[House Hearing, 110 Congress]
[From the U.S. Government Publishing Office]
ACCOUNTABILITY FOR THE DEPARTMENT OF
EDUCATION'S OVERSIGHT OF STUDENT LOANS
AND THE READING FIRST PROGRAM
=======================================================================
HEARING
before the
COMMITTEE ON
EDUCATION AND LABOR
U.S. House of Representatives
ONE HUNDRED TENTH CONGRESS
FIRST SESSION
__________
HEARING HELD IN WASHINGTON, DC, MAY 10, 2007
__________
Serial No. 110-32
__________
Printed for the use of the Committee on Education and Labor
Available on the Internet:
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COMMITTEE ON EDUCATION AND LABOR
GEORGE MILLER, California, Chairman
Dale E. Kildee, Michigan, Vice Howard P. ``Buck'' McKeon,
Chairman California,
Donald M. Payne, New Jersey Ranking Minority Member
Robert E. Andrews, New Jersey Thomas E. Petri, Wisconsin
Robert C. ``Bobby'' Scott, Virginia Peter Hoekstra, Michigan
Lynn C. Woolsey, California Michael N. Castle, Delaware
Ruben Hinojosa, Texas Mark E. Souder, Indiana
Carolyn McCarthy, New York Vernon J. Ehlers, Michigan
John F. Tierney, Massachusetts Judy Biggert, Illinois
Dennis J. Kucinich, Ohio Todd Russell Platts, Pennsylvania
David Wu, Oregon Ric Keller, Florida
Rush D. Holt, New Jersey Joe Wilson, South Carolina
Susan A. Davis, California John Kline, Minnesota
Danny K. Davis, Illinois Cathy McMorris Rodgers, Washington
Raul M. Grijalva, Arizona Kenny Marchant, Texas
Timothy H. Bishop, New York Tom Price, Georgia
Linda T. Sanchez, California Luis G. Fortuno, Puerto Rico
John P. Sarbanes, Maryland Charles W. Boustany, Jr.,
Joe Sestak, Pennsylvania Louisiana
David Loebsack, Iowa Virginia Foxx, North Carolina
Mazie Hirono, Hawaii John R. ``Randy'' Kuhl, Jr., New
Jason Altmire, Pennsylvania York
John A. Yarmuth, Kentucky Rob Bishop, Utah
Phil Hare, Illinois David Davis, Tennessee
Yvette D. Clarke, New York Timothy Walberg, Michigan
Joe Courtney, Connecticut Dean Heller, Nevada
Carol Shea-Porter, New Hampshire
Mark Zuckerman, Staff Director
Vic Klatt, Minority Staff Director
C O N T E N T S
----------
Page
Hearing held on May 10, 2007..................................... 1
Statement of Members:
McKeon, Hon. Howard P. ``Buck,'' Senior Republican Member,
Committee on Education and Labor........................... 6
Prepared statement of.................................... 7
Miller, Hon. George, Chairman, Committee on Education and
Labor...................................................... 2
Prepared statement of.................................... 4
Additional submissions for the record:
Letter from Norman C. Francis, president, Xavier
University, submitted by Hon. Charlie Melancon, a
Representative in Congress from the State of
Louisiana.......................................... 56
Questions for the record, May 16, 2007, submitted to
Secretary Spellings................................ 59
Responses to May 16, 2007, questions................. 63
Questions for the record, May 23, 2007, submitted to
Secretary Spellings................................ 75
Responses to May 23, 2007, questions................. 76
Letter from Thomas C. Healy, vice president for
government relations, Indiana University........... 79
Statement of Witnesses:
Spellings, Hon. Margaret, Secretary, U.S. Department of
Education.................................................. 9
Prepared statement of.................................... 12
Additional submissions for the record:
Higher Education Timeline............................ 80
Delivery Process/Student View--FY 2006............... 81
Letters to Puerto Rico Secretary of Education, dated
March 7 and 21, 2007............................... 82
2006 9.5 SAP Summary................................. 86
2005 9.5 SAP Summary................................. 88
2004 9.5 SAP Summary................................. 90
2003 9.5 SAP Summary................................. 92
2002 9.5 SAP Summary................................. 94
2001 9.5 SAP Summary................................. 96
FY 2006 SAP Summary for Both Taxable and Tax Exempt
by Lender.......................................... 99
ACCOUNTABILITY FOR THE DEPARTMENT OF
EDUCATION'S OVERSIGHT OF STUDENT
LOANS AND THE READING FIRST PROGRAM
----------
Thursday, May 10, 2007
U.S. House of Representatives
Committee on Education and Labor
Washington, DC
----------
The committee met, pursuant to call, at 10:31 a.m., in Room
2175, Rayburn House Office Building, Hon. George Miller
[chairman of the committee] presiding.
Present: Representatives Miller, Kildee, Payne, Andrews,
Hinojosa, McCarthy, Tierney, Kucinich, Wu, Holt, Davis of
California, Davis of Illinois, Bishop of New York, Sarbanes,
Sestak, Loebsack, Altmire, Yarmuth, Hare, Shea-Porter, McKeon,
Petri, Castle, Ehlers, Biggert, Platts, Keller, Wilson, Kline,
Marchant, Fortuno, Foxx, Davis of Tennessee, and Walberg.
Staff present: Aaron Albright, Press Secretary; Tylease
Alli, Hearing Clerk; Jeff Appel, GAO Detailee; Alice Cain,
Senior Education Policy Advisor (K-12); Sarah Dyson,
Administrative Assistant, Oversight; Denise Forte, Director of
Education Policy; Gabriella Gomez, Senior Education Policy
Advisor (Higher Education); Ryan Holden, Senior Investigator,
Oversight; Lloyd Horwich, Policy Advisor for Subcommittee on
Early Childhood, Elementary and Secretary Education; Lamont
Ivey, Staff Assistant, Education; Thomas Kiley, Communications
Director; Ann-Frances Lambert, Administrative Assistant to
Director of Education Policy; Ricardo Martinez, Policy Advisor
for Subcommittee on Higher Education, Lifelong Learning and
Competitiveness; Stephanie Moore, General Counsel; Alex Nock,
Deputy Staff Director; Joe Novotny, Chief Clerk; Rachel
Racusen, Deputy Communications Director; Julie Radocchia,
Education Policy Advisor; Michael Zola, Chief Investigative
Counsel, Oversight; Mark Zuckerman, Staff Director; James
Bergeron, Minority Deputy Director of Education and Human
Services Policy; Robert Borden, Minority General Counsel;
Kathryn Bruns, Minority Legislative Assistant; Steve Forde,
Minority Communications Director; Taylor Hansen, Minority
Legislative Assistant; Amy Raaf Jones, Minority Professional
Staff Member; Victor Klatt, Minority Staff Director; Lindsey
Mask, Minority Director of Outreach; Linda Stevens, Minority
Chief Clerk/Assistant to the General Counsel; and Brad Thomas,
Minority Professional Staff Member.
Chairman Miller [presiding]. Good morning. A quorum being
present, the hearing of the Committee on Education and Labor
on, ``Accountability in the Department of Education's Oversight
of the Student Loans and the Reading First Program,'' will come
to order.
I want to welcome everyone to today's hearing on,
``Accountability in the Department of Education's Oversight of
Student Loans and the Reading First Program.''
I would like to thank Secretary Spellings for taking time
to testify before us today, and we have a lot of ground to
cover.
For several months now, investigations by this committee
and elsewhere at the state and federal level have produced a
stream of troubling revelations about unethical practices in
the student loan industry.
We now know that for the last several years it has been a
common practice for lenders to offer gifts and other
inducements to college financial aid officers and others in
exchange for high loan volume.
At a $74,000 cruise paid for by JP Morgan Chase in 2005,
student financial aid officers dined on five spice quail and
filet mignon. In one particularly egregious example of an
apparent quid-pro-quo, Indiana University essentially accepted
a $3 million line of credit from Sallie Mae in 2004, and later
dropped out of the government's Direct Loan Program.
We know that lenders have inappropriately accessed the
National Student Loan Database in order to find private
information about borrowers for marketing purposes. We know
that lenders abused federal law to reap questionable windfalls,
costing taxpayers hundreds of millions of dollars in
overpayments. We know that lenders designed marketing materials
to be deliberately misleading by making them look like official
government correspondence in order to trick borrowers into
responding.
All of these practices come at the expense of students and
their families. Lenders have spent millions of dollars to
violate the law, and their illegal actions have cost families
untold millions at a time of soaring college costs, and this is
an outrage. These practices also carry a high cost for the
federal taxpayers at a time of tight budgets and huge budget
deficits, which is another outrage.
The federal student loan programs must be managed in the
best interests of students, parents and taxpayers. Doing so is
the responsibility of the Department of Education. I agree with
New York Attorney General Andrew Cuomo that testified before
this committee last month when he said that the department had
been ``asleep at the switch'' when it comes to overseeing the
federal student loan programs. In fact, Mr. Cuomo might have
been too polite.
Although I applaud the proposal of the administration's
2008 budget to reduce some of the excessive subsidies made to
lenders--subsidies that essentially finance bad lender
behavior--the administration has otherwise failed to provide
meaningful oversight on the student loan industry.
In 2001, the Bush administration scrapped plans to issue a
``Dear Colleague'' letter to schools and lenders instructing
them to end the practice of trading gifts and other inducements
for student loan volume.
In 2003, the administration ignored an alert memorandum
from the department's inspector general urging similar action.
In January 2007, the administration allowed nearly 300
million taxpayer dollars to walk out the door because of an
antiquated loophole that allows lenders to bill the government
at a higher rate of interest. The department knew about this
``9.5 percent loophole'' for years but failed to close it.
Over the last several months, New York Attorney General
Cuomo has led the way in the investigations into the student
loan industry, and many other state attorneys general have
begun their own investigations. But the Department of Education
has been conspicuously missing from action.
What makes all of these even more troubling is that many
Education Department officials who have worked directly on the
student loan programs appear, according to press accounts, to
have their own conflicts of interest.
Some have owned stock in student lending companies. Others
are part of a revolving door between the industry and the
department. And I am pleased that the department's inspector
general has agreed to my request to investigate these conflicts
of interest. We need to know whether these conflicts help
explain the department's incredible oversight failures.
The work of the Office of the Inspector General brings us
to the second topic of today's hearing: Reading First, a
program that was rife with conflicts of interest that the
inspector general exposed in 2006.
In a committee hearing last month, we heard testimony from
three former members of a committee hand-picked by the
Education Department to review products that educators use to
assess children's progress in learning to read.
All three of those former committee members--Roland Good,
Ed Kame'enui and Deborah Simmons--profited either directly or
indirectly from the sale of a specific reading product that
states were inappropriately pressured to use if they wanted to
get federal grant money.
We learned from the education inspector general about his
referrals to the Justice Department regarding potential
criminal misconduct by Reading First officials.
We also heard how the former director of Reading First,
Chris Doherty, had improperly bullied states into using
specific reading products. Mr. Doherty's wife worked for an
organization linked to those products, a fact that Mr. Doherty
repeatedly failed to disclose on financial forms he filed while
an employee of the Education Department.
Here again we have to ask why the White House and the
Department of Education allowed this mismanagement to continue
unchecked. Mr. Doherty, in his testimony, provided one
troubling explanation: that he was just following the
department's orders. Mr. Doherty testified, ``I respected the
chain of command at the Department of Education, faithfully
executing orders from my superiors, which I never had reason to
question, and keeping superiors informed about the program.''
When I look at the whole body of evidence that has been
amassed about both the student loan and Reading First programs,
it is clear that, at a minimum, that the Education Department's
oversight failures have been monumental.
But many people, including me, are wondering if that is the
end of the story. Was this simply laziness? Was this
incompetence? Was it a deliberate decision to look the other
way while these things happened? Or was it a failing more
sinister than that? These are the questions that we are hoping
to bring to answer today.
By an overwhelming bipartisan vote of 414 to three, the
House yesterday approved legislation, sponsored by Mr. McKeon
and myself, the Student Loan Sunshine Act, to clean up the
student loan industry. We are considering proposals to
eliminate conflicts of interest from every program within the
Department of Education, including Reading First.
I am hopeful that the testimony we will receive and the
discussion we will have today will assist us in these efforts.
We must make sure that problems like the ones I have described
do not repeat themselves. Students, children, parents,
educators and taxpayers deserve to know that the government is
working on their behalf, not for the financial benefit of a
handful of well-connected individuals and organizations.
And at this time, I would like to recognize the gentleman
from California, the senior Republican of the committee, Mr.
McKeon.
Prepared Statement of Hon. George Miller, Chairman, Committee on
Education and Labor
Good morning. Welcome to today's hearing on ``Accountability for
the Department of Education's Oversight of Student Loans and the
Reading First Program.''
I'd like to thank Secretary Spellings for taking the time to
testify before us today. We have a lot of ground to cover.
For several months now, investigations by this committee and
elsewhere at the state and federal level have produced a stream of
troubling revelations about unethical practices in the student loan
industry.
We now know that, in the last several years, it has been common
practice for lenders to offer gifts and other inducements to college
financial aid officers in exchange for higher loan volume.
At a $74,000 cruise paid for by JP Morgan Chase in 2005, student
financial aid officers dined on five spice quail and filet mignon.
In one particularly egregious example of an apparent quid-pro-quo,
Indiana University essentially accepted a $3 million line of credit
from Sallie Mae in 2004, and later dropped out of the government's
Direct Loan program.
We know that lenders have inappropriately accessed the National
Student Loan Database in order to find private information about
borrowers for marketing purposes.
We know that lenders abused federal law to reap questionable
windfalls, costing taxpayers hundreds of millions of dollars in
overpayments.
All of these practices come at the expense of students and their
families.
Lenders have spent millions of dollars to violate the law, and
their illegal actions have cost families untold millions. At a time of
soaring college costs, this is an outrage.
These practices also carry a high cost for federal taxpayers. At a
time of tight budgets and huge budget deficits, this too is an outrage.
The federal student loan programs must be managed in the best
interests of students, parents, and taxpayers. Doing so is the
responsibility of the U.S. Department of Education.
I agree with New York Attorney General Andrew Cuomo, who testified
before this committee last month and said that the Department has been
'asleep at the switch' when it comes to overseeing the federal student
loan programs.
In fact, Mr. Cuomo might have been too polite.
Although I applaud the proposal in the administration's 2008 budget
to reduce some of the excessive subsidies made to lenders--subsidies
that essentially finance bad lender behavior--the administration has
otherwise failed to provide meaningful oversight of the student loan
industry.
In 2001, the Bush administration scrapped plans to issue a Dear
Colleague letter to schools and lenders instructing them to end the
practice of trading gifts and other inducements for student loan
volume.
In 2003, the administration ignored an alert memorandum from the
Department's Inspector General urging similar action.
In January 2007, the administration allowed nearly 300 million
taxpayer dollars to walk out the door because of an antiquated loophole
that allows lenders to bill the government at a higher rate of
interest. The Department knew about this ``9.5 percent loophole'' for
years--but failed to close it.
Over the last several months, New York Attorney General Cuomo has
led the way with investigations into the student loan industry, and
many other state attorneys general have begun their own investigations.
But the U.S. Department of Education has been conspicuously missing in
action.
What makes all of this even more troubling is that many Education
Department officials who have worked directly on the student loan
programs appear, according to press accounts, to have their own
conflicts of interest.
Some have owned stock in student lending companies. Others are part
of a revolving door between the industry and the Department. I am
pleased that the Department's Inspector General has agreed to my
request to investigate these conflicts of interest. We need to know
whether these conflicts help explain the Department's incredible
oversight failures.
The work of the Office of the Inspector General brings us to the
second topic of today's hearing: Reading First, a program that has been
rife with conflicts of interest that the Inspector General exposed in
September 2006.
In a committee hearing last month, we heard testimony from three
former members of a committee hand-picked by the Education Department
to review products that educators use to assess children's progress in
learning to read.
All three of those former committee members--Roland Good, Ed
Kame'enui, and Deborah Simmons--profited either directly or indirectly
from the sale of a specific reading product that states were
inappropriately pressured to use if they wanted to get federal grant
money.
We learned from the Education Inspector General about his referrals
to the Department of Justice regarding potentially criminal misconduct
by Reading First officials.
We also heard how the former Director of Reading First, Chris
Doherty, had improperly bullied states into using specific reading
products. Mr. Doherty's wife worked for an organization linked to those
products, a fact that Mr. Doherty repeatedly failed to disclose on
financial forms he filed while an employee of the Education Department.
Here again, we have to ask why the White House and the Department
of Education allowed this mismanagement to continue unchecked. Mr.
Doherty, in his testimony, provided one troubling explanation: that he
was just following the Department's orders.
Mr. Doherty testified: ``I respected the chain of command at the
Department of Education, faithfully executing orders from superiors,
which I never had reason to question, and keeping superiors informed
about the program.''
When I look at the whole body of evidence that has been amassed
about both the student loan and Reading First programs, it is clear
that--at a minimum--the Education Department's oversight failures have
been monumental.
But many people, including me, are wondering if that's the end of
the story. Was this simply laziness? Was this incompetence? Was it a
deliberate decision to look the other way while these things happened?
Or was it a failing more sinister than that? These are the questions
that I'm hoping we will begin to answer today.
By an overwhelming vote of 414-3, the House yesterday approved
legislation--the Student Loan Sunshine Act--to clean up the student
loan industry. We are considering proposals to eliminate conflicts of
interest from every program within the Department of Education,
including Reading First.
I am hopeful that the testimony we will receive and the discussion
we will have today will assist us in these efforts.
We must make sure that problems like the ones I have described do
not repeat themselves.
Students, children, parents, educators, and taxpayers deserve to
know that the government is working on their behalf--not for the
financial benefit of a handful of well-connected individuals and
organizations.
I now recognize the gentleman from California, the senior
Republican of the Committee, Mr. McKeon.
Thank you.
______
Mr. McKeon. Thank you, Mr. Chairman, for convening today's
hearing.
And, Madam Secretary, thank you for joining us, and welcome
back to our committee. I look forward to your testimony and our
discussion about the steps the department and Congress are
taking to reaffirm trust in our nation's financial aid system
as well as in Reading First.
Oversight is a healthy congressional practice. It has led
to some key reforms within the Washington bureaucracy, and I
look forward to continuing as a partner in such an effort.
Similarly, oversight within the Department of Education is
certainly nothing new. During the late 1990s, as many of us on
this panel remember, the department failed a series of internal
audits. An estimated $450 million was lost to waste and fraud.
Money intended for South Dakota schools, for example, was
diverted to buy real estate, and a massive theft ring started
by a department employee led to federal charges against 19
people.
After years of work to clean up this mess, in 2003, the
Bush administration announced the department's first
independent clean audit in years, and they have followed suit
each year since. More recently, in 2005, our federal student
aid programs were removed from the Government Accountability
Office's high risk designation list after 15 years.
My colleagues, this turnaround didn't happen by accident,
and I am confident the department will continue to be a partner
in addressing the challenges before us.
As we continue with our oversight of the department, I am
compelled to express a few concerns to help lay the groundwork
for this hearing.
First, I am often puzzled and, frankly, concerned by claims
that men and women with a deep understanding of a particular
policy area should have no role to play in an agency that deals
each day with matters of that very same area of policy.
Chairman Miller, you and I have a deep interest and, as a
result, a deep background with regard to education and labor
issues. That is why we are sitting in these seats after all. To
argue that our background and depth of knowledge taints us and
should bar us from legislating on these matters is not
sensible.
The same holds true, in my opinion, with regard to our
federal agencies. This was the case in the Clinton
administration when so-called industry insiders staffed the
Department of Education. Nothing was wrong with it then;
likewise, nothing is wrong with it now.
Secondly, and I noted this on the floor yesterday when we
considered the bipartisan Student Loan Sunshine Act, we need to
keep in mind the fact that the vast majority of the men and
women involved in our nation's financial aid and Reading First
programs are hardworking, well-intentioned public servants. If
we broadly condemn then, including the vast majority who do
exceptional work, we do so at our own peril and risk
undermining public confidence in student aid programs and a
Reading First Program that, by all accounts, are working well
for millions of American students and their families.
And, finally, I believe oversight should lead to action,
not merely headlines. Overzealous oversight all too often
triggers overly broad requests for information that can
distract an agency from serving the needs of those who depend
on it. In this instance, that is student, parents and
taxpayers.
Similarly, we must be cautious not to engage in an endless
partisan fishing expedition that after awhile runs the risk of
becoming a witch hunt instead of a serious pursuit of changes
to public policy.
With regard to serious changes to public policy, Mr.
Chairman, I believe our bipartisan vote yesterday on the
Student Loan Sunshine Act has gotten us off to a good start.
Through that bill, we have taken key steps to ensure our
financial aid system continues to serve the needs of the
students who depend on it for a chance at a college education.
Madam Secretary, I was pleased to read in your prepared
testimony that your Student Loan Task Force has made a number
of recommendations that will now be incorporated into the
regulatory process.
Going beyond these recommendations, I am hopeful that soon
you will reopen the National Student Loan Data System so
student lenders again will be able to fully participate in this
system and provide the best possible service to families
counting on a student loan to attend college this coming fall
and graduates planning to consolidate their loan prior to July
1 when variable loan interest rates are expected to increase on
existing loans.
I think this is very important that this be done quickly,
because we are at a crucial time for these prospective students
and graduates.
On Reading First, Madam Secretary, I applaud the immediate
administrative changes you have implemented in light of the
inspector general's report.
Mr. Chairman, as you know, Mr. Castle and I introduced
legislation several weeks ago to codify the inspector general's
recommendations. We all are in agreement that Reading First is
a successful and worthy program. Now we must take the
initiative to change the law accordingly to ensure past
instances of mismanagement never repeat themselves again.
Mr. Castle's and my bill will do that, and I urge its
speedy passage in committee.
Once again, Madam Secretary, I thank you for joining us
today. I look forward to your testimony and our discussion.
And, Chairman Miller, I look forward to a productive
hearing that will point us in the direction of real issues,
real action on the two important issues before us today.
Prepared Statement of Hon. Howard P. ``Buck'' McKeon, Senior Republican
Member, Committee on Education and Labor
Thank you, Mr. Chairman, for convening today's hearing. And Madam
Secretary, I thank you for joining us and welcome you back to our
Committee. I look forward to your testimony and our discussion about
the steps the Department and Congress are taking to reaffirm trust in
our nation's financial aid system, as well as Reading First.
Oversight is a healthy congressional practice. It has led to some
key reforms within the Washington bureaucracy, and I look forward to
continuing as a partner in such an effort.
Similarly, oversight within the Department of Education is
certainly nothing new. During the late 1990s, as many of us on this
panel remember, the Department failed a series of internal audits. An
estimated $450 million was lost to waste and fraud. Money intended for
South Dakota schools, for example, was diverted to buy real estate and
new cars; more than $1 million was lost to false overtime payments; and
a massive theft ring, started by a Department employee, led to federal
charges against 19 people. After years of work to clean up this mess,
in 2003, the Bush Administration announced the Department's first
independent, clean audit in years. And they have followed suit each
year since. More recently, in 2005, our federal student aid programs
were removed from the Government Accountability Office's High-Risk
designation list after 15 years. My colleagues, this turnaround didn't
happen by accident, and I am confident the Department will continue to
be a partner in addressing the challenges before us.
As we continue with our oversight of the Department, I am compelled
to express a few concerns to help lay the groundwork for this hearing.
First, I'm often puzzled and, frankly, concerned by claims that men and
women with a deep understanding of a particular policy area have no
role to play in an agency that deals each day with matters of that very
same area of policy. Chairman Miller, you and I have a deep interest--
and, as a result--a deep background with regard to education and labor
issues. That's why we're sitting in these seats, after all. To argue
that our background and depth of knowledge taints us and should bar us
from legislating on these matters is not sensible. The same holds true,
in my opinion, with regard to our federal agencies. This was the case
in the Clinton Administration, when so-called ``industry insiders''
staffed the Department of Education, and nothing was wrong with it
then. Likewise, nothing is wrong with it now.
