Ratings Detail

Rationale

The ratings assigned to Education Funding Trust 2018-A-GS's (EFT 2018-A-GS's) post-graduate loan asset-backed exchange notes reflect our view of:

• The approximately 13.0% credit support available (including excess spread), based on our 'AAA' break-even cash flow scenarios. The credit support is defined as the maximum net loss rate our 'AAA' break-even cash flow scenarios could withstand while still making interest payments on every distribution date and full principal payments by the legal maturity. These credit support level provides coverage of approximately 7.1x our 1.5%-2.0% base-case net loss assumption in the 'AAA' break-even cash flow scenarios.
• The actual performance of the outstanding SoFi student loan transactions issued in 2017-2019. These transactions' cumulative defaults to date are below our expected default rate assumptions (see the Securitization Performance section).
• Our base-case default rate assumption of 2.45%, which we increased from 2.25% used in the previous SoFi transactions prior to the COVID-19 pandemic to account for the uncertain COVID-19 macroeconomic environment that these student loan borrowers will continue to be exposed to (see the Credit Analysis section for more details). This default assumption also accounts for the 2018-A-GS's portfolio forbearance level (13.6%), which is partially offset by the portfolio seasoning level (weighted average of 19.5 months). Accordingly, our 'AAA' cumulative default rate assumption increased to 12.25% from 11.25%.
• The fact that approximately 44% of the 2018-A-GS portfolio as of the cut-off date consisted of loans to medical and healthcare professionals (including approximately 40% to those with advanced medical and healthcare degrees and approximately 4% to those with undergraduate degrees). While we generally expect these obligors will recover quickly once stay-at-home requirements are relaxed, we acknowledge that different medical subsectors will see variance in the time it takes to return to their pre-COVID-19 level of business.
• The current 2018-A-GS portfolio's characteristics as of the June 3, 2020, cut-off date, including a weighted average FICO score of 764, a weighted average gross income of $185,032, and a weighted average monthly free cash flow of $7,773. Approximately 69% of the portfolio consists of loans to advanced-degree holders, who have historically experienced lower unemployment levels than undergraduate degree holders during prior economic downturns. The advanced-degree-holders percentage includes the PLUS loans' borrowers who disclosed their degrees.
• The turbo principal payment structure that allocates all available funds to pay principal sequentially after senior fees, interest, and reserve replenishment (if required).
• Detailed loan-level data, which allowed for a more in-depth analysis of the obligor characteristics, including their employment industries.
• Social Finance Inc.'s (SoFi's) business continuity plan that the company put in place in March 2020 ensuring full operational capacity.
• The moderately low level of servicing intensity, given the collateral pool's strong credit profile and the fact that approximately 76% of the pool's loan payments are made by automated account debit via Automated Clearing House as of the June 3, 2020, cut-off date. We continue to model combined servicing and administration fees of 0.49% (instead of 0.30% specified in the indenture) to address the risk of increased servicing costs during an economic downturn.
• The servicer, The Higher Education Loan Authority of the State of Missouri (MOHELA), a public instrumentality of Missouri. MOHELA provides full-service private student loan servicing and federal loan servicing for its own student loans and those owned by third parties. In March 2020, MOHELA has added 26 employees to the SoFi servicing team to handle an increased number of calls.
• The timely interest and principal payments made by the final maturity dates in 'AAA' stress cash flow scenarios.
• A sensitivity scenario analysis indicating that under moderately stressful economic conditions (defined as about 2.25x our base-case default assumption), the 'AAA' ratings would not decline more than one rating category in the first year, which is consistent with our credit stability criteria.
• The transaction's payment and legal structures.

S&P Global Ratings acknowledges a high degree of uncertainty about the evolution of the coronavirus pandemic. The consensus among health experts is that the pandemic may now be at, or near, its peak in some regions but will remain a threat until a vaccine or effective treatment is widely available, which may not occur until the second half of 2021. We are using this assumption in assessing the economic and credit implications associated with the pandemic (see our macroeconomic and credit updates at www.spglobal.com/ratings). As the situation evolves, we will update our assumptions and estimates accordingly.

