Fitch to Rate Straight-A Funding LLC's Student Loan ABCP 'F1+'.

NEW YORK -- Fitch Ratings expects to assign an 'F1+' rating to the student loan short-term notes (SLST Notes) issued by Straight-A Funding, LLC's ABCP Program (Straight-A). Straight-A's fully-supported ABCP Program is being created pursuant to the Ensuring Continued Access to Student Loans Act (ECASLA). The expected rating is based on the application of Fitch's ABCP criteria, the full credit and liquidity support mechanism provided by the Federal Financing Bank (FFB), the quality of assets being purchased, the legal structure and the program's

administrative support.

On Oct. 7, 2008, the Bush Administration extended ECASLA for one year. Among other provisions, ECASLA grants lenders the option to put student loans to the Department of Education under certain conditions. Straight-A will be one of a number of initiatives that have been implemented under ECASLA by the U.S. Departments of Education and Treasury together with the Office of Management and Budget. The government's stated intention is to continue to provide families with access to federally guaranteed student loans. As conditions to participating in the ABCP Program, student loan lenders generally agree to originate and disburse, or acquire government guaranteed student loans and conduct activities constituting a continued participation in FFELP within a twenty-four month period after selling or pledging loans to the program.

Through its ABCP Program, Straight-A may issue two series of SLST Notes (series-1 and series-2). Series-1 SLST Notes may be issued with expected maturities of up to 90 days and legal final maturities on the third business day following the expected maturity. Series-2 SLST Notes may be issued with expected maturities of up to 90 days and legal final maturities on the seventh business day following the expected maturity. The proceeds of the issuance will be used to fund the purchase of 'AAA' rated funding notes backed by FFELP student loans. The funding notes will be issued by special purpose vehicles sponsored by student loan lenders.

SLST Note noteholders will benefit from full credit and liquidity support provided by the FFB. The FFB is a U.S. government corporation. The support mechanisms will be sized to cover the face amount of SLST Notes being funded by the borrowing plus any interest accrued and to accrue to the legal final maturity of the notes. Further, Straight-A Funding, LLC has entered into a put agreement with the Department of Education (the Department), whereby, following the occurrence of certain events, among them being a failure by the liquidity provider to make a liquidity funding, Straight-A will put student loans to the Department and the Department is obligated to purchase them 45 days after receipt of notice of the put.

The program is being arranged by Citigroup Global Markets Inc and Morgan Stanley & Co. Incorporated. The Bank of New York Mellon will act as the conduit administrator. The program's manager has yet to be determined.

Fitch's rating definitions and the terms of use of such ratings are available on the agency's public site, www.fitchratings.com. Published ratings, criteria and methodologies are available from this site, at all times. Fitch's code of conduct, confidentiality, conflicts of interest, affiliate firewall, compliance and other relevant policies and procedures are also available from the 'Code of Conduct' section of this site.