Secondly--and I noted this on the floor yesterday when we
considered the bipartisan Student Loan Sunshine Act--we need to keep in
mind the fact that the vast majority of the men and women involved in
our nation's financial aid and Reading First programs are hard-working,
well-intentioned public servants. If we broadly condemn them, including
the vast majority who do exceptional work, we do so at our own peril
and risk undermining public confidence in student aid programs and a
Reading First program that--by all accounts--are working well for
millions of American students and their families.
And finally, I believe oversight should lead to action, not merely
headlines. Overzealous oversight all too often triggers overly-broad
requests for information that can distract an agency from serving the
needs of those who depend on it. In this instance, that's students,
parents, and taxpayers. Similarly, we must be cautious not to engage in
an endless, partisan fishing expedition that--after a while--runs the
risk of becoming a witch hunt instead of a serious pursuit of changes
to public policy.
With regard to serious changes to public policy, Mr. Chairman, I
believe our bipartisan vote yesterday on the Student Loan Sunshine Act
has gotten us off to a great start. Through that bill, we have taken
key steps to ensure our financial aid system continues to serve the
needs of the students who depend on it for a chance at a college
education. Madam Secretary, I was pleased to read in your prepared
testimony that your student loan task force has made a number of
recommendations that will now be incorporated into the regulatory
process. Going beyond these recommendations, I am hopeful that soon you
will re-open the National Student Loan Data System so student lenders
again will be able to fully participate in the system and provide the
best possible service to families counting on a student loan to attend
college this coming fall and to graduates planning to consolidate their
loans prior to July 1st, when variable interest rates are expected to
increase for existing loans.
On Reading First, Madam Secretary, I applaud the immediate
administrative changes you have implemented in light of the Inspector
General's reports. Mr. Chairman, as you know, Mr. Castle and I
introduced legislation several weeks ago to codify the Inspector
General's recommendations. We all are in agreement that Reading First
is a successful and worthy program. Now, we must take the initiative to
change the law accordingly to ensure past instances of mismanagement
never repeat themselves again. Mr. Castle's and my bill will do that,
and I urge its speedy passage in Committee.
Once again, Madam Secretary, I thank you for joining us today. I
look forward to your testimony and our discussion. And Chairman Miller,
I look forward to a productive hearing that will point us in the
direction of real action on the two important issues before us today.
______
Chairman Miller. I thank the gentleman for his statement.
Without objection, all members will have 14 days to submit
additional materials or questions for the hearing record.
Before proceeding to introduce our witness, the secretary,
let me lay out the process we will follow in this investigative
hearing.
We will begin with a 10-minute statement by Secretary
Spellings. To ensure that we have a full opportunity to flesh
out relevant facts for the record, I am exercising my
prerogative as chair, pursuant to Rule 2(b) to extend the 5-
minute rule for myself and Mr. McKeon.
Following Secretary Spelling's testimony, Mr. McKeon and I
will each engage in a 20-minute round of questioning, after
which other members will participate under the 5-minute rule.
I would also alert the members that I think we are
expecting a series of votes here, I am told five votes, which
may provide a considerable interruption in the hearing rather
quickly.
But, clearly, I believe we will have time, Madam Secretary,
for your testimony at a pace in which you will be comfortable
delivering it.
Margaret Spellings is the U.S. secretary of education.
Prior to being appointed to that position in January 2005, Ms.
Spellings served as President Bush's assistant for domestic
policy where she helped develop the No Child Left Behind law
and other education policies.
Additionally, she served for 6 years as President Bush's
senior education advisor, developing and implementing then
Governor Bush's education reforms and policies in the state of
Texas.
And during her stint, certainly, as secretary, she has been
very helpful to this committee as we have dealt with the
implementation of No Child Left Behind.
And we appreciate that, and we look forward to your
testimony. And thank you for making this time available.
STATEMENT OF HON. MARGARET SPELLINGS, SECRETARY, U.S.
DEPARTMENT OF EDUCATION
Secretary Spellings. Thank you, Mr. Chairman and members. I
very much appreciate this opportunity to set the record
straight on my department's oversight of college student aid
and the Reading First Program.
Federal student aid is crying out for reform. The system is
redundant, it is Byzantine and it is broken. In fact, it is
often more difficult for students to get aid than it is for bad
actors to game the system.
For example, throughout the 1990s, millions of dollars
meant to help families foot the bill for college were subject
to waste, fraud and abuse. Since President Bush took office, we
have worked hard to clean up this system.
Today, the majority of schools and lenders are doing the
right thing, but when the public's trust is violated, my
department has, and will, act.
For example, since last August, I have been working to
address urgent issued, like preferred lender lists and
inducements through the rulemaking process that you set up by
law. I invited this committee and its counterpart in the Senate
to suggest people to join this process.
At that time, Mr. Chairman, you and other members of this
committee sent me a letter requesting that I delay further
action until Congress could act. I appreciate very much the
fact that yesterday the House of Representatives took an
important first step in this process, but in the absence of
completed congressional action, it has been my duty to expedite
reform.
So in December, I convened representatives from student
groups, institutions and the lending community, as is required
to fully represent all stakeholders, and asked them to look at
ways to make the system more transparent and easier to use for
millions of students and families.
When the committee failed to reach consensus last month, I
immediately assembled an internal task force to work on these
key issues. They reported to me yesterday with recommendations
to end unethical practices, put students' needs first and
maintain trust and integrity throughout the system.
The task force recommended new plans to inject more choice,
competition and transparency into federal student aid. These
plans will ensure every borrower has the right to choose any
lender and require that if a school has a preferred lender
list, it must disclose how and why lenders are chosen. It must
include a minimum of three unaffiliated lenders, and it must
not favor some students more than others.
In addition, we have strengthened longstanding guidance on
what is legal and what is not with regard to inducements. This
includes a ban on gifts and steps to limit deceptive marketing
by lenders. I will work to release draft regulations to be
printed in the Federal Register by the end of this month. Even
if and when a law is passed, I will have jumpstarted the
regulatory process which would ordinarily be just beginning its
18th plus month timeline.
There is more work ahead, of course, but I can't do it
alone. We must work together to change existing law. The
opportunity to enact critical reform has come and gone since
2003 when the Higher Education Act became eligible for renewal.
Students deserve action now.
But let me be clear: If we limit our efforts to lending
practices without addressing the interrelated nature of cost,
financing, quality and accessibility in higher education, we
are only treating the symptoms instead of finding the cure.
We all know that federal student aid has failed to keep up
with dramatic changes in higher education, like soaring tuition
costs and a lack of transparency that makes oversight and real
consumer choice more difficult, let alone the rising demands of
our knowledge economy that have caused enrollment to nearly
triple over the last 25 years while costs have increased nearly
400 percent in that same time period.
That is why, shortly after becoming secretary 2 years ago,
I appointed a commission to make higher education more
responsive to the needs of students, parents, educators and the
business community. That commission found that when it comes to
controlling costs we, at the federal level, certainly have a
role to play. Currently, there are 20 federal programs aiding
students and more than 200 federal laws governing higher
education--layer upon layer of complexity and inefficiency.
My department oversees federal student loans. Private
loans, which have lately been the focus of so much attention,
are overseen by other agencies, like the FTC, the FDIC, the SEC
and the Federal Reserve. Therefore, I am convening the chairs
of all these relevant agencies to coordinate a government-wide
endeavor to end student loan abuse no matter where it occurs.
Mr. Chairman, I invite your committee and your colleagues
in the Senate to help me lead this effort to restore faith in
student financial aid broadly. We cannot fix this broken
enterprise by cherry-picking a few narrow issues to address. We
must peel back the layers, increase transparency, streamline
the entire system and provide much more aid to students, which
is exactly what we have been doing.
I have already provided you with written testimony that
describes in detail how we have improved management and reduced
the default outstanding loan portfolio by 40 percent since
2001. More recently, I have tightened oversight of our student
loan database and sent on-site teams to review the lender
relationships of the 44 schools highlighted in recent reports.
In addition, since my commission's report, we have been
acting on their recommendations to increase affordability,
accessibility and accountability in higher ed. We have worked
to streamline and increase federal aid, strengthening the
accrediting process and telling students much earlier who they
qualify for aid.
Earlier this year, President Bush proposed the largest
increase in federal Pell Grants in 30 years, and I am glad that
the Congress has taken steps to help accomplish that goal.
And I hope very much that we can work together in that same
bipartisan spirit to execute the commission's remaining
recommendations and reauthorize the Higher Education Act this
year.
Mr. Chairman, 5 years ago, with No Child Left Behind, we
worked across party lines and committed to have every child on
grade level by 2014. Today, this law is working, shining a
spotlight on student achievements and building demand for
further changes, like keeping America's teenagers from dropping
out of school.
An integral part of that program is the Reading First
Program, the largest, most effective reading initiative in our
nation's history. The latest data shows that Reading First is
producing sizable gains in fluency and comprehension for nearly
2 million first, second and third graders. I am deeply
concerned about the report Senator Kennedy released yesterday,
and my department is working with the inspector general on this
matter, as we have done previously.
Last fall, I put in place new leadership to oversee Reading
First and issued clear guidance and training in implementation.
I have sought input from states on how to improve the program
and developed a new charter to strengthen peer reviews, and I
have directed my general counsel to take further steps to
prevent conflicts of interest.
But together we can and must do more. From K-12 to higher
education, you and I now have an opportunity to enact
meaningful new policies that make a real difference for
students and families, as we have done before.
Both No Child Left Behind and the Higher Education are up
for renewal again this year. Where these laws need changing,
let's do it. Where families need our help, let's provide it.
Together, we can enact policies that help prepare more students
for college and make sure they can afford it when they get
there.
Thank you, Mr. Chairman. I would be happy to answer your
questions.
[The statement of Secretary Spellings follows:]
Prepared Statement of Hon. Margaret Spellings, Secretary, U.S.
Department of Education
Thank you, Mr. Chairman and Members of the Committee. I appreciate
this opportunity to set the record straight on my department's
oversight of college student aid and the Reading First program.
We've heard a lot lately about alleged unethical practices in the
student loan industry. Students and families expect and deserve honest,
ethical behavior from our government, our universities, and our
lenders.
Annually, ten million students in our country receive Federal
financial aid. My department is the means by which almost half of them
are able to afford college. We work with schools and lenders across our
country. The vast majority of them are doing the right thing for
students.
However, the fact is, federal student aid is crying out for reform.
The system is redundant, it's Byzantine, and it has failed to keep up
with dramatic changes in higher education. In many ways, it's also a
prime target for those looking to game the system.
In the instances when the public's trust is violated, it's our
responsibility to act--and that is what we've done.
Federal Student Aid Purposes, Operational Scope and Scale
The Department of Education's grant, loan, and work-study programs
represent the largest source of student aid for postsecondary education
in the United States. In 2006, these programs provided approximately
$77 billion to more than ten million students and their families.
Federal Student Aid is charged with operational responsibility for
oversight and administration of all the Department's Federal student
financial assistance programs under Title IV of the Higher Education
Act of 1965 (HEA) and, as one of the government's few Performance-Based
Organizations, upholds high standards of operational efficiency,
innovation, and customer care.
The Higher Education Amendments of 1998 established Federal Student
Aid, under the direction of the Secretary, as the Federal Government's
first Performance-Based Organization, with particular emphasis on
modernizing the delivery of the Federal student assistance programs.
The authorizing statute provides that the purposes of the Performance-
Based Organization are to:
Increase accountability;
Improve service to students;
Integrate information systems;
Implement a common integrated delivery system;
Strengthen program integrity; and
Reduce costs of administering the programs.
The Department's Federal Student Aid office ensures the
availability and accessibility of the Free Application for Federal
Student Aid (FAFSA) to students and parents and receives and processes
FAFSAs for over 14 million aid applicants each year. Over the past
several years, Federal Student Aid has dramatically transformed the aid
application process from a 100 percent paper process to one that is now
96 percent web-based.
The Department's Federal Student Aid office is one of the largest
originator of student loans, annually making nearly three million
Direct Loans totaling nearly $13 billion to almost two million student
and parent borrowers. In 2006, it originated over 1.2 million Direct
Consolidation Loans totaling more than $19 billion. It is responsible
for servicing the over $89 billion outstanding loan portfolio of 18
million Direct Loans made to more than seven million borrowers. It is
also responsible for collection on over $21 billion of defaulted
student loans, including Direct Loans (DL), Family Federal Education
Loans (FFEL), and Perkins Loans. It oversees the approximately $450
billion outstanding student loan portfolio, including loans held by
lenders, guaranty agencies, and schools. It also ensures the delivery
of nearly $13 billion in Federal Pell Grants to over five million
undergraduate students each year. The Federal Student Aid systems
process millions of financial and other transactions annually and its
websites receive billions of hits each year. Its customer care centers
annually handle more than 34 million inbound and outbound phone calls.
And each year it sends more than 41 million communications to aid
applicants and borrowers.
State of Affairs in 2001
Despite the critical role that the Department and Federal Student
Aid (FSA) plays in helping millions of students attend college, when
this Administration took the helm of the Department in January 2001, we
inherited a situation in which both were in a state of complete
disarray. The Department and Federal Student Aid had not received clean
audit opinions in years and there was not any expectation of receiving
them in the near future. Millions of dollars of grant money could not
be accounted for. The Inspector General's Office, the General
Accounting Office, and outside auditors had identified 661 audit
recommendations for improving financial management, internal controls,
operational management, program management, and compliance oversight
that needed immediate attention. The situation was dire and the
evidence of mismanagement egregious.
This Administration immediately committed to cleaning up these
programs. Specifically, we committed to:
Ensuring the removal of Student Financial Assistance
Programs from the GAO High Risk List;
Obtaining clean financial audit opinions;
Putting in place effective systems of internal controls to
protect the Department's assets from waste, fraud, and abuse;
Making the systems and processes supporting student aid
delivery and management more efficient and less costly;
Continuing efforts to reduce student loan default costs;
and
Making accountability for results the primary operating
principle for all Education managers, grantees, and contractors.
These commitments were ambitious and important, and I'm pleased to
report we have achieved each and every one of them.
Prior to the establishment of Federal Student Aid as a Performance-
Based Organization, the Federal Student Aid programs were plagued with
oversight and management challenges, high default rates, and customers
who were not happy with the service they received. In 1990, the
Government Accountability Office (GAO) found the federal student aid
programs at high risk for fraud, waste, abuse, and mismanagement.
Financial management and internal controls around the programs were
largely non-existent and unqualified audit opinions were not
attainable. In 1990, student loan cohort default rates had hit an all-
time high of 22.4%. Customer satisfaction was not even measured.
It was indeed shocking the amount of hard work necessary to address
the clear oversight and management issues that landed the federal
student aid programs on the GAO High Risk list in 1990 and where they
remained when this Administration arrived on the scene.
We recognized the inherent challenges in providing billions of
dollars of grants and loans, through thousands of intermediaries to
millions of students; however, we chose to aggressively manage the
challenge to ensure access to postsecondary education while reducing
the vulnerability of student aid programs to fraud, waste, error, and
mismanagement. To accomplish this goal, in April 2001, this
Administration made obtaining clean audit opinions a top management
improvement priority. The Department established a Management
Improvement Team composed of eight members of the senior staff of the
Education Department who worked exclusively on attacking the problems
and developed a comprehensive ``Blueprint for Management Excellence''.
In addition, the President's Management Agenda (PMA), announced in the
summer of 2001, included an initiative specifically focused on
improving the Department's financial management and removing the
federal student aid programs from GAO's high-risk list.
The task at hand was daunting and required the Department and
Federal Student Aid to:
Clearly demonstrate strengthened financial management and
internal controls over the federal student aid programs and the
Department as a whole;
Obtain unqualified audit opinions both on Federal Student
Aid and the Department's financial statements;
Demonstrate Federal Student Aid was integrating its
delivery systems while providing high- quality services to students,
colleges and universities, and financial institutions;
Provide assurance and direct evidence that the Department
has the systems, leadership, and processes in place to continue to
maintain the integrity of its financial management, the major hurdle
for the federal student aid programs' high-risk designation;
Maintain a balanced management approach in the federal
student aid programs that seeks to minimize non- compliance and default
rates while still promoting the widespread use of the programs; and
Demonstrate the existence of plans, processes, and
infrastructure to address risk issues identified as key to the success
of the federal student aid programs.
Theresa ``Terri'' Shaw, appointed as the Chief Operating Officer of
Federal Student Aid in September 2002, was charged specifically with
the task of ensuring the removal of the federal student aid programs
from the GAO High Risk list and achievement of clean financial audit
opinions as her top two priorities. Terri came to the Department after
twenty-two years of exemplary work in federal student aid delivery,
information technology, business process reengineering, contract
management, and organizational change management.
Under this Administration, clean financial audit opinions have been
achieved for the past five consecutive fiscal years beginning with FY
2002. The only prior clean financial audit opinion in the history of
the Department was in 1997. When GAO removed the federal student aid
programs from its High Risk list in early 2005, it recognized the
significant progress of Federal Student Aid and the Department in
resolving financial integrity and management issues and demonstrating
strong commitment and senior-level leadership support for addressing
issues and risks.
In addition, on March 31, 2005, Federal Student Aid achieved ``all
green'' status on the President's Management Agenda (PMA) scorecard for
Elimination of Fraud and Error in the Student Aid Programs and
Deficiencies in Financial Management.
Federal Student Aid also focused on student loan default prevention
and management through default prevention strategies implemented by
participants across the programs. Since FY 2000, the combined FFEL and
Direct Loan FY 2000 cohort default rate has been reduced by nearly 14
percent from 5.9 percent to 5.1 percent for FY 2004. Cohort default
rates have been reduced from an all-time high of 22.4 percent for FY
1990. It is expected that when the FY 2005 cohort default rates are
announced in September 2007 that they will be even lower than the
current 5.1 percent.
At the same time, we also moved to make the financial aid
application (FAFSA) and the process for filling it out more user-
friendly. We went from a process that was 100 percent paper to one that
is now 96 percent electronic. In fact, electronic processing has been
implemented in all phases of the financial aid process. This is
accomplished through a series of secure, user-friendly, and efficient
electronic processes that have simplified the financial aid process for
students and families. Federal Student Aid's new Public Service
Announcement (PSA) ``Only a Dream'' was ranked in the Top 10% most
viewed Nielsen-tracked PSAs in January, Top 5% in February and Top 6%
in March resulting in reaching an audience of over 160 million.
The FY 2006 American Customer Satisfaction Index (ACSI) ratings for
Federal Student Aid's highest volume products and services- including
the electronic FAFSA, Common Origination and Disbursement and Direct
Loan Servicing, score in the ``Excellent'' and ``Good'' range. Our
products and services score higher than the federal government
aggregate scores and on par with private sector scores.
Fair and effective oversight and monitoring of the approximately
6,000 institutions of higher education that participate in the programs
is one of Federal Student Aid's core responsibilities, as is its
oversight of the nearly 3,500 lenders, guaranty agencies, and servicers
that participate in the FFEL Program.
Federal Student Aid's oversight activities include real-time
quality control. Federal Student Aid has built into its systems and
processes edits, triggers, risk assessments, and other features that
enable it to monitor and correct errors and to provide early warnings
of potential trouble. For example, our monitoring alerted us to: (1)
anomalies in access to the National Student Loan Data System (NSLDS);
(2) the financial condition of the Oregon Student Aid Commission (OSAC)
early enough so that a seamless closure and transition of OSAC's
guaranty services could occur; and (3) the increase in special
allowance payments made to loan holders on certain FFEL loans made or
purchased with tax-exempt funds which led the Administration to include
a proposal in the President's FY 2005 Budget that would stop the
increase in 9.5% special allowance.
In addition, Federal Student Aid monitors the school and lending
community by reviewing required annual compliance audits and financial
statements, performing on-site program reviews, and analyzing partner-
specific data to detect trends and areas that could be of concern.
Federal Student Aid engages in an ongoing process of actively
identifying risks in the programs. Noncompliance with statutes,
regulations, and policies by schools, lenders, guaranty agencies, and
servicers not only places Title IV funds at risk but also erodes the
public trust in the programs. We partnered with the Department's Office
of the Inspector General to establish a joint task force to identify
real or potential risks for fraud, waste, abuse, and mismanagement in
the programs. Federal Student Aid also established an Enterprise Risk
Management unit to better coordinate risk monitoring and action plans
among our various business units and with other Department of Education
offices.
Let me speak specifically about the issues that have received
recent attention:
National Student Loan Data System (NSLDS):
In 1994, the Department of Education created NSLDS in order to
facilitate students' access to financial aid and loan information.
Lenders may have access to the National Student Loan Data System
(NSLDS) for the purpose of assisting with determining the eligibility
of an applicant for federal student aid and the collection of federal
student loans and grant overpayments. NSLDS information may not be used
for any other purpose, including the marketing of student loans or
other products. In fact, NSLDS does not provide access to email
addresses, phone numbers, or addresses of borrowers that could be used
for marketing purposes. NSLDS information is protected by the Federal
Privacy Act, and pursuant to the routine uses published in the NSLDS
system of records notice the Department discloses to external
authorized entities, information such as borrower social security
number, date of birth, and data regarding Title IV aid received, as
well as federal loan amounts, outstanding balance, current status of
the loan, and grant amounts only for the purposes described above.
Information accessible to external authorized users of NSLDS is
limited to borrower social security number, date of birth, and data
regarding Title IV aid received, such as federal loan amounts,
outstanding balance, current status of the loan, and grant amounts.
NSLDS does not authorize a user to ``dig through tons of data'',
nor does it authorize the analysis of multiple borrower records for
identification of hidden patterns or behaviors, nor does it authorize
the exploring of transactions, nor does it permit database searches for
multiple borrowers. These activities are commonly referred to as ``data
mining''. NSLDS only allows a user to look up a single borrower at a
time and only if the user has a relationship with the borrower or the
borrower's specific permission to do so, as demonstrated by the
borrower's return of a solicitation which contains such an
authorization, by other written authorization by the borrower; or
verbal permission as noted in call records of the lender. The use of
automated tools to speed up the process of looking up borrower records
one entry at a time is prohibited. Federal Student Aid deploys a
variety of tools and techniques specifically designed to detect the use
of such automated tools. These tools and techniques alert us to the
possibility that automated tools are being used and automatically
suspend the access for the user ID.
A common practice in the consumer credit industry is the purchase
of data from credit bureaus and other sources for the specific purpose
of making an offer of credit to an individual, such as credit card
offers. Consolidation lenders participating in the FFEL program also
follow this practice. Once the solicitation offer is made to a borrower
and permission by the borrower is granted, the lender is authorized to
access NSLDS to obtain information on the underlying loans that the
borrower wishes to consolidate. It is the responsibility of the chief
officer of each entity to ensure that its authorized users are in
compliance with NSLDS access requirements.
There are 60 million student records in NSLDS representing loans
that are both active and paid in full. The signature of the chief
officer of the organization is also required to certify appropriate use
of the system by his or her employees. In addition, the signature of
the individual authorized by the chief officer of the organization is
required for system access and use. With their signature, users confirm
their understanding of the requirements for system use and agree to use
the system in accordance with all rules and regulations. There are
approximately 29,000 school accounts and 7,500 lender accounts.
The data residing in NSLDS are confidential and are protected by a
series of both federally mandated and discretionary security measures,
including the Privacy Act of 1974. These measures include access
management, network and physical security policies and procedures such
as protective surveillance of recurring threats such as virus and mail-
ware filters, monitoring of suspicious external traffic, such as
attempted denial of service attacks, firewalls, access and usage
monitoring and tracking, and routine testing and surveillance using
intrusion detection systems. NSLDS must annually pass, at a minimum, a
FISMA audit, a financial audit or Security Certification and
Accreditation. Most systems are annually tested by more than one of
these three procedures and all systems must pass every test within any
three-year period.
