-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, DdUb7IHahARS3t74EU+mGE0u/bPsAId1grOrbmUSREcT+cIhSkMJaAufNrDtSqBj nZEDkf1rlqLd/tsPlPWplQ== 0000899681-08-000297.txt : 20080331 0000899681-08-000297.hdr.sgml : 20080331 20080331171955 ACCESSION NUMBER: 0000899681-08-000297 CONFORMED SUBMISSION TYPE: 10-K PUBLIC DOCUMENT COUNT: 22 CONFORMED PERIOD OF REPORT: 20071231 FILED AS OF DATE: 20080331 DATE AS OF CHANGE: 20080331 FILER: COMPANY DATA: COMPANY CONFORMED NAME: COLLEGE LOAN CORP TRUST I CENTRAL INDEX KEY: 0001172104 STANDARD INDUSTRIAL CLASSIFICATION: ASSET-BACKED SECURITIES [6189] IRS NUMBER: 016110137 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: 10-K SEC ACT: 1934 Act SEC FILE NUMBER: 333-102791-01 FILM NUMBER: 08726195 BUSINESS ADDRESS: STREET 1: 1100 N MARKET ST CITY: WILMINGTON STATE: DE ZIP: 19890 BUSINESS PHONE: 302-636-6071 10-K 1 collegeloan1-10k_032808.htm 10-K

 

 

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UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

FORM 10-K

 

x

Annual report pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934

 

for the fiscal year ended December 31, 2007

 

or

o

Transition report pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934

 

Commission File Number: 333-102791-01

College Loan Corporation Trust I
(Exact name of registrant as specified in its charter)

College Loan LLC

(Exact name of depositor as specified in its charter)

College Loan Corporation

(Exact name of sponsor as specified in its charter)

 

Delaware
(State or other jurisdiction of incorporation
or organization)

45-6110137
(I.R.S. Employer Identification No.)

 

 

14303 Gateway Place
Poway, California

92064

 

 

(Address of principal executive offices)

(Zip Code)

 

Registrant’s telephone number, including area code:

(888) 972-6311

 

 

Securities registered pursuant to Section 12(b) of the Act:

None

 

 

Securities registered pursuant to Section 12(g) of the Act:

None

 

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.

 

Yes

o

No

x

 

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act.

 

Yes

o

No

x

 

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.

 

Yes

x

No

o

 

Indicate by check mark if disclosure of delinquent filers pursuant to Item 405 of Regulation S-K is not contained herein, and will not be contained, to the best of registrant’s knowledge, in definitive proxy or information statements incorporated by reference in Part III of this Form 10-K or any amendment to this Form 10-K. ____

Not Applicable.

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer or a smaller reporting company. See the definitions of “ large accelerated filer,” “accelerated filer” and “smaller reporting company” in Rule 12b-2 on the Exchange Act.

Large Accelerated Filer

o

Accelerated Filer

o

Non Accelerated Filer

x

Smaller Reporting Company

o

 

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act.):

 

Yes

o

No

x

 

State the aggregate market value of the voting and non-voting common equity held by nonaffiliates computed by reference to the price at which the common equity was last sold, or the average bid and asked price of such common equity, as of the last business day of the registrant’s most recently completed second fiscal quarter.

 

Not Applicable

List hereunder the following documents if incorporated by reference and the Part of the Form 10-K into which the document is incorporated: (1) Any annual report to security holders; (2) Any proxy or information statement; and (3) Any prospectus filed pursuant to Rule 424(b) or (c) under the Securities Act of 1933. The listed documents should be clearly described for identification purposes.

The section titled “College Loan Corporation Trust I” in the Registrant’s prospectus supplement dated October 25, 2007 and the sections titled “The Depositor” and “The Sponsor and the Issuer Administrator” in the Registrant’s prospectus dated October 25, 2007, each of which was filed with the Securities and Exchange Commission on October 26, 2007 pursuant to Rule 424(b), file 333-102791-01, are incorporated by reference into the response to Item 1119 of Regulation AB contained in this Annual Report on Form 10-K.

Explanatory Note

This Annual Report on Form 10-K (the “Report”) is filed with respect to College Loan Corporation Trust I. Certain information requested by this Annual Report on Form 10-K is omitted pursuant to Regulation AB and General Instruction J to Form 10-K.

PART I

 

Item 1.

Business.

 

Omitted

Item 1.A

Risk Factors.

 

Omitted

Item 2.

Properties.

 

Omitted.

Item 3.

Legal Proceedings.

 

Omitted.

Item 4.

Submission of Matters to a Vote of Security Holders.

 

Omitted.

PART II

 

Item 5.

Market for Registrant’s Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities.

 

Omitted.

Item 6.

Selected Financial Data.

 

Omitted.

Item 7.

Management’s Discussion and Analysis of Financial Condition and Results of Operation.

 

Omitted.

Item 7A.

Quantitative and Qualitative Disclosures about Market Risk.

 

Omitted.

Item 8.

Financial Statements and Supplementary Data.

 

Omitted.

Item 9.

Changes in and Disagreements with Accountants on Accounting and Financial Disclosures.

 

Omitted.

Item 9A.

Controls and Procedures

 

Omitted.

Item 9B.

Other Information.

 

None.

PART III

 

Item 10.

Directors and Executive Officers of the Registrant.

 

Omitted.

Item 11.

Executive Compensation.

 

Omitted.

Item 12.

Security Ownership of Certain Beneficial Owners and Management.

 

Omitted.

Item 13.

Certain Relationships and Related Transactions, and Director Independence.

 

Omitted.

Item 14.

Principal Accountant Fees and Services.

 

Omitted.

PART IV

Item 15.

Exhibits, Financial Statement Schedules, and Reports on Form 8-K.

 

 

(a)

List of Documents Filed as Part of thus Annual Report on Form 10-K

 

1)

Not applicable

 

2)

Not applicable

 

3)

See item 15(b) below

 

(b)

Exhibits required by Item 601 of Regulation S-K

 

EXHIBIT

DESCRIPTION

 

 

31.1

Rule 13a-14(a)/15d-14a Certification. (Section 302 Certification)

 

 

33.1

Report on Assessment of Compliance with Servicing Criteria concerning servicing activities of ACS Education Services, Inc. for the year ended December 31, 2007.

 

 

33.2

Report on assessment of Compliance with Servicing Criteria concerning servicing activities of CLC Servicing for the year ended December 31, 2007.

 

 

33.3

Report on assessment of Compliance with Servicing Criteria concerning servicing activities of Great Lakes Educational Loan Services, Inc. for the year ended December 31, 2007.

 

 

33.4

Report on assessment of Compliance with Servicing Criteria concerning servicing activities of Deutsche Bank Trust Company Americas for the year ended December 31, 2007.

 

 

33.5

Report on assessment of Compliance with Servicing Criteria concerning servicing activities of College Loan Corporation for the year ended December 31, 2007.

 

 

34.1

Independent Accountants’ Attestation Report concerning servicing activities of ACS Education Services, Inc. for the year ended December 31, 2007.

 

 

34.2

Independent Accountants’ Attestation Report concerning servicing activities of CLC Servicing for the year ended December 31, 2007.

 

 

34.3

Independent Accountants’ Attestation Report concerning servicing activities of Great Lakes Educational Loan Services, Inc. for the year ended December 31, 2007.

 

 

34.4

Independent Accountants’ Attestation Report concerning servicing activities of Deutsche Bank Trust Company Americas for the year ended December 31, 2007.

 

 

34.5

Independent Accountants’ Attestation Report concerning servicing activities of College Loan Corporation for the year ended December 31, 2007.

 

 

35.1

Statement of Compliance of ACS Education Services, Inc. under the Federal FFEL Origination/Servicing Agreement for the year ended December 31, 2007.

 

 

35.2

Statement of Compliance of CLC Servicing under the Federal FFELP Origination and Servicing Agreement for the year ended December 31, 2007.

 

 

35.3

Statement of Compliance for College Loan Corporation under the Administration Agreement for the year ended December 31, 2007.

 

The following are additional disclosure items required by Regulation AB.

Item 1112(b) Significant Obligor Financial Information

None.

Items 1114(b)(2) and 1115(b). Significant Enhancement Provider Information.

The payment of principal and interest on all of the registrant’s student loans is guaranteed by designated guarantee agencies and reinsured by the U.S. Department of Education. As of December, 2007, 70.2%, 13.2% and 10.3% of the registrant’s student loans (by dollar volume) were guaranteed by Massachusetts Higher Education Assistance Corporation d/b/a American Student Assistance, California Student Aid Commission and Great Lakes Higher Education Guaranty Corporation, respectively. As of that date, no other guarantee agency was guaranteeing 10% or more of the registrant’s student loans.

American Student Assistance

Massachusetts Higher Education Assistance Corporation d/b/a American Student Assistance (“ASA”), a not-for-profit corporation organized in 1956, will guarantee a portion of the Financed Student Loans. ASA is one of the oldest and largest guaranty agencies in the United States, and is the designated guarantor for the Commonwealth of Massachusetts and the District of Columbia. Since 1956, ASA has been a provider of higher education financing products and services to students, parents, schools and lenders across the country, guaranteeing more than $43 billion in loans. Originally created by the General Court of the Commonwealth of Massachusetts as the Massachusetts Higher Education Assistance Corporation, ASA currently acts on behalf of the U.S. Department of Education to ensure that the public policy purposes and regulatory requirements of the FFEL Program are met. ASA has its principal offices located at 100 Cambridge Street, Boston, MA 02114.

Guaranty Volume. The following table sets forth the original principal amount of FFELP Loans (excluding Consolidation Loans) guaranteed by ASA in each of the last five ASA fiscal years:

ASA Fiscal Year
(Ending June 30)

Net FFELP Loans
Guaranteed by ASA
(Dollars in Millions)

 

 

2003

$

914

 

2004

 

1,270

 

2005

 

1,746

 

2006

 

1,788

 

2007

 

2,367

 

 

Under the Higher Education Act, ASA and the U.S. Secretary of Education as of January 1, 2001 entered into a voluntary flexible agreement (“VFA”). Under the VFA, ASA returned its reserve funds that would otherwise have made up its Federal Reserve Fund through an escrow account in the name of the Department of Education. In the event a loan defaults, ASA receives funding from the Department of Education to act as a disbursing agent. The guarantee is, therefore, no longer limited by the funds on deposit in a federal reserve fund. Because ASA holds no federal reserve fund, the concept of a Reserve Ratio is inapplicable. The VFA establishes a “fee for service” model under which ASA is rewarded through the payment of a portfolio maintenance fee for maintaining a healthy portfolio of loans in good standing. The agency is further incented to keep the loans in good standing and to work with borrowers to prevent default because the portfolio maintenance fee increases as ASA’s trigger default rate improves over the national trigger default rate. ASA’s efforts to prevent default are a part of its “Wellness” program of outreach to borrowers from the inception of the loan to educate them on their responsibilities and assist them in repayment.

The Department of Education notified the Guarantee Agency in a letter dated October 2, 2007 that it was canceling its VFA effective January 1, 2008. Because the Guarantee Agency is attempting to renegotiate the VFA with the Department of Education and because the Guarantee Agency would operate under the traditional guarantee agency funding model should the cancellation stand, the Guarantee Agency does not believe that the cancellation will materially adversely affect its business.

The information in the following tables has been provided by ASA from reports provided by or to the U.S. Department of Education. No representation is made by ASA as to the accuracy or completeness of the information.

