EX-99.1 2 a20-35193_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 2020-3 — 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 2020-3 Loan Tape 20200930.xlsx” (the “Data File”), provided by the Company on October 20, 2020, containing certain information on 27,493 student loans (the “Student Loans”) as of September 30, 2020 (the “Cutoff Date”), which we were informed are intended to be included as collateral in the offering by ECMC Group Student Loan Trust 2020-3. 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 stated, 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 stated. 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 stated. 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 “SLS System” means Nelnet, Inc.’s (“Nelnet’s”) servicing system for student loans serviced by Nelnet.

 

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

 

·                  The term “ECMC Lookup Code Document for Student Loans Serviced by Navient” means a document provided by the Company containing code definitions related to Loan Type and Loan Status for student loans serviced by Navient, attached hereto as Exhibit B.

 

·                  The term “ECMC Lookup Code Document for Student Loans Serviced by Nelnet” means a document provided by the Company containing code definitions related to Loan Type, Loan Status, and Guarantor for student loans serviced by Nelnet, attached hereto as Exhibit B.

 

 

 

 

·                  The term “ECMC School Type Document” means a document provided by the Company containing code definitions related to 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 30, 2020, attached hereto as Exhibit C.

 

·                  The term “Transaction History Documents” means 13 documents provided by the Company related to the transaction histories for the 13 Selected Student Loans (defined below) serviced by Nelnet.

 

·                  The term “Loan File” means any file containing some or all of the following documents for each of the Selected Student Loans:

 

·                  From the CLASS System: #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

 

·                  From the SLS System: INQUIRE LOAN FILE, PAGE 1 Screen, DISPLAY BORROWER GROUPS — ALL Screen, and DEFERMENT/FORBEARANCE HISTORY BY DATE Screen

 

·                  From the GUARANTEE System: Loan Overview and Disbursements Screen, NSLDS Screen and ECMC SQL Query Screen

 

·                  ECMC Lookup Code Document for Student Loans Serviced by Navient, ECMC Lookup Code Document for Student Loans Serviced by Nelnet, ECMC School Type Document, ECMC Interest Rate Document, and Transaction History Documents.

 

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, CLASS System, or SLS 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 sample of 100 selected Student Loans (87 Selected Student Loans were serviced by Navient and 13 Selected Student Loans were serviced by Nelnet) 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

 

For Selected Student Loans serviced by Navient:

 

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

 

2

 

 

Attribute

 

Loan File / Instructions

 

 

 

 

 

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.

 

For Selected Student Loans serviced by Nelnet:

 

“1ST DISB DATE” field on the INQUIRE LOAN FILE, PAGE 1 Screen within the SLS System.

 

 

 

Loan Type

 

For Selected Student Loans serviced by Navient:

 

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

 

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 for Student Loans Serviced by Navient. The Company informed us that 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.

 

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.

 

For Selected Student Loans serviced by Nelnet:

 

“LOAN TYPE” field on the INQUIRE LOAN FILE, PAGE 1 Screen within the SLS System and ECMC Lookup Code Document for Student Loans Serviced by Nelnet.

 

We were instructed by the Company to compare the “LOAN TYPE” field on the INQUIRE LOAN FILE, PAGE 1 Screen to the corresponding Loan Type Description on the ECMC Lookup Code Document for Student Loans Serviced by Nelnet.

 

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

 

3

 

 

Attribute

 

Loan File / Instructions

 

 

 

 

 

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

 

For Selected Student Loans serviced by Navient:

 

“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 7/1/2020-6/30/2021” 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.

 

For Selected Student Loans serviced by Nelnet:

 

“INT RATE” field on INQUIRE LOAN FILE, PAGE 1 Screen within the SLS System.

 

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 INQUIRE LOAN FILE, PAGE 1 Screen.

 

For Selected Student Loans that are variable rate (identified as “Floating” in the Fixed/Floating field in the Data File), the Company

 

4

 

 

Attribute

 

Loan File / Instructions

 

 

 

 

 

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 7/1/2020-6/30/2021” column in the ECMC Interest Rate Document to the Current Statutory Borrower Interest Rate in the Data File.

