in the Data File. We were instructed by the Company to consider there to be no Last Payment Date if the “LAST BR PMT RECVD” was 0. In the event the “LAST BR PMT RECVD” field did not agree with the corresponding information contained in the “LAST_PAYMENT_DATE” field in the Data File, we were instructed by the Company to identify the code in the “TRAN” field in the #133 MONETARY HISTORY Screen within the CLASS System for Navient Student Loans. We were instructed by the Company to consider “TRAN” codes from 100 to 106 to reflect payment transactions. If there was no “TRAN” code reflected in the #133 MONETARY HISTORY Screen, we were instructed by the Company to consider there to be no Last Payment Date. The Company further instructed us to compare the “EFF DATE” field in the #133 MONETARY HISTORY Screen before the Cutoff Date to the corresponding information contained in the “LAST_PAYMENT_DATE” field in the Data File.

 

2.              For TruStudent Student Loans, we were instructed by the Company to consider a “TRAN_TYPE” field of “0290A” on the TruStudent Loan Financial Activity Screenshot within the COMPASS System to be “Loans Added,” “1010C” to be “Payment,” and “7001A” to be “Interest Capitalized.”  The Company further instructed us to compare the “EFFECTIVE DATE” field corresponding to the latest “1010C” TRAN TYPE before the Cutoff Date on the TruStudent Loan Financial Activity Screenshot within the COMPASS System to the corresponding information contained in the “LAST_PAYMENT_DATE” field in the Data File. If there was no “TRAN TYPE” of “1010C” before the Cutoff Date, we were instructed by the Company to consider there to be no Last Payment Date. In the event the “EFFECTIVE DATE” field corresponding to the latest “1010C” TRAN TYPE before the Cutoff Date on the TruStudent Loan Financial Activity

 


 

 

ECMC Group Student Loan Trust 2016-1, Student Loan-Backed Notes

August 10, 2016

Page 9

 

Screenshot did not agree with the corresponding information contained in the “LAST_PAYMENT_DATE” field in the Data File, we were instructed by the Company to compare the date of the next business day after the “EFFECTIVE DATE” field to the corresponding information contained in the “LAST_PAYMENT_DATE” field in the Data File.

 

For purposes of comparing Anticipated Payoff Date, we were instructed by the Company to compare the “PAYOFF DATE” field on the #122 PAYMENT SCHEDULE Screen within the CLASS System to the corresponding information contained in the “Anticipated Payoff Date” field in the Data File. In the event the “PAYOFF DATE” field did not agree with the corresponding information contained in the “Anticipated Payoff Date” field in the Data File, we were instructed by the Company to compare the “antic_payoff_dt” field in the ECMC SQL Query Screenshot before the Cutoff Date to the corresponding information contained in the “Anticipated Payoff Date” field in the Supplemental Data File.

 

For purposes of comparing Guarantor, we were instructed by the Company to consider “951” in the “GUARANTOR” field on the ECMC Guarantee Screenshot within the GUARANTEE System to be “MN” and “706” to be “CA.” We were further instructed by the Company that both “MN” and “CA” represent ECMC as the Guarantor.

 

For purposes of comparing State, we were instructed by the Company to compare State as follows:

 

1.              For Navient Student Loans, we were instructed by the Company to compare the “ST” field on the #111 ACCT BALANCE Screen within the CLASS System to the corresponding information contained in the “STATE” field in the Data File. In the event the “ST” field did not agree with the corresponding information contained in the “STATE” field in the Data File, we were instructed by the Company to compare the State information within the ECMC History Screenshot and ECMC Address Group Summary Screenshot within the GUARANTEE System to the corresponding information contained in the “STATE” field in the Data File.

 

2.              For TruStudent Student Loans, we were instructed by the Company to compare the “ST” field on the TruStudent Student Demographic Screenshot within the COMPASS System to the corresponding information contained in the “STATE” field in the Data File.

 

For purposes of comparing Subsidy Indicator, we were instructed by the Company to compare Subsidy Indicator as follows:

 

1.              For Navient Student Loans, we were instructed by the Company to consider the loan to be subsidized if the “PRIN SUB” field on the #111 ACCT BALANCE Screen within the CLASS System was greater than $0.00 and non-subsidized if the “PRIN NSUB” on the #111 ACCT BALANCE Screen within the CLASS System was greater than $0.00.