In addition to cash flow runs incorporating stressed levels of forbearance and deferral, all of which paid timely interest and principal payments by the legal final maturity date, we conducted a further liquidity analysis to assess the effects of a temporary decrease in loan principal and interest payments over the next several months as a result of COVID-19 pandemic effects. Based on this analysis, we believe the transaction has sufficient liquidity to cover its bond interest and expenses over this time period. We are monitoring government proposals being discussed, which are intended to provide relief to student loan obligors and would either reduce or temporarily delay obligors' student loan payments. We will continue to monitor these proposals as they develop and assess their impact on the transaction.

Significant Changes From SoFi 2020-C

The EFT 2018-A-GS transaction was issued as unrated exchange notes in November 2018. According to the indenture, the class E holder has an option to request ratings on one or more note classes (a ratings trigger event). In March 2020, such ratings trigger event occurred. The class E holder elected to obtain ratings on classes A, B, C, and D.

Structural changes from the SoFi 2020-C transaction include that:

• The EFT 2018-A-GS transaction consists of exchange notes that can be exchanged for one of the pre-determined combinations of the securities set forth in the indenture.
• The EFT 2018-A-GS security holders currently hold four fixed-rate note classes (A, B, C, and D) and an interest bearing residual certificate class (E). The 2020-C transaction consisted of three fixed-rate classes (A1-FX, A2-FX, and B).
• The 2018-A-GS rated classes' subordination as of July 14, 2020, is significantly higher than the initial class A subordination in the 2020-C transaction (5.5% of the pool balance), with class A at 33.27%, class B at 25.48%, class C at 17.69%, and class D at 9.89%.
• There has been no overcollateralization (O/C) under class E in the EFT 2018-A-GS since the closing date. Class E currently represents approximately 9.9% of the aggregate security balance. The SoFi 2020-C transaction has an initial O/C of 3.52% of the pool balance.
• Unlike typical rated securitizations from SoFi, where the principal distribution amount first builds and then maintains a target O/C, the EFT 2018-A-GS transaction has been in a turbo mode since its closing date where all available funds remaining after the payments of senior fees, interest, and reserve replenishment (if required) are applied sequentially to the principal balance of the most senior class outstanding until it is paid in full.
• The EFT 2018-A-GS reserve account was set up at closing but remained unfunded. Upon the ratings trigger event in March 2020, the reserve account was fully funded. Its required balance is equal to the 0.25% of the outstanding rated note balance subject to a floor of $653,533 (approximately 0.15% of the rated note balance as of March 2020). The SoFi 2020-C reserve account for the class A notes was funded at closing. Its required balance was 0.25% of the outstanding class A note balance and subject to a floor equal to 0.15% of the initial class A note balance.
• Following the issuance of the notes at closing, Goldman Sachs Bank USA, a majority-owned affiliate of the sponsor, retained an uncertificated interest (the retained interest) representing the right to receive 5.0% of all amounts collected on the portfolio loans (after such amounts are applied in part to pay a pro rata portion of the senior transaction fees and subordinate transaction fees) and distributable on each monthly payment date. In the previous transaction, the retained interest was held by SoFi.

Collateral composition changes from the SoFi 2020-C collateral pool include that:

• The EFT 2018-A-GS pool includes 13.6% of loans in forbearance as of June 3, 2020, cut-off date. The SoFI 2020-C pool did not have any loans in forbearance as of the closing date.
• The current EFT 2018-A-GS pool has a weighted average seasoning of 19.5 months. The SoFI 2020-C transaction has a weighted average seasoning of 2.6 months as of its cut-off date.
• The weighted average FICO score of the pool slightly decreased to 764 from 772.
• The weighted average borrower income increased to $185,032 from $152,821.
• The average loan balance decreased to $59,850 from $68,357.
• The concentration of medical and dental resident refinance loans increased to 5.20% of the pool from 3.67%.
• The concentration of advanced medical and health care degrees (including residents) increased to 40.2% from 32.8%. These advanced degrees include medicine (MD and DO), dental, pharmacy (Pharm.D.), nursing, other medical sciences (MS or MA or higher), occupational therapy (MS, MA, or higher), physical therapy (MPT or DPT), and physician assistant (MPA). The concentration of undergraduate medical and health care degrees decreased to 4.1% from 4.8%.