 

 

 

Current Loan Balance

 

For Selected Student Loans serviced by Navient:

 

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

 

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.

 

For Selected Student Loans serviced by Nelnet:

 

“CURR PRINCIPAL” field on INQUIRE LOAN FILE, PAGE 1 Screen within the SLS System.

 

 

 

Remaining Term

 

For Selected Student Loans serviced by Navient:

 

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 Anticipated Payoff Date (determined in the Anticipated Payoff Date procedures discussed below). The Company further instructed us to compare the Recomputed Remaining Term to the Remaining Term in the Data File.

 

For Selected Student Loans serviced by Nelnet:

 

“REMAINING” field on INQUIRE LOAN FILE, PAGE 1 Screen within the SLS System.

 

In the event the remaining term in the “REMAINING” field on the INQUIRE LOAN FILE, PAGE 1 Screen did not agree with the Remaining Term in the Data File, we were instructed by the Company to identify the repayment date in the “CONVERSION” field on the

 

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Attribute

 

Loan File / Instructions

 

 

 

 

 

INQUIRE LOAN FILE, PAGE 1 Screen and add the number of scheduled repayment date occurrences between the Cutoff Date and the INQUIRE LOAN FILE, PAGE 1 Screen date to the “REMAINING” field in INQUIRE LOAN FILE, PAGE 1 Screen.

 

For Selected Student Loan #98, the loan status was retrospectively changed to forbearance status after the Cutoff Date, as indicated in the “TYP D/F” field in the DEFERMENT/FORBEARANCE HISTORY BY DATE Screen. Since Selected Student Loan #98 was retrospectively changed to forbearance status after the Cutoff Date, the Company instructed us to subtract the number of months indicated in the “#OF MTS” field for the forbearance period that included the Cutoff Date in the DEFERMENT /FORBEARANCE HISTORY BY DATE Screen from the “REMAINING” field in the INQUIRE LOAN FILE, PAGE 1 Screen.

 

 

 

First Disbursement Date

 

For Selected Student Loans serviced by Navient:

 

“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.

 

For Selected Student Loans serviced by Nelnet:

 

“1ST DISB DATE” field on INQUIRE LOAN FILE, PAGE 1 Screen within the SLS System.

 

 

 

Loan Status

 

For Selected Student Loans serviced by Navient:

 

“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 for Student Loans Serviced by Navient.

 

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 for Student Loans Serviced by Navient. The Company further instructed us to compare the Loan Status Description stated on the ECMC Lookup Code Document for Student Loans Serviced by Navient to the Loan Status in the Data File.

 

In the event the Loan Status Description on the ECMC Lookup Code Document for Student Loans Serviced by Navient 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 corresponding Loan Status Description in the ECMC Lookup Code Document for Student Loans Serviced by

 

6

 

 

Attribute

 

Loan File / Instructions

 

 

 

 

 

Navient. The Company further instructed us to compare the identified Loan Status Description stated on the ECMC Lookup Code Document for Student Loans Serviced by Navient to the Loan Status in the Data File.

 

In the event the Loan Status description on the ECMC Lookup Code Document for Student Loans Serviced by Navient 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.

 

For Selected Student Loans serviced by Nelnet:

 

“STATUS” field on INQUIRE LOAN FILE, PAGE 1 Screen within the SLS System and ECMC Lookup Code Document for Student Loans Serviced by Nelnet.

 

We were instructed by the Company to compare the “STATUS” field on the INQUIRE LOAN FILE, PAGE 1 Screen to the corresponding Loan Status Description on the ECMC Lookup Code Document for Student Loans Serviced by Nelnet. The Company further instructed us to compare the Loan Status Description stated on the ECMC Lookup Code Document for Student Loans Serviced by Nelnet to the Loan Status in the Data File.

 

In the event the Loan Status description on the ECMC Lookup Code Document for Student Loans Serviced by Nelnet did not agree with the Loan Status in the Data File, the Company instructed us to compare the loan status in the “loan_status” field on the ECMC SQL Query Screen within the GURANTEE System to the Loan Status in the Data File.

