2023-11-14T17:19:06-06:00 2022-12-31 135565207 KPMG LLP 90 S 7TH ST STE 4200 MINNEAPOLIS MN 55402 990 2022-01-01 411991995 ECMC GROUP INC ECMC 6512210566 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 MARTIN A SCANLON CFO & TREASURER 6512210566 2023-11-14 1 MARTIN SCANLON XXX-XX-XXXX 0 MONROE J GIERL P01413237 6123055000 2023-11-14 2 AAL1 IAL1 2022 2023-04-26 12:10:37Z DANIEL S FISHER 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 1099037948 0 X WWW.ECMCGROUP.ORG X 2000 DE (SEE SCHEDULE O)ECMC GROUP, INC. SUPPORTS EDUCATIONAL CREDIT MANAGEMENT CORPORATION AND ECMC EDUCATION, INC. ECMC GROUP, INC. SUPPORTS THE FURTHERANCE OF THE EXEMPT PURPOSE OF EDUCATIONAL CREDIT MANAGEMENT CORPORATION AND ECMC EDUCATION, INC. BY CREATING, PROVIDING AND INVESTING IN INNOVATIVE EDUCATIONAL OPPORTUNITIES. ECMC GROUP, INC. IS A NONPROFIT CORPORATION WHOSE VISION IS TO EMPOWER UNDERSERVED COMMUNITIES TO THRIVE THROUGH EDUCATION. 10 9 240 0 19455190 3867516 277591010 248434497 91960563 110098286 188485958 101941700 5984001 6856021 564021532 467330504 73644007 528902334 0 0 13655703 15651045 0 0 0 65173536 135624289 152473246 680177668 411548286 -212847164 5806492820 5422363648 4217559074 4273162854 1588933746 1149200794 X ECMC GROUP, INC'S MISSION IS TO HELP STUDENTS SUCCEED BY CREATING, PROVIDING AND INVESTING IN INNOVATIVE EDUCATIONAL OPPORTUNITIES. 0 0 527868902 527868902 0 ECMC GROUP, INC. SUPPORTS THE FURTHERANCE OF THE EXEMPT PURPOSE OF EDUCATIONAL CREDIT MANAGEMENT CORPORATION, ECMC EDUCATION, INC., AND ECMC FOUNDATION BY CREATING, PROVIDING AND INVESTING IN INNOVATIVE EDUCATIONAL OPPORTUNITIES. ECMC GROUP, INC. IS A NONPROFIT CORPORATION WHOSE VISION IS TO EMPOWER UNDERSERVED COMMUNITIES TO THRIVE THROUGH EDUCATION. $26,000,000 CASH CONTRIBUTIONS MADE TO ECMC EDUCATION, INC. TO SUPPORT ITS MISSION TO TRANSFORM CAREER AND TECHNICAL EDUCATION TO PROVIDE ASPIRING AND CURRENT LEARNERS WITH SKILLS TO ELEVATE THEIR CAREERS AND COMMUNITIES, $296,902 CONTRIBUTION MADE BY ECMC GROUP, INC. ON BEHALF OF ECMC EDUCATION, INC. FOR ACCRUED SECTION 4968 EXCISE TAX ON NET INVESTMENT INCOME OF ECMC GROUP, INC. AND SUBSIDIARIES. (CONTINUED ON SCHEDULE O)$501,572,000 CASH AND NONCASH CONTRIBUTIONS MADE TO ECMC FOUNDATION FOR GENERAL SUPPORT OF ITS MISSION TO IMPROVE HIGHER EDUCATION AND CAREER SUCCESS AMONG UNDERSERVED POPULATIONS THROUGH EVIDENCE-BASED INNOVATION. 93404136 0 110098286 LOAN PORTFOLIO SERVICING:ECMC GROUP, INC. AND OAKDALE STUDENT LOAN FUNDING,LLC (OAKDALE), A WHOLLY OWNED SUBSIDIARY OF ECMC GROUP, INC., HAVE ELIGIBLE LENDER TRUST (ELT) AGREEMENTS WITH MANUFACTURERS AND TRADERS TRUST COMPANY. MANUFACTURERS AND TRADERS TRUST COMPANY SERVES AS THE ELT FOR ECMC GROUP, INC. AND OAKDALE. THROUGH THE ELTS, ECMC GROUP, INC. AND OAKDALE PURCHASE FEDERAL FAMILY EDUCATION LOAN PROGRAM (FFELP) REHABILITATED STUDENT LOANS FROM EDUCATIONAL CREDIT MANAGEMENT CORPORATION, A RELATED ENTITY, AND OTHER GUARANTY AGENCIES IN ORDER TO ENSURE THAT STUDENT LOAN BORROWERS CAN REALIZE THE FULL BENEFITS AFFORDED THEM UNDER 34 CFR SEC. 682.405. (CONTINUED ON SCHEDULE O)PATRIOT STUDENT LOAN CAPITAL, LLC (PATRIOT) HAS INTERIM ELIGIBLE LENDER TRUST AGREEMENTS WITH MANUFACTURERS AND TRADERS TRUST COMPANY. ECMC GROUP STUDENT LOAN TRUST 2016-1 (TRUST 2016-1), ECMC GROUP STUDENT LOAN TRUST 2017-1 (TRUST 2017-1), ECMC GROUP STUDENT LOAN TRUST 2017-2 (TRUST 2017-2), ECMC GROUP STUDENT LOAN TRUST 2018-1 (TRUST 2018-1), ECMC GROUP STUDENT LOAN TRUST 2018-2 (TRUST 2018-2), ECMC GROUP STUDENT LOAN TRUST 2019-1 (TRUST 2019-1), ECMC GROUP STUDENT LOAN TRUST 2020-1 (TRUST 2020-1), ECMC GROUP STUDENT LOAN TRUST 2020-2 (TRUST 2020-2), ECMC GROUP STUDENT LOAN TRUST 2020-3 (TRUST 2020-3) AND ECMC GROUP STUDENT LOAN TRUST 2021-1 (TRUST 2021-1), COLLECTIVELY (THE TRUSTS), HAVE ELIGIBLE LENDER TRUST AGREEMENTS WITH MANUFACTURERS AND TRADERS TRUST COMPANY. MANUFACTURERS AND TRADERS TRUST COMPANY SERVES AS THE INTERIM ELIGIBLE LENDER TRUST (INTERIM ELT) FOR PATRIOT AND AS ELIGIBLE LENDER TRUST (ELT) FOR TRUST 2016-1, TRUST 2017-1, TRUST 2017-2, TRUST 2018-1, TRUST 2018-2, TRUST 2019-1, TRUST 2020-1, TRUST2020-2, TRUST 2020-3 AND TRUST 2021-1. THROUGH THE INTERIM ELT, PATRIOT PURCHASES FFELP REHABILITATED STUDENT LOANS FROM ECMC GROUP, INC. AND OAKDALE AND RESELLS THE LOANS THROUGH THE ELT TO THE TRUSTS. THE TRUSTS ISSUED CLASS A NOTES SECURED BY THE RESPECTIVE STUDENT LOAN PORTFOLIOS. 