Transaction Summary

The EFT 2018-A-GS transaction incorporates the following structural features:

• The EFT 2018-A-GS transaction issued unrated exchange notes in November 2018. The transaction's indenture permits the 2018-A-GS exchange notes to be exchanged for one of several pre-determined combinations of the securities after closing.
• The EFT 2018-A-GS security holders currently hold four fixed-rate classes (A, B, C, and D) and one interest-bearing residual certificate (class E).
• Class E provides approximately 9.9% subordination for more senior note classes as of July 14, 2020. Class E will receive principal payments only after all other securities have been paid in full.
• The transaction's fully sequential turbo principal payment structure since its closing date where all available funds remaining after the payments of senior fees, interest, and reserve replenishment (if required) are applied sequentially to the most senior class outstanding until it is paid in full.
• The EFT 2018-A-GS reserve account was set up at closing but remained unfunded. Upon the ratings trigger event in March 2020, the reserve account was fully funded. Its required balance is equal to 0.25% of the outstanding rated note balance and is subject to a floor of $653,533 (approximately 0.15% of the rated note balance as of March 2020). The funds in the reserve accounts are replenishable according to the payment priority described below.
• Following the issuance of the notes at closing, Goldman Sachs Bank USA, a majority-owned affiliate of the sponsor, retained an uncertificated interest (the retained interest) representing the right to receive 5.0% of all amounts collected on the portfolio loans (after such amounts are applied in part to pay a pro rata portion of the senior transaction fees and subordinate transaction fees) and distributable on each monthly payment date.

Payment Structure

Available funds (consisting primarily of collections and recoveries with respect to the portfolio loans and investment earnings on such amounts and including other amounts payable into the distribution account) will be allocated as retained interest available funds in an amount equal to 5.0% such available funds and notes available funds in an amount equal 95.0% of such available funds.

The retained interest available funds will not be available to satisfy any amounts due and payable to the noteholders, and the notes available funds will not be available to satisfy any amount due and payable to the retained interest holder.

The issuer has been making payments on the notes in the following priority (see table 1) on the 15th day of each calendar month or the following business day. The next payment date is July 15, 2020.

Table 1

The administrator may purchase all remaining trust student loans when the pool balance is less than 10% of the initial pool balance at a price sufficient to fully repay the notes' outstanding principal amount together with the accrued interest.

Transaction Overview

SoFi Lending Corp. originated the portfolio of private education loans under its SoFi Loan Program and subsequently sold it to Goldman Sachs Bank USA, a majority-owned affiliate of Goldman Sachs Asset Backed Securities Corp., which acts as a sponsor and a depositor for the EFT 2018-A transaction.

On the closing date, Goldman Sachs Bank USA sold, transferred, assigned, and conveyed the portfolio loans to the depositor, Goldman Sachs Asset Backed Securities Corp. The depositor in turn sold, transferred, assigned, and conveyed such portfolio loans to the underlying trust. The underlying trust issued the underlying trust certificate to the issuer in exchange for the proceeds of the sale of the notes and the retained interest. The underlying trust is entitled to all payments of principal and interest on the portfolio loans.

Following the issuance of the notes at closing, Goldman Sachs Bank USA retained an uncertificated interest (the retained interest) representing the right to receive 5.0% of all amounts collected on the portfolio loans (after such amounts are applied in part to pay a pro rata portion of the senior transaction fees and subordinate transaction fees) and distributable on each monthly payment date.

Transaction Structure

Pool Analysis

The noteholders will receive payments primarily from 95% of the collections on the loan pool. Table 2 outlines the EFT 2018-A-GS initial pool's characteristics as of June 3, 2020.

Table 2

Securitization Performance

We currently maintain ratings on senior classes in 17 SoFi transactions (series 2015-B and series 2017-A through 2020-C). Additionally, we maintain ratings on class B and C notes in the 2017-C transaction. All of these transactions are performing better than our initial expectations. Table 3 provides a summary of our lifetime cumulative default rate assumptions at issuance and currently as well as actual cumulative default rates since closing.