 

 

 

School Type

 

For Selected Student Loans serviced by Navient:

 

“SCHOOL” field on #111 ACCT BALANCE Screen within the CLASS System, Loan Overview and Disbursements Screen within the GUARANTEE System, and the ECMC School Type 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 School Type Document. We were further instructed by the Company to utilize the “School ID” in the ECMC School Type Document to locate the corresponding School Type under the “Loan Tape School Type” field in the ECMC School Type 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

 

7

 

 

Attribute

 

Loan File / Instructions

 

 

 

 

 

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 School Type 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 or the original school in the “orig_school” field on the ECMC SQL Query Screen within the GUARANTEE System to the “School ID” field in the ECMC School Type Document.

 

We were further instructed by the Company to utilize the “School ID” in the ECMC School Type Document to locate the corresponding School Type under the “Loan Tape School Type” field in the ECMC School Type 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.”

 

For Selected Student Loans serviced by Nelnet:

 

“SCHOOL” field on INQUIRE LOAN FILE, PAGE 1 Screen within the SLS System and the ECMC School Type Document.

 

We were instructed by the Company to compare the School ID in the “SCHOOL” field on the INQUIRE LOAN FILE, PAGE 1 Screen to the “School ID” field in the ECMC School Type Document. We were further instructed by the Company to utilize the “School ID” in the ECMC School Type Document to locate the corresponding School Type under the “Loan Tape School Type” field in the ECMC School Type 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 School Type 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 or the original school in the “orig_school” field on the ECMC SQL Query Screen within the GUARANTEE System to the “School ID” field in the ECMC School Type Document.

 

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

 

8

 

 

Attribute

 

Loan File / Instructions

 

 

 

 

 

We were instructed by the Company to consider the School Type to be “Consolidation” if the “LOAN TYPE” field on the INQUIRE LOAN FILE, PAGE 1 was “CONS.”

 

 

 

Initial Repayment Start Date

 

For Selected Student Loans serviced by Navient:

 

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

 

In the event the RPMT BEG DT did not agree with the Initial Repayment Start 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 Initial Repayment Start Date in the Data File.

 

For Selected Student Loans serviced by Nelnet:

 

“1ST DISB DATE” field or “GRAD/SEP DATE” field on the INQUIRE LOAN FILE, PAGE 1 Screen within the SLS System.

 

For Selected Student Loans that are Consolidation loans (identified as “Consolidation” in the “Loan Type” field in the Data File), the Company instructed us to compare the Initial Repayment Start Date in the Data File to the”1ST DISB DATE” field on INQUIRE LOAN FILE, PAGE 1 Screen within the SLS System.

 

For Selected Student Loans that are not Consolidation loans (identified as other loan type in the “Loan Type” field in the Data File), the Company instructed us to compare the Initial Repayment Start Date in the Data File to the “GRAD/SEP DATE” field on INQUIRE LOAN FILE, PAGE 1 Screen within the SLS System.

 

 

 

Last Payment Date

 

For Selected Student Loans serviced by Navient:

 

“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 entry 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.

 

For Selected Student Loans serviced by Nelnet:

 

“LST PMT DT” on the DISPLAY BORROWER GROUPS — ALL Screen within the SLS System.

 

9

 

 

Attribute

 

Loan File / Instructions

 

 

 

 

 

We were instructed by the Company to consider Last Payment Date to be inapplicable (identified as blank entry in the “LAST_PAYMENT_ DATE” field in the Data File) if the “LST PMT DT” field on the DISPLAY BORROWER GROUPS — ALL Screen was blank.

 

In the event the Last Payment Date in the “LST PMT DT” 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 DATE” field with a transaction code of “P30” in the “TRAN CODE” field on the Transaction History Document to the Last Payment Date in the Data File.

 

 

 

Anticipated Payoff Date

 

For Selected Student Loans serviced by Navient:

 

“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.

