IRA SOHNCONFERENCE

Presentation by Steve Eisman

SUBPRIME GOES TO COLLEGE
May 26,2010

Good Afternoon. I would like to thank the Ira Sohn Foundation for the honor of speaking
before this audience. My name is Steven Eisman and I am the portfolio manager of the
FrontPoint Financial Services Fund.Untilrecently, I thought that there would never
again be an opportunityto beinvolved with anindustry as socially destructive and
morally bankrupt as the subprime mortgageindustry. I was wrong. The For-Profit
Education Industry has proven equal to the task.

The title of my presentation is "Subprime goes to College". The for-profit industry has
grown at an extreme and unusual rate, driven by easy access to government sponsored
debt in the form of Title IV student loans, where the credit is guaranteed by the
government. Thus, the government, the stUdents and the taxpayer bear all the risk and the
for-profit industry reaps all the rewards. This is similar to the subprime mortgage sector
in that the subprime originators borefar less risk thah the investors in their mortgage
i·
paper.

In the past 10 years, the for-profit educationindustryhas grown 5-10 times the historical
rate of traditional post secondary education. As of 2009, the industry had almost 10% of
the emolled students but claimed nearly 25% of the $89 billion of Federal Title IV
student loans and grant disbursements. At the current pace of growth, for- profit schools
will draw 40% of all Title IV aid in 10 years.

How has this been allowed to happen?

The simple answer is that they've hired every lobbyist in Washington D.C. There has
been a revolving door between the people who work or lobby for this industry and the
halls of government. One example is Sally Stroup. She was the head lobbyist for the
Apollo Group - the largest for-profit company in 2001-2002. But from 2002-2006 she
became Assistant Secretary of Post-Secondary Education for the DOE under President
Bush. In other words, she was directly in charge of regulating the industry she had
previously lobbied for.

From 1987 through 2000, the amount oftotal Title IV dollars received by students of for-
profit schools fluctuated between $2 and $4 billion per annum. But then when the Bush
administration took over the reigns of government, the DOE gutted many of the rules that
governed the conductof this industry. Once the floodgates were opened, the industry
embarked on 10 years of umestricted massive' growth.

[Federal dollars flowing to the industry exploded to over $21 billion, a 450% increase. ]

At many major-for profit institutions, federal Title IV loan and grant dollars now
comprise close to 90% of total revenues, up significantly vs. 2001. And this growth has

1
driven even more spectacular company profitability and wealth creation for industry
executives. For example, ITT Educational Services (ESI), one of the larger companies in
the industry, has a roughly 40% operating margin vs. the 7%-12% margins of other
companies that receive major governmentcoritracts. ESI is more profitable on a margin
basis than even Apple.

This growth is purely a function of government largesse, as Title IV has accounted for
more than 100% of revenue growth. Here is one ofthe more upsetting statistics. In fiscal
2009, Apollo, the largest company in the industry, grew total revenues by $833 million.
Of that amount, $1.1 billion came from Title IV federally-funded student loans and
grants. More than 100% of the revenue growth came from the federal government. But
of this incremental $1.1 billion in federal loan and grant dollars, the company only spent
an incremental $99 million on faculty compensation and instructional costs - that's 9
cents on every dollar received from the government going towards actual education. The
rest went to marketing and paying the executives.

But leaving politics aside for a moment, the other major reason why the industry has
taken an ever increasing share of governinent dollars is that it has turned the typical
education model on its head. And here is where the subprime analogy becomes very
clear.

There is a traditional relationship between matching means and cost in education.

Typically, families of lesser financial means seek lower cost institutions in order to
maximize the available Title IV loans and grants - thereby getting the most out of every
dollar and minimizing debt burdens. Families with greater financial resources often seek
higher cost institutions because they can afford it more easily.

The for-profit model seeks to recniit those with the greatest financial need and put them
in high cost institutions. This formula maxiniizes the amount of Title IV loans and grants
that these students receive.

With billboards lining the poorest neighborhoods in America and recruiters trolling
casinos and homeless shelters (and I mean that literally), the for-profits have become
increasingly adept at pitching the dream of a better life and higher earnings to the most
vulnerable of society.

But if the industry in fact educated its students and got them good jobs that enabled them
to receive higher incomes and to pay off their student loans, everything I've just said
would be irrelevant.

So the key question to ask is - what do these students get for their education? In many
cases, NOT much, not much at all.

Here is one of the many examples of an education promised and never delivered. This
article details a Corinthian Colleges-owned Everest College campus in California whose
students paid $16,000 for an 8-month course in medical assisting. Upon nearing

2
 completion, the students learned that not only would their credits not transfer to any
community or four-year college, but also that their degree is hot recognized by the
American Association for Medical Assistants. Hospitals refuse to even interview
graduates.

But let's leave aside the anecdotal evidence of this poor quality of education. After all
the industry constantly argues that there will always be a few bad apples. So let's put
aside the anecdotes and just look at the statistics. If the industry provided the right
services, drop out rates and default rates should be low.

Let's first look at drop out rates. Companies don't fully disclose graduation rates, but
using both DOE data, company-provided information and admittedly some of our own
assumptiOhS regarding the level of transfer students, we calculate drop out rates of most
schools are 50%+ per year. As seen on this table, the annual drop out rates of Apollo,
ESI and COCO are 50%.,100%

How good could the product be if drop out rates are so stratospheric? These statistics are
quite alarming, especially given the enormous amounts of debt most for-profit students
must borrow to attend school.

As a result of these high levels of debt, default rates at for profit schools have always
been significantly higher than cot1inlunity colleges or the more expensive private
institutions. .

We have every expectation that the industry's default rates are about to explode.
Because of the growth in the industry and the increasing search for more students, we are
. now back to late 1980s levels of lending to for· profit students on a per student basis.
Back then defaults were off the charts and fraud was commonplace.

Default rates are already starting to skyrocket. It's just like subprime - which grew at
any cost and kept weakening its underwriting standards to grow.

By the way, the default rates the industry reports are artificially low. There are ways the
industry can and does manipulate the data to make their default rates look better.

But don't take my word fbr it The industry.is quite clear what it thinks the default rates
truly are. ESI and COCO supplement Title IV loans with their own private loans. And
they provision 50%-60% up front for those loans. Believe me, when a student defaults
on his or her private loans, they are defaulting on their Title IV loans too.

[Let me just pause here for a second to discuss manipulation of statistics. There are two
key statistics. No school can get more than 90% of its revenue from the government and
2 year cohort default rates cannot exceed 25%for J consecutive years. Failure to comply
with either of these rules and youJose Title IV eligibility.. Lose Title IV eligibility and
.you're company's a zero. . . . ... .

3
Isn't it amazing that Apollo's percentage of revenue from Title IV is 89% and not over
90%. How lucky can they be? We believe (and many recent lawsuits support) that
schools actively manipulate the receipt, disbursement and especially the return of Title IV
dollars to their students to remain under the 90/1 0 threshold.]

The bottom line is that as long as the government continues to flood the for profit
education industry with loan dollars AND the riskior these loans is borne solely by the
students and the government, THEN the industry has every incentive to grow at all costs,
compensate employees based on enrollment, influence key regulatory bodies and
manipulate reported statistics - ALL TOMAINTAIN ACCESS TO THE
GOVERNMENT'S MONEY.

In a sense, these companies are marketing machines masquerading as universities. And

when the Bush adminis:tration eliminated almost all the restrictions on how the industry is
allowed to market, the machine went into overdrive. [Let me quote a bit from a former
employee of BPI.

"Ashford is a for profit school and makes a majority of its moneyon federal loans students take out. They convenientfy
price tuition at the exact amount that a student can qualify for in federal loan money. There is no regard to whethera
stu(1ent realfy belongs in school, the goal is to enrott as many as possible. They also go after GI bifl money and currentfy
have separate teams set up to specifically target military students. If a person has money available for school Ashford
finds a way to go alter them. Ashford is just the middle man, profiting off this money, like milking a cow and working the
system within the limits of what's technically legal, and paying huge salaries white the student suffers with debt that can't
even be forgiven by bankruptcy. We mention tuition prices as little as possible .. this may cause the student to change
their mind.

While it is illegal to pay commissions for student enrollment, Ashford does salary adjustments, basically the same thing.
We are given a matrix that shows the number of students we are expected to enrolt. We also have to meet our quotas
and these are high quotas.

Because we are under so much pressure, we are forced to do anything necessary to get people to fiff out an application -
our jobs depend on it.

It's a boiler room - selling education to people who realty don't want it. "

This former employee then gives an example of soliciting a sick old lady to sign up for Ashford to
meet his quota. . .

"The level of deception is disgusting- and wrong. When someone who can barely afford to live and feed kids as it is, and
doesn't even have the time or education to be able to enroft, they drop out. Then what? Add $20,000 of debt to their
problems - what are they gonna do now. They are officially screwed. We know most of these people wift drop out, but
again, we have quotas and we have no choice. " 1

How do such schools stay in business? The answer is to control the accreditation
process. The scandal here is exactly akin to the rating agency role in subprime
securitizations.

There are two kinds of accreditation -- national and regional. Accreditation bodies are
non-governmental, non-profit peer-reviewing groups. Schools must earn and maintain
proper accreditation toremain eligible for Title IV programs. In many instances, the for-
profit institutions sit on the boards of the accrediting body. The inmates run the asylum.

Historically, most for profit schools are nationally accredited but national accreditation
holds less value than regional accreditation. The latest trend of for profit institutions is to

4
 acquire the dearly coveted Regional Accr~ditation through the outright purchase of small,
financially distressed non-profit institutions and then put that school on-line. In March
2005, BPI acquired the regionally accredited Franciscan University of the Prairies and
renamed it Ashford University. [Remember Ashford. The former employee I quoted
worked at Ashford.] On the date of purchase, Franciscan (now Ashford) had 312
students. BPI took that school online and at the end of2009 it had 54,000 students.

SOLUTIONS

While the conduct of the industry is egregious and similar to the subprime mortgage
sector in just so many ways, for the investment case against the industry to work requires
the governinent to do something -- whereas in subprime all you had to do was wait for
credit quality to deteriorate.

So what is the government going to do? It has already announced that it is exploring
ways to fix the accreditation process, It will probably eliminate the 12 safe harbor rules
on sales practices implernented bythe BushAdministration. And I hope that it is looking
at everything and anything to deal with this industry...

Most importantly, the DOE has proposed a rule known as Gainful Employment. In a
few weeks the DOE will publish the rule. There is some controversy as to what the
proposed rule will entail but I hope that the DOEwill not backtrack on gainful
employment. Once the rule is published in the federal registrar, the industry has until
November to try to get the DOE to back down.

The idea behind the gainful employment rule is tolirilitstudent debt to a certain level.
Specifically, the suggested rule is that the debt service-to-income-ratio not exceed 8%.
The industry has gotten hysterical over this rule because it knows that to comply, it will
probably have to reduce tuition.

[Before I turn to the impact of the rule, let me discuss what happened last week. There
was a news report out that Bob Shireman, the Under Secretary of Education in charge of
this process was leaving. This caused a massive rally in the stocks under the thesis that
this signaled that the DOE. was backing down from gainful employment. This conclusion
is absurd. First, of aU, inside D.C. it has been well known for a while that Shireman
always intended to go home to California after a period of time. Second, to draw a
conclusion about the DOE changing its policy because Shireman is leaving presupposes
that one government official, one man, drives the entire agenda of the U.S. government.]

I cannot emphasize enough that gainfulemploymentchanges the business model. To

date that model has been constant growth in the number of students coupled with
. occasional increases in tuition. Gainful emploYment will cause enrollment levels to grow
less quickly. And the days of raising tuition would be over; in many cases, tuition will go
down.

5
 To illustrate the impact of gainful employment, I've chosen 5 companies, Apollo, ESI,
COCO, EDMC and the Washington Post. Yes, the Washington Post, whose earnings are
all driven by this industry.

Assuming gainful employment goes through, the first year it would impact would
obviously be 2011. However, because the analysis is so sensitive to tuition levels per
school, it's best to have as much information as possible. So for analytical purposes, we
are going to show the impact on actual results in fiscal 2009 and this year's estimates
under the assumption that gainful employment was already in effect.

We employ 2 scenarios. Scenario 1 is static. It takesactual·results and then reduces

tuition costs to get down to the 8% level. Scenario 2 is dynamic. It assumes the same
thing as scenario 1 but then assumes the companies can reduce costs by 5%-15%.

Results for each company depend largely on the mix of students, the duration of each
degree and the price of tuition at each institution

For each company, I show the results under the two scenarios and the corresponding
PIEs. Needless to say, the PIE multiples look quite a bitdifferent under either scenario.

Apollo - In fiscal 2009, the company earned $4.22. The consensus estimate for fiscal
2010 is $5.07. Under scenario 1, fiscal 2009 and the fiscal 2010 estimate get cut by 69%
and 57%, respectively. Under scenario 2, it gets cut 50% and 41 %, respectively.

.ESI - In fiscal 2009, the company earned $7.91. The consensus estimate for fiscal 2010
is $11.05. Under scenario 1, fiscal 2009 turns slightly negative and the fiscal 2010
. estimate.gets cut by 74%. Under scenario2, fiscal 2009 declines by 75% and·the2010
estimate gets cut by 53%.

COCO - In fiscal 2009, the company earned $0.81. The consensus estimate for fiscal
2010 is $1.67. Under scenario 1, fiscal 2009 turns negative and the fiscal 2010 estimate
gets cut by 94%. Under scenario 2, fiscal 2009 declines by 79% and the 2010 estimate
gets cut by 38%.

EDMC -- in fiscaI200~, the company earned $0:87. The consensus estimate for fiscal
2010 is $1.51. Under scenario 1, fiscal 2009 and the fiscal2010 estimate turns massively
negative. Under scenario 2, fiscal 2009 and the fiscal 2010 estimate are also massively
negative, just less massively than scenario 1.· The principal reason why the numbers are
so bad for EDMC is that they have a lot of debt and that debt has to be serviced and
cannot be cut.

Washington Post - The Post's disclosure of Kaplan metrics is slight. Thus, analyzing the
impact from gainful employment is much more difficult andwe have confined our·
analysis solely to fiscal 2009. In fiscal 2009, WPO earned $9.78. Under scenario 1, a
loss of $33.25 per share occurs. Under scenario 2, there is still a loss of $6.19. The

6
principal reason why the numbers are so bad for the Post is that more than 100% of its
EBIDTA comes from this industry through its Kaplan division.

[Let me just add one caveat to our analysis. Implementation of gainful employment
could result in a cut in Illarketingbudgets. Given the high drop out rates ofthis industry
any such cuts could turn a growth industry into a shrinking industry. The numbers that I
just showed do not assume that theindustry shrinks but grows at a slower pace.]

Under gainful employment, most of the companies still have high operating margins
relative to other industries. They are just less profitable and significantly overvalued.
Downside risk could be as high as 50%. And let me add that I hope that gainful
employment is just the beginning. Hopefully, the DOE will be looking into ways of
improving accreditation and of ways to tighten rules on defaults.