Table 3

Our reduced lifetime default rate assumptions for the SoFi transactions issued before 2018 reflect those transactions' strong collateral performance as evidenced in low cumulative default rates and significant pool seasoning (expressed as pool factors) as a result of relatively high prepayment rates. SoFi's 2014-A, 2014-B, and 2015-A paid-off securitizations incurred cumulative default rates in the 0.32%-0.51% range. This performance led us in December 2019 to raise our ratings on the class B and C notes of the 2017-C transaction to 'AA+ (sf)' and 'AA (sf)' from 'A+ (sf)' and 'BBB+ (sf)', respectively (see "Two SoFi Professional Loan Program Ratings Raised, 27 Affirmed From 13 Transactions" published Dec. 11, 2019). While the 2018-2019 transactions may experience higher levels of defaults due to the COVID-19 pandemic, they have built an additional O/C since closing.

In response to the COVID-19 pandemic, SoFi has changed its forbearance policies, waived late fees, stopped collection calls to seriously delinquent borrowers, and stopped collection activities on charged-off loans. SoFi extends forbearance relief to borrowers who live or work in a zone affected by a natural disaster or emergency, as identified by the Federal Emergency Management Agency, and who request such relief. Natural disaster or emergency forbearance is offered for up to 12 months (or for the longer duration of the emergency) in up to three-month increments. During these forbearance periods, interest will accrue but will not be capitalized and the term of the loans will be extended. SoFi reviews its forbearance policy periodically and may revise it in the future.

Historically, forbearance has been an effective default prevention tool that allowed student loan borrowers experiencing a temporary economic hardship to get back on their feet and resume their regular loan payments several months later. We believe that it can still serve this function and perhaps more so for high credit quality refi loan obligors. However, given the unique nature of the current economic environment caused by the COVID-19 pandemic, it remains unclear how the borrowers in COVID-19 forbearance will ultimately perform. Generally, we expect that more borrowers will use forbearance and remain in forbearance for a longer period of time as borrowers seek more flexibility in managing their financial resources during this uncertain time. As yet, we have not seen delinquency levels in the transactions rise.

We have reviewed the available performance data for existing SoFi securitizations. Tables 4-10 below summarize the monthly changes in forbearance, delinquencies, and defaults in 2017-2019 transactions between December 2019 and May 2020. While forbearance percentages in the transactions have increased to 12.22%-15.73% as of May 31, 2020, from 0.23%-0.66% as of Dec. 31, 2019, delinquencies and charge-off levels have remained fairly stable.

Table 4

Table 5

Table 6

Table 7

Table 8

Table 9

Table 10

S&P Global Ratings' Expected Default Rate: 2.45%

When determining the base case cumulative default rate assumption, we considered historical loan performance, the EFT 2018-A-GS pool composition, and the current macroeconomic environment caused by the COVID-19 pandemic, which will likely present employment challenges for some student loan borrowers and result in higher levels of delinquencies and defaults. We moderately increased our cumulative base-case default rate assumption for this pool to higher than what it would otherwise have been in the absence of COVID-19 pandemic-related factors. This increase reflects the uncertain COVID-19 macroeconomic environment that student loan borrowers will continue to be exposed to over the next 12 months.

This default assumption also accounts for the 2018-A-GS pool's forbearance level (13.6%), which is partially offset by the portfolio seasoning level (weighted average of 19.5 months). Approximately 95% of the outstanding pool has made at least 12 monthly payment and interest (P&I) payments, while 98% of the loans in forbearance has made at least 12 monthly P&I payments prior to entering into forbearance.

We have also taken into account that approximately 44% of the loan pool as of the cut-off date consisted of loans to medical and healthcare professionals (including approximately 40% to those with advanced medical and healthcare degrees and approximately 4% to those with undergraduate degrees). While we generally expect these obligors will recover quickly once stay-at-home requirements are relaxed, we acknowledge that different medical subsectors will see variance in the time it takes to return to their pre-COVID-19 level of business.

We have also considered macroeconomic data published by the U.S. Bureau of Labor Statistics. During the previous economic downturns, college degree holders experienced lower unemployment rates than individuals without college degrees (see chart 2).

