2023-11-14T17:17:28-06:00 2022-12-31 135565207 KPMG LLP 90 S 7TH ST STE 4200 MINNEAPOLIS MN 55402 990 2022-01-01 411778617 EDUCATIONAL CREDIT MANAGEMENT CORPORATION EDUC 6512210566 111 WASHINGTON AVE SO 1400 MINNEAPOLIS MN 55401 MARTIN A SCANLON CFO & TREASURER 6512210566 2023-11-14 1 MARTIN SCANLON 999009999 0 MONROE GIERL P01413237 6123055000 2 AAL1 IAL1 2022 2023-04-26 12:10:37Z CHAD TATE 111 WASHINGTON AVE SO 1400 MINNEAPOLIS MN 55401 361979726 0 X WWW.ECMC.ORG X 1994 MN SEE SCHEDULE OEDUCATIONAL CREDIT MANAGEMENT CORPORATION (ECMC) PROVIDES FINANCIAL COUNSELING AND EDUCATION TO EMPOWER STUDENTS TO MAKE BETTER CHOICES ABOUT THEIR FUTURES.ECMC, A 501(C)(3) ORGANIZATION, IS A NATIONAL GUARANTY AGENCY DESIGNATED BY THE U.S. SECRETARY OF EDUCATION UNDER AND PURSUANT TO THE PROVISIONS OF THE HIGHER EDUCATION ACT OF 1965, AS AMENDED. IN 2013, ECMC ADDED THE SOLUTIONS PROGRAM, PROVIDING DEFAULT PREVENTION AND FINANCIAL LITERACY TO STUDENT LOAN BORROWERS TO HELP THEM UNDERSTAND THEIR REPAYMENT OPTIONS BEFORE BECOMING DELINQUENT OR DEFAULTING ON THEIR FEDERALLY INSURED STUDENT LOANS. THE PROGRAM INCLUDES RESOURCES FOR POSTSECONDARY INSTITUTIONS TO ASSIST THEM IN MANAGING THEIR COHORT DEFAULT RATE. SERVICES ARE OFFERED TO POSTSECONDARY INSTITUTIONS UNDER A FEE STRUCTURE. 10 9 343 0 0 0 2234612 2150000 421807940 359485454 10722 312952 18480 31320 424071754 361979726 279916216 249820764 0 0 50343664 49312550 0 0 0 44142113 39480154 374401993 338613468 49669761 23366258 748768663 429860105 689689772 347414956 59078891 82445149 X EDUCATIONAL CREDIT MANAGEMENT CORPORATION (ECMC) PROVIDES FINANCIAL COUNSELING AND EDUCATION TO EMPOWER STUDENTS TO MAKE BETTER CHOICES ABOUT THEIR FUTURES. 0 0 26099460 0 253320539 DEFAULT AVERSION, CLAIMS AND COLLECTION PROGRAM:IN EDUCATIONAL CREDIT MANAGEMENT CORPORATION'S (ECMC'S) ROLE AS A FEDERAL STUDENT LOAN GUARANTOR, WE ARE RESPONSIBLE TO PERFORM DEFAULT PREVENTION ACTIVITIES, REIMBURSE LENDERS FOR DEFAULT AND OTHER TYPES OF CLAIMS, AND RECOVER DEFAULTED STUDENT LOANS. DEFAULT PREVENTION PROGRAM: ECMC HAS A ROBUST DEFAULT PREVENTION PROGRAM FOCUSED ON EDUCATING AND COUNSELING DELINQUENT BORROWERS ON REPAYMENT STRATEGIES TO FIND THE ONE THAT BEST FITS THEIR SITUATION SO THEY CAN SUCCESSFULLY REPAY THEIR LOAN. ECMC'S COMMITMENT TO PREVENTING DEFAULTS IS STRONG; OUR POSITIVE RESULTS REFLECT OUR DEDICATION TO THIS PROGRAM. COLLECTION PROGRAM: FOR THOSE BORROWERS WHO FACE THE UNFORTUNATE SITUATION OF STUDENT LOAN DEFAULT, IT IS NOT ONLY OUR FIDUCIARY RESPONSIBILITY TO THE U.S. TREASURY AND THE TAXPAYER TO COLLECT THOSE LOANS, ECMC IS ALSO COMMITTED TO HELPING THE BORROWER RECOVER FROM DEFAULT. FORTUNATELY, CONGRESS HAS GIVEN US TOOLS TO DO SO, SUCH AS THE LOAN REHABILITATION PROGRAM WHERE WE ARE GIVEN SIGNIFICANT LATITUDE TO ESTABLISH AN INCOME-CONTINGENT REPAYMENT ARRANGEMENT WITH THE BORROWER. WITH SUCCESSFUL COMPLETION OF THIS PROGRAM, THE DEFAULT STATUS IS REMOVED FROM THE BORROWER'S RECORD. SINCE INCEPTION, ECMC HAS RETURNED $21.5 BILLION IN STUDENT LOAN RECOVERIES TO THE U.S. TREASURY.IN MARCH 2020, A NOVEL STRAIN OF CORONAVIRUS, REFERRED TO AS COVID-19, WAS DECLARED A GLOBAL PANDEMIC AND CAUSED SIGNIFICANT DISRUPTION IN THE UNITED STATES AND WORLD ECONOMIES. AS A RESULT OF COVID-19, CONGRESS PASSED A SERIES OF LEGISLATIVE STIMULUS BILLS, WHICH CONTAINED PROVISIONS FOR RELIEF FOR SOME STUDENT BORROWERS. ON MARCH 27, 2020, THE CORONAVIRUS AID, RELIEF, AND ECONOMIC SECURITY (CARES) ACT WAS SIGNED INTO LAW. ON APRIL 3, 2020, THE U.S. DEPARTMENT OF EDUCATION (ED) ISSUED ADMINISTRATIVE GUIDANCE TO GUARANTY AGENCIES, WHICH WERE NOT COVERED BY THE CARES ACT, TO STOP COLLECTION ACTIVITIES ON DEFAULTED STUDENT LOANS UNTIL SEPTEMBER 30, 2020. ON MARCH 30, 2021, ECMC RECEIVED VERBAL GUIDANCE FROM ED INTENDED TO EXTEND THE SAME BENEFITS TO DEFAULTED FFELP BORROWERS THAT DIRECT LOAN BORROWERS RECEIVED UNDER THE CARES ACT. ED VERBALLY DIRECTED GUARANTY AGENCIES TO STOP INTEREST ACCRUAL AND INVOLUNTARY COLLECTIONS FOR DEFAULTED FFELP BORROWERS UNTIL SEPTEMBER 30, 2021, SUBSEQUENTLY EXTENDED TO DECMEBER 31, 2022. ON MAY 12, 2021, ED ISSUED A DEAR COLLEAGUE LETTER (DCL) GEN-21-03 CONFIRMING THIS PREVIOUSLY PROVIDED DIRECTION AND EXPRESSLY AUTHORIZING GUARANTORS TO REIMBURSE THEMSELVES FROM THEIR FEDERAL FUND FOR BORROWER REFUNDS, ADJUSTMENTS AND LOST DEFAULT COLLECTIONS REVENUES DUE TO THE COLLECTIONS PAUSE. ON DECEMBER 2, 2022, ED ISSUED DCL GEN-22-16 INFORMING GUARANTORS OF THEIR OBLIGATIONS REGARDING FFELP LOANS THAT ARE IN DEFAULT ACCORDANCE WITH THE FRESH START INITIATIVE THAT WOULD ELIMINATE NEGATIVE EFFECTS FOR FEDERAL STUDENT LOAN BORROWERS WHO OPT IN AND ARE IN DEFAULT. IN GOOD FAITH, ECMC HAS COMPLIED WITH ALL DCL GUIDANCE AND UTILIZED HISTORICAL RECOVERY RATES TO DERIVE THE ESTIMATED AMOUNTS, WHICH ARE SUBSTANTIATED BY ECMC'S FINANCIAL REPORTING TO ED. ECMC RECORDED $235.2 MILLION FOR REIMBURSEMENT OF LOST COLLECTIONS REVENUE RESULTING FROM THE COLLECTIONS PAUSE PUBLISHED IN THE DCL, $78.6 MILLION OF WHICH IS A RECIEVABLE AS OF DECEMBER 31, 2022. ON NOVEMBER 21, 2022, PRESIDENT BIDEN ANNOUNCED ANOTHER EXTENSION OF THE COLLECTIONS PAUSE PENDING THE SUPREME COURT'S REVIEW OF LOAN FORGIVENESS; PAYMENTS ARE TO RESUME ON THE EARLIER OF 60 DAYS AFTER LITIGATION RESOLUTION OR AUGUST 29, 2023. 