351643 38500 0 THROUGH THE PUBLIC POLICY PROGRAM, ECMC GROUP, INC. SHARES INFORMATION AMONG ECMC GROUP-RELATED MEMBERS ON LEGISLATIVE PROPOSALS AND GOVERNMENTAL REGULATIONS THAT IMPACT THEIR OPERATIONS. THE PROGRAM ENABLES ECMC GROUP, INC. AFFILIATES TO MONITOR PUBLIC POLICY MATTERS AND PROVIDE NONPARTISAN ANALYSIS AND RESEARCH TO POLICYMAKERS, THOUGHT LEADERS AND THE GENERAL PUBLIC. 994932 994932 0 GRANTS AND SPONSORSHIPS SUPPLIED BY ECMC GROUP, INC. TO SCHOOLS AND INDIVIDUALS IN SUPPORT OF ITS TAX-EXEMPT PURPOSE. 994932 994932 0 622619613 1 1 0 0 0 0 0 0 0 0 1 1 1 0 1 1 0 1 0 0 1 0 0 0 0 0 0 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 1 1 1 1 0 0 1 62 0 240 1 1 1 0 0 0 0 0 0 0 0 0 1 0 X 10 9 1 0 0 0 1 1 0 1 1 0 0 1 1 1 1 1 1 1 1 0 CA MN X MARTIN A SCANLON 6512210566 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 JAMES V MCKEON BOARD CHAIR 13.00 5.00 X 0 196250 0 MAURICE M SALTER DIRECTOR 7.00 4.00 X 0 157500 0 JULIA S GOUW DIRECTOR 5.00 4.00 X 0 155000 0 K PAUL SINGH DIRECTOR 4.00 4.00 X 0 152500 0 DIANA J INGRAM DIRECTOR 8.00 4.00 X 0 156250 0 JACK O'CONNELL DIRECTOR 6.00 5.00 X 0 140000 0 DEREK LANGHAUSER DIRECTOR 6.00 4.00 X 0 137500 0 JENNIFER ANDERSON DIRECTOR 7.00 4.00 X 0 132500 0 JAMES RUNCIE DIRECTOR 8.00 4.00 X 0 127500 0 JEREMY J WHEATON PRES & CEO-PART YR, SR ADVISOR 40.00 0.00 X X 1271506 0 52529 DANIEL S FISHER GRP PRES & CEO (EFF 07-03-22) 40.00 0.00 X X 1013493 0 112447 MARTIN A SCANLON CFO & TREASURER 40.00 0.00 X 851966 0 96996 GREGORY A VAN GUILDER CHIEF INVESTMENT OFFICER 40.00 0.00 X 1343530 0 99504 PHILIP BECKER VP, INVESTMENTS 40.00 0.00 X 522808 0 81553 BRIAN BOARDMAN GRP GENERAL COUNSEL & CORP SEC 40.00 0.00 X 382212 0 76486 JOSEPH WATT VP, IMPACT INVESTING 40.00 0.00 X 349855 0 37272 JOSH SLAYTON EDU PRES & SVP GRP DEV-PART YR 40.00 0.00 X 933694 0 35017 SARAH STREHL CHIEF HUMAN RESOURCES OFFICER 40.00 0.00 X 693761 0 93887 RAHOUL GHOSE CHIEF INFORMATION OFFICER 40.00 0.00 X 644050 0 93805 HEIDI J JOHNSON SVP, CHIEF OF STAFF 40.00 0.00 X 501978 0 80375 IRIS CUMBERBATCH SVP, CORPORATE AFFAIRS 40.00 0.00 X 489182 0 62085 STEPHEN H HANSEN VP, INFORMATION TECHNOLOGY 40.00 0.00 X 303119 0 64285 JOHN MCKENNELL VP, CHIEF INFORMATION SEC. OFF 40.00 0.00 X 294398 0 63918 CHRISTOPHER JANZEN VP, ACADEMIC TECHNOLOGY 40.00 0.00 X 301379 0 51956 ADAM TRAMPE VP, DEPUTY GENERAL COUNSEL 40.00 0.00 X 305077 0 69110 HUGH E MCSHERRY VP, CORPORATE SERVICES 40.00 0.00 X 312315 0 59402 TIFFANY THOMPSON VP, FINANCE & CONTROLLER 40.00 0.00 X 309242 0 37112 MATTHEW T MIKULSKI VP, INTERNAL AUDIT 40.00 0.00 X 289044 0 57295 BRUCE FEIST VP, APPLICATIONS & ANALYTICS 40.00 0.00 X 308887 0 69237 AARON WOODRICH SR DIR, INFORMATION TECHNOLOGY 40.00 0.00 X 240392 0 65369 DEAN J VANDECOEVERING SR DIR, FINANCIAL PLANNING 40.00 0.00 X 258967 0 42922 SARA HEGG DIR, TOTAL REWARDS & PAYROLL 40.00 0.00 X 237778 0 63273 CHRISTINE NOEL GOVERNMENT AFFAIRS DIRECTOR 40.00 0.00 X 238862 0 52124 TROY GUNDERMAN DIR, LITIGATION 40.00 0.00 X 235833 0 55779 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 12633328 1520000 1673738 115 1 1 0 NAVIENT SOLUTIONS INC 220 LASLEY AVE WILKES BARRE PA 18706 LOAN PORTFOLIO SERV 6512863 AMAZON WEB SERVICES INC PO BOX 84023 SEATTLE WA 98124 IT SERVICE & SUPPORT 3291648 SOLUTION DESIGN GROUP INC 7500 OLSON MEMIORIAL HWY 250 GOLDEN VALLEY MN 55427 IT SERVICE & SUPPORT 1679805 CDW PO BOX 75723 CHICAGO IL 60675 IT SERVICE & SUPPORT 1523126 KPMG LLP PO BOX 120922 DALLAS TX 75312 ACCOUNTING 1112830 41 248434497 248434497 STUDENT LOAN PORTFOLIO 900099 110098286 110098286 110098286 10781885 10483515 298370 310860360 412006899 303550322 328157122 7310038 83849777 91159815 2191325 88968490 SERVICE FEES ON TRUST 900099 6823570 6780350 43220 INTERCOMPANY SERVICING 900099 32451 32451 6856021 467330504 110098286 19455190 89342531 X 528774722 528774722 127612 127612 7494751 7494751 7334884 1845276 5489608 160137 60735 99402 383620 49627 333993 277653 72229 205424 319255 319255 450369 450369 152110 152110 5101 5101 12105157 9940052 2165105 942276 67482 874794 1342285 83595 1258690 582638 582638 319832 54543 265289 108065 1868 106197 74566192 74566192 6823570 6823570 9313955 9313955 261660 261660 IMPAIRMENT 14202157 14202157 PRINCIPAL LOAN ADJUSTME 10537262 10537262 LOSS ON SUBSIDIARIES 2769751 2769751 SALES AND OTHER TAXES 704651 704651 118003 118003 680177668 622619613 57558055 0 X 42565086 67232695 276079769 190228631 0 0 7455192 7151574 0 0 0 0 0 0 0 0 3339482 3001839 45138149 20043573 35887320 25094576 201464887 324915975 1767602196 1911377364 3423737097 2848783342 37160725 26352419 11201066 18225233 5806492820 5422363648 17971153 21659174 0 0 3307346 2966952 0 0 0 0 0 0 385917193 377992351 0 0 