 

For Selected Student Loans serviced by Nelnet:

 

We were instructed by the Company to recompute the Anticipated Payoff Date (the “Recomputed Anticipated Payoff Date”) by adding the number of months determined in the Remaining Term procedures discussed above to the Cutoff Date. The Company further instructed us to compare the Recomputed Anticipated Payoff Date to the Anticipated Payoff Date in the Data File.

 

 

 

Guarantor

 

For Selected Student Loans serviced by Navient:

 

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

 

For Selected Student Loans serviced by Nelnet:

 

“GUAR AGENCY” field on INQUIRE LOAN FILE, PAGE 1 Screen within the SLS System and ECMC Lookup Code Document for Student Loans Serviced by Nelnet.

 

 

 

State

 

For Selected Student Loans serviced by Navient:

 

“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 or the state in the “state” field

 

10

 

 

Attribute

 

Loan File / Instructions

 

 

 

 

 

on the ECMC SQL Query Screen within the GUARANTEE System to the State in the Data File.

 

For Selected Student Loans serviced by Nelnet:

 

“ADDR” field on the DISPLAY BORROWER GROUPS — ALL Screen within the SLS System.

 

 

 

Subsidy Indicator

 

For Selected Student Loans serviced by Navient:

 

“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.

 

For Selected Student Loans serviced by Nelnet:

 

“GOV SUB STS” or “LOAN TYPE” field on INQUIRE LOAN FILE, PAGE 1 Screen within SLS System and ECMC Lookup Code Document for Student Loans Serviced by Nelnet.

 

For loans for which the “GOV SUB STS” field on the INQUIRE LOAN FILE, PAGE 1 Screen was “G,” we were instructed to consider the loan to be subsidized. For loans for which the “GOV SUB STS” field on the INQUIRE LOAN FILE, PAGE 1 Screen was “B,” we were instructed to consider the loan to be unsubsidized.

 

In the event the date in the “GOV SUB STS” field was blank, we were instructed by the Company to compare the “LOAN TYPE” field on the INQUIRE LOAN FILE, PAGE 1 Screen to the corresponding Subsidy Indicator on the ECMC Lookup Code Document for Student Loans Serviced by Nelnet. The Company further instructed us to compare the resulting Subsidy Indicator to the Subsidy Indicator Field in the Data File.

 

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.

 

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 Loan Files, 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

 

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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, CA

 

November 4, 2020

 

 

12

 

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

 

20203001

 

26

 

20203026

 

51

 

20203051

 

76

 

20203076

 

2

 

20203002

 

27

 

20203027

 

52

 

20203052

 

77

 

20203077

 

3

 

20203003

 

28

 

20203028

 

53

 

20203053

 

78

 

20203078

 

4

 

20203004

 

29

 

20203029

 

54

 

20203054

 

79

 

20203079

 

5

 

20203005

 

30

 

20203030

 

55

 

20203055

 

80

 

20203080

 

6

 

20203006

 

31

 

20203031

 

56

 

20203056

 

81

 

20203081

 

7

 

20203007

 

32

 

20203032

 

57

 

20203057

 

82

 

20203082

 

8

 

20203008

 

33

 

20203033

 

58

 

20203058

 

83

 

20203083

 

9

 

20203009

 

34

 

20203034

 

59

 

20203059

 

84

 

20203084

 

10

 

20203010

 

35

 

20203035

 

60

 

20203060

 

85

 

20203085

 

11

 

20203011

 

36

 

20203036

 

61

 

20203061

 

86

 

20203086

 

12

 

20203012

 

37

 

20203037

 

62

 

20203062

 

87

 

20203087

 

13

 

20203013

 

38

 

20203038

 

63

 

20203063

 

88

 

20203088

 

14

 

20203014

 

39

 

20203039

 

64

 

20203064

 

89

 

20203089

 

15

 

20203015

 

40

 

20203040

 

65

 

20203065

 

90

 

20203090

 

16

 

20203016

 

41

 

20203041

 

66

 

20203066

 

91

 

20203091

 

17

 

20203017

 

42

 

20203042

 

67

 

20203067

 

92

 

20203092

 

18

 

20203018

 

43

 

20203043

 

68

 

20203068

 

93

 

20203093

 

19

 