13235692 1886267 45298700 LOAN GUARANTEE PROGRAM:EDUCATIONAL CREDIT MANAGEMENT CORPORATION (ECMC) IS THE DESIGNATED GUARANTY AGENCY FOR CALIFORNIA, CONNECTICUT, ILLINOIS, MAINE, MISSOURI, OREGON, RHODE ISLAND, SOUTH CAROLINA, TENNESSEE, AND VIRGINIA UNDER THE FEDERAL FAMILY EDUCATION LOAN PROGRAM (FFELP). A GUARANTY AGENCY UNDER FFELP PROVIDES FEDERAL STUDENT LOAN GUARANTEES AND ONGOING PROCESSING SERVICES TO U.S. DEPARTMENT OF EDUCATION-APPROVED FFELP LENDERS AND POSTSECONDARY EDUCATION STUDENTS AND THEIR PARENTS FOR LOANS EXTENDED UNDER FFELP. FFELP WAS ESTABLISHED BY THE U.S. CONGRESS AS A MEANS OF MAKING LOANS AVAILABLE TO STUDENTS ATTENDING QUALIFYING POSTSECONDARY EDUCATIONAL INSTITUTIONS AND TO PARENTS OF SUCH STUDENTS. FFELP PROVIDES FOR THE GUARANTOR TO GUARANTEE THE REPAYMENT OF PRINCIPAL AND ACCRUED INTEREST TO THE LENDER FOR EACH ELIGIBLE LOAN. ADDITIONAL SERVICES PROVIDED BY ECMC IN FULFILLING ITS ROLE AS A GUARANTY AGENCY INCLUDE, BUT ARE NOT LIMITED TO: ASSISTING BORROWERS AND PARENTS IN PREPARING FOR COLLEGE, FINANCIAL LITERACY AND MONEY MANAGEMENT EDUCATION, EDUCATION REGARDING THE OBLIGATIONS ASSOCIATED WITH STUDENT LOANS, AND EDUCATION ON HOW TO AVOID STUDENT LOAN DEFAULT.ON MARCH 30, 2010, THE HEALTH CARE AND EDUCATION AFFORDABILITY RECONCILIATION ACT OF 2010 WAS SIGNED INTO LAW AND AMENDED THE HIGHER EDUCATION ACT BY TERMINATING THE AUTHORITY TO MAKE OR INSURE NEW LOANS UNDER FFELP AFTER JUNE 30, 2010. AS A RESULT, ECMC CEASED GUARANTEEING LOANS EFFECTIVE JULY 1, 2010. ALL EXISTING FFELP LOANS WILL CONTINUE TO BE GUARANTEED AND SERVICED AS FFELP LOANS THROUGHOUT THEIR REMAINING LIFE, WHICH GENERALLY AVERAGES 6 YEARS. AS OF DECEMBER 31, 2022, THE NON-DEFAULT GUARANTEE PORTFOLIO CONSISTED OF $14.8 BILLION IN ORIGINAL OUTSTANDING PRINCIPAL BALANCE.ON NOVEMBER 1, 2016, ECMC ENTERED INTO A THREE-YEAR AGREEMENT WITH THE U.S. DEPARTMENT OF EDUCATION (ED), WHEREBY ECMC WILL PARTICIPATE IN ED'S PROJECT SUCCESS BY PROVIDING SERVICES ON BEHALF OF ED TO CERTAIN MINORITY-SERVING INSTITUTIONS (INSTITUTIONS). THE SERVICES THAT ECMC MAY PROVIDE TO THE INSTITUTIONS INCLUDE INSTITUTIONAL SUPPORT SERVICES TO BENEFIT THE INSTITUTIONS AND SERVICES TO ASSIST THE INSTITUTION'S STUDENTS. ALL OF THE SERVICES PROVIDED MUST RELATE TO FEDERAL STUDENT LOANS. THE SECRETARY HAS AUTHORIZED ECMC TO USE THE GUARANTOR FEDERAL RESERVE FUND TO PAY THE COST OF PROVIDING SERVICES UNDER THE PROJECT SUCCESS PROGRAM, NOT TO EXCEED $20 MILLION FOR THE THREE-YEAR AGREEMENT. THE AGREEMENT WAS RENEWED ON NOVEMBER 1, 2019, FOR AN ADDITIONAL THREE YEARS SUBSEQUESNTLY EXTENDED THROUGH MARCH 31, 2023. THE GUARANTOR FEDERAL RESERVE FUND REIMBURSED ECMC FOR EXPENSES INCURRED IN THE AMOUNT OF $2.3 MILLION FOR THE YEAR ENDED DECEMBER 31, 2022. 3779444 0 3779444 BANKRUPTCY SERVICING:EDUCATIONAL CREDIT MANAGEMENT CORPORATION (ECMC) SERVICES AND MONITORS THE BANKRUPTCY CASES ON FFELP STUDENT LOANS CURRENTLY UNDER CHAPTER 7 OR 13 OF THE BANKRUPTCY CODE. THE BANKRUPTCY LOANS ARE TRANSFERRED FROM THE U.S. DEPARTMENT OF EDUCATION (ED) AND OTHER GUARANTY AGENCIES FOR PROCESSING BY ECMC. AT THE REQUEST OF ED, SPECIALTY STUDENT LOAN SERVICES ARE ALSO PERFORMED FOR ED. THE BANKRUPTCY STUDENT LOAN PORTFOLIO AT DECEMBER 31, 2022 CONSISTED OF $742 MILLION IN OUTSTANDING PRINCIPAL, INTEREST AND FEES. 247934497 247934497 CONTRIBUTIONS MADE TO ECMC GROUP, INC.:ECMC GROUP, INC. IS THE PARENT OF AND A SUPPORTING ORGANIZATION TO EDUCATIONAL CREDIT MANAGEMENT CORPORATION (ECMC). ECMC GROUP, INC. RETAINS THE FOLLOWING AUTHORITY OVER ECMC:1. TO AUTHORIZE AMENDMENTS TO THE ARTICLES OF INCORPORATION AND BYLAWS.2. TO APPROVE THE STRATEGIC AND FINANCIAL PLANS.3. TO ELECT AND/OR APPROVE THE MEMBERS OF THE BOARD OF DIRECTORS.4. TO OVERSEE COORDINATION OF PROGRAMS AND SERVICES OFFERED.5. TO AUTHORIZE FORMATION, GOVERNANCE AND DISSOLUTION.ECMC GROUP, INC. AUTHORIZES THE DISTRIBUTION OF FUNDS FROM ECMC TO ECMC GROUP, INC. SECTION 422B OF THE HIGHER EDUCATION ACT OF 1965, AS AMENDED, ALLOWS ECMC TO INVEST FUNDS AT ITS DISCRETION IN ACCORDANCE WITH PRUDENT INVESTOR STANDARDS AND TO USE FUNDS FOR HIGHER EDUCATION-RELATED ACTIVITIES. ECMC DISTRIBUTES FUNDS TO ECMC GROUP, INC. TO INVEST AND TO DISTRIBUTE TO ECMC FOUNDATION AND ECMC EDUCATION, INC. TO USE FOR HIGHER EDUCATION-RELATED ACTIVITIES. 3570246 4089772 ECMC SOLUTIONS PROGRAM:THE ECMC SOLUTIONS PROGRAM FOCUSES ON PROVIDING DEFAULT PREVENTION AND FINANCIAL LITERACY TO STUDENT LOAN BORROWERS WHILE THEY ARE STILL IN SCHOOL, IN THEIR GRACE PERIOD OR IN REPAYMENT TO HELP THEM UNDERSTAND THEIR REPAYMENT OPTIONS BEFORE BECOMING DELINQUENT OR DEFAULTING ON THEIR FEDERALLY INSURED STUDENT LOANS. THE PROGRAM INCLUDES RESOURCES FOR POSTSECONDARY INSTITUTIONS TO ASSIST THEM IN MANAGING THEIR COHORT DEFAULT RATE. SERVICES ARE OFFERED TO POSTSECONDARY INSTITUTIONS UNDER A FEE STRUCTURE. 792007 52996999 THIRD-PARTY GUARANTOR SERVICING:EDUCATIONAL CREDIT MANAGEMENT CORPORATION (ECMC) PERFORMS FEDERAL FAMILY EDUCATION LOAN PROGRAM (FFELP) LOAN PORTFOLIO SERVICING ACTIVITIES FOR OTHER STATE AND NONPROFIT GUARANTORS OF FFELP LOANS IN RETURN FOR A FEE. FFELP GUARANTOR LOAN PORTFOLIO SERVICING ACTIVITIES ARE IDENTICAL TO THOSE SERVICES THAT IT PERFORMS ON ITS OWN BEHALF AND INCLUDE LOAN CONVERSION ACTIVITIES, DEFAULT AVERSION, BORROWER UPDATES, CUSTOMER SERVICE, PAYMENT PROCESSING, DUE DILIGENCE PROCEDURES AND CLAIM PROCESSING. 