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Page 14 of 26 Exhibit 99(f) KEYCORP STUDENT LOAN TRUST 2004-A 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 26 KPMG LLPSuite 2600One Cleveland Center
1375 East Ninth StreetCleveland, OH 44114-1796 Independent 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 August 1, 2004, about the Sub-Servicers compliance with the servicing of the
KeyCorp Student Loan Trust 2004-A student loans as of December 31, 2004, and for the period from
August 1, 2004 through December 31, 2004, 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 August 1, 2004, included in the
accompanying Statement of Compliance with Specifically Identified Requirements as of December 31,
2004, and for the period from August 1, 2004 through December 31, 2004, 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 (indenture trustee) and is not intended to be and should
not be used by anyone other than these specified parties. March 30, 2005
    
    /S/ KPMG LLP
 KPMG LLP, a U.S. limited liability partnership, is the U.S.
ember firm of KPMG International, a Swiss cooperative.




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Page 16 of 26 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 2004-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 August
1,
2004 (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 period from August 1, 2004 through
December 31, 2004:· 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).




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Page 17 of 26 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 period from August 1, 2004 through
December 31, 2004:· 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 period from August 1, 2004 through
December 31, 2004:· 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.




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Page 18 of 26 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 period from August 1, 2004 through
December 31, 2004:· 34 CFR 682.411, Lender Due Diligence in Collecting Guaranty Agency Loans;
Part (i).2. Financed Private LoansA.
    
    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 period from August 1,
2004 through December 31, 2004, 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, 2004 and
for the period from August 1, 2004 through December 31, 2004.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. NONCOMPLIANCE1. Financed Federal LoansNo items noted.




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Page 19 of 26 PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY Statement of Compliance with Specifically Identified Requirements 2. Financed Private Loans During procedures performed for the period from August 1, 2004 through December 31,
2004, the following noncompliance with the 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 was noted: We noted that the borrower incentive interest rate available to non-guaranteed private
student loans originated by KeyBank National Association within the Keys2Repay
Program was incorrectly applied for the period from August 1, 2004 through December 31,
2004. The interest rate was impacted from 5 to 25 basis points. PHEAAs Response It has been determined that an issue exists with regard to the interest rate assessed for loans
eligible for KeyBanks incentive program, Keys2Repay due to an incorrect code used
during conversion to the servicing system. This issue was originally identified as directly
impacting a time period limited to 2004; however, the comprehensive assessment covers
any loan eligible for the Keys2Repay incentive that would have entered repayment during
the time in which the incorrect code was in use. AES/PHEAA has developed an inquiry to identify those accounts containing this incorrect
code and estimates that a total of 74 borrowers in the 2004-A trust were impacted which
involved a total dollar impact of approximately $360 in the 2004-A trust. AES/PHEAA has received authorization from KeyBank to correct these accounts and will
be performing the necessary adjustments to do so. Confirmation of the clean up will be
forwarded to KPMG as soon as it is available.