-..-_-._......___”.._-_ .” .1”.. 11/,11”1111,1- ,1.1------- linittxi Stal.es General Accountittg Off’ict~ -_ Fact Sheet for the Chairman, Permanent Subcommittee on Investigations, Committee on Governmental Affairs, U.S. Senate S~~pt.twltwr 1990 STUDENT LOAN LENDERS Information on the Activities of the First Independent Trust Company Fd I IllIll 142452 J .._ .._.. ..“l., ..- -__. --.. _._..__._.__. _...“_.._... 111” l”_l ._._.““.” _._., “..“” l-.___.-.___“_l ..._._II__-” _..__ _.-.__l_-,___ ~ --I--.-- United States GAO General Accounting Office Washington, D.C. 20648 Human Resources Division B-241263 September 25,199O The Honorable Sam Nunn Chairman, Permanent Subcommittee on Investigations Committee on Governmental Affairs United States Senate Dear Mr. Chairman: This report responds to your request for information on activities of the First Independent Trust Company (FITCO)of Carmichael, California. FITCO made loans to students participating in the Stafford Student Loan Program until California’s State Banking Department closed it in May 1989. Specifically, you requested information describing the chronology of events from when FITW began and ceased operations and afterwards. In addition, you asked that we (1) analyze FITCQ's loan portfolio, (2) determine whether it owed monies to the Department of Education, and (3) summarize the audits and reviews of FITCOconducted by various organizations. On September 19,1990, we discussed the results of our work with your office. This fact sheet summarizes the information provided at that meeting. The Stafford Student Loan Program, formerly called the Guaranteed Background Student Loan Program, consists of three types of loans: Stafford loans, Parent Loans for Undergraduate Students (PLUS), and Supplemental Loans for Students (SIS). These types of loans differ somewhat in their terms and conditions (see app. I), but each is guaranteed by state or pri- vate nonprofit guaranty agencies against borrowers’ death, disability, bankruptcy, and default. Banks, credit unions, and savings and loan associations are the primary providers of student loans. The federal government reinsures the guaranty agencies against death, disability, bankruptcy, and default. Lenders participating in this program generate revenue by earning interest and receiving from the Department of Education a special allowance payment-to assure that student loans provide close to market rates of return. For Stafford loans (but usually not SLSand PLUS loans) federal interest payments are generally made while the student Page 1 GAO/HlUMO-1S3FY3 Student Loan Lenders c remains in school and afterwards for a grace period,’ and then the bor- rower becomes responsible for principal and interest payments. In con- trast, the special allowance payment is paid to the lender throughout the life of the loan. Lenders can file quarterly for their interest subsidy payments. From Stafford loan borrowers, lenders collect a 5-percent origination fee, which is deducted from each loan disbursement made to the bor- rowers. SLSand PLUS loans are not subject to these fees. The fee is remitted to the Department to help offset the government’s cost of sub- sidizing these loans. In addition, lenders can collect an insurance pre- mium of up to 3 percent from each loan disbursement, regardless of the type of loan. The premium is remitted to the guaranty agencies to help offset their administrative costs. FITCO has made all three types of student loans. Its primary practice was to sell the loans it originated to a secondary market quickly,2 often within a few days of their origination. FITCOcould then use these loan proceeds to make new loans. As agreed with your office, we obtained the requested information pri- Scopeand marily by interviewing and reviewing records provided by officials of Methodology the (1) California State Banking Department, (2) Department of Educa- tion headquarters and its San Francisco regional office (region IX), (3) California Student Aid Commission (CNC), and (4) Higher Education Assistance Foundation (HEAF). We also spoke with and obtained docu- ments from several other organizations that serviced or otherwise were involved in handling FITCOloans. cxc and HEAF guaranteed almost all the loans FITCO made and gave us a statistical analysis of the loans FITCOdisbursed by fiscal year, type of loan, and kind of school borrowers attended. We analyzed loan informa- tion by grouping the schools in two categories-proprietary and nonpro- prietarye3 We did not independently verify the information CMC and HEAF provided. ‘Generally between 6 and 12 months after a student leaves school. 