**Exhibit 33.1**REPORT ON ASSESSMENT OFCOMPLIANCE WITH APPLICABLE SERVICING CRITERIA     KeyBankNational Association, as Administrator (the “Assessing Party”), is responsible forassessing compliance as of December 31, 2006, and for the period from December 7, 2006 (the date ofissuance of asset-backed securities by the KeyCorp Student Loan Trust 2006-A) through December 31,2006 (the “Reporting Period”), with the servicing criteria set forth in Item 1122(d) of RegulationAB, excluding the criteria which the Assessing Party has concluded are not applicable to itsservicing of the KeyCorp Student Loan Trust 2006-A asset-backed securitization transaction backedby student loan receivables serviced by the Assessing Party, as indicated on Appendix A attachedhereto (the “Applicable Servicing Criteria”). The sole asset-backed securitization transactioncovered by this report was the KeyCorp Student Loan Trust 2006-A transaction.     The Assessing Party has assessed its compliance with the Applicable Servicing Criteria for theReporting Period and has concluded that the Assessing Party has complied, in all material respects,with the Applicable Servicing Criteria for the KeyCorp Student Loan Trust 2006-A asset-backedsecuritization transaction backed by student loan receivables serviced by the Assessing Party.     Ernst & Young LLP, an independent registered public accounting firm, has issued an attestationreport on this assessment of compliance with the Applicable Servicing Criteria as of December 31,2006 and for the Reporting Period.KEYBANK NATIONAL ASSOCIATION, as Administrator   /s/ Daniel G. Smith     Name: Daniel G. Smith  Title: Senior Vice President     /s/ Krista C. Neal     Name: Krista C. Neal  Title: Vice President  Date: March 23, 2007
 

 
Appendix A**Servicing Criteria To Be Addressed In Assessment Of Compliance**     The assessment of compliance to be delivered by KeyBank National Association, as theAdministrator, shall address, at a minimum, the criteria identified below as “Applicable ServicingCriteria”:     **Reference** **Criteria** **Applicability**  **General Servicing Considerations**       1122(d)(1)(i) Policies and procedures are instituted to monitor any performance or other triggers and events of default inaccordance with the transaction agreements. **X**     1122(d)(1)(ii) If any material servicing activities are outsourced to third parties, policies and procedures are instituted tomonitor the third party’s performance and compliance with such servicing activities. **X**     1122(d)(1)(iii) Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained. N/A     1122(d)(1)(iv) A fidelity bond and errors and omissions policy is in effect on the party participating in the servicingfunction throughout the reporting period in the amount of coverage required by and otherwise in accordance with theterms of the transaction agreements. N/A       **Cash Collection and Administration**       1122(d)(2)(i) Payments on pool assets are deposited into the appropriate custodial bank accounts and related bank clearingaccounts no more than two business days following receipt, or such other number of days specified in the transactionagreements. **X**     1122(d)(2)(ii) Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorizedpersonnel. **X**     1122(d)(2)(iii) Advances of funds or guarantees regarding collections, cash flows or distributions, and any interest or otherfees charged for such advances, are made, reviewed and approved as specified in the transaction agreements. N/A     1122(d)(2)(iv) The related accounts for the transaction, such as cash reserve accounts or accounts established as a form ofover collateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in thetransaction agreements. **X**     1122(d)(2)(v) Each custodial account is maintained at a federally insured depository institution as set forth in thetransaction agreements. For purposes of this criterion, “federally insured depository institution” with respect to aforeign financial institution means a foreign financial institution that meets the requirements of Rule 13k-1(b)(1)of the Securities Exchange Act. **X**     1122(d)(2)(vi) Unissued checks are safeguarded so as to prevent unauthorized access. N/A     1122(d)(2)(vii) Reconciliations are prepared on a monthly basis for all asset-backed securities related bank accounts, includingcustodial 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 thetransaction 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 oftheir original identification, or such other number of days specified in the transaction agreements. **X**
 

 
     **Reference** **Criteria** **Applicability**  **InvestorRemittances and Reporting**       1122(d)(3)(i) Reports to investors, including those to be filed with the Commission, are maintained in accordance with thetransaction agreements and applicable Commission requirements. Specifically, such reports (A) are prepared inaccordance with timeframes and other terms set forth in the transaction agreements; (B) provide informationcalculated in accordance with the terms specified in the transaction agreements; (C) are filed with the Commissionas required by its rules and regulations; and (D) agree with investors’ or the trustee’s records as to the totalunpaid principal balance and number of pool assets serviced by the servicer. **X**     1122(d)(3)(ii) Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority andother terms set forth in the transaction agreements. **X**     1122(d)(3)(iii) Disbursements made to an investor are posted within two business days to the servicer’s investor records, orsuch other number of days specified in the transaction agreements. **X**     1122(d)(3)(iv) Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, orcustodial bank statements. **X**       **Pool Asset Administration**       1122(d)(4)(i) Collateral or security on pool assets is maintained as required by the transaction agreements or related poolasset documents. **X**     1122(d)(4)(ii) Pool assets and related documents are safeguarded as required by the transaction agreements N/A     1122(d)(4)(iii) Any additions, removals or substitutions to the asset pool are made, reviewed and approved in accordance withany conditions or requirements in the transaction agreements. **X**     1122(d)(4)(iv) Payments on pool assets, including any payoffs, made in accordance with the related pool asset documents areposted to the servicer’s obligor records maintained no more than two business days after receipt, or such othernumber 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. N/A     1122(d)(4)(v) The servicer’s records regarding the pool assets agree with the servicer’s records with respect to an obligor’sunpaid principal balance. N/A     1122(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 relatedpool asset documents. N/A     1122(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 thetimeframes or other requirements established by the transaction agreements. N/A     1122(d)(4)(viii) Records documenting collection efforts are maintained during the period a pool asset is delinquent in accordancewith the transaction agreements. Such records are maintained on at least a monthly basis, or such other periodspecified in the transaction agreements, and describe the entity’s activities in monitoring delinquent pool assetsincluding, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemedtemporary (e.g., illness or unemployment). N/A     1122(d)(4)(ix) Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on therelated pool asset documents. N/A     1122(d)(4)(x) Regarding any funds held in trust for an obligor (such as escrow accounts): (A) such funds are analyzed, inaccordance with the obligor’s pool asset documents, on at least an annual basis, or such other period specified inthe transaction agreements; (B) interest on such funds is paid, or credited, to obligors in accordance withapplicable pool asset documents and state laws; and (C) such funds are returned to the obligor within 30 calendardays of full repayment of the related pool assets, or such other number of days specified in the transactionagreements. N/A
 

 
     **Reference** **Criteria** **Applicability**1122(d)(4)(xi) Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the relatedpenalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that suchsupport has been received by the servicer at least 30 calendar days prior to these dates, or such other number ofdays specified in the transaction agreements. N/A     1122(d)(4)(xii) Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from theservicer’s funds and not charged to the obligor, unless the late payment was due to the obligor’s error or omission. N/A     1122(d)(4)(xiii) Disbursements made on behalf of an obligor are posted within two business days to the obligor’s recordsmaintained by the servicer, or such other number of days specified in the transaction agreements. N/A     1122(d)(4)(xiv) Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with thetransaction agreements. N/A     1122(d)(4)(xv) Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of RegulationAB, is maintained as set forth in the transaction agreements. **X**