KPMG LLP Suite 700 20 Pacifica Irvine, CA 92618-3391

 

•	The term “compared” means compared to the information shown and found it to be in agreement, unless otherwise stated. Such compared information was deemed to be in agreement if differences were within the reporting threshold.

•	The term “recomputed” means recalculated and compared the result to the information shown and found it to be in agreement, unless otherwise stated. Such recomputed information was deemed to be in agreement if differences were within the reporting threshold.

•	The term “reporting threshold” means that dollar amounts were within $1.00, First Payment Dates were within two (2) days, and Remaining Terms were within one (1) month.

•	The term “FDR System” means the Company’s internal servicing system containing certain information such as interest rate, loan status, first payment date, original loan balance, current loan balance, and original maturity date related to the Selected Student Loans (defined below).

The Loan Files were represented by Earnest, on behalf of the Responsible Party, to be copies of the original Loan Files or electronic records contained within the respective system or website.

The procedures we were instructed by the Company to perform and the associated findings are as follows:

Attributes

Loan Files/Instructions

#CSS Screen, “CYCLE DATE” on #CSS Screen, “PAYMENT” fields on #CSS Screen or #CDS Screen, “PRINCIPAL PAID” field in the Amortized Payment History Schedule, and Instructions

Attributes

Loan Files/Instructions

The information regarding the Selected Student Loans was found to be in agreement, except as listed in Exhibit C.

Based on the results of the procedures performed, there is a 95.0% confidence level that the maximum estimated error occurrence rate for each of the attributes across the entire population of 23,871 Student Loans does not exceed 5.0%. Because we are not engaged to express a conclusion, we do not offer a conclusion based on the application of a sampling technique.

We were engaged by the Company to perform this agreed-upon procedures engagement and conducted our engagement in accordance with attestation standards established by the American Institute of Certified Public Accountants, which involves us performing the specific procedures agreed to and acknowledged above and reporting on findings based on performing those procedures. We were not engaged to and did not conduct an examination or review, the objective of which would be the expression of an opinion or conclusion, respectively, on the specified attributes in the Data File. Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have
been reported.

We are required to be independent of the Responsible Party and to meet our other ethical responsibilities, in accordance with the relevant ethical requirements related to our agreed-upon procedures engagement.

The procedures performed were applied based on the information included in the Data File and Provided Information, without verification or evaluation of such information by us; therefore, we express no opinion or any other form of assurance regarding (i) the reasonableness of the information provided to us by the Responsible Party, (ii) the physical existence of the Student Loans, (iii) the reliability or accuracy of the Provided Information, which was used in our procedures, or (iv) matters of legal interpretation.

The procedures performed were not intended to address, nor did they address: (i) the conformity of the origination of the Student Loans to stated underwriting or credit extension guidelines, standards, criteria or other requirements, (ii) the value of collateral securing any such Student Loans being securitized, (iii) the compliance of the originator of the Student Loans with federal, state, and local laws and regulations, or (iv) any other factor or characteristic of the Student Loans that would be material to the likelihood that the issuer of the asset-backed securities will pay interest and principal in accordance with applicable terms and conditions. The procedures performed were not intended to satisfy any criteria for due diligence published by the nationally recognized statistical rating organizations (“NRSROs”).

The terms of our engagement are such that we have no responsibility to update this report because of events and circumstances that may subsequently occur.

This report is intended solely for the information and use of the Specified Parties. It is not intended to be and should not be used by any other person or entity, including investors or the NRSROs, who are not identified in the report as the Specified Parties but may have access to this report as required by law or regulation.