2A lending institution that purchases guaranteed student loans from originating lenders to provide them funds to make new loans. 3CSACprovided us with information for its loans disbursed by nine types of schools. We used its category “vocational profit-making” to show proprietary schools, and combined the remaining eight types of schools to compute nonproprietary school information. Page 2 GAO/HRD-9@lS2Fs Student Loan Lenders B-241253 Our work was conducted between May and September 1990 in accor- dance with generally accepted government auditing standards. Appendix II presents information on selected milestones in FITCO'S activ- Chronology of Events ities, beginning with its start-up in September 1976, covering events leading to its closing in May 1989, and ending with a lawsuit the Cali- fornia Banking Department filed against FITCO'S former officers in June 1990. Appendix II also includes the dates when CSACand HEAF began guaranteeing FITCO'S loans, 1979 and 1986, respectively, and highlights when FITCO was notified of possible problems concerning its operations. During the 11 years FITGO was in the Stafford program, it made over Portfolio Analysis $1 billion in loans that were guaranteed by CSACand HEAF. Table 1 shows the amount of loan disbursements that were guaranteed by CSACand HEAF, most of which were for Stafford loans. Table 1: Net Disbursements by Type of Loan lor CSAC and HEAF Dollars in millions Guaranty agency Type of loan CSAC HEAF -____- Stafford $383.6 $379.0 PLUS 17.7 10.7 SLS 118.1 179.0 Total $519.4 $566.7 Most of FITCO'S loans were made to students attending proprietary schools. Table 2 shows that $366.2 million (68 percent) of the $519.4 million in loans guaranteed by c&c and $547.1 million (96 percent) of the $568.7 million in loans guaranteed by HEXF were made to students attending such schools. Table 2: Net Dlrbursements by Type ot School Ilor CSAC and HEAF Dollars in millions Guaranty agency Type of school CSAC HEAF Proprietary $355.2 $547.1 Nonproprietary 164.2 21.6 Total $519.4 $566.7 Page 3 GAO/HRD-90-183Fs Student Loan Lenders B-241263 When a lender files its quarterly bill with the Department for interest Possible Monies Owed and special allowance subsidy payments, the Department offsets any to the Department of origination fees it is due. For example, if a lender is due $1 million in Education interest and special allowance and owes the Department $400,000 in origination fees, the Department would pay the lender $600,000. Con- versely, if a lender owes more origination fees than interest and special allowance, it should send the Department a check for the difference. Because FITCO sold its loans to secondary market lenders soon after it made them, it usually owed the Department loan origination fees. At one point, FITCO owed the Department over $13 million in fees from loans originated in 1987. These fees were not paid until April 1988. Appendix III contains a detailed analysis of the problems FITCO had in keeping current its origination fee payments to the Department. For example, FITCO owed the Department about $5.5 million after it ceased operations in May 1989; however, in March 1990, the Department agreed with the State Banking Department (as the liquidator of FITCO) to settle this debt for $4.4 million. We confirmed through our analysis of the Department’s records that FITCO actually owed the Department $5.5 million. The Department said that it agreed to the $4.4 million