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EXHIBIT 99(f)
KEYCORP STUDENT LOAN TRUST 2002-A
PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY
Statement of Compliance with
Specifically Identified Requirements
December 31, 2003
(With Independent Accountants' Report Thereon)
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[KPMG LOGO]
KPMG LLP
Suite 2600
One Cleveland Center
1375 E. Ninth Street
Cleveland, OH 44114-1796
INDEPENDENT ACCOUNTANTS' REPORT
JPMorgan Chase Bank
as Eligible Lender Trustee
We have examined Pennsylvania Higher Education Assistance Agency's (Servicer)
assertions with respect to Sections 3.03, 3.04, 4.01, 4.02, 4.03, 4.08, 5.02,
and 5.03 of the Sale and Servicing Agreement dated September 1, 2002, about the
Servicer's compliance with the servicing of the Keycorp Student Loan Trust
2002-A student loans as of December 31, 2003, and for the year then ended, as
indicated in the accompanying, Statement of Compliance with Specifically
Identified Requirements. The Servicer is responsible for the Servicer's
compliance with those requirements. Our responsibility is to express an opinion
on the Servicer's assertions about compliance based on our examination.
Our examination was conducted in accordance with attestation standards
established by the American Institute of Certified Public Accountants and,
accordingly, included examining, on a test basis, evidence about the Servicer's
compliance with those requirements and performing such other procedures as we
considered necessary in the circumstances. We believe that our examination
provides a reasonable basis for our opinion. Our examination does not provide a
legal determination on the Servicer's compliance with specified requirements.
In our opinion, the Servicer's assertions with respect to Sections 3.03, 3.04,
4.01, 4.02, 4.03, 4.08, 5.02, and 5.03 of the Sale and Servicing Agreement dated
September 1, 2002, included in the accompanying Statement of Compliance with
Specifically Identified Requirements as of December 31, 2003, and for the year
then ended, are fairly stated in all material respects.
This report is intended solely for the information and use of Pennsylvania
Higher Eduction Assistance Agency (sub-servicer), Key Bank USA, National
Association (administrator and master servicer), JPMorgan Chase Bank (formerly
known as Bank One, National Association) (eligible lender trustee), JPMorgan
Chase Bank (indenture Trustee), and Ambac Assurance Corporation (securities
insurer) and is not intended to be and should not be used by anyone other than
these specified parties.
February 27, 2004
KPMG LLP, a U.S. limited liability partnership, is the U.S.
member firm of KPMG International, a Swiss cooperative.
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PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY
Statement of Compliance with Specifically Identified Requirements
Pennsylvania Higher Education Assistance Agency (PHEAA) has complied with the
specifically identified servicing requirements for the KeyCorp Student Loan
Trust 2002-A, with respect to Sections 3.03, 3.04, 4.01, 4.02, 4.03, 4.08, 5.02,
and 5.03 of the Sale and Servicing Agreement dated September 1, 2002 (the
Agreement), relating to the student loans that are guaranteed as to payment of
principal and interest by PHEAA or the American Student Assistance Corporation
(ASA) and are reinsured by the Department of Education (Financed Federal Loans),
and student loans guaranteed as to payment of principal and interest by The
Education Resources Institute, Inc. (TERI) and not reinsured by the Department
of Education as well as student loans which are not guaranteed (Financed Private
Loans).
I. COMPLIANCE
1. FINANCED FEDERAL LOANS
A. Compliance with the aforementioned Sections of the Agreement
relating to the Financed Federal Loans is limited to the
following federal regulations as published in their entirety in
the December 18, 1992 Federal Register, Part II, Department of
Education, 34 Code of Federal Regulations (CFR), Federal Family
Education Loan Program: Final Regulations.
We have complied with the following federal regulations for the
Financed Federal Loans as of December 31, 2003 and for the year
then ended:
- 34 CFR 682.202, "Permissible Charges by Lenders to
Borrowers"; all parts except for (a)(2), (b)(5), (c)-(e),
and (g).
- 34 CFR 682.208, "Due Diligence in Servicing a Loan"; all
parts except for (b)(1)(i)-(ii), (b)(1)(v), (b)(2), and
(c)-(f).
- 34 CFR 682.209, "Repayment of a Loan"; all parts except for
(a)(2)(i), (a)(4), (b), (d), (f), (g), and (j).