252296750 247934497 57086771 295411346 1 1 0 1 0 0 0 0 1 1 1 0 0 1 1 1 1 1 0 0 0 0 0 0 0 0 0 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 0 0 0 1 4897 0 343 1 0 0 0 0 0 0 0 0 0 0 0 0 X 10 9 1 0 0 0 1 1 1 1 1 0 0 1 1 1 1 1 1 1 1 0 CA OK OR X MARTIN A SCANLON 6512210566 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 X JAMES V MCKEON BOARD CHAIR 1.00 17.00 X 0 196250 0 MAURICE M SALTER DIRECTOR 1.00 10.00 X 0 157500 0 JULIA S GOUW DIRECTOR 1.00 8.00 X 0 155000 0 K PAUL SINGH DIRECTOR 1.00 7.00 X 0 152500 0 DIANA J INGRAM DIRECTOR 1.00 11.00 X 0 156250 0 JACK O'CONNELL DIRECTOR 1.00 10.00 X 0 140000 0 DEREK LANGHAUSER DIRECTOR 1.00 9.00 X 0 137500 0 JENNIFER ANDERSON DIRECTOR 1.00 10.00 X 0 132500 0 JAMES RUNCIE DIRECTOR 1.00 11.00 X 0 127500 0 JEREMY J WHEATON PRES & CEO-PART YR, SR ADVISOR 0.00 40.00 X 0 1271506 52529 DANIEL S FISHER GRP PRES & CEO (EFF 7-3-22) 0.00 40.00 X X 0 1013493 112447 MARTIN A SCANLON CFO & TREASURER 0.00 40.00 X 0 851966 96996 CHAD TATE ECMC PRESIDENT (EFF 7-3-22) 40.00 0.00 X 437075 0 74385 THERESE B BICKLER VP, ECMC OPERATIONS 40.00 0.00 X 316300 0 67679 PAULA J CRAW VP, OUTREACH 40.00 0.00 X 265922 0 32126 BRIAN BOARDMAN GRP GENERAL COUNSEL & CORP SEC 0.00 40.00 X 0 382212 76486 NATHAN VICKERY SR DIR, REPAYMENT SUCCESS CTR 40.00 0.00 X 221609 0 56051 NATE MALMO DIR, INTERNAL DEFAULT MGMT 40.00 0.00 X 186586 0 53063 J HAMLIN SJOBERG SR DIR, GUARANTOR SERVICES 40.00 0.00 X 211744 0 39002 JAN JACOBSON DIR, CUSTOMER SERVICE 40.00 0.00 X 196083 0 49620 HAN CHO DIR, PORTFOLIO MANAGEMENT 40.00 0.00 X 195005 0 52932 JOHN F DEPODESTA FORMER BOARD CHAIR 0.00 0.00 X 0 75000 0 ROBERTA COOPER RAMO FORMER DIRECTOR 0.00 0.00 X 0 60000 0 I KING JORDAN FORMER DIRECTOR 0.00 0.00 X 0 30000 0 GREGORY A VAN GUILDER FORMER CFO, GRP CIO 0.00 40.00 X 0 1343530 99504 2030324 6382707 862820 46 1 1 0 ALLIED INTERSTATE INC PO BOX 931203 COLUMBUS OH 44193 COLLECTION AGENCY 1081430 PIONEER CREDIT RECOVERY INC PO BOX 100 ARCADE NY 14009 COLLECTION AGENCY 908444 AUTOMATED COLLECTION SERVICES INC 2802 OPRYLAND DR NASHVILLE TN 37214 COLLECTION AGENCY 786782 NOBLE SYSTEMS CORPORATION 1200 ASHWOOD PKWY STE 300 ATLANTA GA 30338 IT SERVICE & SUPPORT 682492 PREMIERE CREDIT OF NORTH AMERICA 2002 WELLESLEY BLVD 100 INDIANAPOLIS IN 46219 COLLECTION AGENCY 470649 26 2150000 2150000 COLLECTION REVENUE 900099 245518022 245518022 THIRD-PARTY GUARANTOR 900099 52996999 52996999 CLAIM REPURCHASE 900099 34490554 34490554 ACCOUNT MAINTENANCE 900099 8958955 8958955 DEFAULT AVERSION 900099 8395783 8395783 9125141 9125141 359485454 312952 312952 INTERCOMPANY SERVICING 900099 31320 31320 31320 361979726 359485454 0 344272 249102543 249102543 718221 718221 1193487 1193487 38977742 21951090 17026652 1705771 974043 731728 4748428 3102439 1645989 2687122 1731394 955728 1929611 1266615 662996 499513 499513 260760 260760 5648304 1446698 4201606 10431929 3167366 7264563 2756171 2593277 162894 3121358 163067 2958291 414027 196548 217479 418132 180245 237887 5283321 113775 5169546 1223297 53271 1170026 DEFAULT AVERSION FEES 4616597 4616597 COMMISSION EXPENSE 1937290 1937290 PROJECT SUCCESS EXPENSE 179684 179684 760160 462936 297224 338613468 295411346 43202122 0 3141481 3178184 21912313 10520461 0 0 28935381 15977699 0 0 0 0 0 0 0 0 1297313 559594 1584195 1521998 253769 62197 0 0 0 0 0 0 5486250 2216666 687742156 397345304 748768663 429860105 7852620 7357132 311912 353208 999751 1363765 0 0 829597 1088312 0 0 0 0 0 0 679695892 337252539 689689772 347414956 X 55592891 78925149 3486000 3520000 59078891 82445149 748768663 429860105 23366258 0 X 0 1 X 1 1 1 X 0 2256993 925578 2234612 2150000 7567183 369655238 319718755 273320049 421826420 359516774 1744037236 369655238 321975748 274245627 424061032 361666774 1751604419 2256993 500000 1910000 2150000 6816993 23491999 27385124 19035350 36252863 30432977 136598313 23491999 29642117 19535350 38162863 32582977 143415306 1608189113 518994 729719 149808 10722 312952 1722195 518994 729719 149808 10722 312952 1722195 370174232 322705467 274395435 424071754 361979726 1753326614 0.91720 0.92520 0.00100 0.00000 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 1 0 0 0 0 1 298672 0 0 298672 0 PART II-B, LINE 1: GENERAL LOBBYING ACTIVITIES ON LEGISLATIVE ISSUES OF RELEVANCE TO EDUCATIONAL CREDIT MANAGEMENT CORPORATION. 0 1 X 3486000 664000 630000 3520000 3216000 964000 694000 3486000 3614000 398000 3216000 3781905 167905 3614000 4644123 862218 3781905 1.00000 0 0 68459 32882 35577 225000 225000 0 1290736 1264116 26620 62197 CUSTODIAL ASSETS HELD FOR GUARANTOR FEDERAL RESERVE 289476705 CUSTODIAL ASSETS HELD FOR FEDERAL SERVICES BUREAU 24446822 DUE FROM FEDERAL SERVICES BUREAU 4484372 DUE FROM GUARANTOR FEDERAL RESERVE 78602044 DUE FROM RELATED ORGANIZATIONS 67333 RIGHT OF USE ASSET 268028 397345304 OBLIGATIONS TO GUARANTOR FEDERAL RESERVE 289476705 OBLIGATIONS TO FEDERAL SERVICES BUREAU 24446822 DUE TO GUARANTOR FEDERAL RESERVE 19373568 DUE TO ECMC SHARED SERVICES COMPANY, LLC 3687415 LEASE LIABILITIES 268029 337252539 X 353404000 0 353404000 8575726 8575726 361979726 82103000 0 82103000 256510468 256510468 338613468 PART IV, LINE 2B: EXPLANATION OF ESCROW AGREEMENT EDUCATIONAL CREDIT MANAGEMENT CORPORATION (ECMC) IS UNDER CONTRACT TO SERVICE THE LOAN PORTFOLIO OF THIRD-PARTY GUARANTY AGENCIES. PORTFOLIO SERVICING ACTIVITIES INCLUDE LOAN CONVERSION ACTIVITIES, DEFAULT AVERSION, BORROWER UPDATES, CUSTOMER SERVICE, PAYMENT PROCESSING, DUE DILIGENCE PROCEDURES AND CLAIM PROCESSING. ASSOCIATED WITH SOME OF THESE ACTIVITIES, ECMC HOLDS FUNDS ON BEHALF OF OTHERS THAT INCLUDE DEPOSITS FOR BORROWERS TO BE APPLIED TO BORROWER ACCOUNTS AT SOME FUTURE TIME. ALL RECORDKEEPING FUNCTIONS FOR THE FUNDS ARE