OREANDA-NEWS. Fitch Ratings places the SLM Student Loan Trust 2004-9 senior and subordinate notes on Rating Watch Negative. A full list of rating actions follows at the end of this press release.

KEY RATING DRIVERS
The rating actions are based on analysis conducted by Fitch that identified trusts with tranches that have heightened risk of missing legal final maturity dates based on principal repayment to date. The transactions identified will be subject to additional analysis over the next few months. Fitch's additional analysis will focus on the remaining time to maturity, recent and historical payment trends, breakeven payment speed thresholds, and structural factors to ensure that the likelihood of payment at maturity is commensurate with the ratings assigned.

The magnitude of the rating actions could vary significantly depending on remaining time to maturity, recent payment trends, issuer actions such as loan purchases, or other external factors. Absent any issuer actions, structural or other mitigants, it is possible that 'AAA' ratings could be lowered to noninvestment grade rating categories. Fitch expects to complete its review and resolve the Rating Watch status for all trusts over the next three to six months.

In taking the actions, Fitch has identified trusts with one or more individual tranches most likely to miss their legal final maturities, which would result in an event of default. In an event of such technical default, Fitch would expect ultimate repayment of full principal and interest on all tranches after the legal final. Tripping an event of default, however, could have adverse rating implications for additional tranches. The rating implications will depend on the waterfall mechanics and voting rights and actions of investors. When an event of default occurs, it is highly likely that the class B notes will not receive timely interest as the principal for the class A notes must be paid in full prior to the class B notes receiving interest. Therefore, the subordinate notes are placed on Rating Watch Negative for all affected trusts.

The main drivers of the heightened maturity risk are prepayments and principal repayment rates coming in more slowly than initial expectations. The decline in prepayment rates has followed the consolidation wave and a slow recovery in the job market for graduates during and after the recession. The growth of government sponsored student loan payment plans, such as the Income Based Repayment Plan has also helped push down repayment speeds. Helping offset these declines more recently are an improving in labor market, expansion of debt consolidation programs, seasoning of portfolios and recent issuer actions to address this risk.

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.

DUE DILIGENCE USAGE
No third party due diligence was provided or reviewed in relation to this rating action.

Fitch has placed the following classes on Rating Watch Negative:

SLM Student Loan Trust 2004-9:
--Class A-5 'AAAsf' notes;
--Class B 'AAAsf' notes.