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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, 2004 (With Independent Accountants Report Thereon)




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Page 15 of 24 KPMG LLPSuite 2600One Cleveland Center1375 East Ninth StreetCleveland, OH 44114-1796Independent Accountants Report
 JPMorgan Chase Bank
as Eligible Lender Trustee We have examined Pennsylvania Higher Education Assistance Agencys (Sub-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 Sub-Servicers compliance with the servicing of the KeyCorp
Student
Loan Trust 1999-B 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
Sub-Servicer
is responsible for the Sub-Servicers compliance with those requirements. Our responsibility is to
express
an opinion on the Sub-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 Sub-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 Sub-Servicers
compliance with specified requirements. In our opinion, the Sub-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,
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 (sub-servicer), KeyBank 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. /S/ KPMG LLP
 February 25, 2005 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 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). 1




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Page 17 of 24 PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY Statement of Compliance with Specifically Identified Requirements  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).  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, 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 (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. 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 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.
    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.
We 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 KeyBank USA, National Association; and Amended Delinquency
Servicing Read and Agreed dated March 18, 2003. 3




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Page 19 of 24 PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY
Statement of Compliance with Specifically Identified Requirements  II.
    NONCOMPLIANCE  1.
    Financed Federal LoansNo items noted.2.
    Financed Private LoansNo items noted. 4