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                                                                   Page 13 of 19

                                                                   EXHIBIT 99(f)



                        KEYCORP STUDENT LOAN TRUST 1999-B

                PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY

                          Statement of Compliance with
                      Specifically Identified Requirements

                                December 31, 2000

                 (With Independent Accountants' Report Thereon)



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                                                                   Page 14 of 19

[KPMG LETTERHEAD]

         One Cleveland Center                    Telephone 216 696 9100
         1375 E. Ninth Street                    Fax 216 696 7792
         Cleveland, OH 44114-1796


                         INDEPENDENT ACCOUNTANTS' REPORT


Bank One, National Association
(formerly known as The First National Bank of Chicago)
as Eligible Lender Trustee

We have examined Pennsylvania Higher Education Assistance Agency's (Servicer)
assertions with respect to Sections 3.03, 3.04, 4.01, 4.02, 4.03, 4.08, 5.02,
and 5.03 of the Sale and Servicing Agreement dated September 1, 1999, about the
Servicer's compliance with the servicing of the KeyCorp Student Loan Trust
1999-B student loans as of December 31, 2000, and for the year then ended, as
indicated in the accompanying Statement of Compliance with Specifically
Identified Requirements. The Servicer is responsible for the Servicer's
compliance with those requirements. Our responsibility is to express an opinion
on the Servicer's assertions about compliance based on our examination.

Our examination was made in accordance with standards established by the
American Institute of Certified Public Accountants and, accordingly, included
examining, on a test basis, evidence about the Servicer's compliance with those
requirements and performing such other procedures as we considered necessary in
the circumstances. We believe that our examination provides a reasonable basis
for our opinion. Our examination does not provide a legal determination on the
Servicer's compliance with specified requirements.

In our opinion, the Servicer's assertions with respect to Sections 3.03, 3.04,
4.01, 4.02, 4.03, 4.08, 5.02, and 5.03 of the Sale and Servicing Agreement dated
September 1, 1999, included in the accompanying Statement of Compliance with
Specifically Identified Requirements as of December 31, 2000, and for the year
then ended, are fairly stated in all material respects.

This report is intended solely for the information and use of Pennsylvania
Higher Education Assistance Agency, Key Bank USA, National Association, Bank
One, National Association (formerly known as The First National Bank of
Chicago), Bankers Trust Company, and MBIA (formerly known as Capital Markets
Assurance Corporation) and is not intended to be and should not be used by
anyone other than these specified parties.


                                      /s/ KPMG LLP


March 2, 2001


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                                                                   Page 15 of 19



                PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY

        Statement of Compliance with Specifically Identified Requirements

Pennsylvania Higher Education Assistance Agency (PHEAA) has complied with the
specifically identified servicing requirements for the KeyCorp Student Loan
Trust 1999-B, with respect to Sections 3.03, 3.04, 4.01, 4.02, 4.03, 4.08, 5.02,
and 5.03 of the Sale and Servicing Agreement dated September 1, 1999 (the
Agreement), relating to the student loans that are guaranteed as to payment of
principal and interest by PHEAA or the American Student Assistance Corporation
(ASA) and are reinsured by the Department of Education (Financed Federal Loans)
and student loans guaranteed as to payment of principal and interest by The
Education Resources Institute, Inc. (TERI) and not reinsured by the Department
of Education (Financed Private Loans).

I.      COMPLIANCE

        1.  FINANCED FEDERAL LOANS

            A.  Compliance with the aforementioned Sections of the Agreement
                relating to the Financed Federal Loans is limited to the
                following federal regulations as published in their entirety in
                the December 18, 1992 Federal Register, Part II, Department of
                Education, 34 Code of Federal Regulations (CFR), Federal Family
                Education Loan Program: Final Regulations.

                We have complied with the following federal regulations for the
                Financed Federal Loans as of December 31, 2000, and for the year
                then ended:

                  -  34 CFR 682.202, "Permissible Charges by Lenders to
                     Borrowers"; all parts except for (a)(2), (b)(5), (c)-(e),
                     and (g).

                  -  34 CFR 682.208, "Due Diligence in Servicing a Loan"; all
                     parts except for (b)(1)(i)-(ii), (b)(1)(v), (b)(2), and
                     (c)-(f).

                  -  34 CFR 682.209, "Repayment of a Loan"; all parts except for
                     (a)(2)(i), (a)(4), (b), (d), (f), (g), (i), and (j).

