SMB Private Education Loan Trust 2024-C Report
SMB Private Education Loan Trust 2024-C Report
Bryan Li SMB 2024-C will use a traditional pass-through structure, with credit enhancement consisting of
Vice President subordination provided by the Class B Notes for the benefit of the Class A-1A Notes and Class A-1B
Credit Ratings - US ABS
Notes (together the Class A Notes), overcollateralization, reserve account, and excess spread.
+1 646 993-7737
[Link]@[Link]
In general, the trust will pay principal sequentially, first to the Class A-1A Notes and Class A-1B Notes
Jonathan Riber
Senior Vice President (pro rata) until the principal balance of each such class is paid in full, and then to the Class B Notes until
Credit Ratings – U.S. ABS the principal balance is paid in full.
+1 212 806-3250
[Link]@[Link]
The Morningstar DBRS provisional credit ratings on the Notes address the timely payment of interest
Stephanie Whited and the ultimate payment of principal by each class of Notes’ respective final maturity date in
Senior Vice President
US Operational Risk - Global accordance with the terms and conditions of the SMB 2024-C transaction documents.
Structured Finance
+1 212 806-3948
[Link]@[Link]
Page 2 of 21 SMB Private Education Loan Trust 2024-C | May 2, 2024
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Transaction Parties and Relevant Dates
Page 2 of 21 Issuing Entity: SMB Private Education Loan Trust 2024-C
Grantor Trust: SMB Private Education Loan Grantor Trust 2024-C
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Sponsor, Seller, Servicer, and Administrator: Sallie Mae Bank
Page 2 of 21 Depositor: SMB Education Funding, LLC
Indenture Trustee and Paying Agent: UMB Bank, N.A.
Page 2 of 21 Trustee and Grantor Trust Trustee: UMB Bank, N.A.
Delaware Trustee and Grantor Trust Delaware Trustee: UMB Delaware Inc.
Statistical Cut-Off Date: April 2, 2024
Closing Date: On or about May 15, 2024
Payment Date: Monthly, on the 15th of each month, or next business day
First Payment Date: June 17, 2024
Final Maturity Date: Class A-1A Notes: June 17, 2052
Class A-1B Notes: June 17, 2052
Class B Notes: June 17, 2052
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Considerations
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Coronavirus
Page 3 of 21 • The transaction assumptions consider Morningstar DBRS’ baseline macroeconomic scenarios for rated
sovereign economies, available in its commentary Baseline Macroeconomic Scenarios for Rated
Page 3 of 21
Sovereigns: March 2024 Update, published on March 27, 2024. These baseline macroeconomic
Page 3 of 21 scenarios replace Morningstar DBRS’ moderate and adverse coronavirus pandemic scenarios, which
were first published in April 2020.
Quality of Collateral
• SMB 2024-C is backed entirely by loans originated under SMB’s Smart Option loan program. Smart
Option loans have demonstrated default rates that are significantly lower as compared with the
Signature loans that SMB previously originated prior to mid-2009. This can be attributed primarily to
stronger underwriting guidelines and borrowers that generally are of higher credit quality.
• Approximately 18.0% of the trust student loans require at least an interest-only (IO) payment while the
borrower is enrolled in school. Approximately 35.0% of the trust student loans require a fixed monthly
payment of $25 while the borrower is enrolled in school. Smart Option loans made to borrowers who
are required to make payments while enrolled in school have performed significantly better than
Smart Option loans that do not require any student loan payments while the borrower is enrolled in
school.
• The weighted-average (WA) current FICO score of the trust student loans was 738. Private student
loans with higher FICO scores are generally expected to perform better than loans with lower FICO
scores.
• Approximately 89.5% of the trust student loans are co-signed. Private student loans with co-signers
are generally expected to experience default rates that are lower than loans without co-signers.
• Approximately 90.6% of the trust student loans were made to borrowers attending four-year schools.
Historical performance demonstrates that such loans generally have the lowest default rate compared
with loans made to borrowers attending other undergraduate school types.
• Approximately 87.0% of the trust student loans consist of loans made to borrowers attending not-for-
profit schools. Such loans have historically defaulted at much lower rates than loans made to students
attending for-profit schools.
• The SMB 2024-C student loan pool is geographically diverse. The top five states are California (9.6%),
New York (9.3%), Pennsylvania (7.5%), Texas (6.4%), and New Jersey (5.8%), which represent
approximately 38.6% of the trust student loan pool. Geographic diversity is a positive as there is less
likelihood that economic downturns concentrated in certain regions would negatively affect
performance of the trust student loan portfolio.
Page 4 of 21 SMB Private Education Loan Trust 2024-C | May 2, 2024
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Structural Features
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• Overcollateralization, note subordination, reserve account amounts, and excess spread create credit
Page 4 of 21 enhancement levels that are commensurate with the respective credit ratings for each class of Notes.
The credit enhancement levels can support the Morningstar DBRS-projected cumulative defaults and
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other cash flow assumptions under various stress scenarios, and the transaction is able to repay
Page 4 of 21 investors in accordance with the terms of the transaction documents. The credit enhancement levels
can withstand coverage of approximately 3.82 times (x) and 3.56x the Morningstar DBRS 9.05% base-
case default rate assumption in the AAA (sf) and AA (sf) breakeven cash flow stress scenarios,
respectively.