amount after con- sidering the litigation risk of pursuing the $6.5 million underpayment (i.e., the probability of prevailing), the resource drain on the federal government needed to pursue the litigation, and the time it would take to receive the $6.6 million. In addition, the Department indicated that the deadline for amending its $4.4 million claim with the State Banking Department had expired. We identified 21 audits and reviews of FITCO activities conducted during Summary of Reviews the 14-year period by such organizations as the State Banking Depart- Conducted at FITCO ment, the Department of Education, CSAC,and HEAF-. (See app. IV.) Each of the audits and reviews found minor or major deficiencies in FIT&S operations. An example of a minor deficiency was that FITCO failed to use new student addresses, which it knew, to mail delinquency letters. A major deficiency was that FITCO did not timely file its interest billings and owed the Department origination fees, such as the $13 mil- lion discussed earlier. In addition, State Banking Department audit reports cited problems in FITCO'S financial operations as early as Page 4 GAO/HRD-QO-133FS Student Loan Lenders B-241263 December 1975 and found generally unsatisfactory conditions as early as November 1976. As the result of BAC’S and HEAF'S last reviews of FITCO in spring 1989, the two guaranty agencies began to terminate their relationship with FITCO. The two agencies found significant problems with FITCO'S opera- tions, including not paying the insurance premiums on loans it had made. As agreed with your office, we did not obtain written comments on this fact sheet. We did, however, discuss its contents with Department of Education program officials and incorporated their comments where appropriate. We are sending copies of this fact sheet to other congressional commit- tees, the Department of Education, and other interested parties. Should you wish to discuss its contents, please call me on (202) 275-1793. Other major contributors are listed in appendix V. Sincerely yours, Franklin Frazier Director, Education and Employment Issues Page 6 GAO/HUD-90488FS Student Loan Lenders , Contents Letter Appendix I 8 Description of the Differences Between the Loan Types Made Under the Stafford Student Loan Program Appendix II SelectedMilestones Detailing FITCO’s Activities Appendix III Additional Analysis of FITCO’s Remittance of Loan Origination Fees Appendix IV Chronology of Audits and Reviews Performed at FITCO Appendix V 16 Major Contributors to This Fact Sheet Related GAO Products 20 Tables * Table 1: Net Disbursements by Type of Loan for CSAC 3 and HEAF Page 6 GAO/HRDM-183FS Student Loan Lenders Content43 Table 2: Net Disbursements by Type of School for CSAC 3 and HEAF Table II. 1: Timeframe of Selected Events Concerning 9 FITCO Table III. 1: FITCO’s Interest Subsidy Billings With 12 Origination Fees for Loans It Originated (Lender Number 828374) Table 111.2:FITCO’s Interest Subsidy Billings for Loans 13 Processed by UES for FITCO (Lender Number 829977) Abbreviations CSAC California Student Aid Commission FITCO First Independent Trust Company GAO General Accounting Office HEAF Higher Education Assistance Foundation PLUS Parent Loans for Undergraduate Students SBD California State Banking Department SIS Supplemental Loans for Students UEZ.3 United Education and Software Page 7 GAO/HRLMO-183FS Student Loan Lenders Appendix I Description of the Differences Between the Loan Types Made Under the Stafford Student Loan PI-OgI-ZtIll The Stafford Student Loan Program consists of three types of loans. These loans differ somewhat in their terms and conditions. Stafford loans, formerly called guaranteed student loans, have the Stafford Loans largest volume of the three loan types (almost $10 billion in fiscal year 1989) and have been available since the program was created as part of the Higher Education Act of 1965. The loans are based on the student borrower’s financial needs. However, borrowers do not have to demon- strate their credit worthiness. Other