Calendar 2000 Calendar 2001 Calendar 2002

ED conducted reviews of lenders 137 369 173

ED conducted reviews of servicers 1 2 6

ED conducted reviews of GA's 39 27 3

GA conducted reviews of lenders 23 GA's @ 154 25 GA's @ 254 19 GA's @ 114

GA conducted reviews of servicers 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 Occurrences Dollar Amount

Deficiencies in Reporting Loans

Eligible for Interest Benefits in Part
III of the ED799 58 $93,207

Failure to Report "Windfall Profits" 36 $86,571

Failure to Report Loan Fees 23 $10,271

Failure to Report Origination Fees 20 $13,180

Billing for Subsidy on Ineligible Loans 13 $18,852

Top 5 lender deficiencies by $

Liability: Calendar 2000 Total Liab: $374,213

Deficiencies in Reporting Loans

Eligible for Interest Benefits in Part
III of the ED799 58 $93,207

Unable to Document Accuracy of ED799

Billing from Lender's Portfolio 2 $92,805

Failure to Report "Windfall Profits" 36 $86,571

Billing for Subsidy on Ineligible Loans 13 $18,852

Defects in Conversion to Repayment 6 $18,840

ED conducted Servicer
Reviews: all deficiencies Total Liab: $90,804

Failure to Report "Windfall Profits" 2 $90,804

GA conducted Lender Reviews

All deficiencies: Calendar 2000 Total Liab: $46,880

Defects in Application of Payments,

Refunds, Borrower Adjustments, Interest
Rates 1 $282

Failure to report Prior Quarter

Adjustments or Incorrect Adjustments 2 $7,432

Billing during Delayed Interest Period 1 $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 Occurrences Dollar Amount

Unpaid Consolidation Loan Fees 55 $792,301

Deficiencies in Reporting Loans

Eligible for Interest Benefits in
Part III of the ED799 22 $73,038

Failure to Report Loan Fees 13 $35,350

Failure to Report Origination
Fees 13 $20,540

Billing for Subsidy on Ineligible

Loans 9 $1,533

Top 5 lender deficiencies by $

Liability: Calendar 2001 Total Liab: $1,040,608

Unpaid Consolidation Loan Fees 55 $792,301

Deficiencies in Reporting Loans

Eligible for Interest Benefits in
Part III of the ED799 22 $73,038

Not Filing ED799 in a Timely

Manner 1 $41,409

Failure to Report Loan Fees 13 $35,350

Incorrect Calculations for

Average Daily Balance 3 $31,482

ED conducted Servicer Reviews:

all deficiencies Total Liab: $529,312

Billing Ineligible Loans 1 $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 Occurrences Dollar Amount

Unpaid Consolidation Loan Fees 45 $1,045,556

Deficiencies in Reporting Loans

Eligible for Interest Benefits in Part
III of the ED799 13 $6,000

Failure to Report Loan Fees 7 $11,008

Failure to Report Origination Fees 6 $14,872

Defects in Conversion to Repayment 5 $2,635

Top 5 lender deficiencies by $

liability: Calendar 2002 Total Liab: $3,185,281

Billing Loans in an Incorrect Special

Loans Category 3 $2,077,242

Unpaid Consolidation Loan Fees 45 $1,045,556

Failure to Report Origination Fees 6 $14,872

Failure to Report Loan Fees 7 $11,008

Failure to Report "Windfall Profits" 2 $10,521

ED conducted Servicer Reviews

No deficiencies were input into PEPS in 2002

GA conducted Lender Reviews

All deficiencies: Calendar 2002 Total Liab: $137,185

Incorrect or ineligible Periods for

Deferments 1 $38

Deficiencies in Reporting Loans

Eligible for Interest Benefits in Part
III of the ED799 1 $3

Failure to Report Loan Fees 1 $3,000

Not Filing ED799 in a Timely Manner 1 $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 Occurrences Dollar Amount

Satisfactory academic progress

standards not adequately monitored or
applied/impared administrative
capability 7 $8,297
Overaward--financial need exceeded 4 $9,436
Refund calculation incorrect 3 $21,074
Pell--overpayment/underpayment 3 $825
Refund made late to Title IV account 3 $1,512

Top 5 school deficiencies by $

liability: Calendar 2002 Total Liab Collected in 2002: $164,349

FFEL Certified without Federal Pell

Grant eligiblity determination 1 $30,222
Refund calculation incorrect 3 $21,074
Student credit balance deficiencies 2 $20,614
Maximum annual ir cumulative FFEL
awardchecks
FFEL exceeded
delivered before 3 $14,837
enrollment 1 $11,144