Fitch Takes Various Rating Actions on Brazos Higher Education Authority 2011-2

Fitch Ratings has affirmed the Brazos Higher Education Authority 2011-2 class A notes at 'AAAsf' with a Stable Rating Outlook. Fitch has upgraded the class B notes to 'Asf' from 'BBBsf' and revised the Outlook to Stable from Positive.

KEY RATING DRIVERS

High Collateral Quality: The trust collateral is comprised 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 at least 97% reinsurance of principal and accrued interest provided by the U.S. Department of Education (ED). On March 24, 2014, Fitch affirmed the U.S. sovereign rating at 'AAA' and assigned a Stable Outlook.

Sufficient Credit Enhancement: CE is provided by excess spread and overcollateralization. Parity levels continue to improve, and as of Dec. 31, 2014 was 106.02%, and 101.78% for the class A and class B notes respectively. The class C notes are unrated. Additionally the class A notes benefit from subordination provided by the class B and C notes, and the class B notes benefit from subordination provided by the class C notes. Excess spread will not be released until all of the notes are paid in full.

Adequate Liquidity Support: Liquidity support is provided by a reserve account (0.25% of the outstanding principal amount of the bonds or $2,588,665).

Acceptable Servicing Capabilities: The loans are serviced by Xerox Education Services Inc., Pennsylvania Higher Education Assistance Agency, Great Lakes Education Loan Services Inc., Navient LLC (formerly Sallie Mae Servicing), and Brazos Loan Servicing. All servicers are acceptable servicers of FFELP loans

RATING SENSITIVITIES

Since FFELP student loan ABS rely 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 credit enhancement driven by positive excess spread given favorable basis factor conditions could lead to future upgrades.

Fitch has taken the following rating actions on Brazos Higher Education Authority 2004:

--Class 2011-II-A-1 affirmed at 'AAAsf; Outlook Stable;

--Class 2011-II- A-2 affirmed at 'AAAsf; Outlook Stable;

--Class 2011-II-A-3 affirmed at 'AAAsf'; Outlook Stable;

--Class 2011-II-B upgraded to 'Asf' from 'BBBsf'; Outlook revised from Positive to Stable.

Additional information is available at 'www.fitchratings.com'

Applicable Criteria and Related Research:

--'Global Structured Finance Rating Criteria' (May 24, 2013);

--'Rating U.S. Federal Family Education Loan Program Student Loan ABS Criteria' (May 17, 2013).

Applicable Criteria and Related Research:

Global Structured Finance Rating Criteria

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=708661

Rating U.S. Federal Family Education Loan Program Student Loan ABS Criteria -- Amended

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=708795

Additional Disclosure

Solicitation Status

http://www.fitchratings.com/gws/en/disclosure/solicitation?pr_id=827121

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