Fitch Ratings has upgraded class A-4 of Access Group 2004-2 to 'BBsf' from 'Bsf'.

The Rating Outlook is Stable. The upgrade reflects continued improved performance. Class A-5 and class B have been affirmed at 'CCCsf'. In addition, Fitch has maintained the Rating Watch Negative on the class A note for Access Funding LLC 2015-1 and affirmed the 'AAsf' rating on class B while maintaining the Stable Outlook.

RATING ACTIONS

Entity / Debt

Rating

Prior

Access Group, Inc. - Federal Student Loan Notes, Series 2004-2

A-4 00432CBX8

LT

BBsf

Upgrade

Bsf

A-5 00432CBY6

LT

CCCsf

Affirmed

CCCsf

B 00432CBZ3

LT

CCCsf

Affirmed

CCCsf

Access Funding 2015-1 LLC

A 00435TAA9

LT

AAAsf

Rating Watch Maintained

AAAsf

B 00435TAB7

LT

AAsf

Affirmed

AAsf

Page

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VIEW ADDITIONAL RATING DETAILS

Transaction Summary

For 2004-2, Class A-3 was paid in full in the first quarter of 2023 and currently, class A-4 is the only senior note receiving principal due to the sequential pay structure amongst class A.

KEY RATING DRIVERS

U.S. Sovereign Risk: The trust collateral comprises Federal Family Education Loan Program (FFELP) loans, with guaranties provided by eligible guarantors and reinsurance provided by the U.S. Department of Education (ED) for at least 97% of principal and accrued interest. The U.S. sovereign rating is currently 'AAA'/Rating Watch Negative.

Collateral Performance: Based on transaction-specific performance to date, Fitch assumed a sustainable constant default rate assumption (sCDR) of 2.0% for 2004-2 and 2.5% for 2015-1 and a sCPR of 6.25% for 2004-2 and 16.0% for 2015-1. The cumulative and effective (after applying Fitch's standard default timing curve) base case and 'AAA' default rate is unchanged at 11.0% and 33.0%, respectively, for Acc. 2004-2 and 14.5% and 43.5%, respectively, for Acc. 2015-1. The TTM levels of deferment and forbearance are 0.8% and approximately 2.7%, respectively, for 2004-2, and 2.5% and 4.5%, respectively, for 2015-1. These levels are used as the starting point in cash flow modeling and subsequent declines and increases are modeled as per criteria. Fitch applies the standard default timing curve. The claim reject rate is assumed to be 0.25% in the base case and 2.0% in the 'AAA' case.

The 30-59DPD increased year over year to 1.9% from 1.4% for 2004-2 and 90-119DPD improved to 0.44% from 0.55%. For Acc 2015-1, 30-59DPD improved to 1.7% from 2.09% and 90-119DPD was 0.44% compared with 0.29% for the same time last year.

Basis and Interest Rate Risk: Basis risk for this transaction arises from any rate and reset frequency mismatch between interest rate indices for SAP and the securities. As of the end of the most recent collection period, all trust student loans are indexed to either 91-day T-bill or 30-day Average SOFR plus spread adjustment (SA) and all notes are indexed to either 30-day or 90-day SOFR plus SA.

Payment Structure: Credit enhancement (CE) is provided by excess spread and the class A notes benefit from subordination provided by the class B notes. Acc 2004-2 is not releasing cash as the parity is below 100.2% but Acc 2015-1 is as the specified overcollateralization amount of the greater of 2.25% of the pool balance and $1,070,000 is maintained for 2015-1. Liquidity support is provided by a reserve account sized at $1.1 million and $303,814 for 2004-2 and 2015-1, respectively.

Operational Capabilities: Day-to-day servicing is provided by Nelnet, Inc., which Fitch believes to be an acceptable servicer of student loans due to its long servicing history.

RATING SENSITIVITIES

Factors that Could, Individually or Collectively, Lead to Negative Rating Action/Downgrade

'AAAsf'-rated tranches of most FFELP securitizations will likely move in tandem with the U.S. sovereign rating given the strong linkage to the U.S. sovereign, by nature of the reinsurance provided by the Department of Education. Aside from the U.S. sovereign rating, defaults, basis risk and loan extension risk account for the majority of the risk embedded in FFELP student loan transactions.

This section provides insight into the model-implied sensitivities the transactions face when one assumption is modified, while holding others equal. Fitch conducts credit and maturity stress sensitivity analysis by increasing or decreasing key assumptions by 25% and 50% over the base case. The credit stress sensitivity is viewed by stressing both the base case default rate and the basis spread. The maturity stress sensitivity is viewed by stressing remaining term, IBR usage and prepayments. The results below should only be considered as one potential outcome, as the transaction is exposed to multiple dynamic risk factors and should not be used as an indicator of possible future performance.

Fitch has revised its global economic outlook forecasts as a result of the war in Ukraine and related economic sanctions. Downside risks have increased highlighted in the special report, 'What a Stagflation Scenario Would Mean for Global Structured Finance', an assessment of the potential rating and asset performance impact of a plausible, albeit worse than expected, adverse stagflation scenario. Fitch expects the FFELP student loan ABS sector, under this scenario, to experience mild to modest asset performance deterioration, indicating some Outlook changes (between 5% and 20% of outstanding ratings). Asset performance under this adverse scenario is expected to be more modest than the most severe sensitivity scenario below. The severity and duration of the macroeconomic disruption is uncertain, but is balanced by a strong labor market and the build-up of household savings during the pandemic, which will provide support in the near term to households faced with falling real incomes.

