Exhibit 8.1


                     [Letterhead of Shearman & Sterling LLP]



                                 April 28, 2005


SLM Education Credit Funding LLC
20 Hemingway Drive
East Providence, Rhode Island 02915


                        SLM Education Credit Funding LLC
                      Registration Statement No. 333-[___]

Ladies and Gentlemen:

                  In connection with the Registration Statement on Form S-3 (the
"Registration Statement") being filed by SLM Education Credit Funding LLC, a
Delaware limited liability company (the "Seller"), with the Securities and
Exchange Commission (the "Commission") under the Securities Act of 1933, as
amended (the "Act"), relating to the registration of an amount of Floating Rate
Student Loan-Backed Notes (the "Notes"), you have requested our opinion
regarding certain descriptions of Federal income tax consequences contained in
the form of prospectus (the "Prospectus") included in the Registration Statement
and the form of Prospectus Supplement with respect to the SLM Student Loan
Trusts, to be formed from time to time (each, a "Trust"), included in the
Registration Statement (the "Prospectus Supplement").

                  Our opinion is based on an examination of the Prospectus and
the Prospectus Supplement. In addition, we have examined the forms of Indenture,
Trust Agreement, Interim Trust Agreement, Sale Agreement, Servicing Agreement,
Purchase Agreement and Master Administration Agreement (including the Supplement
to the Master Administration Agreement) referred to, respectively, as Exhibits
4.1, 4.2, 4.3, 99.1, 99.2, 99.3 and 99.4 in the Exhibit Index to the
Registration Statement. We have also examined such other documents and
information as we have considered necessary in rendering our opinion. Our
opinion assumes that all representations contained in the documents referred to
in this paragraph are correct, that the parties thereto comply with the terms
thereof and that such documents will not be amended. Our opinion is also based
upon the Internal Revenue Code of 1986, as amended, administrative rulings,
judicial decisions, Treasury regulations and other applicable authorities. The
statutory provisions, regulations and interpretations on which our opinion is
based are subject to change, and such changes could apply retroactively. In
addition, there can be no assurance that positions contrary to those stated in
our opinion will not be asserted by the Internal Revenue Service or sustained if
asserted.




                  In our examination, we have assumed the genuineness of all
signatures, the authenticity of all documents submitted to us as originals, the
conformity to original documents of all documents submitted to us as copies and
the authenticity of the originals of such documents. As to any facts material to
the opinions expressed herein which were not independently established or
verified, we have relied upon statements, representations, and certifications of
officers and other representations of the Seller and others.

                  Based on the foregoing, we hereby confirm that the statements
in the Prospectus under the headings "Prospectus Summary--Tax Considerations"
and "U.S. Federal Income Tax Consequences," and in the Prospectus Supplement
under the heading "Summary of Terms--Tax Considerations," subject to the
qualifications set forth therein, accurately describe the material Federal
income tax consequences to holders of offered Notes, under existing law and the
assumptions stated therein.

                  We also note that the Prospectus and the Prospectus Supplement
do not relate to a specific transaction and, accordingly, the descriptions of
Federal income tax consequences referred to above may require modification in
the context of a subsequent transaction.

                  We express no opinion with respect to the matters addressed in
this letter other than as set forth above.

                  We consent to the filing of this opinion as an exhibit to the
Registration Statement and to the use of our name in the Prospectus under the
headings "Prospectus Summary--Tax Considerations," "U.S. Federal Income Tax
Consequences," and "Legal Matters" and in the Prospectus Supplement under the
headings "Summary of Terms--Tax Considerations" and "Legal Matters." In giving
this consent, we do not thereby admit that we are within the category of persons
whose consent is required under Section 7 of the Act or the rules and
regulations of the Commission promulgated thereunder. This opinion is expressed
as of the date hereof unless otherwise expressly stated and we disclaim any
undertaking to advise you of any subsequent changes of the facts stated or
assumed herein or any subsequent changes in applicable law.



                                                     Very truly yours,


                                                     /s/SHEARMAN & STERLING LLP

ACG/FRS/KYL

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