Exhibit 99.1
KPMG LLP Suite 700 20 Pacifica Irvine, CA 92618-3391 |
Independent Accountants’ Agreed-Upon Procedures Report
Education Loan Finance, Inc. (the “Company”)
Citigroup Global Markets Inc. (the “Structuring Agent”)
BofA Securities, Inc.
(together, the “Specified Parties”)
Re: ELFI Graduate Loan Program 2026-A LLC – Data File Procedures
We have performed the procedures described below on the specified attributes in an electronic data file entitled “2026-A Loan Tape vf.xlsx” provided by the Company on September 8, 2026, containing information on 4,149 private education loans (the “Education Loans”) as of August 31, 2026 (the “Data File”), which we were informed are intended to be included as collateral in the offering by ELFI Graduate Loan Program 2026-A LLC. The Company is responsible for the specified attributes identified by the Company in the Data File.
The Specified Parties have agreed to and acknowledged that the procedures performed are appropriate to meet the intended purpose of assisting the Specified Parties in evaluating the accuracy of the specified attributes in the Data File. This report may not be suitable for any other purpose. No other parties have agreed to or acknowledged the appropriateness of these procedures for the intended purpose or any other purpose.
The procedures performed may not address all the items of interest to a user of this report and may not meet the needs of all users of this report and, as such, users are responsible for determining whether the procedures performed are appropriate for their purposes. We make no representation regarding the appropriateness of the procedures either for the intended purpose or for any other purpose.
Unless otherwise stated, the following definitions have been adopted in presenting our procedures and findings:
| · | 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 “reporting threshold” means that dollar amounts and percentages were within $1.00 and 0.01%, respectively. |
| · | The term “Sources” means the following information related to each Selected Education Loan (defined below), provided by the Company, were represented by the Company to be copies of the original documents or electronic records contained within the origination system or servicing system. |
| – | Electronic data file entitled “Loan Doc VOD or KPMG 2026A AUP degree query-updated with replacement.xlsx” detailing the school name and graduation date of the Selected Student Loans, which the Company represented was retrieved from the National Clearing House database by the Company (the “Degree Query File”). |
| – | Loan Detail Information TSX29 Screenshots provided by the Company and represented to be from the Company’s servicing system (the “Servicing System Screenshots”). |
| – | Scanned copies of Credit Score Exception Notice, DegreeVerify Certificate, Hard Pull File, Gross Income Calculation Document, Final Truth-In-Lending. We make no representation regarding the validity or accuracy of these documents or the execution of these documents by the borrower. |
KPMG LLP, a Delaware limited liability partnership, and its subsidiaries are part of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee.
| · | The term “Instructions” means the instructions provided by the Company, pertaining to a procedure, attribute, or methodology, as described in the procedures below. |
| · | The term “Provided Information” means the Sources and Instructions. |
The procedures we were instructed by the Company to perform are as follows:
| A. | We randomly selected a sample of 150 Education Loans from the Data File (the “Selected Education Loans”) using a random sampling tool. A listing of the Selected Education Loans is attached hereto as Exhibit A. For purposes of this procedure, the Company did not inform us of the basis they used to determine the number of Education Loans we were instructed to randomly select from the Data File. |
| B. | For each Selected Education Loan, we compared the specified attributes in the Data File listed below to or using the corresponding information included in the Sources, utilizing the Instructions, as applicable. The Company indicated that the absence of any of the information in the Sources, or the inability to agree the indicated information from the Data File to the Sources for each of the attributes identified, utilizing the Instructions as applicable, constituted an exception. The Sources are listed in the order of priority. |
| Attribute | Sources / Instructions |
| Account Identification No. | Final Truth-In-Lending |
| Loan Type | Final Truth-In-Lending |
| Borrower State | Final Truth-In-Lending |
| Original Loan Balance | Final Truth-In-Lending |
| Current Interest Rate | Servicing System Screenshots– Loan Detail Information TSX29 Screen – “INT RTE” field |
| Current Loan Balance | Servicing System Screenshots – Loan Detail Information TSX29 Screen – “CUR PRIN” field |
| Repayment Begin Date | Servicing System Screenshots – Loan Detail Information TSX29 Screen – “REPAYMENT START” field |
| Repayment End Date | Servicing System Screenshots – Loan Detail Information TSX29 Screen – “EXP PAYOFF DATE” field |
| First Disbursement Date | Servicing System Screenshots– Loan Detail Information TSX29 Screen – “1st DISB DATE” field |
| Loan Status | Servicing System Screenshots – Loan Detail Information TSX29 Screen – “STATUS” field |
| Borrower Credit Score | Hard Pull File, Credit Score Exception Notice |
| Gross Income | Gross Income Calculation Document |
| School Name |
Degree Query File, DegreeVerify Certificate
If multiple values of School Name appeared on the Degree Query File for the same Selected Education Loan, we were instructed by the Company to ultilize the value that agreed with the Data File.
|
| Graduation Date |
Degree Query File, DegreeVerify Certificate
If multiple values of Graduation Date appeared on the Degree Query File for the same Selected Education Loan, we were instructed by the Company to ultilize the value that agreed with the Data File.
|
We found such information to be in agreement without exception.