Federal Student Aid continuously monitors access to NSLDS to
prevent unauthorized use and, since 2003, Federal Student Aid has
invested over $650,000 in improved system security and monitoring tools
and processes to ensure the integrity of student information.
Since 2003, these oversight efforts have resulted in the revocation
of over 52,000 user IDs. The majority of these revocations were due to
user inactivity; however, 261 user IDs were revoked due to suspicious
activity. Of these 261 revoked IDs, 246 user IDs belonged to lenders,
loan holders, guaranty agencies and servicers; and 15 user IDs belonged
to schools.
As a result of the Department's monitoring of NSLDS usage, we
issued a Dear Colleague Letter (DCL) in April 2005. This DCL explicitly
reiterated to program participants that failure to comply with NSLDS
usage requirements may result in the organization or individual losing
access to the system and/or being subject to further sanctions.
Following the release of the DCL, we observed a significant
increase in usage by lenders, loan holders, servicers, and guaranty
agencies. Based on this increase, the Department had concerns as to the
appropriateness of such access and discussed the termination of access
by lenders, loan holders, servicers, and guaranty agencies. As a
result, the Department decided to temporarily suspend access to NSLDS
by all entities except schools and borrowers--effective April 17, 2007.
During this temporary suspension of access, the Department is
conducting a comprehensive review of the specific uses of NSLDS to
determine if there has been unauthorized access or use. The Department
is consulting with the Inspector General to complete this review. As
part of my Task Force on Student Loans established on April 24, 2007,
we are also reviewing all guidance to determine if enhancements are
necessary.
On May 2, 2007, the Department began to notify entities, beginning
with guaranty agencies, of the process to restore their access to
NSLDS. Access to NSLDS will be restored only after the Department has
determined that it is appropriate to do so based on the analysis of
access and usage information for each entity. As such, the timing of
access restoration will not be the same for all entities.
This analysis is being conducted in a manner that assures the
Department that an entity has only accessed and used NSLDS for approved
purposes. Additionally, restoration of access will be predicated on the
receipt and approval by the Department of: (1) a listing that
identifies each of the entity's personnel for whom it wishes to have
NSLDS web access and the specific authorized use or uses by that
person; and (2) a certification, signed by the entity's Chief Executive
Officer (CEO) and its Department of Education Data Point Administrator
(DPA), that affirms that the entity and each of its staff for whom it
has requested, or will request, NSLDS access is in compliance with all
applicable guidance provided by the Department.
Access by an individual will be permanently terminated if the NSLDS
access requirements are violated. Access by an entity will be
permanently terminated if there are three violations of the NSLDS
access requirements within a 12-month period by persons associated with
that entity. In addition, unauthorized access or use of NSLDS may
subject users to criminal or civil penalties, including fines and/or
imprisonment.
The Department is also developing a fact sheet--``Protecting Your
Private Information''--designed to help students and families
understand the importance of protecting their private information and
granting of permission for others (specifically entities other than
schools) to access their NSLDS information.
Alleged Close Relationships with the FFELP Industry:
It has been suggested that the Department administers the FFEL and
DL programs with favoritism to the FFEL program due to alleged close
relationships to the FFEL industry. This suggestion is totally without
merit and has no basis in fact. A recent example that demonstrates the
falsehood of this assertion is the Department's swift response to the
Inspector General's September 2006 report that one lender, Nelnet, was
improperly billing loans from ineligible sources for 9.5% special
allowance payments. Within two weeks, 9.5% payments to Nelnet were
frozen and within months, the industry received a Dear Colleague letter
(DCL) restating the statutory requirements for eligible sources, and we
announced that 9.5% payments would be suspended for the entire
industry. The DCL also indicated that henceforth 9.5% payments would
only be made for loans proven to be eligible after new, industry-wide
audits. The Department then issued the methodology to be used in these
audits, which it developed with the Office of the Inspector General.
While the IG's report highlighted another dimension to the problem,
our work on the 9.5% payments began well before the report's release.
In the summer of 2003, Department staff noted an alarming increase in
special allowance payments made to loan holders on certain FFEL loans
made or purchased with tax-exempt funds. The Department's staff
determined that these claims for the higher payment were being made
under a loophole in the rules written during the previous
administration that allowed certain loans financed with tax-exempt
funds to qualify for a 9.5 percent special allowance subsidy, minus the
applicable rate of interest on such loans. This led the Administration
to include a proposal in the President's FY 2005 Budget that would stop
the increase in 9.5% special allowance payments.
After the Higher Education Act reauthorization was delayed that
year, we began working closely with Congress to address the issue.
President Bush closed the loophole when, on October 30, 2004, he signed
the Taxpayer-Teacher Protection Act of 2004 (TTPA), which enacted a 1-
year moratorium, since made permanent, on granting 9.5% special
allowance subsidies on a wide variety of loans financed with tax-exempt
obligations.
The savings achieved by closing the loophole went to a purpose
close to my heart--to increase loan forgiveness programs for borrowers
who participate in the Federal student aid programs and serve our
country as teachers. Under the law, teachers who are employed full-time
for five consecutive years and are highly qualified in secondary-school
science or math, or are highly qualified in elementary or secondary
school special education, qualify for loan forgiveness of up to
$17,500.
As significant as the Taxpayer-Teacher Protection Act was in
curbing a significant abuse in the Federal student loan programs and
increasing loan forgiveness for teachers, the Higher Education
Reconciliation Act of 2005 (HERA) promises to have a longer and likely
more significant positive impact on academic preparation and higher
education in the U.S. The origins of many of the initiatives contained
in the HERA can be traced directly to President Bush's fiscal year 2006
budget, which proposed significant savings in the Federal student loan
programs and redirected significant funding to student benefits. These
initiatives include curbing excessive special allowance payments and
insurance, making the changes to the treatment of loans in the
Taxpayer-Teacher Protection Act permanent, supporting additional need-
based grant funding, and raising first- and second-year loan limits.
Congress also chose to authorize the two new Federal grant programs
to help low-income students pay for postsecondary education--Academic
Competitiveness and National SMART Grants. These new programs--
authorized on February 8, 2006, and launched just 143 days later on
July 1, 2006--have already awarded more than $400 million to over
330,000 Pell Grant-eligible students helping to reduce their student
loan debt. While these programs are complex and required significant
work by the Department and institutions, I believe that they will:
first, change the way that our high school students prepare for
postsecondary education; and second, encourage more college juniors and
seniors to study critical, high-need subjects. For this reason, I'm
pleased that Congress made the decisions that they did in enacting the
HERA with these two new programs.
President Bush has consistently put the needs of students--
particularly those from low-and middle-income families--first.
Most recently, the President's fiscal year 2008 budget request,
which is pending before Congress, would reduce interest subsidies on
student loans by 1/2 percent, saving $12.4 billion over 5 years. He
also proposed to reduce insurance on FFEL loans from 97% to 95%, saving
an additional $1.6 billion over 5 years. And he proposed to increase
the fee lenders pay when making a consolidation loan from 0.5 percent
to 1.0 percent reducing Federal costs by $850 million. These savings
will be used to pay for increases in the Pell Grant and Academic
Competitiveness Grant programs and to raise loan limits for juniors and
seniors in college. As I am sure you are aware, we have been criticized
by FFEL lenders, some of whom have claimed lower subsidies will force
them to reduce borrower benefits or leave the program. However, I
believe that we can and must responsibly reduce subsidies in the FFEL
program and use those savings to increase grant aid.
Further, it has been suggested that the Department's employment of
skilled staff with industry experience equates to ``close ties'' to the
industry and, therefore, does not allow for unbiased and impartial
oversight and instead emphasizes partnership over enforcement. I should
note for the record that the previous administration's July 1, 1999
report, ``Reinventing Service'', from the Customer Service Task Force,
specifically stated that Federal Student Aid (then named Office of
Student financial Assistance-OSFA) * * *'' should be working in close
partnership with financial institutions.'' Additionally, the previous
administration began the practice of recruiting skilled staff with
industry experience. Greg Woods, Federal Student Aid's first Chief
Operating Officer, created a specific organizational unit, the
Financial Partners Channel, to work in close partnership with lenders,
guaranty agencies, and third-party services participating in the FFELP.
He also began the practice of hiring managers with industry experience.
The first General Manager of the FSA Financial Partners Channel was J.
Barry Morrow, who was previously an executive with Sallie Mae.
Succeeding Mr. Morrow was John Reeves, who was previously the President
of Educaid, at the time the sixth largest student loan lender and the
fourth largest holder of student loans, and prior to that an executive
with The Money Store.
The previous administration understood, and we agree, that the
experience and insights that private-sector leaders and managers bring
to the important task of making the financial aid system work better
for students, schools, and lenders is invaluable.
Since it was first established as a Performance Based Organization
in 1998, Federal Student Aid has assembled a senior leadership team
possessing over 300 years of experience in the private sector, the
higher education community, and government. This team's leadership and
expertise ensures Federal Student Aid achieves its strategic
objectives, including annually delivering critical financial aid to
millions of students and families and managing the inherent risks in
the programs.
Since it is responsible for the administration of both the FFEL and
DL programs, Federal Student Aid administers these programs in an
evenhanded manner. The two programs share the same goals, the same
eligibility requirements, and many of the same benefits. We firmly
believe that the existence of the two programs has led to increased
competition, improved customer service, and lowered costs for students
and taxpayers alike. It should be noted that, since 2002, significant
operational and management improvements have been implemented to
enhance administration and financial and operational management of the
DL program. These improvements are focused on better serving the 1,087
DL schools and the nearly 7 million DL borrowers, as well ensuring the
sound fiscal management of the more than $93 billion outstanding
portfolio. Prior to 2001, billions of dollars disbursed annually under
the DL program were not: (1) fully reconciled to the Department's
financial records; (2) verified as actually being delivered to students
within the required timeframes; and (3) delivered to the DL servicer
for on-going servicing within the required timeframes. Today, all
disbursements are: (1) 100 percent reconciled from the date of
disbursement through loan payoff; (2) verified as being delivered to
the students or returned to the Department with 30 days as required;
and (3) immediately delivered to the DL servicer for on-going
servicing.
Inducements:
New York Attorney General Andrew Cuomo's testimony before this
Committee at its recent Hearing on ``Examining Unethical Practices in
the Student Loan Industry'' was ill informed on the Department's
actions and on federal law. Any suggestion by a state attorney general
that a violation of a state's law on deceptive trade practices and/or a
state's fraud law would equate with an automatic violation of Title IV
of the Higher Education Act (HEA) is misleading.
As Attorney General Cuomo should know, the Department has no
authority to apply the HEA anti-inducement provisions to consumer
credit loans that are governed by other federal regulators, including
the Comptroller of the Currency, the Federal Reserve, the Office of
Thrift Supervision, the Federal Deposit Insurance Corporation, and the
Federal Credit Union Administration. The legal, regulatory, and
supervisory framework for consumer protection specifically includes the
following statutes, which collectively address the lending process,
irrespective of the loan product, in terms of equal access,
origination, disclosure, and privacy:
Truth-in-Lending Act
Fair Credit and Charge Card Disclosure Act
Fair Credit Reporting Act
Equal Credit Opportunity Act
Fair Debt Collection Practices Act
Home Equity Loan Consumer Protection Act
Home Ownership and Equity Protection Act
Fair Housing Act
Real Estate Settlement Procedures Act
Fair Credit Billing Act
Expedited Funds Availability Act
Truth-in-Savings Act
Electronic Funds Transfer Act
Consumer Leasing Act
Gramm-Leach-Bliley Act
Patriot Act
Sarbanes-Oxley Act
The Department is investigating, under its authority, whether, in
fact, there have been violations of the anti-inducement provisions of
the HEA. Federal Student Aid already has teams performing on-site
reviews of the 44 schools and 26 lender/eligible lender trustee
relationship for which unethical practices have been alleged to date to
determine if there have, in fact, been violations of the anti-
inducement provisions of the HEA.
In addition to these efforts to address inducements, we have taken
a number of steps to tighten our oversight responsibilities of federal
student financial aid programs under existing regulations and within
the authority the Department has been given through the
congressionally-mandated process for issuing new regulations. These
steps include, but are not limited to: (1) improved reporting
requirements for guaranty agencies and lenders; (2) improved reporting
and monitoring of the required reserve ratios that must be maintained
by guaranty agencies; (3) the development of a methodology for
establishing a FFELP improper payment error rate; (4) the creation of
consolidated risk management scorecards for both lenders and servicers
to better target oversight monitoring; and (5) the standardization of
the Program Review process. In fact, many of these steps led to the
removal of the federal student aid programs from the GAO High Risk List
in January 2005.
As noted in my letter to Senator Edward Kennedy on April 17, 2007,
the Department issued a Dear Colleague letter on March 30, 2007
reaffirming that student and parent borrowers under the FFEL program
may select the lenders of their choice. Additionally, during its annual
Title IV compliance training conferences in October and November of
2006, Federal Student Aid specifically addressed the importance of
compliance with the anti-inducement provisions in the HEA.
While I appreciate the fact that yesterday, the House of
Representatives took an important first step in this process, I
determined last year that absent Congressional reauthorization of the
HEA, it was my duty to address, among other issues, preferred lender
lists and prohibited inducements in the FFEL program through the
rulemaking process that you set up by law. Indeed, in January 2007, the
Department offered draft regulatory language to strengthen existing
regulations on preferred lender list practices and on inducements.
Despite the Department's urging that the proposed language be adopted,
the negotiated rulemaking committee did not reach consensus at their
fourth and final session on Friday, April 20.
As you know, on April 24, 2007, I announced the formation of a Task
Force on Student Loans to build on the negotiated rulemaking
committee's work around key lender issues such as preferred lender
lists, prohibited inducements, and NSLDS. This internal task force
includes representatives from the Department's Office of Postsecondary
Education, Federal Student Aid, and Office of the General Counsel.
Representatives in the Office of Inspector General participate in an
advisory role.
My Task Force just recommended new plans to strengthen the
Department's original position and make it clear that:
Unethical practices should cease and desist;
All conduct related to student lending should be centered
around borrower interests; and
Trust and integrity must be maintained in our student aid
system.
I appreciate the hard work of the Task Force and their thoughtful
recommendations to protect borrowers. They have made insightful
suggestions that would curb lender inducements to schools and introduce
greater transparency to the practice of selecting preferred lenders. I
will carefully consider these recommendations as I draft a Notice of
Proposed Rulemaking (NPRM). I plan to publish an NPRM that addresses
these issues in the Federal Register in the next several weeks.
Given the limited statutory authority and high threshold that the
Department is required to meet in order to bring enforcement action to
a school, lender, guaranty agency, or other third party, the Task Force
identified areas that we will need to work with you, Chairman Miller,
Congressman McKeon and others in order to strengthen the enforcement
ability of the Department. I look forward to working with you on these
recommendations that put an end to unethical practices, put students'
needs first and maintain trust and integrity throughout the system.
On May 1, 2007, Dallas Martin, President of the National
Association of Student Financial Aid Administrators (NASFAA), testified
during the Subcommittee on Higher Education, Lifelong Learning, and
Competitiveness hearing, ``Paying for a College Education: Barriers and
Solutions for Students and Families''. I strongly disagree with Mr.
Martin's testimony when he claims that the Department's supposed
failure to identify and penalize schools for their inadequate
administration of student's financial aid needs has forced schools to
seek assistance from lenders, guaranty agencies, and others to print
student financial aid consumer information, to perform student loan
exit and entrance counseling, to establish call centers, and to provide
additional staffing during peak periods in the financial aid office. In
fact, for the past five fiscal years, the Department has issued schools
124 citations and assessments totaling nearly $4.4 million for lack of
administrative capability--it is one of the top 10 findings in our
school program reviews.
Deceptive Marketing Practices:
On May 2, 2007, this Committee asked the Federal Trade Commission
(FTC) to investigate the unfair and deceptive practices that lenders
use to market their products and services to students. The Committee
made this request of the FTC after it had reviewed examples of lenders'
unfair and deceptive marketing letters that use what appear to be
official government logos and threatening language. The Department
shares the Committee's concern and, in fact, over the past few years,
Department staff has been communicating with the FTC staff to share
information regarding potentially deceptive marketing materials from a
variety of lenders. The Department joins you in calling on the FTC to
examine these practices.
Reading First
Five years ago, we worked across party lines and made a commitment
to have every child on grade level or above by 2014. Today, No Child
Left Behind is working-shining a spotlight on student achievement and
building an appetite for further change.
An integral part of this law, the Reading First program is the
largest, most effective reading initiative in our nation's history. The
latest data show that Reading First is producing sizable gains in
fluency and comprehension for nearly two million first, second, and
third graders. My Inspector General highlighted where its early
implementation was flawed, and I took immediate action to correct those
problems.
Let me begin by repeating what I have said since the Department of
Education's Inspector General first announced the results of his
Reading First investigation. We agree with the majority of the OIG's
findings and have accepted all of its recommendations to prevent any
future reoccurrence of administrative failures.
Flaws in the early implementation of the program must not sidetrack
the good work of a critically important and successful education
initiative. We have considerable evidence, including three years of
continually improving assessment results, that Reading First is working
as intended by Congress by building on the federally funded research
base. It is expanding the use of research-based reading instruction in
the early grades and significantly improving the reading skills of
students in some of our historically low-achieving schools.
In short, Reading First and the students who benefit from it
deserve your strong support as Congress moves forward in developing the
fiscal year 2008 appropriations act and the reauthorization of No Child
Left Behind.
Goals of Reading First
The goal of Reading First was to translate scientific insights into
practical tools to be used in classrooms. The Federal research
investment supported more than 20 years of research that followed over
44,000 children from age 5 into adulthood. Researchers at the National
Institute of Child Health and Development and the Institute of
Education Sciences tracked children who could read well, and they
tracked others who couldn't read at all. The National Reading Panel
looked at this and thousands of other high-quality scientific studies
to determine what the research tells us about how children learn to
read. When their work was over, our nation had gained evidence-based
insights into how children read, why some of them have more trouble
reading than others, and what we can do to get all children reading
well.
The knowledge gained through the research was embodied in the
Reading First Program designed to improve the quality of reading
instruction so that all children read at grade level by the end of the
third grade. The program pursues this goal through three strategies:
(1) providing substantial resources at both the State and local levels
for implementation of effective reading instruction in schools; (2)
using reading programs and materials that are research-based, combined
with high-quality professional development, to ensure that all
teachers, including special education teachers, have the necessary
skills to teach these researched-based reading programs effectively;
and (3) using assessments to help classroom teachers screen for,
identify, and overcome barriers to students' ability to read at grade
level by the end of third grade.
On the issue of research-based instruction, the statute specifies
that instructional methods and materials, as well as related
professional development, must incorporate the five essential elements
of effective primary-grade reading instruction: (1) phonemic awareness;
(2) decoding; (3) vocabulary development; (4) reading fluency,
including oral reading skills; and (5) reading comprehension
strategies.
The need for implementation of effective strategies and methods of
teaching reading is unquestioned. Though we have been pleased to report
improvements in reading achievement in the early grades over the past
several years, and believe that No Child Left Behind is contributing to
that improvement, overall achievement levels remain alarmingly low.
Less than one-third of all 4th-graders scored at the Proficient
level or above in reading on the 2005 National Assessment of
Educational Progress (NAEP), and results for students in the high-
poverty schools that are the focus of the Reading First program were
even more discouraging. Just 16 percent of 4th-graders eligible for
free or reduced-price lunch scored at the Proficient level or above on
the 2005 reading assessment, and more than half (54 percent) scored
below the Basic level. The 2005 NAEP reading results also highlighted
the continuing achievement gaps among student groups, with the
percentages of African-American students (13 percent) and Hispanic
students (16 percent) scoring at the Proficient level or above falling
far below that of white students (41 percent).
To help close these gaps, the Reading First State Grants program
has made awards to all 50 States, and States have made subgrants to
approximately 1,550 local school districts that serve an estimated
5,200 participating schools. The statute requires a comprehensive
national evaluation of the Reading First program, and the Department
produced the first report of that evaluation last summer. The most
recent Reading First student achievement data, released in April 2007,
indicate that students in Reading First schools have experienced strong
gains in reading proficiency. The July 2006 Reading First
Implementation Evaluation: Interim Report also found that districts are
implementing the major elements of the program, and that Reading First
schools are more likely to be implementing the program features called
for in the Reading First law than are non-Reading First Title I
schools.
Early Results of Reading First
While we do not yet have comprehensive impact data for Reading
First, we do have considerable early evidence that the program is
working as intended. This evidence comes from the most recent Annual
Performance Report data: the Interim Report of the Department's ongoing
implementation evaluation; the September 2006 report, Keeping Watch on
Reading First, produced by the Center on Education Policy (CEP); and a
March 2007 report from the Government Accountability Office (GAO).
New achievement data reported by the States in the Reading First
Annual Performance Report show that Reading First students from nearly
every grade and subgroup (Hispanic, African-American, students with
disabilities, English language learners, and economically
disadvantaged) made impressive gains in reading proficiency in 2005 and
then again in 2006.
In Reading First schools, the percentage of 1st graders meeting or
exceeding proficiency on Reading First fluency outcome measures
increased by 14 percentage points (43% to 57%) from 2004 to 2006.
In Reading First schools, the percentage of 3rd graders meeting or
exceeding proficiency on Reading First fluency outcome measures
increased by 7 percentage points (36% to 43%) from 2004 to 2006.
On average, the 26 States with 2004 baseline data increased the
percentage of students meeting or exceeding proficiency on fluency
outcome measures by 16% for 1st graders, 14% for 2nd graders, and 15%
for 3rd graders.
On average, the 26 States with baseline data increased the
percentage of students meeting or exceeding proficiency on
comprehension outcome measures by 15% for 1st graders, 6% for 2nd
graders, and 12% for 3rd graders.
The Reading First Implementation Evaluation: Interim Report
highlighted the following key findings regarding the early
implementation of the Reading First State Grants program:
Reading First schools are implementing the major statutory
requirements, including the use of scientifically based reading
instruction, increased reading time, interventions for struggling
readers, reading assessments, and increased professional development.
Though non-Reading First Title I schools also emphasized
reading instruction, Reading First strategies (that is, strategies that
reflect the research on what works in teaching children to read) were
used more extensively in Reading First schools than in Title I schools.
Reading First teachers were significantly more likely than
their counterparts in non-Reading First Title I schools to place
struggling students in intervention programs.
Reading First schools were more likely than non-Reading
First Title I schools to have a reading coach, and Reading First
coaches were more likely to provide teachers with various supports than
were coaches in non-Reading First Title I schools.
Reading First staff received significantly more
professional development than did non-Reading First Title I staff.
The changes in Reading First schools suggested by these findings
contributed to the Effective rating achieved by Reading First State
Grants in the 2006 Program Assessment Rating Tool (PART) process. The
PART found that the Reading First program benefited from a strong
program design and local management practices that appeared to help
bring about improvements in student reading achievement. In particular,
based on achievement data submitted by participating States, the PART
found gains on all program performance measures for the 2004-2005
school year.
Between 2003-2004 and 2004-2005, the percentage of students who met
or exceeded proficiency in reading on Reading First outcome measures of
fluency increased:
from 43% to 50% for first-grade students;
from 36% to 39% for third-grade students;
from 33% to 39% for economically disadvantaged second-
grade students;
from 27% to 32% for limited English proficient second-
grade students;
from 34% to 37% for African-American second-grade
students;
from 30% to 39% for Hispanic second-grade students; and
from 17% to 23% for second-grade students with
disabilities.
