OREANDA-NEWS. Fitch Ratings affirms the SLM Student Loan Trust, Series 2004-5 (SLM 2004-5) senior notes at 'AAAsf' and subordinate notes at 'BBBsf'. The Rating Outlook remains Stable for both classes.

KEY RATING DRIVERS

High Collateral Quality: The trust collateral consists of 100% of Federal Family Education Loan Program (FFELP) loans. The credit quality of the trust collateral is high, in Fitch's opinion, based on the guarantees provided by the transaction's eligible guarantors and reinsurance provided by the U.S. Department of Education (ED) for at least 97% of principal and accrued interest. Fitch currently rates the U.S. 'AAA' with a Stable Outlook.

Sufficient Credit Enhancement: Credit enhancement (CE) is provided by overcollateralization (OC; the excess of trust's asset balance over bond balance), excess spread, and for the senior notes, subordination provided by the subordinate notes. As of March 31, 2015, senior and subordinate parities are 104.83% (4.60% CE) and 100.00% respectively. The trust may release cash as long as the total parity of 100.0% is maintained. Additionally, the trust is approaching 40% pool factor, at which time, the reserve account balance will be excluded from the parity calculation, resulting in overcollateralization for the trust.

Adequate Liquidity Support: Liquidity support is provided by a debt service reserve fund sized at the greater of 0.25% of the pool balance and \$4,455,445. The debt service reserve fund is sized at \$4,455,445 as of March 31, 2015.

Acceptable Servicing Capabilities: Navient Solutions, Inc. (formerly, Sallie Mae, Inc.), as servicer, will be responsible for the day to day servicing of the portfolio. Fitch believes Navient Solutions to be an acceptable servicer of FFELP student loans.

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 and basis risk account for the majority of the risk embedded in FFELP student loan transactions. Additional defaults and basis shock beyond Fitch's published stresses 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.

DUE DILIGENCE USAGE
Fitch was not provided due diligence information from any third parties relating to SLM 2004-5.

Fitch has affirmed the following ratings:

SLM Student Loan Trust, Series 2004-5:
--Class A-4 notes at 'AAAsf'; Outlook Stable;
--Class A-5 notes at 'AAAsf'; Outlook Stable;
--Class A-6 notes at 'AAAsf'; Outlook Stable;
--Class B notes at 'BBBsf'; Outlook Stable.