Moody’s Investors Service is giving investors and sponsors more time to review proposed changes to its methodology for rating bonds backed by federally guaranteed student loans.

Moody’s also released additional guidance on the proposed changes, which are intended to more accurately reflect the fact that the underlying loans are paying off at a slower rate as the result of plans allowing students to base monthly payments on their income levels. This increases the risk that bonds backed by Federal Family Education Loans may not pay off at maturity.

Moody’s considers the failure to pay off at maturity to be an event of default. It has put $37 billion of securities, most of which are currently rated ‘AAA,’ under review for downgrades; in some cases this could result in low investment grade or even below investment grade ratings.

The comment period, which originally ended this month, has been extended to October 30.

The ratings action on the securities under review will be completed after the publication of the revised final methodology

Moody’s also said that the “ability and willingness of the securitization sponsors/servicers to take actions to repurchase loans from or extend maturity dates on outstanding transactions may affect the ratings of those deals.”

Servicers, including the two largest, Navient and NelNet, have repurchasing hundreds of millions of dollars of loans from the pools of collateral of existing deals. Sponsors have also called individual tranches of deals at risk of not paying off at maturity.

Moody’s also noted that structural features in new transactions could mitigate the risk caused by lower payment levels. Two deals completed in the past few months have included a “turbo” feature that accelerates payments if certain triggers are met. The senior securities of both deals were rated ‘AAA’ by Moody’s.

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