Let me end by driving the subprime analogy to its ultimate conclusion. By late 2004, it
was clear to me and my partners that the mortgage industry had lost its mind and a
society-wide calamity was going to occur.· It was like watching a train wreck with no
ability to stop it. Who could you complain to? -- The rating agencies? - they were part
of the machine. Alan Greenspan? -he was busy making speeches that every American
should take out an ARM mortgage loan. The aCC? -- its chairman, John Dugan, .was
busy suing state attorney generals, preventing them from even investigating the subprime
mortgage industry.

Are we going to do this all over again? We just loaded up one generation of Americans
with mortgage debt they can't afford to pay back. Are we going to load up a new
generation with student loan debt they can never afford to pay back. The industry is now
25% of Title IV money on its way to 40%. If its growth is stopped now and it is policed,
the problem can be stopped. It ismy hope that this Administrationsees the nature of the
problem and begins to act now. If the gainful employment rule goes through as is, then
this is only the beginning ofthe policing of this industry.

But if nothing is done, then we are on the cusp of a new social disaster. If present trends
continue, over the next ten years almost $500 billion of Title IV loans will have been
funneled to this industry. We estimate total defaults of $275 billion, and because of fees
associated with defaults, for profit students will owe $330 billion on defaulted loans over
the next 10 years. .

[Bracketed Sections might be deleted during the verbal speech because oflack of time.]

7
 Ira Sohn C·onference
Presentation by Steven Eislllan
.FrontPoint Partners
May 26,2010
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.'•
•
 . . . ,

Inthe last 10 years, the for-profit education industry has grown at 5-10 times the
historical rate of traditional post-secondary education

Annual enrollment growth of Total U.S. postsecondary institutions vs. For profit institutions

I _Total industry enrollment growth - For-profit enrollment growth I

25% I I

20%

. ·15%

10%

5%

0%
1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Source: National Center for Education Statistics, 2009

5
 Which has drastically accelerated the for-profit's share of total US post-secondary
enrollments and led to the rapid growth of for-profit institutions

In 1990...
< 1 % of all students attended < 10% of all schools
for-profit colleges... were for-profit. ..

For profit students as a % of total U.S. postsecondarvstudents For profit institutions as a % of total u.S. postsecondary institutions
9'" I I 30% I I

8%

25%
7%

6%
20%

5%

15%
4%

3%
10%

2%

1%1-,- - - - - -iF - -,. -,-,- - - - - - -I ~I .,.,.,R'·'·'·'_'·'·'·'·'·'·'·'·'·'_I_I

~~~~~~~~~~~$~~~~~~~~
~~~~~~~~~~~~~~~~~~~~ ~ ~ ~ ~. ~ ~ ~ ~ ~ ~. ~ v ~ ~ ~ ~ ~ ~ ~ ~
~ ~- ~ ~ ~ ~. ~. ~ ~ ~- ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

In 2009...
almost 10% of students 25% of schools are
. attend for-profit colleges for-profit institutions

Source: National Center for Education Statistics, 2009

6
Despite being less than 10% of total enrollments, for-profits now claim nearly
25% of the $89 billion of Federal Title IV student loans and grant disbursements

For-profit share of Title IV disbursements (Pell grants and Federal stafford loans), 1998 ·2009
27%
26%
In 2009,For-Profitschools collected $4.4 billion of the $18.2 billion
25%
in Federal Pell Grants, or about 24% of all Pell Grant funding -
24% double the proportion from ten yeats ago.
·23%
22%
21%
20%
19%
18%,
17%
16%
15%
.14%
13%
12%
11%
10%
9%
8%
7%
1998 1999. 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

• Pall grants • Subsidized stafford loans 0 Unsubsidized stafford loans

Source: College Board, NCLC

7
How is this possible?! The for-profit industry has bought almost every lobbyist,
and has infiltrated the highest levels of government... a prime example

Sally Stroup was a pivotal player in the deregulation of the for-profit indiJstry...
because she worked for the for-profit industry

, Sally Stroup Biography:

.' 2001 - 2002: Director of Industry and Government Affairs for the Apollo Group
(top lobbyist for APOL)

• 2002 - 2006: Assistant Secretary for Postsecondary Education, U.S. Dept of

• Education (top postsecondary ediJcationposition)

.: 2006- 2008: GOP Deputy Staff Director, U.S. House of'R.epresentatives

, ,Committee on Education and Labor (largest recipient of political contribution$ from
,', , ' for-profit educatio~ industry)' ",' " '

• ,2008 - Present: GOP Staff Director, U.S. House of Representatives Committee on

Education and Labor

...and not surprisingly, her colleagues at the Dept of Education were all driven by similar goals
Name Former DOE position .____ Current lobbying Firm For-profit Education client
WlUlam Hansen Deputy secretary of Eductaion, 2001 .. 2003 Chartwell Education Group APOLLO GROUP

Jonathan Vogel Deputy Counsel to the Department of ED, 2002 - 2005 Sonnenschein, Nath & Rosenthal GRAND CANYON UNIVERSITY

Lauren Maddox DOE Asst Sec for Communications, 2006 .. 2008 Podesta Group CAREER EDUCATION CORP

Rebecca Campoverde DOE Asst Sec for Congressional & Legislative affairs, 2005 .. 2008 Kaplan, Inc, KAPLAN, fNC

Victor F. Klatt III GOP Staff Director for House ED and Labor, 2005 .. 2008 Van Scoyoc Associates APOLLO GROUP

8
From 1987 through 2000, the amount of total Title IV dollars given to for-profit
schools fluctuated between $2 billion and $4 billion dollars...

Total Federal disbursements of Title IV Stafford Loans and Pel! Grants. 1987 - 2009
Dollars in billions
Total Total For profit For profit Total For profit share For profit share
Year Pell Grants Stafford Loans Pell Grants Stafford Loans For profit Pell Grants Stafford Loans
1987 $3.5 $7:3 $0.9 $1.8 $2.7 25% 25%
1988 $3.8 $8.0 $1.0 $2.1 $3~1 27% 27%
1989 $4.5 $8.2 $1.1 $2.3 $,3.4 24% 28%
1990$4.8 $8.3 $1.1 $L9 $3.0 23% 23%
1991 $4.9 $8.8 . $1.1 $1.5 $2.6 22% 17%
1992$5.8 $9.5 $1.2 $1.3 $2.5 21% 14%
1993 $6.2 $9.9 . $1.1 $1.0 $2.1 18% 10%
1994 $5.7 $14.1 $0.9 $1.4 $2.3 15% 10%
1995 $5.5 $19.9 $0.7 $2.0 $2.7 13% 10%
1996$5.5 $22.8 $0.7 $1.9 $2.6 13% 8%
1997$5.8 .$25.1 $0.7 $2.2 $2.9 12% 9%
1998 . $6.3 $26.3 $0.8 $2.3 $3.0 12% 9%
1999 $7.2 $27.2 . $0.9 $2.6 $3.5 13% 10%
$0]. ...---.
2000 $7.2 $28.4 $3.0 $3.9. 13% 10%

Pefl Grants Total Title IV aid grew from

quadrupled from $1 under $4 billion in 2000 to over
billion to $4 billion $21 billion in 2009

.. .but with the leniency shown to the industry under the Bush Administration, the
dollars that flowed to the industry ~loded to over $21 billion, a 450 % increase
9
Source: College Board
At the CUrrent pace of growth, For..;profit schools will claim 200/0 of enrollments,
represent 40% of schools and draw over 40% of all Title IV aid in 10 years

For-profit share of enrollment. schools, Pell grants and Loans, 2009 - 2020

For::profrts % share of:

Total· Totar Pel! Staffofd Total Total Title IV disburSements ($ billions)
Year Enrollment Schools Grants . Loans Title IV Non::Pfofits FOf::PfOfits
2007· 7% 23% 19% 19% 19% . $50.2 $12.0
2008 8% 24% 21% 22% 22% $56.0 $15.5
iVA! = 25%
1
)
?'

2010 9% 26% 25% 25% $71.9 $24.3

2011 10% 27% 26% 27% 27% $76.5 $27.7
20)4 10% 29% 27% 28% 28% $81.2 $31.5
2013 '.. 11% 30% 28% 30% 29% . $86,2 $35.8
2014 12% ·31% 30% 31% 31% ~91.4 $40.8
201~ 13% 32% 31% 33% 32% $96.9 $46.4
2016 ., .. 14% 34% 32% .35% 34% $102.5 $52.8
2017 . 16% 35% 33% 36% 36% $108.4 $60.1
2M8 17% 37% 35% 38% 38% $114.4 $68.5
2019 18% 39% 36% 40% 40% $120.6 $77.9

Key Assumptions for Proiectlons Based on current financials of For-profit

institutions, Jess than 30% of the
. Total post-secondary enrollment grows at 1.5% per year incremental $67 billion (annuallY) in
For-profit enrollment grows at 10% per year (10-yr avg is 14.4% Title IV dollars will go towards
annually)
educating students...
Total post-secondary institutions grow at 1.5% per year; For-profit
institutions grow at 6% per year (both'long-term avg since 1990)
... nearly $50 billion (annuallY) will go
Avg grant and loan amounts per student grows at 5-yr historical avg
growth rates, by institution type
toward non-facultv and executive
compensation and company profits
10
Source: College ,Board, US Dept of Education, industry estimates
At many major for-profit institutions, federal Title IV loan and grant dollars now
comprise close to 90% of total revenues

Title IV,
Apollo'Group Other, 48%
52%

Title IV,
89%

ITT Technical
Institute
Title IV,
65%

Note:. Title IV figures include 2008 unsubsidized loan limit increases on a pro-forma basis

Source: Company-reported financials 11

This growth has driven even more spectacular company profitability and wealth
creation for industry executives and shareholders

ITT Technical Institute (ESI) Profitability has grown 5-fold since 2006

ESI operating margin 0/0, Q106 - Q409 ESI operating profit ($ millions), Q106 - Q409
~/.I ~--------_"":_----------------l' $165
$155
$145
~/o
$135
$125
36% $116
$105
30% $96
$85

::.
$75

:: ..
25%
$65

20%

.16% ~ , " , i ,. I I , I .1
. I
~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~.~ ~ ~ ~ ~ ~# ,p~ ,p~ ...o~
: ",0:~ ..,0:~ ~~ ....0~ ~. ~.~ ~ ~ ~ ~
: ",0:..,0: .,p ....o: ",0' ..,0' ,p
,,0: ",0: ..,0: 'f>.0:,,0: ",0: ..,0: 'f>.0: ,,0: ",0: ..,0: ~ .....0 : .",0: ..,0: ,p ....0 : '\)

Th& top 5 executives at ESI, Corinthian colleges (COCO) and Apollo Group (APOl)
collectively earned over $130 million from'2007-2009

Top 5 executives total compensation

ESI COCO APOL Total
2007 $9,834,695 $4,938,982 $10,441,170 $25,214,847
2008 $8,923,791 $8,849,386 $26,766,979 $44,540,156
2009 $14,366,540 $11,222,377 $34,707,377 $60,296,294

~"t:_ri¥~~~m~F~""'5iB!?CO·17.i:~5"~ie;;,iB;i:~OTI'l~
~.f1/!J);Q, ":s-:. ~~~E:~>o/-~~~~~. :~.: '.. :~ .. ·..:.. _~~I~· ,~~,.~._~~m~ ~~-~~~~--:.¥-~.

Total comp =salary, bonus, stock awards, option awards, non-equity incentives

Source: Company-reported financials and proxy statements 12

Now manY of the US for-profit education companies are among the most profitable
businessesinlhe world

Other industries ,of strategic importance to the U.S.

which are funded by taxpayer dollars are restricted
to lower operating margins on contracts••.

2009 COrJ1lany Operating Margins 5.year Average CompanyOperating Margins, 20()5.. 2009
45% 35%

40%1
35%

30%

25%
-37.4% 30%1

25%

20%
29.0%

20% 15%
15%
10%
10%
5%
5%

0% 0%
ITT Technical Lockheed Raytheon Corp Northrup Boeing ITT Technical Apple Procter & Lockheed Home Depot
Institute Martin Grumman Institute Computer Gamble Martin

So how can Title IV-funded education companies

earn substantially more money than nearly evety
other major US business?

Source: Company-reported financials and proxy statements 13

This growth however, is primarily a function of government largesse, as Title IV
has accounted for more than 100% of the revenue growth of these companies
Apollo Group (APOL) 2007 2008 2009
Total revenues $2,724 $3,141 $3,974
Year-year growth $417 C§ More than 100% of the
% revenue from Title IY* 65% 77% 89%
revenue growth of APOL,
Title IV revenues $1,770 $2,419 $3537 COCO and ESI is driven by
Year-yetlr growth $648 ($1,119
an increase in Federal Title
~1'el§mf~mtltl~_~~~~~~~~1~~~§S~5@~] IV dollars...

Corinthian Colleges (COCO) 2007 2008 2009

Total revenues $919 $1,069 $1,308
Year-year growth . $149 $239
% revenue from Title IY* 75% ·81% 89%
...and of this incremental
Title IV revenues $691 $866 $1,163 $1.1 billion in Title IV and
Year-year growth $174 $297
$833.miUion in revenues,
.&mt~~~IDt~~~l~¥~
ONLY $99 million or 9%
was spent on ed ucational
ITT Technical Institute (ESI) 2007 2008 2009
Total revenues $758 $870 $1,015
expenses like faculty
Year-year growth $112 $146 compensation and other
% revenue from Title IV* 63% 73% 85%
instructional costs
Title IV revenues $477 $635 $863
Year-year growth $157 $228

~#if&"y.~If_;:!!~~~=:~~~~~il11(~-W~&~
Dollars in millions
*Title IV % includes 2008 Stafford unsubsidized loan limit increases

Source: Company-reponed financials 14

But how do they do it? How are for-profit schools grabbing such a growing share of
Title IV dollars?

Traditional relationship - Matching Means with Costs

Families with greaterneeds generally seek lower-cost Families with greater financial resources often seek higher-
institutions to maximize the available Title IV loans and cost institutions becausethey can afford to pay in excess of
grants, getting the most out ofevery dollar to reduce. out- what Title IV loans cover These families typically are not
of~pocket expenses and minimize heavy debt burdens... eligible for grants because of their higher-income status.

LesserM.eans Greater Means

(Low-Mid Income Families) (High Income Families)

•••
Low Cost institutions
(Community College o~ In:-State School)
•
High Cost Institutions
(Private Colleges)

For-profit Model - Max Cost with Minimal Means

Lesser Means The for-profit model has consciously separated the

(Low-Mid Income Families) traditional relationship between costs and means. They
seek to recruit those with the greatest financial needs and

I •
High Cost Institutions I
put them in the highest-cost institutions ...and why?

This formula maximizes the amount of Title IV loans and

grants their students can receive.

15
 •
..•

E..,~.