Additionally, we considered current COVID-19-related unemployment changes by industry (see chart 3).

We also analyzed the credit characteristics of the defaulted refinanced student loans in SoFi's total portfolio. Based on our analysis, we believe that loan obligors without advanced degrees or those with credit scores below 700 have historically defaulted more frequently than their counterparts. We compared the EFT 2018-A-GS pool with the initial characteristics of the series 2014-A through 2015-B pools in terms of concentrations of obligors without advanced degrees and obligors with FICO scores below 700 (see table 11).

Table 11

As indicated in table 11, the EFT 2018-A-GS pool has higher concentrations of obligors without advanced degrees and with credit scores below 700 than the series 2014-A through 2015-B pools. Based on our current default rate assumptions for the series 2014-A through 2015-B transactions, the EFT 2018-A-GS pool composition, and our analysis of macro-economic conditions caused by the COVID-19 pandemic, we increased our base-case default rate assumption to 2.45% from the 2.25% used in multiple pre-COVID-19 transactions. We believe that this moderate increase in the default rate assumption reflects an appropriate balance of the effect that the current macroeconomic environment may have on a very high credit quality obligor pool. Assuming a 25.00% base-case recovery rate, our base-case net loss rate assumption for the EFT 2018-A-GS pool is 1.84%.

Cash Flow Modeling Assumptions And Results

We modeled the EFT 2018-A-GS transaction to test its ability to pay timely interest and full principal payment by the notes' respective maturity dates under various stress cash flow scenarios that we believe are commensurate with the assigned ratings (see table 12).

Table 12

'AAA' Stressed Cash Flow Results

We stressed the cumulative default rates for the pool at approximately 12.25% under our 'AAA' cash flow scenarios. We derived the voluntary prepayment rate, forbearance rate, and recovery rate assumptions from our review of the sponsor's and the industry's historical data, which we adjusted to reflect the series 2018-A-GS's pool composition and the assigned ratings. In the 'AAA' cash flow scenarios, all rated notes received interest payments due on every monthly payment date and principal payments by the notes' maturity dates.

We also performed supplemental analysis to assess the liquidity of the transaction over the next six months and determined that there is sufficient liquidity to make timely note interest payments.

In addition, we ran several liquidity cash flow scenarios with zero voluntary prepayments to test the assets' ability to repay the notes by their maturity dates. The first liquidity scenario assumed a zero default rate. The two other liquidity scenarios assumed the base-case default rate with either a fast or a slow default curve. We kept all other assumptions at the 'AAA' level. Under these liquidity cash flow scenarios, all rated notes received interest payments due on every monthly payment date and principal payments by the notes' maturity dates.

Break-Even Cash Flow Results

In addition to the 'AAA' stressed cash flow scenarios using the 'AAA' stress default rate assumption, we also ran break-even cash flow scenarios that maximized the pool default rate while still making required interest payments on every distribution date and principal payments by the note maturity dates. We kept all other assumptions at the 'AAA' level.

In the 'AAA' break-even scenarios, the transaction was able to absorb cumulative defaults of approximately 14.5% and cumulative net losses of approximately 13.0%% while still making all principal and interest payments on the rated notes. These 'AAA' break-even net losses support a coverage multiple of approximately 7.1x our 1.5%-2.0% base-case net loss rate for the pool. In these 'AAA' break-even scenarios, the rate notes received interest payments due on every monthly payment date and principal payments by the final maturity dates.

Sensitivity Cash Flow Analysis

In addition to the 'AAA' stressed and break-even cash flows, we ran cash flow scenarios to assess the rating stability of the assigned ratings under moderate stress conditions ('BBB' stress scenarios). We believe that in a moderate stress scenario, default rates would be lower and recovery rates would be higher than those in a 'AAA' stress (see table 13).

These 'BBB' stress scenarios are intended to project the deal performance under a moderate recession that would start immediately after closing and would last for at least 12 months. In these 'BBB' scenarios, we analyze the remaining credit enhancement coverage of the remaining net losses over time. The remaining credit enhancement on a given date includes the hard credit enhancement available on that date and cumulative excess spread to be generated in all future periods. The hard credit enhancement includes the reserve account balance and the subordination provided by more junior classes. The remaining net losses on a given date include cumulative net losses to be taken in all future periods. We have tracked the changes in the coverage multiple over time (see chart 4).