• The transaction has a sequential pay structure. No principal will be allocated to the Class B Notes until
the Class A Notes are paid in full. Payments to the Class A Notes will be made on a pro rata basis.
• To build additional credit support early in the transaction and to protect the Notes from losses on the
trust student loan pool in excess of those anticipated, the structure will incorporate a full turbo feature
whereby 100% of remaining available funds after paying senior transaction fees, Note interest, and
certain shortfalls will be used to pay principal on the Class A Notes until the Specified
Overcollateralization Amount, equal to the greater of 25.00% of the then-current pool balance or
$53,304,805 (i.e., 10% of the initial pool balance as of the Cut-Off Date) is reached.
• The Specified Overcollateralization Amount is intended to protect the Notes from losses on the
portfolio in excess of those anticipated. Until the Specified Overcollateralization Amount is met, or if
such levels are not maintained, excess cash may not be released from the trust, and it is possible that
the Class B Notes will not receive any interest payments.
• If the Specified Overcollateralization Amount has been reached, the Class A Notes may revert to full
turbo mode if the pool balance is equal to or less than 10% of the initial pool balance.
• Sequential amortization of the Notes, the overcollateralization target, the subordination of the Class B
Notes, and the reserve account are expected to create increasing credit enhancement over time for
the Class A Notes as a percentage of the outstanding pool balance.
• If the outstanding principal balance of the Class A Notes exceeds the outstanding pool balance, 100%
of remaining available funds after paying senior transaction fees and Class A Note interest will be
used to turbo principal on the Class A Notes. Interest on the Class B Notes will become subordinate to
principal payments on the Class A Notes until this trigger is cured.
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rating category, which consisted of increasing and declining forward interest rate paths for CME Term
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SOFR and 30-day average SOFR based on the Morningstar DBRS Unified Interest Rate Tool.
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Credit Enhancement
Page 5 of 21 Credit Enhancement Summary
Initial Class A Note Subordination (% of Notes) 7.61%
Page 5 of 21 Initial Class A Note Overcollateralization 15.77%
Initial Class B Note Overcollateralization 8.83%
Specified Overcollateralization Amount 25.00% of the current pool balance, subject to a floor equal
to $53,304,805.
Initial Overcollateralization Percentage 8.83% of the initial pool balance.
Specified Reserve Account Balance 0.25% of the initial pool balance at the closing date
($1,332,621), nondeclining.
Overcollateralization
• Initial overcollateralization for the Class A Notes will be 15.77%. Class A overcollateralization is defined
as the excess of the initial pool balance over the aggregate initial principal balance of the Class A
Notes divided by the initial pool balance.
• Initial overcollateralization for the Class B Notes will be 8.83%. Class B overcollateralization is defined
as the excess of the initial pool balance over the aggregate initial principal balance of the Class A
Notes and Class B Notes divided by the initial pool balance.
Note Subordination
• The Class A Notes will benefit from 7.61% initial subordination provided by the Class B Notes. Class A
Note subordination is defined as the initial Class B Note balance divided by the total Note balance.
Reserve Accounts
• A nondeclining reserve account benefiting the Notes will be funded at closing with $1,332,621
(Specified Reserve Account Balance). The reserve account will be available to pay shortfalls, if any, of
senior transaction fees, the First Priority Principal Distribution Amount, Class A Note interest, Class B
Note interest, and Note principal on the related final maturity date.
• The reserve account will be replenished to the extent the amount on deposit is less than the
requirement.
Excess Spread
• Excess spread will be used to turbo the Notes from the first payment date until the transaction reaches
its overcollateralization target. Monthly excess spread is expected to grow significantly over time as
credit enhancement levels increase and as more loans enter active repayment. Excess spread benefits
the Notes by providing cushion against shortfalls and losses.
Page 6 of 21 SMB Private Education Loan Trust 2024-C | May 2, 2024
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Note Principal and Interest
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• In general, the trust will pay principal sequentially, first to the Class A Notes (pro rata) until the
Page 6 of 21 principal balance of such class is paid in full and then to the Class B Notes until the principal balance
of such class is paid in full.
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• For the fixed-rate Notes, the first interest accrual period begins on the Closing Date and ends on June
Page 6 of 21 14, 2024. For all other monthly distribution dates, the interest accrual period will begin on the 15th day
of the month of the immediately preceding distribution date and end on the 14th day of the month of
such distribution date.
• For the floating-rate Notes, the first interest accrual period begins on the Closing Date and ends on
June 16, 2024. For all other monthly distribution dates, the interest accrual period will begin on the
immediately preceding distribution date and ends on the day before such distribution date.
• Interest will be calculated on the fixed-rate Notes based on a 30-day accrual period divided by 360
(except for the initial accrual period, which will be based on the actual number of days elapsed in a
year of 360 days consisting of 12 30-day months).
• Interest will be calculated on the floating-rate Notes based on the actual number of days elapsed in
each accrual period divided by 360.
Page 7 of 21 SMB Private Education Loan Trust 2024-C | May 2, 2024
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Collateral
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Set forth in the following tables are certain characteristics of the trust student loans as of the Statistical
Page 7 of 21 Cut-Off Date as compared with recent rated SMB transactions.