PERFORMED BY ECMC. PART V, LINE 4: INTENDED USES OF ENDOWMENT FUNDS EDUCATIONAL CREDIT MANAGEMENT CORPORATION (ECMC) HAD NET ASSETS WITH DONOR RESTRICTIONS OF $3,520,000 AT DECEMBER 31, 2022 FOR GRANTS ASSOCIATED WITH THE ECMC SCHOLARS PROGRAM THAT WILL BE RELEASED UPON THE OCCURRENCE OF CANDIDATES MEETING CERTAIN PROGRAM REQUIREMENTS. THE ECMC SCHOLARS PROGRAM IS A TWO-YEAR MENTORING PROGRAM AVAILABLE TO HIGH SCHOOL STUDENTS IN CONNECTICUT, OREGON AND VIRGINIA. THE PROGRAM IS DESIGNED FOR HIGH SCHOOL JUNIORS AND SENIORS TO HELP THEM BUILD ACADEMIC AND LIFE SKILLS. STUDENTS SELECTED TO PARTICIPATE IN THE ECMC SCHOLARS PROGRAM, AND COMPLETE THE PROGRAM, EARN GRANTS OF UP TO $4,000 AND $2,000 TO BE USED FOR THEIR FIRST AND SECOND YEARS, RESPECTIVELY, OF ENROLLMENT IN A DEGREE OR CERTIFICATE PROGRAM AT AN ACCREDITED COLLEGE, UNIVERSITY, OR CAREER AND TECHNICAL EDUCATION INSTITUTION. PART X, LINE 2: THE FIN48 (ASC 740) DISCLOSURE IN THE EDUCATATIONAL CREDIT MANAGEMENT CORPORATION (ECMC) FINANCIAL STATEMENTS READS AS FOLLOWS: "ECMC IS EXEMPT FROM TAX ON RELATED INCOME UNDER SECTION 501(C)(3) AND QUALIFIES AS A PUBLIC CHARITY UNDER SECTION 509(A)(2) OF THE INTERNAL REVENUE CODE. ECMC IS ALSO EXEMPT FROM STATE INCOME TAX. HOWEVER, ANY UNRELATED BUSINESS INCOME MAY BE SUBJECT TO TAXATION. ECMC FOLLOWS THE ACCOUNTING STANDARDS FOR CONTINGENCIES IN EVALUATING UNCERTAIN TAX POSITIONS. THIS GUIDANCE PRESCRIBES RECOGNITION THRESHOLD PRINCIPLES FOR THE FINANCIAL STATEMENT RECOGNITION OF TAX POSITIONS TAKEN OR EXPECTED TO BE TAKEN ON A TAX RETURN THAT ARE NOT CERTAIN TO BE REALIZED. NO LIABILITY HAS BEEN RECOGNIZED BY ECMC FOR UNCERTAIN TAX POSITIONS AS OF DECEMBER 31, 2022 AND 2021. ECMC'S TAX RETURNS ARE SUBJECT TO REVIEW AND EXAMINATION BY FEDERAL AND STATE AUTHORITIES." PART XI, LINE 4B - OTHER ADJUSTMENTS: BANKRUPTCY SERVICING 3,779,444. DEFAULT AVERSION FEES RETURNED TO THE GUARANTOR FEDERAL RESERVE FUND 4,616,598. PROJECT SUCCESS EXPENSES NOT REIMBURSED 179,684. PART XII, LINE 4B - OTHER ADJUSTMENTS: DISTRIBUTION TO ECMC GROUP, INC 247,934,497. BANKRUPTCY SERVICING 3,779,444. DEFAULT AVERSION FEES RETURNED TO THE GUARANTOR FEDERAL RESERVE FUND 4,616,598. PROJECT SUCCESS EXPENSES NOT REIMBURSED 179,684. ROUNDING ADJUSTMENT DUE TO AFS BEING REPORTED IN THOUSANDS 245. 1 ADAMS STATE UNIVERSITY 208 EDGEMONT ALAMOSA CO 81101 846000542 STATE SCHOOL 18500 0 PROJECT SUCCESS FOOD PANTRY ALLEN UNIVERSITY 1530 HARDEN ST COLUMBIA SC 29204 570341191 501C3 23115 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY AMERICAN UNIVERSITY OF PUERTO RICO INC PO BOX 602037 BAYAMON RQ 00960 RQ 660350945 501C3 10000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY BENEDICT COLLEGE 1600 HARDEN ST COLUMBIA SC 29204 570314365 501C3 24000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY CENTRAL CAROLINA TECHNICAL COLLEGE 506 N GUIGNARD DR SUMTER SC 29150 570425905 SCHOOL 19000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY CITY COLLEGES OF CHICAGO 1900 W JACKSON BLVD CHICAGO IL 60612 362606236 SCHOOL 13000 0 PROJECT SUCCESS FOOD PANTRY CLINTON COLLEGE 1029 CRAWFORD RD ROCK HILL SC 29730 570387838 501C3 7000 0 PROJECT SUCCESS EMERGENCY AID COLORADO COMMUNITY COLLEGES 900 W ORMAN AVE PUEBLO CO 81004 383721881 STATE SCHOOL 89000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY COPPIN STATE UNIVERSITY DEVELOPMENT FNDN 2500 W NORTH AVE BALTIMORE MD 21216 237127440 501C3 46000 0 PROJECT SUCCESS FOOD PANTRY DENMARK TECHNICAL COLLEGE 1126 SOLOMON BLATT BLVD DENMARK SC 29042 570529056 SCHOOL 21180 0 PROJECT SUCCESS FOOD PANTRY ELIZABETH CITY STATE UNIVERSITY 1704 WEEKSVILLE RD ELIZABETH CITY NC 27909 561047680 STATE SCHOOL 15000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY FAYETTEVILLE STATE UNIVERSITY 1200 MURCHISON RD FAYETTEVILLE NC 28301 561238736 STATE SCHOOL 10000 0 PROJECT SUCCESS EMERGENCY AID FAYETTEVILLE TECH COMMUNITY COLLEGE FOUNDATION INC 2201 HULL RD FAYETTEVILLE NC 28303 581640133 501C3 40000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY FIRST FRUITS FARM INC 20431 MIDDLETOWN RD FREELAND MD 21053 651220502 501C3 10000 0 PROJECT SUCCESS FOOD PANTRY GUILFORD TECHNICAL COMMUNITY COLLEGE PO BOX 309 JAMESTOWN NC 27282 560792519 STATE SCHOOL 10000 0 PROJECT SUCCESS EMERGENCY AID HAROLD WASHINGTON COLLEGE 30 E LAKE ST CHICAGO IL 60601 362606236 SCHOOL 15000 0 PROJECT SUCCESS EMERGENCY AID JOHNSON C SMITH UNIVERSITY 100 BEATTIES FORD RD CHARLOTTE NC 28216 250983069 501C3 14000 0 PROJECT SUCCESS EMERGENCY AID LANE COLLEGE 545 LANE AVE JACKSON TN 38301 620570060 501C3 25000 0 PROJECT SUCCESS FOOD PANTRY LEMOYNE-OWEN COLLEGE 807 WALKER AVE MEMPHIS TN 38126 620475690 501C3 25000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY LENOIR COMMUNITY COLLEGE PO BOX 188 KINSTON NC 28502 560753025 SCHOOL 15000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY LIVINGSTONE COLLEGE 701 W MONROE ST SALISBURY NC 28144 560603922 501C3 7000 0 PROJECT SUCCESS FOOD PANTRY LOS ANGELES CITY COLLEGE FOUNDATION 855 N VERMONT AVE LOS ANGELES CA 90029 956207819 501C3 15000 0 PROJECT SUCCESS FOOD PANTRY MORGAN STATE UNIVERSITY FOUNDATION INC 1700 E COLD SPRING LN TRUTH HALL 201 BALTIMORE MD 21251 237089143 501C3 20000 0 PROJECT SUCCESS FOOD PANTRY NC A&T STATE UNIVERSITY 1601 E MARKET ST GREENSBORO NC 27411 566000007 STATE SCHOOL 15000 0 PROJECT SUCCESS EMERGENCY AID NC CENTRAL UNIVERSITY FOUNDATION INC PO BOX 52466 DURHAM NC 27717 237410301 501C3 15000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY NEW MEXICO STATE UNIVERSITY PO BOX 30001 MSC - 4570 LAS CRUCES NM 88003 856000401 STATE SCHOOL 55000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY NORFOLK STATE UNIVERSITY 700 PARK AVE NORFOLK VA 23504 546002808 STATE SCHOOL 20000 0 PROJECT SUCCESS EMERGENCY AID NORTH CAROLINA WESLEYAN COLLEGE INC 3400 N WESLEYAN BLVD ROCKY MOUNT NC 27804 560686603 501C3 20115 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY PERALTA COMMUNITY COLLEGE DISTRICT 555 RALPH APPEZZATO MEMORIAL PKWY ALAMEDA CA 94501 941590799 STATE SCHOOL 25000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY PONTIFICAL CATHOLIC UNIV OF PUERTO RICO 2250 BLVD LUIS A FERRE AGUAYO STE 523 PONCE RQ 00717 RQ 660191965 SCHOOL 30000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY SAN DIEGO CITY COLLEGE FOUNDATION INC 1313 PARK BLVD ROOM T-160 SAN DIEGO CA 92101 237261624 501C3 15000 0 PROJECT SUCCESS EMERGENCY AID SAN DIEGO COMMUNITY COLLEGE DISTRICT 1313 PARK BLVD SAN DIEGO CA 92101 952644299 STATE SCHOOL 50000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY SISTEMA UNIVERSITARIO ANA G MENDEZ 1339 ANA G MENDEZ AVE SAN JUAN RQ 00928 660201206 501C3 75000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY SOUTH SUBURBAN COLLEGE 15800 S STATE ST SOUTH HOLLAND IL 60473 362597699 STATE SCHOOL 7000 0 PROJECT SUCCESS EMERGENCY AID SOUTHEAST NEW MEXICO COLLEGE 1500 UNIVERSITY DR CARLSBAD NM 88220 863488411 STATE SCHOOL 20000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY TRITON COLLEGE 2000 5TH AVE ROOM G-220 RIVER GROVE IL 60171 362537114 STATE SCHOOL 18000 0 PROJECT SUCCESS FOOD PANTRY UNIVERSIDAD DE PUERTO RICO EN AGUADILLA PO BOX 6150 AGUADILLA RQ 00604 RQ 660560807 SCHOOL 30000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY UNIVERSIDAD DE PUERTO RICO EN ARECIBO CARR 653 KM 08 BO LAS DUNAS ARECIBO RQ 00614 RQ SCHOOL 15000 0 PROJECT SUCCESS FOOD PANTRY UNIVERSIDAD DE PUERTO RICO EN UTUADO PO BOX 2500 UTUADO RQ 00641 RQ 660560808 SCHOOL 30000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY UNIVERSIDAD DE PUERTO RICO-COLEGIO BAYAMON 170 CARR MINILLAS INDUSTRIAL PARK BAYAMON RQ 00959 RQ 660560805 SCHOOL 23500 0 PROJECT SUCCESS FOOD PANTRY UNIVERSIDAD DEL SAGRADO CORAZON PO BOX 12383 SAN JUAN RQ 00914 RQ 660207156 501C3 25000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY UNIVERSIDAD POLITECNICA DE PUERTO RICO PO BOX 192017 SAN JUAN RQ 00919 RQ 660362666 501C3 25000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY WASHINGTON ADVENTIST UNIVERSITY 7600 FLOWER AVE TAKOMA PARK MD 20912 520643528 501C3 45000 0 PROJECT SUCCESS EMERGENCY AID & FOOD PANTRY MAPPING YOUR FUTURE INC PO BOX 1017 LAKE DALLAS TX 75065 460458615 501C3 7000 0 PROGRAM SUPPORT CONGRESSIONAL BLACK CAUCUS FOUNDATION 1720 MASSACHUSETTS AVE NW WASHINGTON DC 20036 521160561 501C3 36000 0 GENERAL SUPPORT CONGRESSIONAL HISPANIC CAUCUS INSTITUTE INC 1128 16TH STREET NW WASHINGTON DC 20036 521114225 501C3 30000 0 GENERAL SUPPORT ECMC GROUP INC 111 WASHINGTON AVE S STE 1400 MINNEAPOLIS MN 55401 411991995 501C3 247934497 0 GENERAL SUPPORT 47 0 COLLEGE NIGHT SCHOLARSHIPS 91 80471 THE COLLEGE PLACE SCHOLARSHIPS 14 7750 ECMC SCHOLARS SCHOLARSHIPS 201 630000 PART I, LINE 2: PROCEDURES FOR MONITORING USE OF GRANT FUNDS ECMC GROUP, INC. IS THE PARENT OF EDUCATIONAL CREDIT MANAGEMENT CORPORATION (ECMC) AND EXERCISES OVERSIGHT OF ECMC BY PROVIDING STRATEGIC DIRECTION AND COORDINATION OF PROGRAMS AND SERVICES OFFERED BY ECMC. ECMC GROUP, INC. AUTHORIZES THE DISTRIBUTION FROM ECMC TO ECMC GROUP, INC. ECMC AND ECMC GROUP, INC. HAVE OVERLAPPING BOARDS AND THE BOARD OF ECMC GROUP, INC. MONITORS THE USE OF GRANT FUNDS. THE REMAINDER OF THE GRANTS AND ASSISTANCE TO THE OTHER ORGANIZATIONS LISTED IN PART II ARE MINIMAL IN NATURE AND GENERALLY ARE ISSUED IN SUPPORT OF STUDENT FINANCIAL AID CONFERENCES AND ORGANIZATIONS AND DO NOT REQUIRE MONITORING. THE ASSISTANCE LISTED IN PART III ARE FUNDS AWARDED TO INDIVIDUALS TO BE USED TOWARD CONTINUING THEIR EDUCATION. THESE ARE ISSUED JOINTLY PAYABLE TO THE STUDENT AND THE SCHOOL THE STUDENT IS ATTENDING TO ENSURE THE FUNDS ARE USED FOR EDUCATIONAL EXPENSES. X 1 1 X X X X 0 1 0 1 0 1 0 0 0 GREGORY A VAN GUILDER FORMER CFO, GRP CIO 0 681535 0 509800 0 152195 0 89868 0 9636 0 1443034 0 41000 JEREMY J WHEATON PRES & CEO-PART YR, SR ADVISOR 0 408446 0 800000 0 63060 0 18300 0 34229 0 1324035 0 20500 DANIEL S FISHER GRP PRES & CEO (EFF 7-3-22) 0 484979 0 504688 0 23826 0 78235 0 34212 0 1125940 0 20500 MARTIN A SCANLON CFO & TREASURER 0 415034 0 412500 0 24432 0 68435 0 28561 0 948962 0 20500 CHAD TATE ECMC PRESIDENT (EFF 7-3-22) 296407 0 132860 0 7808 0 44364 0 30021 0 511460 0 5258 0 BRIAN BOARDMAN GRP GENERAL COUNSEL & CORP SEC 0 264020 0 110925 0 7267 0 39552 0 36934 0 458698 0 4556 THERESE B BICKLER VP, ECMC OPERATIONS 204109 0 107231 0 4960 0 37634 0 30045 0 383979 0 1417 0 PAULA J CRAW VP, OUTREACH 185494 0 77952 0 2476 0 31626 0 500 0 298048 0 0 0 NATHAN VICKERY SR DIR, REPAYMENT SUCCESS CTR 181071 0 39881 0 657 0 27588 0 28463 0 277660 0 0 0 J HAMLIN SJOBERG SR DIR, GUARANTOR SERVICES 169510 0 40202 0 2032 0 25692 0 13310 0 250746 0 0 0 HAN CHO DIR, PORTFOLIO MANAGEMENT 155175 0 38714 0 1116 0 23854 0 29078 0 247937 0 0 0 JAN JACOBSON DIR, CUSTOMER SERVICE 155889 0 38411 0 1783 0 22324 0 27296 0 245703 0 0 0 NATE MALMO DIR, INTERNAL DEFAULT MGMT 145923 0 39750 0 913 0 22881 0 30182 0 239649 0 0 0 JAMES V MCKEON BOARD CHAIR 0 196250 0 0 0 0 0 0 0 0 0 196250 