/s/ KPMG LLP

Irvine, California
June 6, 2025

Selected Student Loan Number

Student Loan Number*

Selected Student Loan Number

Student Loan Number*

Selected Student Loan Number

Student Loan Number*

Selected Student Loan Number

Student Loan Number*

Selected Student Loan Number

Student Loan Number*

Attribute	Instructions
Payment Frequency	Payment Frequency is considered to be:
	a)   “Bi-Weekly” if the 45th position of the “MISC 13” field on the #NM CS Screen is “B” or the “PREV AUTO PAY FLAG” field on the #CMS Screen indicates “0,” or
	b)   “Monthly” if the 45th position of the “MISC 13” field on the #NM CS Screen is not “B” or the “PREV AUTO PAY FLAG” field on the #CMS Screen indicates “A” or “J.”
Loan Status	Loan Status is considered to be :
	a)   “Repayment” if the “CURR LOAN STAT” field on the #EDH Screen is other than “DMIP” or “F***,” and the Repayment Type in the “MISC FIELD 2” field on the #BS3 Screen was either “F0025,”  “FX025,” “SOIOP,” or blank;
	b)   “Repayment” if the “CURR LOAN STATUS” field on the #EDH Screen indicated “SSFP,” “SS**,” or “FORP”;
	c)   “Forbearance” if the “CURR LOAN STATUS” field on the #EDH Screen indicated “SSF*”; or,
	d)   Otherwise, compare to the status contained in the “CURR LOAN STATUS” field on the #EDH Screen.
First Payment Date	Compare or recompute the First Payment Date as follows (Instructions are listed in order of priority until the attribute was agreed):
	a)   If the “MISC FIELD 2” on the #BS3 Screen was “CT010,” “CTIOP,” “F0025,” “FX025,” “P0000,” “PPIOP,” “SOIOP,” or is blank, use “1st ACTIVE DATE” field on the #BS5 Screen.
	b)   If the “MISC FIELD 2” on the #BS3 Screen was “D***,” and “RPMT BEGIN DT” field on the #EDH Screen” was prior to or the same day as the “1st ACTIVE DATE” field on the #BS5 Screen, use “1st ACTIVE DATE” field on the #BS5 Screen.
	c)   If the “MISC FIELD 2” on the #BS3 Screen was “D***,” and “RPMT BEGIN DT” field on the #EDH Screen was after the “1st ACTIVE DATE” field on the #BS5 Screen, recompute the First Payment Date as the first cycle date in the following month after the date in the “RPMT BEGIN DT” field on the #EDH Screen plus one day.
	d)   If the cycle date was after the “RPMT BEGIN DT” field on the #EDH Screen, recompute the First Payment Date as the first cycle date after the date in the “RPMT BEGIN DT” field on the #EDH Screen plus one day.
Current Principal Balance	Compare or recompute the Current Principal Balance as follows (Instructions are listed in order of priority until the attribute was agreed):

	a)   Compare to the “ACCOUNT BALANCE” column on the #CSS Screen or documentation of a change that affects the current principal balance on the #CIS Screen.
	b)   Compare to the amount in the “CUR BAL” field on the #BS Screen.
	c)   Compare to the amount in the “FINANCIAL INSTITUTION” field on the #NM CC Screen.
	d)   Recompute the Current Principal Balance as follows:
	i.     Add any applicable Repayment Fee (shown under the “RPMT FEE” field on the #ED2 Screen) or applicable Capitalized Interest (shown under the “CAP INT” field on the #ED2 Screen) to the “ACCOUNT BALANCE” column on the #CSS Screen, and subtract any applicable disbursement amount (shown under the “DISBURSEMENT” field on the #CSS Screen or the #CDS Screen), applicable adjustment (shown under the “ADJUSTMENT” field on the #CSS Screen or the #CDS Screen), or applicable disbursement return amount (shown under the “MEMO TEXT” field on the #CMS Screen);
	ii.    Subtract any amount indicated in the “RETRO PROCESSING” field on the #ED2 Screen and any additional principal payment applied after the Cutoff Date, identified by either (1) subtracting the recalculated accrued interest (“Interest Rate” field on the #CSS Screen multiplied by the number of days from the start of the “CYCLE DATE” on the #CSS Screen to the day before the date of the first Payment under the “PAYMENT” field on the #CSS Screen or the #CDS Screen, multiplied by the “ACCOUNT BALANCE” column on the #CSS Screen) from the first Payment made under the “PAYMENT” field on the #CSS Screen or the #CDS Screen; and,
	iii.   Subtract any principal paid amount in the “PRINCIPAL PAID” field from the Amortized Payment History Schedule after the last transaction date reflected in the #CSS Screen but before the Cutoff Date.
Remaining Term	Recompute as follows:
	(i)   Subtract the Cutoff Date from either (1) the date one month after the “MATURITY DT” field on the #EDH Screen, or (2) the date indicated in the notation of status change on the #CIS Screen and
	(ii)   Divide the result by the average number of days in a month (i.e., 30.4375, based on 365.25 days in a year).
	If the Cutoff Date was later than the “DUE DATE” field on the #EDH Screen, subtract one month from (ii).

