SecProbe.io

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Mail Stop 4561
								September 13, 2005

Mr. C.E. Andrews
Executive Vice President, Finance
SLM Corporation
12061 Bluemont Way
Reston, Virginia 20190

Re:	SLM Corporation
	Form 10-K for the fiscal year ended
	December 31, 2004
	Forms 10-QSB for quarterly periods ended
	March 31, 2005 and June 30, 2005
      File No.  001-13251

Dear Mr. Andrews:

      We have reviewed your filings and have the following
comments.
We have limited our review of your filings to those issues we have
addressed in our comments. Please be as detailed as necessary in
your
explanation.  In some of our comments, we may ask you to provide
us
with more information so we may better understand your disclosure.
After reviewing this information, we may raise additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-K for the fiscal year ended December 31, 2004

Alternative Performance Measures, pages 61-64

1. Question 8 of the Frequently Asked Questions Regarding the Use
of
Non-GAAP Financial Measures indicates that registrants must meet
the
burden of demonstrating the usefulness of any measure that
excludes
recurring items, especially if that measure is used to evaluate
performance.  Tell us in detail why you believe you overcome the
burden of supporting their usefulness.

2. Please tell us and provide us with an example of how you use
"core
cash" measures in establishing corporate performance targets and
determining incentive

compensation.  Describe how you use your GAAP financial results in
conjunction with this analysis.

Financial Statements

Note 10 - Derivative Financial Instruments, page F-39

3. For each type of derivative instrument that you have classified
as
a fair value hedge or cash flow hedge, please tell us how you
determined that they met the criteria for hedge accounting
pursuant
to paragraphs 20, 21, 28 and 29 of SFAS 133.  Specifically address
the following for each type of hedging relationship:

* the nature and terms of the hedged item and derivative
instrument;

* when and how you identify the hedge instrument and the hedged
item;

* how you define "at inception" of the hedging relationship; and

* the quantitative measures you use to assess effectiveness of
each
hedge both at inception and on an ongoing basis.

4. Please tell us whether you use the short-cut method for
assessing
effectiveness for any of your hedging relationships that qualify
for
hedge accounting treatment under SFAS 133.  If so, please tell us
how
you determine that the hedging relationship meets each of the
conditions in paragraph 68 of SFAS 133.

5. Please tell us whether you aggregate similar assets and
liabilities and hedge as a portfolio.  If so, provide us with a
comprehensive analysis explaining how you apply SFAS133
Implementation Issue F11 to these hedging relationships.

      Please respond to these comments within ten business days or
tell us when you will respond.  Please furnish a cover letter that
keys your responses to our comments and provides and requested
information.  Detailed cover letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing your responses to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under
the Securities Exchange Act of 1934 and that they have provided
all
information investors require for an informed investment decision.
Since the company and its

management are in possession of all facts relating to a company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated
by the Commission or any person under the federal securities laws
of
the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Chris Harley at (202) 551-3695 or me at (202)
551-3449 if you have questions regarding comments on the financial
statements and related matters.

							Sincerely,

							Joyce Sweeney
							Branch Chief
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Mr. C.E. Andrews
Executive Vice President, Finance
SLM Corporation
September 13, 2005
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