3810363382 3870544377 4217559074 4273162854 X 1588933746 1149200794 0 0 1588933746 1149200794 5806492820 5422363648 X -212847164 -226885788 0 X 0 1 X 1 0 X X 2 EDUCATIONAL CREDIT MANAGEMENT CORPORATION 411778617 10 1 0 351643 ECMC EDUCATION INC 472237488 2 1 26296902 108451 2 26296902 460094 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 PART-I LINE-12B 12A TYPE II SUPPORTING ORGANIZATION ECMC GROUP, INC., THE SUPPORTING ORGANIZATION, RETAINS THE FOLLOWING AUTHORITY OVER EDUCATIONAL CREDIT MANAGEMENT CORPORATION AND ECMC EDUCATION, INC. THE SUPPORTED ORGANIZATIONS, AND, THEREFORE, HAS CONTROL OVER EDUCATIONAL CREDIT MANAGEMENT CORPORATION AND ECMC EDUCATION, INC.: 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. PART I, LINE 12G, COLUMN (VI): ECMC GROUP, INC PROVIDED $351,643 OF NONMONETARY SUPPORT TO EDUCATIONAL CREDIT MANAGEMENT CORPORATION FOR PUBLIC POLICY SERVICES RENDERED AND $108,451 NONMONETARY SUPPORT TO ECMC EDUCATION, INC. FOR SHARED FACILITIES, EQUIPMENT OR OTHER ASSETS. RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 1 0 0 0 0 1 178290 0 0 178290 0 SCHEDULE C, PART II-B LINE 1A GENERAL LOBBYING ACTIVITIES ON LEGISLATIVE ISSUES OF RELEVANCE TO ECMC GROUP, INC. 14201214 7486057 6715157 27207575 9558850 17648725 3729360 2998666 730694 25094576 INV IN ECMC HOLDINGS CORPORATION 4502015 F INV IN OAKDALE INV MGMT CORP 2465987 F ALTERNATIVE INVESTMENTS 1757293644 F DIRECT INVESTMENTS 38056386 F IMPACT INVESTMENTS 109059332 F 1911377364 STUDENT LOAN REC-HELD FOR SALE 418590216 F STUDENT LOAN RECEIABLE-PLEDGED 2430193126 C 2848783342 FOUNDATION DEPOSITS IN ECMC GROUP, INC. APPORTIONED INVESTMENT POOL 1552264845 SECURED BORROWINGS OF ECMC GROUP STUDENT LOAN TRUST 2016-1 176764530 SECURED BORROWINGS OF ECMC GROUP STUDENT LOAN TRUST 2017-1 224432558 SECURED BORROWINGS OF ECMC GROUP STUDENT LOAN TRUST 2017-2 273843187 SECURED BORROWINGS OF ECMC GROUP STUDENT LOAN TRUST 2018-1 276704877 SECURED BORROWINGS OF ECMC GROUP STUDENT LOAN TRUST 2018-2 203208103 AMOUNT PAYABLE TO THE DEPARTMENT OF EDUCATION 8545425 DEFERRED FINANCING FEES -11377021 OPERATING LEASE 8063113 SECURED BORROWINGS OF ECMC GROUP STUDENT LOAN TRUST 2019-1 205493652 SECURED BORROWINGS OF ECMC GROUP STUDENT LOAN TRUST 2020-1 228320504 SECURED BORROWINGS OF ECMC GROUP STUDENT LOAN TRUST 2020-2 233253530 SECURED BORROWINGS OF ECMC GROUP STUDENT LOAN TRUST 2020-3 236155719 SECURED BORROWINGS OF ECMC GROUP STUDENT LOAN TRUST 2021-1 254829239 DUE TO RELATED PARTIES 42116 3870544377 X PART X, LINE 2: FIN 48 (ASC 740) FOOTNOTE THE FIN 48 (ASC 740) DISCLOSURE IN THE ECMC GROUP, INC. AND SUBSIDIARIES CONSOLIDATED FINANCIAL STATEMENTS READS AS FOLLOWS: "ECMC GROUP, ECMC, EDUCATION, AND ECMC FOUNDATION ARE NONPROFIT 501(C)(3) CORPORATIONS AND ARE EXEMPT FROM FEDERAL AND STATE INCOME TAXES. HOLDINGS AND ITS SUBSIDIARIES ARE TAXABLE ENTITIES AND ACCOUNT FOR DEFERRED TAX ASSETS AND LIABILITIES UNDER THE LIABILITY METHOD. DEFERRED TAX LIABILITIES ARE RECOGNIZED FOR TEMPORARY DIFFERENCES THAT WILL RESULT IN TAXABLE AMOUNTS IN FUTURE YEARS. DEFERRED TAX ASSETS ARE RECOGNIZED FOR DEDUCTIBLE TEMPORARY DIFFERENCES AND TAX OPERATING LOSS AND TAX CREDIT CARRY FORWARDS. DEFERRED TAX ASSETS ARE REDUCED BY A VALUATION ALLOWANCE WHEN, IN THE OPINION OF MANAGEMENT, IT IS MORE LIKELY THAN NOT THAT SOME PORTION OR ALL OF THE DEFERRED TAX ASSETS WILL NOT BE REALIZED. WITH FEW EXCEPTIONS, GROUP IS NO LONGER SUBJECT TO U.S. FEDERAL, STATE OR LOCAL INCOME TAX EXAMINATIONS BY TAX AUTHORITIES FOR THE YEARS BEFORE 2018. IN THE EVENT OF ANY CURRENT OR FUTURE TAX ASSESSMENTS, HOLDINGS AND ITS SUBSIDIARIES HAVE ELECTED TO RECORD THE INCOME TAXES AND ANY RELATED INTEREST AND PENALTIES AS INCOME TAX EXPENSE ON GROUP'S CONSOLIDATED STATEMENTS OF ACTIVITIES." SCHEDULE D, PART X, LINE 1: $254,829,239 FLOATING RATE CLASS A NOTES SECURED BORROWING OF ECMC GROUP STUDENT LOAN TRUST 2021-1. ECMC GROUP STUDENT LOAN TRUST 2021-1, A DELAWARE STATUTORY TRUST, PURCHASES STUDENT LOANS AND ACCRUED INTEREST FROM PATRIOT STUDENT LOAN CAPITAL, LLC AND SECURITIZES THE ASSETS WITH AN ISSUANCE OF DEBT. THE SECURITIZATION USES A TWO-STEP STRUCTURE THAT LEGALLY ISOLATES THE TRANSFERRED ASSETS. THESE TRANSACTIONS ARE ACCOUNTED FOR AS AN ON-BALANCE SHEET SECURED BORROWING. PATRIOT STUDENT LOAN CAPITAL, LLC, A DISREGARDED ENTITY OF ECMC GROUP, INC., HOLDS THE PRIMARY BENEFICIAL INTEREST IN THE TRUST. ECMC GROUP, INC. IS THE PRIMARY BENEFICIARY OF THE SECURITIZATION TRUST AND IS REQUIRED TO CONSOLIDATE THE TRUST. SCHEDULE D, PART X, LINE 1: $236,155,719 FLOATING