20203019

 

44

 

20203044

 

69

 

20203069

 

94

 

20203094

 

20

 

20203020

 

45

 

20203045

 

70

 

20203070

 

95

 

20203095

 

21

 

20203021

 

46

 

20203046

 

71

 

20203071

 

96

 

20203096

 

22

 

20203022

 

47

 

20203047

 

72

 

20203072

 

97

 

20203097

 

23

 

20203023

 

48

 

20203048

 

73

 

20203073

 

98

 

20203098

 

24

 

20203024

 

49

 

20203049

 

74

 

20203074

 

99

 

20203099

 

25

 

20203025

 

50

 

20203050

 

75

 

20203075

 

100

 

20203100

 

 

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 for Student Loans Serviced by Navient

 

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

 

ECMC Lookup Code Document for Student Loans Serviced by Nelnet

 

Loan Type

 

Loan Type

 

Sub Indicator

 

Description

 

Loan Type
per Data File

 

Subsidy
Indicator

 

 

 

 

 

 

 

 

 

CONH

 

B

 

Consolidation Loan - HEAL (variable rate)

 

CL

 

N

CONS

 

G

 

Consolidation Loan

 

CL

 

Y

CONS

 

B

 

Consolidation Loan

 

CL

 

N

CONU

 

B

 

Consolidation Loan

 

CL

 

N

CONV

 

G

 

Consolidation Loan Variable Rate

 

CL

 

Y

CONV

 

B

 

Consolidation Loan Variable Rate

 

CL

 

N

GRAD

 

Blank

 

Graduate PLUS Loan

 

GB

 

N

PLUS

 

Blank

 

Parental Loan for Undergraduate Students (Grad/Prof students included)

 

PL

 

N

SLS

 

Blank

 

Supplemental Loan for Students

 

SL

 

N

STAF

 

Blank

 

Subsidized Stafford Loan

 

SF

 

N

STAN

 

Blank

 

Non-subsidized Stafford Loan

 

SU

 

N

STAU

 

Blank

 

Unsubsidized Stafford Loan

 

SU

 

N

 

Loan Status

 

Loan Status Code

 

Description

 

 

 

P30

 

Repayment

FVP

 

Forbearance

 

Guarantor

 

Guarantor Code

 

Guarantor Name

 

 

 

GLHEC

 

GREAT LAKES HIGHER EDUCATION/ ASCENDIUM

 

 

Exhibit B

 

ECMC School Type Document

 

School ID

 

School Name

 

School Type

 

Loan Tape
School Type

 

 

 

 

 

 

 

003726

 

AMERICAN NATIONAL UNIVERSITY

 

4

 

4-Year

023344

 

CENTURA COLLEGE

 

4

 

4-Year

021151

 

BUTLER BUSINESS SCHOOL

 

T

 

Proprietary

003213

 

PORTLAND COMMUNITY COLLEGE

 

2

 

2-Year

001074

 

GRAND CANYON UNIVERSITY

 

4

 

4-Year

001807

 

INDIANA STATE UNIVERSITY

 

4

 

4-Year

025042

 

WALDEN UNIVERSITY

 

4

 

4-Year

006951

 

UNIVERSITY OF SOUTH CAROLINA UPSTATE

 

4

 

4-Year

002222

 

UNIVERSITY OF MASSACHUSETTS AT BOSTON

 

4

 

4-Year

010198

 

ECPI COLLEGE OF TECHNOLOGY - VA BEACH

 

4

 

4-Year

000000

 

CLAIMS PROCESSING SCHOOL

 

NULL

 

Consolidation

001459

 

STRAYER UNIVERSITY

 

4

 

4-Year

007954

 

NORMANDALE CMTY COL

 

2

 

2-Year

020988

 

UNIVERSITY OF PHOENIX

 

4

 

4-Year

001150

 

CALIF STATE U SACRAMENTO

 

4

 

4-Year

004586

 

PURDUE UNIVERSITY GLOBAL

 

4

 

4-Year

009079

 

EVEREST COLLEGE

 

2

 

2-Year

023122

 

