OREANDA-NEWS. Fitch Ratings has taken the following rating actions:

SLM Student Loan Trust 2013-5 (SLM 2013-5):

--Class A-2 affirmed at 'AAAsf'; Outlook Stable;

--Class A-3 upgraded to 'AAAsf' from 'Bsf'; Outlook Stable;

--Class B upgraded to 'AAsf' from 'Bsf'; Outlook Stable.

On Oct. 4, 2016, the legal final maturity date of the SLM 2013-5 class A-3 notes was extended to June 2044. This effectively mitigates the maturity risk in Fitch's cash flow modelling, resulting in the upgrade. Because class A-3 no longer experiences technical defaults in modelling, which would have otherwise diverted interest away from the subordinate notes, the class B notes now pass all cash flow stresses as well. The upgrade to 'AAsf' rather than 'AAAsf' reflects the notes' dependence on future excess spread.

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 rated 'AAA'/Outlook Stable.

Collateral Performance: Fitch assumes a base case default rate of 9.25% and a 27.75% default rate under the 'AAA' credit stress scenario. The claim reject rate is assumed to be 0.50% in the base case and 3% in the 'AAA' case. Fitch applies the standard default timing curve in its credit stress cash flow analysis. The trailing 12-month (TTM) average constant default rate, utilized in the maturity stresses, is 2.6%. TTM levels of deferment, forbearance, income-based repayment (prior to adjustment) and constant prepayment rate (voluntary and involuntary) are 11.2%, 17.4%, 17.7% and 13.4%, respectively, and are used as the starting point in cash flow modelling. Subsequent declines or increases are modelled as per criteria. The borrower benefit is assumed to be approximately 0.17%, based on information provided by the sponsor.

Basis and Interest Rate Risk: Fitch applies its standard basis and interest rate stresses to this transaction as per criteria.

Payment Structure: Credit enhancement (CE) is provided by overcollateralization (OC), excess spread and, for the class A notes, subordination. As of August 2016, total and senior effective parity ratios are 101.01% (1.00% CE) and 105.46% (5.18% CE). Liquidity support is provided by a reserve sized at the greater of 0.25% of the pool balance and $998,874, currently equal to $1,634,877. The transaction will continue to release cash as long as the target OC amount of 1.00% (with a floor of $1,250,000) is maintained.

Maturity Risk: Fitch's SLABS cash flow model indicates that the notes are paid in full on or prior to the legal final maturity dates under the commensurate rating scenario.

Operational Capabilities: Day-to-day servicing is provided by Navient Solutions, Inc. (formerly known as Sallie Mae, Inc.). Fitch believes Navient to be an acceptable servicer of FFELP student loans.

CRITERIA VARIATIONS

For transactions in surveillance, Fitch will treat certain assets such as claims filed as short-term assets in its cash flow analysis. Given that Fitch's current criteria is silent on the treatment of such assets, this treatment is considered a criteria variation.

Under the 'Counterparty Criteria for Structured Finance and Covered Bonds', dated July 18, 2016, Fitch looks to its own ratings in analyzing counterparty risk and assessing a counterparty's creditworthiness. The definition of permitted investments for this deal allows for the possibility of using investments not rated by Fitch, which represents a criteria variation. Since the only available funds to invest in are those held in the Collection Account, and the funds can only be invested for a short duration of three months given the payment frequency of the notes, Fitch does not believe such variation has a measurable impact upon the ratings assigned.

Fitch assumed a base case default rate for the credit stresses based on actual trust performance, which is higher than the output from its Default Model. There is no rating impact from such variation.

RATING SENSITIVITIES

Since the FFELP student loan ABS relies on the U. S. government to reimburse defaults, 'AAAsf' FFELP ABS ratings will likely move in tandem with the 'AAA' U. S. sovereign rating. Aside from the U. S. sovereign rating, defaults, basis risk, and loan extension risk account for the majority of the risk embedded in FFELP student loan transactions. Additional defaults, basis shock beyond Fitch's published stresses, lower than expected payment speed, and other factors could result in future downgrades. Likewise, a buildup of CE driven by positive excess spread given favorable basis factor conditions could lead to future upgrades.

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.