Table 13

In moderate stress scenarios, the cumulative remaining credit enhancement coverage of the remaining net losses builds over time. Charts 4 and 5 show the cumulative remaining credit enhancement for the rated classes as multiples of the remaining net losses in the moderate stress scenarios.

Table 14 below shown the credit enhancement multiples for the rated classes observed at the start of the cash flow scenarios and 12 months later depending on the default timing curve.

Table 14

Based on the cash flow scenarios above, we expect our ratings on to remain within one rating category of our 'AAA (sf)' ratings in the first year, which is consistent with our credit stability criteria (see "Methodology: Credit Stability Criteria" published May 3, 2010).

SoFi

SoFi was founded in 2011 by a group of Stanford Graduate School of Business alumni. Under its 2011 pilot program, SoFi raised capital from Stanford alumni and offered private student loans to Stanford business school students. Since its founding, SoFi has shifted its lending strategy to refinancing student loans of employed graduates (from various schools) with high income levels, free cash flow, and credit scores. This strategy is intended to mitigate two major risks for traditional student loan borrowers: nongraduation and unemployment upon graduation. SoFi can offer more competitive pricing to its borrowers than the pricing on the existing student loans they obtained when they were attending school.

In addition to traditional student loan underwriting metrics (such as credit score, income, and adverse credit history checks), SoFi's underwriting criteria include a monthly free cash flow calculation at the time of loan origination (the obligor's income minus debt payments and estimated expenses, such as taxes and mortgage or rent payments).

SoFi Lending Corp, as the administrator, is now authorized to:

• Grant forbearance or deferment on terms consistent with those generally offered under the SoFi Loan Program;
• Settle a default or cure a delinquency on any portfolio loan or otherwise settle any portfolio loan terms with a borrower on terms as required by law or as the administrator may deem to be in the best interest of the SoFi Loan Program;
• Amend the terms of a portfolio loan to provide for a different rate of interest thereon to the extent required by law;
• Revise the principal repayment terms of a portfolio loan in accordance with any authorized repayment plan;
• Grant relief to borrowers residing or attending school in federally-declared disaster areas as the administrator may deem to be appropriate;
• Waive any late payment or similar charge for any borrower;
• Apply any credit to the balance of a portfolio loan if an amount equal to the credit is deposited into the collection account by or at the direction of the sponsor as a payment of such portfolio loan; or
• Amend the terms of any portfolio loan or related agreement if the approval condition is satisfied with respect to that amendment.

However, the administrator will not consent or agree to or permit any amendment or modification of any portfolio loan (other than a charged-off loan) or related agreement unless the amendment or modification meet the following criteria:

• It will not in any manner materially adversely affect the rights or security of the underlying trust or any of the noteholders;
• It is consistent with the detailed servicing guidelines included in the MOHELA servicing agreement and generally accepted servicing practices; and
• It is either required by applicable law or is, in the administrator's reasonable determination, being made to avert default and is a practical manner to obtain a reasonable recovery from the portfolio loan, based on the administrator's prior experience in servicing or overseeing the servicing of similar loans.

MOHELA

MOHELA was established in 1981 to assure that all eligible post-secondary education students have access to guaranteed student loans. The authorizing act has been amended over the years to provide MOHELA with generally expanded powers to finance, acquire, and service student loans, including those guaranteed or insured per the Higher Education Act.

MOHELA provides full-service private student loan servicing, defaulted student loan rehabilitation management, and FFELP loan servicing for its own student loans and those owned by third parties. MOHELA also services direct loans for the U.S. Department of Education, having been awarded a servicing contract as a not-for-profit servicer in September 2011. As of March 31, 2020, MOHELA's servicing portfolio includes $1.2 billion in FFELP loans, $22.0 billion in third-party lender-owned private loans, $61.1 million in MOHELA-owned private loans, and $50.1 billion in direct loans.

