SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
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FORM 8-K
Current Report
Pursuant to Section 13 or 15(D) of
The Securities Exchange Act of 1934
Date of Report (Date of earliest event reported): February 19, 2004
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KEYCORP STUDENT LOAN TRUST 2002-A
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(Exact Name of Registrant as Specified in its Charter)
Delaware 333-62624-03 73-1636567
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(State or Other Jurisdiction of (Commission File Number) (I.R.S. Employer
Incorporation) Identification No.)
c/o Key Bank USA, National Association, as Administrator,
Attn: Debra S. Fronius, Vice President
800 Superior Avenue, Cleveland, Ohio 44114
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(Address of Principal Executive Offices)
Registrant's Telephone Number, Including Area Code: (216) 828-9353
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Item 5. OTHER EVENTS
Historically, the Trust has considered unguaranteed Group II Student Loans to be
uncollectible and charged-off those loans when they are 180 days delinquent.
This practice has been consistent with the practice of the Master Servicer
regarding the charge-off of similar loans owned and serviced by the Master
Servicer. The effect of a charge-off of a Group II Student Loan generally is to
result in a reduction in the Group II Pool Balance, which has the effect of
increasing the Group II Principal Distribution Amount. The timing of the
charge-off of a Financed Student Loan also affects the administrative and
collection procedures relating to the Financed Student Loan.
Recently, the Office of the Comptroller of the Currency, the principal regulator
of national banks, including the Master Servicer, has instructed that, based on
its interpretation of the Uniform Retail Credit Classification and Account
Management Policy (the "Uniform Policy"), unguaranteed student loans held by
national banks should be charged-off for accounting purposes when they are 120
days (rather than 180 days) delinquent. The Uniform Policy was originally issued
in 1999 and revised in 2000 by the Federal Financial Institutions Examination
Council, acting on behalf of various federal bank regulators, including the
Office of the Comptroller of the Currency. The Uniform Policy established
standards for the classification and treatment of retail credit in financial
institutions.
So that the unguaranteed Group II Student Loans owned by the Trust continue to
be managed and administered in the same manner as similar loans owned or
serviced by the Master Servicer, this 120-day standard is also being applied
with respect to the Trust's unguaranteed Group II Student Loans. The effect of
applying this 120-day standard regarding charge-offs of loans of this type to
the unguaranteed Group II Student Loans in the Trust will result in those loans
being charged-off sooner, which causes at least a temporary acceleration of the
reduction in the Group II Pool Balance and increase in the Group II Principal
Distribution Amount. At this time, it is not possible to predict the extent or
duration of any such acceleration in the reduction of the Group II Pool Balance.
It is also not possible to predict whether this change in the timing of the
charge-off of unguaranteed Group II Student Loans will have any effect on either
the number of loans which become delinquent and are ultimately charged-off or
the amounts ultimately recovered on delinquent loans, or the timing of any such
recovery.
SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the
registrant has duly caused this report to be signed on its behalf by the
undersigned hereunto duly authorized.
Date: February 19, 2004
KeyCorp Student Loan Trust 2002-A
By: Key Bank USA, National Association, as Administrator
By: /S/ Debra S. Fronius
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Debra S. Fronius
Vice President