Fitch Ratings has assigned ratings and Rating Outlooks to the class A notes from Navient Private Education Refi Loan Trust 2020-H (NAVSL 2020-H).

RATING ACTIONS

ENTITY/DEBT	RATING		PRIOR

Navient Private Education Refi Loan Trust 2020-H

Class A 63935BAA1

LT	AAAsf 	New Rating		AAA(EXP)sf

Class B 63935BAB9

LT	NRsf 	New Rating		NR(EXP)sf

VIEW ADDITIONAL RATING DETAILS

TRANSACTION SUMMARY

Earnest Operations, LLC, an indirect subsidiary of Navient Corporation, the largest acquirer and servicer of education loans in the U.S., originated the underlying pool of loans in 2019-2020. NAVSL 2020-H is the fourth private student loan refinancings (refi PSL) transaction sponsored by Navient and rated by Fitch, and was structured to comply with requirements under the Term Asset-Backed Securities Loan Facility (TALF) provided by the Federal Reserve Bank of New York.

KEY RATING DRIVERS

Improved Collateral Quality; Lower Expected Defaults: As of the Sept. 23, 2020 statistical cutoff date, the weighted average (WA) FICO score at origination was 777; the WA borrower income was $159,367; and the WA period since graduation at origination was 64 months; all of which have improved from the 2020-G pool. Given the stronger collateral quality and declining levels of coronavirus forbearances, Fitch lowered its base case cumulative default assumption to 3.00% for 2020-H from 3.25% in 2020-G.

While the Earnest program has not undergone any prolonged period of prior economic stress, and defaults are minimal to date, Fitch relied on proxy data sourced from peer refi PSL lenders, Navient's non-refi PSL program and Navient's legacy refi PSL program with loans originated between 2006 and 2008 to derive its default assumption.

Fitch applied a stress multiple of 4.50x at the 'AAAsf' stress level, mainly reflecting the low absolute level of assumed base case defaults and higher expected volatility around assumptions derived via proxy data. A base case recovery rate of 20% (14% at AAAsf) is assumed based on recoveries observed on Navient's non-refi PSL ABS transactions and managed book.

Credit Enhancement Sufficient at 'AAAsf' Stresses: The initial credit enhancement (CE) for class A notes, excluding the reserve account, is expected to be 10.75%, up from 9.50% in 2020-G. Transaction cash flows were satisfactory under all stressed scenarios at Fitch's 'AAAsf' rating category. CE is provided by overcollateralization (OC) and excess spread and, for class A notes, the subordination of class B notes and the class A reserve account. Funds cannot be released from the trust unless the OC (excluding the reserve account) builds up from the initial 3.74% to 5.50% of the outstanding pool balance or 1.50% of the initial pool balance, whichever is higher.

Liquidity support, as well CE at maturity or when sufficient to redeem the notes, for class A is provided by a dedicated reserve account, which will be fully funded at closing and maintained at 0.25% of the initial class A balance.

Coronavirus Pressure Continues: Fitch made assumptions about the spread of coronavirus and the economic impact of the related containment measures. Fitch's baseline scenario assumes that the global recession that took hold in 1H20 and subsequent activity bounce in 3Q20 is followed by a slower recovery trajectory from 4Q20 onward with GDP remaining below its 4Q19 level for 18-30 months. Under this scenario, when setting base case default assumptions for NAVSL 2020-H, Fitch reviewed: (i) recessionary default vintages from Navient's legacy refi PSL and non-refi PSL programs; (ii) loan and borrower characteristics, which should be supportive during short-term performance weakness; and (iii) the servicer's business continuity plan to minimize disruptions in the collection process during the pandemic.

As a downside (sensitivity) macroeconomic scenario (see Rating Sensitivities), Fitch considers a more severe and prolonged period of stress with recovery to pre-crisis GDP levels delayed until around the middle of the decade. Under the downside case, Fitch completed a rating sensitivity by doubling the initial base case loss assumption. Under this sensitivity scenario, the notes could experience a model-implied downgraded of one rating category.

Strong Servicing Support: Navient Solutions, LLC, a wholly owned subsidiary of Navient, will service all the loans in the NAVSL 2020-H trust. Fitch has reviewed the servicing operations of Navient Solutions, and considers it to be an adequate PSL servicer. The servicer has enacted necessary health safety measures that allow employees to work remotely if their function permits during the coronavirus pandemic. Fitch reviewed the servicer's business continuity plan to minimize disruptions in the collection process and concluded that no material impact is expected on transaction performance.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to positive rating action/upgrade:

An upside scenario was not run as an improved performance on the underlying collateral would not result in an upgrade due to the notes being at their highest achievable rating of 'AAAsf'.

Factors that could, individually or collectively, lead to negative rating action/downgrade:

As Fitch's base case default proxy is derived primarily from historical collateral performance, actual performance may differ from the expected performance, resulting in higher loss levels than the base case. This will result in a decline in available CE and the remaining loss coverage levels available to the notes. Therefore, note ratings may be susceptible to potential negative rating actions, depending on the extent of the decline in the coverage.

Under Fitch's Coronavirus Downside Scenario, Fitch considers a more severe and prolonged period of stress with a halting recovery beginning in 2Q21. To reflect this greater stress, Fitch requested cash flows where the base case default assumption was increased by about 40%.

Under this scenario, the results indicate the class A notes could be downgraded by at least one rating category.

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.

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as prepared by KPMG LLP. The third-party due diligence described in Form 15E focused on 359 loans from the referenced pool and compared or re-computed certain details such as loan balance, interest rate, maturity date, school type, school degree and FICO score. Fitch also received Form 15E providing an evaluation of compliance with the requirements of the TALF Underlying Assets Eligibility Criteria, with respect to 60 loans from the referenced pool. Fitch considered this information in its analysis and it did not have an effect on Fitch's analysis or conclusions.

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.

REPRESENTATIONS, WARRANTIES AND ENFORCEMENT MECHANISMS

A description of the transaction's representations, warranties and enforcement mechanisms (RW&Es) that are disclosed in the offering document and which relate to the underlying asset pool is available by clicking the link to the Appendix. The appendix also contains a comparison of these RW&Es to those Fitch considers typical for the asset class as detailed in the Special Report titled 'Representations, Warranties and Enforcement Mechanisms in Global Structured Finance Transactions'.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of ESG credit relevance is a score of '3'. This 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. For more information on Fitch's ESG Relevance Scores, visit www.fitchratings.com/esg

Additional information is available on www.fitchratings.com

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