2
We were engaged by the Company to perform this agreed-upon procedures engagement. We 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 Company 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 Company, (ii) the physical existence of the Education 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 Education Loans to stated underwriting or credit extension guidelines, standards, criteria or other requirements, (ii) the value of collateral securing any such Education Loans being securitized, (iii) the compliance of the originator of the Education Loans with federal, state, and local laws and regulations, or (iv) any other factor or characteristic of the Education Loans that would be material to the likelihood that the issuer of the asset-backed security 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
September 18, 2026
3
Exhibit A - The Selected Education Loans
|
Selected
Loan # |
Education Loan Number* |
Selected Loan # |
Education Loan Number* |
Selected
Loan # |
Education Loan Number* |
| 1 | 2026A001 | 51 | 2026A051 | 101 | 2026A101 |
| 2 | 2026A002 | 52 | 2026A052 | 102 | 2026A102 |
| 3 | 2026A003 | 53 | 2026A053 | 103 | 2026A103 |
| 4 | 2026A004 | 54 | 2026A054 | 104 | 2026A104 |
| 5 | 2026A005 | 55 | 2026A055 | 105 | 2026A105 |
| 6 | 2026A006 | 56 | 2026A056 | 106 | 2026A106 |
| 7 | 2026A007 | 57 | 2026A057 | 107 | 2026A107 |
| 8 | 2026A008 | 58 | 2026A058 | 108 | 2026A108 |
| 9 | 2026A009 | 59 | 2026A059 | 109 | 2026A109 |
| 10 | 2026A010 | 60 | 2026A060 | 110 | 2026A110 |
| 11 | 2026A011 | 61 | 2026A061 | 111 | 2026A111 |
| 12 | 2026A012 | 62 | 2026A062 | 112 | 2026A112 |
| 13 | 2026A013 | 63 | 2026A063 | 113 | 2026A113 |
| 14 | 2026A014 | 64 | 2026A064 | 114 | 2026A114 |
| 15 | 2026A015 | 65 | 2026A065 | 115 | 2026A115 |
| 16 | 2026A016 | 66 | 2026A066 | 116 | 2026A116 |
| 17 | 2026A017 | 67 | 2026A067 | 117 | 2026A117 |
| 18 | 2026A018 | 68 | 2026A068 | 118 | 2026A118 |
| 19 | 2026A019 | 69 | 2026A069 | 119 | 2026A119 |
| 20 | 2026A020 | 70 | 2026A070 | 120 | 2026A120 |
| 21 | 2026A021 | 71 | 2026A071 | 121 | 2026A121 |
| 22 | 2026A022 | 72 | 2026A072 | 122 | 2026A122 |
| 23 | 2026A023 | 73 | 2026A073 | 123 | 2026A123 |
| 24 | 2026A024 | 74 | 2026A074 | 124 | 2026A124 |
| 25 | 2026A025 | 75 | 2026A075 | 125 | 2026A125 |
| 26 | 2026A026 | 76 | 2026A076 | 126 | 2026A126 |
| 27 | 2026A027 | 77 | 2026A077 | 127 | 2026A127 |
| 28 | 2026A028 | 78 | 2026A078 | 128 | 2026A128 |
| 29 | 2026A029 | 79 | 2026A079 | 129 | 2026A129 |
| 30 | 2026A030 | 80 | 2026A080 | 130 | 2026A130 |
| 31 | 2026A031 | 81 | 2026A081 | 131 | 2026A131 |
| 32 | 2026A032 | 82 | 2026A082 | 132 | 2026A132 |
| 33 | 2026A033 | 83 | 2026A083 | 133 | 2026A133 |
| 34 | 2026A034 | 84 | 2026A084 | 134 | 2026A134 |
| 35 | 2026A035 | 85 | 2026A085 | 135 | 2026A135 |
| 36 | 2026A036 | 86 | 2026A086 | 136 | 2026A136 |
| 37 | 2026A037 | 87 | 2026A087 | 137 | 2026A137 |
| 38 | 2026A038 | 88 | 2026A088 | 138 | 2026A138 |
| 39 | 2026A039 | 89 | 2026A089 | 139 | 2026A139 |
| 40 | 2026A040 | 90 | 2026A090 | 140 | 2026A140 |
| 41 | 2026A041 | 91 | 2026A091 | 141 | 2026A141 |
| 42 | 2026A042 | 92 | 2026A092 | 142 | 2026A142 |
| 43 | 2026A043 | 93 | 2026A093 | 143 | 2026A143 |
| 44 | 2026A044 | 94 | 2026A094 | 144 | 2026A144 |
| 45 | 2026A045 | 95 | 2026A095 | 145 | 2026A145 |
| 46 | 2026A046 | 96 | 2026A096 | 146 | 2026A146 |
| 47 | 2026A047 | 97 | 2026A097 | 147 | 2026A147 |
| 48 | 2026A048 | 98 | 2026A098 | 148 | 2026A148 |
| 49 | 2026A049 | 99 | 2026A099 | 149 | 2026A149 |
| 50 | 2026A050 | 100 | 2026A100 | 150 | 2026A150 |
* The Company has assigned a unique Education Loan Number to each Education Loan in the Data File. The Education Loan Numbers referred to in this Exhibit are not the Company’ actual Education Loan Numbers.