Recovery Rates. A Guarantee Agency’s recovery rate, which provides a measure of the effectiveness of the collection efforts against defaulting borrowers after the guarantee claim has been satisfied, is determined by dividing the aggregate amount recovered from borrowers by the aggregate amount of default claims paid by the Guarantee Agency. The table below sets forth the recovery rates for ASA as taken from the Department of Education Guarantee Agency Activity Report form 1130 or form 2000:

Federal Fiscal Year
(Ending September 30)

Cumulative
Recovery Rate

 

 

 

2003

79.4

%

2004

83.5

 

2005

83.0

 

2006

83.6

 

2007

80.8

 

 

Claims Rate. ASA’s claims rate represents the percentage of loans in repayment at the beginning of a federal fiscal year which default during the ensuing federal fiscal year net of repurchases, refunds and rehabilitations. For the federal years 2002-2006, ASA’s claims rate listed below have not exceeded 5%, and as a result, all claims of ASA have been fully reimbursed at the maximum allowable level by the Department of Education. See the description or summary of the FFEL Program herein for more detailed information concerning the FFEL Program. Nevertheless, there can be no assurance the Guarantee Agencies will continue to receive full reimbursement for such claims. The following table sets forth the claims rate of ASA for the last five federal fiscal years:

Federal Fiscal Year
(Ending September 30)

Claims Rate

 

 

 

2003

.9

%

2004

.7

 

2005

1.0

 

2006

1.0

 

2007

1.1

 

 

Net Loan Default Claims. The following table sets forth the dollar value of Default Claims paid net of repurchases, refunds and rehabilitations for the last five years.

ASA Fiscal Year
(Ending June 30)

Default Claims
(Dollars in Millions)

 

 

2003

$

80

 

2004

 

83

 

2005

 

168

 

2006

 

216

 

2007

 

320

 

 

Default Recoveries. The following table sets forth the amount of recoveries returned to the U.S. Department of Education for the last five years.

ASA Fiscal Year
(Ending June 30)

Default Recoveries
(Dollars in Millions)

 

 

2003

$

79

 

2004

 

82

 

2005

 

78

 

2006

 

97

 

2007

 

128

 

 

California Student Aid Commission

The California Student Aid Commission (“CSAC”) is the designated state student loan guaranty agency for the State of California (“State”), responsible for that State’s participation in the FFELP pursuant to California Education Code Section 69760 et seq., and Section 428(c) of the Higher Education Act. CSAC’s role as a guaranty agency is to provide a source of credit to assist students in meeting post-secondary education costs while attending eligible institutions of their choice.

As authorized under California law, CSAC has established an auxiliary organization in the form of a nonprofit public benefit corporation to provide operational and administrative services related to CSAC’s participation in the FFELP. The auxiliary organization, EDFUND, operates CSAC’s federal student loan guaranty program pursuant to an operating agreement with CSAC. CSAC, as the designated state guaranty agency, continues its oversight or all revenues, expenses and assets related to its status.

CSAC began guaranteeing student loans on April 1, 1979, and as of September 30, 2007, had cumulative principal guarantees outstanding of approximately $29.7 billion.

As part of the FFELP, and pursuant to the 1998 Reauthorization Amendments to the Higher Education Act, the state established the Federal Student Loan Reserve Fund, referred to as CSAC’s Federal Fund, and the Student Loan Operating Fund, referred to as CSAC’s Operating Fund. CSAC’s liability pursuant to the FFELP, including for any loan guarantees, is limited solely to the amounts contained in these two funds, and the State has not obligation to replenish these funds if exhausted.

As of September 30, 2007, CSAC’s Federal Fund and Operating Fund balances were as follows: CSAC’s Federal Fund had total assets of $126,538,170, total liabilities of $50,117,449 and total fund equity of $76,420,721; and CSAC’s Operating Fund had total assets of $67,901,237, total liabilities of $36,379,875 and total fund equity of $31,521,362.

The 1998 Reauthorization Amendments require guaranty agencies to return to the U.S. Department of Education $250 million in reserve funds from fiscal years 2002 to 2007, with each agency’s share being based on a formula prescribed in the 1998 Reauthorization Amendments. The U.S. Department of Education advised CSAC that its share of this recall is $24,871,909. The first installment payment of $8,456,449 was paid on August 26, 2002. The second installment of $8,207,730 was paid on August 31, 2006 and the final installment of $8,207,730 was paid on August 31, 2007. These payments are disclosed on the financial statements, and have been recognized as liabilities.

Guaranty Volume. CSAC guaranteed the following amounts for the last five (5) fiscal years ending September 30, as follows:

Fiscal Year

 

FFELP Loan Volume
(Dollars in Millions)

2003

 

4,421

2004

 

5,712

2005

 

6,577

2006

 

6,878

2007

 

6,765

 

The information in the following tables has been provided by CSAC from reports provided by or to the U.S. Department of Education. CSAC has not verified, and makes no representation as to the accuracy or completeness of, the information compiled by the Department of Education or as to any calculations other than required by federal regulation.

Reserve Ratio. Calculated pursuant to 34 C.F.R. 682.419, et seq., CSAC’s reserve ratio (determined by dividing its fund balance by the total amount of loans outstanding) for the last five (5) fiscal years ending September 30, is as follows:

Fiscal Year

 

Reserve Ratio

2003

 

0.25%

2004

 

0.25%

2005

 

0.25%

2006

 

0.25%

2007

 

0.26%

 

Recovery Rate. Calculated pursuant to 34 C.F.R. 682.409, et seq., CSAC’s recovery rate for each of the past five (5) fiscal years ending September 30, is as follows:

Fiscal Year

 

Recovery Rate

2003

 

27.23%

2004

 

27.03%

2005

 

31.12%

2006

 

21.73%

2007

 

19.85%

 

Claims Rate. Calculated pursuant to 34 C.F.R. 682.404, et seq., CSAC’s claims rate for each of the past five (5) fiscal years ending September 30, is as follows:

Fiscal Year

 

Claims Rate

2003

 

2.07%

2004

 

2.14%

2005

 

2.81%

2006

 

3.01%

2007

 

3.31%

 

Uninsured Loan Loss Rate. CSAC’s uninsured loan loss rate (determined by dividing annual uninsured loans by annual net guarantees) for each of the past five (5) fiscal years is as follows:

Fiscal Year

 

Loss Rate

2003

 

0.000%

2004

 

0.017%

2005

 

0.000%

2006

 

0.002%

2007

 

0.057%

 

Great Lakes Higher Education Guaranty Corporation

Great Lakes Higher Education Guaranty Corporation (“GLHEGC”) is a Wisconsin nonstock, nonprofit corporation the sole member of which is Great Lakes Higher Education Corporation (“GLHEC”). GLHEGC’s predecessor organization, GLHEC, was organized as a Wisconsin nonstock, nonprofit corporation and began guaranteeing student loans under the Higher Education Act in 1967. GLHEGC is the designated guarantee agency under the Higher Education Act for Wisconsin, Minnesota, Ohio, Puerto Rico and the Virgin Islands. On January 1, 2002, GLHEC (and GLHEGC directly and through its support services agreement with GLHEC), outsourced certain aspects of its student loan program guaranty support operations to GLELSI. GLHEGC continues as the “guaranty agency” as defined in Section 435(j) of the Higher Education Act and continues its default aversion, claim purchase and compliance, collection support and federal reporting responsibilities as well as custody and responsibility for all revenues, expenses and assets related to that status. GLHEGC (through its support services agreement with GLHEC) also performs oversight of all direct and outsourced student loan program operations. The primary operations center for GLHEC and its affiliates (including GLHEGC and GLELSI) is in Madison, Wisconsin, which includes the data processing center and operational staff offices for both guaranty and servicing functions. GLHEC and affiliates also maintain regional offices in Columbus, Ohio and St. Paul, Minnesota and customer support staff located nationally. GLHEGC will provide a copy of GLHEC’s most recent consolidated financial statements on receipt of a written request directed to 2401 International Lane, Madison, Wisconsin 53704, Attention: Chief Financial Officer.

GLHEGC has entered into a Voluntary Flexible Agreement with the U.S. Department of Education pursuant to the 1998 Reauthorization Amendments. Under GLHEGC’s agreement, which commenced October 1, 2000 and is currently effective through September 30, 2008, GLHEGC’s revenues are tied directly to default aversion performance. Certain sources of GLHEGC’s Operating Fund revenues are replaced by a single fee-for-service funding source tied directly to the percentage of delinquent loans that do not default during the measurement period. In lieu of statutory collection retention amounts, the U.S. Department of Education reimburses GLHEGC only for its actual post-default collection related expenses. This agreement also calls for GLHEGC to escrow the liquid assets of GLHEGC’s Federal Fund for the benefit of the U.S. Department of Education. GLHEGC may also engage in negotiations with lenders to define whether the lender or GLHEGC will complete each of the due diligence requirements. Finally, this agreement allows GLHEGC to pilot a new approach to the claims review process, under which GLHEGC develops and implements with willing lenders and servicers a post-claim random sampling process that replaces the current claim-by-claim process.

The information in the following tables has been provided to the Issuer from reports provided by or to the U.S. Department of Education and has not been verified by the Issuer, GLHEGC or the initial purchasers. No representation is made by the Issuer, GLHEGC or the initial purchasers as to the accuracy or completeness of this information. Prospective investors may consult the United States Department of Education Data Books and Web site http://www.ed.gov/finaid/prof/resources/data/opeloanvol.html for further information concerning GLHEGC or any other guarantee agency.

Guarantee Volume. GLHEGC’s guaranty volume for each of the last five federal fiscal years, including Stafford, Unsubsidized Stafford, SLS, PLUS, Graduate PLUS and Consolidation loan volume, was as follows:

Federal Fiscal Year

 

Guaranty Volume (Millions)

2002

 

4,473.1

 

2003

 

8,721.3

 

2004

 

7,707.6

 

2005

 

9,686.3

 

2006

 

12,797.2

 

 

Reserve Ratio. Following are GLHEGC’s reserve fund levels as calculated in accordance with 34 CFR 682.410(a)(10) for the last five federal fiscal years:

Federal Fiscal Year

 

Federal Guaranty Reserve Fund Level1/

2003

 

1.29%

2004

 

0.99%

2005

 

0.83%

2006

 

0.72%

2007

 

0.69%

 

The Department of Education’s website at

http://www.fp.ed.gov/fp/attachments/activities_whatsnew/03040506ReserveRatioFinalPublicReport.xls has posted reserve ratios for GLHEGC for federal fiscal years 2003, 2004, 2005 and 2006 of 1.168%, .646%, .578% and .517%, respectively. GLHEGC believes the Department of Education has not calculated the reserve ratio in accordance with the Act and the correct ratio should be 1.29%, .99%, .83% and .72%, respectively, as shown above and as explained in the following footnote. On November 17, 2006, the Department of Education advised GLHEGC that beginning in Federal Fiscal Year 2006 it will publish reserve ratios that include loan loss provision and deferred revenues. GLHEGC believes this change should more closely approximate the statutory calculation. According to the Department of Education, available cash reserves may not always be an accurate barometer of a guarantor’s financial health.

1/ In accordance with Section 428(c)(9) of the Higher Education Act, does not include loans transferred from the former Higher Education Assistance Foundation, Northstar Guarantee Inc., Ohio Student Aid Commission or Puerto Rico Higher Education Assistance Corporation. (The minimum reserve fund ratio under the Higher Education Act is .25%.)

Claims Rate. For the past five federal fiscal years, GLHEGC’s claims rate has not exceeded 5%, and, as a result, the highest allowable reinsurance has been paid on all GLHEGC’s claims. The actual claims rates are as follows:

Fiscal Year

 

Claims Rate

2003

 

1.27

%

2004

 

.68

%

2005

 

.51

%

2006

 

.62

%

2007

 

.77

%

 

As a result of various statutory and regulatory changes over the past several years, historical rates may not be an accurate indicator of current delinquency or default trends or future claims rates.

Item 1117. Legal Proceedings

The Registrant knows of no material pending legal proceedings.

Item 1119. Affiliates and Certain Relationships and Related Transactions.

Information related to affiliates of the Registrant and certain relationships and related transactions is provided in the section titled “College Loan Corporation Trust I” in the prospectus supplement dated October 25, 2007 and the sections titled “The Depositor” and “The Sponsor and the Issuer Administrator” in the prospectus dated October 25, 2007, each of which was filed with the Securities and Exchange Commission on October 26, 2007 pursuant to Rule 424(b), file 333-102791-01, and incorporated herein by reference.