~
u

.......

·00
V'J
Q)
'.~
.~

en
;:i
.~
. '. Q)
.. ~'.

~
What results from this combination of profit-motive and lack of quality control is
an expensive education that is highly questionable

:~9t; Q SEE IT ON TV? CHECK HERE F{

News Article summary
ElistB# News m
EV'~re$tColiege students angry over certification
fmay, MarCh 19, 2~1 ~
.. Students paid $16,000 for an eight-month
course in medical assisting at an Everest
College campus in Hayward, CA

.. Students recently learned that:

.. Credits earned at the school do not

transfer to any community or four-year
college

.. Degrees gralitedat the school are not

recognized by the American
Association for Medical Assistants
T~hayw*d.prot~l-.eastbaynews (AAMA)
.j.cim.m.i<iiibwEn-.. i1P<iAiR~ '" i>'P<>!SlIIt: !/IiIlCS
• Hospitals will not interview students
for potentialjobs
HAYWARO. CA(l<GO) -!'Iearly thieedozert Everest Cl>llegesludemsaJe
fiirioustlJeyhaven't receivedlIJemedr~afcertifications they.paid fur. They refused
to go todas5lintif theygBtsOrJieansw=, .. ABC7 talked to the state Medical
Whether they attenddass.or Mt.Jhe sludentshave to pay $100. Assistant's Education Review Board
and found the Hayward Campus is one
Some ofth.e students havebeert altending school fur· eight months, Three weeks
ago.they found out,thalthecollegedoes!l9t supply them with acertificatethey of several Everest operates in California
were told they would get, in ottler.loobtSiiilhe riiedical.pesitionEi theywimt
that the board say is not accredited to
The~utkw~are alfstudyingriiedicar~ssistingandtlieypaid $16;00016ran credential medical assistants.
eight.ffioothcoorse.lheyweretofd thei:reditseamed althe scl1ll01 dll not
transfeilo any cl:lIninunity orfour-yearconiige and th<it has manyofthemangry.

Source: ABC News, KGO-TV San Francisco, CA, March 19, 2010

17
 Even when assuming reported graduation rates (BIG ASSUMPTION), more than
.50% of the student body still drops out every year

APOL 2006 2007 2008 2009

Beginning' enrollment 278,300 282,300 313,700 362,100
+ New students 216,600 258,500 288,200 355,800
- Graduates I drop outs . (212,600) (227,100) (239,800) (274,900)
Ending enrollment 282,300 313,700 362,100 443,000
Assuming these graduation rates,
Graduation rate' 28% 28% 28% 28%
Graduates 61,390 72,338 78,484 83,440 every year 50%+ of APOL and ESI
Drop o u t s . 151 ,21 0 154,762 161,316 191,460 students drop-out annually.
iiti~~~_~~
*Assumeavg tenu(ebtwn 3-4 years for graduates COCO recycles its entire
ESI 2006 2007 2008 2009
enrollment annually.
Beginning enrolinient 42,985 46,896 53,027 61,983
+ New students .' 49,935 54,593 65,313 85,928
- Graduates Idropouts (46,024) (48,462) . (56,357) (67,145)
Ending enrollment 46,896 53,027 61,983 80,766

Graduation rate 44'Yo 44%.. 44% 44%

• Graduation rate estimate based on reported
Graduates 18,449 19,774 21,983 25,302 National Center of Education Statistics da.ta;
figures represent average institutional graduation
Drop outs _ . ' 27,575 28,688 34,374 41,843
~9i:~~p _ _ ~~ rates at top 5 largest institutions
"Assume avg tenure btwn 2-3 years for graduates • For reference, 2009 Dept of ED reported
graduation rates for full-time, first time students at
for-profit schools is between 14-22%; these
COCO 2006 2007 2008 2009 graduation rates have been adjusted to include non
Beginning enrollment 66,114 60,964 61,332 69,211 first-time, full-time students, still may be largely
+ New students 92,185 90,105 100,210 117,352 overstated
- Graduates I drop outs (97,335) (89,737) (92,331) (100,475)
• Former academic counselors of APOL, ESI and
Ending enrollment 60,964 61,332 69,211 86,088
COCO claim that real graduation rates at many
locations are in the single digits
Graduation rate 33% 33% 33% 33%
Graduates 20,968 20,179 21,540 25,624
Drop outs 76,367 69,558 70,791 74,851
~"l'I-~""""'~'~"""':"' ,....,...,....~" ...-.....",~~=..-~-=rr£
................ _ - _ =:z::M - t
.~""~'=--J;v- ~~:;:;~~ ..~It.:::.'it;'~=="";;;>
%D:m"s"l'/~fiiiVB;.-t():taEenrdJliii'e:m'~'w,,~~~~",~
~}--..s:W:."",~~ --~~1"'~"'~tl":-.AA.."'>i~·~~~_'''''' __ ._ .',
llem'~~l1~~!!.t..c"::::$ll!'/o-'j
s~_ -~,:<~"':~----"''"''''""''~~~~~~~
,1':'.,'

"Assume avg tenure btwn 1-2 years for graduates

Source: Company-reported financia/s, IPEDS data (College Navigator), APOL student oultbmes report 2009
Default rates - historical National Cohort Default rates by institution type

Outside of the mid-90~s, when the regulatory environment was more stringent~
default rates at For-profit schools are roughly 2x non-profit default rates

J;X.ib~2.Nati.()n.t~oI1ort~t.llt~,es 'by'll1StitutiOl1·Type·fFY1991.-
:FY~9CJ_f ' ' . " .' .. '.
.3D'5i.
.:26.4%
.1Q91' .19.!l2.1!IQ3i!11S9ol1111995.19l16
25%
EI "1I1998._.,3.XD:.Qt.zm
2D% .•• ··2OJQ.··.ci2JJ4~·2DlE1:I~··~~II.-
15%;',:

10%;'

5%
O'l' .
.AII~

NDle:FY2008 data isdfaft.sm.ce: BMO CaPifalMaikeiS and US Department of Ed'ucationNatiofia1 Cen'ierh

~StI1i5Iii:s;, .

Source: NCES industry data and chart taken from recent BMO capital markets research report

19
 We are back to late~80's levels of lending to for-profit students, a key leading indicator .
.for loan defaults...back then, fraud was commonplace and regulation was minimal

Traditional vs. For-profit disbursements of Title IV Stafford Loans and Pell Grants, 1987 ~ 2009

For-profits % share of:

Total Total Pell
Schools Grants Loans Title IV All schOols Non-Drofit For- rofit
l~l~!~~:
. __
.~ ....,.
1988 2% 10% "27% '27% 27% $899 '. $670 $14,262·
1989 2% 10% 24% 28% 27% $933 $697 $14,640.
1990 2% 10% 23% 23% 23% $948 $740 $14,179
1991 2% 10% 22% 17% 19% $954 $788 $11,133
1992 ·2% 9% 21% 14% 16% $1;053 $895 $10,831
1993 2% 9% J8% 10% 13% $1,120 $989 $9,263
1994 2% 9% 15% 10% 12% $1,385 $1,246 $9,723
1995 2% 9% 13% 10% 11% $1,780 $1,616 $11,339
1996 2% 9% 13% . 8% 9% $1,967 .. $1,827 $8,402
1997 2% 15% '.. 12% 9% 9% $2,131 . $1,974 $8,910
1998 3% 16% .. 12% 9% 9% $2,249 $2,093 $8,317
'.
1999 3% 17% 13% 10% 10% $2,329. $2,154 $8,152
2000 3% 18% 13% 10% 11% $2,323. $2,130 $8,681
2001 3% 19% 14% 12% 12% $2,351 $2,139 $8,533
2002 4% 19% 14% 13% 13% $2,531 $2,278 $9,349
2003 4% 19% 15% 14% 14% $2,848 $2,543 $9,786
2004 5% 20% 16% 16% 16% $3,146 $2,783 $9,909
2005 6% 21% 18% 17% 17% $3,364 $2,947 $10,153
2006 6% 22% 19% 18% 18% $3,420 $2,968 $10,498
2007 7% 23% 19% 19% 19% $3,407 $2,944' $10,074
2008 8% 24% 21% 22% 22% $3,740 $3,173 $10,541
.J1C!9~~~~L~~~.··co
~..,~="£~
. :':.~iP.&)_ .~ ~e;-::.::~~
A~'=-'~""~''':%~-~~r'-:_~fJkC_~~~3?~3''-''~
. .. L~~2~~-'7..;i.0t~.~:.·:,

We must take note that because For-profit students receive 3-5x as much Title IV aid as traditional
students and are growing enrollment at 3x the pace of traditional schools. these early warning
signs must be addressed now before the impact is felt in the coming years...

Source: College Board

20
If history is any guide, we will return to late-SO's Cohort Default rates in 1-2 years,
the worst period of recorded default rates in the history of the DOE

Average Total loans + Grants per Forwprofit student vs. DOE Official CDRs, 1987 - 2009

I·· _Avg Loans + Grants -Official CDR I

$16,000 i I 24%

$15,000
20%
$14,000 .

~ $13,000 16%
~ 0::
~... $12,000
o
o
CIl
c. "iii
::: 12% ~
~ $11,000
o
UJ
i= oo
jg
{:. $10,000 8%

$9.000
4%
$8.000

$7,0001-1-'1-'1-,-,-,I1[1III,-
~ ~ ~ ~ , ~ ~ ~ ~
",PI
~ ~
-j- ~
-1-i-tlEl-
~ ~ , ~ ~
IE

~ b
-.-.-.-

~ ~ ~
-'-'0%
~ ~
~
~~~~~~*~~~~~~~~~~~~~~~~~
~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

21
Source: College Board, US Dept of Education
 · . . .

Because of the excessive drop-out rates and high debt burdens of graduates, the credit
statistics for government loans at for-profits are deteriorating at an alarming pace

Corinthian Colleges.Cohort Default Rates. 2004 - 2008

42%
40%
40% 1. .I -+- 2-yr rates ~3-yr rates I
38%

36%

34%
32%

;30%

28%

26%

24%.

22%
20%
l
---- 21%
~

18%

16%

14%

12%:1 11%
11%

10%
2004 2005 2006 2007 2008

Source: Company-reported financia/s; note: 2008 2-yr rates still preliminary, 3-yr rates estimated

22
Currently, for-profit institutions provision 50 - 60% on loans they make to their
ownstude,nts ...these are students who already have Title IV loans

• Companies are provisioning for more than 500/0+ loss on loans they make to students...
which means they expect more than 1 out of every 2 loans to go bad

• Butabsent any regulatory threat, thE3se companies could care'less if they every loan they
made'went bad because the per-student profitability oftheir models is so high!

• Both companies would still be hugely profitable on a per-student basis even with a 100%
losses on every loan they made

ESI coco ESlearns more than 8 times the

Title iYIQans,grants and private loans $16,959 $14,443 amount it expects to lose from
Intema1 company loan per student ' $2,100 $1,770 , internal loans to students.
Tuition per student (2009) $19,059 $16,213
COCO earns more than 4 times
Provision for loan loss9s(%) 50% 58% its expected loan losses.
Expected losses on internal loans ($1,050) '($1,027)

Note: OP / student equals change in operating profit over change in total enrollment
Loan loss provisions provided by companies

23
'.

Reported statistics... CohortDefault Rates (CDRs)

Cohort Default Rates (CDRs)

• CDRs are the percentage of a school's borrowers who enter repayment on a Federal Loan during a particular
,federal FY (Oct 1 to Sep 30), and default prior to the end of the next FY ,

• ", Effectively a 2-yr snapshot of the total students in default

• CDRs are an important measure of quality - if default rates breach the federally-mandated threshold of 25%
(soon to be 30%), schools can lose eligibility to Title IV '

Can easily be manipulated to mask true defaults

• Deferrals and forbearances used en mass to carry students over the 2 year r~ported timeframe

• ' Schools partner with Sallie Mae and other lenders to delay or manage down defaults through the 2 year
timeframe in exchange for guaranteed loan volumes

• Schools pay down student government loans with internal money and collect directly from students

Z4
·Reported .statistics... the .90/10 rule

The 90/10 rule

... 90/10 says a for-profit may become ineligible to participate in Title IV programs if it derives more than 90% of its
cash basis revenue from Title IV programs

e·· Applies only to for-profit institutions, effectively a cap on total Title IV dollars that can flow to a company as a
percentage of revenues

e. Intended to create a structural boundary for growth from Title IV dollars

. Can also be manipulated

•. Over-returning Title IV dollars to the government when students drop out and then billing students directly

• Pursue alternative government entitlement programs not counted under the Title IV umbrella (military educational
. loans grants)

e When all else fails, raise tuition! Students will have to find alternative (non-Title IV) funding sources to close the
gap between tuition and the amount of total Title IV loans

25
Reported statistics... completions and placements

Completions (graduation stats)

• Company-reported metric that measures the number of students who complete a program (graduate) in 150% of
normal time (for example, 6 years of graduation data for a 4-year bachelors program)

• Non-traditional student body doesn't graduate tog~ther, and often takes much longer than normal to complete, so
hard to understand actual graduation by class

• No independent verification of graduates

. ,",
. " . . , ..

Placements (employment statsJ

• Company-reported metric that measures the number of ~tudents who are placed in a job they were trained for
(gainful employment) . .

• This is gainful employment?

- .. Trained nurses become janitors at hospitals

-. Homeland security degree grads become nighttime security guards at shopping malls

• And for those grads who cannot find employment. .. hire them! Most schools hire unemployed graduates
internallyto boost reported placement stats .

26
 As long as the government continues to flood the for-profit education
. industry with loan dollars,

AND

the risk for these loans is borne SOLELY BY stu,dents and the government...

THEN

the industry'has every incentive to:

:- Grow at all costs
,.- Compensate employees based on enrollment
,'- Influence key regulatory bodies., '
- Manipulate reported statistics and other regulatory measures

ALL TO MAINTAIN ACCESS TO THE GOVERNMENT'S MONEY.

"Its about the numbers. It will always be about the numbers."
- Bill Brebaugh head of University of Phoenix Corporate Enrolhnent
l

fhe entire business model of these companies is centered aroundgrowing enrollment -

it is the single most important measure of growth and profitability, period.

Boiler room tactics:

Actual APOL compensation table snapshot
• ,"Every 6 months we get a review that looks at how
many students we enro1/ed and what percentage of ,~lI'Ii' • • •'
, thein finished their fir$t.class. As long as they finish """1!Iil SIMIJ ..
their first class we get full credit and after that they are
'not our problem ..." '
~"'Ifd·
~~~=--
............
__
1t'IG~
~
...
$2a
.1II!ir.!III.
$1tiUII$2lllt
$2lII:1D'-

...
1M $ZlIk , 'liMO. .'" t mo.. O.T.
'"~

-
". '.' - .
.7..-..
fIM8IWfItI
I2lIlC
$3CIli
~
S30t

..
,,$11:51* o1l11O.o.T•
.uWe are under so' mvch pressure we are forced to do p~

to ........--
.--.... sm
SS1k
,td40,i'W '" f -.O:.T.