Page 7 of 21 SMB 2024-C SMB 2024-A SMB 2023-D SMB 2023-C SMB 2023-B SMB 2023-A SMB 2022-D SMB 2022-C
Statistical Cut-Off Date 2-Apr-24 1-Feb-24 16-Oct-23 5-Jul-23 3-May-23 17-Jan-23 15-Sep-22 21-Jun-22
PageAggregate
7 of 21 Principal Balance ($) 533,048,053 2,103,016,017 1,051,728,897 650,098,314 2,100,722,480 650,041,448 1,098,032,558 680,105,840
Number of Borrowers 34,974 124,722 71,756 45,051 134,029 44,462 78,312 49,312
Number of Loans 35,938 135,916 76,440 46,671 148,132 45,905 83,559 51,124
Average Balance per Borrower ($) 15,241 16,862 14,657 14,430 15,674 14,620 14,021 13,792
Fixed (%) 75.0 69.8 62.9 61.0 56.9 57.0 49.8 52.0
One-Month Libor (%) 0.0 0.0 0.0 0.0 22.9 23.0 50.2 48.0
CME Term SOFR (%) 7.0 9.0 13.9 17.7 0.0 0.0 n/a n/a
30-Day Average SOFR (%) 18.0 21.2 23.1 21.3 20.2 20.0 n/a n/a
WA Interest Rate (%) 11.48 11.36 11.46 11.26 11.20 10.86 9.98 9.30
WA Interest Rate Fixed (%) 10.77 10.40 10.13 10.04 9.88 9.87 9.77 9.73
WA Libor Margin (%) n/a n/a n/a n/a 7.86 7.83 7.76 7.78
WA CME Term SOFR Margin (%) 7.80 7.89 7.89 7.82 n/a n/a n/a n/a
WA 30-Day Average SOFR Margin (%) 8.46 8.38 8.64 8.29 8.21 8.16 n/a n/a
Co-Signer (%) 89.5 90.4 90.0 90.8 91.6 91.9 91.8 92.1
WA FICO Original 744 744 742 743 744 744 744 743
WA FICO Current 738 738 739 741 740 742 745 745
WA Remaining Term (Months) 172 170 161 159 158 160 145 145
WA Months in Active Repayment 16 14 17 16 17 15 20 19
Original FICO
< 640 (%) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
640 - 669 (%) 7.8 7.8 7.8 7.3 7.4 7.4 7.2 7.4
670 - 699 (%) 15.0 14.9 15.5 15.4 15.3 15.1 15.4 15.2
700 - 739 (%) 25.8 25.9 26.6 26.8 26.6 26.2 27.0 27.0
740+ (%) 51.3 51.4 50.1 50.6 50.8 51.4 50.4 50.3
Current FICO
< 640 (%) 5.3 5.2 5.1 4.7 4.7 4.3 4.0 4.2
640 - 669 (%) 7.4 7.4 6.3 6.2 6.6 6.3 5.0 5.4
670 - 699 (%) 13.4 13.4 13.5 12.9 12.9 12.5 11.5 11.4
700 - 739 (%) 22.7 23.3 23.5 23.5 23.7 24.0 23.5 23.5
740+ (%) 51.2 50.7 51.6 52.8 52.1 53.0 56.1 55.5
Payment Status
Active Repayment (%) 27.5 31.9 35.0 38.7 37.0 37.2 40.8 40.7
In-School (%) 54.1 52.4 40.3 39.2 48.2 48.7 35.4 35.0
Grace (%) 12.2 9.6 18.4 17.2 8.8 8.6 17.0 18.2
Deferment (%) 3.9 4.0 5.8 4.4 5.4 4.4 6.2 5.6
Forbearance (%) 2.3 2.0 0.6 0.5 0.6 1.1 0.6 0.5
Loan Program
Smart Option (Interest-Only) (%) 18.0 18.9 17.7 18.9 19.6 20.0 19.8 19.9
Smart Option ($25 Fixed Payment) (%) 35.0 35.0 35.1 34.1 34.1 34.0 33.1 33.1
Smart Option (Deferred Payment) (%) 47.0 46.1 47.1 47.0 46.2 46.0 47.1 47.0
Index
Fixed (WA Interest Rate) (%) 75.0 (10.77) 69.8 (10.40) 62.9 (10.13) 61.0 (10.04) 56.9 (9.88) 57.0 (9.87) 49.8 (9.77) 52.0 (9.73)
One-Month Libor (WA Margin) (%) n/a n/a n/a n/a 22.9 (7.86) 23.0 (7.83) 50.2 (7.76) 48.0 (8.84)
CME Term SOFR (WA Margin) (%) 7.0 (7.80) 9.0 (7.89) 13.9 (7.89) 17.7 (7.82) n/a n/a n/a n/a
30-Day Average SOFR (WA Margin) (%) 18.0 (8.46) 21.2 (8.38) 23.1 (8.64) 21.3 (8.29) 20.2 (8.21) 20.0 (8.16) n/a n/a
School Type
4-Year (%) 90.6 93.2 92.7 93.0 94.1 94.5 94.3 94.2
2-Year (%) 4.1 3.6 4.0 3.9 3.5 3.3 3.6 3.6
Proprietary/Vocational (%) 5.4 3.2 3.3 3.1 2.4 2.2 2.1 2.2
Page 8 of 21 SMB Private Education Loan Trust 2024-C | May 2, 2024