Item 1122. Compliance with Applicable Servicing Criteria

A Managements Assessment of Compliance with Regulation AB Servicing Criteria, along with a related accountant’s attestation report, for each of ACS Education Services, Inc., CLC Servicing, Great Lakes Educational Loan Services, Inc., Deutsche Bank Trust Company Americas and College Loan Corporation is included as an exhibit to this report. Except as described by the following, there have been no material instances of noncompliance with the servicing criteria for the period of this report.

ACS Education Services, Inc. reported material noncompliance with servicing criterion 1122(d)(2)(ii) and 1122(d)(4)(iv). Related to criterion 1122(d)(2)(ii), disbursements made via wire transfers on behalf of an obligor to the lender were not made by authorized personnel. ACS Education Services, Inc. has taken corrective action and now retains daily bank access user reports to provide evidence of compliance with servicing criterion 1122(d)(2)(ii). Related to criterion 1122(d)(4)(iv), certain payments on pool assets were posted to the obligors records more than two business days after receipt. For certain pool assets, the related transaction agreement states that payments are to be made within a mutually acceptable schedule; the referenced schedule has not been executed. ACS Education Services, Inc. expects to execute a mutually acceptable schedule with the lender that will specify payment posting and effective date time frames when payments received do not allow for the systematic posting within two days after receipt.

CLC Servicing reported material noncompliance with servicing criterion 1122(d)(2)(i), 1122(d)(2)(vii) and 1122(d)(4)(vi). Related to criterion 1122(d)(2)(i), transfer of borrower payments to the appropriate custodial account were not made within 2 business days of receipt of payment. Effective November 9, 2007 CLC Servicing changed their process and began wiring funds to the appropriate custodial accounts within two business days of the payment posting date on the CLC Servicing system. Related to criterion 1122(d)(2)(vii), bank account reconciliations have reconciling items that are not cleared within 90 days. As of December 31, 2007, bank account reconciling items are cleared within 90 days. Related to criterion 1122(d)(4)(vi), between July and September 2007, the Student Status Confirmation Report (SSCR) automation process was undergoing system enhancements and SSCR reports with student status changes were not processed timely. This resulted in some loans not entering repayment in a timely manner. The backlog of SSCR processing was resolved in early September and SSCR processing has remained current.

By the end of June 2008, CLC Servicing will have transferred all pool assets and servicing activities to ACS Education Services, Inc. and exited the business of servicing student loans. The transfer of pool assets and servicing activities to ACS Education Services, Inc. will be done in accordance with the transaction documents.

Item 1123. Servicer Compliance Statement

A Servicer Compliance Statement for each of ACS Education Services, Inc., CLC Servicing and College Loan Corporation is included as an exhibit to this report. Exhibit 35.1 references ACS Education Services, Inc., exhibit 35.2 references CLC Servicing and exhibit 35.3 references College Loan Corporation.

 

 

SIGNATURES

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the Registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized:

 

College Loan Corporation Trust I

 

By: College Loan LLC, Depositor

 

 

 

 

 

 

 

By:

/s/ John Falb

 

 

John Falb

 

 

Chief Financial Officer

 

 

College Loan LLC

 

 

Senior Officer In Charge of Securitization

 

 

INDEX TO EXHIBITS

 

EXHIBIT

DESCRIPTION

 

 

31.1

Rule 13a-14(a)/15d-14a Certification. (Section 302 Certification)

 

 

33.1

Report on Assessment of Compliance with Servicing Criteria concerning servicing activities of ACS Education Services, Inc. for the year ended December 31, 2007.

 

 

33.2

Report on assessment of Compliance with Servicing Criteria concerning servicing activities of CLC Servicing for the year ended December 31, 2007.

 

 

33.3

Report on assessment of Compliance with Servicing Criteria concerning servicing activities of Great Lakes Educational Loan Services, Inc. for the year ended December 31, 2007.

 

 

33.4

Report on assessment of Compliance with Servicing Criteria concerning servicing activities of Deutsche Bank Trust Company Americas for the year ended December 31, 2007.

 

 

33.5

Report on assessment of Compliance with Servicing Criteria concerning servicing activities of College Loan Corporation for the year ended December 31, 2007.

 

 

34.1

Independent Accountants’ Attestation Report concerning servicing activities of ACS Education Services, Inc. for the year ended December 31, 2007.

 

 

34.2

Independent Accountants’ Attestation Report concerning servicing activities of CLC Servicing for the year ended December 31, 2007.

 

 

34.3

Independent Accountants’ Attestation Report concerning servicing activities of Great Lakes Educational Loan Services, Inc. for the year ended December 31, 2007.

 

 

34.4

Independent Accountants’ Attestation Report concerning servicing activities of Deutsche Bank Trust Company Americas for the year ended December 31, 2007.

 

 

34.5

Independent Accountants’ Attestation Report concerning servicing activities of College Loan Corporation for the year ended December 31, 2007.

 

 

35.1

Statement of Compliance of ACS Education Services, Inc. under the Federal FFEL Origination/Servicing Agreement for the year ended December 31, 2007.

 

 

35.2

Statement of Compliance of CLC Servicing under the Federal FFELP Origination and Servicing Agreement for the year ended December 31, 2007.

 

 

35.3

Statement of Compliance for College Loan Corporation under the Administration Agreement for the year ended December 31, 2007.

 

 

EX-31 2 collegeloan1-ex311_032808.htm EXHIBIT 31.1 Exhibit 31.1

Exhibit 31.1

CERTIFICATION

I, John Falb, certify that:

l.          I have reviewed this annual report on Form 10-K, and all reports on Form 10-D required to be filed in respect of the period covered by this report on Form 10-K of College Loan Corporation Trust II (the “Exchange Act periodic reports”);

2.         Based on my knowledge, the Exchange Act periodic reports, taken as a whole, do not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3.         Based on my knowledge, all of the distribution, servicing and other information required to be provided under Form 10-D for the period covered by this report is included in the Exchange Act periodic reports;

4.         Based on my knowledge and the servicer compliance statements required in this report under Item 1123 of Regulation AB, and except as disclosed in the Exchange Act periodic reports, the servicers have fulfilled their obligations under the servicing agreement in all material respects.

5.         All the reports on assessment of compliance with servicing criteria for asset-backed securities and their related attestation reports on assessment of compliance with servicing criteria for asset-backed securities required to be included in this report in accordance with Item 1122 of Regulation AB and Exchange Act Rules 13a-18 and 15d-18 have been included as an exhibit to this report, except as otherwise disclosed in this report. Any material instances of noncompliance described in such reports have been disclosed in this report on Form 10-K.

In giving the certifications above, I have reasonably relied on information provided to me by the following unaffiliated parties: ACS Educational Services, Inc., Great Lakes Educational Loan Services and Deutsche Bank Trust Company Americas.

Date: 3/19/08

 

 

/s/ John Falb

 

John Falb

 

Chief Financial Officer

 

College Loan LLC

 

Senior Officer in Charge of Securitization

 

 

EX-33 3 collegeloan1-ex331_032808.htm EXHIBIT 33.1 Exhibit 33.1

EXHIBIT 33.1


ACS Education Services Management Assessment

Management of Affiliated Computer Services, Inc. (ACS) Education Services is responsible for assessing compliance with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission relating to the servicing of (a) publicly-issued student loan backed security transactions issued on or after January 1, 2006 that are serviced by the Company for College Loan Corporation and (b) student loans for which the Company commenced servicing activities for Key Bank, N.A. on or after January 1, 2006 (collectively, the Platform), except for servicing criteria noted in Appendix A as “N/A”, which ACS Education Services has determined are not applicable to the activities it performs with respect to the Platform as of and for the year ended December 31, 2007.

With respect to servicing criterion 1122(d)(2)(i), management has engaged a vendor to perform the activities required by the servicing criterion. ACS Education Services’ management has determined that the vendor is not considered a “servicer” as defined in Item 1101(j) of Regulation AB, and ACS Education Services’ management has elected to take responsibility for assessing compliance with the servicing criterion applicable to the vendor as permitted by Interpretation 17.06 of the SEC Division of Corporation Finance Manual of Publicly Available Telephone Interpretations (“Interpretation 17.06”). Management has policies and procedures in place designed to provide reasonable assurance that the vendor’s activities comply in all material respects with the servicing criterion applicable to the vendor. ACS Education Services’ management is solely responsible for determining that it meets the SEC requirements to apply Interpretation 17.06 for the vendor and related criterion.

ACS Education Services’ management has assessed the effectiveness of the ACS Education Services’ compliance with the applicable servicing criteria as of and for the year ended December 31, 2007. In making this assessment, management used the criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB.

Based on such assessment, management believes that, as of and for the year ended December 31, 2007, ACS Education Services has complied in all material respects with the servicing criteria set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission relating to the servicing of the Platform, except for material noncompliance with servicing criteria 1122(d)(2)(ii) and 1122(d)(4)(iv). Related to criterion 1122(d)(2)(ii), disbursements made via wire transfers on behalf of an obligor to the lender were not made by authorized personnel. ACS Education Services did not maintain documented evidence that authorized personnel made disbursements via wire transfer on behalf of an obligor to the lender. While ACS Education Services management believes controls are in place which provide management reasonable assurance that wire transfers are made only by authorized personnel, documentation evidencing such was not available for a portion of the year ended December 31, 2007. Additional documentation (daily user access reports) is now retained to provide evidence of compliance with servicing criterion 1122(d)(2)(ii). Related to servicing criterion 1122(d)(4)(iv), certain payments on pool assets were posted to the obligor records more than two business days after receipt. For certain pool assets, the related transaction agreement states that payments are to be made within a mutually acceptable schedule; the referenced schedule has not been executed. ACS Education Services expects to execute a mutually acceptable schedule with the applicable lender that will specify payment posting and effective date time frames when payments received do not allow for the systematic posting within two days after receipt.

KPMG LLP, a registered public accounting firm, has issued an attestation report with respect to ACS Education Services’ compliance with the applicable servicing criteria as of and for the year ended December 31, 2007.

 

 

 

 

/s/ Meta Gonzalez

 

Meta Gonzalez, Sr. Vice President

 

 

 

March 10, 2008

 

Date

 

 

ACS

2277 East 220th Street • Long Beach, CA 90810-1696

310.513.2700

 

 

 

APPENDIX A

 

AFFILIATED COMPUTER SERVICES, INC.

EDUCATION SERVICES

Servicing Criteria Addressed in ACS Education Services’

Management Assessment

 

Definitions:

 

X – Servicing criteria subject to assessment

X(1) – Servicing criteria subject to assessment. Compliance is determined based upon Telephone Interpretation 17.06

N/A – Not Applicable

Reg AB Reference

Servicing Criteria

Applicability

 

General Servicing Considerations

 

1122(d)(1)(i)

Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreements.

X

1122(d)(1)(ii)

If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third party’s performance and compliance with such servicing activities.

X

1122(d)(1)(iii)

Any requirements in the transaction agreements to maintain a back-up servicer for the Pool Assets are maintained.

N/A

1122(d)(1)(iv)

A fidelity bond and errors and omissions policy is in effect on the party participating in the servicing function throughout the reporting period in the amount of coverage required by and otherwise in accordance with the terms of the transaction agreements.

X

 

Cash Collection and Administration

 

1122(d)(2)(i)

Payments on pool assets are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days following receipt, or such other number of days specified in the transaction agreements.

X(1)

1122(d)(2)(ii)

Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.

X

1122(d)(2)(iii)

Advances of funds or guarantees regarding collections, cash flows or distributions, and any interest or other fees charged for such advances, are made, reviewed and approved as specified in the transaction agreements.

N/A

1122(d)(2)(iv)

The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of over collateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements.

N/A

1122(d)(2)(v)

Each custodial account is maintained at a federally insured depository institution as set forth in the transaction agreements. For purposes of this criterion, “federally insured depository institution” with respect to a foreign financial institution means a foreign financial institution that meets the requirements of Rule 13k-1(b)(1) of the Securities Exchange Act.

X

1122(d)(2)(vi)

Unissued checks are safeguarded so as to prevent unauthorized access.