-....
, an'y1hlngnecessary get people to fill out an $32k
$3a
11'~ $J3ll
application ..." ' A _____
5 2.-. $341<
$)4lt S83t

• "It's a boiler room - sel/iQg education to people who

~~
'* 1 M: tel8 .... 2 - . O.T.

....
$$I;

'.........
, ~ tnIlbInCI. ~

' -----
~
.cion't really want it." 117~
lIIl~
$1IIIt
U1k
mk AiIk
~ ~"'.h.... O'T•

.....
last tml
- Ashford University (BPI) former enrollment et--"

..
PlI< PJk
e1~ $38l $lIlIk
counselor 83~ $3IIt; $MIl
&I~ S*8!<,

..
~~ $1'11.1- 03_.0.T.
• 'The EC [enrollment counselor] review matrix is all .~ tea Utll

..
fill . . . . . . $401; U2IC
smoke and mirrors so we could fly under the radar of .~ J4Gk Sf.
e1J. . . . . . . . so ~
theDOE. .."
70"" •
71 ......., . . . f tfil
I!Il !MI- ·I.OJ.

- APOLformer enrollment counselor

Source: Court ctOGuments, Hendow"& Albertson vs. UOP, flied 2009

28
Accreditation...the inmates running the asylum

What is Accreditation and why is it important? The Accrediting Council for Independent
Colleges and Schools (ACICS)
• Accreditation helps ensure that education
provided by institutions of higher education ACICSBOARD OF COMMISIONERS
meets acceptable levels of quality
Dr. Gary R. Carlson - Chair Elect
6 of the 16 Board
• The Accreditation bodies are non-governmental Vice President, Academic Affairs
members of ACrCS
ITT Technical Institute
(non-profit) peer-reviewing groups are for-profit
Ms. Mary Hale Barry representatives
• Schools must earn and maintain proper Senior Vice President, Chief Academic Officer
Accreditation to remain eligible to participate in Kaplan Higher Education
Title IV Programs
Ms. Jill DeAtley
Vice President of Regulatory Review
• However, due to the peer-based composition of Career Education Corporation
the Accreditation boards, they cannot function
as a truly independent 3rd party revieW system Mr. Francis Giglio
Director of Compliance and Regulatory Services
Lincoln Educational Services
• In many instances, for-profit institution's
representatives sit on the boards of their Mr. David M. Luce
own Accrediting body, inevitably influencing Assistant Vice President, Accreditation and Licensing
Corinthian Colleges, Inc.
the approval process and oversight of their own
institutions! Mr. Roger Swartzwelder
Executive Vice President, General Counsel and Chief Compliance Officer
Education Corporation of America

"Not a//16 Board members shown

We have seen this before... rating agencies and subprime mortgages.

Is for-profit Accreditation the new credit agency scandal?
29
Accreditation...when you can't earn it, buy it
. .
• The latest trend of for-profit institutions is to acquire t~e dearlyMcovetedRegional Accreditation through the outright
purchase of small,financlally distressed nonMprofit institutions

• Regional Accreditation is the highest stamp of quality (Harvard is Regionally Accredited), and usually takes 5-10 years to earn
through a long peer review process of educational materials, curriculum, teachers, etc .

• But who wants·to wait 5 years?! '.

• Once acquired, these institutionscan serve as a shell for the parent organization to funnel in thousands ofstudents and continue
the growth cycle ...

• Past examples are Bridgepoirit buying Regionally-Accreqited Franciscan University of the Prairies (renamed Ashford University)
and more recent examples are ITT Tech buying Daniel Webster, and Corinthian· Colleges buying Heald College

. ..' . "

Bridgepoint Education{BP I} - a perfect· model ...

BPI Total enrollment, 2005·2008

Timeline
80,000 I . i

70,000
• MARCH 2005 - BPI acquires Regionally-Accredited 70,000
Franciscan University ofthePrairiesand renames
60,000
Ashford University. Ground enrollment = 312
50,000
• BPI flows students through online platform... grows
enrollment by 50,000+ students in 4 years 40,000

30,000
• Mgmt expects 70,000+ students by end of 2010
20,000
• 99% students now online, yet school retains its
Regional Accreditation 10,000
312

Mar.(l!i 2006 2007 2008 2009 2010E

Source: Company-reported financiafs

30
 ..
r.n
•
•

Q)
>
• .,...00(
4-J
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Q)
u
C
.. .,...00(
Summary

- The pace of the growth of the for-profit education industry and their growing claim to Federal monies
will require greater scrutiny to protect students and the integrity of Title IV lending

- The primary revenue and profitability driver for the for-profit companies is unrestricted access to Title
.:IVloans and grants..

• For-profit education companies are now among the mostprofitable businesses in the world due to
goyernment largesse

-Regulations built around company-reported statistics are ineffective, and the Accreditation process
for'for-profit schools and programs is compromised .

- Disaggregation of risk from reward is the fundamental cause of all problems

32
Solutions ~ Gainful employment

• Gainful employment gets at part of the problem because it deals with debt loads, but verification is
problematic

• ' Programs DO NOT have to be shut down for schools to remain compliant with new regulations

• Companies cari restructure their business to accommodate the regulatiOn and schools would
'become more affordable and student debt loads would be lower
."":. :, ,,'" ..... . . . .'. "'.

• 'However, a gainful: employment metric would structurally reset the earnings power of companies

33
Solutions -Gainful employment analysis impact (key assumptions)

1. Cost of programs based on reported cost I credit hour and program length

2. Percent ofdegree financed assumes Title IV % revenues less 100/0 (transfer credits and cash)

·3. Debt service payment based on 7.5% interest rate (6.8% government loans 112% private) and 10- .
yr repayment period
. . . .

4. Starting sala~ies taken from applicable BLS codes, by programt~tegory and job type
." . ; , ' . . :

I
5. Debt service income ratio of8°k basedon Gainful Employment proposed reg ulation ..

6. Student mix by program level and program type

. . . used to calculate total revenue impact

.. 7. Cost cuts estimated on a per-:school basis, based on disclosed cost categories and industry experts

8. EPS impacts and PIE ratios based on existing reported information, share counts, and current
street EPSestimates .

9. Scenario 1: Gainful Employment with no Offsetting Cost Cuts

10. Scenario 2: Gainful Employment with 50/0-15% Cost Cuts

34
Gainful employment and APOL

APOL Scenario 1 Scenario 2

Actua I 2009 EPS $4.22, $4.22

2009EPS (adjusted) . . $1.32 $2.12
200~EPS impact ·:69%: -50%

Sti"eef2010 EPS Estimate

EPS.lmoact

2009 ~PS impact -57% -41%

CurrentP/E (2010 EPS) 10.8 X 10.8 x

Note: PIE Ratios calculated as of 512112010

Source: Company-reported finaneials, programs, tuition rates, and management conference calfs. Street EPS estimates from Bloomberg. Projections based on program-
level tuition adjustments to· comply with 8% debt servicelincome ratio and scenario 2 applies 5-15% cost cuts across education and SG&A to offset revenue declines.

35
Gainful employment and ESI

.-
ESI Scenario 1 Scenario 2

Actual 2009 EPS . $7~91 $7.91 .

.2009 EPS (adjusted): ($0.22) $2.02
ZOO9 EPS impact -103% -74%

Street 2010 EPS Estimate

EPSlmpact

:Z009 EPS impact -74% -53%

Note: PIE Ratios calculated as of 5121/2010

Source: Company-reported financials, programs, tuition rates. and management conferenceca/ls. Street EPS estimates from Bloomberg. Projections based on program-
{evel tuition adjustments to comply with 8% debt service/income ratio and scenario 2 applies 5-15% cost cuts across education and SG&A to offset revenue declines.

36
Gainful employment and COCO

. coco Scenario 1 Scenario 2

Actual 2009 EPS $0.81 .' $0.81

·.'1 EPS
(adjusted) ($0.76) $0.17
.·EPS impact -194% -79%

.IStreet 2010 EPS Estimate $1.67 $1.67

EPSlmpact . . ($1.57) ($0.64)

..2009 EPS impact ·-94% -38%

Current PIE (2010 EPS

Note: PIE Ratios calculated as of 512112010

Source: Company-reported financials, programs, tuition rates, and management conference calls. Street EPS estimates from Bloomberg. Projections based on program-
level tuition adjustments to comply with 8% debt servlce/income ratio and .scenarlo 21 applies 5-15% cost cuts across education and SG&A to offset revenue declines.

, 37
Gainful employment and EDMC

EDMC Scenario 1 Scenario 2

Actual2009'EPS $0.87 $0.87

EPS (adjusted) ($5.50) ($2.21)
EPS impact . ' , -732% -353%
, ,I
I StreetZOl0'EPS
. .Estimate
EPS Imoact
1IiII~~«{~1Jl1llJllll.i1i. ~
. tl
2009 EPS impact -422% -204%

Note: PIE Ratios calculated as of 512112010

Source: Company-reported finanoia{s, program$, tuition rates, and management conference caffs, Street EPS estimates from Bloomberg. Projections based on program-
level tuitfon adjustments to comply with 8% debt service/income ratio and scenario 2 applies 5-15% cost cuts across education and SG&A to offset revenue deolines.

38
.Gainful employment and WPO (Kaplan)

WPO (Kaplan} Scenario 1 Scenario 2

Actual 2009 EPS. $9.78 $9.78

EPS (adjusted) ($33.25) ($6.19)
EPS impact -440% -163%

Street 2010 EPS Estimate·

EPS Impact

2009 EPS impact

.Current PIE (2010 EPS)

Note: PIE Ratios calculated as of 512112010

Source: Company-reported financials, programs, tuition rates, and management conference calls. Street EPS estimates from Bloomberg. Projections based on program-
level tuition adjustments to comply with 8% debt servlcelincome ratio and scenario 2 applies 5-15% cost cuts across education and SG&A to offset revenue declines.

39
 "

If these trends continue, we believe the DOE will face nearly $275B in defaults over
the next'lOyears on a half-a-trillion dollars of lending to the For-Profit Industry

Projected Cumulative Stafford Loans (in $ Billions) and Cumulative Defaulted Dollars
for For-Profit Eciucation Students, 2007 - 2020

$5~i I

.. Total Stafford Loans to FPstudents

$498
. $500 • Projected Defaulted Dollars

$450~..

$400
And because of fees associated with
Ui' :;,' defaultl the government collects
c apprf)ximateIY$1.20 on every $1.00 lent...
g
iii $350
'.
~
...meaning For-profit students will owe
i
ell
$300
. $330 Billion dollars on defaulted' roans over
.3 . the next 10 years
~ $250.
.,
QI

~$200
{!.
$150

$100

$~

$0 1--,
2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Source: College Board, National Center for Education Statistics, industry estimates 40
.. Business Services • Education Services
Signal Hill
Industry Update

July 16, 2010 Regulatory Update --What's Next

Trace Urdan
Our Call:
turdan@signalhill.com
415.364.0365 On Gainful Employment:

MUltiple reliable sources say that the Department of Education (ED) sent a revised,
metric~based Gainful Employment draft to the OMB for review around July 4, suggesthlg that
next week could see the proposal released for public comment. We believe this new draft could
include terms more accomm6d~t1ng than the infamous 8% language first floated by ED in
January's neg-reg sessions.

We further expect, based on reports of conversations between industry and ED officials over the
last few months, that the revised proposal will effectively relieve most of the BA and MA
programs from the debUincome measure through an alternative measure of graduate loan
repayments. We believe the intent of the rules is to target AA and non~degree programs, where
students are seen as less sophisticated and less able to make informed decisions about
borrOWing for their education. We also think there could be a completion/placement standard as
part of the final proposal.

Near-term, we see the publication of the Gainful Employment draft rule as most likely to relieve
pressure on BA and MA programs and, to better clarify the exposure for non-degree and AA
degree providers. (We note that COCO management has pUblicly stated that it will offer an
indication of the the likely impact of the rule on its future earnings, even before a final rule is
published.) Because we believe that clarity in both cases will begin to discredit the
widely-circulated Eisman negative-earnings scenario, we see the GE rule as a potentially
positive catalyst. '
. . . .
Specifically, we believe the terms' of an alternative default measure will be such that company's
with two-year graduate default rates of <3.5% should meet the 90% "active repayment"
criterion. We do not believe the assumption used by most shorts, including apparently Mr.
Eisman, that "active repayment" means current within 30 days.

• Near-term beneficiaries: APOL, BPI, DV, EDMC, LOPE, STRA.

But near-term evidence that negative earnings are unlikely will not by itself relieve the short
pressure on the sector or persuade disenchanted longs to reinvest. The more meaningful
catalyst for the sector will not come, in our opinion. until we see a) an LBO; b) a balanced
assessment ofthe industry's contribution to higher education by the GAO; or c) some positive
, commentary/testimony from USDOE following the rules being finalized.

We believe that private equity remains highly engaged in the sector, and possible Senate bills
notwithstanding, inclined to act as soon as rules become clearer: Though some may be cowed
by Harkin's rhetoric, we think ,others will be able to read the political environment as one in
which a liberal Democrat will be hard-pressed to pass heavy new regulations that will
discourage college access, industry jobs and tax receipts.

• Most'likely LBO candidates: ESI, COCO, CECa, and (if John Sperling is prepared to cede
control,) APOL.

Please see important disclosure inform,ationon pages 2- 3 of this report.

July 16, 2010

Investment Analysis:
Senate HELP Hearings

We're told that the next Senate HELP committee hearing on for-profit education will be devoted to the issue of
"misrepresentation" and will take place during the first week of August.

We believe the politics of rule-making, which encourages USDOE to generate support for the rules during this
public comment period, as well as the politicsofthe mid~term elections, in which the Democrats appear to be
appealing to the left in order to rally their political base, has caused the current firestorm of popUlist outrage in
Congress as expressed by Senators Harkin, Franken, Sanders, and Durbin.

Our read is that having been placed on the defensive early with respect to the need and appropriateness of
new Gainful Employment rules that effectively cap student debt levels by program, USDOE has coordinated an
impressive and highly successful public relations and lobbying effort to shift the terms of the debate such that
these rules now appear to the public to be a badly-needed and even moderate response to a crisis.

We read the Senate HELP hearings, as well as Senator Durbin's speech to the National Press ClUb, in this
context as well. There is a strong professional association between Senator Harkin's top education staffer Luke
Swarthout and Bob Shireman's adVocacy organization,the Institute for College Access & Success. And
Senator Durbin's speech likewise seems to have benefited from a host of talking points supplied directly by
USDOE.

In our analysis, the mid-term elections, the pUblication of a GAO report and most importantly, the finalization of
new rules on Nov. 1, 2010 governing the sector should result in a much more moderate tone among
lawmakers. While we cannot dismiss the possibility of new legislation being introduced in the Senate to alter
rules governing for-profit schools, we rate the likelihood o(passage of any such law as very low given the
source of the agitation arid the tough line being taken by ReplJb1icans on new regUlatory initiatives.