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SMB 2024-C SMB 2024-A SMB 2023-D SMB 2023-C SMB 2023-B SMB 2023-A SMB 2022-D SMB 2022-C
PageSchool
8 of 21Designation
Non-Profit (%) 87.0 90.1 89.8 89.8 92.2 92.1 91.9 91.9
PageFor-Profit
8 of 21 (%) 13.0 9.9 10.2 10.2 7.8 7.9 8.1 8.1
Current Balance
PageLess
8 ofthan
21 $25,000 (%) 60.5 59.8 65.5 64.5 64.1 64.9 63.3 67.3
$25,000 - $49,999 (%) 29.4 31.3 26.9 28.1 28.7 28.3 27.9 26.4
Page$50,000
8 of 21 - $74,999 (%) 5.9 6.1 5.1 5.2 5.4 5.0 6.2 4.5
$75,000 - $99,999 (%) 1.9 1.6 1.5 1.5 1.3 1.3 1.9 1.4
$100,000+ (%) 2.2 1.1 1.0 0.7 0.5 0.4 0.8 0.4
Remaining Term
1 – 60 (%) 1.0 1.5 2.2 2.6 2.8 2.8 3.9 4.0
61 – 120 (%) 7.6 9.8 14.0 16.4 17.7 18.2 26.8 27.9
121 – 180 (%) 44.3 45.6 47.4 47.6 45.0 44.5 43.4 44.1
181 – 240 (%) 44.8 40.7 33.8 31.1 31.9 31.6 23.1 21.3
241 – 300 (%) 2.2 2.4 2.5 2.3 2.6 2.8 2.7 2.7
301 – 360 (%) 0.1 0.0 0.1 * 0.1 0.1 0.1 0.1
361+ (%) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Disbursement Year
2009 (%) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
2010 (%) * 0.0 0.0 0.0 0.0 0.0 0.1 0.1
2011 (%) 0.1 0.0 0.1 0.1 0.1 0.1 0.2 0.2
2012 (%) 0.2 0.1 0.2 0.2 0.3 0.3 0.6 0.6
2013 (%) 0.2 0.2 0.4 0.6 0.6 0.6 1.1 1.1
2014 (%) 0.4 0.4 0.6 0.8 1.0 1.0 1.9 2.0
2015 (%) 0.6 0.6 1.1 1.3 1.7 1.7 3.0 3.4
2016 (%) 1.1 1.0 1.7 2.1 2.6 2.7 5.0 5.7
2017 (%) 1.4 1.5 2.4 3.0 3.3 3.5 6.7 7.0
2018 (%) 1.7 2.1 3.7 4.5 5.1 5.5 9.7 10.5
2019 (%) 3.2 4.2 7.5 8.6 10.0 10.7 18.5 20.7
2020 (%) 5.2 7.5 13.0 15.3 17.7 19.0 36.3 37.1
2021 (%) 15.8 21.1 39.2 43.4 46.3 47.0 17.0 11.6
2022 (%) 44.8 52.4 30.3 20.2 11.3 7.9 0.0 0.0
2023 (%) 25.3 8.9 0.0 0.0 0.0 0.0 0.0 0.0
Geographic Concentration
State 1 (%) CA 9.6 NY 9.5 NY 9.5 NY 9.2 NY 9.7 NY 9.6 NY 9.7 NY 9.7
State 2 (%) NY 9.3 CA 8.5 CA 8.8 CA 9.1 PA 8.3 PA 8.5 PA 8.3 PA 8.6
State 3 (%) PA 7.5 PA 8.1 PA 7.7 PA 8.0 CA 8.1 CA 8.0 CA 8.2 CA 8.1
State 4 (%) TX 6.4 TX 6.5 TX 6.1 NJ 6.1 NJ 6.0 NJ 6.6 NJ 6.3 NJ 6.3
State 5 (%) NJ 5.8 NJ 6.0 NJ 6.0 TX 6.0 TX 5.9 TX 5.9 TX 5.5 TX 5.6
* Represents an amount that is less than 0.05%.
Page 9 of 21 SMB Private Education Loan Trust 2024-C | May 2, 2024
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Originator
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Company Description
Page 9 of 21 Sallie Mae Bank, an industrial bank established in 2005, is a wholly owned subsidiary of Sallie Mae
Corporation. In 2014, Sallie Mae Corporation was legally separated into two distinct publicly traded
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entities: a consumer banking business (Sallie Mae Corporation and its primary operating subsidiary,
Page 9 of 21 SMB) and an education loan management, servicing, and asset recovery business (Navient Corporation).
SMB, which is regulated by the Utah Department of Financial Institutions, the Federal Deposit Insurance
Corporation, and the Consumer Financial Protection Bureau, originates private student loans in addition
to offering traditional savings products, such as savings accounts, money market accounts, and
certificates of deposit. In addition to private student loans, SMB holds and manages pools consisting of
Federal Family Education Loan Program loans.