X

1122(d)(2)(vii)

Reconciliations are prepared on a monthly basis for all asset-backed securities related bank accounts, including custodial accounts and related bank clearing accounts. These reconciliations are (A) mathematically accurate; (B) prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C)  reviewed and approved by someone other than the person who prepared the reconciliation; and (D) contain explanations for reconciling items. These reconciling items are resolved within 90 calendar days of their original identification, or such other number of days specified in the transaction agreements.

X

 

Investor Remittances & Reporting

 

1122(d)(3)(i)

Reports to investors, including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements. Specifically, such reports (A) are prepared in accordance with timeframes and other terms set forth in the transaction agreements; (B) provide information calculated in accordance with the terms specified in the transaction agreements; (C) are filed with the Commission as required by its rules and regulations; and (D) agree with investors’ or the trustee’s records as to the total unpaid principal balance and number of Pool Assets serviced by the Servicer.

N/A

1122(d)(3)(ii)

Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority, and other terms set forth in the transaction agreements.

N/A

1122(d)(3)(iii)

Disbursements made to an investor are posted within two business days to the Servicer’s investor records, or such other number of days specified in the transaction agreements.

N/A

1122(d)(3)(iv)

Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.

N/A

 

Pool Asset Administration

 

1122(d)(4)(i)

Collateral or security on pool assets is maintained as required by the transaction agreements or related pool asset documents.

X

1122(d)(4)(ii)

Pool assets and related documents are safeguarded as required by the transaction agreements.

X

1122(d)(4)(iii)

Any additions, removals, or substitutions to the asset pool are made, reviewed, and approved in accordance with any conditions or requirements in the transaction agreements.

N/A

1122(d)(4)(iv)

Payments on pool assets, including any payoffs, made in accordance with the related pool asset documents are posted to the Servicer’s obligor records maintained no more than two business days after receipt, or such other number of days specified in the transaction agreements, and allocated to principal, interest or other items (e.g., escrow) in accordance with the related pool asset documents.

X

1122(d)(4)(v)

The Servicer’s records regarding the pool assets agree with the Servicer’s records with respect to an obligor’s unpaid principal balance.

X

1122(d)(4)(vi)

Changes with respect to the terms or status of an obligor’s pool assets (e.g., loan modifications or re-agings) are made, reviewed, and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents.

X

1122(d)(4)(vii)

Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures, and repossessions, as applicable) are initiated, conducted, and concluded in accordance with the timeframes or other requirements established by the transaction agreements.

X

1122(d)(4)(viii)

Records documenting collection efforts are maintained during the period a pool asset is delinquent in accordance with the transaction agreements. Such records are maintained on at least a monthly basis, or such other period specified in the transaction agreements, and describe the entity’s activities in monitoring delinquent pool assets including, for example, phone calls, letters, and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment).

X

1122(d)(4)(ix)

Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.

X

1122(d)(4)(x)

Regarding any funds held in trust for an obligor (such as escrow accounts): (A) such funds are analyzed, in accordance with the obligor’s pool asset documents, on at least an annual basis, or such other period specified in the transaction agreements; (B) interest on such funds is paid, or credited, to obligors in accordance with applicable pool asset documents and state laws; and (C) such funds are returned to the obligor within 30 calendar days of full repayment of the related pool assets, or such other number of days specified in the transaction agreements.

N/A

1122(d)(4)(xi)

Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that such support has been received by the servicer at least 30 calendar days prior to these dates, or such other number of days specified in the transaction agreements.

N/A

1122(d)(4)(xii)

Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from the Servicer’s funds and not charged to the obligor, unless the late payment was due to the obligor’s error or omission.

N/A

1122(d)(4)(xiii)

Disbursements made on behalf of an obligor are posted within two business days to the obligor’s records maintained by the servicer, or such other number of days specified in the transaction agreements.

N/A

1122(d)(4)(xiv)

Delinquencies, charge-offs, and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.

X

1122(d)(4)(xv)

Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as set forth in the transaction agreements.

N/A

 

 

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Exhibit 33.2

 

MANAGEMENT'S ASSESSMENT OF COMPLIANCE

WITH REGULATION AB SERVICING CRITERIA

CLC Servicing (the “Servicer”) asserts as of December 31, 2007 and for the period from January 1, 2007 to December 31, 2007 (the “Reporting Period”) and as required by Item 1122(d) of Regulation AB of the Securities and Exchange Commission (“Regulation AB”), that:

 

1.

The Servicer is responsible for assessing compliance as of and for the Reporting Period with the servicing criteria set forth in Item 1122 (d) of Regulation AB, excluding the criteria which we have concluded are not applicable to the servicing activities we perform as indicated on Appendix A, attached hereto (the “Regulation AB Compliance Matrix”), with respect to the funding trust transactions backed by student loan receivables listed on Appendix B (the “Regulation AB Platform”);

 

2.

The Servicer has assessed its compliance with the Applicable Servicing Criteria for the Reporting Period and has concluded that the Servicer has complied, in all material respects, with the Applicable Servicing Criteria with respect to Regulation AB for the Regulation AB Platform; except as provided on Appendix C.

 

3.

With respect to servicing criterion 1122(d)(2)(i) and 1122(d)(4)(iv), management has engaged a vendor to perform the activities required by the servicing criteria. The Servicer’s management has determined that the vendor is not considered a “servicer” as defined in item 1101(j) of Regulation AB, and the Servicer’s management has elected to take responsibility for assessing compliance with the servicing criterion applicable to the vendor as permitted by Interpretation 17.06 of the SEC Division of Corporation Finance Manual of Publicly Available Telephone Interpretations (“Interpretation 17.06”). The Servicer has policies and procedures in place designed to provide reasonable assurance that the vendor’s activities comply in all material respects with the servicing criterion applicable to the vendor. The Servicer’s management is solely responsible for determining that it meets the SEC requirements to apply Interpretation 17.06 for the vendor and related criterion.

 

4.

Grant Thornton LLP, an independent registered public accounting firm, has issued an attestation report on the assessment of compliance with the Regulation AB Compliance Matrix as of and for the Reporting Period as set forth in this assertion.

The Servicer’s assertion is limited to activities processed on the Regulation AB Platform during the Reporting Period. It does not include an assessment of the impact of activities processed prior to the Reporting Period that might have affected the amounts reported by the Servicer during the Reporting Period.

By the end of June 2008, CLC Servicing will have transferred all pool assets and servicing activities to ACS Education Services, Inc. and exited the business of servicing student loans. The transfer of pool assets and servicing activities to ACS Education Services. Inc. will be done in accordance with the transaction documents.

IN WITNESS WHEREOF, the undersigned has executed this Report of the Servicer as of March 19, 2008.

 


CLC Servicing

 
 

By:

/s/ Steve Snyder

 

Name: Steve Snyder

 

Title: President, CLC Servicing

   
   

Date:

3/27/08

 
       

 

 

 

APPENDIX A

 

Compliance Consideration Items

Required Compliance

 

 

Applicable

Not
Applicable

Item #

General Servicing Considerations

 

 

1122(d)(1)(i)

Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreements.

X

 

1122(d)(1)(ii)

If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third party’s performance and compliance with such servicing activities.

X

 

1122(d)(1)(iii)

Any requirements in the transaction requirements to maintain a back-up servicer for the pool assets are maintained.

X

 

1122(d)(1)(iv)

A fidelity bond and errors and omissions policy is in effect on the party participating in the servicing function throughout the reporting period in the amount of coverage required by and otherwise in accordance with the terms of the transaction agreements.

X

 

 

Cash Collection & Administration

 

 

1122(d)(2)(i)

Payments on pool assets are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than 2 business days of receipt, or such other number of days specified in the transaction agreements.

X

 

1122(d)(2)(ii)

Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.

X

 

1122(d)(2)(iii)

Advances of funds or guarantees regarding collections, cash flows or distributions, and any interest or other fees charged for such advances, are made, reviewed and approved as specified in the transaction agreements.

 

X

1122(d)(2)(iv)

The related accounts for the transaction, such as cash reserve accounts established as a form of over collateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements.

 

X

 

 

 

 

 

Applicable

Not
Applicable

1122(d)(2)(v)

Each custodial account is maintained as a federally insured depository institution as set forth in the transaction agreements. For purposes of this criterion, “federally insured depository institution” with respect to a foreign financial institution means a foreign financial institution that meets the requirements of 240.13k-1(b)(1) of this chapter.

X

 

1122(d)(2)(vi)

Unissued checks are safeguarded so as to prevent unauthorized access.

X

 

1122(d)(2)(vii)

Reconciliations are prepared on a monthly basis for all asset backed accounts, including custodial accounts and related bank clearing accounts. These reconciliations: (A) Are mathematically accurate; (B) Are prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C) Are reviewed and approved by someone other than the person who prepared the reconciliations: and (D) Contain explanations for reconciling items. These reconciling items are resolved within 90 calendar days of their original identification, or such other number of days specified in the transaction agreements.

X

 

Investor Remittances & Reporting

1122(d)(3)(i)

Reports to investors, including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements. Specifically such reports (A) Are prepared in accordance with timeframes and other terms set forth in the transaction agreements; (B) Provide information calculated in accordance with the terms specified in the transaction agreements; (C) Are filed with the Commission as required by its rules and regulations; and (D) Agree with investors’ or the trustee’s records as to the total unpaid principal balance and number of pool assets serviced by the servicer.

 

X

1122(d)(3)(ii)

Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.

 

X

 

 

 

 

 

Applicable

Not
Applicable

1122(d)(3)(iii)

Disbursements made to an investor are posted within two business days to the servicer’s investor records, or such other number of days specified in the transaction agreements.

 

X

1122(d)(3)(iv)

Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.

 

X

 

Pool Asset Administration

 

 

1122(d)(4)(i)

Collateral or security on pool assets is maintained as required by the transaction agreements or related pool asset documents.

X

 

1122(d)(4)(ii)

Pool assets and related documents are safeguarded as required by the transaction agreements.

X

 

1122(d)(4)(iii)

Any additions, removals or substitutions to the asset pool are made, reviewed and approved in accordance with any conditions or requirements in the transaction agreements.

 

X

1122(d)(4)(iv)

Payments on pool assets, including any payoffs, made in accordance with the related pool asset documents are posted to the applicable servicer’s obligor records maintained no more than two business days after receipt, or such other number of days specified in the transaction agreements, and allocated to principal, interest or other items (e.g. escrow) in accordance with the related pool asset documents.

X

 

1122(d)(4)(v)

The servicer’s records regarding the pool assets agree with the servicer’s records with respect to an obligor’s unpaid principal balance.

X

 

1122(d)(4)(vi)

Changes with respect to the terms or status of an obligor’s pool assets (e.g., loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents.

X

 

 

 

 

 

 

Applicable

Not
Applicable

1122(d)(4)(vii)

Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframes or other requirements established by the transaction agreements.

X

 

1122(d)(4)(viii)

Records documenting collection efforts are maintained during the period a pool asset is delinquent in accordance with the transaction agreements, Such records are maintained on at least a monthly basis, or such other period specified in the transaction agreements, and describe the entity’s activities in monitoring delinquent pool assets including, for example, phone call, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment).

X

 

1122(d)(4)(ix)

Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.

X

 

1122(d)(4)(x)

Regarding any funds held in trust for an obligor (such as escrow accounts): (A) Such funds are analyzed, in accordance with the obligor’s pool asset documents, on at least an annual basis, or such other period specified in the transaction agreements; (B) Interest on such funds is paid, or credited to obligors in accordance with applicable pool asset documents and state laws: and (C) Such funds are returned to the obligor within 30 calendar days of full repayment of the related pool assets, or such other number of days specified in the transaction agreements.

 

X

1122(d)(4)(xi)

Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that such support has been received by the servicer at least 30 calendar days prior to these dates, or such other number of days specified in the transaction agreements.

 

X

 

 

 

 

 

Applicable

Not
Applicable

1122(d)(4)(xii)

Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from the servicer’s fund not charged to the obligor, unless the late payment was due to the obligor’s error or omission.

 

X

1122(d)(4)(xiii)

Disbursements made on behalf of an obligor are posted within two business days to the obligor’s records maintained by the servicer, or such other number of days specified in the transaction agreements.

 

X

1122(d)(4)(xiv)

Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.