key facts are: . Interest rates for new borrowers are currently 8 percent for the first 4 years of repayment and 10 percent after that. l Maximum loan limits are $17,250 for undergraduates and $54,760 for graduate students. l Borrowers generally have a 6-month grace period after leaving school before repayment begins. These loans enable parents to borrow funds for each dependent student PLUS Loans (those who are not generally responsible for their own financial sup- port) enrolled at a school. These loans started in 1981 and are not needs- based. Other key facts are: l Interest rates are variable and are determined once a year with a ceiling of 12 percent (11.49 percent is the rate now). l Maximum loan limits for each dependent are $4,000 per year to a total of $20,000. l Normally no grace period and payment of principal and interest gener- ally must begin within 60 days after the loan is dispersed. These loans are available to undergraduates who are generally respon- SLS Loans sible for their own financial support, and graduate students. These loans started in 1982 and, like PLUS loans, are not needs-based.’ Also, like PLUS loans, SW loans usually have the same interest rate and borrowing limits, and have no grace period. However, legislation passed in December 1989 restricted the availability of SIS loans for such factors as the school’s borrower-default rate and the borrower’s lack of a high- school diploma or a general equivalency degree. ‘SIS loans were part of the Auxiliary Loans to Assist Students program before 1986, and had terms and conditions similar to SIS; both are reported by the Department as SE3 loans. Page 8 GAO/IiRDSO-183Fs Student Loan Lenders Appendix II SelectedMilestones DetaZng FTlXO’s Activities Table 11.1:Timeframe of Selected Event8 Concerning FITCO Date Event Sept. 2,1975 FITCO began - operations. 19f9a CSAC started guaranteeing FITCO loans. Aug. 1986 HEAF started guaranteeing FITCO loans. Dec. 1986-Mar. 1987 FITCO set up computer services in 600 schools in 43 states to facilitate processing of loan applications. Jan. 15, 1987 Memo from Department of Education headquarters to region IX concerning FITCO’s late processing of refunds and returned checks and its possible unreasonable time for processing the checks. Jan. 26,1987 Region IX recommended a monitoring system to ensure FITCO promptly submitted interest billings and paid origination fees. Feb. 9, 1987 Region IX notified Department headquarters of its concern about FITCO’s practice of supplying schools with personal computers and problems with FITCO’s interest and special allowance pavments, and oriaination-fee billinas practices. Mar. 23, 1987 Department notified FITCO to cease providing schools with computers and software to process loans because these actions constituted an improper inducement. Aug. 5,1987 The Department notified FITCO that charging schools a computer rental fee of $18.75 per month resolved its concern with this issue. Apr. 14, 1988 FITCO paid the Department $13,328,471 for its 1987 loan origination fees. Mar. 3, 1989 FITCO had not been timely in paying insurance premiums to HEAF on thousands of loans. HEAF stated it was willing to allow FITCO a reasonable time to pay insurance premiums in order to reinstate loan guarantees that had been canceled. Mar. 6, 1989 HEAF notified the California Student Loan Finance Corporation (secondary market) that it may have purchased loans from FITCO that were not guaranteed because FITCO had not paid the insurance premiums. Apr. 21, 1989 CSAC notified FITCO that it planned to discontinue guaranteeing its loans. May 1989 The Department notified FITCO that, based on an audit, it owed about $1 .l million for the overpayment of interest and special allowance subsidy payments and an additional $4.4 million in loan oriqination fees. May I,1989 FITCO stopped making student loans. May 1,1989 HEAF notified FITCO that it would no longer guarantee its Stafford, SLS. or PLUS loans. May 51989 The California State Banking Department (SBD) notified FITCO that more