RATE CLASS A NOTES SECURED BORROWING OF ECMC GROUP STUDENT LOAN TRUST 2020-3. ECMC GROUP STUDENT LOAN TRUST 2020-3, A DELAWARE STATUTORY TRUST, PURCHASES STUDENT LOANS AND ACCRUED INTEREST FROM PATRIOT STUDENT LOAN CAPITAL, LLC AND SECURITIZES THE ASSETS WITH AN ISSUANCE OF DEBT. THE SECURITIZATION USES A TWO-STEP STRUCTURE THAT LEGALLY ISOLATES THE TRANSFERRED ASSETS. THESE TRANSACTIONS ARE ACCOUNTED FOR AS AN ON-BALANCE SHEET SECURED BORROWING. PATRIOT STUDENT LOAN CAPITAL, LLC, A DISREGARDED ENTITY OF ECMC GROUP, INC., HOLDS THE PRIMARY BENEFICIAL INTEREST IN THE TRUST. ECMC GROUP, INC. IS THE PRIMARY BENEFICIARY OF THE SECURITIZATION TRUST AND IS REQUIRED TO CONSOLIDATE THE TRUST. SCHEDULE D, PART X, LINE 1: $233,253,530 FLOATING RATE CLASS A NOTES SECURED BORROWING OF ECMC GROUP STUDENT LOAN TRUST 2020-2. ECMC GROUP STUDENT LOAN TRUST 2020-2, A DELAWARE STATUTORY TRUST, PURCHASES STUDENT LOANS AND ACCRUED INTEREST FROM PATRIOT STUDENT LOAN CAPITAL, LLC AND SECURITIZES THE ASSETS WITH AN ISSUANCE OF DEBT. THE SECURITIZATION USES A TWO-STEP STRUCTURE THAT LEGALLY ISOLATES THE TRANSFERRED ASSETS. THESE TRANSACTIONS ARE ACCOUNTED FOR AS AN ON-BALANCE SHEET SECURED BORROWING. PATRIOT STUDENT LOAN CAPITAL, LLC, A DISREGARDED ENTITY OF ECMC GROUP, INC., HOLDS THE PRIMARY BENEFICIAL INTEREST IN THE TRUST. ECMC GROUP, INC. IS THE PRIMARY BENEFICIARY OF THE SECURITIZATION TRUST AND IS REQUIRED TO CONSOLIDATE THE TRUST. SCHEDULE D, PART X, LINE 1: $228,320,504 FLOATING RATE CLASS A NOTES SECURED BORROWING OF ECMC GROUP STUDENT LOAN TRUST 2020-1. ECMC GROUP STUDENT LOAN TRUST 2020-1, A DELAWARE STATUTORY TRUST, PURCHASES STUDENT LOANS AND ACCRUED INTEREST FROM PATRIOT STUDENT LOAN CAPITAL, LLC AND SECURITIZES THE ASSETS WITH AN ISSUANCE OF DEBT. THE SECURITIZATION USES A TWO-STEP STRUCTURE THAT LEGALLY ISOLATES THE TRANSFERRED ASSETS. THESE TRANSACTIONS ARE ACCOUNTED FOR AS AN ON-BALANCE SHEET SECURED BORROWING. PATRIOT STUDENT LOAN CAPITAL, LLC, A DISREGARDED ENTITY OF ECMC GROUP, INC., HOLDS THE PRIMARY BENEFICIAL INTEREST IN THE TRUST. ECMC GROUP, INC. IS THE PRIMARY BENEFICIARY OF THE SECURITIZATION TRUST AND IS REQUIRED TO CONSOLIDATE THE TRUST. SCHEDULE D, PART X, LINE 1: $205,493,652 FLOATING RATE CLASS A NOTES SECURED BORROWING OF ECMC GROUP STUDENT LOAN TRUST 2019-1. ECMC GROUP STUDENT LOAN TRUST 2019-1, A DELAWARE STATUTORY TRUST, PURCHASES STUDENT LOANS AND ACCRUED INTEREST FROM PATRIOT STUDENT LOAN CAPITAL, LLC AND SECURITIZES THE ASSETS WITH AN ISSUANCE OF DEBT. THE SECURITIZATION USES A TWO-STEP STRUCTURE THAT LEGALLY ISOLATES THE TRANSFERRED ASSETS. THESE TRANSACTIONS ARE ACCOUNTED FOR AS AN ON-BALANCE SHEET SECURED BORROWING. PATRIOT STUDENT LOAN CAPITAL, LLC, A DISREGARDED ENTITY OF ECMC GROUP, INC., HOLDS THE PRIMARY BENEFICIAL INTEREST IN THE TRUST. ECMC GROUP, INC. IS THE PRIMARY BENEFICIARY OF THE SECURITIZATION TRUST AND IS REQUIRED TO CONSOLIDATE THE TRUST. SCHEDULE D, PART X, LINE 1: $276,704,877 FLOATING RATE CLASS A NOTES SECURED BORROWING OF ECMC GROUP STUDENT LOAN TRUST 2018-1. ECMC GROUP STUDENT LOAN TRUST 2018-1, A DELAWARE STATUTORY TRUST, PURCHASES STUDENT LOANS AND ACCRUED INTEREST FROM PATRIOT STUDENT LOAN CAPITAL, LLC AND SECURITIZES THE ASSETS WITH AN ISSUANCE OF DEBT. THE SECURITIZATION USES A TWO-STEP STRUCTURE THAT LEGALLY ISOLATES THE TRANSFERRED ASSETS. THESE TRANSACTIONS ARE ACCOUNTED FOR AS AN ON-BALANCE SHEET SECURED BORROWING. PATRIOT STUDENT LOAN CAPITAL, LLC, A DISREGARDED ENTITY OF ECMC GROUP, INC., HOLDS THE PRIMARY BENEFICIAL INTEREST IN THE TRUST. ECMC GROUP, INC. IS THE PRIMARY BENEFICIARY OF THE SECURITIZATION TRUST AND IS REQUIRED TO CONSOLIDATE THE TRUST. SCHEDULE D, PART X, LINE 1: $203,208,103 FLOATING RATE CLASS A NOTES SECURED BORROWING OF ECMC GROUP STUDENT LOAN TRUST 2018-2. ECMC GROUP STUDENT LOAN TRUST 2018-2, A DELAWARE STATUTORY TRUST, PURCHASES STUDENT LOANS AND ACCRUED INTEREST FROM PATRIOT STUDENT LOAN CAPITAL, LLC AND SECURITIZES THE ASSETS WITH AN ISSUANCE OF DEBT. THE SECURITIZATION USES A TWO-STEP STRUCTURE THAT LEGALLY ISOLATES THE TRANSFERRED ASSETS. THESE TRANSACTIONS ARE ACCOUNTED FOR AS AN ON-BALANCE SHEET SECURED BORROWING. PATRIOT STUDENT LOAN CAPITAL, LLC, A DISREGARDED ENTITY OF ECMC GROUP, INC., HOLDS THE PRIMARY BENEFICIAL INTEREST IN THE TRUST. ECMC GROUP, INC. IS THE ARY OF THE SECURITIZATION TRUST AND IS REQUIRED TO CONSOLIDATE THE TRUST. SCHEDULE D, PART X, LINE 1: $224,432,558 FLOATING RATE CLASS A NOTES SECURED BORROWING OF ECMC GROUP STUDENT LOAN TRUST 2017-1. ECMC GROUP STUDENT LOAN TRUST 2017-1, A