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United States securities and exchange commission logo
April 29, 2022
Joe Fisher
Chief Financial Officer
NAVIENT CORP
123 Justison Street
Wilmington, DE 19801
Re: NAVIENT CORP
Form 10-K for the
Fiscal Year Ended December 31, 2021
Filed February 25,
2022
File No. 001-36228
Dear Mr. Fisher:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the fiscal period ending December 31, 2021
Note 4. Allowance for Loan Losses, page F-27
1. We note your accounting
policy on pages F-16 F-17 related to the allowance for loan
losses. Please tell us
how your allowance excluding expected recoveries on charged-off
loans complies with the
guidance in ASC 326-20-50-13 as amended by ASU 2019-04.
2. Tell us how your
accounting for expected recoveries of amounts previously written off
and expected to be
written off complies with the guidance in ASC 326-20-30-1, including
that it should not
exceed the aggregate of amounts previously written off and expected to
be written off.
3. Tell us how you
considered Question 100.04 of Non-GAAP C&D s and Rule 100(b) of
Regulation G as the
allowance at the end of the period excluding expected future
recoveries on
charged-off loans appears to be a tailored accounting measurement.
Joe Fisher
NAVIENT CORP
April 29, 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 Dave Irving at (202) 551-3321 or Michelle Miller at (202)
551-
3368 with any questions.
FirstName LastNameJoe Fisher Sincerely,
Comapany NameNAVIENT CORP
Division of
Corporation Finance
April 29, 2022 Page 2 Office of Finance
FirstName LastName