SMB’s private student loans are primarily originated under its Smart Option program. The Smart Option
program was launched in 2009 and initially included an IO payment option (while the student is enrolled
in school and during the grace period) that emphasized reduced total finance charges. Shortly after the
IO loan was introduced, SMB began offering a fixed-pay option allowing for minimum monthly payments
of $25 while the student is enrolled in school and during the grace period. A third repayment option
offered by SMB under its Smart Option program is the more traditional deferred product where
borrowers are not required to make payments while the student is in school and during the grace period.
The Smart Option program has stricter borrower requirements as compared with SMB’s previous
Signature Loan program that it replaced. While Signature loans were underwritten based primarily on
FICO score, the Smart Option program expanded the scope of the credit and underwriting review,
placing more of an emphasis on factors influencing applicants’ ability and willingness to repay their
debt. In addition to a minimum FICO score, the Smart Option credit underwriting strategy uses a custom
scorecard model and overlay criteria for decline and additional review decisions.
SMB will act as the servicer of the SMB 2024-C transaction. Under the servicing agreement, SMB will be
responsible for servicing the trust student loans, maintaining custody of the trust student loans and
remitting collections to the transaction’s collection account for the life of SMB 2024-C. SMB will agree to
service the trust student loans on the same terms as it services substantially similar loans owned by
SMB.
Page 10 of 21 SMB Private Education Loan Trust 2024-C | May 2, 2024
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Transaction Structure
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Structural Summary
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Priority of Payments
Available Funds
Available funds will generally equal the sum of the following:
1. Amounts received as interest and principal payments with respect to the trust student loans.
2. Any recoveries from charged off trust student loans.
3. Proceeds from any sale of trust student loans.
4. Any amounts received as investment earnings in the trust accounts.
5. Specified Reserve Account Balance amounts, if any.
6. Amounts received from SMB upon repurchase of trust student loans.
Priority of Payments
On each payment date, available funds will be applied in the following order of priority:
1. Pro rata, fees to the Indenture Trustee, Trustee, Grantor Trust Trustee, Delaware Trustee, and
Grantor Trust Delaware Trustee (including extraordinary expenses up to $150,000 per annum).
2. Servicing Fee.
3. Administration Fee (including any unreimbursed Administrator Advances up to $50,000 per annum).
4. Interest due on the Class A Notes, pro rata.
5. First Priority Principal Distribution Amount (if any) to the Class A Notes (pro rata) until paid in full.
6. Interest due on the Class B Notes.
7. To increase the reserve account balance up to the Specified Reserve Account Balance, if applicable.
Page 11 of 21 SMB Private Education Loan Trust 2024-C | May 2, 2024
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8. Regular Principal Distribution Amount, first to the Class A Notes (pro rata) until paid in full and then
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to the Class B Notes until paid in full.
Page 11 of 21 9. Carryover servicing fees, if any.
10. Additional Principal Distribution Amount, if any, first to the Class A Notes (pro rata) until paid in full
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and then to the Class B Notes until paid in full.
Page 11 of 21 11. Pro rata, any unpaid fees and expenses to the Indenture Trustee, Trustee, Grantor Trust Trustee,
Delaware Trustee, and Grantor Trust Delaware Trustee.
12. To the Administrator, any unpaid fees and expenses.
13. To the R Certificateholders, any remaining amounts.
The First Priority Principal Distribution Amount is the amount by which the outstanding principal
balance of the Class A Notes exceeds the current pool balance.
The Regular Principal Distribution Amount is the amount by which the outstanding principal balance of
the Notes exceeds the current pool balance less the Specified Overcollateralization Amount of 25.00%
(subject to a floor of $53,304,805).
Once the transaction’s pool factor is equal to or less than 10% and the trust has not exercised its
optional redemption right, the Additional Principal Distribution Amount is the amount equal to the
Page 12 of 21 SMB Private Education Loan Trust 2024-C | May 2, 2024
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lesser of (1) 100% of the available funds after steps 1 to 9 of the priority of payments and (2) the
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aggregate outstanding principal balance of the Notes.
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Events of Default
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The transaction will include standard events of default (EODs) that contain cure periods and call for the
Page 12 of 21 sale of the assets of the trust and acceleration of the repayment of the principal balance of the Notes.
The key inputs of the cash flow modeling that were analyzed include the following:
• Defaults
• Timing of defaults
• Recoveries
• Prepayments
• Forbearances and deferments
• Borrower benefits
• Basis risk
• Transaction fees
Morningstar DBRS evaluated a total of 20 cash flow scenarios to test each class of Notes. As indicated
in the table below, a baseline of three prepayment scenarios and three default timing curves were
applied to test the resilience of the rated Notes. Additionally, two maturity stress scenarios were
evaluated to test whether the Notes receive their ultimate principal amount by their respective final
maturity dates. The stressed cash flows were modeled based on two interest rate paths: an upward
vector and a downward vector. In each of the stressed cash flow scenarios, the Class A Notes and Class
B Notes received timely payment of interest and the ultimate payment of principal by their respective
final maturity dates.