TEXAS SCHOOL OF BUSINESS

 

2

 

2-Year

022506

 

EVEREST COLLEGE

 

4

 

4-Year

011858

 

OLYMPIA COLLEGE

 

T

 

Proprietary

003456

 

WINTHROP UNIVERSITY

 

4

 

4-Year

002025

 

SOUTHERN UNIV & A&M COL

 

4

 

4-Year

002823

 

ST JOHNS UNIVERSITY

 

4

 

4-Year

024980

 

NEW WAVE HAIR ACADEMY

 

T

 

Proprietary

001365

 

COLORADO STATE UNIVERSITY-PUEBLO

 

4

 

4-Year

001349

 

UNIV OF NORTHERN COLORADO

 

4

 

4-Year

002403

 

DELTA STATE UNIVERSITY

 

4

 

4-Year

003510

 

MIDDLE TENNESSEE STATE UNIVERSITY

 

4

 

4-Year

003451

 

COASTAL CAROLINA UNIVERSITY

 

4

 

4-Year

003424

 

CLAFLIN UNIVERSITY

 

4

 

4-Year

003426

 

UNIVERSITY OF SOUTH CAROLINA AT SUMTER

 

4

 

4-Year

005525

 

SOUTHERN MAINE VOC TECH INSTITUTE

 

2

 

2-Year

002054

 

UNIV OF SOUTHERN MAINE

 

4

 

4-Year

003837

 

CARDINAL STRITCH UNIVERSITY

 

4

 

4-Year

005244

 

KY TECH-CENTRAL KY STATE VOCATIONAL

 

2

 

2-Year

003125

 

UNIVERSITY OF CINCINNATI

 

4

 

4-Year

001523

 

ST. JOHNS RIVER COMMUNITY COLLEGE

 

4

 

4-Year

002063

 

COMMUNITY COLLEGE OF BALTIMORE COUNTY

 

2

 

2-Year

003759

 

J SARGEANT REYNOLDS COMM. COL.

 

2

 

2-Year

010727

 

DEVRY UNIVERSITY

 

4

 

4-Year

001397

 

UNIVERSITY OF NEW HAVEN

 

4

 

4-Year

002114

 

AMERICAN INTERNATIONAL COLLEGE

 

4

 

4-Year

011626

 

WESTWOOD COLLEGE

 

4

 

4-Year

038094

 

MICROPOWER CAREER INSTITUTE

 

T

 

Proprietary

021004

 

EVEREST INSTITUTE

 

2

 

2-Year

021005

 

CLINTON TECHNICAL INSTITUTE

 

2

 

2-Year

001147

 

CALIFORNIA STATE UNIVERSITY

 

4

 

4-Year

011024

 

BRYMAN COLLEGE

 

T

 

Proprietary

001137

 

CALIF STATE U FULLERTON

 

4

 

4-Year

033943

 

REMINGTON COLLEGE

 

4

 

4-Year

001138

 

CALIFORNIA STATE UNIVERSITY

 

4

 

4-Year

004494

 

BRYMAN COLLEGE

 

4

 

4-Year

001005

 

ALABAMA STATE UNIVERSITY

 

4

 

4-Year

001940

 

SOUTHWESTERN COLLEGE

 

4

 

4-Year

001371

 

UNIVERSITY OF DENVER

 

4

 

4-Year

 

 

Exhibit B

 

School ID

 

School Name

 

School Type

 

Loan Tape
School Type

 

 

 

 

 

 

 

001360

 

METROPOLITAN STATE COLLEGE OF DENVER

 

4

 

4-Year

025400

 

TENNESSEE ACADEMY OF COSMOTOLOGY

 

T

 

Proprietary

003993

 

MIDLANDS TECHNICAL COLLEGE

 

2

 

2-Year

004673

 

BAKER COLLEGE

 

4

 

4-Year

002328

 

WASHTENAW COMMUNITY COLLEGE

 

2

 

2-Year

002267

 

GRAND RAPIDS COMMUNITY COLLEGE

 

2

 

2-Year

002303

 

OAKLAND COMMUNITY COLLEGE

 