Important Disclosures
Analyst Certification

I, Trace Urdan, hereby certify that all .of the views expressed in this research report accurately reflect my
personal views about the sUbject securities or issuers. I also certify that no part of my compensation was, is or
will be directly or indirectly related to the specific recommendations or views expressed in this research
report.Signal Hill does not compensate its equity research analysts based on specific investment banking
transactions. Signal Hill Equity research analysts receive compensation based on several factors, including
overall profitability and revenues of the firm, which include investment banking revenues.

Applicable current disclosures for all companies covered in this report are available in written or electronic
format upon request. To request copies of applicable current disclosures please write to the Signal Hill Capital
Group Research Department at the following address: Signal Hill Capital Group Research Department, 300
East LombardStreet, Suite 1700, Baltimore MD 21202. .

Meaning of Ratings

Signal Hill uses a three-tiered rating system defined as follows:

BUY: We expect this stock to outperform its peers over the next 12 months:

HOLD: We expect this stock to perform in line with its peers over the next 12 months:

SELL: We expect this stock tounderperform its peers over the" next 12 months:

Post-Secondary Education 2
 July 16. 2010

Distribution of Ratlngs/IB Services

Signal Hill
IB Serv./Past 12 Mos.
Rating Count Percent Count Percent
BUY 79 61.7 74 93.7
HOLD 48 37.5 39 81.2
SELL 1 0.8 1 100,0

Disclaimer

This report has been prepared using sources we deem.to be reliable but we do not guarantee its accuracy and
it does not purport to be complete. This report is published solely for information purposes and is not intended
to be used as the primary basis for making investment decisions, which should reflect the investment objectives
and financial situation of the investor. The opinions expressed herein are subject to change without notice. This
report is not an offer or the solicitation of an offer to buy or sell securities. Additional information is available
upon request.

! .

Post-Secondary Education 3
 IRA SOHN CQNFERENCE
Presentation by Steve Eisman
SUBPRTh1E GOES TO COLLEGE
May 26,2010

Good Afternoon. I would like to thank the Ira Sohn Foundation for the honor of speaking
before this audience. My name is Steven Eisman and I am the portfolio manager of the
FrontPoint Financial Services Fund. Until recently, I thought that there would never
again be an opportunity to be involved with an industry as socially destructive and
morally bankrupt as the subprime mortgage industry. I waS wrong. The For-Profit
Education Industry has proven equal to the task. .

The title of my presentation is "Subprime goes to College". The for-profit industry has
grown at an extreme and unusual rate, driven by easy access to government sponsored
debt in the form of Title IV student loans, where the credit is guaranteed by the
government. Thus, the government, the students and the taxpayer bear all the risk and the
. for-profit industry reaps all the rewards. This is similar to the subprime mortgage sector
in that the subprime originators bore far less risk than the investors in their mortgage
paper.

In the past 10 years, the for-profit education industry has grown 5-10 times the historical
rate of traditional post secondary education. As of2009, the industry had almost 10% of
the enrolled students but claimed nearly 25% of the $89 billion of Federal Title IV
student loans and grant disbursements. At the current pace of growth, for- profit schools
will draw 40% of all Title IV aid in 10 years.

How has this been allowed to happen?

The simple answer is that they've hired every lobbyist in Washington D.C. There has
been a revolving door between the people who work or lobby for this industry and the
halls of government. One example is Sally Stroup. She was the head lobbyist for the
Apollo Group - the largest for-profit company in 2001-2002. But from 2002-2006 she
became Assistant Secretary of Post-Secondary Education for the DOE under President
Bush. In other words, she was directly in charge of regulating the industry she had
previously lobbied for.

From 1987 through 2000, the amount oftota! Title IV dollars received by students offor-
profit schools fluctuated between $2 and $4 billion per annum. But then when the Bush
administration took over the reigns of government, the DOE gutted many of the rules that
governed the conduct ofthis industry. Once the floodgates were opened, the industry
embarked on 10 years of unrestricted f.llassive growth.. .

[Federal dollars flowing to the industry exploded to over $21, billion, a 450% increase. ]

At many major-for profit institutions, federal Title IV loan and grant dollars now
comprise close to 90% of total revenues, up significantly vs. 2001. And this growth has

1
driven even more spectacular company profitability and wealth creation for industry
executives. For example, ITT Educational Services (ESI), one of the larger companies in
the industry, has a roughly 40% operating margin vs. the 7%-12% margins of other
companies that receive major government contracts. ESI is more profitable on a margin
basis than even Apple. .

This growth is purely a function of government largesse, as Title IV has accounted for
more than 100% ofrevenue growth. Here is one ofthe more upsetting statistics. In fiscal
2009, Apollo, the largest company in the industry, grew total revenues by $833 million.
Of that amount, $1.1 billion came from Title IV federally-funded student loans and
grants. More than 100% of the revenue growth came from the federal government. But
of this incremental $1.1 billion in federal loan and grant dollars, the company only spent
an incremental $99 million on faculty compensation andinstructional costs - that's 9
cents on every dollar received from the government going towards actual education. The
rest went to marketing and paying the executives.

But leaving politics aside for a moment, the other major reason why the industry has
taken an ever increasing share of government dollars is that it has turned the typical
education model on its head.. And here is where the subprime analogy becomes very
clear;

There is a traditional relationship between matching means and cost in education.

Typically, families of lesser financial means seek lower cost institutions in order to
maximize the available Title IV loans and grants - thereby getting the most out of every
dollar and minimizing debt burdens. Families with greater financial resources often seek
higher cost institutions because they can afford it more easily.

The for~profit model seeks to recruit those with the greatest financial need and put them
in high cost institutions. This formula ma.Ximizys the amount of Title IV loans and grants
that these students receive.

With billboards lining the poorest neighborhoods in America and recruiters trolling
casinos and homeless shelters (and I mean that literally), the for-profits have become
increasingly adept at pitching the dream of a better life and higher earnings to the most
vulnerable of society. .

But if the industry in fact educated its students and gotthem good jobs that enabled them
to receive higher incomes and to pay off their student loans, everything I've just said
would be irrelevant.

So the key question to ask is - what do these students get for their education? In many
cases; NOT much, not much atal!. . .
. . '. . . . '.. .:. '.: . ". .

Here is one ofthe many examples of an education promised and never delivered. This
article details a Corinthian Colleges-owned Everest College campus in California whose
students paid $16,000 for an 8-month course in medical assisting. Upon nearing

2
 completion, the students learned that not only would their credits not transfer to any
community or four-year college, but also that their degree is not recognized by the
American Association for Medical Assistants. Hospitals refuse to even interview
graduates.

But let's leave aside th~ anecdotal evidence of this poor quality of education. After all
the industry constantly argues that there will always be a few bad apples. So let's put
aside the anecdotes and just look at the statistics. If the industry provided the right
services, drop out rates and default rates should be low.

Let's first look at drop out rates. Companies don't fully disclose graduation rates, but
using both DOE data, company-provided information and admittedly some of our own
assumptions regarding the level of transfer students, we calculate drop out rates of most
schools are 50%+ per year. As seen on this table, the annual drop out rates of Apollo,
ESI and COCO are 50%-100%

How good could the product be if drop out rates are so stratospheric? These statistics are
. quite alarming, especially given the enormous amounts of debt most for-profit students
must borrow to attend SChooL

As a result of these high levels of debt, defaultrates.at for profit schools have always
been significantly highedhan community colleges or the more expensive private
institutions.

We have every expectation that the industry's default rates are about to explode.
Because ofthe growth in the industry and the increasing search for more students, we are
now back to late 1980s levels of lending to for profit students on a per student basis~
Back then defaults were off the charts and fraud was commonplace.

Default rateS are already starting to skyrocket. It's just like subprime - which grew at
any cost and kept weakening its underwriting standards to grow.

By the way, the default rates the industry reports are artificially low. There ate ways the
industry can and does manipulate the data to make their default rates look better.

But don't take my word for it. the industryis quite clear what it thinks the default rates
. truly are. ESI and COCO supplementTitle IV loans with their own private loans. And
they provision 50%-60% upfront forthoseJoans. Believe me, when a student defaults
on his or her private loans, they are defaulting on their Title IV loans too.

[Let me just pause here for a second to discuss manipulation of statistics. There are two
key statistics. No school can get more than 90% of its revenue from the government and
2 year cohort default rates cannot exceed 25% for 3 consecutive years. Failure to comply.
with either of these rules and you lose TitleIVeligibility. Lose Title IV eligibility and
you're company's a zero.

3
 Isn't it amazing that Apollo's percentage of revenue from Title IV is 89% and not over
90%. How lucky can they be? We believe (and many recent lawsuits support) that
schools actively manipulate the receipt, disbursement and especially the return of Title IV
dollars to their students to remain under the 90/10 threshold.]

The bottom line is that as long as the government continues to flood the for profit
education industry with loan dollars AND the risk forthese loans is borne solely by the
students and the government? THEN the indUstry has every incentive to grow at all costs,
compensate employees based on enrollment, influence key regulatory bodies and
manipulate reported statistics - ALL TO MAINTAIN ACCESS TO THE
GOVERNMENT'S MONEY.

In a sense, these companies are marketing machines masquerading as universities. And

when the Bush administration eliminated almost all the restrictions on how the industry is
allowed to market, the maclline went into overdrive. [Let me quote a bit from a fonner
employee ofBPI.

"Ashford is 8 for profit school and makes a majority of its money on federal loans students take out. They conveniently
price tuition at the exact amount that a student can qualify for in federal loan money; There is no regard to whether a
student really belongs in school, the goal is to enroll 8S many as possIble. They also go after GI bill money and currently
have separate teams set up to specifically target mifitary students. If a person has money avaifable for school Ashford
finds a way to go alter them. Ashford is just the middle man, profiting off this money, like mifking a cow and working the
system within the limits of what's technically legal, and paying huge salaries while the student suffers wIth debt that can't
even be forgiven by bankruptcy. We mention tuition prices as little as possible .. this may cause the student to change
their mind.

While it is illegal to pay commissions for student enrollment, Ashford does salary adjustments, basically the same thing.
We are given a matrix that shows the number of students we- are expected to enroll. We also have to meet our quotas
and these are high quotas.

~---_.--------- .B~au.~_We ..a[ej.ws1eLSQm.I!.Qb. RrrJ...§.SYf~,-';Y~_?J~.fQ[_Cift.c1.._ffUJ.9.§[!Y!!Jjflg-'!'f]_~~~ry.t()g/3JPf!oel~t9fi![9._t!tf!Il_lY'.pH(}ii~,?!!:: ____. ___.__.. .___._:

our jobs depend on it. r

It's a boiler room - selling education to people who really don't Want it. n

This formeremployee then gives an example of soliclting a sick old lady to sign up for Ashford to
meet his quota.

"The level of deception is disgusting - and wrong. When someone who can barely afford to live and feed kids as it is, and
doesn't even have the time or education -to be able to enroll, they drop out. Then what? Add $20,000 of debt to their
problems - what are they gonna do now. They are offICially screwed. We know most of these people will drop out, but -
again, we have quotas and we have no choice. " J

_Howdo such schools stay.in business? The answer is to control the accreditation
process. The scandal here is exactly akin t() the rating agency role in subprime
securitizations.

There are two kinds of accreditation -- national and regional. Accreditation bodies are
-non-governmental, non-profit peer~reviewing groups~ Schools must earn and maintain
proper accreditation to remain eligible for Title IV programs. In many instances, the for-
profit institutions sit on the boards of the accrediting body. The inmates run the asylum..

Historically, most for profit schools areilationally accredited but national accreditation
holds less value thanregionalaccreditatidn~ The la.testtrend offor profit institutions is to

4
 acquire the dearly coveted RegionalAccreditation through the outright purchase of small,
financially distressed non-profit institutions and then put that school on':'line. In March
2005, BPI acquired the regionally accredited Franciscan University of the Prairies and
renamed it Ashford University. [Remember Ashford. The former employee I quoted
worked at Ashford.] On the date of purchase, Franciscan (now Ashford) had 312
students. BPI took that school online and at the end of 2009 it had 54,000 students.

SOLUTIONS

While the conduct of the industry is egregious and similar to the subprime mortgage
sector In just so many ways, for the investment case against the industry to work requires
the government to do something -- whereas in subprime all you had to do was wait for
credit quality to deteriorate.

So what is the government going to do? It has already announced that it is exploring
ways to fix the accreditation process. It will probably eliminate the 12 safe harbor rules
on sales practices implemented by the Bush AdIninistra.tion. And I hope that it is looking
at everything and anything to deal with this induStry.

Most importantly, the DOE has proposed a rule known as Gainful Employment. In a
few weeks the DOE will publish the rule. There is some controversy as to what the
proposed rule will entail but I hope that the DOE will not backtrack on gainful
employment. Once the rule is published in the federal registrar, the industry has until
November to try to get the DOE to back down.

The idea behind the gainful employment rule is to limit student debt to a certain level.
Specifically, the suggested rule is that the debt service-to-income-ratio not exceed 8%.
The industry has gotten hysterical over this rule because it knows that to comply, it 'will
probably have to reduce tuition.

[Before I turn to the impact of the rule, let me discuss what happened last week. There
was a news report out that Bob Shireman, the Under Secretary ofEducation in charge of
. this process was leaving. This ca\lseda masstve rally in the stocks under the thesis that
this signaled that the DOE was backing dov''ll from gainful employment. This conclusion
is absurd. First, of all, inside D.C. it has been well known for a while that Shireman
always interided to go home to California after a period of time. Second, to draw a
conclusion about the DOE changing its policy because Shireman is leaving presupposes
that one government official, one man, drives the entire agenda of the U.S. government.]

] cannot emphasize enough that gainful employment changes the business model. To
date that model has been constant growth In the number ofstudents coupled with
.1 occasional increases in tuition. Gainful employment will cause enrollment levels to grow
less quickly~ And the days of raising tuition would be over; in many cases, tuition will go
down. .

5
 To illustrate the impact of gainful employment, I've chosen 5 companies, Apollo, ESI,
COCO, EDMC and the Washington Post. Yes, the. Washington Post, whose earnings are
all driven by this industry.

Assuming gainful employment goes through, the first year it would impact would
obviously be 2011. However, because the analysis is so sensitive to tuition levels per
school, it's best to have as much information as possible. So for analytical purposes, we
are going to show the impact on actual results in fiscal 2009 and this year's estimates
under the assumption that gainful employment was already in effect.

We employ 2 scenarios. Scenario 1 is static. It takes actual results and then reduces
tuition costs to get down to the 8% level. Scenario 2 is dynamic. It assumes the same
thing as scenario 1 but then assumes the companies can reduce costs by 5%-15%.

Results for each company depend largely on the mix of students, the duration of each
degree and the price of tuition at each institution

For each company, I show the results under the two scenarios and the corresponding
PIEs. Needless to say, the PIE multiples look quite a bit different under either scenario.