Page 13 of 21 SMB Private Education Loan Trust 2024-C | May 2, 2024
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20 Cash Flow Scenarios Applied by Morningstar DBRS
Page 13 of 21 Morningstar DBRS Prepayments (CPR %) Loss Timing Interest Rate Stress
Cash Flow Scenario
Page 13 of 21 1–3 4/5/6/8/10 thereafter, 5, 10 Front-loaded Upward
4–6 4/5/6/8/10 thereafter, 5, 10 Mid-loaded Upward
Page 13 of 21 7–9 4/5/6/8/10 thereafter, 5, 10 Back-ended Upward
10 – 12 4/5/6/8/10 thereafter, 5, 10 Front-loaded Downward
Page 13 of 21 13 – 15 4/5/6/8/10 thereafter, 5, 10 Mid-loaded Downward
16 – 18 4/5/6/8/10 thereafter, 5, 10 Back-ended Downward
19 No Prepayments No Defaults Upward
20 No Prepayments No Defaults Downward
Defaults
For the trust student loans, Morningstar DBRS derived a base-case cumulative default expectation
primarily based on an analysis of historical static pool default data. Morningstar DBRS used static pool
default data from SMB’s Smart Option loan program. The static pool default data was segregated by
loan type, school type, co-signer status, and FICO bucket. Morningstar DBRS analyzed this data to
determine a cumulative default estimate for each of the aforementioned distinct components of the
proposed securitization pool and then developed a seasoning adjusted WA default expectation based
upon the relative contribution of each segment. The Morningstar DBRS analysis of the trust student
loans results in a base-case cumulative default rate expectation for SMB 2024-C of 9.05%.
The resulting stress level default rates are 29.410% for AAA (sf) and 22.625% for AA (sf). This represents
a multiple of approximately 3.250x for AAA (sf) and 2.500x for AA (sf) of the Morningstar DBRS base-
case cumulative default rate expectation for the SMB 2024-C pool.
Timing of Defaults
To test the sensitivity of the SMB 2024-C cash flow structure, various default timing curves were
modeled, including front-loaded, mid-loaded, and back-ended defaults. The timing of defaults reflects
the potential for various economic conditions and applies a high level of stress on the transaction’s cash
flows to test the resilience of the rated Notes. While traditional unseasoned private student loan
securitizations have experienced front-loaded gross defaults whereby as much as 50% of collateral
defaults have occurred by the third year of repayment, Morningstar DBRS expects a flatter default curve
for this transaction because of the quality of the pool as it relates to seasoning, borrower credit, loan
type, school type, and repayment type.
Page 14 of 21 SMB Private Education Loan Trust 2024-C | May 2, 2024
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Recoveries
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The cumulative recovery rate on defaulted loans was assumed to be 15.0% for AAA (sf) and 17.5% for
Page 14 of 21 AA (sf). Recoveries were applied to the cash flow stresses in equal amounts over a 10-year period and
after a six-month lag from the period of borrower default. Recovery assumptions were determined based
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on an analysis of historical data from seasoned Sallie Mae private student loan securitizations, which
Page 14 of 21 demonstrate cumulative recoveries of about 25% to 30% after 10 years from default.
Prepayments
Morningstar DBRS formulated voluntary prepayment rate speed assumptions by evaluating historical
prepayment speed data. Student loan prepayment behavior is mainly influenced by the economic
environment, prevailing interest rates, consolidation options, and loan seasoning. Also contributing to
prepayment speeds will likely be the relatively new and fast-growing student loan refinance market.
While refinance lenders primarily focus on employed borrowers with strong credit and earnings profiles,
it is likely that many of the SMB 2024-C borrowers will eventually qualify for a refinance loan with more
favorable terms. Further, if interest rates rise, or if borrowers anticipate higher interest rates in the
future, borrowers with existing variable-rate loans may seek to refinance into a fixed-rate loan.
Various prepayment scenarios were applied to test the resilience of the Notes. Varying prepayment rates
can provide some indication of how the student loan collateral might perform under unexpected
circumstances and different economic environments. While faster-than-expected prepayments may
decrease credit risk because the securitization trust is exposed to a shorter period of default risk, at the
same time, faster prepayments may lower the amount of excess spread generated by the underlying
collateral, thus reducing the amount of credit enhancement that can be used to absorb losses. Three
prepayment speed assumptions were applied for the nonmaturity cash flow stress scenarios. This
included two flat prepayment assumptions of 5% and 10% constant prepayment rate (CPR), as well as a
ramp of 4% to 10% CPR.
Morningstar DBRS stressed forbearances and deferments concurrently to test the transaction’s ability to
absorb liquidity stresses. In each case, the maximum allowable forbearance and deferment periods were
assumed. The forbearance and deferment assumptions used were 20.0% and 20.0%, respectively, for
the AAA (sf) cash flow stress scenarios and 17.5% and 17.5%, respectively, for the AA (sf) cash flow
stress scenarios. Forbearances and deferments were stressed for 24 months and 48 months,
respectively.
While forbearance and deferment cash flow stresses test a transaction’s liquidity, forbearances and
deferments may create additional credit enhancement to a structure because capitalized interest that
accrues during the forbearance and deferment period is added to the principal balance of the loan. To
Page 15 of 21 SMB Private Education Loan Trust 2024-C | May 2, 2024
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account for this, Morningstar DBRS applied forbearance and deferment assumptions of 0% and 0%,
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respectively (except for loans already in these statuses), under its most constraining cash flow scenario.