DELAWARE STATUTORY TRUST, PURCHASES STUDENT LOANS AND ACCRUED INTEREST FROM PATRIOT STUDENT LOAN CAPITAL, LLC AND SECURITIZES THE ASSETS WITH AN ISSUANCE OF DEBT. THE SECURITIZATION USES A TWO-STEP STRUCTURE THAT LEGALLY ISOLATES THE TRANSFERRED ASSETS. THESE TRANSACTIONS ARE ACCOUNTED FOR AS AN ON-BALANCE SHEET SECURED BORROWING. PATRIOT STUDENT LOAN CAPITAL, LLC, A DISREGARDED ENTITY OF ECMC GROUP, INC., HOLDS THE PRIMARY BENEFICIAL INTEREST IN THE TRUST. ECMC GROUP, INC. IS THE PRIMARY BENEFICIARY OF THE SECURITIZATION TRUST AND IS REQUIRED TO CONSOLIDATE THE TRUST. SCHEDULE D, PART X, LINE 1: $273,843,187 FLOATING RATE CLASS A NOTES SECURED BORROWING OF ECMC GROUP STUDENT LOAN TRUST 2017-2. ECMC GROUP STUDENT LOAN TRUST 2017-2, A DELAWARE STATUTORY TRUST, PURCHASES STUDENT LOANS AND ACCRUED INTEREST FROM PATRIOT STUDENT LOAN CAPITAL, LLC AND SECURITIZES THE ASSETS WITH AN ISSUANCE OF DEBT. THE SECURITIZATION USES A TWO-STEP STRUCTURE THAT LEGALLY ISOLATES THE TRANSFERRED ASSETS. THESE TRANSACTIONS ARE ACCOUNTED FOR AS AN ON-BALANCE SHEET SECURED BORROWING. PATRIOT STUDENT LOAN CAPITAL, LLC, A DISREGARDED ENTITY OF ECMC GROUP, INC., HOLDS THE PRIMARY BENEFICIAL INTEREST IN THE TRUST. ECMC GROUP, INC. IS THE PRIMARY BENEFICIARY OF THE SECURITIZATION TRUST AND IS REQUIRED TO CONSOLIDATE THE TRUST. SCHEDULE D, PART X, LINE 1: $176,764,530 FLOATING RATE CLASS A NOTES SECURED BORROWING OF ECMC GROUP STUDENT LOAN TRUST 2016-1. ECMC GROUP STUDENT LOAN TRUST 2016-1, A DELAWARE STATUTORY TRUST, PURCHASES STUDENT LOANS AND ACCRUED INTEREST FROM PATRIOT STUDENT LOAN CAPITAL, LLC AND SECURITIZES THE ASSETS WITH AN ISSUANCE OF DEBT. THE SECURITIZATION USES A TWO-STEP STRUCTURE THAT LEGALLY ISOLATES THE TRANSFERRED ASSETS. THESE TRANSACTIONS ARE ACCOUNTED FOR AS AN ON-BALANCE SHEET SECURED BORROWING. PATRIOT STUDENT LOAN CAPITAL, LLC, A DISREGARDED ENTITY OF ECMC GROUP, INC., HOLDS THE PRIMARY BENEFICIAL INTEREST IN THE TRUST. ECMC GROUP, INC. IS THE PRIMARY BENEFICIARY OF THE SECURITIZATION TRUST AND IS REQUIRED TO CONSOLIDATE THE TRUST. SCHEDULE D, PART X, LINE 1: $1,552,264,845. AT DECEMBER 31, 2022, ECMC FOUNDATION WAS A PARTICIPANT IN THE ECMC GROUP, INC. APPORTIONED INVESTMENT POOL ("APPORTIONED INVESTMENT POOL"). A PORTION OF ECMC GROUP, INC.'S ASSETS ARE HELD IN THE ECMC GROUP, INC. INVESTMENT PORTFOLIO ASSET POOL, WHICH IS MANAGED BY ECMC GROUP, INC. PARTICIPATION IN THE APPORTIONED INVESTMENT POOL IS AVAILABLE TO ECMC GROUP, INC. AND ITS ELIGIBLE SUBSIDIARIES. INVESTMENTS IN THE APPORTIONED INVESTMENT POOL REPRESENT AN OWNERSHIP INTEREST IN THE INVESTMENT POOL, NOT IN THE UNDERLYING ASSETS THEMSELVES, AND ARE GENERALLY REDEEMABLE TO THE ELIGIBLE SUBSIDIARY UPON REQUEST. UNAPPORTIONED INVESTMENTS, NET, ARE NOT SUBJECT TO PARTICIPATION BY ECMC GROUP, INC.'S SUBSIDIARIES. CENTRAL AMERICA AND THE CARIBBEAN INVESTMENTS 444903000 EUROPE (INCLUDING ICELAND AND GREENLAND) INVESTMENTS 31610000 NORTH AMERICA INVESTMENTS 26477000 0 0 0 0 0 0 502990000 0 502990000 1 0 1 1 1 0 PART III ACCOUNTING METHOD: PART-I LINE-3(F) CENTRAL AMERICA AND THE CARIBBEAN - ACCRUAL EUROPE (INCLUDING ICELAND AND GREENLAND) - ACCRUAL NORTH AMERICAN (CANADA & MEXICO ONLY) - ACCRUAL 1 ECMC FOUNDATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411990628 501(C)(3) 51572000 450000000 FAIR VALUE INVESTMENT - FRACT INT OF ECMC GROUP, INC. APPROR INV POOL GENERAL SUPPORT ECMC EDUCATION INC 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 472237488 501(C)(3) 26296902 0 GENERAL SUPPORT UNIVERSITY OF MINNESOTA FOUNDATION PO BOX 860266 MINNEAPOLIS MN 55486 416042488 501(C)(3) 147500 0 JOHN DEPODESTA LEADERSHIP PROGRAM AMERICAN RED CROSS 25688 NETWORK PL CHICAGO IL 60673 530196605 501(C)(3) 20000 0 UKRAINE RELIEF BESTPREP 7100 NORTHLAND CIR N STE 120 BROOKLYN PARK MN 55428 411265355 501(C)(3) 35300 0 PROGRAM SPONSORSHIP CRISTO REY CORPORATE INTERNSHIP 2924 4TH AVE S MINNEAPOLIS MN 55408 204548714 501(C)(3) 36500 0 WORK STUDY PROGRAM SPONSORSHIP JUNIOR ACHIEVEMENT NORTH 1745 UNIVERSITY AVE W ST PAUL MN 55104 411424988 501(C)(3) 45000 0 PROGRAM SPONSORSHIP JUNIOR ACHIEVEMENT OF GEORGIA INC 275 NORTHSIDE DR NW ATLANTA GA 30314 580598050 501(C)(3) 7500 0 PROGRAM SPONSORSHIP JUNIOR ACHIEVEMENT OF SACRAMENTO INC 3800 WATT AVE STE 285 SACRAMENTO CA 95821 946080866 501(C)(3) 10000 0 PROGRAM SPONSORSHIP JUNIOR ACHIEVEMENT OF SOUTHEAST TEXAS 2115 E GOVERNORS CIR HOUSTON TX 77092 741153957 501(C)(3) 7500 0 PROGRAM SPONSORSHIP JUNIOR ACHIEVEMENT OF SOUTHERN CALIFORNIA INC 6250 FOREST LAWN DR LOS ANGELES CA 90068 951799192 