SEC Regulation AB
 AFFILIATED COMPUTER SERVICES, INC.




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PageReport of Independent Registered Public Accounting Firm
    
    
    3ACS Education Services Management Assessment
    
    
    5Servicing Criteria Addressed in ACS Education Services Management
Assessment (Appendix A)
    
    
    6Individual Asset-Backed Transactions and Securities Defined as the
Platform Addressed in ACS Guaranteed Loan Services Management
Assessment (Appendix B)
    
    
    9




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Audit Tax  AdvisoryReport of Independent Registered Public Accounting Firm
    
    Grant Thornton LLP1000 Wilshire Boulevard, Suite 300Board of Directors and Shareholders
Affiliated Computer Services, Inc.
    
    Los Angeles, CA 90017-1728
T 213.627.1717F 213.624.6793www.GrantThornton.com




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(ACS LOGO)
    
    ACS is now a Xerox company
 ACS Education Services Management Assessment
      /s/ Meta GonzalezMeta Gonzalez, Sr. Vice President2-21-11Date th




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(ACS LOGO)
    
    ACS is now a Xerox company
 Appendix A
Page 1 of 3
 SERVICING CRITERIA ADDRESSED IN ACS EDUCATION SERVICES MANAGEMENT
ASSESSMENT
 Definitions:
 X  Servicing criteria subject to assessment
 X(1)  Servicing criteria subject to assessment. Compliance is determined based upon Telephone Interpretation 17.06
 N/A  Non applicable
 Reg ABReference
    
    Servicing Criteria
    
    ApplicabilityGeneral Servicing Considerations1122(d)(1)(i)
    
    Policies and procedures are instituted to monitor any performance or
other triggers and events of default in accordance with the
transaction agreements.
    
    X1122(d)(1)(ii)
    
    If any material servicing activities are outsourced to third
parties, policies and procedures are instituted to monitor the third
partys performance and compliance with such servicing activities.
    
    X1122(d)(1)(iii)
    
    Any requirements in the transaction agreements to maintain a back-up
servicer for the Pool Assets are maintained.
    
    N/A1122(d)(1)(iv)
    
    A fidelity bond and errors and omissions policy is in effect on the
party participating in the servicing function throughout the
reporting period in the amount of coverage required by and otherwise
in accordance with the terms of the transaction agreements.
    
    XCash Collection and Administration1122(d)(2)(i)
    
    Payments on pool assets are deposited into the appropriate
custodial bank accounts and related bank clearing accounts no more
than two business days following receipt, or such other number of
days specified in the transaction agreements.
    
    X(1)1122(d)(2)(ii)
    
    Disbursements made via wire transfer on behalf of an obligor or to
an investor are made only by authorized personnel.
    
    X1122(d)(2)(iii)
    
    Advances of funds or guarantees regarding collections, cash flows or
distributions, and any interest or other fees charged for such
advances, are made, reviewed and approved as specified in the
transaction agreements.
    
    N/A1122(d)(2)(iv)
    
    The related accounts for the transaction, such as cash reserve
accounts or accounts established as a form of over
collateralization, are separately maintained (e.g., with respect to
commingling of cash) as set forth in the transaction agreements.
    
    N/A1122(d)(2)(v)
    
    Each custodial account is maintained at a federally insured
depository institution as set forth in the transaction agreements.
For purposes of this criterion, federally insured depository
institution with respect to a foreign financial institution means a
foreign financial institution that meets the requirements of Rule
13k-1 (b)(1) of the Securities Exchange Act.
    
    X1122(d)(2)(vi)
    
    Unissued checks are safeguarded so as to prevent unauthorized access.
    
    X1122(d)(2)(vii)
    
    Reconciliations are prepared on a monthly basis for all asset-backed
securities related bank accounts, including custodial accounts and
related bank clearing accounts. These reconciliations are (A)
mathematically accurate; (B) prepared within 30 calendar days after
the bank statement cutoff date, or such other number of days
specified in the transaction agreements; (C) reviewed and approved
by someone other than the person who prepared the reconciliation;
and (D) contain explanations for reconciling items These reconciling
items are resolved within 90 calendar days of their original
identification, or such other number of days specified in the
transaction agreements.
    
    X




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(ACS LOGO)
    
    ACS is now a Xerox company
 Appendix A
Page 2 of 3
 SERVICING CRITERIA ADDRESSED IN ACS EDUCATION SERVICES MANAGEMENT
ASSESSMENT
 Definitions:
 X  Servicing criteria subject to assessment
 X(1)  Servicing criteria subject to assessment. Compliance is determined based upon Telephone
Interpretation 17.06
 N/A  Not applicable
 Reg ABReference
    
    Servicing Criteria
    
    ApplicabilityInvestor Remittances and Reporting1122(d)(3)(i)
    
    Reports to investors, including
those to be filed with the
Commission, are maintained in
accordance with the transaction
agreements and applicable
Commission requirements.
Specifically, such reports (A)
are prepared in accordance with
timeframes and other terms set
forth in the transaction
agreements; (B) provide
information calculated in
accordance with the terms
specified in the transaction
agreements; (C) are filed with
the Commission as required by its
rules and regulations; and (D)
agree with investors or the
trustees records as to the total
unpaid principal balance and
number of Pool Assets serviced by
the Servicer.
    