The number of States reporting an increase in the percentage of
students who met or exceeded proficiency in reading on Reading First
outcome measures of reading comprehension increased:
from 2 to 14 for first grade-students (20 States had two
years of data);
from 7 to 19 for third-grade students (23 States);
from 4 to 14 for economically disadvantaged second-grade
students (20 States);
from 5 to 6 for limited English proficient second-grade
students (18 States);
from 5 to 16 for African-American second-grade students
(19 States);
from 5 to 9 for Hispanic second-grade students (19
States); and
from 2 to 12 for second-grade students with disabilities
(19 States).
These achievement gains are all the more remarkable because the
schools served by Reading First are among the lowest-performing schools
in the country. The early results highlighted by the PART review
suggest that comprehensive implementation of research-based reading
instruction can bring about rapid improvement even in some of our worst
schools.
The PART data were echoed by the CEP report, Keeping Watch on
Reading First, which found that the program was ``having a significant
impact'' on reading instruction in participating districts and schools.
In particular, more than 90 percent of the 1,700 districts surveyed by
CEP reported that the Reading First instructional program and
assessment system were ``important'' or ``very important'' causes of
gains in student achievement in reading.
Another critical benefit of Reading First cited by the CEP report
was the use of Reading First as a school improvement strategy under No
Child Left Behind. In part, this reflects the statutory requirement
that States use Reading First funds to make available professional
development in reading instruction to all schools, and not just those
participating in Reading First. About 80 percent of States reported
that offering professional development through Reading First was a key
strategy for schools identified for improvement under NCLB, and a
similar percentage of States said that providing curriculum and
assessment materials through Reading First was a key improvement
strategy. More importantly, about three-fifths of States reported that
these Reading First-based strategies were ``moderately or very
effective in raising student achievement.''
A March 2007 report from the Government Accountability Office (GAO)
also indicated that States have reported that there have been a number
of changes, as well as improvements, in reading instruction since the
implementation of Reading First. According to the report, 69% of all
States reported great or very great improvement in reading instruction
since inception of Reading First.
Management Issues
My message today is that the senior leadership of the Department of
Education shares the widespread public concern about these issues, and
has moved decisively and rapidly to respond to the issues raised by the
Inspector General. Most significantly, in last year's annual
performance and accountability report to Congress and the public, I
declared a material weakness for program management at the Department
based in large part on the issues raised about the management of the
Reading First program. The material weakness does not diminish the
significant progress we have made as a Department in improving the
management of our programs, but rather reminds us that our work to
ensure that our programs are managed to the highest standards is not
yet complete. In addition, I have instructed my senior staff to
implement each of the recommendations from the Inspector General's
report. More specifically, the Department has already completed more
than a 20 action steps in response to those recommendations. These have
included:
Appointing Dr. Joseph Conaty, a well-respected career
executive with nearly 20 years of experience at the Department of
Education, to manage the program;
Establishing an intra-Departmental group that meets
regularly to help guide the implementation of the program. The group is
made up of various officials within the Department, including
representatives from the Office of Elementary and Secondary Education,
the Office of the General Counsel, and the Office of the Chief
Financial Officer;
Expanding Reading First staff to reduce reliance on
outside contractors;
Providing guidance on ensuring fairness and objectivity in
the peer review process in all formula grant programs. This guidance
was specific to issues involving conflict of interest;
Providing additional guidance to contractors and
subcontractors to enhance the objectivity and effectiveness of their
services, including clarifying conflict-of-interest prohibitions
pertaining to the use of peer review panels and private contractors;
Reviewing all Reading First applications to ensure
compliance with funding criteria. This review determined that the
majority of State applications had the appropriate documentation. The
Department is continuing to work with the additional States to resolve
any remaining issues; and
Conducting outreach to States on potential concerns about
Reading First issues. To date, the Department has received 25 letters
from States. 16 of those letters said only positive things about the
Reading First program. An additional 13 States responded that they
either had no concerns or did not intend to write a letter. We remain
committed to working with all States to address any concerns they may
have about the program.
In addition, the new Reading First program director, together with
representatives from the Office of Inspector General and the Office of
the General Counsel, delivered a presentation at the end of January to
the National Association of State Title I Directors on the ``lessons
learned'' from the IG's findings, including on the implementation of
new internal controls designed to ensure the integrity of the grant
application process. This presentation also described steps that the
Department is taking to ensure that our officials, consistent with the
Department of Education Organization Act, do not take actions that
could be interpreted as directing or controlling State and local
curriculum decisions.
I have also developed a charter for the peer review panel in
Reading First that would further strengthen the program's
implementation in line with the Federal Advisory Committee Act. This
panel would help the Department review issues that arise with State
applications for Reading First and evaluate the third-year progress
reports from the States. A notice of intent to establish this panel in
accordance with the Federal Advisory Committee Act was published in the
Federal Register on March 1, 2007.
We believe that these comprehensive actions will help restore
public confidence in the Department's ability to fairly and impartially
administer the Reading First State Grants program, and allow us to
build on the progress that States, school districts, and schools have
made under this program in improving reading instruction in the early
grades.
I urge the Members of this Committee to look at the entire record,
and not just the recent headlines, as you evaluate the progress of
Reading First and consider changes during the upcoming budget and
reauthorization debates. If you do, I think you will agree that Reading
First, with its emphasis on research-based instruction in the critical
early years, is one of our best tools to ensure that all students
receive a high-quality education, and it that merits your strong
support.
I would also like to take this opportunity to thank Congressman
McKeon and Congressman Castle for introducing H.R. 1939, the Reading
First Improvement Act. This legislation goes a long way toward
addressing many of the concerns about the early implementation of
Reading First. I look forward to continuing to work with Mr. McKeon,
Mr. Castle, and other members of the Committee to strengthen Reading
First.
Conclusion
Where the law needs changing, let's do it. And where families need
our help, let's provide it. Together, we can enact policies that better
prepare more students for college * * * and help make sure they can
afford it once they get there!
But together, we can and must do more. From K-12 to higher
education, you and I now have an opportunity to enact meaningful new
policies that make a real difference for students and families--just as
we did 5 years ago.
There's no time to wait. Nearly two-thirds of all high-growth,
high-wage jobs created in the next decade will require a college
degree-a degree that only one third of Americans have. I stand ready to
work with you to make a real difference in the lives of the people
we're all here to serve.
Thank you. I would be happy to answer your questions.
______
Chairman Miller. Thank you very much for your testimony.
As everyone is aware, the bells have rung, but let us go
ahead and begin.
Madam Secretary, I would hope that you would not
characterize the concerns that have been raised by this
committee, by the Senate committee, by the state attorneys
general as peripheral to the program.
The integrity of these programs is absolutely essential to
its core, which I think you say elsewhere in your testimony,
and the questions that have been raised, the suggestion that
somehow this only dealt with private loans and therefore it is
sort of out of your jurisdiction, I would like to point out
that in many instances these are the same entities making
public and private loans in their negotiations and discussions,
and that is where we get into trouble sometimes with the
institutions of higher education.
And we will all stipulate to your statement that the
federal aid has failed to keep up with the soaring cost of
education, which therefore makes every one of these dollars and
our ability to get them to students and to families even more
valuable.
As you point out, the Congress has long had a policy, the
law, against inducements, prohibitive inducements, and this
issue has been raised for a considerable period of time within
the department. To date, with all due respect, the department
hasn't actually acted on these with any sense or haste or
urgency. And over the last several months, we have seen a
number of inducements identified and people have settled or
people have paid money or they have said they will never do it
again.
But if I could just ask, if I could have your sense of
these inducements. We had ones where clearly there were revenue
sharing and referral fees paid by lenders to colleges. Do you
consider that an acceptable practice?
Secretary Spellings. No, and, Mr. Chairman, this is where I
think we really need some changes in law. The hurdle is very
high. For me to establish a violation, I must prove a quid pro
quo between the----
Chairman Miller. We will get there. We will get there.
Lenders were offering pools of money for lending--private
pools of money for lending in exchange for placement on the
preferred lender and exchange for a percentage of the federal
loan volume on campus. I assume you don't agree with that as a
practice, and that is an inducement. Lenders paying for
financial aid officer's trips to resorts and to serve on the
``advisory boards.''
Secretary Spellings. As I said, Mr. Chairman, I need to
clarify what the provisions are around inducements and the----
Chairman Miller. I understand that.
Lenders paying for supplementing the salaries and school
aid officers, I assume you do not find that an acceptable
practice. Is that correct?
Secretary Spellings. That is correct.
Chairman Miller. Financial aid officers holding stock in
the lenders that they are recommending to students.
Secretary Spellings. Mr. Chairman, of course I don't find
that acceptable, but I have to clarify whose roles and
responsibilities are implicated as we discuss those things.
Chairman Miller. I understand that. Let me get to my point
here.
My concern is about the department in the broad sense of
the word and the image, that from 2001 guidance was requested
and provided to the department about how to deal with this
issue. There were complaints from other lenders, there were
concerns within the department, and nothing was done with
respect to that guidance.
An alert was again provided in August 1 of 2003 and at the
end of long protracted discussions with the inspector general,
essentially, what you had was the department saying, ``We are
going to continue to monitor this,'' until we find the stories
coming out of the New York attorney general about actions that
were taken there.
I just don't quite understand how if monitoring was the
solution that the department chose, how it is that they didn't
pick up any of these activities. Again, these were people who
were skilled and, as Mr. McKeon pointed out, came from the
industry, understood it, and somehow they missed every one of
these, even though we now see them almost in every state in the
union and across a significant number of colleges and lenders.
Secretary Spellings. Well, Mr. Chairman, it is appropriate
that I parse the various issues that you have raised, because
there are different enforcement capabilities around a variety
of them.
Let me start with Nelnet, the issue that was raised----
Chairman Miller. Let's just stick with the inducements for
a second.
Secretary Spellings. All right. Let's stick with the
inducements.
Chairman Miller. So why is it from 2001 until recently when
you started negotiated rulemaking, and that failed; did that
alert you to some of the problems around the inducements until
your appointment of the task force after this all came to
light?
Secretary Spellings. Mr. Chairman, when I became secretary,
I immediately began my work on higher education. I have
probably been the most active secretary in this policy arena in
a very long time. That is why I appointed a commission. But I
think we also have to be aware of the interrelated nature of
all these things.
As they did their work, it became abundantly clear to me
that I needed to initiate a negotiated rulemaking process in
the absence of congressional action. It was the first time,
except for the Fed Up initiative that Congressman McKeon had
precipitated before, that that had been done. And that is why I
initiated the process, the 18-month process, and in December of
last year began to raise these issues before that negotiated
rulemaking group. They failed to reach consensus.
I said that I would take that advice under consultation
that they had, that they did not reach consensus on those
matters, and that is why I have acted to recommend and to post
to the Federal Register these aspects to end this inducement
practice.
Now, I also have to say, Mr. Chairman----
Chairman Miller. With all due respect, Madam Secretary,
this isn't about you. It is about the department. It is about
the failure of the department over a period of 5 years to deal
with the problem that is growing in intensity, growing in its
ethical unacceptance and probably in its criminal behavior.
And as we now see, settlement after settlement, all across
the country, at no time did anybody in the department think of
picking up the phone and telling people, ``You have got to stop
this. We are going to work on a regulation.''
It essentially has gone on to today without an official
statement by the department about its unacceptability. That is
the point.
Secretary Spellings. Well, Mr. Chairman, I agree in large
part with aspects of your point, but I think it is appropriate,
and this is one of those a picture is worth a thousand words
sorts of instances where I would like to commend you to our
little diagram about how oversight of this program works.
Chairman Miller. I have seen it. I have looked at it.
Secretary Spellings. Now, I want to talk specifically about
inducement matters, and that is that the hurdle that must be
cleared by the department for us to assert a violation in the
SL Program is a quid pro quo relationship between the awarding
of a particular loan and the cruise of New York Harbor, for
example, so that I must prove a direct relationship between
that act and the awarding of the loan. And that is why we need
changes in the law.
Chairman Miller. But with all due respect, the question of
whether you can prove that or not and your understanding, and
apparently a lot of other people's understanding, as they
prosecuted this, is to, at a minimum, its ethical
unacceptability. The idea that if you couldn't prove it there,
that therefore no action is taken, ``We are going to monitor
it.''
On all of the monitoring, over 5 years, you couldn't make
the determination as a department that these practices should
have been stopped?
These practices, people were laying out millions of dollars
of these inducements. I appreciate that there is not a piece of
paper between the University of Indiana and a $3 million grant
from Sallie Mae and they drive the Direct Student Loan Program,
a federal program off campus. But, you know, when they were
caught at it, they pledged to never do it again and paid back
the money. You know, when these other people were caught at the
cruises and it was brought to light, they paid back the money,
they rebated money to students, they swore they would never do
it again.
So none of that was about proving it in the court of law.
People were caught and the officials showed up at their front
door and said, ``This practice is unethical and illegal.'' They
didn't say, ``Well, take me to the Supreme Court.'' They were
caught, but nobody from the Department of Education showed up
at the front door. That is what I don't understand.
Secretary Spellings. And I guess my question would be, did
anyone show up from the FTC or the SEC or these other bodies--
--
Chairman Miller. But they are not here today, with all due
respect.
Secretary Spellings. Well, Mr. Chairman----
Chairman Miller. This is about your program. Your program
is coupled; you can't suggest that this is laid off on the
private loan sector. This is coupled with the very same
parties. It is convenient to decouple them, but the fact of the
matter is, Sallie Mae was offering private pools of money in
exchange for an increased federal participation in the loan
volume. They were coupled----
Secretary Spellings. Mr. Chairman----
Chairman Miller [continuing]. And when they were caught,
Madam Chairman, when it was suggested that we understood what
they were doing, they said they will never do it again.
Other lenders had brought this to the attention of the
department.
Secretary Spellings. I agree with you that we need changes
in the law to make it more robust with respect to enforcement.
Chairman Miller. What went wrong?
Secretary Spellings. Mr. Chairman, as you know, and as I
have pointed out on this diagram, there are 6,000 institutions.
This is a multibillion dollar industry. There are aspects that
relate to eligibility and authorities governing the SL Program
and others that relate to SL. There are multiple grant
programs.
Chairman Miller. When it was suggested that students would
not get a loan they applied for because it was not the lender
that the school chose, you issued a, ``Dear Colleague.'' Boom,
you stopped the practice.
Secretary Spellings. And I have the authority to do that
under current law.
Chairman Miller. For paying people, for putting people on
their payroll, for providing trips and inducements, for taking
the federal program off campus for money, there is no ``Dear
Colleague,'' there is no letter, there is no phone call that
the department, the director of the program, whoever, can make
to say, ``This is unacceptable''?
Secretary Spellings. We have conducted thousands and
thousands of audits of programs over the last several years,
obviously.
Chairman Miller. But, apparently, not related to this.
Secretary Spellings. Well, to the extent that I am charged
with implementing a law and enforcing a law that has a very
high hurdle to be cleared, then perhaps we need a change in the
law.
Chairman Miller. With all due respect, I cannot accept that
answer, because it isn't about the high hurdles to be cleared.
It is about whether or not you look at a situation, and, again,
other law enforcement looked at the situation, made a
determination and the practice ended. Nobody went to the
Supreme Court, nobody went over the high hurdle.
It was clear on its face the egregious nature of the
inducement, the conflict of interest and the unethical
behavior. Nowhere in 5 years of monitoring, which was your--the
department's, not yours--the department's accepted practice did
anybody make an effort to call a halt to these practices, with
all of the audits that you cite in your testimony.
Secretary Spellings. Well, as I said, we monitor these
programs vigilantly. There are----
Chairman Miller. Apparently not, Madam Secretary. I
understand what you are saying, and that was what you told the
inspector general, that your choice of enforcement was
continuing monitoring. Who was monitoring? Did they have
blinders on?
Secretary Spellings. Thousands of audits and----
Chairman Miller. Not with respect to this problem. I know
you have audits and people paid money, and you found problems
with the programs all over the campuses.
Secretary Spellings. And fines.
Chairman Miller. You never found one of these problems,
apparently.
Secretary Spellings. Well, to the extent that it was not a
violation of the laws that I am charged with overseeing, then,
no, we didn't take action.
Chairman Miller. Well, then you made an assumption, that
whether you put people on a cruise to the Caribbean, whether
you pay millions of dollars to kick a federal program off
campus, whether you provide private money so you can buy a
larger share of the Federal Loan Program on a particular
campus, you made a decision at the outset that none of that was
a violation of the law and it was not worthy of any discussion
with the campus, with the college president, with the lending
authority or with the loan officer on campus.
Secretary Spellings. Clearly, I was concerned about those
practices, and that is why I initiated the rulemaking last
fall. But I would say that the ability to try to prove that
level of legal burden in such cases was not something that----
Chairman Miller. I am afraid that has become a crutch. That
is sort of like you said it is a high burden on Nelnet, so,
therefore, we will let them keep the $300 million and they will
give up the--they gave up $1 billion and you said this was too
high a burden to think about going to court and the minute you
walked in the door they gave $1 billion.
Secretary Spellings. Mr. Chairman----
Chairman Miller. They must have had a hell of a strong
case. They must have said, ``Boy, we have got that Department
of Education nailed. We have got them so nailed we are going to
give up $1 billion.'' It is just not plausible.
Secretary Spellings. Well, I would like to take a moment
and explain the Nelnet settlement, if I may.
Chairman Miller. We are going to have to decide whether we
are going to run and vote. We have 2 minutes.
Secretary Spellings. When you get back.
Chairman Miller. Yes. With baited breath, we wait for the
answer.
Secretary Spellings. Yes, sir.
Chairman Miller. Thank you, Madam Secretary.
Secretary Spellings. Thank you.
[Recess.]
Chairman Miller. The committee will come back to order.
Madam Secretary, thank you very much for putting up with
the interruption. You are no stranger to the Hill, so you know
how this works. But also thank you very much.
The secretary has agreed to stay till 1:30 to allow as many
members as possible to have an opportunity to question.
I think I have about 5 minutes left.
Madam Secretary, when we left, I was concerned that the
department for a considerable period of time had chosen the
alternative in looking at inducements of monitoring, of
continuous monitoring of this program and the fact that it did
not appear that in all of that monitoring that they became
aware of many of the egregious practices that you, I and Mr.
McKeon and almost everybody else think were wrong within the
program. And I just don't understand why that was the selected
practice.
Secretary Spellings. Mr. Chairman, I agree that we have
work to do on preferred lenders and inducements, and that is
why today I have taken action to post those rules.
As you know, much of this has come to our attention through
the attorney general of New York, and, like you, I have read
about much of that in the newspaper. Those are things that
violate various state deceptive trade practices, laws and so
forth, and I do, I think this speaks to an area where we need
to strengthen the law and strengthen the ability to have
oversight.
As I said before, the threshold is very high for us to
prove a direct quid quo pro between the inducement, the group
and the actual loan or increase in lending. But is there more
to do on inducements? You bet, and that is why I am doing so.
Chairman Miller. Well, I appreciate that answer, and I
welcome those changes, and I think they are important, because
I find that more in keeping with the OIG's recommendation where
the OIG stated that, ``We are looking for the department to
take a strong role and provide guidance to the community, not
wait and see what the community wants them to say about it.''
That was in response to the August 1, 2003, guidance.
And I think the OIG had it right, and I think it has been a
costly lapse in enforcement by the department to the
credibility of this program, because I think it is very clear,
when we held our hearings and when we agreed upon the bill,
when we talked about the practices, there is an agreement here
that these are just unacceptable inside of this program.
And my concern is that it may be a high legal barrier, but
I suspect we haven't completely lost a sense of shame, and when
you are dealing with marquis universities and marquis public
companies, these practices just don't hold up very well in the
light of day.
And I think that the Office of the Secretary and the
department have got to let these people know that these
practices are unacceptable. We will deal with the legalities
later, but they have got to be told that this is unacceptable
to the ethical standards of the department, to the Congress and
certainly to the people who are borrowing money.
Secretary Spellings. I will use what moral suasion I have,
but I also----
Chairman Miller. It is considerable.
Secretary Spellings [continuing]. Want to use the
negotiated rulemaking to do something that we can enforce.
Chairman Miller. No, I understand that. I understand that,
and you have been working that process. I am just saying at
some point you have got to stop the bleeding. And in this case,
I think there is enough moral suasion in the department to stop
the bleeding while you go forward with that.
If I can turn, in my remaining time, to the question of the
9.5, the so-called Nelnet issue. There you engaged in the
settlement with Nelnet, which ended up, I believe, if I
characterize this right, they kept $278 million from past
practices, and they forego potential revenue on a continuation
of those practices into the future of $800 million over X
number of years. Is that a fair statement?
Secretary Spellings. The potentiality for additional costs
of the government was nearing $1 billion, yes.
Chairman Miller. Right. Can you tell us why the settlement
in that frame?
Secretary Spellings. Yes, sir, I can. And this is a highly
complex part of the law, the 9.5 percent special allowance
payment provision. It has not been tested in a court. There are
four practices that were brought to bear as part of this. You
all closed three of those four in HERA and in the Teacher
Taxpayer Protection Act.
Chairman Miller. Right.
Secretary Spellings. For the record, I will say that the
president was very early in observing this practice in January
of 2004. In his 2005 budget, he sought to close it and so
forth. So that chapter is closed.
With respect to one other practice, the transferring, it
was not considered to be unlawful to the extent that they were
first and second generation loans.
Chairman Miller. Right.
Secretary Spellings. My inspector general brought to my
attention that that organization was misusing that particular
aspect. We, at the Department of Education, had sent, I think,
an unclear answer and continued to make payments in the year
between Nelnet's request for an answer and subsequent action.
And, as such, I believed, and obviously anyone can second guess
the legal settlement, that we had significant exposure to this
government and significant liability potential for not only
this entity but potentially impacting others.
And so that is why, I think, as a matter of prudence, I
agreed to end, finally, this practice, settle that lawsuit for
approximately $278 million, mitigating it against the nearly $1
billion of additional damage that might have been incurred had
we lost that lawsuit. I worked with my inspector general to
provide a methodology that would be sound and that could apply
about legitimate reimbursements under that, and that is what we
have done.
Chairman Miller. Thank you. And I appreciate that action.
Again, I say this not to hold you responsible, but this is a
review of the department with respect to enforcement. This 9.5
problem was outlined in 2001 in a department-wide memo saying
that, essentially, that these people put together a scheme to
extend the life and this exorbitant subsidy at a time of record
low interest rates, costing this huge amount of money. And it
really isn't until Nelnet comes to light quite later and you
deal with that.
But, again, the failure to respond to this, to look at it,
to engage with it over 4 years until Nelnet, we paid out a lot
of money in those 9.5s.
And, apparently, there were others who were doing the same
kind of things. You have sent them a ``Dear Colleague.'' It
appears you may have stopped them in their tracks when you said
they are going to have to prove the trail of their right to the
9.5 and you are going to ask for an audit of each one of those.
Again, my concern is that $1 billion is on the table--and
there is no question I am second guessing your judgment here--
you make a determination there is a very high legal barrier to
do this and yet the people who are engaged in the same practice
stop the practice when they get a ``Dear Colleague.''
And Nelnet, as I said before, if it is such an easy case
for them, why do they walk away from $1 billion? I mean, if
they spent $100 million on lawyers, if it was so easy, they
would be in great shape.
Secretary Spellings. Well, that is something we will----
Chairman Miller. It was a scheme.
Secretary Spellings [continuing]. Obviously we will never
know the answer to that of----
Chairman Miller. That is right. That is my concern.
Secretary Spellings [continuing]. Who would have won a
lawsuit in this case. I was concerned that having paid, I
think, four or five quarterly payments to that and many other
organizations around that, that we had significant legal
exposure, and all I could do at the time was all I could do,
which was to end definitively once and for all that practice by
closing that loophole and applying a methodology broadly across
the industry.