School Type	School Type is considered to be “N” (Not for profit) if the school name in the “School” field in the “Eligibility/Rate Check” section of the Verify Report Page is included in the Title IV Federal School Code List.
School Degree	School Degree is considered to be:
	a)   The most recent, highest completed degree, in the “Educations” section of the Verify Report Page;
	b)   “Masters” or “MD” if the “Educations” section of the Verify Report Page or the “Underwritten Education Degree” field in the Application Underwriting Snapshot Page indicates “medical_other” or “DO,” respectively;
	c)   “NonGrad” if the “Educations” section of the Verify Report Page or the “Underwritten Education Degree” field in the Application Underwriting Snapshot Page indicates “incomplete_grads;” or
	d)   “High School” if (i) the school name in the “underwritten_education_ degree” field in the Data File is a high school and (ii) the “is_parent_plus” field in the Data File indicates “Yes.”
Repayment Status	Repayment Status is considered to be :
	a)   “Repayment” if the “CURR LOAN PHASE” field on the #EDH Screen is other than “DMIP” or “F***,” and the Repayment Type in the “MISC FIELD 2” field on the #BS3 Screen was either “F0025,” “FX025,” “SOIOP,” “PPIOP,” or blank;
	b)   “Repayment” if the “CURR LOAN PHASE” field on the #EDH Screen indicated “SSFP,” “SS**,” or “FORP;” or,
	c)   “Forbearance” if the “CURR LOAN PHASE” field on the #EDH Screen indicated “SSF*”.
	d)   Otherwise, compare to the status contained in the “CURR LOAN PHASE” field on the #EDH Screen.
	For the Selected Student Loans with Repayment Status changed after the Cutoff Date, compare to the status contained in the “ORIG STMT STATUS” field on the #ED2 Screen corresponding to the immediate prior cycle date
Remaining Amortizing Term	Recompute as follows (Instructions are listed in order of priority until the attribute was agreed):
	a)   If the “RPMT_OPT_CD” field in the Data File is “full_principal_and_interest”, calculate the Remaining Amortizing Term as the difference between the “MATURITY DATE” field on the #EDH Screen and the Cutoff Date. Divide the result by the average number of days in a month (i.e., 30.4375, based on 365.25 days in a year) and round up to the nearest whole number.