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Borrower Benefits
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Each trust student loan may benefit from a certain interest rate reduction for borrowers that arrange to
Page 15 of 21 have their loan payments automatically withdrawn from a bank account. This reduction is lost for
periods in which the borrower does not actually have loan payments automatically withdrawn. In the
Morningstar DBRS stressed cash flow scenarios, it was assumed that 50% for AAA (sf) and 45% for AA
(sf) of the SMB 2024-C eligible borrowers utilize automatic withdrawal.
Basis Risk
The Notes will be exposed to basis risk because the trust student loan pool pays interest based on both
variable rates (25.0% of the student loan pool) and fixed rates (75.0% of the student loan pool) and each
class of Notes will have a fixed rate, or in the case of the Class A-1B Notes, a floating rate. Further, the
floating-rate Notes will adjust based on 30-day average SOFR, while the variable-rate loans pay interest
based on CME Term SOFR or 30-day average SOFR. To test this basis risk, in its stressed cash flow
scenarios, Morningstar DBRS assumed two stressed interest rate environments for each credit rating
category, which consisted of increasing and declining forward interest rate paths for CME Term SOFR
and 30-day average SOFR based on the Morningstar DBRS Unified Interest Rate Tool.
Transaction Fees
Transaction fees were included in the cash flow stresses at their contractual or maximum allowable
amounts. Please see Appendix A for more detail on transaction fees.
Maturity Stresses
In order to test the ability of the transaction to redeem the Notes before their respective final maturity
dates, maturity stress scenarios were run whereby it was assumed that zero defaults occur, there are
zero prepayments, and deferments and forbearances occur consecutively, rather than concurrently.
Breakeven Stresses
In addition to the cash flow scenarios discussed, breakeven cash flows stresses were performed that
maximized cumulative defaults (until the first dollar of Note defaults) while keeping all other AAA (sf)
and AA (sf) assumptions the same. Based on the most constraining cash flow scenario, the transaction is
able to withstand cumulative defaults of approximately 34.57% for AAA (sf) and 32.23% for AA (sf). This
represents a multiple of approximately 3.82x for AAA (sf) and 3.56x for AA (sf) of the Morningstar DBRS
base-case cumulative default rate expectation for the SMB 2024-C pool.
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Legal Structure and Opinions
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SMB 2024-C is expected to be a special-purpose entity structured to be bankruptcy remote by restricting
Page 16 of 21 the Issuer’s operations so that it does not engage in business with or incur liabilities to any other entity,
which may bring bankruptcy proceedings against the Issuer.
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Page 16 of 21 Morningstar DBRS expects to receive an opinion of counsel to the effect that the transfer of the loans to
the trust constitutes a true sale and that the trust assets will not be consolidated with those of SMB in
the event of bankruptcy. Additionally, Morningstar DBRS expects to receive an opinion of counsel that
the trustee has a first-perfected security interest in the trust assets.
Morningstar DBRS expects to receive an opinion of counsel to the effect that the Notes will (or should)
be treated as debt for federal income tax purposes, rather than as an interest in the loans and other
assets of the trust or as an equity interest in the Issuer.
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Appendix A — Cash Flow Details
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Capital Structure
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Class Size ($) Collateral Hard Credit Coupon (%) Multiple Range Morningstar Credit Rating Constraining Scenario
(%) Enhancement (x) DBRS
(%) Multiple (x)
A-1A* 16.02 [TBD] 3.00 - 4.50 3.250 AAA (sf) Default Curve 2/10% CPR/Down
449,000,000 84.23
16.02 SOFR + [TBD] 3.00 - 4.50 3.250 AAA (sf) Default Curve 2/10% CPR/Down
A-1B*
B 37,000,000 6.94 9.08 [TBD] 2.25 - 3.25 2.500 AA (sf) Default Curve 2/10% CPR/Down
Total 486,000,000 91.17
OC 47,048,053 8.83
* The allocation of the aggregate initial principal balance of the Class A Notes between the Class A-1A Notes and the Class A-1B Notes will be determined on or before the date of pricing. The
aggregate initial principal balance of the Class A Notes will be equal to $449,000,000, of which the issuing entity expects that the initial principal balance of the Class A-1B Notes will be an amount not
less than $100,000,000 and not more than $150,000,000.
Default Curves Default Curve 1 (%) Default Curve 2 (%) Default Curve 3 (%)
Co-signed Non-co-signed
Year 1 15 20 20 12.5
Year 2 15 20 20 12.5
Year 3 15 10 20 12.5
Year 4 15 10 20 12.5
Year 5 10 10 20 12.5
Year 6 10 10 12.5
Year 7 10 10 12.5
Year 8 10 10 12.5
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Appendix B — Environmental, Social, and Governance
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(ESG) Considerations
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N N
Environmental Overall:
Emissions, Effluents, Do the costs or risks result in a higher default risk or lower recoveries for the securitized assets?
N N
and Waste
Carbon and GHG Costs Do the costs or risks related to GHG emissions result in higher default risk or lower recoveries of
N N
the securitized assets?