X

 

1122(d)(4)(xv)

Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as set forth in the transaction agreements.

 

X

 

 

APPENDIX B

 

College Loan Corporation Trust I
College
Loan Corporation Trust II

 

Appendix C

 

 

Reg. AB Section 1122 (d)(2)(i)

Transfer of borrower payments to Deutsche Bank custodial account were not made within 2 days of receipt of payment.

Resolution: CLC Servicing (“CLCS”) was wiring funds to Deutsche Bank every two business days but was not considering the payment posting date. Effective November 9. 2007, CLCS changed its process and began wiring funds to Deutsche Bank within two business days of the payment posting date on the CLCS System.

 

Reg. AB Section 1122 (d)(2)(vii)

Bank account reconciliations have reconciling items that are not cleared within 90 days.

Resolution: As of December 31. 2007, bank account reconciling items are cleared within 90 days.

 

Reg. AB Section 1122 (d)(4)(vi)

Between July and September 2007, the Student Status Confirmation Report (SSCR) automation process was undergoing system enhancements and SSCR reports with student status changes were not processed timely. This resulted in some loans not entering repayment in a timely manner.

Resolution: The backlog of SSCR processing was resolved in early September and SSCR processing has remained current.

 

EX-33 6 collegeloan1-ex333_032808.htm EXHIBIT 33.3 Exhibit 33.3

Exhibit 33.3

GREAT LAKES EDUCATIONAL LOAN SERVICES, INC.

MANAGEMENT’S ASSESSMENT OF COMPLIANCE WITH REGULATION AB

SERVICING CRITERIA

Great Lakes Educational Loan Services, Inc. (“Great Lakes”) asserts as of December 31, 2007, and for the period from January 1, 2007 to December 31, 2007 (the “Reporting Period”), and as required by Item 1122(d) of Regulation AB of the Securities and Exchange Commission (“Regulation AB”), that:

 

1.

Great Lakes is responsible for assessing compliance as of and for the Reporting Period with the servicing criteria set forth in Item 1122(d) of Regulation AB, excluding the criteria which we have concluded are not applicable to the servicing activities we perform as indicated on the attached schedule (the “Applicable Servicing Criteria”), with respect to student loans serviced on the Great Lakes’ servicing system (the “Regulation AB Platform”);

 

2.

Great Lakes has assessed its compliance with the Applicable Servicing Criteria for the Reporting Period and has concluded that Great Lakes has complied, in all material respects, with the Applicable Servicing Criteria with respect to Regulation AB for the Regulation AB Platform; and

 

3.

Ernst & Young LLP, an independent registered public accounting firm, has issued an attestation report on the assessment of compliance with the Applicable Servicing Criteria for the Reporting Period as set forth in this assertion.

 

 

Great Lakes Educational Loan Services, Inc.

 
 
 /s/ Michael J. Noack

Name:

Michael J. Noack

Title:

Chief Servicing Officer

 

February 2, 2008

 

GREAT LAKES EDUCATIONAL LOAN SERVICES, INC.

Applicable Servicing Criteria Schedule (continued)

 

Reference

Criteria

Applicable

 

General Servicing Considerations

 

1122(d)(1)(i)

Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the Transaction Documents.

Yes

1122(d)(1)(ii)

If any material servicing activities arc outsourced to third parties, policies and procedures are instituted to monitor the third party’s performance and compliance with such servicing activities.

Yes

1122(d)(1)(iii)

Any requirements in the Transaction Documents to maintain a back-up servicer for the trust student loans arc maintained.

No

1122(d)(1)(iv)

A fidelity bond and errors and omissions policy is in effect on the party participating in the servicing function throughout the reporting period in the amount of coverage required by and otherwise in accordance with the terms of the Transaction Documents.

No

 

Cash Collection and Administration

 

1122(d)(2)(i)

Payments on trust student loans are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days following receipt, or such other number of days specified in the Transaction Documents.

Yes

1122(d)(2)(ii)

Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.

No

1122(d)(2)(iii)

Advances of funds or guarantees regarding collections, cash flows or distributions, and any interest or other fees charged for such advances, are made, reviewed and approved as specified in the Transaction Documents.

No

1122(d)(2)(iv)

The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of ovcrcollateralization, arc separately maintained (e.g., with respect to commingling of cash) as set forth in the Transaction Documents.

No

1122(d)(2)(v)

Each custodial account is maintained at a federally insured depository institution as set forth in the Transaction Documents. For purposes of this criterion, “federally insured depository institution” with respect to a foreign financial institution means a foreign financial institution that meets the requirements of Section 240.13k-1 (b)(1) of Regulation AB.

Yes

1122(d)(2)(vi)

Unissued checks arc safeguarded so as to prevent unauthorized access.

Yes

 

1122(d)(2)(vii)

Reconciliations are prepared on a monthly basis for all asset-backed securities related bank accounts, including custodial accounts and related bank clearing accounts. These reconciliations: (A) are mathematically accurate; (B) are prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the Transaction Documents; (C) are reviewed and approved by someone other than the person who prepared the reconciliation; and (D) contain explanations for reconciling items. These reconciling items are resolved within 90 calendar days of their original identification, or such other number of days specified in the Transaction Documents.

Yes

 

Investor Remittance and Reporting

 

1122(d)(3)(i)

Reports to investors, including those to be filed with the Commission, are maintained in accordance with the Transaction Documents and applicable Commission requirements. Specifically, such reports: (A) are prepared in accordance with timeframes and other terms set forth in the Transaction Documents; (B) provide information calculated in accordance with the terms specified in the Transaction Documents; (C) are filed with the Commission as required by its rules and regulations; and (D) agree with investors’ or the trustee’s records as to the total unpaid principal balance and number of student loans serviced by the Servicer.

No

1122(d)(3)(ii)

Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the Transaction Documents.

No

1122(d)(3)(iii)

Disbursements made to an investor are posted within two business days to the Servicer’s investor records, or such other number of days specified in the Transaction Documents.

No

1122(d)(3)(iv)

Amounts remitted to investors per the investor reports agree with canceled checks, or other form of payment, or custodial bank statements.

No

 

Pool Administration

 

1122(d)(4)(i)

Collateral or security on student loans is maintained as required by the Transaction Documents or related student loan documents.

No

1122(d)(4)(ii)

Student loans and related documents are safeguarded as required by the Transaction Documents.

Yes

1122(d)(4)(iii)

Any additions, removals or substitutions to the student loans are made, reviewed and approved in accordance with any conditions or requirements in the Transaction Documents.

No

 

1122(d)(4)(iv)

Payments on student loans, including any payoffs, made in accordance with the related student loan documents are posted to the Servicer’s obligor records maintained no more than two business days after receipt, or such other number of days specified in the Transaction Documents, and allocated to principal, interest or other items (e.g., escrow) in accordance with the related student loan documents.

Yes

1122(d)(4)(v)

The Servicer’s records regarding the student loans agree with the Servicer’s records with respect to an obligor’s unpaid principal balance.

Yes

112(d)(4)(vi)

Changes with respect to the terms or status of an obligor’s student loans (e.g., loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the Transaction Documents and related student loan documents.

Yes

112(d)(4)(vii)

Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframes or other requirements established by the Transaction Documents.

Yes

1122(d)(4)(viii)

Records documenting collection efforts are maintained during the period a student loan is delinquent in accordance with the Transaction Documents. Such records are maintained on at least a monthly basis, or such other period specified in the Transaction Documents, and describe the entity’s activities in monitoring delinquent student loans including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment).

Yes

1122(d)(4)(ix)

Adjustments to interest rates or rates of return for student loans with variable rates are computed based on the related student loan documents.

Yes

1122(d)(4)(x)

Regarding any funds held in trust for an obligor (such as escrow accounts): (A) such funds are analyzed, in accordance with the obligor’s student loan documents, on at least an annual basis, or such other period specified in the Transaction Documents; (B) interest on such funds is paid, or credited, to obligors in accordance with applicable student loan documents and state laws; and (C) such funds are returned to the obligor within 30 calendar days of full repayment of the related student loans, or such other number of days specified in the Transaction Documents.

No

 

1122(d)(4)(xi)

Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that such support has been received by the Servicer at least 30 calendar days prior to these dates, or such other number of days specified in the Transaction Documents.

No

1122(d)(4)(xii)

Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from the Servicer’s funds and not charged to the obligor unless the late payment was due to the obligor’s error or omission.

No

1122(d)(4)(xiii)

Disbursements made on behalf of an obligor are posted within two business days to the obligor’s records maintained by the Servicer, or such other number of days specified in the Transaction Documents.

No

1122(d)(4)(xiv)

Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the Transaction Documents.

Yes

1122(d)(4)(xv)

Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as set forth in the Transaction Documents.

Yes

 

 

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M'.NZQ)\1=7\/?%V3XDIH'Q"UY?"C._A9A#*5VJ=PB\+8_P!6P7]8**`LNR^Y M'YQ^//V9?B-K/A#]JKP?IUUX1U;0?'WA/Q=+\"=!UA7T^?P5XJ^)/AZ9?B!H M>OZU"KROX8E\7QGQ='A"'7Q#*%RZX/1_LZ_L^^._@MH_Q"\+:K#HGCJV\9_$ MU_B?8ZOJMZ/[2T)M;\.^'DN/#KDQ.)(/!'BO1%C\"NK!(_!<<,(>.Z0QG[YH MI?6[Z7;N_P"7TV^[[PLNR^Y'YOP?L[_$&^^&6G?#S6$UC2[S15T._/B?PO\` M$*72O$OA_6=#TCQ-;!?AS-_PB)AF\.QSZXT,Q+XI:ZCC6XMWD]QU MWPI\3/&'P#^(OPQU_1_#I\87?PWN/!^BZU87LFF>&?$FM:WX%$;:ZD**9/#R MKXK>4,%5MK>7L!#@U]7T4PLNR_K_`(9?BB@84444`%%%%`!111 D0`4444`%%%%`!1110`4444`%%%%`!1110`4444`%%%%`'__9 ` end EX-33 8 collegeloan1-ex334_032808.htm EXHIBIT 33.4 Exhibit 33.4

Exhibit 33.4

 

MANAGEMENT’S ASSERTION OF COMPLIANCE

Management of the Trust & Securities Services department of Deutsche Bank National Trust Company and Deutsche Bank Trust Company Americas (collectively the “Company”) is responsible for assessing compliance with the servicing criteria set forth in Item 1122(d) of Regulation AB promulgated by the Securities and Exchange Commission. Management has determined that the servicing criteria are applicable in regard to the servicing platform for the period as follows:

Platform: Publicly-issued (i.e., transaction-level reporting required under the Securities Exchange Act of 1934, as amended) residential mortgage-backed securities, commercial mortgage-backed securities and other asset-backed securities issued on or after January 1, 2006 for which the Company provides trustee, securities administration, paying agent or custodian services, excluding any publicly issued transactions sponsored or issued by any government sponsored entity (the “Platform”).

Applicable Servicing Criteria: All servicing criteria set forth in Item 1122(d), except for the following criteria: 1122(d)(2)(iii), 1122(d)(4)(iv), 1122(d)(4)(v), 1122(d)(4)(vi), 1122(d)(4)(vii), 1122(d)(4)(viii), 1122(d)(4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii) and 1122(d)(4)(xiv), which management has determined arc not applicable to the activities the Company performs with respect to the Platform (the “Applicable Servicing Criteria”). Servicing criterion 1122(d)(4)(iii) is applicable to the activities the Company performance with respect to the Platform only as it relates to the Company’s obligation to report additions, removals or substitutions on reports to investors in accordance with the transactions agreements. With respect to applicable servicing criterion 1122(d)(1)(iii), there were no activities performed during the twelve months ended December 31, 2007 with respect to the Platform, because there were no occurrences of events that would require the Company to perform such activities.

Period: Twelve months ended December 31, 2007 (the “Period”).

Management’s interpretation of Applicable Servicing Criteria: The Company’s management has determined that servicing criteria 1122(d)(1)(iii) is applicable only with respect to its continuing obligation to act as, or locate a, successor servicer under the circumstances referred to in certain governing documents. It is management’s interpretation that Deutsche Bank Trust Company Americas has no other active back-up servicing responsibilities in regards to 1122(d)(1)(iii) as of and for the Period.