0 0 MAURICE M SALTER DIRECTOR 0 157500 0 0 0 0 0 0 0 0 0 157500 0 0 DIANA J INGRAM DIRECTOR 0 156250 0 0 0 0 0 0 0 0 0 156250 0 0 JULIA S GOUW DIRECTOR 0 155000 0 0 0 0 0 0 0 0 0 155000 0 0 K PAUL SINGH DIRECTOR 0 152500 0 0 0 0 0 0 0 0 0 152500 0 0 JOHN F DEPODESTA FORMER BOARD CHAIR 0 75000 0 0 0 0 0 0 0 0 0 75000 0 0 ROBERTA COOPER RAMO FORMER DIRECTOR 0 60000 0 0 0 0 0 0 0 0 0 60000 0 0 I KING JORDAN FORMER DIRECTOR 0 30000 0 0 0 0 0 0 0 0 0 30000 0 0 PART I, LINE 1A TAX INDEMNIFICATION AND GROSS-UP PAYMENTS CERTAIN TAXABLE BENEFITS ARE GROSSED UP TO MAKE THE EMPLOYEE WHOLE; THIS HAS BEEN APPROVED BY THE BOARD OF DIRECTORS. PART I, LINE 4B SUPPLEMENTAL NONQUALIFIED RETIREMENT PLAN ECMC GROUP, INC. MAINTAINS A SUPPLEMENTAL NONQUALIFIED RETIREMENT PLAN DESCRIBED IN SECTION 457 (F), AND A SUPPLEMENTAL EMPLOYEE RETIREMENT PLAN (SERP), TO ATTRACT AND RETAIN EMPLOYEES, TYPICALLY IN MANAGEMENT POSITIONS. IN 2022, GREGORY A. VAN GUILDER, DANIEL S. FISHER AND MARTIN A. SCANLON PARTICIPATED IN THE 457(F) PLAN, AND RECEIVED EMPLOYER CONTRIBUTIONS OF $8,268, $19,135, AND $9,335, RESPECTIVELY. PART I, LINE 5 COMPENSATION CONTINGENT ON REVENUES OF THE ORGANIZATION ECMC GROUP, INC.'S ANNUAL OFFICER INCENTIVE PLAN REQUIRES ACHIEVEMENT OF STATED PRIMARY FINANCIAL GOALS, WHICH INCLUDES REVENUES, BEFORE ANY PAYMENT TO ANY OFFICER IS MADE. PART I, LINE 6 COMPENSATION CONTINGENT ON NET EARNINGS OF THE ORGANIZATION ECMC GROUP, INC.'S ANNUAL OFFICER INCENTIVE PLAN REQUIRES ACHIEVEMENT OF STATED KEY PERFORMANCE METRICS, WHICH INCLUDES NET EARNINGS, BEFORE ANY PAYMENT TO ANY OFFICER IS MADE. FORM 990, PART VI, SECTION A, LINE 2 FAMILY/BUSINESS RELATIONSHIPS AMONGST INTERESTED PERSONS MR. MCKEON AND MR. SALTER - BUSINESS RELATIONSHIP FORM 990, PART VI, SECTION A, LINE 6 CLASSES OF MEMBERS OR STOCKHOLDERS EDUCATIONAL CREDIT MANAGEMENT CORPORATION (ECMC) HAS ONE MEMBER. THE MEMBER IS ECMC GROUP, INC., A DELAWARE NON-STOCK, NONPROFIT CORPORATION EXEMPT UNDER SECTION 501(C)(3). THERE ARE NO STOCKHOLDERS. FORM 990, PART VI, SECTION A, LINE 7A MEMBERS OR STOCKHOLDERS ELECTING MEMBER OF GOVERNING BODY ECMC GROUP, INC. HAS THE RIGHT TO ELECT AND/OR APPROVE ALL THE DIRECTORS OF THE EDUCATIONAL CREDIT MANAGEMENT CORPORATION BOARD OF DIRECTORS. FORM 990, PART VI, SECTION A, LINE 7B DECISIONS REQUIRING APPROVAL BY MEMBERS OR STOCKHOLDERS ECMC GROUP, INC., THE SOLE MEMBER OF EDUCATIONAL CREDIT MANAGEMENT CORPORATION (ECMC), RETAINS THE FOLLOWING AUTHORITY OVER EDUCATIONAL CREDIT MANAGEMENT CORPORATION: 1. TO AUTHORIZE AMENDMENTS TO THE ARTICLES OF INCORPORATION AND BYLAWS. 2. TO APPROVE THE STRATEGIC AND FINANCIAL PLANS. 3. TO ELECT AND/OR APPROVE THE MEMBERS OF THE BOARD OF DIRECTORS. 4. TO OVERSEE COORDINATION OF PROGRAMS AND SERVICES OFFERED. 5. TO AUTHORIZE FORMATION, GOVERNANCE AND DISSOLUTION. FORM 990, PART VI, SECTION B, LINE 11B REVIEW OF FORM 990 BY GOVERNING BODY ALL MEMBERS OF THE BOARD OF DIRECTORS AND EXECUTIVE MANAGEMENT ARE PROVIDED A COPY OF FORM 990 TO REVIEW AND PROVIDE COMMENTS PRIOR TO FILING. ALL MEMBERS OF THE BOARD OF DIRECTORS AND EXECUTIVE MANAGEMENT ARE PROVIDED WITH A COPY OF THE FINAL VERSION OF FORM 990 BEFORE IT HAS BEEN FILED. FORM 990, PART VI, SECTION B, LINE 12C CONFLICT OF INTEREST POLICY OFFICERS, DIRECTORS AND ALL EMPLOYEES ARE REQUIRED TO REAFFIRM ON AN ANNUAL BASIS THEIR UNDERSTANDING OF THE COMPANY'S CONFLICT OF INTEREST POLICY. THE AFFIRMATION SPECIFICALLY REFERENCES THAT THE INDIVIDUAL WILL COMPLY WITH THE DIRECTIVES OF THE CONFLICT OF INTEREST POLICY. OFFICERS, DIRECTORS AND KEY EMPLOYEES ARE ALSO REQUIRED TO COMPLETE AN ANNUAL FORM 990 RELATIONSHIP DISCLOSURE DOCUMENT TO IDENTIFY ANY POTENTIAL CONFLICTS OF INTEREST. FINALLY, THE COMPANY'S VENDOR PROCUREMENT PROCESS INCLUDES QUESTIONS OF BUSINESS UNIT CONTRACT OWNERS TO DETERMINE IF ANY CONFLICTS OF INTEREST MAY EXIST. MONITORING AND ENFORCEMENT OF THE POLICY ARE ACCOMPLISHED THROUGH THE POLICY REAFFIRMATION PROCESS, AFFIRMATIVE DISCLOSURE REQUESTS AND THE POLICY REQUIREMENT THAT ALL CONFLICTS OF INTEREST BE REPORTED. IN CASES WHERE A POTENTIAL CONFLICT EXISTS AT THE OFFICER AND KEY EMPLOYEE LEVELS, THE ISSUE IS DISCLOSED TO THE INDIVIDUAL'S SUPERVISOR, GENERAL COUNSEL AND/OR VICE PRESIDENT, DEPUTY GENERAL COUNSEL. FOR POTENTIAL CONFLICTS INVOLVING DIRECTORS, THE DISCLOSURE IS MADE TO THE BOARD CHAIR. THE DIRECTOR WILL BE REQUIRED TO EXCUSE THEMSELVES FROM DELIBERATION AND VOTING ON MATTERS FOR WHICH THEY MAY HAVE A CONFLICT OF INTEREST. FORM 990, PART VI, SECTION B, LINE 15 LINE 15A: PROCESS TO ESTABLISH COMPENSATION OF TOP MANAGEMENT OFFICIAL THE FOLLOWING DESCRIBES THE ECMC GROUP, INC., EDUCATIONAL CREDIT MANAGEMENT CORPORATION (ECMC) AND ECMC EDUCATION, INC. EXECUTIVE COMPENSATION METHODOLOGY. THE GOVERNANCE & COMPENSATION COMMITTEE OF THE ECMC GROUP, INC. BOARD OF DIRECTORS IS WHOLLY COMPRISED OF INDEPENDENT, OUTSIDE DIRECTORS. IN 2022, THE COMMITTEE RETAINED EXECUTIVE COMPENSATION EXPERTS FROM GRANT THORNTON AND AON, GLOBAL COMPENSATION CONSULTING ORGANIZATIONS, THROUGH ARNOLD & PORTER KAYE SCHOLER LLP TO IDENTIFY APPROPRIATE CEO AND SENIOR EXECUTIVE COMPENSATION PACKAGES. ARNOLD & PORTER KAYE SCHOLER LLP PROVIDED AN OPINION ON THE REASONABLENESS OF THIS COMPENSATION. THE MARKET ANALYSIS PERFORMED BY GRANT THORNTON AND AON FOR ARNOLD & PORTER KAYE SCHOLER LLP INCLUDES SALARY AND INCENTIVE DATA FROM AN APPROPRIATE PEER GROUP UNDER IRS REGULATIONS AND INCLUDES BOTH NONPROFIT AND FOR-PROFIT ENTITIES. LINE 