	b)   If the “RPMT_OPT_CD” field in the Data File is not “full_principal_and_interest”, consider the “BORROWER_STATUS” field in the Data File and recompute as follows:
	i.    If the “BORROWER_STATUS” field in the Data File is equal to “repayment”, recompute using step a) above.
	ii.    If the “BORROWER_STATUS” field in the Data File is equal to “school” or “grace”, calculate the Remaining Amortizing Term as the difference between the “RPMT BEGIN DT” field on the #EDH Screen and the “MATURITY DATE” field on the #EDH Screen. Divide the result by the average number of days in a month (i.e., 30.4375, based on 365.25 days in a year) and round up to the nearest whole number.
	iii.   If the “BORROWER_STATUS” field in the Data File is equal to “deferment” or “forbearance”, calculate the Remaining Amortizing Term as the difference between the “RPMT BEGIN DT” field on the #EDH Screen and the next cycle date after the “MATURITY DATE” field on the #EDH Screen. Divide the result by the average number of days in a month (i.e., 30.4375, based on 365.25 days in a year) and round up to the nearest whole number.
	c)   Compare the Remaining Amortizing Term to the “rpmt_prin_int_rmng_term_cnt“ column in Remaining Amortizing Term Supplemental File
Days Past Due	Recompute Days Past Due as the sum of:
	a)   If there was a payment posted in the “PAYMENT” field during the cycle date encompassing the Cutoff Date on the #CSS Screen, 0
	b)   With any cycle after the latest payment posted,  the difference between the Cutoff Date and the last “CYCLE DATE” on the #CSS Screen where a payment was posted.
Interim Status End Date	Interim Status End Date is considered to be (Instructions are listed in order of priority until the attribute was agreed):
	a)   If the “CURR LOAN STAT” field on the #EDH Screen is “RPMT” or begins with “SS”, then 0.
	b)   If the “CURR LOAN STAT” field on the #EDH Screen is “SCHL” or “GRCE,” then “CYCLE DATE” on the #CSS Screen after the date in “RPMT BEGIN DT” field on the #EDH Screen.
	c)   If the “CURR LOAN STAT” field on the #EDH Screen begins with “D” or “F”, then the second date listed in “RULS MIN PAY” field on the #NPO Screen.

Contractual Interest Rate	Compare or recompute Contractual Interest Rate as follows:
	a)   If the “AUTO-PAY STRT DT” field on the #NM AF Screen is before the Cutoff Date, add the Autopay Discount in the “DDD_RATE” field within the “DDDBenefit” tab on #HDI Screen to the “INT RT” column on #EDH Screen; or
	b)   Compare to the “INT RT” column on #EDH Screen
Cosigner Flag	Consider the Cosigner Flag as follows:
	a)   If the SECONDARY SSN#” field on #NM CR Screen is not equal to 0, “Y”.
	b)   Otherwise, “N”
Short Term Interest Only Forbearance	Consider the Short Term Interest Only Forbearance as follows:
	a)   If the “CURR LOAN STAT” column on #EDH Screen is equal to “SSFP”, “Y”.
	b)   Otherwise, “N”.
Term Extension	Consider the Term Extension as follows:
	a)   If there is a value of “Y” or “E: to the right of “#2” field and on the left of “#3: field, “Y”
	b)   Otherwise, “N”
Loan Mod	Consider the Loan Mod as follows:
	a)   If there a code begins with “SCRR” under the “INTEREST RT” field with value “(CP IC ID)”, “Y”
	b)   Otherwise, “N”
Title IV School	Instructions are listed in order of priority until the attribute was agreed:
	a)   Compare the school name under the “underwritten_school_name” field in the Data File to the corresponding information on the Title IV Federal School Code List. If the school name is present, Title IV School is deemed to be “True”;
	b)   Compare the U.S. Department of Education’s Office of Postsecondary Education (OPE) code under the “underwritten_education_opeid” field in the Data File to the “School Code” field in the Title IV Federal School Code List. If the OPE Code is present, Title IV School is deemed to be “True”;
	c)   Observe whether the school name under the “underwritten_school_name” field in the Data File appeared in the “Institution_Name” field in the Accredited Programs List. If the school name is present, Title IV School is deemed to be, “True”;

	d)   Observe whether the school name under the “underwritten_school_name” field in the Data File appears in the “Educations” section of the Verify Report Page or “Underwritten Education School Name” field in the Application Underwriting Snapshot Page for the Selected Student Loans. If the school name is present, Title IV School is deemed to be “True”;
	e)   Otherwise, “False”
	In the event the school name in the “underwritten_school_name” field in the Data File indicates the school is a satellite campus, but the Title IV Federal School Code List or the Accredited Programs List designation is not available at the satellite campus level, compare the name of the college or university to which the satellite campus relates to the Title IV Federal School Code List or the Accredited Programs List.

(*) The Company has assigned a unique Student Loan Number to each student loan in the Data File. The Student Loan Numbers referred to in this Exhibit are not the actual Student Loan Numbers.