Access Group, Inc. - Federal Student Loan Notes, Series 2004-2

Current Rating: Class A-4 'BBsf'; Class A-5 and Class B 'CCCsf'.

Credit Stress Rating Sensitivity

Default increase 25%: class A-4 'BBsf', class A-5 'CCCsf', class B 'CCCsf';

Default increase 50%: class A-4 'BBsf', class A-5 'CCCsf', class B 'CCCsf';

Basis Spread increase 0.25%: class A-4 'BBsf', class A-5 'CCCsf', class B 'CCCsf';

Basis Spread increase 0.5%: class A-4 'BBsf', class A-5 'CCCsf', class B 'CCCsf'.

Maturity Stress Rating Sensitivity

CPR decrease 25%: class A-4 'CCCsf', class A-5 'CCCsf', class B 'CCCsf';

CPR decrease 50%: class A-4 'CCCsf', class A-5 'CCCsf', class B 'CCCsf';

IBR Usage increase 25%: class A-4 'Bsf', class A-5 'CCCsf', class B 'CCCsf';

IBR Usage increase 50%: class A-4 'Bsf', class A-5 'CCCsf', class B 'CCCsf';

Remaining Term increase 25%: class A-4 'CCCsf', class A-5 'CCCsf', class B 'CCCsf';

Remaining Term increase 50%: class A-4 'CCCsf', class A-5 'CCCsf', class B 'CCCsf'.

Current Rating: - Class A - 'AAAsf'; Class B - 'AAsf'.

Credit Stress Rating Sensitivity

Default increase 25%: class A 'BBBsf', class B 'Asf';

Default increase 50%: class A 'BBBsf', class B 'Asf';

Basis Spread increase 0.25%: class A 'Asf', class B 'Asf';

Basis Spread increase 0.5%: class A 'Asf', class B 'Asf'.

Maturity Stress Rating Sensitivity

CPR decrease 25%: class A 'AAAsf', class B 'AAAsf';

CPR decrease 50%: class A 'AAAsf', class B 'AAAsf';

IBR Usage increase 25%: class A 'AAAsf', class B 'AAAsf';

IBR Usage increase 50%: class A 'AAAsf', class B 'AAAsf';

Remaining Term increase 25%: class A 'AAAsf', class B 'AAAsf';

Remaining Term increase 50%: class A 'AAAsf', class B 'AAAsf'.

Factors that Could, Individually or Collectively, Lead to Positive Rating Action/Upgrade

Access Group, Inc. - Federal Student Loan Notes, Series 2004-2

Credit Stress Rating Sensitivity

Default decrease 25%: class A-4 'AAAsf', class A-5 'CCCsf', class B 'CCCsf';

Basis Spread decrease 0.25%: class A-4 'AAAsf', class A-5 'CCCsf', class B 'CCCsf'.

Maturity Stress Rating Sensitivity

CPR increase 25%: class A-4 'Asf', class A-5 'CCCsf', class B 'CCCsf';

IBR Usage decrease 25%: class A-4 'Asf', class A-5 'CCCsf', class B 'CCCsf';

Remaining Term decrease 25%: class A-4 'AAAsf', class A-5 'CCCsf', class B 'CCCsf'.

Access Funding 2015-1 LLC

Class A is rated 'AAAsf' and is at its highest attainable rating. Results shown below are for class B.

Credit Stress Rating Sensitivity

Default decrease 25%: class B 'AAAsf';

Basis Spread decrease 0.25%: class B 'AAAsf'.

Maturity Stress Rating Sensitivity

CPR increase 25%: class B 'AAAsf';

IBR Usage decrease 25%: class B 'AAAsf';

Remaining Term decrease 25%: class B 'AAAsf'.

Best/Worst Case Rating Scenario

International scale credit ratings of Structured Finance transactions have a best-case rating upgrade scenario (defined as the 99th percentile of rating transitions, measured in a positive direction) of seven notches over a three-year rating horizon; and a worst-case rating downgrade scenario (defined as the 99th percentile of rating transitions, measured in a negative direction) of seven notches over three years. The complete span of best- and worst-case scenario credit ratings for all rating categories ranges from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings are based on historical performance. For more information about the methodology used to determine sector-specific best- and worst-case scenario credit ratings, visit https://www.fitchratings.com/site/re/10111579.

CRITERIA VARIATION

The rating for class A-4 of 2004-2 is more than one category lower than the lowest model implied rating of 'Asf'. As noted in the FFELP criteria, if the final ratings are different from the model results by more than one rating category, it would constitute a criteria variation. The upgrade is limited as cash flow modelling under the maturity stress indicates that the note is paid in full on the legal final maturity date for ratings of 'BBB' and 'A'. The limited margin of safety on the repayment date expected under those levels of stress is not considerate commensurate with investment-grade ratings. Had Fitch not applied this variation, the notes could have been upgraded to 'Asf'.

USE OF THIRD PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G -10

Form ABS Due Diligence-15E was not provided to, or reviewed by, Fitch in relation to this rating action.

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF RATING

The principal sources of information used in the analysis are described in the Applicable Criteria.

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless otherwise disclosed in this section. A score of '3' means ESG issues are credit-neutral or have only a minimal credit impact on the entity, either due to their nature or the way in which they are being managed by the entity. Fitch's ESG Relevance Scores are not inputs in the rating process; they are an observation on the relevance and materiality of ESG factors in the rating decision. For more information on Fitch's ESG Relevance Scores, visit https://www.fitchratings.com/topics/esg/products#esg-relevance-scores.

Additional information is available on www.fitchratings.com

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