Third parties classified as vendors: With respect to servicing criteria 1122(d)(2)(i), 1122(d)(4)(i), and 1122(d)(4)(ii), management has engaged various vendors to perform the activities required by these servicing criteria. The Company’s management has determined that these vendors ate not considered a “servicer” as defined in Item 1101(j) of Regulation AB, and the Company’s management has elected to take responsibility for assessing compliance with the servicing criteria applicable to each vendor as permitted by Interpretation 17.06 of the SEC Division of Corporation Finance Manual of Publicly Available Telephone Interpretations (“Interpretation 17.06”). As permitted by Interpretation 17.06, management has asserted that it has policies and procedures in place to provide reasonable assurance that the vendor’s activities comply in all material respects with the servicing criteria applicable to each vendor. The Company’s management is solely responsible for determining that it meets the SEC requirements to apply Interpretation 17.06 for the vendors and related criteria.

With respect to the Platform and the Period, the Company’s management provides the following assertion of compliance with respect to the Applicable Servicing Criteria:

1.         The Company’s management is responsible for assessing the Company’s compliance with the Applicable Servicing Criteria.

2.         The Company’s management has assessed compliance with the Applicable Servicing Criteria, including servicing criteria for which compliance is determined based on Interpretation 17.06 as described above. In performing this assessment, management used the criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB.

3.         Based on such assessment, as of and for the Period, the Company has complied, in all material respects, with the Applicable Servicing Criteria.

KPMG LLP, a registered public accounting firm, has issued an attestation report with respect to the management’s assertion of compliance with the Applicable Servicing Criteria as of and for the Period.

 

 

DEUTSCHE BANK NATIONAL TRUST COMPANY

 

By:

/s/ Gary R. Vaughan

 

 

Name: Gary R. Vaughan

 

Its: Managing Director

 

 

By:

/s/ David Co

 

 

Name: David Co

 

Its: Director

 

 

By:

/s/ Jose Sicilia

 

 

Name: Jose Sicilia

 

Its: Managing Director



 

 

By:

/s/ Kevin Fischer

 

 

Name: Kevin Fischer

 

Its: Director



 

 

By:

/s/ Robert Prier

 

 

Name: Robert Prier

 

Its: Director



 

DEUTSCHE BANK TRUST COMPANY AMERICAS

 

By:

/s/ Kevin C. Weeks

 

 

Name: Kevin C. Weeks

 

Its: Managing Director



 

 

By:

/s/ Jenna Kaufman

 

 

Name: Jenna Kaufman

 

Its: Director



February 29, 2008
 

 

 

 

 

 

 

EX-33 9 collegeloan1-ex335_032808.htm EXHIBIT 33.5 Exhibit 33.5

EXHIBIT 33.5

MANAGEMENT’S ASSESSMENT OF COMPLIANCE

WITH REGULATION AB SERVICING CRITERIA

College Loan Corporation (the “Administrator”) asserts as of December 31, 2007 and for the period from January 1, 2007 to December 31, 2007 (the “Reporting Period”) and as required by Item 1122(a) of Regulation AB of the Securities and Exchange Commission (“Regulation AB”), that:

 

1.

The Servicer is responsible for assessing compliance as of and for the Reporting Period with the servicing criteria set forth in Item 1122 (d) of Regulation AB, excluding the criteria which we have concluded are not applicable to the servicing activities we perform as indicated on Appendix A, attached hereto, (the “Regulation AB Compliance Matrix”) with respect to the funding trust transactions backed by student loan receivables listed on Appendix B (the “Regulation AB Platform”);

 

2.

The Servicer has assessed its compliance with the Applicable Servicing Criteria for the Reporting Period and has concluded that the Servicer has complied, in all material respects, with the Applicable Servicing Criteria with respect to Regulation AB for the Regulation AB Platform;

 

3.

As it relates to Item 1122(d)(3)(ii), the Servicer is responsible only for computing amounts that will be allocated to investors. The Servicer is not responsible for remitting the allocated amounts to investors, which is the responsibility of the Trustee;

 

4.

Grant Thornton LLP, an independent registered public accounting firm, has issued an attestation report on the assessment of compliance with the Regulation AB Compliance Matrix as of and for the Reporting Period as set forth in this assertion.

The Servicer’s assertion is limited to activities processed on the Regulation AB Platform during the Reporting Period. It does not include an assessment of the impact of activities processed prior to the Reporting Period that might have affected the amounts reported by the Servicer during the Reporting Period.

IN WITNESS WHEREOF, the undersigned has executed this Report of the Servicer as of March 19, 2008.

 

 

COLLEGE LOAN CORPORATION

 

 

 

 

 

 

 

By:

/s/ John Falb

 

Name:

John Falb

 

Title:

Chief Financial Officer

 

Date: 3/19/08

 

 

APPENDIX A

 

 

Compliance Consideration Items

Required Compliance

 

 

Applicable

Not

Applicable

Item #

General Servicing Considerations

 

 

1122(d)(1)(i)

Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreements.

X

 

1122(d)(1)(ii)

If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third party’s performance and compliance with such servicing activities.

 

X

1122(d)(1)(iii)

Any requirements in the transaction requirements to maintain a back-up servicer for the pool assets are maintained.

 

X

1122(d)(1)(iv)

A fidelity bond and errors and omissions policy is in effect on the party participating in the servicing function throughout the reporting period in the amount of coverage required by and otherwise in accordance with the terms of the transaction agreements.

 

X

 

Cash Collection & Administration

 

 

1122(d)(2)(i)

Payments on pool assets are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than 2 business days of receipt, or such other number of days specified in the transaction agreements.

 

X

1122(d)(2)(ii)

Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.

 

X

1122(d)(2)(iii)

Advances of funds or guarantees regarding collections, cash flows or distributions, and any interest or other fees charged for such advances, are made, reviewed and approved as specified in the transaction agreements.

 

X

1122(d)(2)(iv)

The related accounts for the transaction, such as cash reserve accounts established as a form of over collateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements.

 

X

1122(d)(2)(v)

Each custodial account is maintained as a federally insured depository institution as set forth in the transaction agreements. For purposes of this criterion, “federally insured depository institution” with respect to a foreign financial institution means a foreign financial institution that meets the requirements of 240.13k-1(b)(1) of this chapter.

 

X

1122(d)(2)(vi)

Unissued checks are safeguarded so as to prevent unauthorized access.

 

X

1122(d)(2)(vii)

Reconciliations are prepared on a monthly basis for all asset backed accounts, including custodial accounts and related bank clearing accounts. These reconciliations: (A) Are mathematically accurate; (B) Are prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C) Are reviewed and approved by someone other than the person who prepared the reconciliations; and (D) Contain explanations for reconciling items. These reconciling items are resolved within 90 calendar days of their original identification, or such other number of days specified in the transaction agreements.

X

 

 

 

 

 

Applicable

Not

Applicable

 

Investor Remittances & Reporting

 

 

1122(d)(3)(i)

Reports to investors, including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements. Specifically such reports (A) Are prepared in accordance with timeframes and other terms set forth in the transaction agreements; (B) Provide information calculated in accordance with the terms specified in the transaction agreements; (C) Are filed with the Commission as required by its rules and regulations; and (D) Agree with investors’ or the trustee’s records as to the total unpaid principal balance and number of pool assets serviced by the servicer.

X

 

1122(d)(3)(ii)

Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.

X

 

1122(d)(3)(iii)

Disbursements made to an investor are posted within two business days to the servicer’s investor records, or such other number of days specified in the transaction agreements.

 

X

1122(d)(3)(iv)

Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.

X

 

 

Pool Asset Administration

 

 

1122(d)(4)(i)

Collateral or security on pool assets is maintained as required by the transaction agreements or related pool asset documents.

 

X

1122(d)(4)(ii)

Pool assets and related documents are safeguarded as required by the transaction agreements.

X

 

1122(d)(4)(iii)

Any additions, removals or substitutions to the asset pool are made, reviewed and approved in accordance with any conditions or requirements in the transaction agreements.

X

 

1122(d)(4)(iv)

Payments on pool assets, including any payoffs, made in accordance with the related pool asset documents are posted to the applicable servicer’s obligor records maintained no more than two business days after receipt, or such other number of days specified in the transaction agreements, and allocated to principal, interest or other items (e.g. escrow) in accordance with the related pool asset documents.

 

X

1122(d)(4)(v)

The servicer’s records regarding the pool assets agree with the servicer’s records with respect to an obligor’s unpaid principal balance.

 

X

1122(d)(4)(vi)

Changes with respect to the terms or status of an obligor’s pool assets (e.g. loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents.

 

X

1122(d)(4)(vii)

Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframes or other requirements established by the transaction agreements.

 

X

1122(d)(4)(viii)

Records documenting collection efforts are maintained during the period a pool asset is delinquent in accordance with the transaction agreements, Such records are maintained on at least a monthly basis, or such other period specified in the transaction agreements, and describe the entity’s activities in monitoring delinquent pool assets including, for example, phone call, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment).

 

X

1122(d)(4)(ix)

Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.

 

X

1122(d)(4)(x)

Regarding any funds held in trust for an obligor (such as escrow accounts): (A) Such funds are analyzed, in accordance with the obligor’s pool asset documents, on at least an annual basis, or such other period specified in the transaction agreements; (B) Interest on such funds is paid, or credited to obligors in accordance with applicable pool asset documents and state laws; and (C) Such funds are returned to the obligor within 30 calendar days of full repayment of the related pool assets, or such other number of days specified in the transaction agreements.

 

X

1122(d)(4)(xi)

Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that such support has been received by the servicer at least 30 calendar days prior to these dates, or such other number of days specified in the transaction agreements.

 

X

1122(d)(4)(xii)

Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from the servicer’s fund not charged to the obligor, unless the late payment was due to the obligor’s error or omission.

 

X

1122(d)(4)(xiii)

Disbursements made on behalf of an obligor are posted within two business days to the obligor’s records maintained by the servicer, or such other number of days specified in the transaction agreements.

 

X

1122(d)(4)(xiv)

Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.

 

X

1122(d)(4)(xv)

Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as set forth in the transaction agreements.

X

 

 

 

APPENDIX B

 

College Loan Corporation Trust I

College Loan Corporation Trust II

 

 

EX-34 10 collegeloan1-ex341_032808.htm EXHIBIT 34.1 Exhibit 34.1

Exhibit 34.1

 


 

KPMG LLP
Suite 800
400 Capitol Mall
Sacramento, CA 95814

 

 

 

Report of Independent Registered Public Accounting Firm

 

The Board of Directors
Affiliated Computer Services, Inc.
Education Services:

We have examined the compliance of Affiliated Computer Services, Inc. (ACS) Education Services (the Company) with the servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission’s Regulation AB for (a) publicly issued student loan backed security transactions issued on or after January 1, 2006 that are serviced by the Company for College Loan Corporation and (b) student loans for which the Company commenced servicing activities for Key Bank, N.A. on or after January 1, 2006 (collectively, the Platform), except for servicing criteria 1122(d)(1)(iii), 1122(d)(2)(iii)-(iv), 1122(d)(3)(i)-(iv), 1122(d)(4)(iii), 1122(d)(4)(x)-(xiii) and 1122(d)(4)(xv), which the Company has determined are not applicable to the activities it performs with respect to the Platform, as of and for the year ended December 31, 2007. Management is responsible for the Company’s compliance with those servicing criteria. Our responsibility is to express an opinion on the Company’s compliance based on our examination.

Our examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the servicing criteria specified above and performing such other procedures as we considered necessary in the circumstances. Our examination included testing of less than all of the individual asset-backed transactions and securities that comprise the Platform, testing of less than all of the servicing activities related to the Platform, and determining whether the Company processed those selected transactions and performed those selected activities in compliance with the servicing criteria. Furthermore, our procedures were limited to the selected transactions and servicing activities performed by the Company during the period covered by this report. Our procedures were not designed to determine whether errors may have occurred either prior to or subsequent to our tests that may have affected the balances or amounts calculated or reported by the Company during the period covered by this report for the selected transactions or any other transactions. We believe that our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the Company’s compliance with the servicing criteria.