15B: PROCESS TO ESTABLISH COMPENSATION OF OTHER OFFICERS OR KEY EMPLOYEES THE FOLLOWING DESCRIBES THE ECMC GROUP, INC., EDUCATIONAL CREDIT MANAGEMENT CORPORATION (ECMC) AND ECMC EDUCATION, INC. EXECUTIVE COMPENSATION METHODOLOGY. THE GOVERNANCE & COMPENSATION COMMITTEE OF THE ECMC GROUP, INC. BOARD OF DIRECTORS IS WHOLLY COMPRISED OF INDEPENDENT, OUTSIDE DIRECTORS. IN 2022, THE COMMITTEE RETAINED EXECUTIVE COMPENSATION EXPERTS FROM GRANT THORNTON AND AON, GLOBAL COMPENSATION CONSULTING ORGANIZATIONS, THROUGH ARNOLD & PORTER KAYE SCHOLER LLP TO IDENTIFY APPROPRIATE CEO AND SENIOR EXECUTIVE COMPENSATION PACKAGES. ARNOLD & PORTER KAYE SCHOLER LLP PROVIDED AN OPINION ON THE REASONABLENESS OF THIS COMPENSATION. THE MARKET ANALYSIS PERFORMED BY GRANT THORNTON AND AON FOR ARNOLD & PORTER KAYE SCHOLER LLP INCLUDES SALARY AND INCENTIVE DATA FROM AN APPROPRIATE PEER GROUP UNDER IRS REGULATIONS AND INCLUDES BOTH NONPROFIT AND FOR-PROFIT ENTITIES. FORM 990, PART VI, SECTION C, LINE 19 REQUIRED DOCUMENTS AVAILABLE TO THE PUBLIC DOCUMENTS ARE MADE AVAILABLE TO THE PUBLIC AS REQUIRED BY LAW. FORM 990, PART VI, SECTION B, LINE 13: WHISTLEBLOWER POLICY THE ECMC GROUP, INC. WHISTLEBLOWER POLICY REQUIRES DIRECTORS, OFFICERS AND EMPLOYEES TO OBSERVE HIGH STANDARDS OF BUSINESS AND PERSONAL ETHICS IN THE CONDUCT OF THEIR DUTIES AND RESPONSIBILITIES. EMPLOYEES AND REPRESENTATIVES OF THE CORPORATION ARE DIRECTED TO PRACTICE HONESTY AND INTEGRITY IN FULFILLING THEIR RESPONSIBILITIES AND COMPLY WITH ALL APPLICABLE LAWS AND REGULATIONS. THE POLICY REQUIRES REPORTING OF POTENTIAL ILLEGAL PRACTICES OR VIOLATIONS OF CORPORATE POLICIES, AND PROHIBITS RETALIATION FOR GOOD FAITH REPORTING OF SUSPECTED VIOLATIONS UNDER THE POLICY. IN ADDITION, ECMC GROUP, INC. HAS A CODE OF ETHICS AND BUSINESS CONDUCT POLICY THAT IS AFFIRMED ANNUALLY BY ALL ECMC GROUP, INC. AND AFFILIATED COMPANIES' OFFICERS AND EMPLOYEES. THERE IS A PROVISION INCORPORATED INTO THE CODE OF ETHICS AND BUSINESS CONDUCT POLICY THAT STATES THERE CAN BE NO RETALIATION AGAINST ANYONE ACTING IN GOOD FAITH WHEN ASKING A QUESTION, REPORTING A CONCERN OR FOR PARTICIPATING IN AN INVESTIGATION. ECMC GROUP, INC. HAS ESTABLISHED A TELEPHONE HOTLINE AND WEBSITE ADMINISTERED BY AN OUTSIDE VENDOR TO REPORT CONCERNS, WITH AN OPTION TO REPORT ANONYMOUSLY. THE HOTLINE AND WEBSITE ARE AVAILABLE AND ACCESSIBLE TO ECMC GROUP, INC. AND AFFILIATED COMPANIES' DIRECTORS, OFFICERS, EMPLOYEES AND VENDORS. FORM 990, PART VII, SECTION A: CONSULTING JOHN F. DEPODESTA, ROBERTA COOPER RAMO AND I. KING JORDAN, FORMER DIRECTORS, HAD CONSULTING AGREEMENTS IN 2022. ECMC GROUP INC 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411991995 EDUCATION FINANCE DE 501(C)(3) LINE 12B TYPE II N/A 0 ECMC FOUNDATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411990628 PROMOTE EDUCATION DE 501(C)(3) LINE 12B TYPE II ECMC GROUP INC 0 ECMC EDUCATION INC 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 472237488 CAREER COLLEGES DE 501(C)(3) LINE 2 ECMC GROUP INC 0 ECMC REVENUE MANAGEMENT CORPORATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 831761663 STUDENT LOAN DEFAULT RESOLUTION DE 501(C)(3) LINE 10 EDUCATIONAL CREDIT MANAGEMENT CORPORATION 1 ECMC SERVICES INC 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 831763915 STUDENT LOAN REPAYMENT SERVICES DE 501(C)(3) LINE 10 ECMC GROUP INC 0 1 NORTH CHINA A EQUITY FUND LLC 1 N WACKER DR CHICAGO IL 60606 844524632 INVESTMENTS DE N/A EXCLUDED 0 0 ATX A-TEAM THE GUILD LP 500 W SECOND ST STE 1900 163 AUSTIN TX 78701 843490066 INVESTMENTS TX N/A EXCLUDED 0 0 AUBREY GEMS PARTNERS LP 800 THIRD AVE 28TH FL NEW YORK NY 10022 365009933 INVESTMENTS NY N/A EXCLUDED 0 0 BST 052 A SERIES OF SAX CAP FUND III LP PO BOX 3217 SEATTLE WA 98114 853876811 INVESTMENTS DE N/A EXCLUDED 0 0 CHLOE CAPITAL FUND I LP 700 CASCADILLA ST STE 201 ITHACA NY 14850 844269068 INVESTMENTS DE N/A EXCLUDED 0 0 COMMONFUND CAP SECONDARIES OPP FUND 15 OLD DANBURY RD WILTON CT 06897 842082338 INVESTMENTS DE N/A EXCLUDED 0 0 CRP VF IV GP LP 7600 N CAP OF TX HWY BLDG B STE 130 AUSTIN TX 78731 863644095 INVESTMENTS DE N/A EXCLUDED 0 0 ECMC-UV CO-INVESTMENT FUND LP 104 W 40TH ST STE 1600 NEW YORK NY 10018 813873029 INVESTMENTS DE N/A EXCLUDED 0 0 ELEMENTS HEALTH VENTURES II LLC 623 5TH AVE 14TH FL NEW YORK NY 10022 862638962 INVESTMENTS DE N/A EXCLUDED 0 0 FUND D-2 RIOT VENTURES OPPORTUNITY FUND 1632 ABBOT KINNEY BLVD VENICE CA 90291 920652495 INVESTMENTS DE N/A EXCLUDED 0 0 GEM MINING 4 LLC 550 S MAIN ST STE 310 GREENVILLE SC 29601 871562792 INVESTMENTS DE N/A EXCLUDED 0 0 ONRAMP EDUC & WORKFORCE INNOV FUND 821 E WASHINGTON AVE STE 200-G MADISON WI 53703 843999115 INVESTMENTS DE N/A EXCLUDED 0 0 PC-1 DEVELOPERS LLC 3600 MAYBERRY DR RENO NV 89509 831603672 INVESTMENTS NV N/A EXCLUDED 0 0 R7 FAMILY FUND LP 100 S WACKER DR STE 1675 CHICAGO IL 60606 851019413 INVESTMENTS DE N/A EXCLUDED 0 0 RI FUND I A SERIES OF BOOST VC SPV LP PO BOX 3217 SEATTLE WA 98114 874641779 INVESTMENTS CJ N/A EXCLUDED 0 0 SUPERIOR SOLUTIONS I LP 111 WASHINGTON AVE S STE 1400 MINNEAPOLIS MN 55401 882485015 INVESTMENTS DE N/A EXCLUDED 0 0 TABOR MILLENNIAL FUND LP 11 E 44TH ST STE 705 NEW YORK NY 10017 880598843 INVESTMENTS DE N/A EXCLUDED 0 0 TABOR OFFSHORE OPPORTUNITIES LTD 11 E 44TH ST STE 705 NEW YORK NY 10017 INVESTMENTS CJ N/A EXCLUDED 0 0 UNLESS VENTURES LP 1023 WALNUT ST STE 100 BOULDER CO 80302 874222103 INVESTMENTS DE N/A EXCLUDED 0 0 UP FUND I A SERIES OF BOOST VC SPV LP PO BOX 