Allowance for Credit Losses and Unfunded Loan Commitments

12 Months Ended

Dec. 31, 2024

Receivables [Abstract]

Allowance for Credit Losses and Unfunded Loan Commitments

Allowance for Credit Losses and Unfunded Loan Commitments

Our provision for credit losses represents the periodic expense of maintaining an allowance sufficient to absorb lifetime expected credit losses in the held for investment loan portfolios. The evaluation of the allowance for credit losses is inherently subjective, as it requires material estimates that may be susceptible to significant changes. We believe the allowance for credit losses is appropriate to cover lifetime expected losses incurred in the loan portfolios.

When a new loan commitment is made, we record the CECL allowance as a liability for unfunded loan commitments by recording a provision for credit losses. The allowance is recorded in “Other Liabilities” on the consolidated balance sheet. When the loan is funded, we transfer that liability to the allowance for loan losses.

The majority of the total accrued interest receivable on our Private Education Loan portfolio represents accrued interest on deferred loans where no payments are due while the borrower is in school and on fixed-pay loans where the borrower makes a $25 monthly payment that is smaller than the interest accrued on the loan in that month. The allowance for credit losses considers the collectability of both principal and accrued interest. The allowance for uncollectible interest estimates the additional uncollectible interest that is not captured in the allowance for credit losses. See “— Accrued Interest Receivable” in this Note 6 for further discussion.

For the years ended December 31, 2024, 2023, and 2022, the allowance for loan losses, ending total loans, and accrued interest balances were all collectively evaluated for impairment, none of the balances were individually evaluated for impairment.

See Note 2, “Significant Accounting Policies — Allowance for Credit Losses” for a more detailed discussion on our allowance for credit losses accounting policies.

Allowance for Credit Losses Metrics

The following tables provide a summary of the activity in the allowance for loan losses and the allowance for unfunded loan commitments during the years ended December 31, 2024, 2023, and 2022.

Year Ended December 31, 2024 (dollars in thousands)	FFELP  Loans			Private Education Loans			Total
Allowance for loan losses, beginning balance	$	4,667		$	1,335,105		$	1,339,772
Transfer from allowance for unfunded loan commitments	—			311,787			311,787
Provisions:
Provision for current period	4,010			357,067			361,077
Loan sale reduction to provision	—			(235,955)			(235,955)
Total provisions(1)	4,010			121,112			125,122
Net charge-offs:
Charge-offs	(380)			(376,840)			(377,220)
Recoveries	—			44,756			44,756
Net charge-offs	(380)			(332,084)			(332,464)
Write-downs arising from transfer of loans to held for sale(2)	(8,297)			—			(8,297)
Allowance for loan losses, ending balance	—			1,435,920			1,435,920
Allowance for unfunded loan commitments, beginning balance(3)	—			112,962			112,962
Provision(1)(4)	—			283,393			283,393
Transfer to allowance for loan losses	—			(311,787)			(311,787)
Allowance for unfunded loan commitments, ending balance(3)	—			84,568			84,568
Total allowance for credit losses, ending balance	$	—		$	1,520,488		$	1,520,488
Net charge-offs as a percentage of average loans in repayment(5)	—		%	2.19		%
Allowance for loan losses coverage of net charge-offs	—			4.32
Total allowance for credit losses as a percentage of the ending total loan balance, plus unfunded loan commitments and total accrued interest receivable	—		%	5.83		%
Ending total loans, gross	$	—		$	22,235,008
Average loans in repayment(5)	$	—		$	15,139,184
Ending loans in repayment(5)	$	—		$	16,106,751
Unfunded loan commitments	$	—		$	2,311,660
Total accrued interest receivable	$	—		$	1,549,415

(1) See “— Provisions for Credit Losses” below in this Note 6 for a reconciliation of the provisions for credit losses reported in the consolidated statements of income.

(2) Represents fair value adjustments on loans transferred to held for sale.

(3) When a new loan commitment is made, we record an allowance to cover lifetime expected credit losses on the unfunded commitments, which is recorded in “Other Liabilities” on the consolidated balance sheet. See “— Unfunded Loan Commitments” in this Note 6 for further discussion.

(4) Includes incremental provision for new commitments and changes to provision for existing commitments.

(5) Loans in repayment include loans on which borrowers are making interest only or fixed payments, as well as loans that have entered full principal and interest repayment status after any applicable grace period (but, for purposes of the table, do not include those loans while they are in forbearance).

Year Ended December 31, 2023 (dollars in thousands)	FFELP  Loans			Private Education Loans			Total
Allowance for loan losses, beginning balance	$	3,444		$	1,353,631		$	1,357,075
Transfer from allowance for unfunded loan commitments	—			320,237			320,237
Provisions:
Provision for current period	2,224			240,347			242,571
Loan sale reduction to provision	—			(205,383)			(205,383)
Total provisions(1)	2,224			34,964			37,188
Net charge-offs:
Charge-offs	(1,001)			(420,095)			(421,096)
Recoveries	—			46,368			46,368
Net charge-offs	(1,001)			(373,727)			(374,728)
Allowance for loan losses, ending balance	4,667			1,335,105			1,339,772
Allowance for unfunded loan commitments, beginning balance(2)	—			124,924			124,924
Provision(1)(3)	—			308,275			308,275
Transfer to allowance for loan losses	—			(320,237)			(320,237)
Allowance for unfunded loan commitments, ending balance(2)	—			112,962			112,962
Total allowance for credit losses, ending balance	$	4,667		$	1,448,067		$	1,452,734
Net charge-offs as a percentage of average loans in repayment(4)	0.23		%	2.44		%
Allowance for loan losses coverage of net charge-offs	4.66			3.57
Total allowance for credit losses as a percentage of the ending total loan balance, plus unfunded loan commitments and total accrued interest receivable	0.87		%	5.89		%
Ending total loans, gross	$	537,401		$	21,025,844
Average loans in repayment(4)	$	433,225		$	15,310,934
Ending loans in repayment(4)	$	406,568		$	15,409,814
Unfunded loan commitments	$	—		$	2,221,077
Total accrued interest receivable	$	—		$	1,354,565

(1) See “— Provisions for Credit Losses” below in this Note 6 for a reconciliation of the provisions for credit losses reported in the consolidated statements of income.

(2) When a new loan commitment is made, we record an allowance to cover lifetime expected credit losses on the unfunded commitments, which is recorded in “Other Liabilities” on the consolidated balance sheet. See “— Unfunded Loan Commitments” in this Note 6 for further discussion.

(3) Includes incremental provision for new commitments and changes to provision for existing commitments.

(4) Loans in repayment include loans on which borrowers are making interest only or fixed payments, as well as loans that have entered full principal and interest repayment status after any applicable grace period (but, for purposes of the table, do not include those loans while they are in forbearance).

Year Ended December 31, 2022 (dollars in thousands)	FFELP  Loans			Private Education Loans			Credit Cards			Total
Allowance for loan losses, beginning balance	$	4,077		$	1,158,977		$	2,281		$	1,165,335
Transfer from allowance for unfunded loan commitments	—			344,310			—			344,310
Provisions:
Provision for current period	(20)			410,254			3,301			413,535
Loan sale reduction to provision	—			(174,231)			—			(174,231)
Loans transferred to held-for-sale	—			—			(2,372)			(2,372)
Total provisions(1)	(20)			236,023			929			236,932
Net charge-offs:
Charge-offs	(613)			(427,416)			(3,215)			(431,244)
Recoveries	—			41,737			5			41,742
Net charge-offs	(613)			(385,679)			(3,210)			(389,502)
Allowance for loan losses, ending balance	3,444			1,353,631			—			1,357,075
Allowance for unfunded loan commitments, beginning balance(2)	—			72,713			—			72,713
Provision(1)(3)	—			396,521			—			396,521
Transfer to allowance for loan losses	—			(344,310)			—			(344,310)
Allowance for unfunded loan commitments, ending balance(2)	—			124,924			—			124,924
Total allowance for credit losses, ending balance	$	3,444		$	1,478,555		$	—		$	1,481,999
Net charge-offs as a percentage of average loans in repayment(4)	0.12		%	2.55		%	—		%
Allowance for loan losses coverage of net charge-offs	5.62			3.51			—
Total allowance for credit losses as a percentage of the ending total loan balance, plus unfunded loan commitments and total accrued interest receivable	0.57		%	6.30		%	—		%
Ending total loans, gross	$	609,050		$	20,303,688		$	—
Average loans in repayment(4)	$	517,139		$	15,103,123		$	—
Ending loans in repayment(4)	$	453,915		$	15,129,550		$	—
Unfunded loan commitments	$	—		$	1,995,808		$	—
Total accrued interest receivable	$	—		$	1,177,562		$	—

(1) See “— Provisions for Credit Losses” below in this Note 6 for a reconciliation of the provisions for credit losses reported in the consolidated statements of income.

(2) When a new loan commitment is made, we record an allowance to cover lifetime expected credit losses on the unfunded commitments, which is recorded in “Other Liabilities” on the consolidated balance sheet. See “— Unfunded Loan Commitments” in this Note 6 for further discussion.(

(3) Includes incremental provision for new commitments and changes to provision for existing commitments.

(4) Loans in repayment include loans on which borrowers are making interest only or fixed payments, as well as loans that have entered full principal and interest repayment status after any applicable grace period (but, for purposes of the table, do not include those loans while they are in forbearance).

Provisions for Credit Losses

Below is a reconciliation of the provisions for credit losses reported in the consolidated statements of income.

Consolidated Statements of Income Provisions for Credit Losses Reconciliation
Years Ended December 31,
(dollars in thousands)	2024		2023		2022
Private Education Loan provisions for credit losses:
Provisions for loan losses	$	121,112	$	34,964	$	236,023
Provisions for unfunded loan commitments	283,393		308,275		396,521
Total Private Education Loan provisions for credit losses	404,505		343,239		632,544
Other impacts to the provisions for credit losses:
FFELP Loans	4,010		2,224		(20)
Credit Cards	—		—		929
Total	4,010		2,224		909
Provisions for credit losses reported in consolidated statements of income	$	408,515	$	345,463	$	633,453

The provision for credit losses for the year ended December 31, 2024 was $409 million, compared with $345 million in the year-ago period. During 2024, the provision for credit losses was primarily affected by new loan commitments, net of expired commitments, and changes in recovery rates, which were partially offset by $236 million in negative provisions recorded as a result of the approximately $3.69 billion in Private Education Loan sales during 2024, an improved economic outlook, and changes in management overlays.

In 2023, the provision for credit losses was primarily affected by new loan commitments, net of expired commitments, slower prepayment rates, management overlays, and changes in economic outlook, which were partially offset by $205 million in negative provisions recorded as a result of the approximately $3.15 billion in Private Education Loan sales during 2023 and an increase in recovery rates (as the result of a change in our defaulted loan recovery process).

During 2022, the provision for credit losses was primarily affected by new loan commitments made during the period, slower than expected prepayment rates, and additional management overlays, which were partially offset by negative provisions recorded related to approximately $3.34 billion in Private Education Loans sold in 2022 and the adoption of a new loss model that included a reduction in the long-term estimate of losses after the reasonable and supportable period. Management overlays increased in 2022 due to several factors, including additional provisions arising from our expectation of higher future losses related to the previously announced credit administration practices changes we implemented in 2021, “gap year” loans, a shortage and lack of tenured collections staff, and other operational challenges we experienced in 2022. “Gap year” loans refer to loans to borrowers who took a “gap year” during the COVID-19 pandemic and entered full principal and interest repayment status starting in late 2021 and early 2022. Losses on those “gap year” loans were higher than expected and contributed to the higher provision expense recorded in 2022 to cover the higher-than-expected losses.

Private Education Loans Allowance for Credit Losses - Forecast Assumptions

See Note 2, “Significant Accounting Policies — Allowance for Credit Losses” for a more detailed discussion on the forecast assumptions used in calculating the allowance for credit losses.

Loan Modifications to Borrowers Experiencing Financial Difficulty

The allowance for credit losses incorporates an estimate of lifetime expected credit losses and is recorded on each asset upon asset origination or acquisition. The starting point for the estimate of the allowance for credit losses is historical information, which includes losses from modifications of receivables whose borrowers are experiencing financial difficulty. We use a discounted cash flow model to determine the allowance for credit losses. An assessment of whether a borrower is experiencing financial difficulty is made on the date of a modification.

The effect of most modifications of loans made to borrowers who are experiencing financial difficulty is already included in the allowance for credit losses because of the measurement methodologies used to estimate the allowance. The forecast of expected future cash flows is updated as the loan modifications occur.

Within the Private Education Loan portfolio, we deem loans greater than 90 days past due as nonperforming. FFELP Loans are at least 97 percent guaranteed as to their principal and accrued interest by the federal government in the event of default and, therefore, we did not deem FFELP Loans as nonperforming from a credit risk perspective at any point in their life cycle prior to claim payment and continued to accrue interest on those loans through the date of claim.

For additional information, see Note 2, “Significant Accounting Policies —Allowance for Credit Losses” in this Form 10-K.

Under our current forbearance practices, temporary forbearance of payments is generally granted in one-to-two month increments, for up to 12 months over the life of the loan, with 12 months of positive payment performance by a borrower required between grants (meaning the borrower must make payment in a cumulative amount equivalent to 12 monthly required payments under the loan). During the first six months following a borrower’s grace period, the borrower may be eligible for extended grace forbearance in one six-month increment (which would also count towards the 12-month forbearance cap). See Note 5, “Loans Held for Investment — Certain Collection Tools - Private Education Loans” in this Form 10-K. In the first quarter of 2022, we adopted ASU No. 2022-02. Under this ASU, if the debt has been previously restructured, an entity must consider the cumulative effect of past restructurings made within the 12-month period before the current restructuring when determining whether a delay in payment resulting from the current restructuring is insignificant. Due to our current forbearance practices, including the limitations on forbearances offered to borrowers, we do not believe the granting of forbearances will exceed the significance threshold and, therefore, we do not consider the forbearances as loan modifications.

We offer certain administrative forbearances (e.g., death and disability, bankruptcy, military service, disaster forbearance, and in school assistance) that are required by law (such as by the Servicemembers Civil Relief Act), are considered separate from our active loss mitigation programs, or do not exceed the significance threshold and therefore are not considered to be loan modifications requiring disclosure under ASU No. 2022-02. In addition, we may offer on a limited basis term extensions or rate reductions or a combination of both to borrowers to reduce consolidation activities. For purposes of this disclosure, we do not consider them modifications of loans to borrowers experiencing financial difficulty and they therefore are not included in the tables below.

For additional information on our forbearance and modification programs, see Note 5, “Loans Held for Investment —Certain Collection Tools — Private Education Loans” in this Form 10-K.

As part of the additional modification programs that were launched in the fourth quarter of 2023, we also offered for a short period of time a permanent term extension with no interest rate reduction program. This program ended in the fourth quarter of 2023. The amortized cost of this program totaled $7.3 million as of December 31, 2024, representing 0.03 percent of the total Private Education Loan portfolio. This program added a weighted average of 6.7 years to the life of loans in the program. As of December 31, 2024, $6.0 million of these loans were in a current or deferred status, $0.6 million of these loans were 30-59 days past due, $0.4 million of these loans were 60-89 days past due, and $0.3 million of these loans were 90 days or greater past due. As of December 31, 2024, the defaulted amount and amortized cost basis of loans that received a permanent term extension and no interest rate reduction and defaulted during the year ended December 31, 2024 and were modified for borrowers experiencing financial difficulty during the twelve months prior to default were $2.5 million and $2.0 million, respectively. Additionally, loans that received a permanent term extension with no interest rate reduction in the fourth quarter of 2023 that were both modified and subsequently charged-off during the twelve months ended December 31, 2024 are not included in the amortized cost basis and had an amortized cost basis of $0.6 million.

The following tables show the amortized cost basis at the end of the respective reporting periods of the loans to borrowers experiencing financial difficulty that were modified during the period, disaggregated by class of financing receivable and type of modification. When we approve a Private Education Loan at the beginning of an academic year, we do not always disburse the full amount of the loan at the time of approval, but instead have a commitment to fund a portion of the loan at a later date (usually at the start of the second semester or subsequent trimesters). We consider borrowers to be in financial difficulty after they have exited school and have difficulty making their scheduled principal and interest payments. The increase in loan modifications during the year ended December 31, 2024 compared to the year-ago period is primarily due to additional modification programs implemented in the fourth quarter of 2023 and subsequent refinements to those programs.

	Loan Modifications Made to Borrowers Experiencing Financial Difficulty
Year Ended December 31, 2024 (dollars in thousands)	Interest Rate Reduction				Combination - Interest Rate Reduction and Term Extension
Loan Type:	Amortized Cost Basis		% of Total Class of Financing Receivable		Amortized Cost Basis		% of Total Class of Financing Receivable
Private Education Loans	$	31,966	0.13	%	$	1,003,089	4.20	%
Total	$	31,966	0.13	%	$	1,003,089	4.20	%

	Loan Modifications Made to Borrowers Experiencing Financial Difficulty
Year Ended December 31, 2023 (dollars in thousands)	Interest Rate Reduction				Combination - Interest Rate Reduction and Term Extension
Loan Type:	Amortized Cost Basis		% of Total Class of Financing Receivable		Amortized Cost Basis		% of Total Class of Financing Receivable
Private Education Loans	$	48,637	0.22	%	$	331,889	1.48	%
Total	$	48,637	0.22	%	$	331,889	1.48	%

The following tables describe the financial effect of the modifications made to loans whose borrowers are experiencing financial difficulty:

Year Ended December 31, 2024
Interest Rate Reduction		Combination - Interest Rate Reduction and Term Extension
Loan Type	Financial Effect	Loan Type	Financial Effect
Private Education Loans	Reduced average contractual rate from 13.22% to 3.79%	Private Education Loans	Added a weighted average 9.23 years to the life of loans Reduced average contractual rate from 12.71% to 3.66%

Year Ended December 31, 2023
Interest Rate Reduction		Combination - Interest Rate Reduction and Term Extension
Loan Type	Financial Effect	Loan Type	Financial Effect
Private Education Loans	Reduced average contractual rate from 13.37% to 4.00%	Private Education Loans	Added a weighted average 10.20 years to the life of loans Reduced average contractual rate from 12.92% to 4.00%

Private Education Loans are charged off at the end of the month in which they reach 120 days delinquent or otherwise when the loans are classified as a loss by us or our regulator. Therefore, the amortized cost basis of the loan is reduced by the uncollectible amount and the allowance for credit losses is adjusted by the same amount. See Note 2, “Significant Accounting Policies — Allowance for Credit Losses — Allowance for Private Education Loan Losses” and “Significant Accounting Policies — Allowance for Credit Losses — Allowance for FFELP Loan Losses” in this Form 10-K for a more detailed discussion.

For the periods presented, the following table presents the defaulted amount and period-end amortized cost basis, by modification category, of loans that defaulted during the period and were modified for borrowers experiencing financial difficulty during the 12 months preceding default. Solely for the purpose of the below table, starting in the quarter ended December 31, 2024, we changed our definition of payment default to be two missed consecutive post-modification payment obligations. As such, as reflected for the year ended December 31, 2024 below, defaulted amount represents the principal amount of modified loans at the time the borrower missed two consecutive post-modification payment obligations during the period. Previously, as reflected for the year ended December 31, 2023 in the table below, defaulted amount represented the principal amount of modified loans at the time they became 60 days or more past due in the relevant period. Loans that were both modified and subsequently charged-off during the twelve months ended December 31, 2024 are not included in the period-end amortized cost basis and had an amortized cost basis of $40.4 million at the time of charge-off. The increase in loan modifications during the year ended December 31, 2024 compared to the year-ago period is primarily due to the additional modification programs implemented in the fourth quarter of 2023 and subsequent refinements to those programs. The following two tables do not include loans that received a permanent term extension with no interest rate reduction during the fourth quarter of 2023, which are described earlier in this Note 6.

	Year Ended December 31, 2024				Year Ended December 31, 2023
(Dollars in thousands)	Defaulted Amount		Period-end Amortized Cost Basis		Defaulted Amount		Period-end Amortized Cost Basis
Loan Type:
Private Education Loans
Interest Rate Reduction	$	6,460	$	4,621	$	4,521	$	4,174
Combination - Interest Rate Reduction and Term Extension	143,300		114,307		26,341		24,798
Total	$	149,760	$	118,928	$	30,862	$	28,972

We closely monitor performance of the loans to borrowers experiencing financial difficulty that are modified to understand the effectiveness of the modification efforts. The following table depicts the performance of loans that have been modified during the respective reporting periods (the twelve months ended December 31, 2024 and 2023, respectively).

	Twelve Months Ended December 31, 2024				Twelve Months Ended December 31, 2023
(Dollars in thousands)	Balance		%		Balance		%
Payment Status (Amortized Cost Basis)(1):
Loan modifications in deferment(2)	$	33,645			$	6,843
Loan modifications in repayment:
Loans current(3)(4)	826,007		83	%	334,967		90	%
Loans delinquent 30-59 days(3)(4)	77,446		8	%	17,205		4	%
Loans delinquent 60-89 days(3)(4)	43,484		4	%	7,689		2	%
Loans 90 days or greater past due(3)(4)	54,473		5	%	13,822		4	%
Total loan modifications in repayment	1,001,410		100	%	373,683		100	%
Total Private Education Loan modifications	$	1,035,055			$	380,526

(1)Loans that were both modified and subsequently charged-off during the twelve months ended December 31, 2024 and 2023 are excluded from the table and had an amortized cost basis of $40.4 million and $8.4 million, respectively. Additionally, loans that received a permanent term extension with no interest rate reduction during the fourth quarter of 2023 are excluded from the table.

(2)Deferment includes customers who have returned to school or are engaged in other permitted educational activities and are not yet required to make full principal and interest payments on the loans (e.g., residency periods for medical students or a grace period for bar exam preparation). Deferment also includes loans that have entered a forbearance after the loan modification was granted.

(3)Represents loans in repayment, which include loans that have entered full principal and interest repayment status after any applicable grace period (but, for purposes of the table, do not include those loans while they are in forbearance).

(4)The period of delinquency is based on the number of days scheduled payments are contractually past due.

Private Education Loans Held for Investment - Key Credit Quality Indicators

For Private Education Loans, the key credit quality indicators are FICO scores, the existence of a cosigner, the loan status, and loan seasoning. The FICO scores are assessed at original approval and periodically refreshed/updated through the loan’s term. The following tables highlight the gross principal balance of our Private Education Loan portfolio (held for investment), by year of origination approval/first disbursement, stratified by key credit quality indicators.

As of December 31, 2024 (dollars in thousands)	Private Education Loans Held for Investment - Credit Quality Indicators
Year of Origination Approval	2024(1)		2023(1)		2022(1)		2021(1)		2020(1)		2019 and Prior(1)		Total(1)		% of Balance
Cosigners:
With cosigner	$	4,519,952	$	4,707,685	$	2,741,871	$	1,759,261	$	1,151,751	$	4,642,019	$	19,522,539	88	%
Without cosigner	504,640		613,825		443,376		310,175		222,245		618,208		2,712,469		12
Total	$	5,024,592	$	5,321,510	$	3,185,247	$	2,069,436	$	1,373,996	$	5,260,227	$	22,235,008	100	%
FICO at Origination Approval(2):
Less than 670	$	293,025	$	394,962	$	261,589	$	155,661	$	94,355	$	475,186	$	1,674,778	8	%
670-699	615,617		753,548		449,214		285,181		197,205		898,535		3,199,300		14
700-749	1,525,547		1,641,641		998,834		660,373		451,695		1,782,121		7,060,211		32
Greater than or equal to 750	2,590,403		2,531,359		1,475,610		968,221		630,741		2,104,385		10,300,719		46
Total	$	5,024,592	$	5,321,510	$	3,185,247	$	2,069,436	$	1,373,996	$	5,260,227	$	22,235,008	100	%
FICO Refreshed(2)(3):
Less than 670	$	453,705	$	666,049	$	467,562	$	301,367	$	194,124	$	831,053	$	2,913,860	13	%
670-699	633,749		710,546		409,808		248,325		138,730		578,639		2,719,797		12
700-749	1,485,771		1,512,643		879,450		563,941		362,715		1,398,737		6,203,257		28
Greater than or equal to 750	2,451,367		2,432,272		1,428,427		955,803		678,427		2,451,798		10,398,094		47
Total	$	5,024,592	$	5,321,510	$	3,185,247	$	2,069,436	$	1,373,996	$	5,260,227	$	22,235,008	100	%
Seasoning(4):
1-12 payments	$	2,860,113	$	774,471	$	499,812	$	280,154	$	159,762	$	324,506	$	4,898,818	22	%
13-24 payments	—		2,729,334		372,496		191,989		122,938		340,556		3,757,313		17
25-36 payments	—		—		1,564,157		254,068		110,952		429,127		2,358,304		11
37-48 payments	—		—		—		987,977		170,051		451,494		1,609,522		7
More than 48 payments	—		—		—		—		625,916		3,262,308		3,888,224		17
Not yet in repayment	2,164,479		1,817,705		748,782		355,248		184,377		452,236		5,722,827		26
Total	$	5,024,592	$	5,321,510	$	3,185,247	$	2,069,436	$	1,373,996	$	5,260,227	$	22,235,008	100	%
2024 Current period(5) gross charge-offs	$	(1,826)	$	(29,094)	$	(68,454)	$	(53,697)	$	(37,318)	$	(186,451)	$	(376,840)
2024 Current period(5) recoveries	117		2,191		6,487		5,771		3,840		26,350		44,756
2024 Current period(5) net charge-offs	$	(1,709)	$	(26,903)	$	(61,967)	$	(47,926)	$	(33,478)	$	(160,101)	$	(332,084)
Total accrued interest by origination approval vintage	$	195,291	$	484,531	$	325,962	$	197,504	$	106,565	$	239,562	$	1,549,415
(1)Balance represents gross Private Education Loans held for investment. (2)Represents the higher credit score of the cosigner or the borrower. (3)Represents the FICO score updated as of the fourth-quarter 2024. (4)Number of months in active repayment (whether interest only payment, fixed payment, or full principal and interest payment status) for which a scheduled payment was due. (5)Current period refers to period from January 1, 2024 through December 31, 2024.

As of December 31, 2023 (dollars in thousands)	Private Education Loans Held for Investment - Credit Quality Indicators
Year of Origination Approval	2023(1)		2022(1)		2021(1)		2020(1)		2019(1)		2018 and Prior(1)		Total(1)		% of Balance
Cosigners:
With cosigner	$	3,903,676	$	4,428,163	$	2,516,380	$	1,535,308	$	1,378,699	$	4,529,768	$	18,291,994	87	%
Without cosigner	586,443		660,576		421,042		283,781		253,601		528,407		2,733,850		13
Total	$	4,490,119	$	5,088,739	$	2,937,422	$	1,819,089	$	1,632,300	$	5,058,175	$	21,025,844	100	%
FICO at Origination Approval(2):
Less than 670	$	328,199	$	395,526	$	208,696	$	118,935	$	137,494	$	451,613	$	1,640,463	8	%
670-699	635,642		704,642		400,744		254,762		257,840		868,777		3,122,407		15
700-749	1,383,779		1,586,783		934,033		590,401		545,333		1,709,299		6,749,628		32
Greater than or equal to 750	2,142,499		2,401,788		1,393,949		854,991		691,633		2,028,486		9,513,346		45
Total	$	4,490,119	$	5,088,739	$	2,937,422	$	1,819,089	$	1,632,300	$	5,058,175	$	21,025,844	100	%
FICO Refreshed(2)(3):
Less than 670	$	495,451	$	638,381	$	379,738	$	217,956	$	214,665	$	791,875	$	2,738,066	13	%
670-699	616,684		672,777		365,674		193,462		176,963		564,245		2,589,805		12
700-749	1,347,094		1,477,310		836,747		498,414		445,244		1,361,073		5,965,882		28
Greater than or equal to 750	2,030,890		2,300,271		1,355,263		909,257		795,428		2,340,982		9,732,091		47
Total	$	4,490,119	$	5,088,739	$	2,937,422	$	1,819,089	$	1,632,300	$	5,058,175	$	21,025,844	100	%
Seasoning(4):
1-12 payments	$	2,514,079	$	740,450	$	440,293	$	245,631	$	208,941	$	332,608	$	4,482,002	21	%
13-24 payments	—		2,675,956		303,045		167,532		165,577		384,760		3,696,870		18
25-36 payments	—		—		1,524,834		195,091		129,571		456,448		2,305,944		11
37-48 payments	—		—		—		902,938		208,521		446,350		1,557,809		7
More than 48 payments	—		—		—		116		706,097		2,985,015		3,691,228		18
Not yet in repayment	1,976,040		1,672,333		669,250		307,781		213,593		452,994		5,291,991		25
Total	$	4,490,119	$	5,088,739	$	2,937,422	$	1,819,089	$	1,632,300	$	5,058,175	$	21,025,844	100	%
2023 Current period(5) gross charge-offs	$	(1,812)	$	(31,032)	$	(70,331)	$	(49,624)	$	(50,585)	$	(216,711)	$	(420,095)
2023 Current period(5) recoveries	172		2,342		6,496		4,923		5,260		27,175		46,368
2023 Current period(5) net charge-offs	$	(1,640)	$	(28,690)	$	(63,835)	$	(44,701)	$	(45,325)	$	(189,536)	$	(373,727)
Total accrued interest by origination approval vintage	$	177,959	$	408,800	$	269,978	$	152,094	$	116,618	$	229,116	$	1,354,565
(1)Balance represents gross Private Education Loans held for investment. (2)Represents the higher credit score of the cosigner or the borrower. (3)Represents the FICO score updated as of the fourth-quarter 2023. (4)Number of months in active repayment (whether interest only payment, fixed payment, or full principal and interest payment status) for which a scheduled payment was due. (5)Current period refers to period from January 1, 2023 through December 31, 2023.

Delinquencies - Private Education Loans Held for Investment

The following tables provide information regarding the loan status of our Private Education Loans held for investment, by year of origination approval/first disbursement. Loans in repayment include loans on which borrowers are making interest only or fixed payments, as well as loans that have entered full principal and interest repayment status after any applicable grace period (but, for purposes of the following tables, do not include those loans while they are in forbearance).

	Private Education Loans Held for Investment - Delinquencies by Origination Approval Vintage
As of December 31, 2024 (dollars in thousands)	2024			2023			2022			2021			2020			2019 and Prior			Total
Loans in-school/grace/deferment(1)	$	2,164,479		$	1,817,705		$	748,782		$	355,248		$	184,377		$	452,236		$	5,722,827
Loans in forbearance(2)	19,984			124,728			87,961			52,686			31,575			88,496			405,430
Loans in repayment:
Loans current	2,820,940			3,312,916			2,259,455			1,590,812			1,107,189			4,422,021			15,513,333
Loans delinquent 30-59 days(3)	13,533			36,441			45,543			35,245			27,302			152,684			310,748
Loans delinquent 60-89 days(3)	3,973			15,239			23,359			18,365			10,921			68,878			140,735
Loans 90 days or greater past due(3)	1,683			14,481			20,147			17,080			12,632			75,912			141,935
Total Private Education Loans in repayment	2,840,129			3,379,077			2,348,504			1,661,502			1,158,044			4,719,495			16,106,751
Total Private Education Loans, gross	5,024,592			5,321,510			3,185,247			2,069,436			1,373,996			5,260,227			22,235,008
Private Education Loans deferred origination costs and unamortized premium/(discount)	47,659			25,599			10,788			6,142			4,057			8,825			103,070
Total Private Education Loans	5,072,251			5,347,109			3,196,035			2,075,578			1,378,053			5,269,052			22,338,078
Private Education Loans allowance for losses	(258,235)			(326,207)			(234,532)			(150,324)			(90,600)			(376,022)			(1,435,920)
Private Education Loans, net	$	4,814,016		$	5,020,902		$	2,961,503		$	1,925,254		$	1,287,453		$	4,893,030		$	20,902,158
Percentage of Private Education Loans in repayment	56.5		%	63.5		%	73.7		%	80.3		%	84.3		%	89.7		%	72.4		%
Delinquent Private Education Loans in repayment as a percentage of Private Education Loans in repayment	0.7		%	2.0		%	3.8		%	4.3		%	4.4		%	6.3		%	3.7		%
Loans in forbearance as a percentage of loans in repayment and forbearance	0.7		%	3.6		%	3.6		%	3.1		%	2.7		%	1.8		%	2.5		%

(1)Deferment includes customers who have returned to school or are engaged in other permitted educational activities and are not yet required to make payments on the loans (e.g., residency periods for medical students or a grace period for bar exam preparation).

(2)Loans for customers who have requested extension of grace period generally during employment transition or who have temporarily ceased making full payments due to hardship or other factors, consistent with established loan program servicing policies and procedures.

(3)The period of delinquency is based on the number of days scheduled payments are contractually past due.

	Private Education Loans Held for Investment - Delinquencies by Origination Approval Vintage
As of December 31, 2023 (dollars in thousands)	2023			2022			2021			2020			2019			2018 and Prior			Total
Loans in-school/grace/deferment(1)	$	1,976,040		$	1,672,333		$	669,250		$	307,781		$	213,593		$	452,994		$	5,291,991
Loans in forbearance(2)	19,265			93,079			58,438			35,450			31,818			85,989			324,039
Loans in repayment:
Loans current	2,469,817			3,254,534			2,131,040			1,416,069			1,323,825			4,213,986			14,809,271
Loans delinquent 30-59 days(3)	17,599			34,627			37,147			28,020			31,432			149,926			298,751
Loans delinquent 60-89 days(3)	5,720			17,227			20,077			16,614			15,482			75,897			151,017
Loans 90 days or greater past due(3)	1,678			16,939			21,470			15,155			16,150			79,383			150,775
Total Private Education Loans in repayment	2,494,814			3,323,327			2,209,734			1,475,858			1,386,889			4,519,192			15,409,814
Total Private Education Loans, gross	4,490,119			5,088,739			2,937,422			1,819,089			1,632,300			5,058,175			21,025,844
Private Education Loans deferred origination costs and unamortized premium/(discount)	35,616			18,556			9,465			5,809			3,556			8,552			81,554
Total Private Education Loans	4,525,735			5,107,295			2,946,887			1,824,898			1,635,856			5,066,727			21,107,398
Private Education Loans allowance for losses	(269,642)			(335,090)			(194,104)			(118,755)			(100,111)			(317,403)			(1,335,105)
Private Education Loans, net	$	4,256,093		$	4,772,205		$	2,752,783		$	1,706,143		$	1,535,745		$	4,749,324		$	19,772,293
Percentage of Private Education Loans in repayment	55.6		%	65.3		%	75.2		%	81.1		%	85.0		%	89.3		%	73.3		%
Delinquent Private Education Loans in repayment as a percentage of Private Education Loans in repayment	1.0		%	2.1		%	3.6		%	4.1		%	4.5		%	6.8		%	3.9		%
Loans in forbearance as a percentage of loans in repayment and forbearance	0.8		%	2.7		%	2.6		%	2.3		%	2.2		%	1.9		%	2.1		%

(1)Deferment includes customers who have returned to school or are engaged in other permitted educational activities and are not yet required to make payments on the loans (e.g., residency periods for medical students or a grace period for bar exam preparation).

(2)Loans for customers who have requested extension of grace period generally during employment transition or who have temporarily ceased making full payments due to hardship or other factors, consistent with established loan program servicing policies and procedures.

(3)The period of delinquency is based on the number of days scheduled payments are contractually past due.

