types of master trusts of which the most common is the de-linked master trust. Discrete trusts consist of a fixed or static pool of receivables that are tranched into senior/subordinated bonds. A master trust has the advantage of offering multiple deals out of the same trust as the number of receivables grows, each of which is entitled to a pro-rata share of all of the receivables. The delinked structures allow the issuer to separate the senior and subordinate series within a trust and issue them at different points in time. The latter two structures allow investors to benefit from a larger pool of loans made over time rather than one static pool. Student loans ABS collateralized by student loans (“SLABS”) comprise one of the four (along with home equity loans, auto loans, and credit card receivables) core asset classes financed through asset-backed securitizations and are a benchmark subsector for most floating rate indices . Federal Family Education Loan Program (FFELP) loans are the most common form of student loans and are guaranteed by the U.S. Department of Education ("USDE") at rates ranging from 95%–98% (if the student loan is serviced by a servicer designated as an "exceptional performer" by the USDE the reimbursement rate was up to 100%). As a result, performance (other than high cohort default rates in the late 1980s) has historically been very good and investors rate of return has been excellent. The College Cost Reduction and Access Act became effective on October 1, 2007, and significantly changed the economics for FFELP loans; lender special allowance payments were reduced, the exceptional performer designation was revoked, lender insurance rates were reduced, and the lender paid origination fees were doubled. The FFELP loan program ended in 2010, but as of 2020 there was about $245 billion in outstanding debt from 11 million debtors. A second, and faster growing, portion of the student loan market consists of non-FFELP or private student loans. Though borrowing limits on certain types of FFELP loans were slightly increased by the student loan bill referenced above, essentially static borrowing limits for FFELP loans and increasing tuition are driving students to search for alternative lenders. Students utilize private loans to bridge the gap between amounts that can be borrowed through federal programs and the remaining costs of education. The United States Congress created the Student Loan Marketing Association (Sallie Mae) as a government sponsored enterprise to