LENDER DEFICIENCY CODES IN PEPS

Code 6000 6010 6015 6020 6030 6050 6060 6070 6080 6090 6100 6110 6150 6160 6170 6180 6200 6210 6217 6220 6230 6250 6260 6300 6310 6320 6330 6340 6350 6360 6390 6400 6420 6421 6422 6423 6424 6425 6430 6450 6500 6520 6530 6540 6550 6580 Explanation Management & Reporting Deficiencies Not Filing ED 799 in a Timely Manner Not Reimbursing ED for Credit Balances Missing Documents in Borrower Files Documents Do Not Support Loan Detail or ED799 Records Non Segregation of Duties (Lender Audit) Failure in Reporting or Meeting Requirements of the Plan for Doing Business Not Completing, Inaccurate GA Required Reports (Lender Manifest, PIF, etc.) Not Completing, Inaccurate Other GA Required Reports (eg. Reconciliation) Not Responding to Program Review Findings Failure to Comply with GA or ED Reporting Requirements Failure to Report Insurance Fees to the GA Failure to Notify GA of Loan Purchase Failure to Notify GA of Consolidation Loan for Guaranty Failure to Notify GA of Underlying Loan PIF by Consolidation Failure to Notify GA for Pre-Claim Assistance (Default Aversion) Deficiencies in Reporting New Loans for Fees in Part II of the ED799 Failure to Report Origination Fees Failure to Pay Fees on Loans Bought / Sold Failure to Report Loan Fees Failure to Cancel 120 Day Checks; Billing Past Eligibility for Outstanding Checks Failure to Report Prior Quarter Adjustments or Incorrect Adjustments Unpaid Consolidation Loan Fees Deficiencies in Reporting Loans Eligible for Interest Benefits in Part III of the ED799 Failure to Report "Windfall Profits" Billing Loans at an Incorrect Interest Rate Incorrect Calculations for Average Daily Balance Failure to Apply "Windfall Profits" to Borrowers' Accounts Failure to Report Prior Quarter Adjustments or Incorrect Adjustments Billing During Delayed Interest Period Billing for Subsidy on Ineligible Loans Deficiencies in Reporting Loans Eligible for Special Allowance in Part IV of the ED799 Billing Loans in an Incorrect Special Allowance Category Tax Exempt - Incorrectly coding loans as floor eligible - non-TTPA Tax Exempt - Bond Issues incorrectly coded as floor eligible - non-TTPA Tax Exempt - Incorrectly coding loans as floor eligible - TTPA Tax Exempt - Bond Issues incorrectly coded as floor eligible - TTPA Tax Exempt - Other floor related violations Incorrect Calculations for Average Daily Balance Failure to Report Prior Quarter Adjustments or Incorrect Adjustments Failure to Document Specific Activities Loan Records Do Not Support Part V Submissions Charging Interest to the Borrower During Eligible Periods of Deferment Incorrectly Capitalizing Interest Billing Loans Not Eligible Due to Sale / Purchase (After / Prior to Date of Ownership) Failure to Submit or Document Claims

Appendix A, Page 158

LENDER DEFICIENCY CODES IN PEPS
6590 6600 6610 6620 6650 6670 6690 6700 6710 6799 6800 6810 6820 6830 6840 6850 6855 6860 6870 6880 6900 6910 6930 6940 6970 6980 6990 6999 Billing Ineligible Loans ED799 Does Not Reflect Lender's Portfolio Unable to Document Accuracy of ED799 Billing from Lender's Portfolio Loan Records Do Not Support Part VI Submissions Loan Summaries Do Not Equal Loan Details Billing for Loans After Sale Unable to Document Accuracy of ED799 from Loan Servicer Records Failure in Completing the ED799 Failure to Correct Prior Program Review Findings Improper Calculations or Reporting of Loans Across Multiple Sections of the ED799 Failure in Loan Servicing (Borrower Services) Defects in Promissory Notes Defects in Application of Payments, Refunds, Borrower Adjustments, Interest Rates Defects in Disbursement Defects in Disclosure Defects in Conversion to Repayment Failure to Notify Borrower of Loan Purchase Defects in Due Diligence of Collections Defects in Responding to Borrower Requests Defects in Skip Tracing General Program Requirements, Fraud, Abuse Failure to Do Credit Bureau Reporting Incorrect or Ineligible Periods for Deferments Incorrect or Ineligible Periods for Forbearances General Lack of Controls, Internal Reconciliation Necessary General Lack of Controls, Abuse, Independent Audit Required Falsification of Records, Refer to OIG Unknown Prior Deficiency Code

Appendix A, Page 159