Chairman Miller. Well, I think, as we saw with your ``Dear
Colleague,'' that might have stopped Nelnet in their tracks
too, and it could have stopped from the department, not
necessarily when you were there but either while you were there
or your predecessor and could have stopped this hemorrhaging of
money that they were not entitled to, that had been brought to
their attention.
I have run out of time. I don't think this is the last we
are going to hear about it. My understanding is that the
Department of Justice is now looking at that audit and we will
see where that takes us.
I recognize Mr. McKeon.
Mr. McKeon. Thank you, Mr. Chairman.
Madam Secretary, I know that you have been at the
department now for a little less than 2 years, but we keep
talking about before you got there, so I want to go back even a
little further than before you got there.
You have been criticized, your administration's been
criticized for lack of oversight, but there is really no
context for that allegation. In comparison to the Clinton
administration, can you tell us how many program reviews and
audits were handled by the Federal Student Aid Office during
the Clinton administration and the current one?
Secretary Spellings. Mr. Chairman--I mean, Congressman, no,
I do not----
Mr. McKeon. That is okay. [Laughter.]
Secretary Spellings. Pardon me, Mr. Chairman.
Chairman Miller. I call him a Democrat all the time. You
might as well call him chairman. It will balance out over time.
Secretary Spellings. Pardon me, Mr. Chairman.
Well, we have not done any analysis about that, candidly,
and I----
Mr. McKeon. Maybe you could do it for the record as a
follow up.
Secretary Spellings. I would be glad to, but my
understanding is that it is somewhat in excess of the kind of
monitoring, the thousands of monitoring investigations that go
on as part of FSA enforcement. We will certainly look at that.
I am about going forward.
Mr. McKeon. I had a follow-up question on that, and maybe I
can get that for the record too. Just, kind of, if you could do
a comparison between the 6 years that President Bush has been
president----
Secretary Spellings. I would be delighted to do that.
Mr. McKeon [continuing]. And the 8 years and even before
that, if we want to go back 20 years, because some of these
programs have been around that long.
You have been criticized for not addressing the issue of
the 9.5 loans in a timely fashion, an issue that has been
around for at least 20 years. We know that the Clinton
administration actually increased the number of loans eligible
for 9.5 when they published their 1996 ``Dear Colleague''
letter. But what I want to know is what the Clinton
administration did to limit payment on those 9.5 loans.
Secretary Spellings. I am not aware of any action that they
took.
Mr. McKeon. Maybe you could find out, if you could clarify
that in the record.
Secretary Spellings. I will.
Mr. McKeon. Madam Secretary, isn't it true that you
personally took this issue on and pushed Congress to enact
legislation to limit 9.5 loans when the general counsel at the
Department of Education advised you that negotiated rulemaking
would be required to change policy, and you realized that such
a progress would take longer than getting Congress to act?
Secretary Spellings. Well, I think I would say a couple of
things. First, in January of 2004, actually, February of 2004,
in the president's 2005 budget, he recommended the closing of
this loophole. As I have explained, it is a complicated
provision, that there are actually four aspects of this law.
And with respect to the one that did not need additional
statutory action, we did clarify that through a ``Dear
Colleague'' letter.
Mr. McKeon. Madam Secretary, you have been criticized for
not enforcing the inducement prohibition in the Higher
Education Act. We know that the Clinton administration took an
action against Sallie Mae, which was decided in Sallie Mae's
favor by an administrative law judge in 1996.
For the record, do you know how many other enforcement
actions were taken by the Clinton administration with respect
to inducements?
Secretary Spellings. I do know that the department lost
that case that you mentioned. With respect to other actions
that they may have taken, I will tell you that as high as the
threshold is, that the hurdle is, we have taken action against
some of these inducement issues, and there are some examples of
that in my written testimony, with the Dr. Scholl's Podiatric
College and various other entities where a direct relationship
was proved. But I will also do analysis of the previous
administration and ours about enforcement around those matters.
Mr. McKeon. Madam Secretary, has your administration taken
any such action against lenders?
Secretary Spellings. On inducements?
Mr. McKeon. Yes.
Secretary Spellings. Well, as I said, the statutory burden
that I have to prove and that is brought to bear by me is a
difficult one to prove. However, obviously, all these various
other things that are going on with attorneys general around
the country and the like are brought to bear under state laws
and various other enforcement authorities. So to the extent
that that might implicate other lenders, I am not aware.
I do want to say quickly that we have contacted the
Attorney General's Office in New York and asked him for all the
information that he has found, and he has made one contact with
my inspector general's office with respect to personnel
matters, but I am very anxious to get what information he has
and, as I said in my opening statement, have sent teams to the
44 institutions that we have read about in the paper, and I am
anxious to get what information he might have internally.
Mr. McKeon. Madam Secretary, last week, the testimony of
Dallas Martin, president of the National Association of Student
Financial Aid Administrators, before the Subcommittee on Higher
Education, Lifelong Learning and Competitiveness, stated that
the department has never fined an institution of higher
education for lack of administrative capability and that had
the department done so schools would not have accepted help
with staffing in the financial aid office or with call centers
or brochures.
Do you think that is true? And in light of his testimony,
do you plan on fining more schools for lack of administrative
capability if someone at the U.S. Department of Education
believes the institution needs more staff in the financial aid
office?
Secretary Spellings. Well, I would say a couple of things
about that. One is, that that is something that we do look at
as part of the reviews of the programs, and since 2004, we have
assessed citations or fines at 124 different instances of those
matters, to the tune of nearly $4.5 million.
However, having said that, I mean, the staffing of
universities is not within the purview of the Department of
Education, and so while it is something we certainly look with
respect to capacity adequately serving students and eligibility
for these programs, yes, but in the aggregate of how many
people does it take at the University of Texas to run a
program, that is certainly in their jurisdiction.
Mr. McKeon. Madam Secretary, did you ever imagine you would
be expected to be the ethics police for our nation's colleges?
Secretary Spellings. No, Congressman. I didn't imagine it,
and I don't think I am. I think the academy has a role to play
here and should. In fact, I have found in some cases the
silence to be a little deafening, and I think they can do more
internally through codes of conduct at institutions or state
legislative policies or higher education governing board
policies and those sorts of things. But it would be
imponderable for me to be fully aware of the individual
situations of staff and financial aid officers and more than
6,000 different colleges and universities in this country.
Mr. McKeon. Are you surprised that our colleges have not
been addressing the ethics issues that have been written about
in the press?
Secretary Spellings. Well, I think I am encouraged when I
see that when it is called to their attention they have gone to
work. Obviously, it is not in their interest to have a lack of
credibility and lack of confidence around their good
reputations. And so I think they have sprung into action in
those isolated cases.
I do think they can do more. I think there can be codes of
conduct put in place and so forth, and I will urge them to do
so.
Mr. McKeon. I said in my opening statement that I hope that
what we could get out of this kind of a hearing is a chance for
us to work together to get action to stop bad acts that have
taken place and move forward together. Because, really, all of
us should be focused on what is best for the young people or
sometimes not so young people in our nation that are trying to
get an education to better themselves to achieve the American
dream. That should be our focus, in my view, not to play gotcha
with things that have happened in the past, unless we use it as
a learning thing to move forward.
I really am concerned that some of the things that have
been written, some of the things that have been said, even some
of the things that have happened in hearings here tend to paint
a bad light on 6,000 schools when it may be just a very small
number of those that are really doing things they shouldn't be
doing. The same with the number of lenders. Yes, the ones that
are out of line, that are doing things that are violating the
things that the chairman talked about that we all agree on,
those should be taken care of. And the bill, I think, that we
passed yesterday in the House moves to help that.
Yesterday, the New York Times quoted Terry Hartle, a former
Kennedy staffer and current senior vice president of the
American Council of Education, as saying many of the problems
that have come to light had not been considered a problem
before. Lots of things that were seen as acceptable 3 months
ago are no longer regarded that way.
Why do you think that is? Are things really as bad as the
press would like us to think or is this political theatrics?
Secretary Spellings. Well, Congressman, I will let others
be the judge of that, but I do think what is, kind of, a
teachable moment out of all of this is that we have learned
there is major room for improvement in all of this, and I do
think that there has been some service in that.
I do think, in light of your comment previous to that as
well as the one you just made is, that it is hard enough to get
kids qualified and interested and unintimidated enough with
accessing higher education in the first place. And we need to
do all we can to provide a lot of confidence and a lot of sense
of security around that process.
And we must understand, kind of, the macro level policy
picture here, which is not just about a special allowance
payment but how all of this fits together for kids, how easy it
is, how early it is, how rich the package of benefits are with
respect to the level of a Pell Grant or whatever, transparency
about choosing an institution, issues about quality.
I mean, I think there is a whole lot of grist for the mill
here, and I think it would be a missed opportunity if we only
jumped on just one narrow aspect. And I hope we won't, and I
know we won't, and I really commend you all for the step you
took yesterday.
Mr. McKeon. I have one final question, and then I want to
yield time to Mr. Keller, the ranking member on the
subcommittee.
One of the concerns that I have had is that people that are
giving up their time, they could be working in private
industry, but they come to work for the government, not so much
out of how much money they could make or how much power they
can enjoy but out of a dedication really to serve.
Madam Secretary, I see from the press that your chief
operating officer, Terri Shaw, just resigned, although I
understand from your announcement she told you back in February
that she intended to resign. Yesterday, The Washington Post
quoted Michael Dannenberg, a former Kennedy staffer and
longtime critic of the FFEL Program of saying, ``Her tenure has
been characterized by lack of oversight and negligent
administration of the Student Loan Program.''
And even Senator Obama felt compelled to comment and
implied that Mrs. Shaw was more interested in helping banks
than students.
Would you care to react to that statement?
Secretary Spellings. I would, and I want to thank Terri
publicly for her service these last 5 years as the head of this
performance-based organization, the FSA. She is not a political
appointee, is not confirmed by the Senate, serves in that
capacity of one of three performance-based organizations.
She did come to me earlier this year--her term is expiring
this summer--and indicated her desire to leave somewhat short
of that for personal and family reasons.
She has had a major hand in seeing this organization
removed from the high risk status that they were under for
years and years. You all will remember the stolen credit card--
I mean, the stolen computers and the credit cards and on and on
and on, the 61-inch television purchased, et cetera, as well as
these five clean audits.
And I think she has given good service to this government.
I look forward to finding a strong manager and someone with
expertise to replace her, and we will work hard to do that
quickly so we can all get about this business of making sure
this program is one of great integrity.
Mr. McKeon. Thank you very much.
Mr. Chairman, I would like to yield time now to Mr. Keller.
Mr. Keller. I thank the gentleman from California for
yielding.
And I thank you for being here, Madam Secretary.
I am going to ask you a series of specific questions, but
to put it in perspective, I think there is some confusion that
I read about in the news media about the $85 billion student
lending industry. In reality, about $60 billion of that is the
Federal Stafford Student Loans, which is roughly 70 percent of
the $85 billion. And a much smaller percentage are these
alternative private loans, which are not federal loans
guaranteed under Title IV of the Higher Education Act.
The principal and almost exclusive focus of the New York
Attorney General Cuomo was on these alternative private loans,
which aren't governed by the Higher Education Act.
And when he was here, he talked about students being hurt,
and I asked him specifically, ``Do you have any evidence of any
student receiving a federal loan under title IV being hurt as a
result of paying a higher interest rate or higher origination
fee than the federal law allows,'' and he said, no, he didn't
have any of that.
He did say that there were one or two schools that only had
one FFEL lender and he hoped that they would have more. I think
we can all agree on that. But even then no evidence anyone was
hurt.
So with that as background, let me ask you a few questions.
As a U.S. secretary of education, do you have jurisdiction to
conduct oversight and regulation of these alternative private
loans which aren't federal loans guaranteed under title IV of
the Higher Education Act?
Secretary Spellings. No, sir, I don't.
Mr. Keller. Okay. And you cannot, on your own, even if you
wanted to, go out today and promulgate a bunch of regulations
which essentially say that you want to apply the Higher
Education Act anti-inducement provision to these private
alternative consumer credit loans because you don't have that
legal authority. Is that correct?
Secretary Spellings. That is correct, but I do think it is
appropriate that as a member of the president's cabinet, and I
have said today that I intend to work with the chairs of the
SEC, the FTC, the FDIC, among others, to make sure that we have
a system of integrity throughout the government.
Mr. Keller. Right. And, in fact, you know that we passed
the Sunshine Student Loan Act yesterday by an overwhelming
margin, which would, for the first time, give you some
oversight over some of these loans. For example, you would, for
the first time, be able to issue a fine of $25,000 to colleges
or non-federal lenders which have violated the provisions of
that law. Are you familiar with that?
Secretary Spellings. Yes, sir.
Mr. Keller. But as of this date, you don't have that
authority, obviously, because we haven't passed it through the
Senate, and it hasn't been signed into law by the president,
correct?
Secretary Spellings. That is correct.
Mr. Keller. So with that as background, I was somewhat
perplexed at the testimony on April 25 from New York Attorney
General Andrew Cuomo, who said, ``The U.S. Department of
Education has been asleep at the switch. The entity charged
with maintaining the integrity of the student loan market
failed. The failure of the department to pass adequate
regulations is disappointing and irresponsible.''
Prior to that testimony by the attorney general from New
York, Cuomo, on April 25, did he ever call you and say, ``Hey,
Margaret Spellings, this is your fellow former cabinet member
here, and I just want you to know that I think you have been
asleep at the switch as head of the U.S. Department of
Education''?
Secretary Spellings. No, sir, he didn't. And as I have
said, his office had one contact with one individual in my
inspector general's office around a personnel matter only,
which is the subject of an inspector general investigation. But
that is the only contact we have had. We have sent letters,
made calls and received late last night a letter from his
deputy.
Mr. Keller. And prior to that April 25 hearing, Attorney
General Cuomo never called you to say that you have failed to
maintain the integrity of the student loan department?
Secretary Spellings. No, sir, he has not.
Mr. Keller. Prior to April 25, he never called you and said
that he is disappointed in you and you have been irresponsible
as head of the Department of Education?
Secretary Spellings. No, sir, he has not.
Mr. Keller. Now, after that appearance, he then went out
and had a press conference on April 25 and issued a press
release, which I have here, dated April 25, entitled, ``Cuomo
Testifies Before House Education Committee on Student Loan
Industry. Cuomo says Department of Education Asleep at the
Switch.'' And then he goes through in three separate times here
says that your department has been asleep at the switch. ``I am
not quick to criticize, but I believe in this case the
Department of Education has been asleep at the switch.''
Since that press conference and this press release on April
25, has Attorney General Cuomo ever called you to have any
discussions with you about improvements you can make?
Secretary Spellings. No, sir, he has not.
Mr. Keller. Okay. Well, I have had a chance to look at the
record, as you might imagine here, and I can tell you from
reviewing it that the U.S. Department of Education under your
leadership has a far better record of oversight than existing
during the Clinton administration. And I could give you several
examples but I am limited on time so I will just give you one
to start with.
Ever since you have been in charge of the Department of
Education, the GAO has removed the Student Financial Aid Office
from their high risk list for programs which are at risk of
waste, fraud and abuse. The Department of Education under the
Clinton administration in 1992 to 2000 was on that list
consistently.
And since Attorney General Cuomo was so critical of you as
a cabinet secretary, I thought, well, let me just take a look
at his record. And then I saw that he was the secretary of HUD
from January 1997 to January 2001 and guess what? The GAO put
his entire department on the high risk list for waste, fraud
and abuse.
So I guess the moral of this story is that people who live
in glass HUD houses probably shouldn't being throwing stones.
Let me ask you a little bit about the direct lending versus
FFEL. Would you agree with me that there is room for the
existence and healthy competition for both of these programs,
direct lending and FFEL, because they improve together customer
service and lower costs for students and taxpayers?
Secretary Spellings. I absolutely would, and I think we
have a lot of good arguments that would show support for that.
Lots of consumer choice.
Mr. Keller. Since I have laid out some of the criticisms,
let me just ask you, do you feel that you have been guilty of
lax oversight or you have somehow been asleep at the switch?
Secretary Spellings. No, sir, I don't. In fact, some have
said I am the most active secretary of education in these
higher ed matters that has been seen for a long time.
Mr. Keller. Okay. I believe Congressman McKeon's time has
expired but----
Chairman Miller. The gentleman's time has expired. Mr.
McKeon's time has expired.
Mr. Kildee?
Mr. Kildee. Yes, sir. I yield 30 seconds to Chairman
Miller.
Chairman Miller. Well, since the defense of Clinton made me
do it, I thought we would enter Mr. Clinton's 2001 budget where
he also asked for the repeal of the 9.5.
And the question of whether or not the beat goes on, again,
Cuomo announced that he has entered into a cooperative
agreement today with CIT and Student Loan Xpress where they
have agreed to join him in the investigation of those two
entities on a cooperative basis of Student Loan Xpress and of
Matteo Fontana, the Department of Education official who
received stock and other benefits from Student Loan Xpress.
Mr. Kildee?
Mr. Kildee. Thank you, Mr. Chairman.
Madam Secretary, greed is a vice that every human
institution has to guard against, including the Congress
itself, obviously. The problem with the student loans and the
Reading First really are worded in greed. And vigilance is a
great guardian against greed. We read in scripture, who will
watch the watchman?
One would hope that someone decides the inspector general
would be vigilant. Oversight within a department really has to
come from the top down. There are only two people involved in
the day-to-day administration of the Reading First Program, and
most of the work was contracted out by the department.
Why did the department fail to provide the appropriate
resources to this very vital program, which distributes roughly
$1 billion per year? And what has the department done to ensure
sufficient resources are now being devoted to Reading First?
Secretary Spellings. Well, Congressman, I think the Reading
First Program is one of the hallmark accomplishments of No
Child Left Behind and it has caused great improvement in
reading instruction for kids. It is a national program. The
contracted efforts largely have centered around regional
technical assistance to make sure that users in states and
districts have access to guidance and technical assistance as
they have implemented that program.
It was certainly something that we did with expertise from
throughout the country and in the field.
Mr. Kildee. But I think that within the department there
was a big change. You had two people really in a day-by-day
basis watching it. Within the department the vigilance has to
be there, and when the inspector general uncovers these things
and the inspector general tells us that matters were such that
he had referred much of this problem or some of this problem to
the Justice Department, that is indicative that there could
have been greater vigilance.
Secretary Spellings. Well, I certainly agree that there is
much room for improvement in the oversight of that program.
That is why I adopted every single aspect of his inspector
general's report. I have worked hard to put changes in place,
including making personnel changes, instituting training
programs for my staff, safeguarding the peer review process,
reaching out to states and on and on. I do think improvements
can and should be made. I think it is obviously very
detrimental to a very effective program when that sort of thing
is called into question.
Mr. Kildee. Within your department have you asked yourself,
who is watching the watchman? There has to be a system. It is
great to have an inspector general, we have inspector generals
for our departments, but when it reaches that level and we find
some problems there, there has been some problems above that,
what structurally have you done to try to avoid those problems
in the future?
Secretary Spellings. Well, I have increased the staff from
two, that you mentioned, to seven people who work as part of
the embrace of the inspector general's work. I can tell you at
the time, this early implementation happened, kind of, in the
2002-2003 timeframe. Obviously, Secretary Paige was at the
helm. There was a deputy, there was a person who was in charge
of elementary and secondary education and then Mr. Doherty, who
was here before you a few weeks ago, who managed the program.
Mr. Kildee. Well, I appreciate what you are doing and I
really--wherever there is money and wherever there are people
we have to say guard against greed, because greed is the root
of all these things. And I think that your department, you are
entrusted with an enormous amount of taxpayer dollars for
programs that are very, very important. And No Child Left
Behind Reading First is such an important element.
Secretary Spellings. Absolutely.
Mr. Kildee. So I commend you for increasing the number of
two to seven, but I think you have to help breed an increasing
culture within the department to watch for these possibilities
where greed leads to the loss of taxpayer dollars and a
weakening of the program.
Secretary Spellings. I certainly intend to do that, and no
one is hurt more by that lack of confidence than me and my
department and the senior management of it and then
specifically, kind of, a lack of confidence and the ability to
invest in these very effective programs. And I regret that.
Mr. Kildee. Thank you, Madam Secretary.
Mr. Keller. I thank the gentleman for yielding.
I started to ask you, Madam Secretary, if you felt that you
have done a good job with oversight and I believe you said you
think you have done a good job with oversight?
Secretary Spellings. Yes, sir.
Mr. Keller. Isn't it true that you guys have under your
leadership already started performing on-site reviews at 44
different colleges with respect to 26 separate lenders relating
to the anti-inducement provisions of the Higher Education Act?
Secretary Spellings. Yes, we have. I mentioned that in my
opening statement, and I would be anxious to get whatever
internal information General Cuomo has that might aid our work
in that regard. But we have sent teams to every single one of
those institutions, yes.
Mr. Keller. Well, I hope you now get a call from Attorney
General Cuomo.
Secretary Spellings. With your help.
Mr. Keller. I know the press release that I read was one of
15 press releases that he has issued only since February 1 on
the student loan issue, so I know he has got some free time. I
hope he picks up the phone and calls you.
Let me then ask you about some of this allegation of being
too close with some of the FFEL lenders, because some of the
people who used to work in the lending industry now work at the
Department of Education, and some people are upset about that,
which to me is like saying if you used to be a farmer and you
know what you are talking about, you are not allowed to go to
work at the Department of Agriculture.
So with that said, isn't it true that during the Clinton
administration that you had some senior former student lending
executives, like Barry Morrow with Sallie Mae and John Reeves
as president of a large lender called Educaid who went on and
worked in the Clinton administration student loan department?
Secretary Spellings. Yes, sir. There obviously have been
people from various organizations that have served at the
Department of Education in this administration and the one
previous.
Mr. Keller. Okay. And in terms of cracking down, I know you
had one instance where you put an employee on administrative
leave when you learned that they had certain stock by a lender,
and some people might want to inquire, ``Hey, why didn't you
just fire that person?'' Isn't it true that in reality that
person actually had acquired that stock well before even
joining the Department of Education?
Secretary Spellings. Yes. And, obviously, we count on--I
mean, the burden is on the individual, as it is on all of us,
to complete the 278 form to be accurate and honest in the
reflection of what holdings they have.
And to the extent that Mr. Fontana did not meet that
standard, I have asked the inspector general to review that
case and have in the meantime put him on administrative leave.
Obviously, we live in a country where you are innocent until
proven guilty, and I will be glad to report back to this
committee about what the inspector general finds.
Mr. Keller. Okay. Thank you.
Let me walk through some of the provisions of the Sunshine
Student Loan Act, and the reason I want to is I know your task
force hasn't reached a final consensus, and so I want to see
how comfortable you are with what we have agreed to here.
First, with respect to preferred lenders, under the
Sunshine Student Loan Act, it says you can still have a
preferred lender list, but you have to have at least three FFEL
lenders and you have to explain why they were selected and why
it benefits the students.
That is something pretty consistent with your task force
recommendations. Are you comfortable with that provision?
Secretary Spellings. Absolutely. In fact, in my statement,
I said that I am moving forward and will post those in the
Federal Register very shortly, and they will become effective
in November.
Mr. Keller. Great. Also, the Sunshine Student Loan Act
provides a code of conduct which essentially says there can be
no conflicts of interests, gifts or revenue sharing between
lenders and the colleges or their employees. Are you
comfortable with that language as well?
Secretary Spellings. Yes, sir.
Mr. Keller. Okay. Some people, in light of the somewhat
unrelated scandal up in New York, have said that, well, maybe
we should just completely abolish the preferred lender list and
do away with it, and I want to ask you about that.
I am concerned about that approach, because if you are an
18-year-old freshman in college, the preferred lender list
really creates order out of chaos. There are over 1,000
lenders, and some of these lenders provide very low interest
rates, low origination fees, are very flexible when you want to
defer payments and have great customer service. Other lenders
may have higher rates and fees, bad customer service and could
be characterized as somewhat fly by night operations.