Apollo -In fiscal 2009, the company earned $4.22. The consensus estimate for fiscal
2010 is $5.07. Under scenario 1, fiscal 2009 and the fiscal 2010 estimate get cut by 69%
and 57%, respectively. Under scenario 2, it gets cut50% and 41%, respectively.

ESI - In fiscal 2009, the company earned $7.91. The consensus estimate for fiscal 2010
is $11.05. Under scenario 1, fiscal 2009 turns slightly negative and the fiscal 2010
estimate gets cut by 74%, Under scemui02,fisca12009declines by 75% and the 2010
estimate gets cut by 53%.

COCO - In fiscal 2009, the company earned $0.81. The consensus estimate for fiscal
2010 is $1.67. Under scenario 1, fiscal 2009 turns negative and the fiscal 2010 estimate
gets cut by 94%. Under scenario 2, fiscal 2009 declines by 79% and the 2010 estimate
gets cut by 38%.
.' ' . '. . .' .
EDMC -- In fiscal 2009, th~ company earned $0.87. The consensus estimate for fiscal
2010 is $1.51. Under scenario 1, fiscal 2009 and the fisca12010 estimate turns massively
negative. Under scenario 2, fiscal 2009 an.d the fiscal 2010 estimate are also massively
negative, just less massively than scenario 1. . The principal reason why the numbers are
so bad for EDMC is that they have a lot of debt and that debt has to be serviced and
cannot be cut.

. Washington Post - The Post's disclosure ofKaplan metries is slight. Thus, analyzing the
impact from gainful employment is much more diff'icultartd we have confined our
analysis solely to fisca12009. In fiscal 2009, WPO earned $9.78. Under scenario 1, a
loss of$33.25 per share occurs. Under scenano 2, there is still a loss of$6.19. The

·6
 principal reason why the numbers are so bad for the Post is that more than 100% of its
EBIDTA comes from this industry through its Kaplan division.

[Let me just add one caveat to our analysis. Implementation of gainful employment
could result in a cut in marketing budgets. Given the high drop out rates of this industry
any such cuts could turn a growth industry into a shrinking industry. The numbers that I
just showed do not assume that the industry shrinks but grows at a slower pace.]

Under gainful employment, most of the companies still have high operating margins
relative to other industries. They are just less profitable and significantly overvalued.
Downside risk could be as high as 50%. And let me add that I hope that gainful
employment is just the beginning. Hopefully, the DOE will be looking into ways of
imprOVIng accreditation and of ways to tighten rules on defaults.

Let me end by driving the subprime analogy to its ultimate conclusion. By late 2004, it
was clear to me and my partners that the mortgage industry had lost its mind and a
society-wide calamity was going to occur. It was like watching a train wreck with no
ability to stop it. Who could you complain to? -- The rating agencies? - they were part
.of the machine. Alan Greenspan? - he was busy making speeches that every American
should take out an ARM mortgage loan. The aCC? -- its chairman, John Dugan, was
busy suing state attomey·generals,preventirigthem from even investigating the subprime
mortgage industry.

Are we going to do this all over again? We just loaded up one generation of Americans
with mortgage debt they can't afford to pay back. Are we going to load up a new
. generation with student loan debt they can never afford to pay back. The industry is now
25% of Title IV money on its way to 40%.. If its growth is stopped now and it is policed,
the problem can be stopped. It is iny hopethat this Administration sees the nature of the
problem and begins to act now. If the gainful employment rule goes through as is, then
this is only the beginning of the policing ofthis industry.

But if nothing is done, then we are on the cusp of a new social disaster. If present trends
continue, over the next ten years almost $500 billion of Title IV loans will have been
funneled to this industry. We estimate total defaults of $275 billion, and because of fees
associated with defaults, for profit studehts will owe $330 billion on defaulted loans over·
the next 10 years. ..

[Bracketed Sections might be deleted during the verbal speech because of lack of time.]

7
. . . - Ira Sohn Conference

'Presentation by Steven EisInan,'.,

FrontPointPartners·
May 26,2010
 Disclosures

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Inthe last 10 years, the for-profit education industry has grown at 5-10 times the
historical rate of traditional post-secondary education

Annual enrollmentgrowth of Total U.S; postsecondary institutions vs~ For profit institutions

I .Total industry enrollment growth • For-profit enrollment growth I

--------,----,--~========-------~--:-----~..:-------'---__::_li
25% .,..,

20%

... 15%

10%

5%

0%
1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Source: National Center for Education Statistics, 2009

5
 Which has drastically accelerated the for-profit's share of total US post-secondary
enrollments and led to the rapid growth of for-profit institutions

In 1990...
< 1% of all students attended < 10% of all schools
for-profit colleges... were for-profit. ..

For profit students as a% of total U.S. postsecondary students For profit institutions as a % of total U.S. postsecondary institutions
9% I 30% I I

8%

25%
7%

6%
20%

5%

15%
4%

3%
10%

2%

1%'-,-,-,-.-'-'-'-'-
~ ~
# *
~ ~
- - · · · · · · · -
~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
-I
5%1

~
,-,-

~ ~ ~
-,-,-
~~~~#~~~~~~~~~~~~~~~
~ ~ ~-
-I- -,-,- - -1-
~ ~ ~ ~ ~ ~ ~ ~
-l-i·'-C·~-1

~ ~ ~ ~ ~
~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

In 2009...
almost 10% of students 25% of schools are
attend for-profit colleges for-profit institutions

Source: National Center for Education Statistics, 2009

6
Despite being less than 100/0 of total enrollments, for-profits now claim nearly
25% of the $89 billion of Federal Title IV student loans and grant disbursements

For~profit share of Title IV disbursements (Pellgrants and Federal·stafford loans), 1998 - 2009
27% "T"I---~----"""---"""-~-------~-----:----_:"""":'_--'-------"""-------;---II
26%
In 2009, For-Profit schools collected $4.4 billion of the $18.2 billion
25% .
in Federal Pell GrantS,or about 24% of $11 Pell Grant funding -
24% - double the proportion from tert years ago.
23%
22%
21%
20% -
19%
18%
17%
16°h
16%
14% '
13%
12%
11%
10%
9%
8%
7%
1998 1999 2000 2001 20tl2 2003 2004 2005 2006 2007 2008 2009

• Pell grants • Subsidized stafford loans o Unsubsidized stafford loans

7
Source: College Board, NcLc
How is this possible?! The for-profit industry hasbought almost every lobbyist
and has infiltrated the highest levels of government... a prime example

Sally Stroup was a pivotal player hi the deregulation of the for-profit industry...
because she worked for the for-profit industry

Sally Stroup Biography:

·2001 - 2002: Director of Industry and Government Affairs for the Apollo Group
(top lobbyist for APOL)
' . .
• 2002 - 2006: Assistant Secretary ,for Postsecondary Education, U.S. Dept of
Education (top postsecondary education position)
. , ,
. ...
:.
2006 ~ 2008: GOP Deputy StciffDirector, U.S. House of Representatives
Committee on Education and Labor (largest recipief1tof political contributions from
, for-profit edqcation industry)

• 2008 - Present: GOP Staff Director, U.S. House of Representatives Committee on

Education and Labor

...and not surprisingly, her colleagues at the Dept of Education were all driven by similar goals

Name' Former DOE position Current Lobbying Firm For-profrt Education client
William Hansen Deputy Secretary of Educlaion, 2001 - 2003 Chartwell Education Group APOLLO GROUP

Jonathan Vogel Deputy Counsel to the Department of ED, 2002 • 2005 Sonnenschein, Nath & Rosenthal GRAND CANYON UNIVERSITY

Lauren Maddox DOE Asst Sec for Communications, 2006· 2008 Podesta Group CAREER EDUCATION CORP

Rebecca Campoverde DOE Asst Sec for Congressional & Legislative affairs, 2005 - 2008 Kaplan, Inc. KAPLAN, INC

Victor F. Klatt III GOP Staff Director for House ED and Labor, 2005 -2008 Van Scoyoc Associates APOLLO GROUP

8
From 1987 through 2000, the amount of total Title IV dollars given to for-profit
schools fluctuated between $2 billion and $4 billion dollars...

Total Federaldisbursements of Title IV Stafford Loans and Pel! Grants. 1987 ~ 2009
Dollars in billions
Total Total For profit For profit Total For profit share For profit.share
.Yu! Pell Grants Stafford Loans Pell Granl$ Stafford Loans For profit Pell Grants Stafford Loans
1987 $3.5 $7.3 $0.9 $1.8 $2:7 25% 25%
1988 $3.8 $8.0 $1.0 $2.1 $3.1 27% 27%
, 1989 $4.5 $8.2 ' $1.1 $2.3 ,$3-4 24% 28%
1990 $4.8 $8.3 $1,1 $1.9 $3.0 23% 23%
1991 $4.9 $8.8 $1.1 $1.5 $2.6 22% 17%
1992, $5.8 $9.5 $1.2 $1.3 $2.5 21% 14%
1993 $6.2 $9.9 $1.1 $1.0 $2.1 18% 10%
1994 $5.7 $14.1 . $0:9 $1.4 $2.3 15% 10%
1995' $5.5 $19.9 $0.7 $2.0 $2,7 13% 10%
1996 $5.5 $22.8 $0.7 $1.9 $2.6 13% 8%
'1997 $5.8 $25.1 $ot" $2.2 . $2.9 12"10 9%
1998' ' $6.3 , , $26.3 $0,8 $2.3 $3.0 12% 9%
'1999 $7.2 $27.2 $0.9, $2.6 $3.5 13% 10%
, 2000 $7.2 $28.4 $Q.9 $3.0 ----
$3.9 13% 10%

PellGrants Total Title IV aid grew from

quadrupled from $1 under $4 billion in 2000 to over
billion to $4 billion $21 billion in 2009

...but with the leniency shown to the industry under the Bush Administration, the
dollars that flowed to the industry ~loded to over $21 billion, a 4500/0 increase
9
Source: Col/ege Board
At the current pace of growth, For-profit schools will claim 20% of enrollments, .
represent 40% of schools and draw over 40% of all Title IV aid in 10 years

For-profit share of enrollment. schools, Pen grants and Loans. 2009 - 2020

For-profits % share of:

Total Total Pel! Stafford Total Total Title IV disbursements ($ billions)
. Year Enrollment Schools GrantS Loans Title IV . Non-profits For-proflts
2007 7% 23% 19% 19% 19% $50.2$12.0
20088% 24%21% 22% 22% ... $56.0 $15.5
~~~.~m!*_l~ji~~i!4i~~t~~_~~~~L~I~~t;~I~(§14i~Wl~~~~~}~~~~~
2010 9% 26% 25% 25% 25% $71.9 $24.3
2011 10%. 27% .26% 27% 27% $76.5 $27.7
2012 10% 29% 27% 28% 28% $81.2 $31.5
2013 11% 30% 28% 30% 29% $86.2 $35.8
2014 12% 31% 30%, 31% 31% $91.4 $40.8
··2015 13% . 32% 31% 33% 32% $96.9 $46.4
2016 14% 34% 32% 35% 34% $102.5 $52.8
. 2017 16% 35% 33% 36% 36% . $108.4 $60.1
2018 17% 37% 35% 38% 38% $114.4 $68.5
2019 18% 39% ·36% 40% 40% $120.6 $77.9

Key Assumptions for Projections Based on current financials of For-profit

institutions~ less than 30% of the
Total post-secondary enrollment grows at 1.5% per year incremental $67 billion (annually) in
For-profit enrollment grows at 10% per year (10-yr avg is 14.4% Title IV dollars will go towards
annually) . educating students ...
• Total post-secondary institutions grow at 1.5% per year; For-profit
institutions grow at 6% per year (both long-term avg since 1990)
...nearly $50 billion (annually) will go
Avg grant and loan amounts per student grows at 5.-yr historical avg
growth rates, by institution type
.toward non-faculty and executive
compensation and company profits
10
Source: College Board, US Dept of Education, industry estimates
At many malor for-profit institutions, federal Title IV loan and grant dollars now
comprise close to 90% of total revenues

Title IV,
.Apollo Group Other, .48%
52%

Title N,
89%

ITT Technical
Institute
Title IV,
65%

Note: Title IV figures include 2008 unsubsidized loan limit increases on a pro--forma l:?asis .

Source: Company-reported financia/s

. 11
This growth has driven even more spectacular company profitability and wealth
creation for industry executives and shareholders·

ITT Technical Institute (ESI) Profitability has grown5-fold since 2006

ESI operating margin % I Q106 - Q409 ESI operating profit ($ millions), Q106 - Q409
45% $165
$155
$145
40%
$135
$125
35"1. $115
$105
30% $96
$85 ..
$75 ...
25
1 % $65
$55 .. •
20%; •
15% I. i i i ·

s:,b .r:,b Dq, Db r:,"

i i i

r:," ~
i

s:," CS>.'O s:,ft.

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r:,'O r:,'O Do..

