SEC Comment Letter for SLM Corp (SLM, SLMBP) (CIK 0001032033) (SLM) — May 5, 2022
SLM Corp (SLM, SLMBP) (CIK 0001032033)
Date: May 5, 2022 · CIK: 0001032033 · Accession: 0000000000-22-004920
AI Filing Summary & Sentiment
File numbers found in text: 001-13251
Letter
United States securities and exchange commission logo May 5, 2022 Jonathan W. Witter Chief Executive Officer SLM Corporation 300 Continental Drive Newark, DE 19713 Re:SLM Corporation Form 10-K for the fiscal period ending December 31, 2021 Filed February 24, 2022 File No. 001-13251 Dear Mr. Witter: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the fiscal year ended December 31, 2021 Note 11. Borrowings, page F-55 1.We note your disclosure with regard to your unconsolidated VIEs, that you determined while you are the sponsor, servicer and administrator and may have a significant impact on economic performance, the risk of absorbing losses that could be significant is low. Please tell us how your determination that the risk is low of absorbing significant losses is consistent with the guidance in ASC 810-10-25-38A(b) that requires determination of whether your obligation to absorb losses or benefits could be significant.
FirstName LastNameJonathan W. Witter Comapany NameSLM Corporation May 5, 2022 Page 2 FirstName LastName Jonathan W. Witter SLM Corporation May 5, 2022 Page 2
In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Michelle Miller at 202-551-3368 or Sharon Blume at 202-551- 3474 with any questions. Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
May 5, 2022
Jonathan W. Witter
Chief Executive Officer
SLM Corporation
300 Continental Drive
Newark, DE 19713
Re:SLM Corporation
Form 10-K for the fiscal period ending December 31, 2021
Filed February 24, 2022
File No. 001-13251
Dear Mr. Witter:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we ask you to provide us with
information so we may better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for the fiscal year ended December 31, 2021
Note 11. Borrowings, page F-55
1.We note your disclosure with regard to your unconsolidated VIEs, that you determined
while you are the sponsor, servicer and administrator and may have a significant impact
on economic performance, the risk of absorbing losses that could be significant is low.
Please tell us how your determination that the risk is low of absorbing significant losses is
consistent with the guidance in ASC 810-10-25-38A(b) that requires determination of
whether your obligation to absorb losses or benefits could be significant.
FirstName LastNameJonathan W. Witter
Comapany NameSLM Corporation
May 5, 2022 Page 2
FirstName LastName
Jonathan W. Witter
SLM Corporation
May 5, 2022
Page 2
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact Michelle Miller at 202-551-3368 or Sharon Blume at 202-551-
3474 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance