EX-99.1 2 a20-11966_1ex99d1.htm EX-99.1

Exhibit 99.1

 

 

 

 

 

Independent Accountants’ Report on Applying Agreed-Upon Procedures

 

 

ECMC Group, Inc. (the “Company”)

J.P. Morgan Securities LLC (“J.P. Morgan”)

(together, the “Specified Parties”)

 

Re: ECMC Group Student Loan Trust 2020-1 – Data File Procedures

 

We have performed the procedures described below, which were agreed to by the Specified Parties, on the specified attributes identified by the Company in an electronic data file entitled “ECMC 2020-1 Loan Tape 20200131.xlsx” (the “Data File”), provided by the Company on February 6, 2020, containing certain information on 60,591 student loans (the “Student Loans”) as of January 31, 2020 (the “Cutoff Date”), which we were informed are intended to be included as collateral in the offering by ECMC Group Student Loan Trust 2020-1. The Company is responsible for the specified attributes identified by the Company in the Data File. The sufficiency of these procedures is solely the responsibility of the Specified Parties. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose.

 

Unless otherwise indicated, the following definitions have been adopted in presenting our procedures and findings:

 

·                  The term “compared” means compared to the information shown and found it to be in agreement, unless otherwise noted. Such compared information was deemed to be in agreement if differences were attributable to materiality threshold.

 

·                  The term “recomputed” means recalculated and compared the result to the information shown and found it to be in agreement, unless otherwise noted. Such recomputed information was deemed to be in agreement if differences were attributable to materiality threshold.

 

·                  The term “materiality threshold” means that dollar amounts and percentages were within $1.00 and 0.1%, respectively.

 

·                  The term “CLASS System” means Navient Solutions, LLC’s (“Navient’s”) servicing system for student loans serviced by Navient.

 

·                  The term “GUARANTEE System” means the Company’s servicing system.

 

·                  The term “ECMC Lookup Code Document” means a document provided by the Company containing code definitions related to Loan Type, Loan Status, and School Type attached hereto as Exhibit B.

 

·                  The term “ECMC Interest Rate Document” means a document provided by the Company containing interest rate calculation information issued by the U.S. Department of Education dated June 26, 2019, attached hereto as Exhibit C.

 

 

 

 

 

 

 

 

 

 

 

 

 

 


 

 

·                  The term “Loan File” means any file containing some or all of the following documents for each of the Selected Student Loans (defined below): #111 ACCT BALANCE Screen, #128 BORROWER CRITICAL DATA UPDATE Screen, #133 MONETARY HISTORY Screen, #135 EFFECTIVE STATUS HISTORY Screen, #151 BORROWER CORRESPONDENCE HISTORY Screen, and #155 CRITICAL CHANGES DETAIL HISTORY Screen within the CLASS System, and Loan Overview and Disbursements Screen, NSLDS Screen and ECMC SQL Query Screen within the GUARANTEE System, ECMC Lookup Code Document, and ECMC Interest Rate Document. The Company represented that the Loan File was either the original Loan File, a copy of the original Loan File, or a copy of electronic records contained within the GUARANTEE System or the CLASS System. We make no representation regarding the validity, enforceability, or authenticity of any information in the Loan Files.

 

I.                The Selected Student Loans

 

The Company instructed us to select a random sample of 100 Student Loans from the Data File. The resulting 100 selected Student Loans constitutes the “Selected Student Loans,” attached hereto as Exhibit A. For purposes of this procedure, the Company did not inform us as to the basis for how they determined the number of Student Loans we were instructed to randomly select from the Data File.

 

II.             The Data File

 

For each Selected Student Loan, we compared the specified attributes listed below contained in the Data File to the corresponding information appearing in the respective Loan File. The Specified Parties indicated that the absence of any of the noted documents or the inability to agree the indicated information from Data File to the information contained in the Loan Files, utilizing instructions provided by the Company (as applicable) indicated below, for each of the attributes identified, constituted an exception. Where applicable, the Loan File documents are listed in the order of priority until such attribute was agreed.

 

Attribute

 

Loan File / Instructions

 

 

 

Origination Date

 

“FIRST DISB DATE” field on the #128 BORROWER CRITICAL DATA UPDATE Screen within the CLASS System.

 

In the event the date in the “FIRST DISB DATE” field on the #128 BORROWER CRITICAL DATA UPDATE Screen did not agree with the Origination Date in the Data File, we were instructed by the Company to compare the origination date in the “tbl_load_dt” field on the ECMC SQL Query Screen within the GUARANTEE System to the Origination Date in the Data File.

 

 

 

Loan Type

 

“PROG,” “PRIN SUB,” and “PRIN NSUB” fields on #111 ACCT BALANCE Screen within the CLASS System and the ECMC Lookup Code Document.

We were instructed by the Company to compare the “PROG,” “PRIN SUB,” and “PRIN NSUB” fields on the #111 ACCT BALANCE Screen to the corresponding Loan Type Description on the ECMC Lookup Code Document.

 

If the amount in the “PRIN SUB” field was greater than $0.00, the loan was considered to be subsidized, and if the amount in the “PRIN NSUB” field was greater than $0.00, the loan was considered to be non-subsidized.

 

The Company further instructed us to compare the resulting Loan Type (subsidized or non-subsidized) to the Loan Type in the Data File.

 

2


 

 

Attribute

 

Loan File / Instructions

 

 

 

 

 

In the event the resulting Loan Type (subsidized or non-subsidized) did not agree with the Loan Type in the Data File, we were instructed by the Company to compare the loan type in the “Loan Type” field on the Loan Overview and Disbursement Screen within the GUARANTEE System to the Loan Type in the Data File.

 

 

 

Interest Rate Type

 

ECMC Interest Rate Document. We were instructed by the Company to (i) locate the corresponding interest rate chart in the ECMC Interest Rate Document using the Loan Type information in the Data File, and (ii) identify if the First Disbursement Date in the Data File was included in the “First Disbursement Made on or After” or “First Disbursement Made Before” fields (the “First Disbursement Date Range”) in the ECMC Interest Rate Document.

 

If the First Disbursement Date was included in the First Disbursement Data Range, the Company instructed us to deem the Interest Rate Type to be “Floating,” and if the First Disbursement Date was not included in the First Disbursement Date Range, to deem the Interest Rate Type to be “Fixed.”

 

The Company further instructed us to compare the resulting Interest Rate Type (i.e., Fixed or Floating) to the Fixed/Floating field in the Data File.

 

 

 

Current Statutory Borrower Interest Rate

 

“INT RATE” field on #111 ACCT BALANCE Screen within the CLASS System and ECMC Interest Rate Document.

 

For Selected Student Loans that are fixed rate(identified as “Fixed” in the Fixed/Floating field in the Data File), the Company instructed us to compare the Current Statutory Borrower Interest Rate in the Data File to the “INT RATE” field on the #111 ACCT BALANCE Screen.

 

For Selected Student Loans that are variable rate (identified as “Floating” in the Fixed/Floating field in the Data File), the Company instructed us to (i) locate the corresponding interest rate chart in the ECMC Interest Rate Document using the Loan Type information in the Data File, (ii) compare the First Disbursement Date in the Data File to the First Disbursement Date Range, and (iii) compare the corresponding interest rate in the “Interest Rate For the Period 7/1/2019-6/30/2020” column in the ECMC Interest Rate Document to the Current Statutory Borrower Interest Rate in the Data File.

 

In the event the “INT RATE” field on the #111 ACCT BALANCE Screen did not agree with the Current Statutory Borrower Interest Rate amount in the Data File, we were instructed by the Company to compare the updated interest rate amount noted in the “MESSAGE” field on the #151 BORROWER CORRESPONDENCE HISTORY Screen within the CLASS System to the Current Statutory Borrower Interest Rate in the Data File.

 

 

 

Current Loan Balance

 

“AMT OUT” field on #111 ACCT BALANCE Screen within the CLASS System.

 

3


 

 

Attribute

 

Loan File / Instructions

 

 

 

 

 

In the event the AMT OUT amount on the #111 ACCT BALANCE Screen did not agree with the Current Loan Balance in the Data File, we were instructed by the Company to compare the latest loan balance before the Cutoff Date in the “PRINCIPAL” field on the #133 MONETARY HISTORY Screen within the CLASS System to the Current Loan Balance in the Data File.

 

In the event the latest loan balance before the Cutoff Date in the “PRINCIPAL” field on the #133 MONETARY HISTORY Screen within the CLASS System did not agree with the Current Loan Balance in the Data File, the Company instructed us to (i) add the principal payment amounts after the Cutoff Date in the “PRINCIPAL” field or subtract capitalized interest after the Cutoff Date in the “PRINCIPAL” field with a transaction code of 980 on the #133 MONETARY HISTORY Screen to the AMT OUT amount on the #111 ACCT BALANCE Screen and (ii) compare the resulting sum to the Current Loan Balance in the Data File.

 

 

 

Remaining Term (Recomputed Remaining Term)

 

“ANTICPD PIF DT” field on #111 ACCT BALANCE Screen within the CLASS System.

 

We were instructed by the Company to recompute the Remaining Term (the “Recomputed Remaining Term”) by counting the number of payments between the Cutoff Date and the “ANTICPD PIF DT” field on the #111 ACCT BALANCE Screen. The Company further instructed us to compare the Recomputed Remaining Term to the Remaining Term in the Data File.

 

 

 

First Disbursement Date

 

“FIRST DISB DATE” field on #128 BORROWER CRITICAL DATA UPDATE Screen within the CLASS System.

 

In the event the date in the “FIRST DISB DATE” field on the #128 BORROWER CRITICAL DATA UPDATE Screen did not agree with the First Disbursement Date in the Data File, we were instructed by the Company to compare the first disbursement date in the “tbl_load_dt” field on the ECMC SQL Query Screen within the GUARANTEE System to the First Disbursement Date in the Data File.

 

 

 

Loan Status

 

“STATUS” field on #111 ACCT BALANCE Screen within the CLASS System, “STAT” field on #135 EFFECTIVE STATUS HISTORY Screen within the CLASS System, and ECMC Lookup Code Document.

 

We were instructed by the Company to compare the “STATUS” field on the #111 ACCT BALANCE Screen to the corresponding Loan Status Description on the ECMC Lookup Code Document. The Company further instructed us to compare the Loan Status Description stated on the ECMC Lookup Code Document to the Loan Status in the Data File.

 

In the event the Loan Status Description on the ECMC Lookup Code Document did not agree with the Loan Status in the Data File, we were instructed by the Company to use the latest loan status change information before the Cutoff Date in the “STAT” field on the #135 EFFECTIVE STATUS HISTORY Screen and identify the

 

4


 

 

Attribute

 

Loan File / Instructions

 

 

 

 

 

corresponding Loan Status Description in the ECMC Lookup Code Document. The Company further instructed us to compare the identified Loan Status Description stated on the ECMC Lookup Code Document to the Loan Status in the Data File.

 

In the event the Loan Status description on the ECMC Lookup Code Document did not agree with the Loan Status in the Data File, the Company instructed us to compare the loan status in the “status_1” field on the ECMC SQL Query Screen within the GURANTEE System to the Loan Status in the Data File. In the event the “status_1” field on the ECMC SQL Query Screen did not agree with the Loan Status in the Data File, we were instructed by the Company to compare the “Loan Status” field in the Loan Overview and Disbursements Screen within the GUARANTEE System to the Loan Status in the Data File.

 

 

 

School Type

 

“SCHOOL” field on #111 ACCT BALANCE Screen within the CLASS System, Loan Overview and Disbursements Screen within the GUARANTEE System, and the ECMC Lookup Code Document.

 

We were instructed by the Company to compare the School ID in the “SCHOOL” field on the #111 ACCT BALANCE Screen to the “School ID” field in the ECMC Lookup Code Document. We were further instructed by the Company to utilize the “School ID” in the ECMC Lookup Code Document to locate the corresponding School Type under the “Loan Tape School Type” field in the ECMC Lookup Code Document.

 

We were then instructed to compare the resulting School Type to the School Type in the Data File. If the School Type in the Data File was “2-Year Public/Private” or “4-Year Public,” we were instructed by the Company to consider the School Type as “2-Year” and “4-Year,” respectively.

 

In the event the School Type in the “Loan Tape School Type” field in the ECMC Lookup Code Document did not agree with the School Type in the Data File, we were instructed by the Company to compare the School ID in the “Original School” field on the Loan Overview and Disbursements Screen to the “School ID” field in the ECMC Lookup Code Document.

 

We were further instructed by the Company to utilize the “School ID” in the ECMC Lookup Code Document to locate the corresponding School Type under the “Loan Tape School Type” field in the ECMC Lookup Code Document. We were then instructed to compare the resulting School Type to the School Type in the Data File.

 

We were instructed by the Company to consider the School Type to be “Consolidation” if the “PG” field on the #111 ACCT BALANCE Screen was “SM.”

 

 

 

First Repayment Date

 

“RPMT BEG DT” field on #111 ACCT BALANCE Screen within the CLASS System.

 

5


 

 

Attribute

 

Loan File / Instructions

 

 

 

 

 

In the event the RPMT BEG DT did not agree with the First Repayment Date in the Data File, we were instructed by the Company to compare the “Date Entered Repayment” field on the NSLDS Screen within the GUARANTEE System to the First Repayment Date in the Data File.

 

 

 

Last Payment Date

 

“LAST BR PMT RECVD” field on #111 ACCT BALANCE Screen within CLASS System.

 

We were instructed by the Company to consider Last Payment Date to be not applicable (identified as “blank” in the “LAST_PAYMENT_DATE” field in the Data File) if the “LAST BR PMT RECVD” field on the #111 ACCT BALANCE Screen was zero.

 

In the event the Last Payment Date in the “LAST BR PMT RECVD” field did not agree with the Last Payment Date in the Data File, we were instructed by the Company to compare the Last Payment Date on or before the Cutoff Date in the “TRAN EFF DATE” field on the #133 MONETARY HISTORY Screen within CLASS System to the Last Payment Date in the Data File.

 

 

 

Anticipated Payoff Date

 

“ANTICPD PIF DT” field on #111 ACCT BALANCE Screen within CLASS System and ECMC SQL Query Screen within the GURANTEE System.

 

In the event the date in the “ANTICPD PIF DT” field did not agree with the Anticipated Payoff Date in the Data File, we were instructed by the Company to compare the payoff date on or before the Cutoff Date in the “antic_payoff_dt” field on the ECMC SQL Query Screen to the Anticipated Payoff Date in the Data File.

 

 

 

Guarantor

 

“GUAR” field on #111 ACCT BALANCE Screen within the CLASS System

 

 

 

State

 

“ST” field on #111 ACCT BALANCE Screen within the CLASS System.

 

In the event the State in the “ST” field did not agree with the State in the Data File, we were instructed by the Company to compare the state on or before the Cutoff Date in the “CRITICAL CHANGE-PREVIOUS VALUE” field on the #155 CRITICAL CHANGES DETAIL HISTORY Screen within CLASS System to the State in the Data File.

 

 

 

Subsidy Indicator

 

“PRIN SUB” and “PRIN NSUB” fields on #111 ACCT BALANCE Screen within the CLASS System.

 

We were instructed by the Company to consider the loan to be subsidized if the “PRIN SUB” field on the #111 ACCT BALANCE Screen was greater than $0.00, and non-subsidized if the “PRIN NSUB” field on the #111 ACCT BALANCE Screen was greater than $0.00.

 

The information regarding the Selected Student Loans was found to be in agreement with the respective information contained in the Loan Files. There were no conclusions that resulted from the procedures.

 

6


 

 

This agreed-upon procedures engagement was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants. We were not engaged to, and did not, conduct an examination or review, the objective of which would be the expression of an opinion or conclusion, respectively, on the specified attributes identified by the Company in the Data File. Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to the Specified Parties.

 

The procedures performed were applied based on the information indicated in the Data File and the Loan Files, recomputation methodologies, and instructions provided by the Company, without verification or evaluation of such information or instructions by us; therefore, we express no opinion or any other form of assurance regarding (i) the physical existence of the Student Loans, (ii) the reasonableness of the information and instructions provided by the Company, (iii) the reliability or accuracy of the Loan Files which were used in our procedures, or (iv) matters of legal interpretation.

 

The procedures performed were not intended to address, nor did they address: (i) the conformity of the origination of the Student Loans to stated underwriting or credit extension guidelines, standards, criteria or other requirements, (ii) the value of collateral securing any such Student Loans being securitized, (iii) the compliance of the originator of the Student Loans with federal, state, and local laws and regulations, or (iv) any other factor or characteristic of the student loans that would be material to the likelihood that the issuer of the asset-backed security will pay interest and principal in accordance with applicable terms and conditions. The procedures performed were not intended to satisfy any criteria for due diligence published by a nationally recognized statistical rating organization (“NRSRO”).

 

The terms of our engagement are such that we have no obligation to update this report because of events and transactions that may subsequently occur.

 

This report is intended solely for the information and use of the Specified Parties and is not intended to be and should not be used by any other person or entity, including investors and NRSRO’s, who are not identified in this report as Specified Parties but who may have access to this report as required by law or regulation.

 

 

 

 

/s/ KPMG LLP

 

 

Irvine, California

March 4, 2020

 

7


 

Exhibit A

 

 

 

 

The Selected Student Loans

 

Selected
Student
Loan
Number

 

Student
Loan ID
Number

 

Selected
Student
Loan
Number

 

Student
Loan ID
Number

 

Selected
Student
Loan
Number

 

Student
Loan ID
Number

 

Selected
Student
Loan
Number

 

Student
Loan ID
Number

1

 

20201001

 

26

 

20201026

 

51

 

20201051

 

76

 

20201076

2

 

20201002

 

27

 

20201027

 

52

 

20201052

 

77

 

20201077

3

 

20201003

 

28

 

20201028

 

53

 

20201053

 

78

 

20201078

4

 

20201004

 

29

 

20201029

 

54

 

20201054

 

79

 

20201079

5

 

20201005

 

30

 

20201030

 

55

 

20201055

 

80

 

20201080

6

 

20201006

 

31

 

20201031

 

56

 

20201056

 

81

 

20201081

7

 

20201007

 

32

 

20201032

 

57

 

20201057

 

82

 

20201082

8

 

20201008

 

33

 

20201033

 

58

 

20201058

 

83

 

20201083

9

 

20201009

 

34

 

20201034

 

59

 

20201059

 

84

 

20201084

10

 

20201010

 

35

 

20201035

 

60

 

20201060

 

85

 

20201085

11

 

20201011

 

36

 

20201036

 

61

 

20201061

 

86

 

20201086

12

 

20201012

 

37

 

20201037

 

62

 

20201062

 

87

 

20201087

13

 

20201013

 

38

 

20201038

 

63

 

20201063

 

88

 

20201088

14

 

20201014

 

39

 

20201039

 

64

 

20201064

 

89

 

20201089

15

 

20201015

 

40

 

20201040

 

65

 

20201065

 

90

 

20201090

16

 

20201016

 

41

 

20201041

 

66

 

20201066

 

91

 

20201091

17

 

20201017

 

42

 

20201042

 

67

 

20201067

 

92

 

20201092

18

 

20201018

 

43

 

20201043

 

68

 

20201068

 

93

 

20201093

19

 

20201019

 

44

 

20201044

 

69

 

20201069

 

94

 

20201094

20

 

20201020

 

45

 

20201045

 

70

 

20201070

 

95

 

20201095

21

 

20201021

 

46

 

20201046

 

71

 

20201071

 

96

 

20201096

22

 

20201022

 

47

 

20201047

 

72

 

20201072

 

97

 

20201097

23

 

20201023

 

48

 

20201048

 

73

 

20201073

 

98

 

20201098

24

 

20201024

 

49

 

20201049

 

74

 

20201074

 

99

 

20201099

25

 

20201025

 

50

 

20201050

 

75

 

20201075

 

100

 

20201100

 

 

 

 

 

 

Note: The Company has assigned a unique identifier to each Selected Student Loan. The Student Loan ID Numbers referred to in this Exhibit are not the Customer Account Numbers.

 


 

Exhibit B

 

 

 

ECMC Lookup Code Document

 

Loan Type

 

Loan Type

Sub Indicator

Description

Loan Type
per Data File

Subsidy
Indicator

GB

N

Grad PLUS Loan

GB

N

GS

N

Unsubsidized Stafford Loan

SU

N

GS

S

Subsidized Stafford

SF

Y

PL

N

PLUS Loan

PL

N

SL

N

SLS Loan

SL

N

SM

N

Unsubsidized Consolidation

CL

N

SM

S

Subsidized Consolidation

CL

Y

 

 

Loan Status

 

Loan Status Code

Description

DHAR

Deferment

DMLT

Deferment

DSCH

Deferment

DSUM

Deferment

DUEM

Deferment

FORA

Forbearance

FORB

Forbearance

FORD

Forbearance

FORM

Forbearance

FORV

Forbearance

FRAB

Forbearance

FRAT

Forbearance

PCNX

Paid In Full - Refunded

PCON

Paid In Full By Consolidated

PIFB

Paid In Full By Borrower

PIFG

Paid In Full By Guarantor

PRES

Paid In Full - Resale

PTRN

Paid In Full - Servicer Transfer

RPMT

Repayment

 


 

Exhibit B

 

 

 

School Type

 

School
ID

School Name

Navient
School Type

Loan Tape
School Type

000000

CLAIMS PROCESSING SCHOOL

2

2-Year

000000

CLAIMS PROCESSING SCHOOL

4

4-Year

000000

CLAIMS PROCESSING SCHOOL

T

Proprietary

000000

CLAIMS PROCESSING SCHOOL

NULL

Consolidation

021715

WESTERN INTERNATIONAL UNIVERSITY

2

2-Year

021715

WESTERN INTERNATIONAL UNIVERSITY

4

4-Year

021715

WESTERN INTERNATIONAL UNIVERSITY

T

Proprietary

021715

WESTERN INTERNATIONAL UNIVERSITY

NULL

Consolidation

004586

PURDUE UNIVERSITY GLOBAL

2

2-Year

004586

PURDUE UNIVERSITY GLOBAL

4

4-Year

004586

PURDUE UNIVERSITY GLOBAL

T

Proprietary

004586

PURDUE UNIVERSITY GLOBAL

NULL

Consolidation

011145

NORTH HARRIS COUNTY COLLEGE

2

2-Year

011145

NORTH HARRIS COUNTY COLLEGE

4

4-Year

011145

NORTH HARRIS COUNTY COLLEGE

T

Proprietary

011145

NORTH HARRIS COUNTY COLLEGE

NULL

Consolidation

001107

SOUTHERN ARKANSAS UNIVERSITY

2

2-Year

001107

SOUTHERN ARKANSAS UNIVERSITY

NULL

Consolidation

001107

SOUTHERN ARKANSAS UNIVERSITY

4

4-Year

025693

LE CORDON BLEU COLLEGE OF CULINARY ARTS

NULL

Consolidation

025693

LE CORDON BLEU COLLEGE OF CULINARY ARTS

2

2-Year

003530

UNIVERSITY OF TENNESSEE-KNOXVILLE

2

2-Year

003530

UNIVERSITY OF TENNESSEE-KNOXVILLE

4

4-Year

003530

UNIVERSITY OF TENNESSEE-KNOXVILLE

T

Proprietary

003530

UNIVERSITY OF TENNESSEE-KNOXVILLE

NULL

Consolidation

020988

UNIVERSITY OF PHOENIX

2

2-Year

020988

UNIVERSITY OF PHOENIX

4

4-Year

020988

UNIVERSITY OF PHOENIX

T

Proprietary

020988

UNIVERSITY OF PHOENIX

NULL

Consolidation

010854

THOMAS JEFFERSON SCHOOL OF LAW

4

4-Year

010854

THOMAS JEFFERSON SCHOOL OF LAW

NULL

Consolidation

003213

PORTLAND COMMUNITY COLLEGE

2

2-Year

003213

PORTLAND COMMUNITY COLLEGE

4

4-Year

003213

PORTLAND COMMUNITY COLLEGE

T

Proprietary

003213

PORTLAND COMMUNITY COLLEGE

NULL

Consolidation

004490

PATTEN UNIVERSITY

2

2-Year

004490

PATTEN UNIVERSITY

4

4-Year

001153

CALIF STATE U NORTHRIDGE

2

2-Year

001153

CALIF STATE U NORTHRIDGE

4

4-Year

001153

CALIF STATE U NORTHRIDGE

T

Proprietary

001153

CALIF STATE U NORTHRIDGE

NULL

Consolidation

001459

STRAYER UNIVERSITY

2

2-Year

001459

STRAYER UNIVERSITY

4

4-Year

001459

STRAYER UNIVERSITY

T

Proprietary

001459

STRAYER UNIVERSITY

NULL

Consolidation

011941

AMERICAN UNIVERSITY OF PUERTO RICO

4

4-Year

011941

AMERICAN UNIVERSITY OF PUERTO RICO

T

Proprietary

002402

COPIAH-LINCOLN JUNIOR COLLEGE

2

2-Year

002402

COPIAH-LINCOLN JUNIOR COLLEGE

4

4-Year

001241

MONTEREY INST OF INTERNAT’L STUDIES

4

4-Year

001072

COCHISE COLLEGE

2

2-Year

001072

COCHISE COLLEGE

4

4-Year

011649

LOYOLA MARYMOUNT UNIV

2

2-Year

011649

LOYOLA MARYMOUNT UNIV

4

4-Year

011649

LOYOLA MARYMOUNT UNIV

NULL

Consolidation

 


 

Exhibit B

 

 

 

School
ID

School Name

Navient
School Type

Loan Tape
School Type

022613

NATIONAL INSTITUTE OF TECHNOLOGY 3

2

2-Year

022613

NATIONAL INSTITUTE OF TECHNOLOGY 3

T

Proprietary

022613

NATIONAL INSTITUTE OF TECHNOLOGY 3

NULL

Consolidation

001139

CA STATE UNIVERSITY, LONG BEACH

2

2-Year

001139

CA STATE UNIVERSITY, LONG BEACH

4

4-Year

001139

CA STATE UNIVERSITY, LONG BEACH

NULL

Consolidation

001380

WESTERN CONNECTICUT STATE COLLEGE

2

2-Year

001380

WESTERN CONNECTICUT STATE COLLEGE

4

4-Year

001380

WESTERN CONNECTICUT STATE COLLEGE

NULL

Consolidation

999999

NSLDS DEFAULT SCHOOL

2

2-Year

999999

NSLDS DEFAULT SCHOOL

4

4-Year

999999

NSLDS DEFAULT SCHOOL

T

Proprietary

999999

NSLDS DEFAULT SCHOOL

NULL

Consolidation

002748

LE MOYNE COLLEGE

2

2-Year

002748

LE MOYNE COLLEGE

4

4-Year

002748

LE MOYNE COLLEGE

NULL

Consolidation

006951

UNIVERSITY OF SOUTH CAROLINA UPSTATE

2

2-Year

006951

UNIVERSITY OF SOUTH CAROLINA UPSTATE

4

4-Year

006951

UNIVERSITY OF SOUTH CAROLINA UPSTATE

NULL

Consolidation

011031

TECHNICAL CAREER INSTITUTES

2

2-Year

011031

TECHNICAL CAREER INSTITUTES

4

4-Year

011031

TECHNICAL CAREER INSTITUTES

T

Proprietary

012427

ERIE COMMUNITY COLLEGE SOUTH CAMPU

2

2-Year

012427

ERIE COMMUNITY COLLEGE SOUTH CAMPU

4

4-Year

031277

SOUTHERN NEW ENGLAND SCHOOL OF LAW

4

4-Year

031277

SOUTHERN NEW ENGLAND SCHOOL OF LAW

NULL

Consolidation

009466

KAPLAN CAREER INSTITUTE

2

2-Year

024973

MILAN INSTITUTE

2

2-Year

024973

MILAN INSTITUTE

4

4-Year

024973

MILAN INSTITUTE

T

Proprietary

024973

MILAN INSTITUTE

NULL

Consolidation

023512

IMAGE MAKERS BEAUTY ACADEMY

T

Proprietary

002838

SUNY AT STONY BROOK

2

2-Year

002838

SUNY AT STONY BROOK

4

4-Year

002838

SUNY AT STONY BROOK

T

Proprietary

002838

SUNY AT STONY BROOK

NULL

Consolidation

002129

BOSTON CONSERVATORY

4

4-Year

035424

COPPER MOUNTAIN COLLEGE

2

2-Year

035424

COPPER MOUNTAIN COLLEGE

NULL

Consolidation

003702

AVERETT UNIVERSITY

2

2-Year

003702

AVERETT UNIVERSITY

4

4-Year

003702

AVERETT UNIVERSITY

T

Proprietary

003702

AVERETT UNIVERSITY

NULL

Consolidation

002064

COLLEGE OF SOUTHERN MARYLAND

2

2-Year

002064

COLLEGE OF SOUTHERN MARYLAND

4

4-Year

002064

COLLEGE OF SOUTHERN MARYLAND

NULL

Consolidation

032673

CAPELLA UNIVERSITY

2

2-Year

032673

CAPELLA UNIVERSITY

4

4-Year

032673

CAPELLA UNIVERSITY

NULL

Consolidation

003448

UNIV OF SOUTH CAROLINA

2

2-Year

003448

UNIV OF SOUTH CAROLINA

4

4-Year

003448

UNIV OF SOUTH CAROLINA

NULL

Consolidation

009928

PIEDMONT VIRGINIA COMMUNITY COLLEGE

2

2-Year

009928

PIEDMONT VIRGINIA COMMUNITY COLLEGE

4

4-Year

004910

BRIGHTWOOD CAREER INSTITUTE

2

2-Year

004910

BRIGHTWOOD CAREER INSTITUTE

T

Proprietary

003726

AMERICAN NATIONAL UNIVERSITY

2

2-Year

 


 

Exhibit B

 

 

 

School
ID

School Name

Navient
School Type

Loan Tape
School Type

003726

AMERICAN NATIONAL UNIVERSITY

4

4-Year

003726

AMERICAN NATIONAL UNIVERSITY

T

Proprietary

003726

AMERICAN NATIONAL UNIVERSITY

NULL

Consolidation

003991

GREENVILLE TECHNICAL COLLEGE

2

2-Year

003991

GREENVILLE TECHNICAL COLLEGE

4

4-Year

003991

GREENVILLE TECHNICAL COLLEGE

NULL

Consolidation

001125

CA BAPTIST UNIVERSITY

2

2-Year

001125

CA BAPTIST UNIVERSITY

4

4-Year

001125

CA BAPTIST UNIVERSITY

NULL

Consolidation

004920

TRIDENT TECHNICAL COLLEGE

2

2-Year

004920

TRIDENT TECHNICAL COLLEGE

4

4-Year

004920

TRIDENT TECHNICAL COLLEGE

T

Proprietary

004920

TRIDENT TECHNICAL COLLEGE

NULL

Consolidation

003446

SOUTH CAROLINA STATE UNIVERSITY

2

2-Year

003446

SOUTH CAROLINA STATE UNIVERSITY

4

4-Year

003446

SOUTH CAROLINA STATE UNIVERSITY

T

Proprietary

003446

SOUTH CAROLINA STATE UNIVERSITY

NULL

Consolidation

003993

MIDLANDS TECHNICAL COLLEGE

2

2-Year

003993

MIDLANDS TECHNICAL COLLEGE

4

4-Year

003993

MIDLANDS TECHNICAL COLLEGE

T

Proprietary

003993

MIDLANDS TECHNICAL COLLEGE

NULL

Consolidation

003425

CLEMSON UNIVERSITY

2

2-Year

003425

CLEMSON UNIVERSITY

4

4-Year

003425

CLEMSON UNIVERSITY

NULL

Consolidation

001562

GEORGIA PERIMETER COLLEGE

2

2-Year

001562

GEORGIA PERIMETER COLLEGE

4

4-Year

001562

GEORGIA PERIMETER COLLEGE

NULL

Consolidation

010487

CARROLL TECHNICAL INSTITUTE

4

4-Year

010487

CARROLL TECHNICAL INSTITUTE

T

Proprietary

010487

CARROLL TECHNICAL INSTITUTE

NULL

Consolidation

002102

UNIVERSITY OF BALTIMORE

2

2-Year

002102

UNIVERSITY OF BALTIMORE

4

4-Year

023112

AMERICAN SCHOOL OF TECHNOLOGY

2

2-Year

023112

AMERICAN SCHOOL OF TECHNOLOGY

4

4-Year

023112

AMERICAN SCHOOL OF TECHNOLOGY

T

Proprietary

024992

JAY TRUCK DRIVING TRAINING CENTER

T

Proprietary

001733

NATIONAL-LOUIS UNIVERSITY

4

4-Year

001733

NATIONAL-LOUIS UNIVERSITY

T

Proprietary

001733

NATIONAL-LOUIS UNIVERSITY

NULL

Consolidation

003419

CHARLESTON SOUTHERN UNIVERSITY

2

2-Year

003419

CHARLESTON SOUTHERN UNIVERSITY

4

4-Year

003419

CHARLESTON SOUTHERN UNIVERSITY

NULL

Consolidation

002798

PRATT INSTITUTE

4

4-Year

002798

PRATT INSTITUTE

NULL

Consolidation

002173

NORTH SHORE COMMUNITY COLLEGE

2

2-Year

002173

NORTH SHORE COMMUNITY COLLEGE

4

4-Year

002173

NORTH SHORE COMMUNITY COLLEGE

T

Proprietary

002173

NORTH SHORE COMMUNITY COLLEGE

NULL

Consolidation

004852

CLARK STATE COMMUNITY COLLEGE

2

2-Year

004852

CLARK STATE COMMUNITY COLLEGE

4

4-Year

030723

EVEREST COLLEGE

2

2-Year

030723

EVEREST COLLEGE

4

4-Year

030723

EVEREST COLLEGE

T

Proprietary

030723

EVEREST COLLEGE

NULL

Consolidation

007684

KISHWAUKEE COLLEGE

2

2-Year

007684

KISHWAUKEE COLLEGE

4

4-Year

004934

DAYMAR COLLEGE

2

2-Year

 


 

Exhibit B

 

 

 

School
ID

School Name

Navient
School Type

Loan Tape
School Type

004934

DAYMAR COLLEGE

4

4-Year

004934

DAYMAR COLLEGE

T

Proprietary

004934

DAYMAR COLLEGE

NULL

Consolidation

009740

INVER HILLS CMTY COL

2

2-Year

009740

INVER HILLS CMTY COL

4

4-Year

008145

NASHVILLE STATE TECHNICAL INST

2

2-Year

008145

NASHVILLE STATE TECHNICAL INST

4

4-Year

008145

NASHVILLE STATE TECHNICAL INST

T

Proprietary

008145

NASHVILLE STATE TECHNICAL INST

NULL

Consolidation

003531

UNIV OF TENNESSEE - MARTIN

2

2-Year

003531

UNIV OF TENNESSEE - MARTIN

4

4-Year

003531

UNIV OF TENNESSEE - MARTIN

NULL

Consolidation

009566

MIDSOUTH SCHOOL OF BEAUTY

T

Proprietary

002407

HINDS COMMUNITY COLLEGE

2

2-Year

002407

HINDS COMMUNITY COLLEGE

4

4-Year

002407

HINDS COMMUNITY COLLEGE

NULL

Consolidation

003478

AUSTIN PEAY STATE UNIVERSITY

2

2-Year

003478

AUSTIN PEAY STATE UNIVERSITY

4

4-Year

003478

AUSTIN PEAY STATE UNIVERSITY

NULL

Consolidation

030226

LE CORDON BLEU COLLEGE OF CULINARY ARTS

2

2-Year

030226

LE CORDON BLEU COLLEGE OF CULINARY ARTS

4

4-Year

030226

LE CORDON BLEU COLLEGE OF CULINARY ARTS

NULL

Consolidation

011574

BAUDER COLLEGE

2

2-Year

011574

BAUDER COLLEGE

4

4-Year

 


 

Exhibit C

 

ECMC Interest Rate Document

 

FFEL “Converted” Variable-rate Stafford Loan Interest Rates for the Period July 1, 2019 through June 30, 2020

(Loans That Were Subject to the “Windfall Profits” Provisions of §427A(i) of the HEAL)

(Table 1)

 

COHORT

 

 

CITATION

  INTEREST RATE FORMULA (T-Bill Rate + Additional Sum = Total)

Type of loan/
Borrower

First
Disbursement
Made On or After

First
Disbursement
Made Before

Higher Education
Act of 1965, As
Amended

91-Day
Treasury Bill
Rate

Additional
Sum

Total

Maximum
Rate

INTEREST RATE FOR
THE PERIOD
7/1/19 – 6/30/20

8/10% Loans
(SD/XB FVAR10)
(new borrowers)

7-1-88
and
7-23-92

7-23-92

10-1-92

§427A(i)(1)
§427A(i)(7)(A)

2.36%

3.25%

5.61%

10%

5.61%

7% Loans
(SD/SE FVAR7)
(old borrowers)

7-23-92
SD
10-1-92
SE

10-1-92
SD
7-1-94
SE

§427A(i)(3)
§427A(i)(7)(A)

2.36%

3.1%

5.46%

7%

5.46%

8% Loans
(SD/SE FVAR8)
(old borrowers)

7-23-92
SD/XB
10-1-92
SE

10-1-92
SD
7-1-94
SE

§427A(i)(3)
§427A(i)(7)(A)

2.36%

3.1%

5.46%

8%

5.46%

9% Loans
(SD/SE FVAR9)
(old borrowers)

7-23-92
SD
10-1-92
SE

10-1-92
SD
7-1-94
SE

§427A(i)(3)
§427A(i)(7)(A)

2.36%

3.1%

5.46%

9%

5.46%

8/10% loans
(SD)
(SE/XE FVAR10)
(old borrowers)

7-23-92
SD
10-1-92
SE/XE

10-1-92
SD
7-1-94
SE/XE

§427A(i)(3)
§427A(i)(7)(A)

2.36%

3.1%

5.46%

10%

5.46%

 

Page 1

 

June 26, 2019     

 


 

Exhibit C

 

 

 

FFEL Regular Variable-rate Stafford Loan Interest Rates for the Period July 1, 2019 through June 30, 2020
(Table 2)

 

  COHORT

CITATION

  INTEREST RATE FORMULA (T-Bill Rate + Additional Sum = Total)

Type of
Borrower

First
Disbursement
Made On or After

First
Disbursement
Made Before

Higher
Education Act
of 1965, As

Amended

During

91-Day
Treasury
Bill Rate

Additional
Sum

Total

Maximum
Rate

INTEREST RATE FOR
THE PERIOD
7/1/19 – 6/30/20

“New” Borrower
(SE/XE EVAR)

10/1/92

7/1/94

§427A(e)(1)

 

2.36%

3.1%

5.46%

9%

5.46%

“New” Borrower
(SE/XE EVAR)

7/1/94
(for a period of
enrollment
ending prior to
7/1/ 94)

 

§427A(e)(1)

 

2.36%

3.1%

5.46%

9%

5.46%

All Borrowers
(regardless of
prior borrowing)
(SG/XG EVAR)

7/1/94
(for a period of
enrollment that
includes or begins
on or after
7/1/94)

7/1/95

§427A(f)(1)

 

2.36%

3.1%

5.46%

8.25%

5.46%

 

 

 

 

 

Page 2

 

June 26, 2019     

 


 

Exhibit C

 

 

 

FFEL Regular Variable-rate Stafford Loan Interest Rates for the Period July 1, 2019 through June 30, 2020

(Table 2)

 

  COHORT

CITATION

  INTEREST RATE FORMULA (T-Bill Rate + Additional Sum = Total)

Type of
Borrower

First
Disbursement
Made On or After

First
Disbursement
Made Before

Higher
Education Act
of 1965, As
Amended

During

91-Day
Treasury
Bill Rate

Additional
Sum

Total

Maximum
Rate

INTEREST RATE FOR
THE PERIOD
7/1/19 – 6/30/20

All Borrowers
(regardless of
prior borrowing)

7/1/95

7/1/98

§427A(g)(2)
(SH/XH EVAR)


§427A(f)(1)
(SG EVAR)

In-school, grace
and deferment
periods

All other
periods

2.36%



2.36%

2.5%



3.1%

4.86%



5.46%

8.25%



8.25%

4.86%



5.46%

All Borrowers
(regardless of
prior borrowing)

7/1/98

7/1/2006

§427A(j)(2)
§427A(k)(2)
(SJ/XJ/CA/CE/
LA/LE EVAR)

§427AU)(j)(1)
§427A(k)(1)
(SK/XK/CB/CF/
LB/LF EVAR)

In-school, grace
and deferment
periods


All other
periods

2.36%




2.36%

1.7%




2.3%

4.06%




4.66%

8.25%




8.25%

4.06%




4.66%

 

 

 

 

Page 3

 

June 26, 2019     

 


 

Exhibit C

 

 

 

FFEL Variable-rate PLUS and SLS Loan Interest Rates for the Period July 1, 2019 through June 30, 2020

(Table 3)

 

  COHORT

CITATION

  INTEREST RATE FORMULA (T-Bill Rate + Additional Sum = Total)

Type of Loan

First
Disbursement
Made On or After

First
Disbursement
Made Before

Higher
Education Act of
1965, As
Amended

91-Day
Treasury Bill
Rate

One-year
Constant
Maturity

Additional
Sum

Total

Maximum
Rate

INTEREST RATE FOR
THE PERIOD
7/1/19 – 6/30/20

PLUS/SLS*
(SD VAR)

 

10/1/92

§427A(c)(4)(B)

 

1.98%

3.25%

5.23%

12%

5.23%

 

SLS*
(SE/XE EVAR)

 

10/1/92
(for a period of
enrollment
beginning prior to
7/1/94)

 

 

§427A(c)(4)(D)

 

 

1.98%

 

3.1%

 

5.08%

 

11%

 

5.08%

PLUS*
(SE EVAR)

10/1/92

7/1/94

§427A(c)(4)(D)

 

1.98%

3.1%

5.08%

10%

5.08%

PLUS
(SG EVAR)

7/1/94

7/1/98

§427A(c)(4)(E)

 

1.98%

3.1%

5.08%

9%

5.08%

PLUS*
(SH EVAR)

7/1/98

1/1/2000

§427A(j)(3)
§427A(k)(3)

2.36%

 

3.1%

5.46%

9%

5.46%

PLUS
(CD/XO/CH/
LD/LH/ EVAR)

1/1/2000

7/1/2006

§427A(k)(3)

2.36%

 

3.1%

5.46%

9%

5.46%

 

*      These loans will not be subject to special allowance payments during the four quarters ending 9/30/19, 12/31/19, 3/31/2020, and 6/30/2020. See Sections 438(b)(2)(C)(i); 438(b)(2)(C)(ii); 438(b)(2)(G)(v); and 438(b)(2)(H)(v) of t he Higher Education Act of 1965, as amended.

 

 

Page 4

 

June 26, 2019     

 


 

Exhibit C

 

 

 

FFEL Variable-rate and Fixed-rate Consolidation Loan Interest Rates for the Period July 1, 2019 through June 30, 2020

(Table 4)

 

  COHORT

CITATION

  INTEREST RATE FORMULA

Consolidation
Loans Made On
or After

Consolidation
Loans Made
Before

Consolidation Loans for
Which the Loan Application
Was Received by an Eligible
Lender On or After

Consolidation Loans for
Which the Loan
Application Was
Received by an Eligible
Lender Before

Higher Education
Act of 1965, As
Amended

Method Used to Determine
Interest Rate

Maximum Rate

 

7/1/94

 

 

§428C(c)(1)(B)

The interest rate is the weighted average of the interest rates on the loans consolidated, rounded to the nearest whole percent, but may not be less than 9 percent.

 

7/1/94
(SE)

 

 

11/13/97

§428C(c)(1)(C)

The interest rate is the weighted average of the interest rates on the loans consolidated, rounded upward to the nearest whole percent.

 

 

 

 

 

 

Page 5

 

June 26, 2019     

 


 

Exhibit C

 

 

 

FFEL Variable-rate and Fixed-rate Consolidation Loan Interest Rates for the Period July 1, 2019 through June 30, 2020

(Table 4)

 

  COHORT

CITATION

  INTEREST RATE FORMULA

Consolidation
Loans Made On
or After

Consolidation
Loans Made
Before

Consolidation Loans for
Which the Loan Application
Was Received by an Eligible
Lender On or After

Consolidation Loans for
Which the Loan
Application Was
Received by an Eligible
Lender Before

Higher Education
Act of 1965, As
Amended

Method Used to Determine
Interest Rate

Maximum Rate

 

 

11/13/97
(SG/XG EVAR)

10/1/98

§427A(f)
§428C(c)(1)(D)

The interest rate is determined annually and equals the bond equivalent rate of 91-Day Treasury Bills auctioned on the final auction held before June 1st of each year, plus 3.10 percent. The interest rate may not exceed the maximum rate. (For the period July 1, 2019 through June 30, 2020 the interest rate for these loans is 2.36 percent plus 3.10 percent or 5.46 percent.)

8.25%

 

 

10/1/98
(SL/XL/CC/CG/CK/LC/LG/LK)

6/30/2010

§427A(k)(4)(A)
§428C(c)(1)(A)

The interest rate is the weighted average of the interest rates on the loans being consolidated, rounded to the nearest higher 1/8th of one percent. The interest rate may not exceed the maximum rate.

8.25%

 

Page 6

 

June 26, 2019     

 


 

Exhibit C

 

 

 

FFEL Variable-rate and Fixed-rate Consolidation Loan Interest Rates for the Period July 1, 2019 through June 30, 2020

(Table 4)

 

  COHORT

CITATION

  INTEREST RATE FORMULA

Consolidation
Loans Made On
or After

Consolidation
Loans Made
Before

Consolidation Loans for
Which the Loan Application
Was Received by an Eligible
Lender On or After

Consolidation Loans for
Which the Loan
Application Was
Received by an Eligible
Lender Before

Higher Education
Act of 1965, As
Amended

Method Used to Determine
Interest Rate

Maximum Rate

 

 

11/13/97

6/30/2010

§428C(d)(2)(B)

The interest rate for the HEAL portion of the consolidation loan is determined annually and equals the average of the bond equivalent rates of the 91-Day Treasury Bills auctioned for the quarter ending June 30, plus 3.0 percent. (For the period July 1, 2019 through June 30, 2020 the interest rate for these loans is 2.37 percent plus 3.00 percent or 5.37 percent .) There is no maximum rate on this portion of the loan.

N/A

 

 

 

 

 

 

Page 7

 

June 26, 2019     

 


 

Exhibit C

 

 

 

Loans First Disbursed on or After July 1, 2006 have Fixed Rates:

 

 

LOAN TYPE

GRADE LEVEL

First Disbursed
July 1, 2006 through
June 30, 2008

First Disbursed
July 1, 2008 through
June 30, 2009

First Disbursed
July 1, 2009 through
June 30, 2010

Subsidized Stafford

Undergraduate
(CE/CF/CI/CJ/LE/LF/LI/LI)

6.80

6.00

5.60

Graduate
(CE/CF/CI/CJ/LE/LF/LI/LI)

6.80

6.80

6.80

Unsubsidized Stafford

Undergraduate
(CE/CF/CI/CJ/LE/LF/LI/LI)

6.80

6.80

6.80

Graduate
(CE/CF/CI/CJ/LE/LF/LI/LI)

6.80

6.80

6.80

PLUS Loans

Parent and Grad Student
(CH/CM/LH/LM)

8.50

8.50

8 .50

 

 

 

 

 

 

Page 8

 

June 26, 2019