- 34 CFR 682.210, "Deferment"; all parts except for (a)(9) and
(b)(6).
- 34 CFR 682.211, "Forbearances"; all parts except for (a)(3)
and (d).
- 34 CFR 682.213, "Prohibition Against the Use of the Rule of
78s."
- 34 CFR 682.300, "Payment of Interest Benefits on Stafford
Loans."
- 34 CFR 682.301, "Eligibility of Borrowers for Interest
Benefits on Stafford Loans"; all parts except for (a) and
(c).
- 34 CFR 682.302, "Payment of Special Allowance on FFEL
Loans"; all parts except for (c)(2), (c)(3), (d), and (e).
- 34 CFR 682.304, "Methods for Computing Interest Benefit and
Special Allowance"; all parts except for (a), (b), and
(d)(2).
- 34 CFR 682.305, "Procedures for Payment of Interest Benefit
and Special Allowance"; all parts except for (a)(2)-(4),
(b), and (c).
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PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY
Statement of Compliance with Specifically Identified Requirements
- 34 CFR 682.402, "Death, Disability and Bankruptcy Payments"; all
parts except for (e), (g), and (i)-(k).
- 34 CFR 682.411, "Due Diligence by Lenders in the Collection of
Guaranty Agency Loan"; all parts except for (f), (i), (j), (m),
and (n).
- 34 CFR 682.414, "Records, Reports, and Inspection Requirements for
Guaranty Agency Programs"; all parts except for (a)(1), (a)(2),
(a)(3), (b), and (c).
B. Compliance with the aforementioned Sections of the Agreement relating to
the Financed Federal Loans is limited to the following federal
regulations as published in their entirety in the December 1, 1995
Federal Register, Part III, Department of Education, 34 Code of Federal
Regulations (CFR), Federal Family Education Loan Program: Final Rule.
We have complied with the following federal regulations for the Financed
Federal Loans as of December 31, 2003 and for the year then ended:
- 34 CFR 682.209, "Repayment of a Loan"; Part (b).
C. Compliance with the aforementioned Sections of the Agreement relating to
the Financed Federal Loans is limited to the following federal
regulations as published in their entirety in the October 29, 1999
Federal Register, Part V, Department of Education, 34 Code of Federal
Regulations (CFR), Federal Family Education Loan Program: Final Rule.
We have complied with the following federal regulations for the Financed
Federal Loans as of December 31, 2003 and for the year then ended:
- 34 CFR 682.411, "Lender Due Diligence in Collecting Guaranty Agency
Loans"; Part (f).
D. Compliance with the aforementioned Sections of the Agreement relating to
the Financed Federal Loans is limited to the following federal
regulations as published in their entirety in the July 27, 2000 Federal
Register, Part V, Department of Education, 34 Code of Federal Regulations
(CFR), Federal Family Education Loan Program: Final Rule.
We have complied with the following federal regulations for the Financed
Federal Loans as of December 31, 2003 and for the year then ended:
- 34 CFR 682.411, "Lender Due Diligence in Collecting Guaranty Agency
Loans"; Part (i).
2. FINANCED PRIVATE LOANS
A. Compliance with the aforementioned sections of the Agreement relating to
the Financed Private Loans is limited to the following requirements
contained in the Access Loan Programs Servicing Agreement between
Pennsylvania Higher Education Assistance Agency and Society National Bank
dated March 23, 1995.
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PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY
Statement of Compliance with Specifically Identified Requirements
We have complied with the following sections of the Agreement
relating to the Financed Private Loans as of December 31, 2003 and
for the year then ended:
I. "Account Servicing, Document Storage"
II. "Delinquency Servicing"
III. "Deferment and Forbearance Processing"
IV. "Filing Claims"
B. Compliance with the aforementioned sections of the Agreement
relating to the Financed Private Loans is limited to the following
requirements contained in the 2000 Servicing Guidelines for TERI,
effective December 1, 2000.
We have complied with the revised delinquency servicing requirements
for TERI guaranteed Financed Private Loans as of December 31, 2003
and for the year then ended.
II. NONCOMPLIANCE
1. FINANCED FEDERAL LOANS
No items noted.
2. FINANCED PRIVATE LOANS
No items noted.
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