Our examination disclosed the following material noncompliance with servicing criteria 1122(d)(2)(ii) and 1122(d)(4)(iv), as applicable to the Company during the year ended December 31, 2007:

With respect to servicing criterion 1122(d)(2)(ii), disbursements made via wire transfers on behalf of an obligor to the lender were not made by authorized personnel.

With respect to servicing criterion 1122(d)(4)(iv), certain payments on pool assets made in accordance with the related pool asset documents were posted to the obligor records more than two business days after receipt.

As described in the accompanying ACS Education Services Management Assessment, the Company has engaged a vendor to perform the activities required by servicing criterion 1122(d)(2)(i). The Company has determined that this vendor is not considered a “servicer” as defined in Item 1101(j) of Regulation AB, and the Company has elected to take responsibility for assessing compliance with the servicing criterion applicable to the vendor as permitted by Interpretation 17.06 of the SEC Division of Corporation Finance Manual of Publicly Available Telephone Interpretations (Interpretation 17.06). As permitted by Interpretation 17.06, the Company has asserted that it has policies and procedures in place designed to provide reasonable assurance that the vendor’s activities comply in all material respects with the servicing criteria applicable to the vendor.  The Company is solely responsible for determining that it meets the SEC requirements to apply Interpretation 17.06 for the vendor and related criterion as described in its assertion, and we performed no procedures with respect to the Company’s eligibility to apply Interpretation 17.06.

 

In our opinion, except for the material noncompliance described above, ACS Education Services complied, in all material respects, with the aforementioned servicing criteria, including servicing criterion 1122(d)(2)(i) for which compliance is determined based on Interpretation 17.06 as described above, as of and for the year ended December 31, 2007.

 

 


 

Sacramento, California

March 10, 2008

 

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EXHIBIT 34.2

 

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

 

Board of Directors

CLC Servicing

 

We have examined CLC Servicing’s (the “Company”) compliance with the servicing criteria set forth in Item 1122(d) of the U.S. Securities and Exchange Commission’s Regulation AB for funding trust transactions backed by student loan receivables (the “Platform”) described in the accompanying Management’s Assessment of Compliance with Regulation AB Servicing Criteria (“Management’s Report”) as of and for the year ended December 31, 2007, excluding criteria 1122(d)(2)(iii) and (iv), 1122(d)(3)(i) through 1122(d)(3)(iv), 1122(d)(4)(iii), 1122(d)(4)(x) through 1122(d)(4)(xiii), and 1122(d)(4)(xv) which management has determined are not applicable to the activities performed by the Company with respect to the Platform. The Platform consists of the asset-backed transactions and securities defined by management in Appendix B of Management’s Report. Management is responsible for the Company’s compliance with the applicable servicing criteria. Our responsibility is to express an opinion on the Company’s compliance with the applicable servicing criteria for the Platform based on our examination.

Our examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the applicable servicing criteria for the Platform and performing such other procedures as we considered necessary in the circumstances. Our examination included testing selected asset-backed transactions and securities constituting the Platform and evaluating whether the Company performed servicing activities related to those transactions and securities in compliance with the applicable servicing criteria for the period covered by this report. Accordingly, our testing may not have included servicing activities related to each asset-backed transaction or security constituting the Platform. Further, our examination was not designed to detect material noncompliance that may have occurred prior to the period covered by this report and that may have affected the Company’s servicing activities during the period covered by this report. We believe that our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the Company’s compliance with the applicable servicing criteria.

As described in Management’s Report, the Company engaged various vendors to perform servicing activities with respect to criteria 1122(d)(2)(i) and 1122(d)(4)(iv). The Company determined that each vendor is not considered a “servicer,” as that term is defined in Item 1101(j) of Regulation AB, and therefore, the Company is assuming responsibility for compliance with such servicing criteria applicable to each vendor’s servicing activities. In accordance with Regulation AB and its related interpretations, the requirement for management to assess compliance with the servicing criteria applicable to a vendor’s activities is satisfied if the Company has instituted policies and procedures to monitor whether such vendor’s activities comply in all material respects with such criteria. Compliance with the applicable servicing criteria is achieved if those policies and procedures are designed to provide reasonable assurance that such vendor’s activities comply with such criteria and those policies and procedures are operating effectively for the period covered by Management’s Report. Our examination does not provide a legal determination of whether a vendor is or is not considered a servicer, and therefore, on whether the Company, in its Management Report, is eligible to elect to take responsibility for assessing compliance with the servicing criteria applicable to each vendor’s servicing activities.

 

Our examination disclosed the following material noncompliance with servicing criteria 1122(d)(2)(i), 1122(d)(2)(vii) and 1122(d)(4)(vi) applicable to the Company as of and for the year ended December 31, 2007 for the Platform:

 

With respect to servicing criterion 1122(d)(2)(i), deposit of payments on pool assets into the appropriate custodial bank account were made more than more than 2 business days after receipt.

 

With respect to servicing criterion 1122(d)(2)(vii), reconciling items in the custodial account bank reconciliations were not resolved within 90 days of their original identification.

 

With respect to servicing criterion 1122(d)(4)(vi), borrower and loan status changes were not made, reviewed and approved by appropriate individuals.

In our opinion, except for the material noncompliance described in the preceding paragraph, CLC Servicing complied, in all material respects, with the aforementioned applicable servicing criteria as of and for the year ended December 31, 2007 for the funding trust transactions backed by student loan receivables platform.

We do not express an opinion or any other form of assurance on management’s remediation procedures in Appendix C of Management’s Report or the Company’s exit strategy described in Management’s Report.

 

/s/ GRANT THORNTON LLP

 

San Diego, California

March 19, 2008

 

EX-34 14 collegeloan1-ex343_03208.htm EXHIBIT 34.3 Exhibit 34.3


 

Ernst & Young LLP
875 East Wisconsin Avenue
Milwaukee, Wisconsin 53202


Phone:   (414) 273-5900
Fax:        (414) 223-7200
www.ey.com

 

 

Exhibit 34.3

 

Report of Independent Registered Public Accounting Firm

We have examined management’s assertion, included in the accompanying Management’s Assessment of Compliance with Regulation AB Servicing Criteria, that Great Lakes Educational Loan Services, Inc. (the “Company”) complied with the servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission’s Regulation AB for the Company’s student loan servicing platform (the “Platform”) as of and for the year ended December 31, 2007, except for 1122(d)(1)(iii)-(iv), 1122(d)(2)(ii)-(iv), 1122(d)(3)(1)-(iv), 1122(d)(4)(i), 1122(d)(4)(iii), and 1122(d)(4)(x)-(xiii), which the Company has determined are not applicable to the activities performed by them with respect to the servicing platform covered by this report. Management is responsible for the Company’s compliance with those servicing criteria. Our responsibility is to express an opinion on management’s assertion about the Company’s compliance with the servicing criteria based on our examination.

Our examination was conducted in accordance with standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the applicable servicing criteria and performing such other procedures as we considered necessary in the circumstances. Our examination included testing of less than all of the individual asset-backed transactions and securities that comprise the Platform, testing of less than all of the servicing activities related to the Platform, and determining whether the Company processed those selected transactions and performed those selected activities in compliance with the servicing criteria. Furthermore, our procedures were limited to the selected transactions and servicing activities performed by the Company during the period covered by this report. Our procedures were not designed to determine whether errors may have occurred either prior to or subsequent to our tests that may have affected the balances or amounts calculated or reported by the Company during the period covered by this report for the selected transactions or any other transactions. We believe that our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the Company’s compliance with the servicing criteria.

In our opinion, management’s assertion that the Company complied with the aforementioned servicing criteria as of and for the year ended December 31, 2007, for the Company’s student loan servicing platform is fairly stated in all material respects.

 

February 2, 2008

 

 

 

0802-0910750

A member firm of Ernst & Young Global Limited

 

 

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M"'A3P)^T;^U9^TUXX^/?Q`\%^$?%I^(FE>!='_X1[P%\+?A3X.3QMA$UT>'/ MAQ\-?#8+Q_(K.R`HRNM?I_10`4444`%?)7P2_9"_9W_9S\9_%WQY\%/A3X?^ M'GB[X^^-5\9_%#5-%BN9IM?U+=J^L",.VY-'T-M>\0^(_%9\/>'U7PP/%?B; MQ8Z+&_B+47/UK10`4444`%%%%`!1110`4444`%%%%`!1110`4444`%%%%`!1 - -110`4444`%%%%`'_V3\_ ` end EX-34 17 collegeloan1-ex344_032808.htm EXHIBIT 34.4 Exhibit 34.4

Exhibit 34.4

KPMG LLP
303 East Wacker Drive
Chicago, IL 60601-5212

 

Report of Independent Registered Public Accounting Firm

The Board of Directors

The Trust & Securities Services department of Deutsche Bank National Trust Company and Deutsche Bank Trust Company Americas:

We have examined the accompanying management’s assertion that the Trust & Securities Services department of Deutsche Bank National Trust Company and Deutsche Bank Trust Company Americas (collectively the “Company”) complied with the servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission’s Regulation AB for publicly-issued (i.e., transaction-level reporting required under the Securities Exchange Act of 1934, as amended) residential mortgage-backed securities, commercial mortgage-backed securities and other asset-backed securities issued on or after January 1, 2006, for which the Company provides trustee, securities administration, paying agent or custodian services, excluding any publicly issued transactions, sponsored or issued by any government sponsored entity (the Platform), except for servicing criteria 1122(d)(2)(iii), 1122(d)(4)(iv), 1122(d)(4)(v), 1122(d)(4)(vi), 1122(d)(4)(vii), 1122(d)(4)(viii), 1122(d)(4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii) and 1122(d)(4)(xiv), which the Company has determined are not applicable to the activities it performs with respect to the Platform, as of and for the twelve months ended December 31, 2007. Servicing criterion 1122(d)(4)(iii) is applicable to the activities the Company performs with respect to the Platform only as it relates to the Company’s obligation to report additions, removals or substitutions on reports to investors in accordance with the transactions agreements. With respect to applicable servicing criterion 1122(d)(1)(iii), management’s assertion indicates that there were no activities performed during the twelve months ended December 31, 2007 with respect to the Platform, because there were no occurrence of events that would require the Company to perform such activities. Management is responsible for the Company’s compliance with those servicing criteria. Our responsibility is to express an opinion on management’s assertion about the Company’s compliance based on our examination.

Our examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the servicing criteria specified above and performing such other procedures as we considered necessary in the circumstances. Our examination included testing selected asset-backed transactions and securities that comprise the Platform, selected servicing activities related to the Platform, and determining whether the Company processed those selected transactions and performed those selected activities in compliance with the servicing criteria. Furthermore, our procedures were limited to the selected transactions and servicing activities performed by the Company during the period covered by this report. Our procedures were not designed to determine whether errors may have occurred either prior to or subsequent to our tests that may have affected the balances or amounts calculated or reported by the Company during the period covered by this report for the selected transactions or any other transactions. We believe that our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the Company’s compliance with the servicing criteria.

As described in the accompanying management’s assertion for servicing criteria 1122 (d)(2)(i), 1122(d)(4)(i) and 1122(d)(4)(ii), the Company has engaged various vendors to perform the activities required by these servicing criteria. The Company has determined that these vendors are not considered a “servicer” as defined in Item 1101(j) of Regulation AB, and the Company has elected to take responsibility for assessing compliance with the servicing criteria applicable to each vendor as permitted by Interpretation 17.06 of the SEC Division of Corporation Finance Manual of Publicly Available Telephone Interpretations (“Interpretation 17.06”). As permitted by Interpretation 17.06, the Company has asserted that it has policies and procedures in place designed to provide reasonable assurance that the vendors’ activities comply in all material respects with the servicing criteria applicable to each vendor. The Company is solely responsible for determining that it meets the SEC requirements to apply Interpretation 17.06 for the vendors and related criteria as described in its assertion and we performed no procedures with respect to the Company’s eligibility to apply Interpretation 17.06.