3217 SEATTLE WA 98114 851519551 INVESTMENTS DE N/A EXCLUDED 0 0 WY FUND I A SERIES OF BOOST VC SPV LP PO BOX 3217 SEATTLE WA 98114 851519506 INVESTMENTS DE N/A EXCLUDED 0 0 GENGLOBAL CRYSTAL LLC 1302 PACIFC AVE SAN FRANCISCO CA 94109 882663560 INVESTMENTS DE N/A EXCLUDED 0 0 GENGLOBAL SUNSHINE LLC 1302 PACIFC AVE SAN FRANCISCO CA 94109 853885948 INVESTMENTS DE N/A EXCLUDED 0 0 UNLESS LGH SPV LLC 1023 WALNUT ST STE 100 BOULDER CO 80302 880557430 INVESTMENTS DE N/A EXCLUDED 0 0 ECMC RECORDS & REC MGMT CORPORATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411989959 DOCUMENT MANAGEMENT DE N/A C 0 ECMC HOLDINGS CORPORATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411991992 STRATEGIC OVERSIGHT DE N/A C 0 ECMC MANAGEMENT SERVICES CORPORATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411989960 MANAGEMENT SERVICES DE N/A C 0 ECMC PRIVATE MARKET OPPORTUNITES LP 156 W 56TH ST CITYSPIRE BLDG SQUAD NEW YORK NY 10019 842552668 INVESTMENTS DE N/A C 0 ECMC SERVICING CORPORATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 471154366 LOAN SERVICING DE N/A C 0 ECMC TECHNOLOGY SERVICES CORPORATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411989958 TECHNOLOGY SERVICES DE N/A C 0 EDUCATIONAL CREDIT SERVICES COMPANY 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411992001 PRIVATE LOANS DE N/A C 0 OAKDALE INVESTMENT MANAGEMENT CORP 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 352085743 HOLDING INVESTMENTS DE N/A C 0 0 1 1 0 0 0 0 0 0 0 0 1 1 1 1 1 1 0 0 SCHEDULE R, PART V - TRANSACTIONS WITH RELATED ORGANIZATIONS: LINE 1B-GIFT, GRANT, OR CAPITAL CONTRIBUTION FROM RELATED ORGANIZATION(S): $247,934,497 CONTRIBUTION MADE BY EDUCATIONAL CREDIT MANAGEMENT CORPORATION (ECMC) TO ECMC GROUP, INC. ECMC GROUP, INC., THE PARENT OF AND A SUPPORTING ORGANIZATION TO ECMC. ECMC GROUP, INC. RETAINS THE FOLLOWING AUTHORITY OVER ECMC: 1. TO AUTHORIZE AMENDMENTS TO THE ARTICLES OF INCORPORATION AND BYLAWS. 2. TO APPROVE THE STRATEGIC AND FINANCIAL PLANS. 3. TO ELECT AND/OR APPROVE THE MEMBERS OF THE BOARD OF DIRECTORS. 4. TO OVERSEE COORDINATION OF PROGRAMS AND SERVICES OFFERED. 5. TO AUTHORIZE FORMATION, GOVERNANCE AND DISSOLUTION. ECMC GROUP, INC. AUTHORIZES THE DISTRIBUTION OF FUNDS FROM ECMC TO ECMC GROUP, INC. SECTION 422B OF THE HIGHER EDUCATION ACT OF 1965, AS AMENDED, ALLOWS ECMC TO INVEST FUNDS AT ITS DISCRETION IN ACCORDANCE WITH PRUDENT INVESTOR STANDARDS AND TO USE FUNDS FOR HIGHER EDUCATION-RELATED ACTIVITIES. ECMC DISTRIBUTES FUNDS TO ECMC GROUP, INC. TO INVEST AND TO DISTRIBUTE TO ECMC FOUNDATION AND ECMC EDUCATION, INC. TO USE FOR HIGHER EDUCATION-RELATED ACTIVITIES. LINE 1C-GIFT, GRANT, OR CAPITAL CONTRIBUTION FROM RELATED ORGANIZATION(S): $2,150,000 GRANTS MADE BY ECMC FOUNDATION TO EDUCATIONAL CREDIT MANAGEMENT CORPORATION TO SUPPORT COLLEGE SUCCESS INITIATIVES. LINE 1L-PERFORMANCE OF SERVICES FOR RELATED ORGANIZATION(S): $71,600 FOR DEFAULT AVERSION SERVICES WERE PAID BY ECMC EDUCATION, INC. LINE 1M-PERFORMANCE OF SERVICES BY RELATED ORGANIZATION(S): $351,643 FOR PUBLIC POLICY SERVICES PAID BY ECMC GROUP, INC. LINE 1N-SHARING OF FACILITIES, EQUIPMENT, MAILING LISTS, OR OTHER ASSETS WITH RELATED ORGANIZATION(S): $3,892,926 ALLOCATED EXPENSES FOR FACILITIES, EQUIPMENT, MAILING LISTS, OR OTHER ASSETS SHARED WITH ECMC GROUP, INC. LINE 1N-SHARING OF FACILITIES, EQUIPMENT, MAILING LISTS, OR OTHER ASSETS WITH RELATED ORGANIZATION(S): $3,082,738 ALLOCATED EXPENSES FOR FACILITIES, EQUIPMENT, MAILING LISTS, OR OTHER ASSETS SHARED WITH ECMC SHARED SERVICES COMPANY, LLC, A WHOLLY OWNED SUBSIDIARY OF ECMC GROUP, INC., A RELATED ORGANIZATION. LINE 1O-SHARING OF PAID EMPLOYEES WITH RELATED ORGANIZATION(S): $3,361,535 ALLOCATED EXPENSES FOR PAID EMPLOYEES SHARED WITH ECMC GROUP, INC. LINE 1O-SHARING OF PAID EMPLOYEES WITH RELATED ORGANIZATION(S): $42,348,995 ALLOCATED EXPENSES FOR PAID EMPLOYEES SHARED WITH ECMC SHARED SERVICES COMPANY, LLC, A WHOLLY OWNED SUBSIDIARY OF ECMC GROUP, INC., A RELATED ORGANIZATION. LINE 1Q-REIMBURSEMENT PAID BY RELATED ORGANIZATION(S) FOR EXPENSES: $3,620,047 REIMBURSEMENT PAID BY ECMC GROUP, INC. FOR EXPENSES. LINE 1Q-REIMBURSEMENT PAID BY RELATED ORGANIZATION(S) FOR EXPENSES: $64,175 REIMBURSEMENT PAID BY ECMC SHARED SERVICES COMPANY, LLC, A WHOLLY OWNED SUBSIDIARY OF ECMC GROUP, INC., A RELATED ORGANIZATION, FOR EXPENSES. LINE 1P-REIMBURSEMENT PAID TO RELATED ORGANIZATION(S) FOR EXPENSES: $291,214 REIMBURSEMENT PAID BY ECMC EDUCATION, INC. FOR EXPENSES. SCHEDULE R, PART I - DISREGARDED ENTITIES OF RELATED ORGANIZATIONS: 1(A)-NAME: OAKDALE STUDENT LOAN FUNDING, LLC (27-1914648), 111 WASHINGTON AVE SO, STE 1400, MINNEAPOLIS, MN 55401. 1(B)-PRIMARY ACTIVITY. HOLDING FFELP LOANS. 1(C)-LEGAL DOMICILE. DE. 1(F)-DIRECT CONTROLLING ENTITY. ECMC GROUP, INC. 2(A)-NAME: ECMC SHARED SERVICES COMPANY, LLC (81-0690960), 111 WASHINGTON AVE SO, STE 1400, MINNEAPOLIS, MN 55401. 2(B)-PRIMARY ACTIVITY. SUPPORT SERVICES FUNCTIONS. 2(C)-LEGAL DOMICILE. DE. 2(F)-DIRECT CONTROLLING ENTITY. ECMC GROUP, INC. 3(A)-NAME: PATRIOT STUDENT LOAN CAPITAL, LLC (81-3501777), 111 WASHINGTON AVE SO, STE 1400, MINNEAPOLIS, MN 55401. 3(B)-PRIMARY ACTIVITY. TRUST STUDENT LOANS. 3(C)-LEGAL DOMICILE. DE. 3(F)-DIRECT CONTROLLING ENTITY. ECMC GROUP, INC. 4(A)-NAME: SUPERIOR SOLUTIONS I GP, LLC (88-2460810), 111 WASHINGTON AVE SO, STE 1400, MINNEAPOLIS, MN 55401. 4(B)-PRIMARY ACTIVITY. INVESTMENTS. 4(C)-LEGAL DOMICILE. DE. 4(F)-DIRECT CONTROLLING ENTITY. ECMC GROUP, INC.