Calendar 2000 Calendar 2001 Calendar 2002 ED conducted reviews of lenders ED conducted reviews of servicers ED conducted reviews of GA's GA conducted

reviews of lenders GA conducted reviews of servicers 137 1 39 369 2 27 173 6 3

23 GA's @ 154 25 GA's @ 254 19 GA's @ 114 0 1 GA @ 7 3 GA's @ 4

Source: Postsecondary Education Participants System (PEPS) as of 1/9/2003

ED Conducted Reviews
Top 5 lender deficiencies by # occurrences: Calendar 2000 Deficiencies in Reporting Loans Eligible for Interest Benefits in Part III of the ED799 Failure to Report "Windfall Profits" Failure to Report Loan Fees Failure to Report Origination Fees Billing for Subsidy on Ineligible Loans Top 5 lender deficiencies by $ Liability: Calendar 2000 Deficiencies in Reporting Loans Eligible for Interest Benefits in Part III of the ED799 Unable to Document Accuracy of ED799 Billing from Lender's Portfolio Failure to Report "Windfall Profits" Billing for Subsidy on Ineligible Loans Defects in Conversion to Repayment Occurrences Dollar Amount

58 36 23 20 13

$93,207 $86,571 $10,271 $13,180 $18,852

Total Liab: $374,213

58

$93,207

2 36 13 6

$92,805 $86,571 $18,852 $18,840

ED conducted Servicer Reviews: all deficiencies
Failure to Report "Windfall Profits" 2

Total Liab:

$90,804

$90,804

GA conducted Lender Reviews
All deficiencies: Calendar 2000 Total Liab: $46,880

Defects in Application of Payments, Refunds, Borrower Adjustments, Interest Rates Failure to report Prior Quarter Adjustments or Incorrect Adjustments Billing during Delayed Interest Period

1

$282

2 1

$7,432 $39,166

GA conducted Servicer Reviews
No deficiencies were input into PEPS in 2000

ED Conducted Reviews
Top 5 lender deficiencies by # occurrences: Calendar 2001 Unpaid Consolidation Loan Fees Deficiencies in Reporting Loans Eligible for Interest Benefits in Part III of the ED799 Failure to Report Loan Fees Failure to Report Origination Fees Billing for Subsidy on Ineligible Loans Top 5 lender deficiencies by $ Liability: Calendar 2001 Unpaid Consolidation Loan Fees Deficiencies in Reporting Loans Eligible for Interest Benefits in Part III of the ED799 Not Filing ED799 in a Timely Manner Failure to Report Loan Fees Incorrect Calculations for Average Daily Balance ED conducted Servicer Reviews: all deficiencies Billing Ineligible Loans 1 55 Occurrences Dollar Amount 55 $792,301

22 13 13

$73,038 $35,350 $20,540

9

$1,533

Total Liab: $792,301

$1,040,608

22

$73,038

1 13

$41,409 $35,350

3

$31,482

Total Liab:

$529,312

$529,312

GA conducted Lender Reviews
No deficiencies were input into PEPS in 2001

GA conducted Servicer Reviews
No deficiencies were input into PEPS in 2001

ED Conducted Reviews
Top 5 lender deficiencies by # occurrences: Calendar 2002 Unpaid Consolidation Loan Fees Deficiencies in Reporting Loans Eligible for Interest Benefits in Part III of the ED799 Failure to Report Loan Fees Failure to Report Origination Fees Defects in Conversion to Repayment Top 5 lender deficiencies by $ liability: Calendar 2002 Billing Loans in an Incorrect Special Loans Category Unpaid Consolidation Loan Fees Failure to Report Origination Fees Failure to Report Loan Fees Failure to Report "Windfall Profits" ED conducted Servicer Reviews No deficiencies were input into PEPS in 2002 Occurrences Dollar Amount 45 $1,045,556

13 7 6 5

$6,000 $11,008 $14,872 $2,635

Total Liab:

$3,185,281

3 45 6 7 2

$2,077,242 $1,045,556 $14,872 $11,008 $10,521

GA conducted Lender Reviews
All deficiencies: Calendar 2002 Total Liab: $137,185

Incorrect or ineligible Periods for Deferments Deficiencies in Reporting Loans Eligible for Interest Benefits in Part III of the ED799 Failure to Report Loan Fees Not Filing ED799 in a Timely Manner

1

$38

1 1 1

$3 $3,000 $134,144

GA conducted Servicer Reviews
No deficiencies were input into PEPS in 2002

GA conducted School Reviews

Top 5 school deficiencies by # occurrences: Calendar 2002 Satisfactory academic progress standards not adequately monitored or applied/impared administrative capability Overaward--financial need exceeded Refund calculation incorrect Pell--overpayment/underpayment Refund made late to Title IV account Top 5 school deficiencies by $ liability: Calendar 2002 FFEL Certified without Federal Pell Grant eligiblity determination Refund calculation incorrect Student credit balance deficiencies Maximum annual ir cumulative FFEL awardchecks delivered before FFEL exceeded enrollment

Occurrences Dollar Amount

7 4 3 3 3

$8,297 $9,436 $21,074 $825 $1,512

Total Liab Collected in 2002:

$164,349

1 3 2 3 1

$30,222 $21,074 $20,614 $14,837 $11,144