MOHELA began originating and servicing loans for its own private loan program in 1995. MOHELA originated and serviced over $370 million in private loans for more than 30,000 borrowers before ending the program in 2008. Through an affiliate, MOHELA has also launched the Missouri Family Education Loan Program (MOFELP), an interest-free loan program for Missouri students meeting certain financial need and academic achievement standards. As of March 31, 2020, MOFELP had approximately $21.0 million outstanding, with 3,890 borrowers in repayment.

Backup Administrator

ECMC Holdings Corp. is the backup administrator. ECMC Holdings is a wholly owned subsidiary of ECMC Group Inc., a Delaware nonprofit corporation. The core of the ECMC Group Inc. companies' nonprofit activities is providing support for the administration of federal student loan programs and the activities of Educational Credit Management Corp. (ECMC). ECMC is a national guarantee agency under FFELP and the designated guarantor in Virginia, Oregon, Connecticut, and California. As of March 31, 2020, ECMC reported to the National Student Loan Data System weekly on a current outstanding student loan portfolio of $26.3 billion. ECMC Holdings Corp. is party to an intercompany service agreement with ECMC and ECMC Group Inc., according to which it may receive services from other ECMC Group Inc. entities as necessary to perform any required functions as a backup administrator or as successor administrator.

Related Criteria

• Criteria | Structured Finance | Legal: U.S. Structured Finance Asset Isolation And Special-Purpose Entity Criteria, May 15, 2019
• Criteria | Structured Finance | General: Incorporating Sovereign Risk In Rating Structured Finance Securities: Methodology And Assumptions, Jan. 30, 2019
• General Criteria: Methodology And Assumptions For Stressed Reinvestment Rates For Fixed-Rate U.S. Debt Obligations, Dec. 22, 2016
• Criteria | Structured Finance | General: Methodology: Criteria For Global Structured Finance Transactions Subject To A Change In Payment Priorities Or Sale Of Collateral Upon A Nonmonetary EOD, March 2, 2015
• Criteria | Structured Finance | General: Global Framework For Cash Flow Analysis Of Structured Finance Securities, Oct. 9, 2014
• Criteria | Structured Finance | ABS: Methodology And Assumptions For U.S. Private Student Loan ABS Credit Analysis, Feb. 13, 2013
• Criteria | Structured Finance | General: Criteria Methodology Applied To Fees, Expenses, And Indemnifications, July 12, 2012
• General Criteria: Global Investment Criteria For Temporary Investments In Transaction Accounts, May 31, 2012
• Criteria | Structured Finance | General: Methodology For Servicer Risk Assessment, May 28, 2009

Related Research

• COVID-19 Activity In Global Structured Finance As Of July 3, 2020, July 13, 2020
• U.S. Biweekly Economic Roundup: Strong Job Gains May Slow As Virus Surges, July 2, 2020
• The Global Economy Begins A Slow Mend As COVID-19 Eases Unevenly, July 1, 2020
• Credit Conditions North America: Rolling Out The Recovery, June 30, 2020
• COVID-19 Is Testing The Resilience Of Global Structured Finance, May 18, 2020
• Effects Of COVID-19 On U.S. Student Loan ABS, April 30, 2020
• Global Structured Finance Scenario And Sensitivity Analysis 2016: The Effects Of The Top Five Macroeconomic Factors, Dec. 16, 2016

In addition to the criteria specific to this type of security (listed above), the following criteria articles, which are generally applicable to all ratings, may have affected this rating action: "Counterparty Risk Framework: Methodology And Assumptions," March 8, 2019; "Post-Default Ratings Methodology: When Does Standard & Poor's Raise A Rating From 'D' Or 'SD'?," March 23, 2015; "Global Framework For Assessing Operational Risk In Structured Finance Transactions," Oct. 9, 2014; "Methodology: Timeliness of Payments: Grace Periods, Guarantees, And Use of 'D' And 'SD' Ratings," Oct. 24, 2013; "Criteria For Assigning 'CCC+', 'CCC', 'CCC-', And 'CC' Ratings," Oct. 1, 2012; "Methodology: Credit Stability Criteria," May 3, 2010; and "Use of CreditWatch And Outlooks," Sept. 14, 2009.