capital would be needed to continue ooeratina. May lo,1989 A HEAF official stated that FITCO was inappropriately commingling school tuition refunds with monies used to make new loans or pav insurance premiums to HEAF. Y (continued) Page 9 GAO/IUUHl@183Fs Student Loan Lenders c , Appendix II Selected MIlestones Detailing FlTCD’s Activities Date Event May 11,1989 HEAF canceled conditional uarantees it previously issued on FITCO loans because of F ITCO’s nonpayment of insurance premiums. May 12,1989 HEAF filed suit against FITCO for failure to forward refunds to subsequent holders (secondary market lenders) of loans. May 19,1989 The Department notified HEAF that reinsurance coverage would be maintained for FITCO-originated loans, if FITCO or current holders of the loans would pay origination fees due. May 19,1989 SBD closed FITCO. May 31,1989 HEAF notified SBD that it intended to terminate its relationship with FITCO by not guaranteeing more loans. June 9, 1989 SBD, as liquidator of FITCO, wanted to settle the nonpayment of insurance premiums with HEAF. June 20,1989 HEAF rejected SBD’s offer to pay FITCO’s insurance premiums due to HEAF. Oct. 19, 1989 The Department filed its claim and supporting documentation with SBD. Jan. 12,199O The Department accepted SBD’s offer of $4.4 million in full satisfaction of all of FITCO’s unpaid origination fees. Jan. 16,199O The Department’s Office of Inspector General informed the Department that a consultant for SBD indicated that the claim against FITCO for unpaid origination fees needed to be changed if possible. It reported that FITCO owed origination fees of $5.5 million. Jan. 19, 1990 Department agreed to settle its claim against FITCO for the nonpayment of origination fees for $4.4 million. Mar. 20, 1990 Final agreement between the Department and SBD citing payment of $4.4 million to satisfy all of FITCO’s obligations. June 19, 1990 SBD filed civil lawsuit against former officers of FITCO. ‘A CSAC official could not provide GAO with the date that CSAC started guaranteeing student loans Page 10 GAO/HRD9@183PS Student Loan Lenders Appendix III Additional Analysis of FTlEO’s F&mittance of km Origination Fees When FITCO’S loan volume increased substantially in late 1986, the Department became concerned that FITCO’Scash flow problems might affect its timely payment of loan origination fees because the fees could amount to several million dollars each quarter. In January 1987, a region IX official recommended to Department headquarters that a mon- itoring system be established to assure that interest billings are sub- mitted promptly and origination fees paid. Department headquarters replied by suggesting that the regional official monitor FITCO’S filings by having FITCBsend him a copy of each form 799 when filed.1 This official could also confirm that the form 799 was even- tually processed by requesting copies from Department headquarters. In late 1987, CSACreviewers asked for the Department’s assistance in reviewing FITCO’S interest billing forms. In January 1988, two region IX reviewers went to FITCO, including the official who suggested setting up a monitoring system. They found that FITGO had not remitted to the Department its loan origination fees for any loans originated in 1987. The forms for the first three quarters of 1987 were filed in December 1987, but the Department returned them to FITCO because they were incomplete. Tables III. 1 and III.2 detail the form 799 history for loan origination fees for FITCO'S student loans. Table III.1 shows those origination fees for loans FITCO originated itself and covers the period June 1984 through March 1989. ‘FITCO filed two form 7998,one for loansit originated directly and anotherfor loansthat were originated on behalf of FITCOby United Educationand software. Page 11 GAO/HlUM&183Fs Student Loan Lenders Appendix III Additional Analysie of =0’s Remittance of Loan Origination Fees Table 111.1:FITCO’s Interest Subrldy Bllllngs With OtiginaUon Fees for Loans Date the Cumulative Date It Orlglnated (Lender