501(C)(3) 7500 0 PROGRAM SPONSORSHIP MPLS DOWNTOWN COUNCIL 81 S 9TH ST STE 260 MINNEAPOLIS MN 55402 410761732 501(C)(3) 8500 0 PROGRAM SPONSORSHIP PAGE EDUCATION FOUNDATION PO BOX 581254 MINNEAPOLIS MN 55458 363605013 501(C)(3) 9000 0 PROGRAM SPONSORSHIP READING PARTNERS TWIN CITIES 2324 UNIVERSITY AVE W STE 105 ST PAUL MN 55114 770568469 501(C)(3) 5429 0 PROGRAM SPONSORSHIP THE UCLA FOUNDATION 10920 WILSHIRE CENTER 9TH FL LOS ANGELES CA 90024 952250801 501(C)(3) 106500 0 ESTABLISH ENDOWED LECTURE IN NONPROFITS CONGRESSIONAL BLACK CAUCUS FOUNDATION 1720 MASSACHUSETTS AVE NW WASHINGTON DC 20036 521160561 501(C)(3) 21000 0 GENERAL SUPPORT CONGRESSIONAL HISPANIC CAUCUS INSTITUTE INC 1128 16TH STREET NW WASHINGTON DC 20036 521114225 501(C)(3) 17500 0 GENERAL SUPPORT 17 0 ROBERT A. STEIN SCHOLARSHIP 23 127612 PART I, LINE 2: PROCEDURES FOR MONITORING USE OF GRANT FUNDS ECMC GROUP, INC. IS THE SOLE MEMBER OF ECMC FOUNDATION AND ECMC EDUCATION, INC. AND CLOSELY MONITORS THE USE OF THE CASH GRANT THROUGH REPORTS TO MANAGEMENT AND THE BOARD OF DIRECTORS ON A REGULAR BASIS. THE ROBERT A. STEIN SCHOLARSHIPS LISTED IN PART III ARE ISSUED AS JOINTLY PAYABLE TO THE STUDENT AND THE SCHOOL TO ENSURE THE FUNDS ARE USED FOR EDUCATIONAL EXPENSES. THE INDIVIDUAL SCHOLARSHIPS WERE AWARDED TO FURTHER THE INDIVIDUALS' EDUCATION. X X X 1 1 X X X X 1 1 0 0 1 0 1 0 0 GREGORY A VAN GUILDER CHIEF INVESTMENT OFFICER 681535 0 509800 0 152195 0 89868 0 9636 0 1443034 0 41000 0 JEREMY J WHEATON PRES & CEO-PART YR, SR ADVISOR 408446 0 800000 0 63060 0 18300 0 34229 0 1324035 0 20500 0 DANIEL S FISHER GRP PRES & CEO (EFF 07-03-22) 484979 0 504688 0 23826 0 78235 0 34212 0 1125940 0 20500 0 JOSH SLAYTON EDU PRES & SVP GRP DEV-PART YR 155575 0 259000 0 519119 0 16350 0 18667 0 968711 0 8220 0 MARTIN A SCANLON CFO & TREASURER 415034 0 412500 0 24432 0 68435 0 28561 0 948962 0 20500 0 SARAH STREHL CHIEF HUMAN RESOURCES OFFICER 326288 0 344250 0 23223 0 57405 0 36482 0 787648 0 18015 0 RAHOUL GHOSE CHIEF INFORMATION OFFICER 311907 0 303750 0 28393 0 56544 0 37261 0 737855 0 10892 0 PHILIP BECKER VP, INVESTMENTS 337849 0 173750 0 11209 0 47602 0 33951 0 604361 0 9525 0 HEIDI J JOHNSON SVP, CHIEF OF STAFF 238516 0 240500 0 22962 0 48330 0 32045 0 582353 0 5917 0 IRIS CUMBERBATCH SVP, CORPORATE AFFAIRS 242646 0 222000 0 24536 0 47462 0 14623 0 551267 0 4560 0 BRIAN BOARDMAN GRP GENERAL COUNSEL & CORP SEC 264020 0 110925 0 7267 0 39552 0 36934 0 458698 0 4556 0 JOSEPH WATT VP, IMPACT INVESTING 246193 0 102500 0 1162 0 37272 0 0 0 387127 0 0 0 BRUCE FEIST VP, APPLICATIONS & ANALYTICS 283096 0 24134 0 1657 0 37148 0 32089 0 378124 0 0 0 ADAM TRAMPE VP, DEPUTY GENERAL COUNSEL 216498 0 87638 0 941 0 35154 0 33956 0 374187 0 0 0 HUGH E MCSHERRY VP, CORPORATE SERVICES 223385 0 86100 0 2830 0 35263 0 24139 0 371717 0 0 0 STEPHEN H HANSEN VP, INFORMATION TECHNOLOGY 211059 0 85995 0 6065 0 36690 0 27595 0 367404 0 1188 0 JOHN MCKENNELL VP, CHIEF INFORMATION SEC. OFF 210464 0 81900 0 2034 0 35582 0 28336 0 358316 0 37 0 CHRISTOPHER JANZEN VP, ACADEMIC TECHNOLOGY 192193 0 87075 0 22111 0 34416 0 17540 0 353335 0 531 0 TIFFANY THOMPSON VP, FINANCE & CONTROLLER 213906 0 93525 0 1811 0 34862 0 2250 0 346354 0 725 0 MATTHEW T MIKULSKI VP, INTERNAL AUDIT 204849 0 81000 0 3195 0 34874 0 22421 0 346339 0 0 0 AARON WOODRICH SR DIR, INFORMATION TECHNOLOGY 194733 0 44708 0 951 0 27722 0 37647 0 305761 0 0 0 DEAN J VANDECOEVERING SR DIR, FINANCIAL PLANNING 207789 0 49815 0 1363 0 31287 0 11635 0 301889 0 0 0 SARA HEGG DIR, TOTAL REWARDS & PAYROLL 164450 0 71500 0 1828 0 29308 0 33965 0 301051 0 0 0 TROY GUNDERMAN DIR, LITIGATION 188652 0 46521 0 660 0 28664 0 27115 0 291612 0 0 0 CHRISTINE NOEL GOVERNMENT AFFAIRS DIRECTOR 193276 0 43968 0 1618 0 27136 0 24988 0 290986 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 TRAVEL FOR COMPANIONS ECMC GROUP, INC.'S TRAVEL POLICY HAD AN EXCEPTION THAT WAS APPROVED BY THE CFO (AND DEVIATIONS FROM ANY PROVISION OF THE POLICY MUST BE APPROVED IN WRITING BY AN OFFICER IN CONJUNCTION WITH THE ECMC GROUP, INC. CFO). IN 2022, ECMC GROUP, INC. PAID TRAVEL EXPENSES FOR AN ECMC GROUP, INC. EMPLOYEE'S SPOUSE TO ATTEND A COMPANY-SPONSORED EVENT. THE EXCEPTION TO POLICY WAS APPROVED. FIRST-CLASS OR CHARTER TRAVEL ECMC GROUP, INC.'S TRAVEL POLICY REQUIRES THAT THE LEAST COSTLY CLASS OF AIRFARE BE UTILIZED WHENEVER POSSIBLE. DUE TO A LACK OF FLIGHT AVAILABILITY AND SCHEDULE RESTRICTIONS, ECMC GROUP, INC. PAID FOR ONE FIRST CLASS SEAT FOR A KEY EMPLOYEE IN ONE INSTANCE IN 2022 FOR MEDICAL PURPOSES. 