    N/A1122(d)(3)(ii)
    
    Amounts due to investors are
allocated and remitted in
accordance with timeframes,
distribution priority and other
terms set forth in the
transaction agreements.
    
    N/A1122(d)(3)(iii)
    
    Disbursements made to an investor
are posted within two business
days to the Servicers investor
records, or such other number of
days specified in the transaction
agreements.
    
    N/A1122(d)(3)(iv)
    
    Amounts remitted to investors per
the investor reports agree with
cancelled checks, or other form
of payment, or custodial bank
statements.
    
    N/APool Asset Administration1122(d)(4)(i)
    
    Collateral or security on pool
assets is maintained as required
by the transaction agreements or
related pool asset documents.
    
    X1122(d)(4)(ii)
    
    Pool assets and related documents
are safeguarded as required by
the transaction agreements
    
    X1122(d)(4)(iii)
    
    Any additions, removals or
substitutions to the asset pool
are made, reviewed and approved
in accordance with any conditions
or requirements
in the transaction agreements.
    
    N/A1122(d)(4)(iv)
    
    Payments on pool assets,
including any payoffs, made in
accordance with the related pool
asset documents are posted to the
Servicers obligor records
maintained no more than two
business days after receipt, or
such other number of days
specified in the transaction
agreements, and allocated to
principal, Interest or other
items (e.g., escrow) in
accordance with the related pool
asset documents.
    
    X1122(d)(4)(v)
    
    The Servicers records regarding
the pool assets agree with the
Servicers records with respect
to an obligors unpaid principal
balance.
    
    X1122(d) (4)(vi)
    
    Changes with respect to the terms
or status of an obligors pool
assets (e.g., loan modifications
or re-agings) are made, reviewed
and approved by authorized
personnel in accordance with the
transaction agreements and
related pool asset documents.
    
    X1122(d)(4)(vii)
    
    Loss mitigation or recovery
actions (e.g., forbearance plans,
modifications and deeds in lieu
of foreclosure, foreclosures and
repossessions, as applicable) are
initiated, conducted and
concluded in accordance with the
timeframes or other requirements
established by the transaction
agreements.
    
    X




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(ACS LOGO)
    
    ACS is now a Xerox company
 Appendix A
Page 3 of 3
 SERVICING CRITERIA ADDRESSED IN ACS EDUCATION SERVICES MANAGEMENT
ASSESSMENT
 Definitions:
 X  Servicing criteria subject to assessment
 X(1)  Servicing criteria subject to assessment. Compliance is determined based upon Telephone
Interpretation 17.06
 N/A  Not applicable
 Reg ABReference
    
    Servicing Criteria
    
    Applicability1122(d)(4)(viii)
    
    Records documenting collection
efforts are maintained during the
period a pool asset is delinquent
in accordance with the transaction
agreements. Such records are
maintained on at least a monthly
basis, or such other period
specified in the transaction
agreements, and describe the
entitys activities in monitoring
delinquent pool assets including,
for example, phone calls, letters
and payment rescheduling plans in
cases where delinquency is deemed
temporary (e.g., illness or
unemployment).
    
    X1122(d)(4)(ix)
    
    Adjustments to interest rates or
rates of return for pool assets
with variable rates are computed
based on the related pool asset
documents.
    
    X1122(d) (4)(x)
    
    Regarding any funds held in trust
for an obligor (such as escrow
accounts): (A) such funds are
analyzed, in accordance with the
obligors pool asset documents, on
at least an annual basis, or such
other period specified in the
transaction agreements; (B)
interest on such funds is paid, or
credited, to obligors in
accordance with applicable pool
asset documents and state laws;
and (C) such funds are returned to
the obligor within 30 calendar
days of full repayment of the
related pool assets, or such other
number of days specified in the
transaction agreements.
    
    N/A1122(d) (4) (xi)
    
    Payments made on behalf of an
obligor (such as tax or insurance
payments) are made on or before
the related penalty or expiration
dates, as indicated on the
appropriate bills or notices for
such payments, provided that such
support has been received by the
servicer at least 30 calendar days
prior to these dates, or such
other number of days specified in
the transaction agreements.
    
    N/A1122(d) (4)(xii)
    
    Any late payment penalties in
connection with any payment to be
made on behalf of an obligor are
paid from the Servicers funds and
not charged to the obligor, unless
the late payment was due to the
obligors error or omission.
    
    N/A1122(d)(4)(xiii)
    
    Disbursements made on behalf of an
obligor are posted within two
business days to the obligors
records maintained by the
servicer, or such other number of
days specified in the transaction
agreements.
    
    N/A1122(d) (4)(xiv)
    
    Delinquencies, charge-offs and
uncollectible accounts are
recognized and recorded in
accordance with the transaction
agreements.
    
    X1122(d)(4)(xv)
    
    Any external enhancement or other
support, identified in Item
1114(a)(1) through (3) or Item
1115 of Regulation AB, is
maintained as set forth in the
transaction agreements.
    
    N/A




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(ACS LOGO)
    
    ACS is now a Xerox company
  
 Lender Name
    
    Client CodeKey Bank, N.A
    
    FU, FV, and PCSallie Mae, Inc
    
    SB