Fitch Ratings has affirmed the ratings of all outstanding classes of SLM Student Loan Trust 2011-3 and SLM Student Loan Trust 2012-7.

The Rating Outlooks for all classes across the two transactions have been maintained.

RATING ACTIONS

Entity / Debt

Rating

Prior

SLM Student Loan Trust 2011-3

A 78445UAA0

LT

AAAsf

Affirmed

AAAsf

B 78445UAD4

LT

AAAsf

Affirmed

AAAsf

SLM Student Loan Trust 2012-7

A-3 78447KAC6

LT

Bsf

Affirmed

Bsf

B 78447KAD4

LT

Bsf

Affirmed

Bsf

Page

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VIEW ADDITIONAL RATING DETAILS

Transaction Summary

SLM 2011-3: The class A and class B notes passed all of Fitch's credit and maturity stresses in cash flow modeling, and Fitch has affirmed them at 'AAAsf'.

SLM 2012-7: The class A-3 notes did not pass Fitch's base case stresses in cash flow modeling due to the notes not paying in full prior to their legal final maturity date. The rating of the class B notes is constrained by the rating of the senior notes, because of an event of default (EOD) caused by the class A-3 notes not paying in full prior to their legal final maturity date. The class B notes will not receive principal or interest payments.

Fitch has affirmed the class A-3 and class B notes at 'Bsf', supported by qualitative factors such as Navient's ability to call the notes upon reaching 10% pool factor and the revolving credit agreement allowing Navient to lend to the trust, which would then be junior to the A-3 and B classes. Navient has the option but not the obligation to lend to the trust, so Fitch does not give quantitative credit to this agreement. However, this agreement provides qualitative comfort that Navient is committed to limiting investors' exposure to maturity risk. Navient Corporation's current rating is 'BB-'/Stable.

KEY RATING DRIVERS

U.S. Sovereign Risk: The trust collateral comprises 100% Federal Family Education Loan Program (FFELP) loans with guaranties provided by eligible guarantors and reinsurance provided by the U.S. Department of Education (ED) for at least 97% of principal and accrued interest. The U.S. sovereign rating is currently 'AAA'/Outlook Stable.

Collateral Performance: For all transactions, after applying the default timing curve per criteria, the effective default rate is unchanged from the cumulative default rate. Fitch applies the standard default timing curve in its credit stress cash flow analysis. Additionally, consolidation from the Public Service Loan Forgiveness Program, which ended in October 2022, drove the short-term inflation of CPR. Voluntary prepayments are expected to return to historical levels. Fitch assumes the claim reject rate is 0.25% in the base case and 2.00% in the 'AAA' case.

SLM 2011-3: Based on transaction-specific performance to date, Fitch assumes a cumulative default rate of 20.00% under the base case scenario and a default rate of 60.00% under the 'AAA' credit stress scenario. Fitch is maintaining the sustainable constant default rate (sCDR) of 3.00% and the sustainable constant prepayment rate (sCPR; voluntary and involuntary prepayments) of 9.50% in cash flow modeling. The trailing-12-month (TTM) levels of deferment, forbearance, and income-based-repayment (IBR; prior to adjustment) are 3.83% (3.95% at March 31, 2022), 13.18% (11.64%) and 22.01% (21.43%). These assumptions are used as the starting point in cash flow modelling and subsequent declines or increases are modelled as per criteria.

The 31-60 DPD and the 91-120 DPD have decreased at March 31, 2023, and are currently 3.76% for 31 DPD and 1.23% for 91 DPD compared to 4.09% and 1.36% at March 31, 2022 for 31 DPD and 91 DPD, respectively. The borrower benefit is approximately 0.14%, based on information provided by the sponsor.

SLM 2012-7: Based on transaction-specific performance to date, Fitch assumes a cumulative default rate of 38.25% under the base case scenario and a default rate of 100.00% under the 'AAA' credit stress scenario, with an effective default rate of 99.22% after applying the default timing curve, as per criteria. Fitch is revising the sCDR upwards to 5.00% from 4.10% and maintaining the sCPR of 10.00% in cash flow modeling.

The TTM levels of deferment, forbearance, and IBR are 5.71% (5.97% at March 31, 2022), 19.36% (17.03%) and 23.96% (26.80%). These assumptions are used as the starting point in cash flow modelling and subsequent declines or increases are modelled as per criteria. The 31-60 DPD and the 91-120 DPD have decreased at Feb. 28, 2023, and are currently 5.50% for 31 DPD and 2.02% for 91 DPD compared to 5.99% and 2.42% at March 31, 2022 for 31 DPD and 91 DPD, respectively. The borrower benefit is approximately 0.04%, based on information provided by the sponsor

Basis and Interest Rate Risk: Basis risk for these transactions arises from any rate and reset frequency mismatch between interest rate indices for Special Allowance Payments (SAP) and the securities. As of the most recent distribution dates, approximately 99.78% and 99.86% of the student loans in SLM 2011-3 and SLM 2012-7, respectively, are indexed to LIBOR, with the rest indexed to the 91-day T-bill rate. All notes in SLM 2011-3 and SLM 2012-7 are indexed to one-month LIBOR. Fitch applies its standard basis and interest rate stresses to the transactions as per criteria.