2

 

2-Year

003404

 

JOHNSON & WALES UNIVERSITY

 

4

 

4-Year

003726

 

AMERICAN NATIONAL UNIVERSITY

 

4

 

4-Year

023344

 

CENTURA COLLEGE

 

4

 

4-Year

021151

 

BUTLER BUSINESS SCHOOL

 

T

 

Proprietary

003213

 

PORTLAND COMMUNITY COLLEGE

 

2

 

2-Year

001074

 

GRAND CANYON UNIVERSITY

 

4

 

4-Year

001807

 

INDIANA STATE UNIVERSITY

 

4

 

4-Year

025042

 

WALDEN UNIVERSITY

 

4

 

4-Year

002329

 

WAYNE STATE UNIVERSITY

 

4

 

4-Year

000000

 

CLAIMS PROCESSING SCHOOL

 

NULL

 

Consolidation

001459

 

STRAYER UNIVERSITY

 

4

 

4-Year

002447

 

WILLIAM CAREY COLLEGE

 

4

 

4-Year

002377

 

ST. CLOUD STATE UNIVERSITY

 

4

 

4-Year

001669

 

DANVILLE AREA COMMUNITY COLLEGE

 

2

 

2-Year

010727

 

DEVRY UNIVERSITY

 

T

 

Proprietary

001164

 

CHAPMAN UNIVERSITY

 

4

 

4-Year

001707

 

LEWIS UNIVERSITY

 

4

 

4-Year

 

 

Exhibit C

 

ECMC Interest Rate Document

 

FFEL “Converted” Variable-rate Stafford Loan Interest Rates for the Period July 1, 2020 through June 30, 2021

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

(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
7/1/20 – 6/30/21

 

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)

 

0.13

%

3.25

%

3.38

%

10

%

3.38

%

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)

 

0.13

%

3.1

%

3.23

%

7

%

3.23

%

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)

 

0.13

%

3.1

%

3.23

%

8

%

3.23

%

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)

 

0.13

%

3.1

%

3.23

%

9

%

3.23

%

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)

 

0.13

%

3.1

%

3.23

%

10

%

3.23

%

 

Page 1

June 30, 2020

 

 

Exhibit C

 

FFEL “Converted” Variable-rate Stafford Loan Interest Rates for the Period July 1, 2020 through June 30, 2021

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

(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
7/1/20 – 6/30/21

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

FFEL Regular Variable-rate Stafford Loan Interest Rates for the Period July 1, 2020 through June 30, 2021

(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
7/1/20 – 6/30/21

 

“New” Borrower (SE/XE EVAR)

 

10/1/92

 

7/1/94

 

§427A(e)(1)

 

 

 

0.13

%

3.1

%

3.23

%

9

%

3.23

%

“New” Borrower (SE/XE EVAR)

 

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

 

 

 

§427A(e)(1)

 

 

 

0.13

%

3.1

%

3.23

%

9

%

3.23

%

 

 

7/1/94

 

7/1/95

 

§427A(f)(1)

 

 

 

0.13

%

3.1

%

3.23

%

8.25

%

3.23

%

 

Page 2

June 30, 2020

 

 

Exhibit C

 

FFEL “Converted” Variable-rate Stafford Loan Interest Rates for the Period July 1, 2020 through June 30, 2021

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

(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
7/1/20 – 6/30/21

 

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

 

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

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Page 3

June 30, 2020

 

 

Exhibit C

 

FFEL Regular Variable-rate Stafford Loan Interest Rates for the Period July 1, 2020 through June 30, 2021

(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
7/1/20 – 6/30/21

 

All Borrowers (regardless of prior borrowing)

 

7/1/95

 

7/1/98

 

§427A(g)(2)
(SH/XH EVAR)

 

In-school, grace and deferment periods

 

0.13

%

2.5

%

2.63

%

8.25

%

2.63

%

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

§427A(f)(1)
(SG EVAR)

 

All other periods

 

0.13

%

3.1

%

3.23

%

8.25

%

3.23

%

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)

 

In-school, grace and deferment periods

 