So as long as the preferred lender list is done right, I
think it is a pretty good idea sometimes to have a financial
aid administrator who has been doing that job for 2 or 3
decades to be able to give these 18-year-olds some advice on,
``Here are four or five lenders that we think are pretty
good.'' Would you agree with that assessment?
Secretary Spellings. Absolutely agree with you.
Mr. Keller. Okay.
I am sorry, my time has expired, Mr. Chairman.
Chairman Miller. Mr. Andrews?
Mr. Andrews. Thank you.
I thank the secretary for her testimony.
Madam Secretary, you were confirmed in the first quarter of
2005; is that right?
Secretary Spellings. That is correct.
Mr. Andrews. And when you were confirmed, was Ms. Shaw the
chief operating officer of the student aid operation?
Secretary Spellings. Yes, she was. She is in a 5-year term,
which will expire this summer.
Mr. Andrews. I assume that you met with her when you first
came aboard and did you ask her were there any outstanding
audit issues or problems with her area?
Secretary Spellings. In January of 2005, we had just been
removed from the high risk list----
Mr. Andrews. Right.
Secretary Spellings [continuing]. Which she had worked very
hard to do, so I was very encouraged by that then recent event.
But, certainly, I asked her about the work of her operation, as
you would expect me to as a manager.
Mr. Andrews. Did she indicate that there were any
outstanding issues from the inspector general of the
department?
Secretary Spellings. I don't remember that we talked
specifically about individual aspects of particular ongoing
inspector general reports, but, certainly, those have since
come to my attention, and I do talk with her about it. Whether
I did it in January 2005, in the first quarter, I can't recall.
Mr. Andrews. Okay. On August 1 of 2003, Cathy Lewis,
assistant inspector general of the department, sent a memo to
Sally Stroup, called an alert memorandum, and I am going to
quote from that.
It talks about a review that had been done and it says,
``Our review,'' meaning the IG of your department, ``concluded
that there are bargaining practices between schools and lenders
for FFEL preferred loan status and private loan volume that
should be addressed through statutory and regulatory changes or
further department guidance. Given the current marketing
practices by schools and lenders, the department should examine
the roles and responsibilities of schools as well as lenders
and lender affiliates in the inducement issue.''
Between your tenure, beginning in the first quarter of 2005
and January of 2007, did you take any actions at all in
response to that report from the inspector general?
Secretary Spellings. Well, yes, Congressman, absolutely.
And my inspector general at FSA, there are many, many technical
things, much of which has been worked through to the
satisfaction of the inspector general, and some of those remain
open.
Mr. Andrews. So what did you do prior to January of 2007
about this report?
Secretary Spellings. Well, I give to you a lengthy list of
the various steps that have been taken around particular
issues. As I have said, some of those have been reached to the
satisfaction of the inspector general and some of have not, and
we continue to work on those.
Mr. Andrews. Well, let me ask you specifically----
Secretary Spellings. But also may I mention quickly that--
--
Mr. Andrews. Yes.
Secretary Spellings [continuing]. The negotiated
rulemaking, of course, that we initiated last August is an
important thing to call attention to, and certainly we put
specific language on the table, in December, for the
negotiators to consider----
Mr. Andrews. Did you assign any of the investigators or
analysts from the department to do the examination the
inspector general asked you to? Did you send them out to look
at schools or lenders to see if these inducement payments were
taking place?
Secretary Spellings. We have thousands of monitoring visits
that occur from year to year. Some of them are in the arena of
inducements. You have heard me get asked about administrative
capacity and staffing, among other things.
Mr. Andrews. I understand that, but you have a specific
recommendation from your inspector general that dates back to
August 1 of 2003 when you were not there, when you were not
there, that says that the specific problem of inducements in
the bargaining practices between schools and lenders should be
looked at.
I am asking you to submit to the committee anything that
you have, any document, any e-mail, any documentary evidence
which shows what the department did in response to that
specific report of August 1, 2003. Because I see a flurry of
activity starting in January 2007 when this becomes a public
issue. But I am specifically wondering, did you meet with Ms.
Shaw and talk about this issue prior to January of 2007?
Secretary Spellings. I spoke with her about many things,
including inducements, in the entire operation. I will
certainly provide that analysis to you, but I have three
examples--April 2004, March of 2006 and April of 2007--about
three specific issues related to impermissible inducements.
Mr. Andrews. Okay. So what did you do in April of 2004?
Secretary Spellings. Marketing practices that U.S. Bank
National Association violated anti-inducement provisions of the
HEA. The bank was required to cease those practices, prohibited
from making payments, required to obtain the pending
applications from the borrower.
Mr. Andrews. So it sounds like you did have authority to do
something about it. How many of those enforcement actions did
you direct the department to conduct between January of 2005
and January of 2007?
Secretary Spellings. I don't have a specific number off the
top of my head. I will get that for you. As I said, these are
cases where that very high hurdle, that very strong threshold
has been cleared.
Mr. Andrews. I understand. My time has expired.
I would just, Mr. Chairman, make the comment that perhaps
Mr. Cuomo came in and filled a vacuum that existed before this
happened, and I would be curious to see whether the vacuum
existed or not, and I am sure the secretary will show us.
Secretary Spellings. Thank you, Congressman.
Chairman Miller. Mr. Castle?
Mr. Castle. Thank you, Mr. Chairman.
Madam Secretary, I have a lot of respect for you and the
job that you have done, but obviously there are some problems
here, and one of my concerns is how can we resolve some of
these issues as far as the future is concerned.
I am looking at the president's fiscal year 2008 budget
request, and in it he has some reductions in a variety of
categories--special allowance lender insurance, exceptional
performer, lender paid origination fee, collection retention,
et cetera.
I assume this was prepared with consultation with your
department and that you are in favor of all of these changes;
is that correct?
Secretary Spellings. Yes, that is right.
Mr. Castle. Are you also in favor of all of the changes in
the bipartisan Student Loan Sunshine Act, which was the bill we
passed yesterday, in case you don't recognize the name?
Secretary Spellings. I do recognize the name, and I think
it is a great step in the right direction, Congressman.
Mr. Castle. Yes. I actually do too, and I congratulate the
chairman and the ranking member for their good work as far as
that is concerned.
I will tell you my problem with all of this: I mean, I
don't like the lending problems, I don't like the conflicts we
have heard about----
Secretary Spellings. Me neither.
Mr. Castle [continuing]. Either within or without the
department. All these things concern me a great deal.
I have been on this committee for a while now, and to me it
is very confusing to really be able to follow the bouncing ball
with all these different programs. You indicated, I think,
there are 20 programs which aid students earlier, and you
indicated there are layers and layers of inefficiencies. And
you also said that you are convening chairs to end student
abuse and I know you have had some things going on with respect
to that.
Don't we need a big bang solution here? I mean, do we have
too much out there in terms of the offerings? I mean, I am just
really surprised at all the different methods by which a
private lending institution can make money in this.
I mean, I think even I could put together a lending
institution and make money on it with these provisions. Not
that anybody would be dumb enough to borrow from me, but it
just seems to me that there are a lot of problems with respect
to that. There is a lot of conflict with the Direct Lending
Program versus using the private banks.
Should we be doing something different to make it simpler?
I mean, I am all for transparency, I think it is highly
important, and choice, but is it just such a complicated system
that we have put together that it just doesn't work well for
the students and their families?
Secretary Spellings. I think, absolutely, and I think the
student is the one that suffers. You have seen my picture over
here of all the various aspects here, the various grants, the
various loans, and then on top of whatever state aid there is
or institutional aid. So it is highly complex and confusing.
I have fairly recently issued an RFP to take a look at a
more comprehensive system of streamlining how that might work,
just as a matter of good policy and sound management, but I do,
I think it is very, very complex for the borrower and subject
to abuse, particularly in a time of rapidly increasing costs,
which is much and much less covered by federal grants.
Mr. Castle. Well, I would hope in all this, I mean, I hope
we would really push on simplification, which I hope would
reduce bureaucracy, inefficiency and then reduce some of the
costs of all of this, particularly to the consumer, so,
ultimately, we could have lower interest rates, which are
guaranteed after all, but lower interest rates being paid by
these students and by their families.
But let me change subjects for a moment here. You mentioned
in your opening that I think in the last 25 years the cost of
college has gone up 400 percent.
Secretary Spellings. Four hundred percent.
Mr. Castle. Which is far above the cost of living. And I
don't know what that would be on a compounded basis, but it
would be 14 or 15 percent or something of that nature, which to
me is astounding. And I have talked about this before, but I
have never really been satisfied with it. And it just seems to
me that you have the bully pulpit, we have the bully pulpit,
the president has a bully pulpit, that this is more than just
problems in the lending industry.
And I would hope that as part of this overall problem of
simplification and trying to deal with the lending practices,
that we could also try to work on holding down the costs of
higher education and use these bully pulpits to make sure they
understand that they have got to keep their cost reductions in
line, at least with the cost of living, if not less.
Is anything happening along those lines at this time?
Secretary Spellings. Yes, and I think, absolutely, use the
bully pulpit, but I think we ought to do more, and I think a
big first step, a great first step is more transparency. The
president asked for $25 million to start doing some pilot
programs about better data and information systems so that
parents can be confident when they look at information in the
IPEDS database about completion rates, about post-graduate
employment and things like that that might be brought to bear
for more effective, more prudent consumers.
In addition to that, we have asked for resources and some
of this is going on in the field, and I appreciate that
leadership. As to the value added by the learning experience,
after a mom or dad spends hundreds of thousands of dollars for
an education, is their kid coming back home to live with them
or did they actually know how to think, cipher, write, compute
and so forth that is going to be necessary for the workforce.
So I think we have to have a lot more information, and I
think that will be a good first step in helping get a handle on
some of these cost issues.
Mr. Castle. Thank you, Madam Secretary.
Thank you, Mr. Chairman. I yield back.
Chairman Miller. Mr. Hinojosa? The gentleman is recognized
for 5 minutes.
Mr. Hinojosa. Thank you, Mr. Chairman.
Madam Secretary, the actions that you have reported taking
for the Reading First will primarily address the future
management and the operations of that program. However, the
current impact of the conflicts of interest and the
inappropriate involvement in curriculum by the department and
its contractors has not been addressed.
What affirmative steps will your department take to inform
the states that were coerced into using certain products that
they may have the option of expanding or modifying their
Reading First Program to incorporate other tools and materials
that are research-based?
Secretary Spellings. In the aftermath of the inspector
general's report, which I told you I embrace completely, at his
suggestion, and I certainly heeded it, had engaged with each
and every single state in our country about areas where they
found problems or recommended improvements, and we have done
that. And I am pleased to report that the vast majority of
states and school people are highly supportive of Reading
First.
Can we make improvements? Should we make improvements with
respect to subcontractor relationships, as has been brought to
bear by the investigation yesterday? Yes, we can and we should.
But I also want to put in the context that this is a state
program. We fund states who then, in turn, make decisions as to
local school districts about curriculum products that are
purchases by them or by the state. It is usually by the school
district. And so I am not sure yet, and certainly intend to
look at very carefully, about particular ethical violations
that might have occurred in that context. But if it has, I
certainly intend to take strong action about it.
Mr. Hinojosa. So will you ask and inquire as to see what
individuals in different states, such as my state of Texas, did
things that were unethical and that were not under your
instructions? And if so, what actions are you going to take to
penalize them?
Secretary Spellings. The allegations that have been brought
to our attention have to do with the potential conflicts of
those who were offering technical assistance in a regional
sense, and I intend to investigate those. I do not have
evidence as of yet that there has been any violation or misdeed
by any state official with respect to that. In fact, this law
builds in a lot of authority for states to make curriculum
decisions and purchase products as they see fit, and they have
across the gamut of various products and programs.
Mr. Hinojosa. I want to now go to the student loans. This
administration focused on culture of accountability for state
education agencies, school districts and now colleges and
universities. However, when it came to enforcing and regulating
against prohibited inducements, your department's preference
was to have the lending community police itself. Why this
double standard, and who should be held accountable in the
administration for failing to curb these abuses?
Secretary Spellings. Congressman, I would disagree with
your assessment that we let the lending community police
itself. We have conducted thousands and thousands of reviews
and program audits. We have assessed fines. We have sanctioned
and cited various violations, including the three that I just
mentioned to Congressman Andrews about inducements.
Can we do more, should we do more? You bet. I am an
accountability-oriented person, and that certainly applies to
the student loan business as well.
Mr. Hinojosa. Well, on this question, we will just have to
agree to disagree, because there is too much evidence of
wrongdoing.
Now, I will ask you another question on the use of private
loans. Private student loans have become a larger percentage of
the new loans over the last few years. Do you believe this is
and should be a concern, and should they be allowed to flourish
unregulated in this current environment?
Secretary Spellings. Well, I do agree that, as I said, in
this sort of complicated process as the Pell Grant has failed
to keep up with the very rapidly increasing cost of college,
there has come to be more reliance on the private loan sector.
Those loans are not overseen by me and my department but by
other regulators--the FTC, SEC, Federal Reserve and on and on--
as well as state attorneys general as part of their deceptive
trade practices or whatever banking laws and consumer loan laws
might apply in those particular cases.
Mr. Hinojosa. Your chart indicates that it has about $16
billion worth of business----
Secretary Spellings. That is correct.
Mr. Hinojosa [continuing]. And growing very rapidly. So it
seems to me that if your department doesn't have authority and
oversight and our committee doesn't either, then there will be
another committee, Financial Services, that could certainly
look into this and take whatever action necessary to regulate
them.
Secretary Spellings. I hope they will. As well, I said I
would convene my colleagues from those various other agencies,
and you all certainly took some steps yesterday in the passage
of the law that Congressman Miller authored.
Mr. Hinojosa. I yield back.
Secretary Spellings. Mr. Fortuno?
Mr. Fortuno. Thank you, Chairman Miller.
And thank you, Madam Secretary, for being here with us
today. I appreciate, certainly, you taking the time to address
very important issues as to the laws in Reading First. However,
as the only congressman from Puerto Rico, I will try to bring
it closer to home, if I may, certainly as it relates to Reading
First and related programs in my district, in Puerto Rico.
I am very concerned with the chronic mismanagement within
the Puerto Rico Department of Education, and my concern is that
over 575,000 American citizens who attend the public school
system in Puerto Rico are being shortchanged while very few in
San Juan and Washington seem to care about their fate and the
improper use of taxpayers' money by the Puerto Rico Department
of Education.
Time and time again I have raised before this committee and
your staff clear evidence that the Puerto Rico Department of
Education is underperforming. I must have a parentheses here. I
must commend Julia Phillips from your congressional relations
staff. She has tried really hard, and we will keep trying
really hard, and that is what I am trying to get to.
But let me give you some examples. First, there exists
clear evidence that the Puerto Rico Department of Education is
not complying with AYP requirements. This past March, your
department sent two letters to the department down there
detailing violations of NCLB's AYP requirements and stated they
will withhold over $800,000 as administrative fees in
punishment. Clearly, the Puerto Rico Department of Education is
not meeting NCLB standards in this case. Actually, less than
half of the public schools there are meeting it.
Are you aware, Madam Secretary, that--and I would like to
certainly have some questions to be answered at the end in
writing, ideally--that of all jurisdictions within our nation,
Puerto Rico Department of Education sends the most funds back
to Washington annually? In the past 2 years, the department has
returned over $35 million in federal funding to the U.S.
Treasury due to mismanagement.
Additionally, the department at the state level has
consistently ignored the needs of our special education
students. In March 21 of this year, the Education and Labor
Committee hearing here, I shared letters with Chairman Miller
and Ranking Member McKeon from Ms. Maria Miranda, who is the
director of the Technical Assistance Program at the University
of Puerto Rico, and Mr. Alpidio Rolon, who chairs the Puerto
Rico chapter of the American Federation of the Blind.
In his letter, Mr. Rolon wrote, ``The Department of
Education''--he is talking about the Puerto Rico Department of
Education--``states that 29 blind students out of 439 received
brail books during 2006-2007, clearly, failing their
responsibility to the students with special needs.''
Puerto Rico is also the only jurisdiction in the nation not
to participate in the Reading First Program, believe it or not,
a key NCLB program designed to assist students attending K
through third grade. Puerto Rico is standing to lose more than
$207 million in federal funding due to both their refusal to
comply with federal guidelines and repeated failure to submit
successful applications.
And, finally, the recent NAEP scores are dismal. NAEP
results also show that the majority of students in Puerto Rico
fall short of demonstrating basic achievement in math, which
indicates partial mastery of the knowledge and skills needed
for proficiencies in the subject. Only 9 percent of fourth
graders and 4 percent of eighth graders reach basic level. Less
than 1 percent of students reach the proficient or advanced
levels of achievement. These are among the lowest scores in the
nation.
Madam Secretary, I have three questions for your, and I
would rather, if it is possible, have answers for the committee
in writing. I know that you are probably not prepared to
address them all.
First, in your view, what continues to be the chronic
problems that plague the department in Puerto Rico and prevent
them from doing a better job? Specifically, how do you and your
department plan for better federal oversight of the Puerto Rico
Department of Education, given what I told you?
Second, my staff and the Congressional Research Service
have had continual problems obtaining reliable data on NCLB
implementation in Puerto Rico. My staff was advised by your
staff that Puerto Rico only recently agreed they needed to
update their data collection systems. The question is, what
progress have they made in that area and what will your
department do to have them get their act together?
Thirdly, how is your department helping them increase staff
retention in the Puerto Rico Department of Education? That is
another, actually, item that has been brought to our attention,
and they are having serious problems in retaining staff.
So, Madam Secretary, I would appreciate it if you could
send us back those answers.
Secretary Spellings. I would be glad to do that,
Congressman.
And it is a very regrettable and sad situation, especially
for the kids in Puerto Rico. As you have said, they lack
capacity in personnel, and they lack capacity in data and
management. As I know you want me to be a good steward of
federal tax dollars, they have to right the ship if they are to
participate in programs like Reading First.
And I pledge to answer those questions and look forward to
our work together and your leadership to right the ship there.
And I appreciate your interest.
Mr. Fortuno. Thank you, Madam Secretary.
I yield back. Thank you.
Chairman Miller. The gentleman's time has expired.
Mr. Tierney?
Mr. Tierney. Thank you, Mr. Chairman, Madam Secretary.
Madam Secretary, I am somewhat concerned about the whole
Nelnet situation, the special allowances payments on that. I
just look at the history of the failure of the department to
send out a clarifying letter over a period of time, though it
belatedly did, but I also note that on a Friday afternoon is
when the decision came down. We all know what Friday afternoons
are in terms of announcing decisions of what we are going to
do.
But the department decides to allow the company to keep
$278 million. It boggles my mind why we don't get the entire
amount of money back and what the excuse was to allow somebody
to get away with essentially theft of the situation and not
take the whole thing back, as your inspector general's report
clearly indicated should be done.
Secretary Spellings. Well, Congressman, I don't know that
you were in the room at the time, but, obviously, as I settled
this lawsuit, could we have taken a different point of view,
and you may have, certainly, that is the case.
But let me tell you the facts as I know them, which is that
we had continued to pay that organization, as well as others,
quarterly special allowance payments under the transferring
provision, a legal authority for first and second generation
loans. It was discovered by my inspector general that that
organization had abused provision and was doing something other
than that. You all have previously----
Mr. Tierney. But they also discovered that back in 2005
with respect to another organization, so it is not like this is
the first eye opening that the department had.
Secretary Spellings. There are four parts of the special
allowance payments, and so various ones of those were
implicated throughout the investigation in New Mexico and
Nelnet in this case.
The reason that I settled this lawsuit, to get to your
fundamental question, is because there was a risk of an
additional nearly $900 million that this government was at risk
of losing had we lost the lawsuit. This law has----
Mr. Tierney. So you totally disagree with your inspector
general who made a clear indication that they didn't think that
that risk was there and that you ought to collect the entire
amount. And that is also not the reason that Ms. Tucker gave on
her Friday afternoon expose on here when she indicated that she
thought it was because it would jeopardize the financial status
of some small nonprofit lenders on the situation, which would
boggle the mind, I think, if she is arguing that there is some
shortage of capital out there on the situation.
Secretary Spellings. Well, obviously, this particular issue
and case has implications for nonprofit and for-profit
organizations other than Nelnet.
Mr. Tierney. I hope you are not arguing seriously that
there is some shortage of capital out there that means that we
should tolerate theft in order to resolve this.
Secretary Spellings. No, clearly not. I made the judgment
that it was better to end, finally and with certainty, this
practice, to describe a methodology that the industry could
apply across the board.
Mr. Tierney. I hear what you are saying. I mean, I think
you were extremely belated in doing that, given the history of
this thing, but tell me what you didn't have confidence in with
respect to your inspector general's report who had the exact
opposite conclusion that you reached. You don't have confidence
in your inspector general?
Secretary Spellings. No, I have a great deal of confidence
in my inspector general. I don't agree with him 100 percent of
the time on every matter.
Mr. Tierney. Well, I am going to leave it at that, but I am
entirely uncomfortable with this, for the whole scenario of how
it occurred, the Friday afternoon release, the large amount of
money that was given here, the total disagreement with the
inspector general on this. I think it is very weak, the
presentation that you make on that, and I think we should all
be careful.
Mr. Chairman, I hope that we do some more oversight on that
issue alone and how many people were allowed to just take the
money and run as a result of that decision, which I think that
maybe we could have the inspector general in to find out what
it is that the secretary and the inspector general don't seem
to jive on.
Because you agreed in one instance, and when you took back
a certain amount of money you found that you were in total
agreement with his decision. Just going forward you apparently
had some problems letting them keep the money.
Mr. Chairman, I yield to you if you have some additional
questions.
Chairman Miller. In your request, there is a bipartisan
request in to further proceed on the Nelnet matter, given the
range of the money.
I am just a little concerned here that somehow the problem
here is Andrew Cuomo, and I just want to state for the record,
I think but for the attorney general of New York, Andrew Cuomo,
we wouldn't be here today. We would not have passed the
Sunshine Act, and the public would not be aware of the outright
incredible unethical, at a minimum, behavior, I think criminal
behavior in a number of cases, that not only is he
investigating but attorney generals all over the country and
the U.S. attorney are taking a look at where people have bribed
their way onto campus.
And to suggest that somehow he only dealt with the private
loans when in fact he told this committee that they are
connected, and we know that, well, they are connected when the
person says, ``We will give you private money if you give us
more federal access to the program,'' as Sallie Mae did, and
when you blew the whistle on them, they promised never to do
that again. Other lenders have been yelling about that practice
for a long, long time.
So there was a connection between access to private
lending, to campus and the federal program, and among the
larger lenders those programs have in fact been coupled.
And the suggestion that somehow that the problem is here
that Andrew Cuomo, who used to be the secretary of HUD, where,
by the way, he received many, many awards from national
organizations for innovative leadership of that department, is
outrageous to suggest that.
I suspect that the parents who are borrowing this money and
the students who are borrowing this money are very happy to
have Mr. Cuomo blow the whistle on this activity. I wish that
somebody else had done it prior to his doing it, somebody with
direct oversight of the department, but that didn't happen.
And since we are in a revisionist history here, let the
record show that but for the actions of Mr. Kildee and Mr. Van
Hollen who dogged on the floor the 9.5 problem, there would
have never been legislation on the 9.5, in spite of the
recommendation of the Clinton administration, in spite of the
recommendation of the Bush administration. Because the 9.5
lenders had it about the way they wanted it in the Congress,
but, finally Mr. Kildee and Mr. Van Hollen got the amendment
accepted in HHS and the rest is history as to what took place
there, finally in 2006, 2 years later, after Kildee and Van
Hollen had dogged them down.
So I would just like to straighten that part out of the
record.