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Db r:,"~" D" SI>". D'O· Dft. SI>'b SI>'b. r;:,OJ r;:,o.. r:,o.. Sl>0J
,,~ "'~. ">~ ,p ..(1: "'~ '!>~ ~~ ..Q o- .. ,p. ">~ ,p ..~ "'~ ...~ ,p ..~ -f>' ....<Y- ,p."~ ">~,,~ ..o: -f>'.
">~ .p ..0 : ",0: ...0 : .p

• The top 5 executives at ESI, Corinthian colleges (COCO) and Apollo Group (APOL)
collectively earned over $130 million from 2007·2009

Top 5 executives total compensation

ESI COCO APOl Total
2007 $9,834,695 $4,938.982 $10,441,170 $25,214,847
2008
2009

t.';~-K~~~~.~""",~~~ii:Ta~~"'5';~O:·"iiI=:Q·_·O~5~'r~~O·~
~~~~~~~.JlJQ.p~:~~._-
$8,923,791
$14,366,540
$8,849,386
. $11.222,377

. ~. ~~·eJP~~~,~~4~~::l.~Iii!~--~iN~_ ,·:.. ·.. :tr · . " !~u~?~"~yJy~a_~~.c;_~_·_~

Total comp '" salary, bonus, stock awards, aptian awards, non-equity incentives
$26,766,979
$34,707,377

i.
$44,540,156
$60,296.294

Source: Company-reported financ;als and proxy statements 12

Now many of the US for-profit education companies are among the most'profitable
businesses in the world

Other industries of strategic imporlance to the U.S.

which are funded by taxpayer dollars are restricted
to lower operating margins on contracts...

2009 COl11lany Operating Margins 6·year Average Company Operating Margins, 2005· 2009
45% 35%

40%1
35%

30%

25%
-37.~%, 30%1

25%

20%
29.0%

20% 15%

15%
10%
10"10
5%
5%

0% 0%
lIT Technical Lockheed Raytheon Corp Northrup Boeing lIT TechnIcal Apple Procter & 'Lockheed Home Depot
Institute Martin Grumman Institute Conipu1er Gamble Martin

So how can Title IV-funded education companies

earn sUbstantially more money than nearly every
other major US business?

Source: Company-reported finBnciB/s and proxy statements 13

This growth however, is primarily a function of government largesse, as Title IV
has accounted for more than 100% of the revenue growth of these companies
Apollo Group fAPOL) 2007 2008 2009
Total revenues $2,724 $3,141 $3,974
Year-year growth
% revenue from Title IV" 65%
$417
77%
C~~~
8 Yo
More than 100% of the
revenue growth ofAPOL,
Title IV revenues $1,770 $2,419 $3537 COCO and ESI is driven by
Year-year growth $648 c!1,119
an increase in Fecieral Title
!'4't:~e·~~a~'="""·"'fj·ro~m-"5:""'liie"'~I"'!-'~~~~'@'.~.»-.
··~~~"'~~~fl:c6i.S!'j;~~~~~oi$;
~~{fft .. ;.,.; ut!~h~~~~d'~~~"-'·." ' , ~;lig~~$7~~~~~~~M.~~~:~;::'~~~:( . IV dollars...

Corinthiim Colleges (COCO) 2007 2008 -

·2009
-. .
Total revenues $919 . $1,069 $1;308
Year-year. g rowth $149 $239
% revenue from Title IV" 75% 81% 89%
~~.and of this incremental

..
Title IV revenues $691. $866 $1,163 $1.1 billion in Title IV and
Year-yellr growth . $174 $297
$833 million in revenues,
w~_~~.·
~<ii
~ 0' ~A~
'" _ ..
<II. ~).
,_,
·;_._e·~·>'\i~~~:0:4~~~;JAws
,.,~~.!~ ~Iue!u
~_ • • " . ' ,.,....... '.;, >_.=k$-j,."
..~~~
...... ~~]I~/i1i.... ~.r="'~~':LD=
_..!&__« .....~(o:> _....... ::;l: _ . . . _""~ ...... ~

ONLY $99 million or 9%

was spent on educational
ITT Technlcallnstltute (ESI) 2007 2008 2009
Total revenues $758 $870 $1,015
expenses like faculty
Year-year growth $112 $146 compensation and other
% revenue from Title IV· 63% 73% 85%
instructional costs
Title IV revenues $477 $635 $863
Year-year growth $167 $228

~Ei\?iir&!~~iQ~l€fitjj,~~~r~.a~.;W.s
:x~-~." " : ~~~~j;;!)~.f~~'t¢~!£e ~ ...~~.,.-,. .. '" ~ ,l,'~~~~
_ _
..~~ - .u~~
:#~1i51!~
~.~~~ ...

Dollars in milfions .
*Title IV % includes 2008 Stafford unsubsidized loan limit increases

Source: Company-reported financials . 14

But how do they do it? How are for-profit schools grabbing such a growing share of
Title IV dollars?

Traditional relationship - Matching Means with Costs

. Families with greater needs generally seek lower-cost Families with greater financial resources often seek higher-
. '. institutions to maximize the available Title IV loans and cost institutions because they can afford to pay in excess of
. grants, getting the most out of every dollar to reduce out- what Titfe IV loans cover. These families typically are not
.of-pocket expenses and minimize heavy debt burdens.... eligible for grants because of their higher-income status.

Lesser Means . Greater Means

' .. '.
(Low~Mid Income Families)

Low Cost Institutions

(High Income Families)

•
,tiigh Cost Institutions
(Community College or In-State School) '. (Private Colleges) .

For-profit Model - Max Cost with Minimal Means

Lesser Means The for-profit model has consciously separated the

(Low-Mid Income Families) traditional relationship between costs and means. They
seek to recruit those with the greatest financial needs and

I •
High Cost Institutions I
put them in the highest-cost institutions ...and why?

This formula maximizes the amount of Title IV loans and

grants their students can receive.

15
 •
•
•

Q)
,
s
What results from this combination of profit-motive and lack of quality control is
an expensive education that is highly questionable
.__ . --- ... ~--_ ... '---

"~9.i <; SF;: IT 0" TV? C'lEeK Hl::Kt:. rc

News Article summary
~" East ~y News~
~ E;verestColiege stud¢ntsangryove.r certiflc.3tlon • Students paid $16,000 for an eight-month
~
I~ ..... . .
frilay. March HI,Z010· .. .
course in medical assisting at an Everest
I~
College campus in Hayward, CA

• Students recently learned that:

• Credits. . earned at the school

. do not
transfer to any community or four-year
.college . .

• Degrees granted at the school are not .

recognized by the American
Association for Medical Assistants
;:;:z~~n:!i;r,:~(:t!t~t\1. rJ t: ~ -'$ (AAMA) .

• Hospitals will not interview students

for potential jobs .
.~ HAYWARO; CA (1<60) __ Nearly th~dozeoEYefestColJegesttiderils¥e
~ rUriOustllE!y h1lviml mc~ tiJe m~ical ceitifications they' paid ror: They nirused

.
~. \0 go toc1assimtil theygetllOme ansWers. • ABC7 talked to the state Medical
.
~. Whetlierlhey. attend class or not,lIieslUdents h~ to pay.S100. Assistant's Education Review Board
and found the Hayward Campus is one
.~
• Felconductosea
Some Cif!\I.e students have beenatt41nding schoolfor eight months. Three v.:eeks • ·Ber1<..ley _.ti~n·
~ ago 1I1eytoundoUl that the .college does not supplyth lllll with. acell.iftC<l\e they • bead whale ~~COVI of several Everest operates in California
.~ Wele told they wouldg~. in oi¥' ioobtain thE! niedical p9sitionsthey want:
• DUClgtll proposal to that the board say is not accredited to
"~ The stud~s area1fstudyit1!lme(rt¢alitsSistingand~ypaid$16.00Qfilrliri • 3 a~ied after:&Sh
credential medical assistants.
• 5W-oerc widm.
.
~ ~~-:~~t~~:~:in~:~:r:~~t~~~~:::~~at~~er:~:~~~otan9'Y. • \i1cbuo dog .rolien
• PDtre dlosc..m

Source: ABC News, KGO-TV San Francisco, CA, March 19, 2010

17
Even when assuming reported graduation rates (BIG ASSUMPTION), more than
50°.!c> of the student body still drops out every year

AfQb 2006 ~ 2008 ~

Beginning enrollment 278,300 282,300 313,700 362,100
+ New students 216,600 258,500 288,200 355,800
- Graduates! drop outs (212,600) (227,100) (239,800) (274,900)
Ending enrollment 282,300 313,700 362,100 443,000
Assuming these graduation rates,
Graduation rate, 28% 28% 28~0 28%
Graduat~s 61,390 72,338 78,484 83,440 every year 50%+ of APOL and ESI
Drop outs " " , 151,210 154,762 161,316 191,460 students drop-out annually.
m~..I«~
"'. .~., .'.~ . . . . . .,
_,' ':" -
.~".:
~_,
.)j.~~x ,~VFi:"_
~~E:~~
~
•. Kl ••ff, •••.

"Assuine'avg tenure btwn 3-4 years for graduate's coco recycles its entire
enrollmentannuall~
ESI 2006 2007 2008 2009
BeginnIng enrollment .42,985 46,8~53,027 61,983
+ New ~ttldents 49,935 54,593 ~5,313 85~928
- Gr~dt.i~tes I drop outs (46,024) (48,462) (56,357) (67,t451
Ending "enrollment 46,89653,027 61,983 80,766

G~duation rate 44% 44 % 44% 44% Graduation rate estimate based on reported
Graduates 18,449 19,774 21,983 25,302 National Center of Education StatistiCs data;
Dropouts , " 27,575' 28;688 34,374 41,843 figures represent average institutional graduation
rates at top 5 largest institutions
~~~i!;~'N!Ii1h~_61f_~'
. ~ ..'. :l~tX9.z:r..t. ,,;;;::,:c: '..
"'==.0:1:1. . . .. .,
, ··s:;.·.. .~' .•~~
,'" .. ,

"Assume avg tenure btwn 2-3 years for graduates • For reference, 2009 Dept of ED reported
graduation rates for full-time, first time students at
for-profit schools is between 14-22%; these
~', 2006 !!WI 2008 2009 graduation rates have been adjusted to include non
Beginning enrollment 66,114 60,964 61,332 69,211 first-time, full-time students, still may be largely
+ New students 92,185 90,105 100,210 117,352 overstated
- Graduates,! drop outs (97,335) (89,737) (92,331) (100,475)
• Former academic counselors of APOL, ESI and
Ending enrollment 60,964 61,332 69,211 86,088
COCO claiin that real graduation rates at many
locations are in the single digits
Graduation rate 33% 33% 33% 33%
Graduates 20,968 20,179 21,540 25,624
Drop outs 76,367 69,558 70,791 74,851'
~~~'<ffilF- >""'S' ' ~I"""""":~ ""i·i.5iSZ;;lf'~'~=~.s*~""""·, , '_ _i~"""f~';~~'i<>~
Wf~· .1'!.;gf.@.!g~l!t';.~",Jff.E!.n~"ji..'I'iI'liW-:::.~'",.!~RlF-60~:,~4r%
_ ",. JjJfi;~~ti
"Assume avg ten~re btwn 1-2 years for graduates

Source: Company-reported financials, {PEDS data (College Navigator), APOL student oul&lmes report 2009
Default rates - historical National Cohort Default rates by institution type

Outside of the mid-90's, when the regulatory environment was more stringent,
default rates at For-profit schools are roughlv 2x non-profit default rates

EXhiIJiI~2.Naticma[
fY200B) " COtlortDefaUI1:Rates<by'lnstitUtionJ"Ype
. (FY1991 - .

3D%
.• gjB1Qf12:1i11ge3m1!l94 .B1ggs:11i119i16
:m19911199B.IIEiil3lUD .• 2IDt.3m
•.zn1 EJ2IIR·~~b.1I21:& ••2IQ

H&dIX:Is R.at:.~ ~Hci#«~ PirtvateFor-'PRJl1t

HeiIe:.FY2008·da!a isd'ratl 'SDI.REBMO .eapital.Mam::!t5 illldUS Department OfEd~ NaIicniiI C'.erErh

Edul:3IiDri'~'

Source: NCES industry data and chart taken from recent SMO.capital markets research reporl

19
We are back to late-SO's levels of lending to for-profit students, a key leading indicator
for loan defaults ...back then, fraud was commonplace and regulation was minimal

Traditional VB. For-profit disbursements of Title IV Stafford Loans and Pel! Grants, 1987 - 2009

For-profits % share of: Average Pell Grant + Loans

Total Total . Pen Stafford Total . Per Student
Year Enrollment Schools . Grants Loans lie IV All schools .ti2!!:El.rofit
~~~~~~~~:~~~(~~i.~~lI
1988 2% 10% 27% 27% 27%$899 $670 $14,262
1989 2% 10% . 24% 28% 27% $933 $697 $14,640
1990 2% 10% 23% 23% 23%$948 $740 $14,179
1991 2% 10% 22% 17% 19% $954 $788 $11,133
1992 2% 9% 21% 14% 16% $1,053 $895 $10,831
1993 2% 9% 18% 10% 13% $1,t20 $989 $9,263.
19942% 9% 15% 10% ·12% $1,385. $1,246 $9,723
1995. 2%9%13% 10% 11% 51,780 $1,616 $11,33~
1996 2% 9% ·13% 8% 9% $1;967 $1,827 $8,402
1997 .2% 15% 12% 9% 9% $2;131 $1,974 $8,910
1998 3% 16%12% 9% 9% $2,249 $2,093 $8,317
1999 3%17% 13% 10% 10% $2;329 $2,154 $8,152
2000 3% 18% 13% 10% 11% $2;323 $2,130 $8,681
2001 3% 19% 14% 12%· 12%$2,351 $2,139 $8,533
2002 4% 19% 14% 13% 13% $2,531 $2,278 $9,349
2003 4% 19% 15% 14% 14% $2,848 $2,543 $9,786
2004 5% 20% 16% 16% 16% $3,146 $2,783 $9,909
2005 6% 21%18% 17% 17%$3,364 $2,947 $1.0;153
2006 6% 22% 19% 18% 18% $3,420 52,968 . $10,498
2007 7% 23% 19% 19% 19% $3,407 $2,944 $10,074
2008 8% 24% 21% 22% 22% $3,740 $3,173 $10541
m)J~!!;S&~~ff~~~~~~~~~jW~~~1\¥fE:~~it~~

We must take note that because For-profit students receive 3-5x as much Title IV aid as traditional
students and are growing enrollment at 3x the pace of traditional schools. these early warning
signs must be addressed now before the impact is felt in the coming years...

20
SoiJrce: College Board
If history is any guide, we will return to late-80's Cohort Default rates in 1-2 years,
the worst period of recorded default rates in the history of the DOE

Average Total Loans + Grants per For-profit student vs. DOE Official CDRs, 1987 - 2009

I _Avg Loans + Grants -Official CDR I

$16,000 I. I 24%

$15,000
20%'
$14,000

~ $13,000 16%

-lii
Q)
~
::J
IIJ ,
'"o
(.)
$12,000
:!
0.

