Federal Family Education Loan Program
Eliminating the Exceptional Performer Designation Would Result in Substantial Savings without Adversely Affecting the Loan Program Gao ID: GAO-07-1087 July 26, 2007The federal government guarantees loans in the Federal Family Education Loan program (FFELP) so that private lenders that participate in the program will be reimbursed if a borrower defaults, and about $4.6 billion was spent in fiscal year 2006 to repay lenders for defaulted loans. To retain the guarantee on their loans, all FFELP lenders must comply with minimum due diligence requirements for servicing loans, including establishing a borrower's first repayment due date and making a certain number of attempts to contact delinquent borrowers. Lenders that adhere to these requirements are eligible to receive at least a standard reimbursement rate of 97 percent of the outstanding principal and accrued interest for defaults. However, pursuant to a provision of the Higher Education Amendments of 1992, the Secretary of Education has the authority to designate lenders and loan servicers as "exceptional performers" in servicing FFELP loans, and loans serviced by those with the exceptional performer designation qualify for a 99 percent reimbursement rate. The amendments also provided authority to the Secretary of Education to terminate the exceptional performer program following a GAO study, if such termination is in the fiscal interest of the United States. To obtain the exceptional performer designation, loan servicers have to obtain an initial audit, by independent auditors, demonstrating at least 97 percent compliance with due diligence requirements for a random sample of loans they service, and they must continue to demonstrate compliance through quarterly and annual audits to maintain the designation. The first exceptional performer designation that Education granted took effect in January 2004, and 18 organizations that service about 90 percent of all FFELP loans currently have the exceptional performer designation. Congress asked us to conduct a review of the exceptional performer program to answer the following questions: (1) To what extent is the exceptional performer program meeting its objectives of improving loan servicing and decreasing defaults? (2) What are the costs and benefits of the exceptional performer program?
In summary, we reported the following findings. The exceptional performer program has not materially affected loan servicing, and default claims have not declined in the years following the first exceptional performer designation. Specifically, representatives from each of the exceptional performers we interviewed told us they did not make substantive changes to their loan servicing to obtain the designation, and technological advances made prior to the first exceptional performer designation automated much of loan servicing, which simplified compliance with due diligence requirements. Additionally, both the number and dollar amount of default claims relative to all out-of-school FFELP loans increased from fiscal years 2004 to 2006. The federal government incurs substantial costs, while lenders receive most of the benefits for the exceptional performer program. The Congressional Budget Office estimates that the federal government will spend $1 billion during the next 5 years on the extra 2 percent reimbursement for default claims on loans serviced by exceptional performers. Providing an extra 2 percent reimbursement rate for default claims serviced by exceptional performers is not in the fiscal interest of the federal government because lenders are being paid a premium to perform due diligence activities that are already required of all lenders. The risk of having default claims rejected already provides lenders with sufficient incentive to comply with due diligence requirements. Further, the criteria established in 1992 for the exceptional performer designation do not indicate exceptional performance today because technological advances have made it easier for lenders to meet these criteria. Congress has included language to eliminate the exceptional performer designation as part of proposed legislation on federal student aid. The House and Senate each passed different versions of this legislation that would eliminate the provision, and action is pending on final legislation. On the basis of our findings, we agree that the exceptional performer program should be eliminated. If the proposed legislation is not enacted by the end of the current session of Congress, we recommend that the Secretary of Education use her existing authority to eliminate the exceptional performer program.
GAO-07-1087, Federal Family Education Loan Program: Eliminating the Exceptional Performer Designation Would Result in Substantial Savings without Adversely Affecting the Loan Program
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Exceptional Performer Designation Would Result in Substantial Savings
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Report to the Chairman, Committee on Education and Labor, House of
Representatives:
United States Government Accountability Office: GAO:
July 2007:
Federal Family Education Loan Program:
Eliminating the Exceptional Performer Designation Would Result in
Substantial Savings without Adversely Affecting the Loan Program:
GAO-07-1087:
Contents:
Letter:
Appendix I: Briefing Slides:
Appendix II: Comments from the Department of Education:
Abbreviations:
FFELP: Federal Family Education Loan program: NSLDS: National Student
Loan Data System:
[End of section]
United States Government Accountability Office: Washington, DC 20548:
July 26, 2007:
The Honorable George Miller:
Chairman:
Committee on Education and Labor: House of Representatives:
Dear Mr. Chairman:
The federal government guarantees loans in the Federal Family Education
Loan program (FFELP) so that private lenders that participate in the
program will be reimbursed if a borrower defaults, and about $4.6
billion was spent in fiscal year 2006 to repay lenders for defaulted
loans. To retain the guarantee on their loans, all FFELP lenders must
comply with minimum due diligence requirements for servicing loans,
including establishing a borrower's first repayment due date and making
a certain number of attempts to contact delinquent borrowers. Lenders
that adhere to these requirements are eligible to receive at least a
standard reimbursement rate of 97 percent of the outstanding principal
and accrued interest for defaults. However, pursuant to a provision of
the Higher Education Amendments of 1992, the Secretary of Education has
the authority to designate lenders and loan servicers as "exceptional
performers" in servicing FFELP loans, and loans serviced by those with
the exceptional performer designation qualify for a 99 percent
reimbursement rate. The amendments also provided authority to the
Secretary of Education to terminate the exceptional performer program
following a GAO study, if such termination is in the fiscal interest of
the United States[Footnote 1].