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, LINES 4A-B SEVERANCE OR CHANGE-OF-CONTROL PAYMENT THE FOLLOWING RECEIVED A SEVERANCE PAYMENT IN 2022: JOSH SLAYTON - $486,529 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, MARTIN A. SCANLON, AND SARAH STREHL PARTICIPATED IN THE 457(F) PLAN, AND RECEIVED EMPLOYER CONTRIBUTIONS OF $8,268, $19,135, $9,335 AND $255, RESPECTIVELY. PART I, LINE 5 COMPENSATION CONTINGENT ON REVENUES OF A RELATED 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 A RELATED 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 MR. MCKEON AND MR. SALTER - BUSINESS RELATIONSHIP FORM 990, PART VI, SECTION A, LINE 6 CLASSES OF MEMBERS OR STOCKHOLDERS EACH DIRECTOR OF THE ECMC GROUP, INC.'S BOARD OF DIRECTORS IS A MEMBER OF ECMC GROUP, INC. AT YEAR END 2022, THERE WERE 10 MEMBERS OF THE BOARD OF DIRECTORS AND, THEREFORE, 10 MEMBERS OF THE CORPORATION. MEMBERSHIP TERMINATES UPON THE TERMINATION OF SUCH MEMBER'S DIRECTOR STATUS ON THE BOARD OF DIRECTORS. THERE ARE NO STOCKHOLDERS. FORM 990, PART VI, SECTION A, LINE 7A MEMBERS OR STOCKHOLDERS ELECTING MEMBERS OF GOVERNING BODY THE MEMBERS OF ECMC GROUP, INC. BOARD OF DIRECTORS ARE NOMINATED BY THE GOVERNANCE & COMPENSATION COMMITTEE OF THE BOARD AND ELECTED BY THE BOARD OF DIRECTORS. THE GOVERNANCE & COMPENSATION COMMITTEE CONSISTS OF SUCH INDEPENDENT MEMBERS APPOINTED TO IT BY THE ECMC GROUP, INC. BOARD OF DIRECTORS. 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 OF ECMC GROUP, INC. AND ITS DISREGARDED ENTITIES 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 OF ECMC GROUP, INC. AND ECMC SHARED SERVICES COMPANY, LLC, A DISREGARDED ENTITY OF ECMC GROUP, INC., 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 OFFICIALS THE FOLLOWING DESCRIBES THE ECMC GROUP, INC., INCLUDING ECMC SHARED SERVICES COMPANY, LLC, 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., INCLUDING ECMC SHARED SERVICES COMPANY, LLC, 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, 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, INCLUDING ECMC SHARED SERVICES COMPANY, LLC, A DISREGARDED ENTITY OF ECMC GROUP, INC., 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., INCLUDING ECMC SHARED SERVICES COMPANY, LLC, A DISREGARDED ENTITY OF 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 X, LINE 25: OTHER LIABILITIES OTHER LIABILITIES AT DECEMBER 31, 2022, INCLUDE $1,552,264,845 ECMC FOUNDATION DEPOSITS IN THE ECMC GROUP, INC. APPORTIONED INVESTMENT POOL ("APPORTIONED INVESTMENT POOL"). A PORTION OF ECMC GROUP, INC.'S ASSETS ARE HELD IN THE ECMC GROUP, INC. INVESTMENT PORTFOLIO ASSET POOL, WHICH IS MANAGED BY ECMC GROUP, INC. PARTICIPATION IN THE APPORTIONED INVESTMENT POOL IS AVAILABLE TO ECMC GROUP, INC. AND ITS ELIGIBLE SUBSIDIARIES. INVESTMENTS IN THE APPORTIONED INVESTMENT POOL REPRESENT AN OWNERSHIP INTEREST IN THE INVESTMENT POOL, NOT IN THE UNDERLYING ASSETS THEMSELVES, AND ARE GENERALLY REDEEMABLE TO THE ELIGIBLE SUBSIDIARY UPON REQUEST. UNAPPORTIONED INVESTMENTS, NET, ARE NOT SUBJECT TO PARTICIPATION BY ECMC GROUP, INC.'S SUBSIDIARIES. FORM 990, PART VII, SECTION A: CONSULTING JOHN F. DEPODESTA, ROBERTA COOPER RAMO AND I. KING JORDAN, FORMER DIRECTORS, HAD CONSULTING AGREEMENTS IN 2022. FORM 990, PART XI, LINE 5, NET UNREALIZED LOSS ON INVESTMENTS: NET UNREALIZED LOSS ON INVESTMENT IN THE ECMC GROUP, INC APPORTIONED INVESTMENT POOL ARE $226,885,788. OAKDALE STUDENT LOAN FUNDING LLC 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 271914648 HOLDING FFELP LOANS DE 15557839 661150047 ECMC GROUP INC ECMC SHARED SERVICES COMPANY LLC 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 810690960 SUPPORT SERVICES FUNCTIONS DE 0 24044029 ECMC GROUP INC PATRIOT STUDENT LOAN CAPITAL LLC 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 813501777 TRUST STUDENT LOANS DE 0 104548242 ECMC GROUP INC SUPERIOR SOLUTIONS I GP LLC 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 882460810 INVESTMENTS DE 0 0 ECMC GROUP INC EDUCATIONAL CREDIT MANAGEMENT CORP 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411778617 FFELP GUARANTOR MN 501(C)(3) LINE 10 ECMC GROUP INC 1 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 1 ECMC EDUCATION INC 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 472237488 CAREER COLLEGES DE 501(C)(3) LINE 2 ECMC GROUP INC 1 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 0 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 1 1 NORTH CHINA A EQUITY FUND LLC 1 N WACKER DR CHICAGO IL 60606 844524632 INVESTMENTS DE ECMC GROUP INC EXCLUDED -9509508 0 0 