 

2.              For TruStudent Student Loans, we were instructed by the Company to compare the “LOAN PGM” field on the TruStudent Loan Detail Information Screenshot within the COMPASS System to the corresponding Subsidy Indicator Information in the ECMC Lookup Code Document. The Company further instructed us to compare the Subsidy Indicator Information stated in the ECMC Lookup Code Document to the corresponding information contained in the “SUBSIDY_IND”

 


 

 

ECMC Group Student Loan Trust 2016-1, Student Loan-Backed Notes

August 10, 2016

Page 10

 

field in the Data File. Refer to Exhibit C for a list of ECMC Lookup Codes and the corresponding Subsidy Indicator Information provided by the Company.

 

For purposes of comparing Interest Rate Type, we were instructed by the Company to compare the “Current Int Rate Type” field on the ECMC Guarantee Screenshot within the GUARANTEE System to the corresponding information contained in the “FIXEDFLOATING” field in the Data File. The Company further instructed us to consider “F” in the “Current Int Rate Type” field on the ECMC Guarantee Screenshot to be “Fixed” and “V” to be “Floating.”

 

The information regarding the Selected Student Loans was found to be in agreement with the respective information contained in the Loan Files, excepted as noted in Exhibit B. There were no conclusions that resulted from the procedures.

 

We were not engaged to, and did not, conduct an audit, examination or review, the objective of which would be the expression of an opinion or conclusion on the Data File and the Supplemental Data File. Accordingly, we do not express such an opinion or conclusion.  Had we performed additional procedures, other matters might have come to our attention that would have been reported to the Specified Parties.

 

The procedures performed were applied based on the information included in the Data File, the Supplemental Data File, and instructions provided by the Company, without verification or evaluation of such information or instructions by us; therefore, we express no opinion or any other form of assurance regarding (i) the physical existence of the student loans, (ii) the reliability or accuracy of the Loan Files, or data and documents furnished to us by the Company which were used in our procedures, or (iii) matters of legal interpretation.

 

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

 

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

 

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

 

 

/s/ KPMG LLP

 

August 10, 2016

 


 

THE FOLLOWING PAGE CONSTITUTES EXHIBIT A.

 


 

Exhibit A

 

The Selected Student Loans

 

Selected
Student
Loan
Number

 

Student
Loan ID
Number

 

Selected
Student
Loan
Number

 

Student
Loan ID
Number

 

Selected
Student
Loan
Number

 

Student
Loan ID
Number

 

Selected
Student
Loan
Number

 

Student
Loan ID
Number

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

1

 

7053602-4

 

26

 

6892456-3

 

51

 

6986728-1

 

76

 

7697622-4

 

2

 

6907124-2

 

27

 

6949019-2

 

52

 

8332055-4

 

77

 

6328169-1

 

3

 

7094736-2

 

28

 

6334372-12

 

53

 

7127361-3

 

78

 

551271-1

 

4

 

6662833-8

 

29

 

6916912-1

 

54

 

7392600-1

 

79

 

7692852-2

 

5

 

1214566-7

 

30

 

8697420-6

 

55

 

5614390-1

 

80

 

8089011-1

 

6

 

8688551-1

 

31

 

8694732-2

 

56

 

4088277-11

 

81

 

254610-1

 

7

 

6689613-6

 

32

 

528074-6

 

57

 

6899647-10

 

82

 

7921087-1

 

8

 

7739833-1

 

33

 

6314267-6

 

58

 

7049043-3

 

83

 

8005778-2

 

9

 

6499656-1

 

34

 

6929513-4

 

59

 

7063941-1

 

84

 

3029378-8

 

10

 

270595-1

 

35

 

846158-3

 

60

 

6853113-6

 

85

 

6882184-16

 

11

 

6777706-1

 

36

 

1469524-1

 

61

 

6926918-2

 

86

 

7395552-2

 

12

 

659117-1

 

37

 

8660093-1

 

62

 

6446938-2

 

87

 

611901-2

 

13

 

6819880-5

 

38

 

6442711-3

 

63

 

79287-2

 

88

 

748467-1

 

14

 

6819880-2

 

39

 

6003142-1

 

64

 

486507-1

 

89

 

584070-1

 

15

 

8672122-4

 