To obtain the exceptional performer designation, loan servicers have to
obtain an initial audit, by independent auditors, demonstrating at
least 97 percent compliance with due diligence requirements for a
random sample of loans they service, and they must continue to
demonstrate compliance through quarterly and annual audits to maintain
the designation. The first exceptional performer designation that
Education granted took effect in January 2004, and 18 organizations
that service about 90 percent of all FFELP loans currently have the
exceptional performer designation.
You asked us to conduct a review of the exceptional performer program
to answer the following questions: (1) To what extent is the
exceptional performer program meeting its objectives of improving loan
servicing and decreasing defaults? (2) What are the costs and benefits
of the exceptional performer program?
We briefed your staff on the results of our analysis on June 28, 2007.
This report formally conveys the information provided during that
briefing. In summary, we reported the following findings:
* The exceptional performer program has not materially affected loan
servicing, and default claims have not declined in the years following
the first exceptional performer designation. Specifically,
representatives from each of the exceptional performers we interviewed
told us they did not make substantive changes to their loan servicing
to obtain the designation, and technological advances made prior to the
first exceptional performer designation automated much of loan
servicing, which simplified compliance with due diligence requirements.
Additionally, both the number and dollar amount of default claims
relative to all out-of-school FFELP loans increased from fiscal years
2004 to 2006.
* The federal government incurs substantial costs, while lenders
receive most of the benefits for the exceptional performer program. The
Congressional Budget Office estimates that the federal government will
spend $1 billion during the next 5 years on the extra 2 percent
reimbursement for default claims on loans serviced by exceptional
performers.
Providing an extra 2 percent reimbursement rate for default claims
serviced by exceptional performers is not in the fiscal interest of the
federal government because lenders are being paid a premium to perform
due diligence activities that are already required of all lenders. The
risk of having default claims rejected already provides lenders with
sufficient incentive to comply with due diligence requirements.
Further, the criteria established in 1992 for the exceptional performer
designation do not indicate exceptional performance today because
technological advances have made it easier for lenders to meet these
criteria.
Congress has included language to eliminate the exceptional performer
designation as part of proposed legislation on federal student aid. The
House and Senate each passed different versions of this legislation
that would eliminate the provision, and action is pending on final
legislation.[Footnote 2] On the basis of our findings, we agree that
the exceptional performer program should be eliminated. If the proposed
legislation is not enacted by the end of the current session of
Congress, we recommend that the Secretary of Education use her existing
authority to eliminate the exceptional performer program.
We provided copies of a draft of this report to the Department of
Education for review and comment. In written comments, Education agreed
with our recommendation to eliminate the exceptional performer program
and said it was hopeful that Congress would do so through
reauthorization of the Higher Education Act. See appendix II for the
department's comments.
We used the following methodologies to develop our findings. To
understand the history and requirements of the exceptional performer
program, we reviewed relevant laws, regulations, and guidance related
to the exceptional performer program. To determine whether the
exceptional performer program is meeting its objectives and the costs
and benefits of the program, we conducted semistructured interviews
with officials at the first 7 organizations that received the
exceptional performer designation, 3 loan servicers that have not
applied for the designation, and 6 of the 35 state-designated guaranty
agencies that administer most aspects of the FFELP program. To ensure
that the guaranty agencies we interviewed did not have a vested
interest in the exceptional performer program, we selected guaranty
agencies that do not have organizational components or affiliates that
make or service FFELP loans that could be eligible to become
exceptional performers. Further, we selected guaranty agencies from
different regions in the country. We also conducted interviews with two
trade associations representing FFELP lenders and servicers, two
leading financial research services that provide credit ratings of
lenders and securities issued by lenders, and officials at the
Department of Education.
