The rating on Pennsylvania Higher Education Assistance Agency's (PHEAA) student loan adjustable-rate revenue refunding bonds 2001 series B is based on an unconditional, irrevocable financial guaranty insurance policy that guarantees payment of scheduled principal and interest provided by Financial Security Assurance Inc. (FSA) ('AAA' insurer financial strength rating). Although the 'AAA' rating is dependent on Standard&Poor's rating of FSA's insurer financial strength, the underlying transaction is of investment-grade quality, as illustrated by the following: The structural features that restrict proprietary loan originations, and limit recycling and the withdrawal of funds; The excess spread; The principal overcollateralization of the bonds; The bankruptcy-remote municipal issuer; and The superior servicing track record of PHEAA. PHEAA is a government instrumentality created according