EX-99.1 2 e72212ex99-1.htm INDEPENDENT ACCOUNTANTS' REPORT

Exhibit 99.1

 

  KPMG LLP
  Suite 700
  20 Pacificia
  Irvine, CA 92618-3391

 

Independent Accountant’s Report on Applying Agreed- Upon Procedures

 

Goal Structured Solutions, Inc. (the “Company”)

Merrill Lynch, Pierce, Fenner & Smith Incorporated

(together, the “Specified Parties”)

 

Re:Goal Structured Solutions Trust 2016-A, Private Credit Student Loan Backed Notes (the “Notes”) – Student Loan File Procedures

 

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 results 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 “Data File” means an electronic data file, provided to us by the Company containing certain information related to 15,734 student loans and their related attributes as of August 31, 2016.

 

·The term “Selected Student Loans” means a sample of 175 student loans which we were instructed by the Company to randomly select from the Data File. The Company did not inform us as to the basis for how they selected the number of student loans that we were instructed to randomly select from the Data File. A listing of the Selected Student Loans is attached hereto as Exhibit A.

 

·The term “FICO File” means an electronic data file, provided to us by the Company containing borrower and co-borrower FICO score information for the student loans as of August 31, 2016.

 

·The term “Loan Files” means any file containing some or all of the following documents: Executed Promissory Note, Disclosure Statement, Servicing System Record, and FICO File.

 

The Company is responsible for the Data File.

 

 

 

 

For each Selected Student Loan, we compared the attributes listed below to the corresponding information appearing in the applicable Loan File.

 

The Specified Parties indicated that the absence of any of the Loan File information or the inability to agree the indicated information from the Data File to the Loan File for each of the attributes identified constituted an exception. The Loan File information is listed in the order of priority until such attribute was compared.

 

Attribute Loan Files
First Disbursement Date Servicing System Record
Original Loan Balance

Executed Promissory Note, Disclosure Statement

Monthly Payment

Servicing System Record and instructions provided by the Company described below

Interest Rate Servicing System Record
Loan Repayment Term

Disclosure Statement, Servicing System Record and instructions provided by the Company described below 

Loan Type Servicing System Record
Last Payment Date

Servicing System Record and instructions provided by the Company described below

Forbearance End Date (as applicable) Servicing System Record
Deferment End Date (as applicable) Servicing System Record
Current Loan Balance Servicing System Record
State Servicing System Record
Remaining Term

Servicing System Record and instructions provided by the Company described below

Loan Status Servicing System Record
School Name Servicing System Record
Borrower’s FICO Score FICO File
Co-Borrower’s FICO Score FICO File

For purposes of comparing Monthly Payment, the Company instructed us not to perform procedures related to Selected Student Loans which were in forbearance or deferment status (identified as “F” or “D” in the “CYCLESTAT” field in the Data File). We were informed by the Company that such Selected Student Loans did not contain an accurate monthly payment amount in the Servicing System Record until the loan entered into

 

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repayment status. We noted six (6) Selected Student Loans with a forbearance or deferment status in the Data File. This was not considered an exception.

 

For purposes of comparing Monthly Payment, the Company instructed us to compare the Monthly Payment in the “CURINSTAMT” field in the Data File to the “Pmt Amt” field in the Servicing System Record. In the event the Monthly Payment in the Data File did not agree with the “Pmt Amt” field in the Servicing System Record, we were instructed by the Company to compare the Monthly Payment in the Data File to the “Total Amt Due” field in the Servicing System Record.

 

For purposes of comparing Monthly Payment, for Selected Student Loans with a next payment due date (“NXTINSTDUE” field in the Data File) in October 2016, the Company instructed us to compare the Monthly Payment in the “INSTLAMT1” field in the Data File to the corresponding information in the Servicing System Record.

 

For purposes of comparing Loan Repayment Term, in the event the Loan Repayment Term in the Data File did not agree with the corresponding information in the Disclosure Statement, the Company instructed us to compare the Loan Repayment Term in the Data File to the “Max Term” field in the Servicing System Record.

 

For purposes of comparing Last Payment Date, if the Servicing System Record indicated the Selected Student Loan did not have sufficient funds received for the latest payment on or prior to August 31, 2016 (identified as “Nonsufficient Fu” under the “Action” field in the Servicing System Record), the Company instructed us to compare the latest payment date immediately preceeding the payment date the Selected Student Loan did not have sufficient funds received to the corresponding information in the Data File.