To assess changes in defaults on FFELP loans since the exceptional
performer designation was granted, we analyzed data from the National
Student Loan Data System (NSLDS) covering fiscal years 1998 to 2006. To
control for portfolio growth, we analyzed defaulted loans relative to
all out-of-school loans, that is, all loans that were in repayment,
deferment, forbearance, and default. To assess the reliability of NSLDS
data, we talked with agency officials about data quality control
procedures and reviewed relevant documentation. We determined the data
were sufficiently reliable for the purposes of this study. We conducted
our work from October 2006 through June 2007 in accordance with
generally accepted government auditing standards.
We are sending copies of this report to relevant congressional
committees, the Secretary of Education, and other interested parties
and will make copies available to others upon request. In addition,
this report will be available at no charge on GAO's Web site at
[hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-7215 or scottg@gao.gov. Contact points for our
Office of Congressional Relations and Public Affairs may be found on
the last page of this report. Key contributors to this report include
Debra Prescott (Assistant Director), Kathy Peyman (Analyst-in-Charge),
Carlo Salerno, Jeff Appel, Jessica Botsford, Crystal Bernard, Doreen
Feldman, Cynthia Grant, Jean McSween, and Charles Willson.
Sincerely yours,
Singed by:
George A. Scott:
Director, Education, Workforce, and Income Security Issues:
[End of section]
Appendix I: Briefing Slides:
1Eliminating the Exceptional Performer Designation Would Result in
Substantial Savings Without Adversely Affecting the Loan Program:
Briefing for the Chairman,House Committee on Education and Labor: June
28, 2007:
Overview:
* Introduction;
* Research Questions;
* Scope and Methodology;
* Summary of Findings;
* Background;
* Research Findings;
Conclusions.
Introduction:
* The federal government insures loans in the Federal Family Education
Loan program (FFELP) so that lenders are reimbursed at least 97 percent
of the loan‘s outstanding principal and accrued interest if a borrower
defaults. In fiscal year 2006, the federal government spent about $4.6
billion reimbursing lenders for defaults.
* The Higher Education Amendments of 1992 included provisions for
designating lenders and loan servicersfor exceptional performance in
servicing FFELP loans. Loans serviced by exceptional performersreceive
a higher reimbursement rate--99 percent–if the loan defaults.
* Because about 90 percent of FFELP loans are now serviced by lenders
and servicerswith the exceptional performer designation, concerns have
been raised about the need for such a program and Congress has
introduced legislation to eliminate it.
Research Questions:
1. To what extent is the exceptional performer program meeting its
objectives of improving loan servicing and decreasing defaults? 2. What
are the costs and benefits of the exceptional performer program?
Scope and Methodology:
To address our research objectives, we:
* Reviewed relevant laws, regulations, and guidance related to
receiving the exceptional performer designation;
* Conducted interviews with: the first 7 organizations to receive the
exceptional performer designation, 3 organizations that have
notreceived the designation, 6 guaranty agencies that do not have ties
to organizations that make or service FFELP loans, 2 trade associations
representing FFELP lenders and servicers, 2 leading financial research
services that provide credit ratings of lenders and securities issued
by lenders, and the Department of Education (Education);
* Analyzed trends in default claims while controlling for portfolio
growth using data from the National Student Loan Data System (NSLDS)
coveringfiscal years 1998-2006. We found the data sufficiently reliable
for the purposes of this study;
* Conducted our work from October 2006 through June 2007 in accordance
with generally accepted government auditing standards.
Summary of Key Findings:
Despite High Costs, the Exceptional Performer Program Has Not Benefited
the Federal Government:
*The exceptional performer program has not materially affected loan
servicing, and default claims did not decline in the years following
the first exceptional performer designation.
* The program‘s costs are borne primarily by the federal government
–approximately $1 billion over the next 5 years for the higher
reimbursement rate paid on default claims –while lenders receive most
of the program‘s benefits.
Background:
Under FFELP, Private Lenders Provide Federally Insured Loans to
Students:
* Lenders can either service their own loans or contract these
activities out to a third-party loan servicer.
* Thirty-five guaranty agencies administer most aspects of the program,
including the review of default claims.
* Using federal funds, guaranty agencies currently insure all lenders
for at least 97 percent of the loan‘s outstanding principal and accrued
interest. The agencies also work with lenders and borrowers to prevent
loan defaults and collect on loans after they default.