                  -   34 CFR 682.210, "Deferment"; all parts except for (a)(9)
                      and (b)(6).

                  -   34 CFR 682.211, "Forbearances"; all parts except for
                      (a)(3) and (d).

                  -   34 CFR 682.213, "Prohibition Against the Use of the Rule
                      of 78s."

                  -   34 CFR 682.300, "Payment of Interest Benefits on Stafford
                      Loans."

                  -  34 CFR 682.301, "Eligibility of Borrowers for Interest
                     Benefits on Stafford Loans"; all parts except for (a) and
                     (c).

                  -  34 CFR 682.302, "Payment of Special Allowance on FFEL
                     Loans"; all parts except for (c)(2), (c)(3), (d), and (e).

                  -  34 CFR 682.304, "Methods for Computing Interest Benefit and
                     Special Allowance"; all parts except for (a), (b), and
                     (d)(2).

                  -  34 CFR 682.305, "Procedures for Payment of Interest Benefit
                     and Special Allowance"; all parts except for (a)(2)-(4),
                     (b), and (c).

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                                                                   Page 16 of 19


                 PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY

        Statement of Compliance with Specifically Identified Requirements

                -  34 CFR 682.402, "Death, Disability and Bankruptcy Payments";
                   all parts except for (e), (g), and (i)-(k).

                -  34 CFR 682.411, "Due Diligence by Lenders in the Collection
                   of Guaranty Agency Loans"; all parts except for (f), (i),
                   (j), (m), and (n).

                -  34 CFR 682.414, "Records, Reports, and Inspection
                   Requirements for Guaranty Agency Programs"; all parts except
                   for (a)(1), (a)(2), (a)(3), (b), and (c).

          B.  Compliance with the aforementioned Sections of the Agreement
              relating to the Financed Federal Loans is limited to the following
              federal regulations published in the December 1, 1995 Federal
              Register, Part III, Department of Education, 34 Code of Federal
              Regulations (CFR), Federal Family Education Loan Program: Final
              Rule.

              We have complied with the following federal regulations for the
              Financed Federal Loans as of December 31, 2000 and for the year
              then ended:

                -  34 CFR 682.209, "Repayment of a Loan"; Part (b).

          C.  Compliance with the aforementioned Sections of the Agreement
              relating to the Financed Federal Loans is limited to the following
              federal regulations published in the October 29, 2000 Federal
              Register, Part V, Department of Education, 34 Code of Federal
              Regulations (CFR), Federal Family Education Loan Program: Final
              Rule.

              We have complied with the following federal regulations for the
              Financed Federal Loans as of December 31, 2000 and for the year
              ended:

               -   34 CFR 682.411, "Lender Due Diligence in Collecting Guaranty
                   Agency Loans"; Part (f).

          D.  Compliance with the aforementioned Sections of the Agreement
              relating to the Financed Federal Loans is limited to the following
              federal regulations published in the July 27, 2000 Federal
              Register, Part V, Department of Education, 34 Code of Federal
              Regulations (CFR), Federal Family Education Loan Program: Final
              Rule.

              We have complied with the following federal regulations for the
              Financed Federal Loans as of December 31, 2000 and for the year
              ended:

               -   34 CFR 682.411, "Lender Due Diligence in Collecting Guaranty
                   Agency Loans"; Part (i).

2.      FINANCED PRIVATE LOANS

          A.  Compliance with the aforementioned sections of the Agreement
              relating to the Financed Private Loans is limited to the following
              requirements contained in the Access Loan Programs Servicing
              Agreement between Pennsylvania Higher Education Assistance Agency
              and Society National Bank dated March 23, 1995.

              I.   "Account Servicing, Document Storage"

              II.  "Delinquency Servicing"


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                                                                   Page 17 of 19



                 PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY

        Statement of Compliance with Specifically Identified Requirements

              IV.  "Deferment and Forbearance Processing"

              VI.  "Filing Claims"

          B.   Compliance with the aforementioned sections of the Agreement
               relating to the Financed Private Loans is limited to the
               following requirements contained in the 2000 Servicing Guidelines
               for TERI, effective December 1, 2000.

               We have complied with the revised delinquency servicing
               requirements for TERI guaranteed Financed Private Loans for the
               period December 1, 2000 through December 31, 2000.

II.         NONCOMPLIANCE

            1.   FINANCED FEDERAL LOANS

                 No items noted.

            2.   FINANCED PRIVATE LOANS

                 No items noted.



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