In our opinion, management’s assertion that the Company complied with the aforementioned servicing criteria, including servicing criteria 1122 (d)(2)(i), 1122(d)(4)(i) and 1122(d)(4)(ii) for which compliance is determined based on Interpretation 17.06 as described above, as of and for the twelve months ended December 31, 2007 is fairly stated, in all material respects.


 

Chicago, Illinois

February 29, 2008

 

EX-34 18 collegeloan1-ex345_032808.htm EXHIBIT 34.5 Exhibit 34.5

Exhibit 34.5

 

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

 

Board of Directors and Shareholders

College Loan Corporation

 

We have examined management’s assertion, included in the accompanying Management’s Assessment of Compliance with Regulation AB Servicing Criteria (“Management’s Report”), that College Loan Corporation (the “Company”) complied with the servicing criteria set forth in Item 1122(d) of the U.S. Securities and Exchange Commission’s Regulation AB for the funding trust transactions backed by student loan receivables (the “Platform”) as of and for the year ended December 31, 2007, excluding criteria 1122(d)(1)(ii) through 1122(d)(1)(iv), 1122(d)(2)(i) through 1122(d)(2)(vi), 1122(d)(3)(iii), 1122(d)(4)(i), and 1122(d)(4)(iv) through 1122(d)(4)(xiv), which management has determined are not applicable to the activities performed by the Company with respect to the Platform. The Platform consists of the asset-backed transactions and securities defined by management in Appendix B of Management’s Report. Management is responsible for the Company’s compliance with the applicable servicing criteria. Our responsibility is to express an opinion on management’s assertion about the Company’s compliance with the applicable servicing criteria for the Platform based on our examination.

Our examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the applicable servicing criteria for the Platform and performing such other procedures as we considered necessary in the circumstances. Our examination included testing selected asset-backed transactions and securities constituting the Platform and evaluating whether the Company performed servicing activities related to those transactions and securities in compliance with the applicable servicing criteria for the period covered by this report. Accordingly, our testing may not have included servicing activities related to each asset-backed transaction or security constituting the Platform. Further, our examination was not designed to detect material noncompliance that may have occurred prior to the period covered by this report and that may have affected the Company’s servicing activities during the period covered by this report. We believe that our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the Company’s compliance with the applicable servicing criteria.

In our opinion, management’s assertion that College Loan Corporation complied with the aforementioned applicable servicing criteria as of and for the year ended December 31, 2007 for the funding trust transactions backed by student loan receivables platform is fairly stated, in all material respects. 

 

/s/ GRANT THORNTON LLP

 

San Diego, California

March 19, 2008

 

EX-35 19 collegeloan1-ex351_032808.htm EXHIBIT 35.1 Exhibit 35.1

Exhibit 35.1


 

SERVICER COMPLIANCE STATEMENT FOR

 COLLEGE LOAN CORPORATION TRUST I

March 10, 2008

College Loan Corporation

14303 Gateway Place

Poway, CA 92064

In connection with the Annual Report on Form 10-K of the College Loan Corporation Trust I for the fiscal year ending December 31, 2007 (the “Report”) and pursuant to Item 1123 of Regulation AB of the Securities and Exchange Commission, the undersigned, a duly authorized officer of the ACS Education Services Inc. (the “Servicer”), does hereby certify and represent as follows:

1.

A review of the activities and performance of the Servicer under the Agreement dated as of March 11, 2002, as amended, between the Servicer and College Loan Corporation Trust I (the “Servicing Agreement”) for the period that is the subject of the Report has been made under the supervision of the undersigned;

 

2.

To the best knowledge of the undersigned, based on such review, the Servicer has fulfilled all of its obligations under the Servicing Agreement in all material respects throughout the period that is the subject of the Report; except for material noncompliance with servicing criteria 1122(d)(2)(ii) and 1122(d)(4)(iv). Related to criterion 1122(d)(2)(ii), disbursements made via wire transfers on behalf of an obligor to the lender were not made by authorized personnel. ACS Education Services did not maintain documented evidence that authorized personnel made disbursements via wire transfer on behalf of an obligor to the lender. While ACS Education Services management believes controls are in place which provide management reasonable assurance that wire transfers are made only by authorized personnel, documentation evidencing such was not available for a portion of the year ended December 31, 2007. Additional documentation (daily user access reports) is now retained to provide evidence of compliance with servicing criterion 1122(d)(2)(ii). Related to servicing criterion 1122(d)(4)(iv), certain payments on pool assets were posted to the obligor records more than two business days after receipt. For certain pool assets, the related transaction agreement states that payments are to be made within a mutually acceptable schedule; the referenced schedule has not been executed. ACS Education Services expects to execute a mutually acceptable schedule with the applicable lender that will specify payment posting and effective date time frames when payments received do not allow for the systematic posting within two days after receipt.

 

 

3.

To the best knowledge of the undersigned, based on such review, there have been no failures to fulfill any such obligation in any material respect, except for material noncompliance with servicing criteria 1122(d)(2)(ii) and 1122(d)(4)(iv). Related to criterion 1122(d)(2)(ii), disbursements made via wire transfers un behalf of an obligor to the lender were not made by authorized personnel. ACS Education Services did not maintain documented evidence that authorized personnel made disbursements via wire transfer on behalf of an obligor to the lender. While ACS Education Services management believes controls are in place which provide management reasonable assurance that wire transfers are made only by authorized personnel, documentation evidencing such was not available for a portion of the year ended December 31, 2007. Additional documentation (daily user access reports) is now retained to provide evidence of compliance with servicing criterion 1122(d)(2)(ii). Related to servicing criterion 1122(d)(4)(iv), certain payments on pool assets were posted to the obligor records more than two business days after receipt. For certain pool assets, the related transaction agreement states that payments are to be made within a mutually acceptable schedule; the referenced schedule has not been executed. ACS Education Services expects to execute a mutually acceptable schedule with the applicable lender that will specify payment posting and effective date time frames when payments received do not allow for the systematic posting within two days after receipt.

 

IN WITNESS WHEREOF, the undersigned has executed this Servicer Compliance Statement as of March 10, 2008.

 

ACS EDUCATION SERVICES, INC.

 

By:

/s/ Meta Gonzalez

 

Name:   Meta Gonzalez

Title:  Senior Vice President

 

 

ACS
2277 East 220th Street – Long Beach, CA 90810-1596
310 513 2700

 

 

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ML^?$#5M"TRW^)/P@^.7PF^('PC\7^"/'T.FV;^*-'L=+^(&AZ-<>)/#$&IRS M?\([XNT*35-%UC3#`6O(-6AU/2]/^J:**`"OX[O^"V__``3._;A\9_\`!5_] MA_\`X*C_``-^%^L_M??!']G/6?@9=>/?V=?#&O\`ARS^(OA&U^$?Q1O?'6OW M?@/PQXRUK1=$\40^+[*^2]M(M)NI-83Q98I#J]B^CFTO;;^Q&B@#\L/A9^V_ MK'[3W[1?P9\+>$O^"<7[7'A_P/HW_";:QXH_:=_:K^!;?L\:?\#]1;P%JGV+ M3O`/AOXI6\/Q/\6>(?&MS/;^!M9U/P?H^E^'+33M7NA)XBURUBU&PM_U/HHH M`*^6OVW/!O@3XA_LE?M`>!_B9\"/%O[3G@?Q1\-=?TC7O@%X#6U'C3XIPW4* MBS\+>%[J\USPU;:5KESJ(LY]-UZ3Q!HY\/W5O'K<=_;RV"./J6B@#^`KX'?L MG_\`!0G]EKX_?LMZ-_P1@UW_`(*O^`O@WKWQ'@D_:)_98_X*)_!#7_!7[.OP M#\#R^)=/E\2,GCCQS!H'PH\=VUY'J'B0RP_!&V\1>-;NVM5U_2/&EYJEY9B; M^\BS\"^%-/\`%^I^/++1X;;Q7K.FQZ3JFK12W*O>V,36C)'-;>=]C,@-A9CS 0Q;B?;`J^9M:0/UM%`'__V3\_ ` end EX-35 21 collegeloan1-ex352_032808.htm EXHIBIT 35.2 Exhibit 35.2

Exhibit 35.2

SERVICER COMPLIANCE STATEMENT FOR

COLLEGE LOAN CORPORATION TRUST I

March 19, 2008

College Loan Corporation

14303 Gateway Place

Poway, CA 92064

In connection with the Annual Report on Form 10-K of the College Loan Corporation Trust I for the fiscal year ending December 31, 2007 (the “Report”) and pursuant to Item 1123 of Regulation AB of the Securities and Exchange Commission, the undersigned, a duly authorized officer of the CLC Servicing (the “Servicer”), does hereby certify and represent as follows:

 

1.

A review of the activities and performance of the Servicer under the Agreement dated as of November 2, 2007, as amended, between the Servicer and College Loan Corporation Trust I (the “Servicing Agreement”) for the period that is the subject of the Report has been made under the supervision of the undersigned;

 

2.

To the best knowledge of the undersigned, based on such review, the Servicer has fulfilled all of its obligations under the Servicing Agreement in all material respects throughout the period that is the subject of the Report; and

 

3.

To the best knowledge of the undersigned, based on such review, there have been no failures to fulfill any such obligation in any material respect except as provided on Attachment A.

IN WITNESS WHEREOF, the undersigned has executed this Servicer Compliance Statement as of March 19, 2008.

 

CLC Servicing

 

 

By:

/s/ Steve Snyder

 

Name:

Steve Snyder

Title:

President, CLC Servicing

 

 

 

Attachment A

 

Reg. AB Section 1122 (d)(2)(i)

Transfer of borrower payments to Deutsche Bank custodial account were not made within 2 days of receipt of payment.

Resolution: CLC Servicing (“CLCS”) was wiring funds to Deutsche Bank every two business days but was not considering the payment posting date. Effective November 9, 2007, CLCS changed its process and began wiring funds to Deutsche Bank within two business days of the payment posting date on the CLCS System.

 

Reg. AB Section 1122 (d)(2)(vii)

Bank account reconciliations have reconciling items that are not cleared within 90 days.

Resolution: As of December 31, 2007, bank account reconciling items are cleared within 90 days.

 

Reg. AB Section 1122 (d)(4)(vi)

Between July and September 2007, the Student Status Confirmation Report (SSCR) automation process was undergoing system enhancements and SSCR reports with student status changes were not processed timely. This resulted in some loans not entering repayment in a timely manner.

Resolution: The backlog of SSCR processing was resolved in early September and SSCR processing has remained current.

 

 

EX-35 22 collegeloan1-ex353_032808.htm EXHIBIT 35.3 Exhibit 35.3

Exhibit 35.3

SERVICER COMPLIANCE STATEMENT FOR

COLLEGE LOAN CORPORATION TRUST I

March 19, 2008

College Loan Corporation

14303 Gateway Place

Poway, CA 92064

In connection with the Annual Report on Form 10-K of the College Loan Corporation Trust I for the fiscal year ending December 31, 2007 (the “Report”) and pursuant to Item 1123 of Regulation AB of the Securities and Exchange Commission, the undersigned, a duly authorized officer of College Loan Corporation (the “Servicer”), does hereby certify and represent as follows:

 

1.

A review of the activities and performance of the Servicer under the Agreement dated as of March 1, 2002, as amended, between the Servicer and College Loan Corporation Trust I (the “Servicing Agreement”) for the period that is the subject of the Report has been made under the supervision of the undersigned;

 

2.

To the best knowledge of the undersigned, based on such review, the Servicer has fulfilled all of its obligations under the Servicing Agreement in all material respects throughout the period that is the subject of the Report; and

 

3.

To the best knowledge of the undersigned, based on such review, there have been no failures to fulfill any such obligation in any material respect.

IN WITNESS WHEREOF, the undersigned has executed this Servicer Compliance Statement as of March 19, 2008.

 

 

COLLEGE LOAN LLC

 

 

 

 

 

 

 

By:

/s/ John Falb

 

Name:

John Falb

 

Title:

Chief Financial Officer

 

 

 

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