All Lenders Must Adhere to Minimum Due Diligence Requirements to Retain
FFELP Loan Guarantees:
* Establish each borrower‘s first repayment due date and convert the
borrower to repayment within specified time frames.
* For delinquent borrowers lenders must also:
- Send a required number of collection letters, make a required number
of telephone calls, and ensure there are no gaps greater than 45 days
between attempts to contact the borrower.
- Perform a process called ’skip tracing“ to obtain a borrower‘s
current address or telephone number whenever the lender learns it has
incorrect contact information.
- Seek default aversion assistance from the guaranty agency between 60
and 120 days of delinquency.
- Send a final demand letter requiring repayment of the loan in full on
or after 241 days of delinquency.
* File default claims with guaranty agencies within a specified time
frame.
The Exceptional Performer Provisions Developed During a Period of
Concern over High Loan Defaults:
* When Congress enacted the Higher Education Amendments of 1992, which
contained the provision for the Exceptional Performer designation, the
most recently reported cohort default rate was very high ”about 22
percent.[Footnote 3]
* In 1994, when it issued regulations for the exceptional performer
designation, the Department of Education stated that it expectedthe
designation to reduce the cost of defaults by encouraging lenders and
loan servicersto improve their servicing and collection of FFELP loans.
After the First Designation, the Number of Designated Organizations
Grew Quickly:
* Twelve years after the provision was enacted, Education granted the
first exceptional performer designation to take effect January 2004. *
Today, there are 18 designated Exceptional Performers that service
about 90 percent of all outstanding FFELP loans.
Exceptional Performer Designation Focuses on Adherence to Due Diligence
Requirements:
* The 1992 statutory provisions for the exceptional performer
designation grew out of lenders‘ concerns that the due
diligencerequirements for servicing delinquent loans were too rigid and
resulted in claim rejections and disproportionate financial penalties.
* To obtain the designation, lenders and loan servicershave to obtain
an initial audit demonstrating at least 97 percent compliance with due
diligence requirements for a random sample of loans they service.
Exceptional performers must continue to have quarterly and annual
audits to maintain the designation.
Exceptional Performer Program Shifts Oversight of Due Diligence
Compliance from Guaranty Agency to Audits:
* For standard performers, guaranty agencies review all default claims
filed to ensure compliance with due diligence requirements. When
violations are identified, guaranty agencies can reject the claim or
impose penalties that reduce the claim amount depending on the nature
of the violation.
* For exceptional performers, the audits serve as evidence that due
diligence compliance has been met. Guaranty agencies cannot reject
claims or impose penalties that reduce the size of the claim for due
diligence violations on loans serviced by an exceptional performer.
Question 1: Improving Loan Servicing:
The Exceptional Performer Program Has Not Materially Affected Loan
Servicing:
* Representatives from each of the exceptional performers we
interviewed told us that they did not make substantive changes to their
loan servicing in order to obtain the designation. However, they said
undergoing regular audits of their due diligence compliance helped
their organizations strengthen internal controls over due diligence.
* Both exceptional and standard performers we interviewed said that
they go beyond the minimum due diligence requirements by, for example,
making additional contact attempts with delinquent borrowers.
* Guaranty agency officials told us that they observed no difference
between exceptional and standard performers with respect to due
diligence compliance.
Default Claims Have Not Declined Since Fiscal Year 2004, When the First
Exceptional Performer Designation Was Granted:
* In the period after the program was enacted but before the
firstexceptional performer designation was granted, cohort default
rates on FFELPloans steadily declined for various reasons, such as
barring schools with high cohort default rates from participating in
FFELP.
* The requirements for obtaining and retaining the exceptional
performer designation relate to complying with due diligence processes
andnot improving outcomes such as reducing defaults.
* From fiscal years 2004 through 2006, the volume of outstanding loans
serviced by exceptional performers grew to about 90 percent, according
to Department of Education officials. For the same time period, we
analyzed FFELP default claims relative to outstanding FFELP loans and
found:
- the number of default claims increased from 2.8 percent to 3.7
percent, and:
- the dollar amount of default claims increased from 1.8 percent to 1.9
percent of loan volume.
Figure 1: FFELP Default Claims as a Percentage of All Outstanding "Out
of School" Loans.[Footnote 4]
This is a line graph depicting the percent of default claims per fiscal
year. There are two lines depicted: (1) Based on number of loans
defaulted; (2) Based on dollar volume of loans.