	Private Education Loans Held for Investment - Delinquencies by Origination Approval Vintage
As of December 31, 2022 (dollars in thousands)	2022			2021			2020			2019			2018			2017 and Prior			Total
Loans in-school/grace/deferment(1)	$	1,827,649		$	1,433,322		$	578,253		$	380,639		$	219,280		$	455,910		$	4,895,053
Loans in forbearance(2)	16,046			64,360			38,613			37,802			30,583			91,681			279,085
Loans in repayment:
Loans current	2,411,441			2,991,839			1,907,574			1,683,986			1,301,809			4,262,698			14,559,347
Loans delinquent 30-59 days(3)	14,164			30,740			30,877			35,213			31,366			144,948			287,308
Loans delinquent 60-89 days(3)	5,523			15,056			14,433			18,201			16,697			77,595			147,505
Loans 90 days or greater past due(3)	1,710			11,842			14,872			16,819			16,107			74,040			135,390
Total Private Education Loans in repayment	2,432,838			3,049,477			1,967,756			1,754,219			1,365,979			4,559,281			15,129,550
Total Private Education Loans, gross	4,276,533			4,547,159			2,584,622			2,172,660			1,615,842			5,106,872			20,303,688
Private Education Loans deferred origination costs and unamortized premium/(discount)	26,714			15,933			9,062			5,496			3,575			8,876			69,656
Total Private Education Loans	4,303,247			4,563,092			2,593,684			2,178,156			1,619,417			5,115,748			20,373,344
Private Education Loans allowance for losses	(304,943)			(323,506)			(181,915)			(141,424)			(101,023)			(300,820)			(1,353,631)
Private Education Loans, net	$	3,998,304		$	4,239,586		$	2,411,769		$	2,036,732		$	1,518,394		$	4,814,928		$	19,019,713
Percentage of Private Education Loans in repayment	56.9		%	67.1		%	76.1		%	80.7		%	84.5		%	89.3		%	74.5		%
Delinquent Private Education Loans in repayment as a percentage of Private Education Loans in repayment	0.9		%	1.9		%	3.1		%	4.0		%	4.7		%	6.5		%	3.8		%
Loans in forbearance as a percentage of loans in repayment and forbearance	0.7		%	2.1		%	1.9		%	2.1		%	2.2		%	2.0		%	1.8		%

(1)Deferment includes customers who have returned to school or are engaged in other permitted educational activities and are not yet required to make payments on the loans (e.g., residency periods for medical students or a grace period for bar exam preparation).

(2)Loans for customers who have requested extension of grace period generally during employment transition or who have temporarily ceased making full payments due to hardship or other factors, consistent with established loan program servicing policies and procedures.

(3)The period of delinquency is based on the number of days scheduled payments are contractually past due.

Accrued Interest Receivable

The following table provides information regarding accrued interest receivable on our Private Education Loans. The table also discloses the amount of accrued interest on loans 90 days or greater past due as compared to our allowance for uncollectible interest. The majority of the total accrued interest receivable represents accrued interest on deferred loans where no payments are due while the borrower is in school and fixed-pay loans where the borrower makes a $25 monthly payment that is smaller than the interest accruing on the loan in that month. The accrued interest on these loans will be capitalized to the balance of the loans when the borrower exits the grace period after separation from school. The allowance for credit losses considers the collectibility of both principal and accrued interest. The allowance for uncollectible interest estimates the additional uncollectible interest that is not captured in the allowance for credit losses. See Note 2, “Significant Accounting Policies — Allowance for Credit Losses — Uncollectible Interest” in this Form 10-K for additional information.

	Private Education Loans
	Accrued Interest Receivable
(Dollars in thousands)	Total Interest Receivable		90 Days or Greater Past Due		Allowance for Uncollectible Interest(1)
December 31, 2024	$	1,549,415	$	6,420	$	12,366
December 31, 2023	$	1,354,565	$	8,373	$	9,897

(1) At December 31, 2024 and 2023, $164 million and $151 million, respectively, of accrued interest receivable was not expected to be capitalized and $1.4 billion and $1.2 billion of accrued interest receivable was expected to be capitalized.

Unfunded Loan Commitments

When we approve a Private Education Loan at the beginning of an academic year, that approval may cover the borrowing for the entire academic year. As such, we do not always disburse the full amount of the loan at the time of such approval, but instead have a commitment to fund a portion of the loan at a later date (usually at the start of the second semester or subsequent trimesters). We estimate expected credit losses over the contractual period in which we are exposed to credit risk via a contractual obligation to extend credit, unless that obligation is unconditionally cancellable by us. See Note 2, “Significant Accounting Policies — Allowance for Credit Losses — Off-Balance Sheet Exposure for Contractual Loan Commitments” in this Form 10-K for additional information.

At December 31, 2024, we had $2.3 billion of outstanding contractual loan commitments that we expect to fund during the remainder of the 2024/2025 academic year. The tables below summarize the activity in the allowance recorded to cover lifetime expected credit losses on the unfunded commitments, which is recorded in “Other Liabilities” on the consolidated balance sheets, as well as the activity in the unfunded commitments balance.

Years Ended December 31, (dollars in thousands)	2024				2023				2022
	Allowance		Unfunded Commitments		Allowance		Unfunded Commitments		Allowance		Unfunded Commitments
Beginning Balance	$	112,962	$	2,221,077	$	124,924	$	1,995,808	$	72,713	$	1,776,976
Provision/New commitments - net(1)	283,393		7,103,832		308,275		6,602,803		396,521		6,180,805
Transfer - funded loans(2)	(311,787)		(7,013,249)		(320,237)		(6,377,534)		(344,310)		(5,961,973)
Ending Balance	$	84,568	$	2,311,660	$	112,962	$	2,221,077	$	124,924	$	1,995,808

(1)  Net of expirations of commitments unused. Also includes incremental provision for new commitments and changes to provision for existing commitments.

(2)  When a loan commitment is funded, its related liability for credit losses (which originally was recorded as a provision for unfunded commitments) is transferred to the allowance for credit losses.

The unfunded commitments disclosed above represent the total amount of outstanding unfunded commitments at each period end. However, historically not all of these commitments are funded prior to the expiration of the commitments.

We estimate the amount of commitments expected to be funded in calculating the reserve for unfunded commitments. The amount we expect to fund and use in our calculation of the reserve for unfunded commitments will change period to period based upon the loan characteristics of the underlying commitments.