Payment Structure: Credit enhancement (CE) is provided by over-collateralization (OC), excess spread and for the class A notes, subordination. As of the most recent collection period, the senior parity ratios (including the reserve account) are 123.44% (18.99% CE) and 113.83% (12.15% CE) for SLM 2011-3 and 2012-7, respectively. The total parity ratios (including the reserve account) are 106.49% (6.10% CE) and 101.37% (1.36% CE) for SLM 2011-3 and 2012-7, respectively.

Liquidity support is provided by a reserve account sized at 0.25% of the outstanding pool balance. As of the most recent collection period, the reserve accounts are at their floors of $1,197,172 and $1,248,784 for SLM 2011-3 and 2012-7, respectively. SLM 2011-3 will release cash when the target OC (excluding the reserve account) of the greater of $10,000,000 or 5.50% is reached. SLM 2012-7 will continue to release cash as long as 101.01% reported total parity is maintained.

Operational Capabilities: Day-to-day servicing is provided by Navient Solutions, LLC. Fitch believes Navient to be an acceptable servicer, due to its extensive track record as one of the largest servicers of FFELP loans.

RATING SENSITIVITIES

Factors that Could, Individually or Collectively, Lead to Negative Rating Action/Downgrade

SLM Student Loan Trust 2011-3

Current Ratings: class A 'AAAsf'; class B 'AAAsf'

Current Model-Implied Ratings: class A 'AAAsf' (Credit and Maturity Stress); class B 'AAAsf' (Credit and Maturity Stress)

Credit Stress Rating Sensitivity

Default increase 25%: class A 'AAAsf'; class B 'AAAsf';

Default increase 50%: class A 'AAAsf'; class B 'AAAsf';

Basis spread increase 0.25%: class A 'AAAsf'; class B 'AAAsf';

Basis spread increase 0.50%: class A 'AAAsf'; class B 'AAAsf'.

Maturity Stress Rating Sensitivity

CPR decrease 25%: class A 'AAAsf'; class B 'AAAsf';

CPR decrease 50%: class A 'AAAsf'; class B 'AAAsf';

IBR usage increase 25%: class A 'AAAsf'; class B 'AAAsf';

IBR usage increase 50%: class A 'AAAsf'; class B 'AAAsf';

Remaining term increase 25%: class A 'AAAsf'; class B 'AAAsf';

Remaining term increase 50%: class A 'AAAsf'; class B 'AAsf'.

SLM Student Loan Trust 2012-7

Current Ratings: class A 'Bsf'; class B 'Bsf'

Current Model-Implied Ratings: class A 'CCCsf' (Credit and Maturity Stress); class B 'CCCsf' (Credit and Maturity Stress)

Credit Stress Rating Sensitivity

Default increase 25%: class A 'CCCsf'; class B 'CCCsf';

Default increase 50%: class A 'CCCsf'; class B 'CCCsf';

Basis spread increase 0.25%: class A 'CCCsf'; class B 'CCCsf';

Basis spread increase 0.50%: class A 'CCCsf; class B 'CCCsf'.

Maturity Stress Rating Sensitivity

CPR decrease 25%: class A 'CCCsf'; class B 'CCCsf';

CPR decrease 50%: class A 'CCCsf'; class B 'CCCsf';

IBR usage increase 25%: class A 'CCCsf'; class B 'CCCsf';

IBR usage increase 50%: class A 'CCCsf; class B 'CCCsf';

Remaining Term increase 25%: class A 'CCCsf'; class B 'CCCsf';

Remaining Term increase 50%: class A 'CCCsf'; class B 'CCCsf'

Factors that Could, Individually or Collectively, Lead to Positive Rating Action/Upgrade

SLM Student Loan Trust 2011-3

No upgrade credit or maturity stress sensitivity is provided for either the class A or class B notes, as they are already at their highest possible model-implied ratings.

SLM Student Loan Trust 2012-7

Credit Stress Sensitivity

Default decrease 25%: class A 'CCCsf'; class B 'CCCsf';

Basis Spread decrease 0.25%: class A 'CCCsf'; class B 'CCCsf'.

Maturity Stress Sensitivity

CPR increase 25%: class A 'CCCsf'; class B 'CCCsf';

IBR usage decrease 25%: class A 'CCCsf'; class B 'CCCsf';

Remaining Term decrease 25%: class A 'CCCsf'; class B 'CCCsf'.

Best/Worst Case Rating Scenario

International scale credit ratings of Structured Finance transactions have a best-case rating upgrade scenario (defined as the 99th percentile of rating transitions, measured in a positive direction) of seven notches over a three-year rating horizon; and a worst-case rating downgrade scenario (defined as the 99th percentile of rating transitions, measured in a negative direction) of seven notches over three years. The complete span of best- and worst-case scenario credit ratings for all rating categories ranges from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings are based on historical performance. For more information about the methodology used to determine sector-specific best- and worst-case scenario credit ratings, visit https://www.fitchratings.com/site/re/10111579.

USE OF THIRD PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G -10

Form ABS Due Diligence-15E was not provided to, or reviewed by, Fitch in relation to this rating action.

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF RATING

The principal sources of information used in the analysis are described in the Applicable Criteria.

ESG Considerations

Unless otherwise disclosed in this section, the highest level of ESG credit relevance is a score of '3'. This means ESG issues are credit-neutral or have only a minimal credit impact on the entity, either due to their nature or the way in which they are being managed by the entity. For more information on Fitch's ESG Relevance Scores, visit www.fitchratings.com/esg

Additional information is available on www.fitchratings.com

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