~
' ,
12% e
o
~ $11,000 w
l- o
o
io '
I- $10,000 8%

$9,000
4%
$8,000

~IOOO'-'-i-l- - -,-,- -'-1.-'-'-'- - -,- ~ ~i-I-l-i-l-IO%

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
~~~~~~~~~~~~~~~~~~~~~~~~
~ * ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

21
Source: College Board, US Dept of Education
Because of the excessive drop-out rates and high debt burdens of graduates, the credit
statistics. for government loans at for-profits are deteriorating at an alarming pace

Corinthian Colleges Cohort Default Rates, 2004 • 2008

42% -, -------'-........:..--------~--------,...------------~~~--ll 40%

40% I -+- 2-yr rates ~ 3~yr rates I
38%

36%

34%

32%
30%
30%

28%

26%

24%

22% 21%

·20%

18%

16%

14%

12% 11%
11%

10°.4 I I " I
2004 2005 2006 2007 2008

Source: Company-reported financials; note: 2008 2-yr rates still preliminary, 3-yr rates estimated

22
 . ',~ ..
Currently, for-profit institutions provision 50 - 60% on loans they mak~rto t; :jr
own students...these are students who already have Title IV loans "

• ' Companies are provisioning for more than 50%+ loss on loans they make to students:....
which means they expect more than 1 out of every 2 loans to go bad ''

• But absent any regulatory threat, these companies could care less if they every loan tflley
'made went bad because the per-student profitability of their models is so high!
.' . . .

• ' Both companie$ would still be hugely profitable on a per-student basis even with a 10<»0/0
losses on every loan they m a d e ,
. .. ~

. ~"

ESI coco ESI earns moret~an f ,:jes the

Title IV loans, grants and' p~vate loans $16,959 $14,443 a~ount it exp~~ ,,' to, 'l. from
Internal company loan per student $2,100 $1,770 mternal loan$ to sf <:'nts.
$19,059 $16,213 , :.'
Tuitionper student (2009)
CO?O earns mote, th,~' ,times
,Provision for loan losses (%) 50% 58% Its expected)pan j" as.
Expected losses on internal loans ($1,050) ($1,027)

Note: OP / student equals change in operating profit over change in total enrollment
Loan loss provisions provided by companies

23
Reported statistics... Cohort Default Rates (CDRs)

Cohort Default Rates (CDRs)

• CDRs are the percentage of a school's borrowers who enter repayment on a Federal Loan during a particular
federal FY (Oct 1 to Sep 30), and default prior to the end of the next FY .

• Effectively a 2~yr snapshot of the totaJstudents in defallit

• CDRs are em important measure of quality - if default rates breach the federally-mandated threshold of 25%
(soon to be,30%), schools can lose eligibility to Title IV ..

',', .
Can easily be manipulated to mask true defaults
'. Deferrals and forbearances used en mass to carry students over the 2 year reported timeframe

• Schools partner with Sallie Mae and other lenders to delay or manage down- defaults through the 2 year
timeframe in exchange for guaranteed loan volumes

• Schools pay down student government loans with internal money and collect directly from students

24
Reported statistics... the 90/10 rule

The 90/10 rule

• 90/10 says a for-profit may become ineligible to participate in Title IV programs if it derives more than 90% of its
cash basis revenue from Title IV programs

• Applies only"to for-profit institutions, effectively a cap on total Title IV dollars that can flow to a company as a
percentageof revenues .

• Intended to create a structural boundary for growth from Title IV dollars

Can also be rnanipulated

• Over-returning Title IV dollars to the government when students drop out and then billing studentsdirectly

• Pursue alternative government entitlement programs not counted under theTitle IV umbrella (military educational
loans grants)

• When all else fails, raise tuition! Students will have to find alternative (non-Title IV) funding sources to close the
gap between tuition and the amount of total Title IV loans

25
Reported statistics... completions and placements

Completions (graduation stats)

• Company-reported metric that measures the number of students who complete a program (graduate) in 150% of
normfill time (for example, 6 years of graduation data for a 4-year bachelors program)

• Non-traditional student body doesn't graduate together, and often takes much longer than normal to complete, so .
to
hard 'understand actual graduation by class
. . " '

• No independent verification of graduates

Placements'employmentstats)
. .

• Company-reported metric that measures the number of students who are placed- in a job they were trained for
(gainfulernployment)' .

• This is gainful employment?

- Trained nurses become janitors at hospitals

-. Homeland security degree grads become nighttime security guards at shopping malls

• And for those grads who cannot find employment. .. hire theml Most schools hire unemployed graduates
internally to boost reported placement stats

26
 As long as the government continues to flood the for-profit education
industry with loan· dollars,

AND

the risk:for these loans is borneSOLELY BY students and the government...

.. THEN·

,. , the industry has every incentive to:

'- Grow alall costs

,- Compensate employees based on enrollment
- Influence key regulatory bodies
- Manipulate reported statistics and other regulatory measures

ALL TO MAINTAIN ACCESS TO,THE GOVERNMENT'S MONEY.

NIts about the numbers. It will always be about the numbers. If

- Bill Brebaugh, head of University of Phoenix Corporate Enrollment

The entire business model of these companies is centered around growing enrollment -
it is the single most important measure of growth and profitabifit~ period.

Boiler room tactics:

Actual APOL compensation table snapshot
• .. "Every 6 months we get a review that looks at how
manystudents WeenrQ/led and what percentage of
..... ...,...
-
~1I111l_ • •
them finished their first class. As long as they finish ~ _

IiIIIMJ 11ft
.,.~
Rf!!fe!! .1IIIIl!IIIl
their first class we getJiJ/I credit and after that they are •.I O . ~ $2R $1.11>'-
. $2:Qt;1o_ .
111O,"~
. not our problem... ;1 . .. ~~ 1M J28k '. ~per.1_0.T,

sza ~
~--­
",1ft'CIIInIllllI $3Qk
•.. ."We are under so much pressure we are forcedio do 48~ ~tk
== $IlI2S pit' +1fno. 0.T.

..
<18~ ~ ss1k
,$$4ii p. • hI... O.T.
anything necessary to get people to fill but an 51. . . . . . $m $12k
$33
51~ $m
.application ... " a~ $SC1c. Aa
a .......... U4lc.

.........
55___.
54 ......... UIII. $34il

...
$Me te1....... 2_0.T.
• •. It's a boiler room -.Se./ling education topeople who se~
$35k.
~ $:D
'. don't really want it." 17~
.......-. ·PlIk
..m'k
Si$

- Ashford University (BPI) fornier enrollment

counselor·
ell~
W1~

.ee.--..
a........
.,....
a~·
........
mTc
I3a

$3IIk
An(
PJt<
P8IC
$We
A8I\
~"'"' +2:Il1O.D.T,

$11I151* .3_,0,".
• "The EC [enro/lmentcounselor] review matrix is all '"~
011 ____
61. ....
$4Ok
$4ilk
~
"'*
MJlc
$Q
smoke and mirrors so we could fly under the radar of 11I'_ _ _ _ so $'I.
the DOE. .."

- APOL former enrollment counselor

70 . . . . . . . .
71 . . . . . . .
$4GIC
J!II
f*1I< ....
H'lk
~. HfS..,Um9.T.

Source: Court documents, Hendow & Albertson VS. UOP, filed 2009

28
Accreditation...the inmates running the asylum

What is Accreditation and why is it important? The Accrediting Council for Independent
Colleges and Schools (ACICS)
• Accreditation helps ensure that education
provided by institutions of higher education ACICS BOARD OF COMMISIONERS
meets acceptable levels of quality·
Dr. Gary R. Carlson - Chair Elect
• The Accreditation bodies are no~~governmental Vice President, Academic Affairs 6 of the 16 Board
members of ACICS
ITT Technical Institute
(non'-profit) PE3er-reviewing
. groups. are for-profit
Ms. Mary Hale Barry representatives
• Schools niust earn and maintain proper Senior Vice President, Chief Academic Officer
Accreditation to remain eligible to participate in Kaplan Higher Education .
. Title IV Programs ' . .
. Ms. Jill DeAtley·
Vice President of Regulatory Review .
• However, dueto.the peer-based composition of Career Education Corporation
the Accreditation boards, they cannot function
as a truly independent 3rd party review system Mr. Francis Giglio
Director of Compliance and Regulatory Services
Lincoln Educational Services
• In many instances, for-profit institution's
representatives sit on the boards of their Mr. David M. Luce
own Accrediting body, inevitably influencing Assistant Vice President. Accreditation and Licensing
Corinthian Colleges, Inc.
the approval process and oversight of their own
institutions! Mr. Roger Swartzwelder
Executive Vice President. General Counsel and Chief Compliance Officer
Education Corporation of America

*Not all 16 Board members .shown

We have seen this before ...rating agencies and subprime mortgages.

Is for-profit Accreditation the new credit agency scandal?
29
Accreditation...whenyou can't earn it, buy it·

• The latest trend of for-profit institutions is to acquire the dearly-covetedRegional Accreditation through the outright
purchase of small, financially distressed non-profitinstitutions .

• Regional Accreditation is the highest stamp of quality (Harvard is Regionally Accredited), and usually takes 5-10 years to earn
through a long peer review process of educational materials, curriculum, teachers, etc

• But whow~mts to wait 5 years?!

• Once acqUired, these institutions can serve as a shell'for the parent organization to funnel in thousands of students and continue
the growth c y c l e . . . · · .

• Past examples are Bridgepoint buying Regionally-Accfe<:iited Franciscan University of the Prairies (renamed Ashford University)
and more recent examples are ITT Tech buying DanietWebster, and Corinthian Colleges buying Heald College

BriddepointEducation (BPI) - a perfect model ...

BPI Total enrollment, 2005 ·2008

Timeline
80,000 I i
70,000
• MARCH 2005 - BPI acquires Regionally-Accredited 70,000
Franciscan University of the Prairies and renames
Ashford University. Ground enrollment 312= 60,000

50,000
• BPI flows students through online platform... grows
enrollment by 50,000+ students in 4 years 40,000

30,000
• Mgmt expects 70,000+ students by end of 2010
2.0,000
• 99% students now online, yet school retains its
Regional Accreditation 10,000
312

Mar-05 2006 2007 2.008 2009 2010E

Source: Company-reported financia/s

30
 •
•
•

~
:(\$
., .. ··c
. .;js
. ~ ". .~

CIJ
. . '
Summary

• The pace of the growth of the for-profit education industry and their growing claim to Federal monies
will require greater scrutiny to protect students and the integrity of Title IV lending

• The. primary revenue and profitability driver for the for-profit companies is unrestricted access to Title
IV loans and grant?
". '. . . .' ".".. . ..' . '. .

• For-profifeducation companies are now among the most profitable businesses in the world due to
'g,overnment largesse

• ·R~gulations builtaround company-reported statistics eire ineffective, and the Accreditationprbcess

for for-profit schools'Clnd programsiscompromised .

• . Disaggregation of risk from reward is the fundamental cause of all problems

32
Solutions -Gainful employment

• Gainful employment gets at part of the problem because it deals with debt loads, but verification is
problematic

• . Programs DO NOT have to be shut down for schools to remain compliant with new regulations

• Companies can restructure their business to accommodate the regulation and schools would
become more affordable and student debt loads. would be lower

•. However, a gainful employment metric would structurally reset the earnings power of companies

33
Solutions- Gainful employment analysis impact (key ass~mptions)

. .
1. Cost of programs based on reported cost I credit hour and program length

2. Percent of degree financed assumes Title IV o/q revenues less 10% (transfer credits and cash)

3. Debt service payment based on 7.5% interest rate (6.8% government loans 112% private) and 10-
yr repayment period

4. Starting sCllaries taken from applicable BLSc~des, by program category and job type

5. Debt servi~e I income ratio of 8% based on Gainful Employment proposed regulation

6. Student mixby program level and programtype used to calcul'ate total revenue impact
. .

7. Cost cuts ~stimated ona per-school basis, based on disclosed cost categories and industry experts
. ." " . . . ," ." . .... . ,:

8.. EPS impacts and PIE ratios based on existing reported information, share counts, and current
street EPS estimates

9. Scenario 1: Gainful Employment with no Offsetting Cost Cuts

10. Scenario 2: Gainful Employment with 5°!'o-150/0 Cost Cuts

34
Gain£-ql employment and APOL

·APm: Scenario 1 Scenario 2

Ac:tua12009 EPS $4.22 $4.22',

2009 EPS (adjustedl $1.32 ' $2.12
2009 EPS impact -69% -50%
,',

Street'2010 EPS Estimate

" ,
$5.07'
"IPS Impact ($2.90)
ii.11I~.I.,;c.~a;;.~• •I.I
2009 EPS impact -57%' -41%

Current PjE(2010 EPS) 10.8x 10.8 X

Note: PIE Ratios calculated as of 512112010

Source: Company-rf#)9rted financials, programs. tuition rates, and management conference calls. Street EPS estimates from Bloomberg, Projections based on program-
level tuition adjustments to comply with 8% debt service/income ratio and scenario 2 applies 5-15% cost cuts across education and SG&A to offset revenue declines.

35
Gainful employment and ESI

ESI Scenario 1 Scenario 2

IActual2009 EPS $7.91 $7.91

, 2009 EPS (adjlisted) ($0.22) $2.02
:.2009 EPS impact -103% -74%

"::IStreet 2010 EPSEstimate

'EPS Impact

2009 EPSimpact ..74% ~53%

Current PIE (2010 EPS) 10~O x 10.0 x

Note: PIE Ratios calculated as of 512112010

Source: Company-reported financ/a/s, programs, tuition rates, and management conference calfs, Street EPS estimates from Bloomberg. Projections based on program-
level tuition adjustments to comply with 8% debt service/income ratio and scenario 2 applies 5·15% cost cuts across education and SG&A to offset revenue declines.

36
Gainful employment and COCO

coco Scenario 1 .Scenario 2.

Actual 2009 EPS $0.81 $0.81

EPS (adjusted) ($0.76) $0.17
EPSimpact ~194% -79%

Street 2010 EPS Estimate . $1.67

EPS I·mpact ... ($1.57)

2009 EPS impact -94% -38%

Current PIE (2010 EPS)

Note: PIE Ratios calculated as of 5/21/2010

Source: Company-reported financia/s, programs, tuition rates, and management conference calls. Street cPS est/mates from Bloomberg. Projections based on program-
level tuition adjustments to comply with 8% debt servicelincome ratio and scenario 2 applies 5-15% cost cuts across education and SG&A to offset revenue decfines.

37
 ,

Gainful employment and EDMC·

EDMC Scenario 1 Scenario 2

Actu.a12009 EPS $0.87 . . $0.87

EPS (adjusted) ($5.50) . ($2.21)
.' .:
EPS'impact -732% -353%

StreetiOl0 EPS Estimate .

EPS Impact

Current PIE (2010 EPS)

Note: PIE Ratios calculated as of 512112010

Source: Company-reported finane/a/s, programs, tuition rates, and management conference calls. Street EP$ estimates from Bloomberg. Projections based on program-
level tuition adjustments toeomply with 8% debt service/income ratio and scenario 2 applies 5-15% cost euts across education and SG&A to offset revenue declines.

38
 Gainful employment andWPO (Kaplan).

WPO(Kaplanl Scenario 1 .Scenario 2

'. ,
..Actua 12009 EPS $9.78 $9.78.
EPS' (adjusted) ($33.25) ($6.19)·
'I EPS impact -440%· -163%

Note: PIE Ratios calculated as of 512112010

Source: Company-reported flnancials, programs, tuition rates, and management conference caf/s. Street EPS estimates from Bloomberg. Projections based on prOgram-
level tuition adjustments to comply with 8% debt service/income ratio and scenario 2 applies 5-15% cost cuts across education and SG&A to offset revenue declines,

39
If these trends continue, we believe the DOE will face nearly $275B in defaults over
the next 10 years on a half-a-trillion dollars of lending to the For-Profit Industry

Projected Cumulative Stafford Loans (in $ Billions) and Cumulative Defaulted Dollars
, for For-Profit Education Students, 2007 - 2020

$550 , I

• Total' Stafford Loans to FP students

$498
$500 • ProjeGted Defaulted Dollars

'$450

And because of feesassoc;ated with

,$400
d~fault, the gover,,"ment collects
I
'0 appr(Jximately $1.20 on every $1.00 lent...
'=:' $350
,iii , '

: "*" ...meaning For-profit students will owe

"i $300
, ,'CII ' $330 Billion' dollars on defaulted loans over ,
,0
,.J the next 10years
'.;;:: $250
, ',Gl

...E.
ji $200
...o
$150

$100·

$50

$0 ' - - ,
2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

40
Source: Col/ege Board, National Center for Education Statistics, industry estimates