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                                                                   Page 13 of 20
                                                                   Exhibit 99(f)





                       KEYCORP STUDENT LOAN TRUST 1999-B

                PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY

                          Statement of Compliance with
                      Specifically Identified Requirements

                               December 31, 2001

                 (With Independent Accountants' Report Thereon)

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                                                                   Page 14 of 20



[KPMG LOGO]

     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
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, 2001, 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 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 attestation 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, 2001, 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, Bankers Trust Company, and MBIA and is not intended
to be and should not be used by anyone other than these specified parties.



                                [KPMG SIGNATURE]



March 1, 2002



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                                                                   Page 15 of 20


                 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).

1.   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, 2001 and for the year
               then ended:

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

               o 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).

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

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

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

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

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

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

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

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

               o 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 20


                PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY

       Statement of Compliance with Specifically Identified Requirements


               o 34 CFR 682.403, "Death, Disability and Bankruptcy Payments";
                 all parts except for (e), (g), and (i)-(k).

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

               o 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, 2001 and for the year
               then ended:

               o 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, 2001 and for the year
               then ended:

               o 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, 2001 and for the year
               then ended:

               o 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.



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                                                                   Page 17 of 20


                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 to the Financed Private Loans
               as of December 31, 2001 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, 2001 and for the year then ended.


II.  NONCOMPLIANCE

     1.   FINANCED FEDERAL LOANS

          No items noted.

     2.   FINANCED PRIVATE LOANS

          No items noted.



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