Percentage of Default Claims: Fiscal Year 1999; Based on number of
loans: 2.6 percent Based on dollar volume of loans: 2.3 percent
Percentage of Default Claims: Fiscal Year 2004; Based on number of
loans: 2.8 percent Based on dollar volume of loans: 1.8 percent
Percentage of Default Claims: Fiscal Year 2005; Based on number of
loans: 3.4 percent Based on dollar volume of loans: 2.0 percent
Percentage of Default Claims: Fiscal Year 2006; Based on number of
loans: 3.7 percent Based on dollar volume of loans: 1.9 percent
Source: GAO analysis of NSLDS data.
[End of table]
Question 2: Costs and Benefits:
Substantial Program Costs Are Borne Largely by the Federal Government,
Benefits Accrue Primarily to Lenders: Federal Government:
* The primary cost of the program to the federal government is theextra
2 percent in lender reimbursement. The Congressional Budget Office
estimates the extra 2 percent will cost the federal government about $1
billion from fiscal year 2008 through fiscal year 2012.
* In addition to these costs, the federal government foregoes the
assessment of interest penalties for due diligence violations by
exceptional performers.
Guaranty Agencies:
* Guaranty agencies told us they incurred minor system reprogramming
costs associated with managing separate review processes for
exceptional and standard performers as well as marginally higher costs
associated with reimbursing claims serviced by exceptional performers
at the higher reimbursement rate.
* Some guaranty agencies reported marginal time and labor savings
because they are not reviewing exceptional performers‘ claims for due
diligence compliance.
Exceptional Performers:
* Exceptional performers main cost is the audits needed to obtain and
retain the designation. Costs for these audits ranged from $80,000 to
$400,000, according to estimates provided by exceptional performer
officials.
* Lenders receive two financial benefits for default claims on loans
serviced by exceptional performers: the 2 percent higher reimbursement
rate and the absence of interest penalties for due diligence
violations.
* Because their claims cannot be rejected for due diligence violations,
exceptional performers save administratively from not having to
resubmit claims or address guaranty agencies‘ questions about due
diligence compliance.
* Also, exceptional performers reported that the designation provides
public recognition and can be used for marketing purposes.
Conclusions:
* Providing lenders an extra 2 percent reimbursement rate for default
claims serviced by exceptional performers is not in the fiscal
interestof the federal government in light of findings that the
exceptional performer program has not materially improved loan
servicing and default claims have not declined in the years following
the first designation.
- The federal government is paying lenders a premium to perform due
diligence activities that are already required of all lenders.
- The risk of having default claims rejected and incurring penalties
for due diligence violations already provides lenders incentives to
fully comply with due diligence requirements.
- Federal expenditures for the program are not justified by the time
and labor savings from expedited claim review that some guaranty
agencies and exceptional performers reported.
* The criteria established in 1992 for the exceptional performer
designation do not indicate exceptional performance today, because
technological advances have made it easier for lenders to meet these
criteria.
[End of section]
Appendix II: Comments from the Department of Education:
Chief Operating Officer:
Department of Education:
830 First St. NE:
Washington, DC 20202:
[hyperlink, http://www.FederalStudentAid.ed.gov]: 1-800-4-FED-AID:
July 20 2007:
Honorable David M. Walker:
Comptroller General:
Government Accountability Office: 441 G Street, NW:
Washington, DC 20548:
Dear Mr. Walker:
In accordance with 31 U.S.C. 720, I am writing to respond to
conclusions presented in the Government Accountability Office (GAO)
report, "Federal Family Education Loan Program: Eliminating the
Exceptional Performer Designation Would Result in Substantial Savings
without Adversely Affecting the Loan Program" (GAO-07-1078).
The Department concurs with the recommendations of the report, and we
are hopeful that Congress will eliminate the exceptional performer
program through reauthorization of the Higher Education Act. Thank you
for the opportunity to respond.
Sincerely,
Signed by:
Lawrence Warder:
Acting Chief Operating Officer: Federal Student Aid:
[End of section]
FOOTNOTES
[1] The Higher Education Amendments of 1992 provided for a GAO study of
the exceptional performer designation to be conducted within 3 years of
enactment of the legislation, but the study could not be undertaken
until recently because no organizations had received the designation.
[2] The legislation being considered is H.R. 2669, the College Cost
Reduction Act of 2007.
[3] The Department of Education calculates a cohort default rate based
on the percentage of borrowers who enter repayment during a particular
fiscal year and default before the end of the next fiscal year.
[4] Out of School loans are loans classified as being in repayment,
deferment, forbearance or default.
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