1.00000 ATX A-TEAM THE GUILD LP 500 W SECOND ST STE 1900 163 AUSTIN TX 78701 843490066 INVESTMENTS TX ECMC GROUP INC EXCLUDED 2700000 0 0 0.66000 AUBREY GEMS PARTNERS LP 800 THIRD AVE 28TH FL NEW YORK NY 10022 365009933 INVESTMENTS NY ECMC GROUP INC EXCLUDED -7607790 32830833 0 0 0.70000 BST 052 A SERIES OF SAX CAP FUND III LP PO BOX 3217 SEATTLE WA 98114 853876811 INVESTMENTS DE ECMC GROUP INC EXCLUDED 8479 141527 0 0 1.00000 CHLOE CAPITAL FUND I LP 700 CASCADILLA ST STE 201 ITHACA NY 14850 844269068 INVESTMENTS DE ECMC GROUP INC EXCLUDED 2717 3053379 0 0 0.55000 COMMONFUND CAP SECONDARIES OPP FUND 15 OLD DANBURY RD WILTON CT 06897 842082338 INVESTMENTS DE ECMC GROUP INC EXCLUDED 1146950 26067557 0 161070 0 1.00000 CRP VF IV GP LP 7600 N CAP OF TX HWY BLDG B STE 130 AUSTIN TX 78731 863644095 INVESTMENTS DE ECMC GROUP INC EXCLUDED -1752307 17258900 0 0 0.94000 ECMC-UV CO-INVESTMENT FUND LP 104 W 40TH ST STE 1600 NEW YORK NY 10018 813873029 INVESTMENTS DE ECMC GROUP INC EXCLUDED 3454128 0 0 0.99000 ELEMENTS HEALTH VENTURES II LLC 623 5TH AVE 14TH FL NEW YORK NY 10022 862638962 INVESTMENTS DE ECMC GROUP INC EXCLUDED 24897 3486568 0 0 0.51000 FUND D-2 RIOT VENTURES OPPORTUNITY FUND 1632 ABBOT KINNEY BLVD VENICE CA 90291 920652495 INVESTMENTS DE ECMC GROUP INC EXCLUDED 892450 0 0 1.00000 GEM MINING 4 LLC 550 S MAIN ST STE 310 GREENVILLE SC 29601 871562792 INVESTMENTS DE ECMC GROUP INC EXCLUDED 6119317 1751984 0 0 1.00000 ONRAMP EDUC & WORKFORCE INNOV FUND 821 E WASHINGTON AVE STE 200-G MADISON WI 53703 843999115 INVESTMENTS DE ECMC GROUP INC EXCLUDED 10718 1166437 0 0 0.82000 PC-1 DEVELOPERS LLC 3600 MAYBERRY DR RENO NV 89509 831603672 INVESTMENTS NV ECMC GROUP INC EXCLUDED -256637 4553818 0 -256637 0 0.67000 R7 FAMILY FUND LP 100 S WACKER DR STE 1675 CHICAGO IL 60606 851019413 INVESTMENTS DE ECMC GROUP INC EXCLUDED 11397488 0 0 1.00000 RI FUND I A SERIES OF BOOST VC SPV LP PO BOX 3217 SEATTLE WA 98114 874641779 INVESTMENTS CJ ECMC GROUP INC EXCLUDED 2600088 0 0 0.99000 SUPERIOR SOLUTIONS I LP 111 WASHINGTON AVE S STE 1400 MINNEAPOLIS MN 55401 882485015 INVESTMENTS DE ECMC GROUP INC EXCLUDED -58321 72523457 0 -136647 0 1.00000 TABOR MILLENNIAL FUND LP 11 E 44TH ST STE 705 NEW YORK NY 10017 880598843 INVESTMENTS DE ECMC GROUP INC EXCLUDED -4173921 20889473 0 0 0.97000 TABOR OFFSHORE OPPORTUNITIES LTD 11 E 44TH ST STE 705 NEW YORK NY 10017 INVESTMENTS CJ ECMC GROUP INC EXCLUDED 612153 28726088 0 0 0.93000 UNLESS VENTURES LP 1023 WALNUT ST STE 100 BOULDER CO 80302 874222103 INVESTMENTS DE ECMC GROUP INC EXCLUDED 268246 26402927 0 0 0.75000 UP FUND I A SERIES OF BOOST VC SPV LP PO BOX 3217 SEATTLE WA 98114 851519551 INVESTMENTS DE ECMC GROUP INC EXCLUDED 1033000 0 0 0.99900 WY FUND I A SERIES OF BOOST VC SPV LP PO BOX 3217 SEATTLE WA 98114 851519506 INVESTMENTS DE ECMC GROUP INC EXCLUDED 80001 1233308 0 0 0.99900 GENGLOBAL CRYSTAL LLC 1302 PACIFC AVE SAN FRANCISCO CA 94109 882663560 INVESTMENTS DE ECMC GROUP INC EXCLUDED 2021194 0 0 1.00000 GENGLOBAL SUNSHINE LLC 1302 PACIFC AVE SAN FRANCISCO CA 94109 853885948 INVESTMENTS DE ECMC GROUP INC EXCLUDED 4539535 0 0 1.00000 UNLESS LGH SPV LLC 1023 WALNUT ST STE 100 BOULDER CO 80302 880557430 INVESTMENTS DE ECMC GROUP INC EXCLUDED 2000958 0 0 1.00000 OAKDALE INVESTMENT MANAGEMENT CORP 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 352085743 HOLDING INVESTMENTS DE ECMC GROUP INC C 6624 2578725 1.00000 1 ECMC HOLDINGS CORPORATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411991992 STRATEGIC OVERSIGHT DE ECMC GROUP INC C 244037 4572097 1.00000 1 EDUCATIONAL CREDIT SERVICES COMPANY 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411992001 PRIVATE LOANS DE N/A C 1 ECMC RECORDS & REC MGMT CORPORATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411989959 DOCUMENT MANAGEMENT DE N/A C 1 ECMC MANAGEMENT SERVICES CORPORATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411989960 MANAGEMENT SERVICES DE N/A C 1 ECMC TECHNOLOGY SERVICES CORPORATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411989958 TECHNOLOGY SERVICES DE N/A C 1 ECMC SERVICING CORPORATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 471154366 LOAN SERVICING DE N/A C 1 ECMC PRIVATE MARKET OPPORTUNITIES LP 156 W 56TH ST CITYSPIRE BLDG SQUAD NEW YORK NY 10019 842552668 INVESTMENTS DE ECMC GROUP INC C 30024852 1.00000 1 0 1 1 1 0 0 0 0 0 0 0 1 0 1 1 1 1 0 0 ECMC FOUNDATION B 501572000 ALLOCATION ECMC EDUCATION INC B 26296902 ALLOCATION EDUCATIONAL CREDIT MANAGEMENT CORPORATION C 247934497 ALLOCATION 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