40

 

6144940-1

 

65

 

6605513-2

 

90

 

1469650-8

 

16

 

380773-2

 

41

 

3843113-2

 

66

 

7377566-1

 

91

 

860412-2

 

17

 

6782976-7

 

42

 

6576128-1

 

67

 

6258465-2

 

92

 

1891140-1

 

18

 

6551756-1

 

43

 

6596203-5

 

68

 

562307-1

 

93

 

1469784-6

 

19

 

6773661-9

 

44

 

6664593-1

 

69

 

8673059-1

 

94

 

850762-1

 

20

 

2705488-1

 

45

 

8342780-9

 

70

 

3008016-1

 

95

 

702854-1

 

21

 

6559614-1

 

46

 

1990853-8

 

71

 

5315538-3

 

96

 

302794-1

 

22

 

6377477-13

 

47

 

5246698-4

 

72

 

4069019-8

 

97

 

1468930-1

 

23

 

6265293-12

 

48

 

525961-12

 

73

 

763686-5

 

98

 

671041-2

 

24

 

7003239-4

 

49

 

680027-5

 

74

 

7943047-1

 

99

 

1071935-1

 

25

 

5072949-2

 

50

 

911024-1

 

75

 

3703819-1

 

100

 

8678385-1

 

 


 

THE FOLLOWING PAGE CONSTITUTES EXHIBIT B.

 


 

Exhibit B

 

Exceptions List

 

Selected Student
Loan Number

 

Student Loan
ID Number

 

Attribute

 

Per Data File

 

Per Loan File

 

89

 

584070-1

 

Last Payment Date

 

08/06/2015

 

11/17/2014

 

91

 

860412-2

 

Last Payment Date

 

02/04/2015

 

12/15/2014

 

93

 

1469784-6

 

Recomputed Remaining Term

 

96

 

94

 

100

 

8678385-1

 

Recomputed Remaining Term

 

71

 

69

 

 


 

THE FOLLOWING PAGES CONSTITUTE EXHIBIT C.

 


 

Exhibit C

 

ECMC Lookup Codes

 

Navient Student Loan Type

 

Loan Type

 

Sub Indicator

 

Description

 

Loan Type
per Data File

 

Subsidy
Indicator

 

Branch ID

 

 

 

 

 

 

 

 

 

 

 

GB

 

N

 

Grad PLUS Loan

 

GB

 

N

 

0001

 

 

 

 

 

 

 

 

 

 

 

GS

 

N

 

Unsubsidized Stafford Loan

 

SU

 

N

 

5001

 

 

 

 

 

 

 

 

 

 

 

GS

 

S

 

Subsidized Stafford

 

SF

 

Y

 

0001

 

 

 

 

 

 

 

 

 

 

 

PL

 

N

 

PLUS Loan

 

PL

 

N

 

0001

 

 

 

 

 

 

 

 

 

 

 

SL

 

N

 

SLS Loan

 

SL

 

N

 

0001

 

 

 

 

 

 

 

 

 

 

 

SM

 

N

 

Unsubsidized Consolidation

 

CL

 

N

 

0001

 

 

 

 

 

 

 

 

 

 

 

SM

 

S

 

Subsidized Consolidation

 

CL

 

Y

 

0001

 

 

TruStudent Student Loan Type

 

Loan Type

 

Description

 

Loan Type
per Data File

 

Subsidy
Indicator

CNSLDN

 

Unsubsidized Consolidation Loan

 

CL

 

N

PLUS

 

PLUS Loan

 

PL

 

N

PLUSGB

 

Grad PLUS Loan

 

GB

 

N

SLS

 

SLS Loan

 

SL

 

N

SPCNSL

 

Unsubsidized Spousal Consolidation Loan

 

CL

 

N

STFFRD

 

Subsidized Stafford

 

SF

 

Y

SUBCNS

 

Subsidized Consolidation

 

CL

 

Y

SUBSPC

 

Subsidized Spousal Consolidation Loan

 

CL

 

Y

UNCNS

 

Unsubsidized Consolidation

 

CL

 

N

UNSPC

 

Unsubsidized Spousal Consolidation Loan

 

CL

 

N

UNSTFD

 

Unsubsidized Stafford Loan

 

SU

 

N

 


 

Navient Student Loan Status Code

 