 

For purposes of comparing Remaining Term, the Company instructed us to consider the Remaining Term of Selected Student Loans that were in grace status (identified as “G” in “CYCLESTAT” field in the Data File) to be zero. The Company informed us that the Remaining Term (“REPTERM1” field in the Data File) for student loans that are in grace status is not populated until the loan enters repayment status.

 

The information regarding the Selected Student Loan was found to be in agreement with the respective information in the Loan Files. 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. 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 indicated in the Data File, and information 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 Data File, the Loan Files, or any 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.

 

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

 

/s/ KPMG LLP

 

November 9, 2016

 

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Exhibit A
The Selected Student Loans
 

 

Selected
Student
Loan
Number
Loan ID Selected
Student
Loan
Number
Loan ID Selected
Student
Loan
Number
Loan ID Selected
Student
Loan
Number
Loan ID Selected
Student
Loan
Number
Loan ID
1 XXXX494 36 XXXX083 71 XXXX243 106 XXXX232 141 XXXX708
2 XXXX660 37 XXXX223 72 XXXX318 107 XXXX385 142 XXXX730
3 XXXX957 38 XXXX229 73 XXXX452 108 XXXX437 143 XXXX765
4 XXXX020 39 XXXX230 74 XXXX547 109 XXXX457 144 XXXX769
5 XXXX056 40 XXXX306 75 XXXX692 110 XXXX585 145 XXXX866
6 XXXX073 41 XXXX363 76 XXXX762 111 XXXX620 146 XXXX032
7 XXXX080 42 XXXX463 77 XXXX792 112 XXXX646 147 XXXX170
8 XXXX105 43 XXXX475 78 XXXX991 113 XXXX688 148 XXXX207
9 XXXX259 44 XXXX497 79 XXXX149 114 XXXX735 149 XXXX230
10 XXXX530 45 XXXX757 80 XXXX180 115 XXXX782 150 XXXX410
11 XXXX549 46 XXXX793 81 XXXX251 116 XXXX830 151 XXXX437
12 XXXX556 47 XXXX860 82 XXXX286 117 XXXX028 152 XXXX557
13 XXXX703 48 XXXX960 83 XXXX308 118 XXXX560 153 XXXX568
14 XXXX785 49 XXXX065 84 XXXX425 119 XXXX595 154 XXXX752
15 XXXX817 50 XXXX089 85 XXXX950 120 XXXX793 155 XXXX757
16 XXXX863 51 XXXX122 86 XXXX516 121 XXXX983 156 XXXX831
17 XXXX018 52 XXXX255 87 XXXX523 122 XXXX191 157 XXXX941
18 XXXX069 53 XXXX277 88 XXXX606 123 XXXX263 158 XXXX962
19 XXXX109 54 XXXX361 89 XXXX660 124 XXXX320 159 XXXX008
20 XXXX114 55 XXXX381 90 XXXX791 125 XXXX327 160 XXXX068
21 XXXX215 56 XXXX438 91 XXXX157 126 XXXX334 161 XXXX172
22 XXXX834 57 XXXX517 92 XXXX364 127 XXXX455 162 XXXX259
23 XXXX918 58 XXXX560 93 XXXX387 128 XXXX482 163 XXXX316
24 XXXX025 59 XXXX644 94 XXXX388 129 XXXX503 164 XXXX408
25 XXXX038 60 XXXX936 95 XXXX416 130 XXXX638 165 XXXX520
26 XXXX041 61 XXXX969 96 XXXX484 131 XXXX660 166 XXXX524
27 XXXX101 62 XXXX060 97 XXXX546 132 XXXX705 167 XXXX684
28 XXXX201 63 XXXX066 98 XXXX547 133 XXXX729 168 XXXX172
29 XXXX248 64 XXXX067 99 XXXX553 134 XXXX760 169 XXXX188
30 XXXX280 65 XXXX114 100 XXXX555 135 XXXX229 170 XXXX390
31 XXXX311 66 XXXX134 101 XXXX744 136 XXXX354 171 XXXX417
32 XXXX467 67 XXXX253 102 XXXX778 137 XXXX494 172 XXXX546
33 XXXX490 68 XXXX578 103 XXXX881 138 XXXX501 173 XXXX552
34 XXXX512 69 XXXX789 104 XXXX914 139 XXXX522 174 XXXX591
35 XXXX054 70 XXXX197 105 XXXX214 140 XXXX611 175 XXXX709