And Mr. Petri is recognized for 5 minutes.
Mr. Petri. Thank you very much, Mr. Chairman, and I will be
submitting additional questions for a response for the record
by the secretary. Time is limited at this particular occasion.
Madam Secretary, you kind of inherited a whole series of
programs and our legal framework, and I know you are doing your
best within that to operate the department. I would like to
explore a little bit more with you the subject that has been
raised by the chairman and several others, and that is the
Nelnet situation.
They submitted, as I understand it, some $1,100,000 worth
of reimbursements under a 9.5 percent arrangement and did
receive some $278 million that they had and then you entered
into a settlement with them to basically stabilize the
situation where it stood, and they agreed to give up their
additional claims for the remainder of the $1.1 billion and the
department agreed to not ask for the $278 million back.
And as the chairman pointed out, if they were confident
that they could have got their $1.1 billion total, they
probably wouldn't have agreed to this agreement. So there is
clearly somewhat of a grey area.
The inspector general recommended that we attempt, as a
government, to collect the whole amount back, but there was
some element of uncertainty here, and you entered into that
settlement.
We asked the Congressional Research Service to review the
whole thing, and they basically seemed to indicate to us in
their study that your authority is total and complete. It is
not subject to review by us within the existing law, by the
Justice Department or anyone else. And that is not your fault,
that is our fault, really.
And we have a system with checks and balances. There are a
number of other outstanding claims, and under the current
situation, you are going to have to enter into a final
agreement that presumably could be subject to no challenge. So
you signed a check, in effect, for $278 million of taxpayers'
money. You have the authority to enter into similar agreements
that cannot be reviewed or challenged by anyone under current
law for I don't know how much.
Perhaps you could say how many outstanding claims are you
reviewing and, secondly, whether you think this is really sound
or whether we ought to review that and figure out if there can
be some sort of system of checks and balances or where the
Justice Department or some other people could do an independent
analysis or review to see if they think the government should
pursue these claims or they should throw upon you who may not
even have legal training the authority to enter into contracts
that are final.
Secretary Spellings. Well, I certainly can do that. As you
said, I do have the authority to enter into agreements such as
this. This is an $85 billion enterprise. Two-hundred-seventy-
eight-million dollars, I guess some might suggest, I certainly
would, that we may have saved the taxpayers another 800-and-
some-odd-million dollars in payments had we lost the lawsuit.
But, certainly, we can get you----
Mr. Petri. On that point, it is my understanding--I could
stand corrected--that, actually, Nelnet reserved the right to
reopen the agreement, but the Education Department gave up the
right to reopen the agreement, and it is final so far as the
government is concerned.
Secretary Spellings. And to the extent that you would like
us to look at various authorities that I have in comparison
with other departments and agencies, we can certainly do that
or the GAO can do that.
But, I guess, one of the things, and I certainly don't mean
this facetiously is, as a policymaker and administrator, on the
one hand, I hear you say, take immediate, aggressive action to
stop X, but don't use your judgment as the primary authority
over these programs to use it.
Mr. Petri. Well, ma'am, you didn't have to enter into an
immediate agreement. You could have just stopped payment and
let them sue you, and we would have been no worse off. So that
is not necessarily the case.
Do you have an idea of the total amount of potential claims
that are outstanding under this, similar to Nelnet?
Secretary Spellings. I certainly can get that.
Mr. Petri. How much more are we talking about?
Secretary Spellings. Obviously, there are many other
lenders that would be subject to that. That is why this final
and certain methodology that the inspector general endorsed was
so important to bring to bear virtually simultaneously in doing
that.
But, absolutely, I can get that information for you.
Mr. Petri. Thank you.
Chairman Miller. Mr. Bishop?
Mr. Bishop of New York. Thank you, Mr. Chairman. Thank you
for holding this hearing.
And, Madam Secretary, thank you for coming and giving us so
much time this morning.
I certainly share the concerns that my colleagues have
raised with respect to the level of oversight on the student
loan issue and on Reading First, but I want to focus in on an
area that is very troubling to the higher ed community,
somewhat more obscure, but has to do with a subject that you
have raised a few times this morning, and that is the
negotiated rulemaking.
It is my view, and I think this is shared broadly across
the higher ed community, that the department is using the
negotiated rulemaking process to achieve by regulatory means
that which the department has been unable to achieve by
legislative means.
And I think there are three examples of this, what the
department is attempting to do right now with transfer of
credit policy, what the department is attempting to do in terms
of what has been characterized in certain newspapers as a slow
bleed of the Perkins Loan Program and, lastly, what the
department seems to be attempting to do to impose what appears
to be a uniform standard, sort of a national level of
competence that all college students would be expected to
adhere to, as administered through the accreditation process.
And let me just take the transfer of credit. My
understanding is that the current negotiated rulemaking process
goes forward under the aegis of allowing regulations to conform
to the Higher Education Reconciliation Act of 2005. That act
contains not a single mention of transfer of credit policy.
Transfer of credit policy is an issue that is under active
consideration in this Congress. In fact, there was language in
the Higher Ed Act that passed out of this committee.
Congressman Souder and I offered a bipartisan amendment to
strip that language, but now the department is attempting to
reimpose that language by virtue of this negotiated rulemaking
process.
And I would like you to comment on that. Why is this
something that falls to the authority of the department and
doesn't remain within the legislative authority of the Congress
in your view?
Secretary Spellings. Well, the Congress, obviously, has the
authority to trump any and everything at the U.S. Department of
Education or any department at any time. The negotiated
rulemaking is such and is so lengthy to allow for lots of
public commentary and so forth. It followed on the heels of a
year-long commission report that I had initiated and so forth.
So a lot of public awareness and public debate occurred on
these various issues.
These issues are certainly not----
Mr. Bishop of New York. If I may interrupt, if the
department is interested in transfer of credit, for example,
the 1998 Higher Ed Act mandated that the department conduct a
study of transfer of credit policies and their effect on
student enrollment. That study has never been conducted.
Why doesn't the department conduct that study as opposed to
attempting to circumvent the legislative process and impose
through regulatory means whatever the department's agenda is?
Secretary Spellings. Well, we can certainly bring to bear
information that we have about the implications of transfer of
credit for students and taxpayers, and we will do that.
Mr. Bishop of New York. Okay. But will you allow the
negotiated rulemaking process to go forward or will you allow
the Congress to work its will? We are going to undertake and
pass a Higher Ed Act that will address the issue of transfer of
credit, which is where it rightly belongs, here in the
Congress.
Secretary Spellings. I hope you will do that. Nobody would
be more excited for the Higher Ed Act to be newly reauthorized
than the secretary of education.
Mr. Bishop of New York. I think some of us might be
excited.
Secretary Spellings. But, obviously, I am going to proceed
with, as I have told you, particularly in light of these
various issues related to financial oversight and stewardship,
a prudent negotiated rulemaking process on these issues. Have
they concluded yet? Will there be opportunity for public
comment and so on? Are these issues far from finally resolved?
Absolutely, they are not, but the process is ongoing.
Mr. Bishop of New York. Even though the Congress would
retain the right to impose their legislative will.
Secretary Spellings. When the Congress imposes their
legislative will, that will certainly trump any and all efforts
with respect to a negotiated rulemaking, including the law that
you passed yesterday.
Mr. Bishop of New York. And you position, I take it, would
be the same on the issue of accreditation?
Secretary Spellings. Yes, sir. As I said, the process is
ongoing. No final decision has been reached about the issues
that you are concerned about and raise. But I precipitated the
public debate around those issues in the absence of a statute
last August and through the spring of this year. They are not
complete.
Mr. Bishop of New York. And that public debate is pursuant
to the issuance of the report, the so-called Spellings
commission report?
Secretary Spellings. The initiation of the rulemaking was,
in part, out of that, as well as these issues that have been
raised. I used the negotiated rulemaking process to investigate
a series of issues.
Mr. Bishop of New York. I just want to assure you that this
Congress is going to address in the Higher Ed Act these issues
from all vantage points that you are attempting to address via
the regulatory process. We are going to exercise our
legislative authority to address these issues.
Thank you very much. I appreciate your time.
Secretary Spellings. Thank you.
Chairman Miller. The gentleman's time has expired, and all
time for this hearing has expired.
Madam Secretary, thank you very much, one for agreeing to
appear before the committee today. Thank you for answering the
questions of the members. Especially thank you for staying an
additional time due to the interruption we had with the votes.
I thank you for all of your responses. I think you can see
the level of concern by the committee. You share that concern.
You made that clear today.
I want to, again, make it clear that this is a hearing on
oversight of this department, which you happen to head at this
time, but, as you heard, many of the concerns here predated
you, and these problems started to grow in intensity and in
concern and in different levels of activity by people who
should be working to serve the students and families of the
Student Loan Program or the districts under Reading First. They
have got crossways in this system.
There are other ongoing investigations of some of these
personalities and some of the audits done. We will continue
that effort, and we look forward to your cooperation.
This is about this committee moving forward. We wanted to
demonstrated that with the passage of the bipartisan bill and
inclusion of suggestions that Mr. Keller made and Mr. McKeon
had made and others, because we think that there is just very
little distinction on our commitment to the integrity of the
Student Loan Program.
Mr. McKeon apologized for leaving. He had a leadership
meeting where I think there were some votes to be taken within
the leadership and he had to leave early, but he left it in the
very capable hands of Mr. Keller.
And thank you very much for your time and your
consideration. I know there were some questions that people
wanted to get for the record, and we will transmit those to
you, and we look forward to the answers.
Secretary Spellings. Thank you, Mr. Chairman. I appreciate
it.
Chairman Miller. Thank you.
[Additional submissions for the record by Mr. Miller
follow:]
[VIA FACSIMILE],
May 16, 2007.
Hon. Margaret Spellings, Secretary of Education,
U.S. Department of Education, Washington, DC.
Dear Secretary Spellings: Thank you again for testifying at the May
10, 2007 hearing, ``Accountability for the Department of Education's
Oversight of Student Loans and the Reading First Program.'' As
discussed during the hearing, the Committee would appreciate your
assistance in providing written responses to the enclosed questions to
ensure that the Committee's hearing record is complete. We would
appreciate your responses in Word format, no later than May 24, 2007.
If you have any questions, please do not hesitate to contact Michael
Zola, Chief Investigative Counsel for the Committee at (202) 226-9403.
Sincerely,
George Miller,
Chairman.
Representative Jason Altmire (D-PA) has asked that you respond to
the following questions:
1. The former Reading First Director, Chris Doherty, was referred
to the Justice Department because he had a conflict of interest coming
into the Department of Education that he did not properly disclose. Mr.
Doherty's wife works for an organization with ties to a specific
reading methodology and with ties to reading products. Can you please
explain why the Department failed to properly address this conflict?
2. When was the first time you learned that Mr. Doherty's wife
worked for an organization with ties to reading products? What did you
do about it?
3. What steps will the Department take going forward to proactively
identify and address conflicts of interest among its own employees?
4. What was your role in the implementation of Reading First while
you served in the White House?
5. Did you play any role in selecting program officials,
contractors, sub-contractors, or consultants?
6. Did you ever have discussions with Beth Ann Bryan, Douglas
Carnine, or Reid Lyon about Reading First prior to joining the
Department? What specifically did those conversations entail?
Representative Robert Scott (D-VA) has asked that you respond to
the following questions:
1. Are you aware that Kentucky made changes to its Reading First
grant application to eliminate certain reading programs before
receiving their federal grant? Have you submitted inquiries to states
to determine which, if any, additional states changed their Reading
First grant application to eliminate certain reading programs before
receiving their grant? Assuming that such changes were made, what
remedies will be available for organizations that were eliminated in
grant applications?
2. What campaign contributions were made by Nelnet in the two years
prior to the company's settlement with the Department?
Representative Donald Payne (D-NJ) has asked that you respond to
the following questions:
1. The purpose of the National Student Loan Data is to serve as a
central repository on student loans for lenders, guarantors, schools,
borrowers, and the Department to update and obtain information needed
administering the student loan programs. This is not the case of
someone hacking into a government database; the Department must approve
all users and monitors their use. How do you justify the fact that for
the nearly a month, the vast majority of users who have done nothing,
have not been able to use the system to administer the loan programs?
2. Last year, there was a significant backlog in Consolidation loan
processing because of unexpected guidance that the Department issued in
April, which Congress later overturned by repealing the ``single holder
rule.'' Your decision to lock lenders out of the NSLDS seems to be
creating another backlog this year. What are you going to do to restore
access to the system now and avoid causing another situation which
results in borrowers waiting months to be able to lower their monthly
payments using Consolidation loans?
3. The Department notes that it has begun to restore access to the
system. How many lenders have been allowed to regain access to the
system? Why hasn't the Department provided lenders with information and
a timeline for restoring access?
4. Before you made your decision on April 17th to lock lenders out
of the system, didn't the system already record each access of every
borrower's record, noting the time and user who accessed a borrower's
record? Why wasn't this enough information for the Department to be
able to investigate whether users were not properly accessing records?
What has the shut down accomplished that couldn't have been done while
still maintaining access to users in compliance?
5. Were any security breaches by unauthorized users identified by
the Inspector General before you made your decision on April 17th?
6. Have there ever been any instances of identity theft
attributable to a user accessing NSLDS?
7. With regard to the charge that lenders were using the system for
marketing, are lenders able to obtain a borrower's address from the
system? Phone number? E-mail? How can the system be used for marketing,
if it contains no contact information on borrowers?
8. Can you confirm that lenders able to obtain from NSLDS lists of
borrowers at a given institution who have outstanding student loans?
9. Can a user access a borrower's record in NSLDS without already
knowing the borrower's social security number?
10. Were you aware that your decision would result in certain
lenders not being able to verify borrowers' eligibility for
consolidation loans or would significantly disrupt the loan
consolidation process?
11. What specific threat did you believe you were addressing when
you made the decision on April 17th?
12. Are you aware that the shut down of the system benefits large
lenders who already hold a borrower's loans such as Sallie Mae, Nelnet,
and the Department's Direct Loan program, since they do not need to
access NSLDS in order make Consolidation loans to their borrowers? Why
would you take an action that would limit a borrower's choice of
lender, when clearly it is the intent of this body to offer borrowers
the broadest degree of choices?
Representative Howard ``Buck'' McKeon (R-CA) has asked that you
respond to the following questions:
Student Loans
1. Chairman Miller has recently sent some marketing documents to
the Federal Trade Commission in order to determine if such documents
are deceptive marketing material. I have seen some of those materials
and they look fairly deceptive to me. Has the Department sent such
marketing documents to the FTC in the past and what was the response?
2. Madam Secretary, you have been criticized for not enforcing the
inducement prohibition in the Higher Education Act. We know that the
Clinton Administration took an action against Sallie Mae which was
decided in Sallie Mae's favor by an administrative law judge in 1996.
For the record, do you know how many other enforcement actions were
taken by the Clinton Administration with respect to inducements?
3. Madam Secretary, has your administration taken any such actions
against lenders or other parties?
4. One of the things Chairman Miller has asked you to implement is
``emergency regulations'' to put an end to some of the practices that
have been in the media lately. To your knowledge, has the Department
ever enacted ``emergency regulations?'' Does the Department even have
the legal authority to enact ``emergency regulations'' for an activity
like this?
5. There seems to be a lot of confusion about what is a prohibited
inducement even though the law is clear about not paying a school for
loan applicants. The Department issued guidance explaining the law when
it was first enacted and it has not significantly changed since its
enactment more than 15 years ago. Do we have a problem with the law or
is this really more of an ethics issue for colleges?
6. The bill we passed yesterday addresses the ethics issue but it
did nothing to address the statutory provision on inducements so if
this is a problem with the law, what should Congress do to solve the
problem?
7. While the press has been pointing to a report by the Office of
the Inspector General that alleges that the close relationship the
Office of Federal Student Aid has with lenders and guaranty agencies
has impeded FSA's ability to do proper compliance and oversight of
these entities, that is not what I have seen or heard from companies in
my state. What are your thoughts on this?
Reading First
8. From the various reports that have been released, including the
report issued by Senator Kennedy yesterday, it is clear that mistakes
were made in the implementation of the program related to conflicts of
interest, mismanagement, and curriculum control. In your testimony, you
outline many of the things that the Department has done or is doing to
respond to these various reports. As you know, last month I introduced
H.R. 1939, the Reading First Improvement Act, to address many of those
findings related to conflicts of interest, mismanagement, and
curriculum control. Many of the provisions in this bill codify steps
you are already taking. Do you believe H.R. 1939 reflects the approach
that Congress should take to provide the Department more clarity in
terms of how the Department should implement this unique program? How
can Congress partner with you to strengthen this program going forward?
9. Madam Secretary, it is clear from the Inspector General's
reports that some states felt pressured at different points during the
implementation of the program and that the application process was not
perfectly transparent, and I hope that we can fix those problems going
forward. Yet, I also received a letter following our first Reading
First hearing from a state Reading First director speaking very highly
of the program and Chris Doherty in particular. This state director was
not only thrilled with the program's outcomes, he felt that those
outcomes were directly attributable to the hard work of Chris and
others at the Department. You have stated that the department has
reached out to states to solicit their feedback on the program. How
would you characterize state feelings about Reading First?
Representative Joe Wilson (R-SC) has asked that you respond to the
following questions:
1. Given the consequences to borrowers of continuing to limit
access to NSLDS during a time when many borrowers would like to
consolidate their loans, how will the Department communicate with
borrowers and industry going forward when issues such as this arise?
2. I understand that limited notice was provided to users of NSLDS
of the restrictions imposed a few weeks ago. What was the process
undertaken by the Department in determining the amount of notice given
to NSLDS users prior to imposing a restriction on the system's access?
3. I understand that the restrictions on the system are beginning
to be lifted for guaranty agencies. How long do you expect that the
restrictions will continue to be in place for other users of the
system?
4. Madam Secretary, in conducting investigations into the
relationships between institutions and lenders, the New York Attorney
General submitted notices to many institutions, including an
institution in my home state--Clemson University. It is my
understanding that Clemson received funds that it puts towards need-
based grant aid to students through an arrangement it has with a
private loan lender. The South Carolina Attorney General Henry McMaster
reviewed the agreement, at the urging of Attorney General Andrew Cuomo,
and found nothing wrong with the agreement. Since this is a private
loan arrangement, do you have any authority over these arrangements and
is it an illegal inducement under the HEA?
5. Do you have suggestions for how the federal government should
respond to issues when attorneys general in 2 different states disagree
about what constitutes inappropriate behavior?
Representative Thomas Petri (R-WI) has asked that you respond to
the following questions:
I. Department Loan Program Mismanagement
1. Given the prevalence of unethical relationships between lenders
and financial aid offices, would you agree that the Department has
failed to provide sufficient leadership to prevent and identify these
practices?
2. Can you explain the Department's failure to implement gift and
ethics regulations, as it was advised to do in 2001 and again in 2004
after the Financial Aid Administrators Assn' failed to adopt industry
standards?
3. It's become increasingly clear that various Department officials
failed to act to prevent subsidy abuse and unethical lender practices
over the last decade. Would you agree that these officials should be
held to account for their mismanagement?
II. Nelnet $278 Million Settlement
You recently forgave $278 million to student lender Nelnet, which
manipulated subsidies to bill taxpayers at the 9.5% rate. I received
your response within an hour prior to this hearing:
1. How do you justify your decision, given Nelnet's brazen abuse
and manipulation of taxpayer funds, not to try to fully collect these
payments?
2. Can you please provide all other lenders, subsidy figures, and
loan volume in question with regards to 9.5%?
3. You indicated that you would conduct audits of all other
potential 9.5% abusers before offering any further forgiveness.
a. Have any additional settlements been reached and;
b. Do you still intend to offer forgiveness on a case-by-case basis
in accordance to the audit results?
4. According to some legal analysts, neither individual taxpayers
nor the Department of Justice has the legal authority to challenge your
settlement, only the lender.
5. Would you agree that Congress should include an oversight
mechanism in HEA for future settlements, given the large sums of
taxpayer funds at stake?
III. On the Guaranteed Loan Program
The Bush Administration's Office of Management and Budget and
Treasury Department, along with the Congressional Budget Office,
Government Accountability Office, and private economists have all
agreed that the guaranteed loan program is significantly more expensive
than the Direct Loan alternative--costing taxpayers an estimated $3--5
billion annually in excess subsidies.
1. Would you agree that these wasteful subsidies in the guaranteed
program are a product of a structurally-broken system?
2. Would you agree that a market-based loan guarantee auction would
reduce wasteful spending by requiring lenders competitively bid for
taxpayer subsidies?
3. Why did it take the Administration six years to publicly
recognize on the excess subsidies in the guaranteed loan program given
the strong supporting evidence?
4. Can you please provide a complete list of FFELP lenders and
federal subsidy payments for the most recent year that data is
available?
IV. Misc. Direct Loan Question
The Higher Education Act (Section 455) mandates that the Direct
Loan program provide ``the same terms, conditions, and benefits'' as
the FFEL program.
The only lender to provide federal loan borrowers lower interest
rates in recent years has been MyRichUncle which has offered 5.8%
rates. Reducing Direct Loan interest rates to 5.8% as MyRichUncle has
would save the typical student borrower $1,000 in student loan
payments.
In 1999, Secretary Riley enforced this provision and lowered Direct
Loan program fees to match the lower origination fees that guaranteed
lenders were offering.
1. Why hasn't the Bush Administration lowered interest rates for
Direct Loans to match the lower interest rates being offered by
guaranteed lenders like MyRichUncle?
Representative Mark Souder (R-IN) has asked that you respond to the
following questions:
1. Madam Secretary, can you tell us what statutory authority exists
in the Higher Education Act that allows schools in the Direct Loan
program to force students and parents to borrow from the government,
thereby restricting their free choice in selecting a student loan
lender?
2. Considering much of the current discussion began as a result of
lenders complaining that schools were restricting the choices of
students and parents, how do you justify allowing the Direct Loan
program to eliminate all choices and forcing students to borrow from
one lender?
3. There has been a proposal in Congress that would bribe schools
to join the Direct Loan program with the lure of potential grant funds.
What is your opinion of that proposal? Could the Department of
Education handle a substantial increase in Direct Loan volume? Do you
support bribing schools in this fashion or would you prefer that a
robust level of competition continues to exist between the two loan
programs?
4. Included in H.R. 890, The Student Loan Sunshine Act, was a
provision that required institutions with preferred lender lists to
disclose to both you and the public why the lenders were placed on the
list. The Democrats opposed including a provision that was in H.R.
1994, The Financial Aid Accountability & Transparency Act, which
required Direct Loan schools to disclose why they selected the
Department as their lender. It seems to me that if one argues that
students need to know why a school selected 3 to 4 lenders in the FFEL
program, then it is even more important that students be given that
same information when their school only selects ONE lender for them
just like a school does in the DL program. What do you think about
that?
______
Responses to May 16, 2007 Written Questions for the Committee on
Education and Labor
Rep. Jason Altmire (D-PA):
1. The former Reading First Director, Chris Doherty, was referred
to the Justice Department because he had a conflict of interest coming
into the Department of Education that he did not properly disclose. Mr.
Doherty's wife works for an organization with ties to a specific
reading methodology and with ties to reading products. Can you please
explain why the Department failed to properly address this conflict?
I have reviewed the matter and determined that the Department
reviewers acted in a reasonable way in addressing this matter. However,
because this matter has been referred to the U.S. Attorney's Office as
a possible criminal matter, it would be inappropriate to discuss the
specifics of the Department's actions until that review has been
completed.
2. When was the first time you learned that Mr. Doherty's wife
worked for an organization with ties to reading products? What did you
do about it?
See the answer to Question 1 above.
3. What steps will the Department take going forward to proactively
identify and address conflicts of interest among its own employees?