Description

DHAR

 

Deferment

DMLT

 

Deferment

DSCH

 

Deferment

DSUM

 

Deferment

DUEM

 

Deferment

FORA

 

Forbearance

FORB

 

Forbearance

FORD

 

Forbearance

FORM

 

Forbearance

FORV

 

Forbearance

FRAB

 

Forbearance

FRAT

 

Forbearance

PCNX

 

Paid In Full - Refunded

PCON

 

Paid In Full By Consolidated

PIFB

 

Paid In Full By Borrower

PIFG

 

Paid In Full By Guarantor

PRES

 

Paid In Full - Resale

PTRN

 

Paid In Full - Servicer Transfer

RPMT

 

Repayment

 

TruStudent Student Loan Status
Code

 

Description

BANKRUPTCY V

 

In Repayment - Bankruptcy verified; claim to be filed with GA

CLAIM CANCEL

 

In Repayment - Claim filing canceled with GA

CLAIM PENDIN

 

In Repayment - Claim filing pending

CLAIM SUBMIT

 

In Repayment - Claim filed with GA

CLM PD W/RES

 

Claim Paid By GA

CURRENT

 

In Repayment - Current

DEATH ALLEGE

 

In Repayment - Death alleged

DEATH VERIFI

 

In Repayment - Death verified; claim to be filed with GA

DEFERMENT

 

Deferment

DELINQUENT

 

In Repayment - Past Due

DISABILITY A

 

In Repayment - Disability alleged

DISABILITY V

 

In Repayment - Disability verified; claim to be filed with GA

FORBEARANCE

 

Forbearance

PAID IN FULL

 

Paid In Full

PRECLAIM SUB

 

In Repayment - 60+ Days Past Due. Delinquency assistance requested from GA

 


 

School
Code

 

Navient
Student Loan
School Type

 

School Name

 

School Type per
Data File

001047

 

4

 

TROY UNIVERSITY

 

4-Year

001137

 

4

 

CALIF STATE U FULLERTON

 

4-Year

001139

 

4

 

CA STATE UNIVERSITY, LONG BEACH

 

4-Year

001183

 

4

 

HOLY NAMES COLLEGE

 

4-Year

001196

 

4

 

DOMINICAN UNIVERSITY OF CALIFORNIA

 

4-Year

001243

 

4

 

MOUNT SAINT MARY’S COLLEGE

 

4-Year

001315

 

4

 

UNIVERSITY OF CALIFORNIA

 

4-Year

001348

 

4

 

COLORADO SCHOOL OF MINES

 

4-Year

001459

 

4

 

STRAYER UNIVERSITY

 

4-Year

001534

 

4

 

FL METRO UNIVERSITY

 

4-Year

001838

 

4

 

TAYLOR UNIVERSITY

 

4-Year

002148

 

4

 

ENDICOTT COLLEGE

 

4-Year

002172

 

2

 

MOUNT WACHUSETT COMMUNITY COLLEGE

 

2-Year

002779

 

4

 

NAZARETH COLLEGE OF ROCHESTER

 

4-Year

003023

 

4

 

CAPITAL UNIVERSITY

 

4-Year

003199

 

4

 

MARYLHURST UNIVERSITY

 

4-Year

003213

 

2

 

PORTLAND COMMUNITY COLLEGE

 

2-Year

003703

 

4

 

BLUEFIELD COLLEGE

 

4-Year

003719

 

4

 

LONGWOOD UNIVERSITY

 

4-Year

003726

 

4

 

AMERICAN NATIONAL UNIVERSITY

 

4-Year

003775

 

4

 

EASTERN WASHINGTON UNIVERSITY

 

4-Year

003810

 

4

 

CONCORD COLLEGE

 

4-Year

004586

 

4

 

KAPLAN UNIVERSITY

 

4-Year

004839

 

T

 

PHILLIPS JUNIOR COLLEGE, HARDBARGER

 

Proprietary

004910

 

2

 

KAPLAN CAREER INSTITUTE

 

2-Year

007844

 

T

 

SANFORD-BROWN INSTITUTE

 

Proprietary

008093

 

2

 

HEALD COLLEGE

 

2-Year

008871

 

2

 

CONCORDE CAREER COLLEGE

 

2-Year

009079

 

2

 

EVEREST COLLEGE

 

