hard · Asset-Backed Securities Asset-Specific Nuances

An FFELP student loan ABS trust holds a pool of loans that reset quarterly off the 91-day Treasury bill auction rate, with a government guarantee covering principal and a substantial share of interest via Special Allowance Payments (SAP). The trust's senior notes pay a floating coupon indexed to 3-month SOFR, reset monthly.

What is the primary risk this basis mismatch creates for the trust, independent of borrower default?

  1. Credit risk increases because the government guarantee does not cover any interest shortfall arising from index mismatches between the collateral and the bonds.
  2. Basis risk arises because collateral yield tracks T-bill/SAP while the notes float off SOFR, so index spread compression can erode excess spread with zero defaults.
  3. Prepayment risk increases because quarterly collateral resets are structurally incompatible with monthly note resets, which under the PSA forces an automatic mandatory cleanup call.
  4. Extension risk increases because SAP payments recalculate only annually, which under Treasury methodology causes the notes' average life to lengthen whenever T-bill rates rise.

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