September 2, 2015 Alert
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September 2, 2015


This afternoon, September 2nd, Moody’s Investors Service published a new report that illustrates the application of its proposed new assumptions for rating student loan ABS backed by loans made under the Federal Family Education Loan Program ("FFELP"). Moody’s also announced that it has extended until October 30, 2015 the comment period on its Request for Comment ("RFC") regarding the proposed changes to rating these securities.

“This extension will provide additional time for market participants to review this illustration along with other aspects of our RFC,” says Moody’s Managing Director Debash Chatterjee. “The newly published document provides additional clarity and transparency on how we plan to apply the proposed assumptions by providing an example of a sample loan pool.”

Moody's invites market participants to provide feedback on the RFC by submitting their comments here.

After considering responses to this RFC, Moody’s will finalize its revised approach to rating securities backed by FFELP student loans, publish its updated methodology, resolve the ratings of the securities put on review in April and June and take rating actions on any other securities impacted by the revised methodology.

SFIG's Student Loan Committee is working on a response to these proposed changes and submitted an extension request on August 14th. We appreciate the extension of the comment deadline as it provides a better opportunity to provide a thoughtful and meaningful response to the RFC.

If you are interested in joining our Student Loan Committee, please contact


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