##### 



Page 12 of 17 Exhibit 99(d) KEYCORP STUDENT LOAN TRUST 1999-A PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY Statement of Compliance with
Specifically Identified Requirements December 31, 2004 (With Independent Accountants Report Thereon)




---



##### 



Page 13 of 17 Independent Accountants Report JPMorgan Chase Bank
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 January 1, 1999, about the Servicers compliance with the servicing of the KeyCorp Student
Loan
Trust 1999-A student loans as of December 31, 2004, 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 conducted in accordance with attestation 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 January 1, 1999, included in the accompanying
Statement of Compliance with Specifically Identified Requirements as of December 31, 2004, 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 (servicer), KeyBank National Association (administrator), JPMorgan Chase Bank (formerly
known as Bank One, National Association) (eligible lender trustee), and Deutsche Bank Trust Company
Americas (formerly known as Bankers Trust Company) (indenture trustee) and is not intended to be
and
should not be used by anyone other than these specified parties. /S/ KPMG LLP February 25, 2005




---



##### 



Page 14 of 17 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-A, 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 January 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 various other guarantors 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 as well as student loans which are not guaranteed (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, 2004 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). 1




---



##### 



Page 15 of 17 PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY Statement of Compliance with Specifically Identified Requirements  34 CFR 682.305, Procedures for Payment of Interest Benefit and Special Allowance;
all parts except for (a)(2)-(4), (b), and (c).  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 as published in their
entirety 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, 2004 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 as published in their
entirety in the October 29, 1999 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, 2004 and for the year then 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 as published in their
entirety 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, 2004 and for the year then ended:  34 CFR 682.411, Lender Due Diligence in Collecting Guaranty Agency Loans;
Part (i). 2




---



##### 



Page 16 of 17 PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY Statement of Compliance with Specifically Identified Requirements  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 Society National Bank dated March 23, 1995We have complied with the following Sections of the Agreement relating to the Financed
Private Loans as of December 31, 2004 and for the year then ended:  I.
    Account Servicing, Document StorageII.
    Delinquency Servicing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 as of December 31, 2004 and for the year then ended.C.
    Compliance with the aforementioned Sections of the Agreement relating to the Financed
Private Loans is limited to the following requirements contained in the Master
Servicing
Agreement Between Pennsylvania Higher Education Assistance Agency and Key Bank USA,
National Association dated June 1, 1997; Key Bank USA Graduate Loan Program
Servicing
Schedule for the Master Servicing Agreement dated June 1, 1997 between Pennsylvania
Higher Education Assistance Agency and Key Bank USA, National Association; and
Amended Delinquency Servicing Read and Agreed dated March 18, 2003. II. NONCOMPLIANCE  1.
    Financed Federal LoansNo items noted.  2.
    Financed Private LoansNo items noted. 3