2-Year

009635

 

4

 

FLORIDA INTERNATIONAL UNIVERSITY

 

4-Year

010546

 

2

 

CENTURY COLLEGE

 

2-Year

011024

 

T

 

BRYMAN COLLEGE

 

Proprietary

011123

 

2

 

EVEREST COLLEGE

 

2-Year

012873

 

2

 

NAT’L INST OF TECHNOLOGY

 

2-Year

020655

 

2

 

BROOKS COLLEGE

 

2-Year

020836

 

2

 

TESST COLLEGE OF TECHNOLOGY-BELTSVILLE

 

2-Year

020917

 

2

 

KAPLAN COLLEGE

 

2-Year

020988

 

4

 

UNIVERSITY OF PHOENIX

 

4-Year

021136

 

4

 

AMERICAN INTERCONTINENTAL UNIVERSITY

 

4-Year

021160

 

2

 

SANFORD-BROWN COLLEGE

 

2-Year

022171

 

4

 

PIMA MEDICAL INSTITUTE

 

4-Year

 


 

School
Code

 

Navient
Student Loan
School Type

 

School Name

 

School Type per
Data File

022188

 

4

 

BROOKLINE COLLEGE

 

4-Year

022372

 

4

 

PHILLIPS GRADUATE INSTITUTE

 

4-Year

022418

 

2

 

AMERICAN CAREER COLLEGE

 

2-Year

023063

 

2

 

KAPLAN COLLEGE

 

2-Year

023519

 

2

 

KAPLAN COLLEGE

 

2-Year

023610

 

4

 

ITT TECHNICAL INSTITUTE

 

4-Year

025083

 

2

 

SOUTHEAST COMMUNITY COLLEGE

 

2-Year

025933

 

2

 

HEALD COLLEGE

 

2-Year

025964

 

2

 

CRIMSON TECHNICAL COLLEGE

 

2-Year

025996

 

T

 

MANSFIELD BUSINESS SCHOOL

 

Proprietary

025998

 

4

 

EVEREST UNIVERSITY

 

4-Year

026149

 

T

 

SANFORD-BROWN INSTITUTE

 

Proprietary

030727

 

4

 

WESTWOOD COLLEGE

 

4-Year

030998

 

T

 

ILLINOIS SCHOOL OF HEALTH CAREERS

 

Proprietary

031070

 

4

 

SOUTHWEST COLL OF NATUROPATHIC MED & HEALTH SCIENC

 

4-Year

031081

 

T

 

SUMMIT CAREER COLLEGE

 

Proprietary

031275

 

2

 

ADVANCED TECHNOLOGY INSTITUTE

 

2-Year

033953

 

2

 

INTERNATIONAL CAREER DEVELOPMENT CENTER

 

2-Year

034274

 

T

 

CAREER COLLEGES OF AMERICA

 

Proprietary

588888

 

 

 

DEPT OF ED CODE DEFAULT/PLUG VALUE

 

Consolidation

 

 

 

 

 

 

(see Note below)

 

Note: If the loan/program type is Consolidation (see Loan type descriptions), then the school type is Consolidation.

 

School
Code

 

TruStudent
Student Loan
School Type

 

School Name

 

School Type
per Data File

00132800

 

12

 

UNIVERSITY OF SOUTH

 

Graduate

00853200

 

AP

 

HEALD COLLEGE

 

Proprietary

58888800

 

 

 

DEPT OF ED CODE DEFAULT/PLUG VALUE

 

Consolidation

00206200

 

12

 

BOWIE STATE UNIVERS

 

Graduate

00369600

 

12

 

UNIVERSITY OF VERMO

 

Graduate

00312500

 

12

 

UNIVERSITY OF CINCI

 

Graduate

00368300

 

12

 

CASTLETON STATE COL

 

Graduate

00736600

 

AP

 

LINCOLN TECHNICAL I

 

Proprietary

01035100

 

AP

 

PSI INSTITUTE

 

Proprietary

00368300

 

12

 

CASTLETON STATE COL

 

Graduate

00278800

 

12

 

NIAGARA UNIVERSITY

 

Graduate

00857500

 

AP

 

SALON PROFESSIONAL

 

Proprietary

01116700

 

5

 

COMMUNITY COLLEGE O

 

2-Year Pub /Priv