Number 828374) Form 799 Department balance until Department for quarter processed Fees reported Department received ending form 799 and not offset was paid payment 06184 10/28/84 $38,595.99 $38,595.99 09184 11/28/84 133.433.05 172.029.04 2/20/85 12184 02/24/85 223,259.43 223,259.43 03185 04;28;85 3359336.77 558,596.20 06185 08/01/85 354,850.18 913,446.38 10/01/85 09185 02/23/86 520,108.94 520.108.94 3/19/86 12185 03/09/86 679,600.ll 679,600.11 03186 08/20/86 286,665.79 966,265.90 06186 12/31/86 233.479.52 1.199.745.42 09186 02/11/87 543,655.24 1,743,400.66 12186 07126187 1,547,042.48 3,290,443.14 l/17/88 03187 02/14/88 2,259,380.13 2,259,380.13 06187 02/14/88 3,413,841.54 5,673,221.67 09;87 02;14;88 4;860,694.25 10;533,915.92 12187 02/28/88 2,794,555.30 13,328,471.22 4/14/88 03188 11/27/88 2.252.481.82 2.252.481.82 06188 10/06/88 765,$61.46 3,018.443.28 09188 06/l 4189 799,181.13 3,817,624.41 - 12188 08/02/89 413,512.90 4,231,137.31 03189 07/10/89 (92,015.64) 4,139,121.67 In addition to originating loans itself, FITCO had an arrangement with a third party-United Education and Software (UES)~-to process loans on its behalf. The interest subsidy billings for these loans also were not filed on time. Table III.2 shows the billing history for FITCO loans processed by LIES,including their payment and nonpayment of origina- tion fees. 2UESis a private organizationthat operateda data systemthat handledloan servicing and that owns and operatesa group of private schools. Page 12 GAO/HRD-QO-lS3FS Student Loan Lenders Mditlonal Analyd~ of FITCO’e Remittance of Iann wtion Fees Tablo 111.2:FITCOQ Interert Subrldy Bllllnga for Loanr Procesred by UES for Date the Cumulative Date PITCO (Lender Number 829977) Form 799 Department balance until Department for quarter processed Fees reported Department received ending form 799 and not offset was paid payment 09104 12/17/86 $137.782.50 $137.782.50 12104 12/17/M 214,207.65 352,070.15 03105 12/17/86 237,807.65 589,877.80 06/05 12/17/06 218,790.ll 808,667.91 09ft35 12/17/06 81,325.80 889,993.71 12105 12/17/86 197,748.26 1,087,741.97 03106 12/17/06 218v443.54 1,306,185.51 06186 - 12/17/06 251,206.74 1,557,392.25 0/13/06 09186 12/17/06 134,364.98 1343364.98 4/30/s? 12186 05/10/07 196,988.93 196,988.93 03187 05/03/07 496.130.25 693.119.18 7/23/87 06187 05/19/00 545,145.70 545,145.70 09/07 05/19/08 718,551.51 545,145.70 7/18/00~ 12187 05/19/88 617,719.84 1,162,865.54 03h3a 06/05/08 242.335.69 1.405.201.23 06/00 01/05/09 ($1,134.76) 1,404,066.47 ‘FITCO only paid $718,551.51 on the July 18, 1988, payment instead of the full cumulative balance. FIT0 paid its origination fees in 1988, after the Department advised it to file subsequent reports on time and noted that its compliance would be closely monitored. However, a CSACreview in early 1989 revealed that FITCO had not filed its forms 799 for 1988 and estimated that FITCO owed the Department about $6.6 million in origination fees for loans originated in 1988. FITCH filed its forms 799 for loans originated in 1988 and 1989 but did not pay origination fees due. FITCO reported it owed $6.5 million in such fees-$4.1 million for loans it processed and $1.4 million for loans originated by the UES. The Department settled with SBD (as liquidator of FITCO)in March 1990 for $4.4 million on the outstanding origination fees. The agreement stated that the Department knew that FITCO owed origination fees that may have exceeded $6.5 million. The Department said that it agreed to the $4.4 million amount after con- sidering the litigation risk of pursuing the $6.5 million underpayment (i.e., the probability of prevailing), the resource drain on the federal Page 13 GAO/HRD+O-lS3FY4 Student Loan Lenders Appendix III Additional Analysis of PITCO’s Remittance of Loan Origination Fees government needed to pursue the litigation, and how long it would take to receive the $6.6 million. In addition, the Department indicated that it had already filed its claim with SBD for $4.4 million, and that the dead- line for amending that claim had expired. Page 