Are there potential benefits of GHG-efficient assets on affordability, financeability, or future
N N
values (recoveries)?
Carbon and GHG Costs: N N
Climate and Are the securitized assets in regions exposed to climate change and adverse weather events
N N
Weather Risks affecting expected default rates, future valuations, and/or recoveries?
N N
Social Overall:
Social Impact of Do the securitized assets have an extraordinarily positive or negative social impact on the
Products and borrowers and society, and do these characteristics of these assets result in different default N N
Services rates and/or recovery expectations?
Does the business model or the underlying borrower(s) have an extraordinarily positive or
negative effect on their stakeholders and society, and does this result in different default rates N N
and/or recovery expectations?
Considering changes in consumer behavior or secular social trends: does this affect the default
N N
and/or loss expectations for the securitized assets?
Social Impact of Products and Services: N N
Human Capital and Are the originator, servicer, or underlying borrower(s) exposed to staffing risks and could this
N N
Human Rights have a financial or operational effect on the structured finance issuer?
Is there unmitigated compliance risk due to mis-selling, lending practices, or work-out procedures
that could result in higher default risk and/or lower recovery expectations for the securitized N N
assets?
Human Capital and Human Rights: N N
Product Does the originator’s, servicer’s, or underlying borrower(s)’ failure to deliver quality products and
Governance services cause damage that may result in higher default risk and/or lower recovery expectations N N
for the securitized assets?
Data Privacy and Does the originator’s, servicer’s, or underlying borrower(s)’ misuse or negligence in maintaining
Security private client or stakeholder data result in the risk of financial penalties or losses to the issuer? N N
N N
Governance Overall:
Corporate / Does the transaction structure affect the assessment of the credit risk posed to investors due to a
Transaction lack of appropriate independence of the issuer from the originator and/or other transaction N N
Governance parties?
Considering the alignment of interest between the transaction parties and noteholders: does this
affect the assessment of credit risk posed to investors because the alignment of interest is N N
inferior or superior to comparable transactions in the sector?
Does the lack of appropriately defined mechanisms in the structure on how to deal with future
N N
events affect the assessment of credit risk posed to investors?
Considering how the transaction structure provides for timely and appropriate performance and
asset reporting: does this affect the assessment of credit risk posed to investors because it is N N
inferior or superior to comparable transactions in the sector?
* A Relevant Effect means that the impact of the applicable ESG risk factor has not changed the rating or rating trend on the issuer.
A Significant Effect means that the impact of the applicable ESG risk factor has changed the rating or trend on the issuer.
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Environmental
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There were no environmental factors that had a relevant or significant effect on the credit analysis. For
Page 19 of 21 more details about which environmental factors could have an effect on the credit analysis, please refer
to the checklist above.
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Page 19 of 21 Social
There were no social factors that had a relevant or significant effect on the credit analysis. For more
details about which social factors could have an effect on the credit, please refer to the checklist above.
Governance
There were no governance factors that had a relevant or significant effect on the credit analysis. For
more details about which governance factors could have an effect on the credit analysis, please refer to
the checklist above.
The above ESG discussion relates to credit risk factors that could affect the Issuer's credit profile and,
therefore, the credit ratings of the notes. They are separate from ESG sustainability factors, which are
generally outside the scope of this analysis. A description of how Morningstar DBRS considers ESG
factors within the Morningstar DBRS analytical framework can be found in the Morningstar DBRS
Criteria: Approach to Environmental, Social, and Governance Risk Factors in Credit Ratings at
[Link]
Page 20 of 21 SMB Private Education Loan Trust 2024-C | May 2, 2024
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Appendix C—Scope and Meaning of Financial
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Obligations
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Morningstar DBRS' credit ratings on the Class A-1A, Class A-1B, and Class B Notes address the credit
risk associated with the identified financial obligations in accordance with the relevant transaction
documents. For information on the associated financial obligations, please refer to the corresponding
press release published for this credit rating action.
Morningstar DBRS' credit ratings do not address nonpayment risk associated with contractual payment
obligations contemplated in the applicable transaction documents that are not financial obligations. The
associated contractual payment obligation that is not a financial obligation for each of the rated notes is
the related interest on any unpaid Noteholders’ Interest Distribution Amount.
Morningstar DBRS' long-term credit ratings provide opinions on risk of default. Morningstar DBRS
considers risk of default to be the risk that an issuer will fail to satisfy the financial obligations in
accordance with the terms under which a long-term obligation has been issued. The Morningstar DBRS
short-term debt rating scale provides an opinion on the risk that an issuer will not meet its short-term
financial obligations in a timely manner.
Notes:
All figures are in U.S. dollars unless otherwise noted.
This report is based on information as of May 2, 2024. Subsequent information may result in material changes to the credit rating assigned herein
and/or the contents of this report.
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About Morningstar DBRS
Page 21 of 21 Morningstar DBRS is a full-service global credit ratings business with approximately 700 employees around the world. We’re a market leader in
Canada, and in multiple asset classes across the U.S. and Europe.
Page 21 of 21
We rate more than 4,000 issuers and nearly 60,000 securities worldwide, providing independent credit ratings for financial institutions, corporate and
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and tech-forward approach.
Page 21 of 21
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