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                                                                  Page 14 of 24

                                                                  EXHIBIT 99(f)

                        KEYCORP STUDENT LOAN TRUST 1999-B

                PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY

                          Statement of Compliance with
                      Specifically Identified Requirements

                                December 31, 2003

                 (With Independent Accountants' Report Thereon)
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                                                                   Page 15 of 24

[KPMG LOGO]

           KPMG LLP
           Suite 2600
           One Cleveland Center
           1375 E. Ninth Street
           Cleveland, OH

           44114-1796




                         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 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, 2003, 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
September 1, 1999, included in the accompanying Statement of Compliance with
Specifically Identified Requirements as of December 31, 2003, 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 (sub-servicer), Key Bank USA, National
Association (administrator and master servicer), 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.


                                                KPMG LLP

February 27, 2004


---- KPMG LLP, a U.S. limited liability partnership, is the U.S.
     member firm of KPMG International, a Swiss cooperative.
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                                                                   Page 16 of 24



                 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 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, 2003 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).


                                        1
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                                                                   Page 17 of 24

                 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 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, 2003 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, 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, 2003 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, 2003 and for the
                  year then 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.


                                       2
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                                                                   Page 18 of 24

                 PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY

        Statement of Compliance with Specifically Identified Requirements

                  We have complied with the following sections of the Agreement
                  relating to the Financed Private Loans as of December 31, 2003
                  and for the year then ended, except as noted in the
                  `Noncompliance' section:

                  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, 2003 and for the year then ended.

II.   NONCOMPLIANCE

      1.    FINANCED FEDERAL LOANS

            No items noted.

      2.    FINANCED PRIVATE LOANS

            During procedures performed for the year ended December 31, 2002,
            and as reported in the February 28, 2003 report, the following
            noncompliance was noted which relates to the year ended December 31,
            2003 and therefore, is repeated in this report:

            I.    "Account Servicing, Document Storage" which states "Without
                  limiting the generality of the foregoing or of any other
                  provision set forth in the Agreement and notwithstanding any
                  other provision to the contrary set forth herein, the
                  Subservicer shall manage, service, administer and make
                  collections with respect to the Financed Student Loans (other
                  than collection of any Interest Subsidy Payments and Special
                  Allowance Payments, which the Eligible Lender Trustee will
                  perform on behalf of the Trust) in accordance with, and
                  otherwise comply with, all applicable Federal and State laws,
                  including all applicable standards, guidelines and
                  requirements of the Higher Education Act (in the case of any
                  Financed Federal Loans) and any Guarantee Agreement (in the
                  case of all the Financed Student Loans)"

            The interest rate on Residency Access Loan (REL) loans was
            incorrectly stated at 4.607% for the period of January 1, 2003
            through February 21, 2003. The correct interest rate should have
            been 3.957%.

         PHEAA'S RESPONSE

         A corrective action was implemented immediately to require enhanced
         quality assurance by the Graduate Services staff. The compensating
         control now requires a primary and secondary review and sign off by the
         originating department.


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                                                                   Page 19 of 24



                 PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY

        Statement of Compliance with Specifically Identified Requirements


         In addition, an inquiry identified REL loans that contained this error
         and all impacted accounts were corrected as of February 21, 2003 by
         updating the Interest Rate Loan Program Definition Table. Verification
         of the change was provided to KPMG for report purposes. The inquiry
         identified all REL loans with outstanding balances that were in
         repayment, which resulted in 1.86% of the Trust being impacted by this
         error prior to correction.


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