14 GAO/H&D9O-183Fs Student Loan Lenders I Appelidix IV Chronology of Audits md Reviews Performed at lTlK0 Review number Review date(s) Who conducted the review 1 Dec. 16,1975 State Banking Department - 2 Nov. 5,1976 State Banking Department 3 Dec. 9,1977 State Banking Department 4 May 31,1978 State Banking Department 5 Nov. 30,1979 State Banking Department 6 Aug. 29,198O State Banking Department 7 Feb. 27,198l Department of Education - 8 Mar. 31, 1981 State Banking Department 9 Feb. 24-26, 1982 Department of Education 70 Mar. 31, 1983 State Banking Department -11 June 27-29,1984 California Student Aid Commission 12 July 27, 1984 Department of Education 13 Aug. 31, 1985 State Banking Department 14 Mar. 3-7, 1986 California Student Aid Commission 15 Nov. 17,1986 State Banking Department 16 Nov. 19, 1987- California Student Aid Commission Jan. 21,1988 17 Jan. 27,1988 Department of Education/ California Student Aid Commission 18 Mar. 1987-May 1988 Department of Education 19 Mar. 31, 1988 State Banking Department 20 Feb. 27-Mar. 24, 1989 California Student Aid Commission 21 Apr. 10-20, 1989 Higher Education Assistance Foundation Y Page 15 GAO/HUD-W183FS Student Loan Lenders Appendix V Major Contributors to This Fact Sheet * Joseph J. Eglin, Assistant Director, (202) 401-8623 Human Resources Christopher C. Crissman, Evaluator-in-Charge Division, Washington, D.C. Revae E. Steinman, Regional Assignment Manager Los Angeles Regional Cheryl L. Gordon, Site Senior Office Carla D. Brown, Evaluator Page 18 GAO/HRlMWl83F8 Student Loan Lendem Page 17 GA0/HRD904&3FS Student Loan Lenders Page 18 GAO/IUfD9O-1S3FS Student Loan Lenders Page 19 GAO/IZRLM94!33FS Student Loan Lenders Related GAO Products Supplemental Student Loans: Legislative Changes Have Sharply Reduced Loan Volume (GAOIHRD-90-149FS,Aug. 3, 1990) Financial Problems in the Stafford Student Loan Program (GAO/T- HRD-90-62,July 27, 1990) Guaranteed Student Loans: Credit Bureau Reporting Practices by Guar- - anty Agencies and Lenders (GAO~HRD-SO-71~~,Apr. 9, 1990) Supplemental Student Loans: Who Are the Largest Lenders? (GAO/ HRD-90-72~8,Feb. 21, 1990) GAO Views on the Stafford Student Loan Program (GAO/T-HRD-90-13, Feb. 20,199O) Supplemental Student Loans: Who Borrows and Who Defaults (GAO/ HRD90-33FS, Oct. 17, 1989) Guaranteed Student Loans: Analysis of Student Default Rates at 7,800 Postsecondary Schools (GAO/HRD-89-63BR, July 5, 1989) Defaulted Student Loans: Preliminary Analysis of Student Loan Bor- rowers and Defaulters (GAO~HRD-8%112BR,June 14, 1988) GAO'S Views on the Default Task Force’s Recommendations for Reducing Default Costs in the Guaranteed Student Loan Program (GAO/T-HRD-88-7, Feb. 2, 1988) Guaranteed Student Loans: Potential Default and Cost Reduction Options (GAO/HRD-~~-~~BR,Jan. 7, 1988) Guaranteed Student Loans: Analysis of Insurance Premiums Charged by Guaranty Agencies (GAO/HRD-88-16BR, Oct. 7, 1987) Guaranteed Student Loans: Legislative and Regulatory Changes Needed to Reduce Default Costs (GAO/HRD-87-76, Sept. 30, 1987) Defaulted Student Loans: Private Lender Collection Efforts Often Inade- quate (GAOIHRD-87-48, Aug. 20, 1987) Defaulted Student Loans: Guaranty Agencies’ Collection Practices and Procedures (GAO/HRD-~~-~~~BR,July 17, 1986) (104660) Page20 GAO/HRD90-183Fs Student Loan Lenders Ordering Information The first, five copies of each GAO report are free. Addit.ional copies are $2 each. Orders should be sent to the following address, accom- pitnithd by a check or money order made out to the Superint~~l<It~nt, of Documents, whtw necessary. Orders for 100 or more copies to be mailed to a single address are discounted 25 percent.. IIS. General Accounting Office PA). Box 6018 <;aith(~rsburg, MD 20877 Orders may also be placed by calling (202) 275-6241. 1 Permit, No. (;lOO 1 Ol‘l‘i(3al hsitwss
Student Loan Lenders: Information on the Activities of the First Independent Trust Company
Published by the Government Accountability Office on 1990-09-25.
Below is a raw (and likely hideous) rendition of the original report. (PDF)