OREANDA-NEWS. Fitch Ratings has affirmed the Nelnet Student Loan Trust 2004-4 notes (Nelnet 2004-4) as follows:

--Class A at 'AAAsf'; Outlook Stable;
--Class B at 'AAsf'; Outlook Stable.

KEY RATING DRIVERS

High Collateral Quality: The trust collateral consists of 100% 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. The current U.S. sovereign rating is 'AAA' with a Stable Outlook.

Sufficient Credit Enhancement (CE): Cash flow scenarios for the Nelnet 2004-4 notes were satisfactory under Fitch's stresses. CE is provided by overcollateralization (OC; the excess of trust's asset balance over bond balance) and excess spread. The senior notes also benefit from CE provided by the subordination of the class B notes. As of December 2015, parity is 101.59% (1.57% CE) as and senior parity is 111.33% (10.18% CE). This trust is releasing cash as long as the OC amount of $5,144,248 is maintained.

Adequate Liquidity Support: Liquidity is provided by a reserve fund equal to the greater of 0.25% of the pool balance and $2,991,407. As of December 2015, the reserve fund balance is $2,991,407.

Acceptable Servicing Capabilities: National Education Loan Network is the master servicer and Nelnet Inc. is the subservicer. Fitch believes both National Education Loan Network and Nelnet Inc. to be acceptable servicers of FFELP student loans.

On Nov. 18, 2015, Fitch released its exposure draft which delineates revisions it plans to make to the 'Rating U.S. Federal Family Education Loan Program Student Loan ABS Criteria', dated June 23, 2014. Fitch has reviewed this transaction under both the existing and proposed criteria.

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.

DUE DILIGENCE USAGE

No third party due diligence was provided or reviewed in relation to this rating action.