0.13

%

1.7

%

1.83

%

8.25

%

1.83

%

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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

 

All other periods

 

0.13

%

2.3

%

2.43

%

8.25

%

2.43

%

 

Page 4

June 30, 2020

 

 

Exhibit C

 

FFEL Variable-rate PLUS and SLS Loan Interest Rates for the Period July 1, 2020 through June 30, 2021

(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
7/1/20 – 6/30/21

 

PLUS/SLS*
(SD VAR)

 

 

 

10/1/92

 

§427A(c)(4)(B)

 

 

 

0.17

 

3.25

%

3.42

%

12

%

3.42

%

SLS*
(SE/XE EVAR)

 

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

 

 

 

§427A(c)(4)(D)

 

 

 

0.17

 

3.1

%

3.27

%

11

%

3.27

%

PLUS*
(SE EVAR)

 

10/1/92

 

7/1/94

 

§427A(c)(4)(D)

 

 

 

0.17

 

3.1

%

3.27

%

10

%

3.27

%

PLUS
(SG EVAR)

 

7/1/94

 

7/1/98

 

§427A(c)(4)(E)

 

 

 

0.17

 

3.1

%

3.27

%

9

%

3.27

%

PLUS*
(SH EVAR)

 

7/1/98

 

1/1/2000

 

§427A(j)(3) 
§427A(k)(3)

 

0.13

%

 

 

3.1

%

3.23

%

9

%

3.23

%

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

 

1/1/2000

 

7/1/2006

 

§427A(k)(3)

 

0.13

%

 

 

3.1

%

3.23

%

9

%

3.23

%

 

*          These loans will not be subject to special allowance payments during the four quarters ending 9/30/20, 12/31/20, 3/31/2021, and 6/30/2021. See Sections 438(b)(2)(C)(i); 438(b)(2)(C)(ii); 438(b)(2)(G)(v); and 438(b)(2)(H)(v) of the Higher Education Act of 1965, as amended.

 

Page 5

June 30, 2020

 

 

Exhibit C

 

FFEL Variable-rate and Fixed-rate Consolidation Loan Interest Rates for the Period July 1, 2020 through June 30, 2021

(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 6

June 30, 2020

 

 

Exhibit C

 

FFEL Variable-rate and Fixed-rate Consolidation Loan Interest Rates for the Period July 1, 2020 through June 30, 2021

(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, 2020 through June 30, 2021 the interest rate for these loans is 0.13 percent plus 3.10 percent or 3.23 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 7

June 30, 2020

 

 

Exhibit C

 

FFEL Variable-rate and Fixed-rate Consolidation Loan Interest Rates for the Period July 1, 2020 through June 30, 2021

(Table 4)

 

COHORT

 

CITATION

 

INTEREST RATE FORMULA

 

 

 

 

 

 

Consolidation Loans for

 

 

 

 

 

 

 

 

 

 

Consolidation Loans for

 

Which the Loan

 

 

 

 

 

 

Consolidation

 

Consolidation

 

Which the Loan Application

 

Application Was

 

Higher Education

 

 

 

 

Loans Made On

 

Loans Made

 

Was Received by an Eligible

 

Received by an Eligible

 

Act of 1965, As

 

Method Used to Determine

 

 

or After

 

Before

 

Lender On or After

 

Lender Before

 

Amended

 

Interest Rate

 

Maximum Rate

HEAL Portion of the Consolidation Loan

 

 

 

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, 2020 through June 30, 2021 the interest rate for these loans is 0.15 percent plus 3.00 percent or 3.15 percent.) There is no maximum rate on this portion of the loan.

 

N/A

 

Page 8

June 30, 2020

 

 

Exhibit C

 

FFEL 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/LJ)

 

6.80

 

6.00

 

5.60

 

 

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

 

6.80

 

6.80

 

6.80

 

Unsubsidized Stafford

 

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

 

6.80

 

6.80

 

6.80

 

 

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

 

6.80

 

6.80

 

6.80

 

PLUS Loans

 

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

 

8.50

 

8.50

 

8.50

 

 

Page 9

June 30, 2020