OREANDA-NEWS. Fitch Ratings has affirmed the senior student loan notes at 'AAAsf' and the subordinate student loan notes at 'AAsf' issued by Higher Education Funding I - Amended and Restated 2005 Indenture of Trust (2004). The Rating Outlook on the notes, which is tied to the sovereign rating of the U.S. government, is Stable.

KEY RATING DRIVERS

High Collateral Quality:
The trust collateral consists of 100% Federal Family Education Loan Program (FFELP) loans including about 9% of rehabilitated (rehab) loans. The credit quality of the trust collateral is high, in Fitch's opinion, based on the guarantees provided by the transaction's eligible guarantors and at least 97% reinsurance of principal and accrued interest provided by the U.S. Department of Education (ED). Fitch currently rates the U.S. 'AAA' with a Stable Outlook.

Sufficient Credit Enhancement:
Total credit enhancement (CE) is provided by overcollateralization (OC), excess spread and, for the class A notes, 4.86% in subordination provided by the class B notes. As of the February 2015 collection period, senior and total parity is 106.32% and 101.16%, respectively. However, Fitch only gives credit to senior and total parity of 106% and 101%, respectively, as that is the trust's release level.

Adequate Liquidity Support:
Liquidity support is initially provided by a \$7,702,125 reserve account (0.75% of outstanding note balance with a floor of \$2 million). Additionally, there is a \$1.2 million Cap I account, scheduled to be release on May 25, 2015.

Acceptable Servicing Capabilities:
Day-to-day servicing will be provided by AES and ACS. Both servicers have demonstrated adequate servicing capabilities.

RATING SENSITIVITIES

Since FFELP student loan ABS rely on the U.S. government to reimburse defaults, 'AAAsf' FFELP ABS ratings will likely move in tandem with the 'AAA' U.S. sovereign rating. Aside from the U.S. sovereign rating, defaults and basis risk account for the majority of the risk embedded in FFELP student loan transactions. Additional defaults and basis shock beyond Fitch's published stresses could result in future downgrades. Likewise, a buildup of credit enhancement driven by positive excess spread given favorable basis factor conditions could lead to future upgrades.

Fitch has taken the following rating actions

Higher Education Funding I - Amended and Restated 2005 Indenture of Trust (2004):

--2004-1 A-1 affirmed at 'AAAsf'; Outlook Stable;
--2004-1 A-2 affirmed at 'AAAsf'; Outlook Stable;
--2004-1 A-3 affirmed at 'AAAsf'; Outlook Stable;
--2004-1 A-4 affirmed at 'AAAsf'; Outlook Stable;
--2004-1 A-5 affirmed at 'AAAsf'; Outlook Stable;
--2004-1 A-6 affirmed at 'AAAsf'; Outlook Stable;
--2004-1 A-9 affirmed at 'AAAsf'; Outlook Stable;
--2004-1 A-10 affirmed at 'AAAsf'; Outlook Stable;
--2004-1 A-12 affirmed at 'AAAsf'; Outlook Stable;
--2004-1 A-13 affirmed at 'AAAsf'; Outlook Stable;
--2004-1 A-14 affirmed at 'AAAsf'; Outlook Stable;
--2004-1 A-15 affirmed at 'AAAsf'; Outlook Stable;
--2005-1 A-3 affirmed at 'AAAsf'; Outlook Stable;
--2005-1 A-4 affirmed at 'AAAsf'; Outlook Stable;
--2005-1 A-5 affirmed at 'AAAsf'; Outlook Stable;
--2004-1 B-1 affirmed at 'AAsf'; Outlook Stable;
--2004-1 B-2 affirmed at 'AAsf'; Outlook Stable.