The Department runs an ethics program in accordance with
regulations and guidance issued by OGE, an independent Executive branch
agency charged with establishing government-wide ethics policy. The
Department has received periodic program reviews by the OGE. Most
recently, the Department's ethics program was recognized for excellence
in training when it received the OGE 2007 Ethics Training Award. In
2004, OGE reported, ``ED's ethics program is essentially sound and
appears to be appropriately tailored to the needs of agency employees''
and that the ethics training requirements are ``not only being met, but
also exceeded in many ways.'' In the report of its 1997 review, OGE
stated that, ``Education's ethics program is sound and well managed. We
are impressed with the commitment shown by [the staff] to providing
high quality services to employees and with the measures taken to
prevent actual or the appearance of conflicts of interest on the part
of Education employees.'' In OGE's report of its 1993 review, it noted,
``In many respects [the ED ethics program] is one that could serve as a
model for other executive branch agencies.''
Moving forward, the Department will continue to vigorously review
and evaluate financial disclosure reports filed by Department
employees. In order to enhance our current program, the Department has
instituted a two-attorney review of each public financial disclosure
report. Additionally, I have asked the head of the Department's ethics
office to identify best practices in the government ethics programs and
to prepare a report with recommendations on ways to further enhance the
Department's ethics program. Finally, both the Department's OIG and OGE
have recently initiated reviews of the Department's ethics program. We
are cooperating with both of these reviews and believe the results will
further inform our efforts to enhance the ethics program at the
Department.
4. What was your role in the implementation of Reading First while
you served in the White House?
My duties at the Domestic Policy Council (DPC) included budget and
policy issues for well over 500 federal grant and loan programs across
eight Cabinet and other major agencies. While at DPC, I had
responsibilities with regard to the development and implementation of
many government initiatives, including those involving Global Aids,
Immigration, Postal Reform, Food Safety, Pandemic Flu, and the overall
implementation of the No Child Left Behind Act, which includes Reading
First.
5. Did you play any role in selecting program officials,
contractors, sub-contractors, or consultants?
The Department's officials had delegated authority from the
Secretary of Education to select program officials, contractors,
subcontractors, and consultants.
6. Did you ever have discussions with Beth Ann Bryan, Douglas
Carnine, or Reid Lyon about Reading First prior to joining the
Department? What specifically did those conversations entail?
In my role at DPC, I generally discussed matters about the
Department with Reid Lyons and Beth Ann Bryan, but it would be
inappropriate for me to discuss the details of these discussions as a
former senior adviser to the President of the United States.
Rep. Bobby Scott (D-VA):
1. Are you aware that Kentucky made changes to its Reading First
grant application to eliminate certain reading programs before
receiving their federal grant? Have you submitted inquiries to states
to determine which, if any, additional states changed their Reading
First grant application to eliminate certain reading programs before
receiving their grant? Assuming that such changes were made, what
remedies will be available for organizations that were eliminated in
grant applications?
Although I am not aware of the specifics of every State's Reading
First application, I am aware of the testimony of that was provided by
Star Jones, the Associate Commissioner for the Office of Teaching and
Learning at the Kentucky Department of Education, at your Committee's
April 20th hearing on the implementation of the Reading First program.
In an effort to address any concerns about the Reading First
program, on September 29, 2006, then-Assistant Secretary for Elementary
and Secondary Education Henry Johnson, sent a letter to State Reading
First Directors notifying them of the report from the Department's
Office of the Inspector General entitled The Reading First Program's
Grant Application Process. In the letter, Dr. Johnson asked each State
to notify the Department of any concerns it may have with the process
used to review State Reading First applications. He also requested that
they notify us if they did not have any complaints.
The Department received responses from 25 States. Of the 25 States
that responded, 16 (Alabama, Alaska, Arizona, Arkansas, Colorado,
Hawaii, Kansas, Maryland, Mississippi, Missouri, Rhode Island, South
Dakota, Tennessee, Utah, Washington, and the Virgin Islands) expressed
no concerns with the review process, and a number had positive comments
about the program or review process. For example, Kansas indicated that
it was approved without identifying a core reading program and likely
had the most flexible Reading First plan. Kansas also indicated that it
had no problems during the review process that were not resolved, and
that they appreciated the help that they received from the Department.
Seven States (Maine, Massachusetts, Montana, New Hampshire, New Jersey,
North Dakota, and Wisconsin) expressed concerns with the review
process. For example, New Hampshire expressed concerns with the
efficiency of the review process. The State noted that the Department
did not provide it with comments from the peer-review panel in a timely
manner, and that the length of the review process put stress on the
system at the state and local level. Two States, Oregon and
Pennsylvania, responded to the letter but did not express an opinion on
the quality of the review process.
Program staff contacted each State that did not reply to the
request to provide comments on the review process. In conversations
between Department and State program staff, seven States (California,
Delaware, Iowa, South Carolina, Texas, Vermont, and American Samoa)
indicated that they had no concerns with the review process and did not
plan to submit a response. Kentucky indicated that the State had
concerns with the process but did not submit a response because it had
previously communicated its concerns to the Department. The remaining
States did not respond to Department staff or indicated that they had
no comments on the review process.
Any State that believes that it was pressured to remove a specific
reading program from its Reading First application may submit an
amendment to its application. The State would have to demonstrate that
the program proposed for inclusion meets the criteria described in its
Reading First plan for identifying programs based on scientifically
based reading research. Since the OIG issued its inspection report,
staff have held meetings of all the Reading First State directors and
the States were told about the process for submitting amendments to
their approved State plans.
2. What campaign contributions were made by Nelnet in the two years
prior to the company's settlement with the Department?
The Department does not have this information.
Rep. Donald Payne (D-NJ):
1. The purpose of the National Student Loan Data is to serve as a
central repository on student loans for lenders, guarantors, schools,
borrowers, and the Department to update and obtain information needed
[in] administering the student loan programs. How do you justify the
fact that for nearly a month, the vast majority of users who have done
nothing, have not been able to use the system to administer the loan
programs?
Access for Guaranty Agencies, Lenders, and Lender Servicers was
temporarily suspended on April 18, 2007. Access for borrowers,
students, and institutions of higher education was not affected and
these entities represent the majority of NSLDS users. While Guaranty
Agencies, Lenders, and Lender Servicers were affected by the temporary
suspension, we are working diligently to restore their access. We
reinstated NSLDS access for 32 out of 35 Guaranty Agencies (91%) of
Guaranty Agencies. We anticipate restoring access to the remainder of
the Guaranty Agencies in the near future. We requested additional
certifications from lenders and lender servicers and access to these
entities will be provided when the requested information is received.
To date, we have reinstated access for approximately 11% of the lenders
who had accessed the system within the past year and approximately 24%
of the lender servicers who had accessed the system within the past
year. We are still developing a process to reinstate access for those
entities that participate in the program as Eligible Lender Trustees.
That said, we understand that this temporary suspension has delayed
some functions by the affected organizations. However, ensuring
appropriate access to NSLDS to protect the confidentiality of our
borrowers' financial information is our highest priority.
2. Last year, there was a significant backlog in Consolidation loan
processing because of unexpected guidance that the Department issued in
April, which Congress later overturned by repealing the ``single holder
rule.'' Your decision to lock lenders out of the NSLDS seems to be
creating another backlog this year. What are you going to do to restore
access to the system now and avoid causing another situation which
results in borrowers waiting months to be able to lower their monthly
payments using Consolidation loans?
Borrowers can log onto the NSLDS Borrower website to obtain the
data needed to complete the consolidation loan application. Lenders can
continue to process the application without accessing NSLDS.
Additionally, because of the new fixed student loan rates and the
increased consolidation volume in previous years, we anticipate a lower
volume of consolidation requests this year.
3. The Department notes that it has begun to restore access to the
system. How many lenders have been allowed to regain access to the
system? Why hasn't the Department provided lenders with information and
a timeline for restoring access?
Appropriate instructions for Guaranty Agencies and Lenders,
including Lender Servicers, were sent on May 2, 2007 and May 15, 2007,
respectively, to the Chief Operating Officer of each organization via
e-mail. As the entity responds and the data is reviewed, access is
being restored.
4. Before you made your decision on April 17th to lock lenders out
of the system, didn't the system already record access of every
borrower's record, noting the time and user who accessed a borrower's
record? Why wasn't this enough information for the Department to be
able to investigate whether users were not properly accessing records?
What has the shut down accomplished that couldn't have been done while
still maintaining access to users in compliance?
We continuously monitor access to NSLDS to prevent unauthorized
use. As a result of this monitoring, we issued a Dear Colleague Letter
(DCL) in April 2005 reiterating NSLDS usage requirements. Following the
release of the DCL, we observed a significant increase in usage by
lenders, loan holders, servicers, and guaranty agencies. This was a
matter of concern to us and we began considering potential courses of
action. After consideration of alternatives, the Department temporarily
suspended access to NSLDS by lenders, lender servicers, and guaranty
agencies. Please note there is no indication of any unauthorized access
to NSLDS.
5. Were any security breaches by unauthorized users identified by
the Inspector General before you made your decision on April 17th?
No. We are not aware of any NSLDS security breaches by unauthorized
users identified by the Inspector General.
6. Have there ever been any instances of identity theft
attributable to a user accessing NSLDS?
No. We are not aware of any instances of identity theft
attributable to a user accessing NSLDS.
7. With regard to the charge that lenders were using the system for
marketing, are lenders able to obtain a borrower's address from the
system? Phone number? E-mail? How can the system be used for marketing,
if it contains no contact information on borrowers?
NSLDS does not provide access to email addresses, phone numbers or
addresses of borrowers, nor does it authorize the analysis or database
searches of multiple borrower records. However, lenders that
participate in the FFEL Program often purchase data from credit bureaus
and other sources for the specific purpose of making an offer of credit
to an individual, in this case a FFELP consolidation loan. Within this
solicitation is a request for permission to access NSLDS to obtain
information on the borrower's loans.
8. Can you confirm that lenders [are] able to obtain from NSLDS
lists of borrowers at a given institution who have outstanding student
loans?
Authorized NSLDS users cannot obtain lists of borrowers at a given
institution who have outstanding student loans. NSLDS only allows a
user to look up a single borrower at a time and only if the user has a
relationship with the borrower or, until recently, had specific
permission from the borrower to do so. The use of automated tools is
prohibited. Federal Student Aid deploys a variety of tools and
monitoring techniques to alert us to the possibility that automated
tools are being used and automatically suspend the access for the user
ID.
9. Can a user access a borrower's records in NSLDS without knowing
the borrower's social security number?
No. Prior to April 30th, in order to access a borrower's records in
NSLDS, the user had to, at a minimum, enter the borrower's social
security number to access the records. Beginning on April 30th, the
social security number, date of birth, and borrower's first name are
required to access a borrower's records.
10. Were you aware your decision would result in lenders not being
able to verify borrower's eligibility for consolidation loans or would
significantly disrupt the loan consolidation process?
Lenders can continue to process consolidation loan applications
without accessing NSLDS. Borrowers can log onto the NSLDS Borrower
website to obtain the data needed to complete the consolidation loan
application.
That said, we understand that this temporary suspension has delayed
some functions by the affected organizations. However, ensuring
appropriate access to NSLDS to protect the confidentiality of our
borrowers' financial information is our highest priority.
11. What specific threat did you believe you were addressing when
you made the decision on April 17th?
We continuously monitor access to NSLDS to prevent unauthorized
use. As a result of this monitoring, we issued a Dear Colleague Letter
(DCL) in April 2007 reiterating NSLDS usage requirements. Following the
release of the DCL, we observed a significant increase in usage by
lenders, loan holders, servicers, and guaranty agencies. This was a
matter of concern to us and we began considering potential courses of
action. After consideration of alternatives, the Department temporarily
suspended access to NSLDS by lenders, lender servicers, and guaranty
agencies. Please note there is no indication of any unauthorized access
to NSLDS.
12. Are you aware that the shut down of the system benefits large
lenders who already hold a borrower's loans such as Sallie Mae, Nelnet,
and the Department's Direct Loan program, since they do need to access
NSLDS in order to make Consolidation loans to their borrowers? Why
would you take an action that would limit a borrower's choice of
lender, when clearly it is the intent of this body to offer borrowers
the broadest degree of choices?
The borrower is free to select any eligible, participating lender
by selecting a consolidation loan application and working with his/her
lender of choice.
As we mentioned above, the data needed by the consolidation
borrowers is still accessible to complete the consolidation loan
application. Borrowers can log onto the NSLDS Borrower website to
obtain the data needed to complete the loan application. Lenders can
continue to process the application without accessing NSLDS.
Ranking Member McKeon (R-CA):
1. Chairman Miller has recently sent some marketing documents to
the Federal Trade Commission in order to determine if such documents
are deceptive marketing materials. I have seen some of those materials
and they look fairly deceptive to me. Has the Department sent such
marketing documents to the FTC in the past and what was the response?
The Department shares the Committee's concern. In fact, during 2003
and 2004, the Department of Education referred to the FTC 31 complaints
about 10 private student loan companies who were distributing marketing
materials that the department thought might be deceptive. We understand
from FTC staff that they have given careful consideration to these
complaints. The Department of Education and FTC staffs currently are
discussing how to improve cooperation on all matters related to private
student loans, including improving the sharing of information
concerning marketing materials that could be deceptive.
2. Madam Secretary, you have been criticized for not enforcing the
inducement prohibition in the Higher Education Act. We know that the
Clinton Administration took an action against Sallie Mae which was
decided in Sallie Mae's favor by an administrative law judge in 1996.
For the record, do you know how many other enforcement actions were
taken by the Clinton Administration with respect to inducements?
We are not aware of any other formal enforcement actions taken by
the Clinton Administration with respect to inducements.
3. Madam Secretary, has your administration taken any such actions
against lenders or other parties?
Fair and effective oversight and monitoring of the nearly 3,500
lenders, guaranty agencies, and servicers that participate in the FFEL
Program, is one of the Department's highest priorities. In fact, our
oversight and monitoring activities conducted between fiscal year 2003
and the present resulted in the assessment, collection, or return of
over $712,000,000 by lenders, guarantee agencies, and third-party
servicers in the Federal Family Education Loan Program (FFELP).
In addition, Federal Student Aid (FSA) monitors the school and
lending community by reviewing required annual compliance audits and
financial statements, performing on-site program reviews, and analyzing
partner-specific data to detect trends and areas that could be of
concern. FSA has reviewed many audits and completed a number of on-site
program reviews of schools, lenders, guaranty agencies, and third-party
servicers for fiscal years 2001 though 2006, and is, in fact currently
engaged in several dozen reviews of program participants with regard to
the payment of possibly improper inducements.
Last year, the Department created an intra-department team to
conduct targeted reviews and investigate complaints from students and
lenders. When the Department determines a violation may have occurred,
we look into it and, if necessary, take appropriate actions to stop it.
Typically, we contact the lender, servicer, or guaranty agency and tell
it to stop and, in most cases, it halts the questionable practice.
Cease-and-desist letters have been issued to those entities that were
found to be in noncompliance with the regulations.
We are planning to review schools, lenders, and eligible lender
trustees and, in fact, have begun our on-site visits.
4. One of the things Chairman Miller has asked you to implement is
``emergency regulations'' to put an end to some of the practices that
have been in the media lately. To your knowledge, has the Department
ever enacted ``emergency regulations?'' Does the Department even have
the legal authority to enact ``emergency regulations'' for an activity
like this?
In our May 9th written response to the Chairman, we provided a
detailed answer to the question of ``emergency regulations.'' First, it
is incorrect to suggest that the Department possessed the authority
under current law to ``immediately publish emergency regulations'' on
``inducements and bribes.'' Section 492(b)(2) of the Higher Education
Act of 1965 (HEA), states that the Department must conduct negotiated
rulemaking ``unless the Secretary determines that applying such a
requirement with respect to given regulations is impracticable,
unnecessary, or contrary to the public interest'' within the meaning of
section 553(b)(3)(B) of title 5, United States Code.
In addition to the requirements for negotiated rulemaking, the
Administrative Procedure Act provides, in 5 USC 553(b), that the
Department must allow for public notice and comment when undertaking
rulemaking unless ``the agency for good cause finds ... that notice and
public procedure thereon are impracticable, unnecessary, or contrary to
the public interest.'' As interpreted by the courts, rulemaking is
considered ``impracticable'' when execution of the agency's statutory
duties would be unavoidably prevented by undertaking public rulemaking.
Notice and comment is ``unnecessary'' in those limited situations in
which the administrative rule is a routine determination, insignificant
in nature and impact, and inconsequential to the industry and to the
public. Finally, ``contrary to the public interest'' applies only in
the narrow circumstance when the interest of the public would be
defeated by any requirement of advance notice of rulemaking, such as
when announcement of a proposed rule would enable financial
manipulation that the rule sought to prevent.
Accordingly, the matters referred to by Chairman Miller do not fit
any of the exceptions to the negotiated-rulemaking requirement or the
notice-and-comment requirement. Any regulatory action on lender issues
by the Department would not be routine, insignificant, or
inconsequential. Moreover, notice-and-comment rulemaking would not
``unavoidably prevent'' the Department from fulfilling its
responsibilities to provide federal financial assistance or perform
other functions.
Finally, given the intense interest in financial aid issues, it
would be impossible to argue that preventing notice and comment could
be in the ``public interest.'' And even if some emergency authority for
waiving the proposed rulemaking and negotiated rulemaking requirement
existed, changes to the federal student financial aid regulations
published by the Department cannot, because of Sec. 482(c) of the HEA,
be effective until July 1 after the year they are published (and, even
then, only if they are published by November 1). The Department has no
authority to disregard the November 1 deadline. Thus, any regulations
published now cannot take effect until July 1, 2008.
5. There seems to be a lot of confusion about what is a prohibited
inducement even though the law is clear about not paying a school for
loan applicants. The Department issued guidance explaining the law when
it was first enacted and it has not significantly changed since its
enactment more than 15 years ago. Do we have a problem with the law or
is this really more of an ethics issue for colleges?
In order to answer the question of whether the law is insufficient
or not, a dialogue is necessary among the various stakeholders.
6. The bill we passed yesterday addresses the ethics issue but it
did nothing to address the statutory provision on inducements so if
this is a problem with the law, what should Congress do to solve the
problem?
If Congress determines that the law is not adequate in addressing
the issue of inducement, then Congress should amend the law.
7. While the press has been pointing to a report by the Office of
the Inspector General that alleges that the close relationship the
Office of Federal Student Aid has with lenders and guaranty agencies
has impeded FSA's ability to do proper compliance and oversight of
these entities, that is not what I have seen or heard from companies in
my state. What are your thoughts on this?
I hold the employees at the Department of Education in high regard.
Collectively, they are dedicated and committed to ensuring that
borrowers have a competitive and robust system at their disposal. In
addition, they value maintaining the integrity of that system.
With regard to hiring, the business community seeks individuals who
meet certain requirements for their jobs. In many cases, these
requirements include a skill or knowledge set around the particular
job. In fact, Congress hires individuals to staff key positions on
Committees with individuals who have a background in the appropriate
specialized field. I would venture to guess that some banking
experience would be necessary to be considered for a policy-level
position at the Committee on Financial Services. As such, it is wholly
appropriate and, indeed, responsible for my Department to seek
individuals who have a background in certain areas of education. With
regard to the duties required of someone who works in the Federal
Student Aid, most of the strongest candidates come from the lending
community, as they have the requisite knowledge and understanding of
the system.
8. From the various reports that have been released, including the
report issued by Senator Kennedy yesterday, it is clear that mistakes
were made in the implementation of the program related to conflicts of
interest, mismanagement, and curriculum control. In your testimony, you
outline many of the things that the Department has done or is doing to
respond to these various reports. As you know, last month I introduced
H.R. 1939, the Reading First Improvement Act, to address many of those
findings related to conflicts of interest, mismanagement, and
curriculum control. Many of the provisions in this bill codify steps
you are already taking. Do you believe H.R. 1939 reflects the approach
that Congress should take to provide the Department more clarity in
terms of how the Department should implement this unique program? How
can Congress partner with you to strengthen this program going forward?
As you note, the Department has implemented all of the
recommendations in the Office of Inspector General's (OIG) inspection
report on an expedited basis and, in some cases, went beyond what was
suggested by the OIG to implement improvements. This should be very
helpful in the effective implementation of the Reading First program
and build on the many successes of the program. The provisions in H.R.
1939 are consistent with, and supplement well, the actions the
Department has taken. The implementation of corrective measures and the
provisions in H.R. 1939 will help to further ensure the integrity,
objectivity, and transparency of the Reading First program. We look
forward to working with Congress on this issue.
9. Madam Secretary, it is clear from the Inspector General's
reports that some states felt pressured at different points during the
implementation of the program and that the application process was not
perfectly transparent, and I hope that we can fix those problems going
forward. Yet, I also received a letter following our first Reading
First hearing from a state Reading First director speaking very highly
of the program and Chris Doherty in particular. This state director was
not only thrilled with the program's outcome, he felt those outcomes
were directly attributable to the hard work of Chris and others at the
Department. You have stated that the [D]epartment has reached out to
states to solicit their feedback on the program. How would you
characterize state feelings about the program?
I believe that States are very happy with the increases in reading
achievement that they are seeing in schools participating in the
Reading First program. For example, in California, over 73 percent of
school districts participating in Reading First showed improvements in
reading comprehension for second graders, while more than 70 percent
showed improvement in reading fluency for first graders. In the second
grade, proficiency in reading comprehension increased nearly 11 percent
for Hispanic students, 10 percent for economically disadvantaged
students, and nearly 8 percent for limited English proficient students.
Nationally, students who participated in Reading First are
experiencing tremendous gains in reading achievement. On average,
States increased the percentage of Reading First students meeting or
exceeding proficiency on fluency outcome measures--a 16 percent average
gain for 1st graders, 14 percent for 2nd graders, and 15 percent for
3rd graders. Similar increases for reading comprehension outcome
measures were also found--a 15 percent average gain for 1st graders, 6
percent for 2nd graders, and 12 percent for 3rd graders.
Rep. Joe Wilson (R-SC):
1. Given the consequences to borrowers of continuing to limit
access to NSLDS during a time when many borrowers would like to
consolidate their loans, how will the Department communicate with
borrowers and industry going forward when issues such as this arise?
Under the current temporary suspension, borrowers are able to
consolidate their loans and are able to log onto the NSLDS Borrower
website to obtain the data needed to complete the consolidation loan
application. We continue to communicate with the community through
established means--including postings to Federal Student Aid Websites,
Dear Colleague Letters, Dear Partner Letters, and individual letters
and emails to industry organizations.
2. I understand that limited notice was provided to users of NSLDS
of the restrictions imposed a few weeks ago. What was the process
undertaken by the Department in determining the amount of notice given
to NSLDS users prior to imposing a restriction on the system's access?
Through the Department's ongoing and targeted monitoring of NSLDS,
we observed a significant increase in usage by lenders, loan holders,
servicers, and guaranty agencies. After consideration of alternatives,
the Department, on April 17, 2007, temporarily suspended access to
NSLDS by those entities.
Ensuring appropriate access to NSLDS to protect the confidentiality
of our borrowers' financial information is our highest priority. The
new security measures include two functions and added minimal burden to
users. First, after logging into NSLDS, a user is prompted with a box
that contains several random letters and/or numbers. The user must
correctly enter the information displayed in the box to receive
authorization to continue into NSLDS. This process should take less
than a few seconds, but provides added security against automated tools
logging onto NSLDS. Second, all queries into NSLDS web access requires
the user to provide the social security number, date of birth, and
first name of the borrower. This added security measure also adds
little time to the borrower look-up process but provides an added level
of security for borrowers' private financial information.
Additional security measures are currently being researched. If
these new security features change the system in such a way that users
will need training or notice, we will communicate this change to the
community.
3. I understand that the restrictions on the system are beginning
to be lifted for guaranty agencies. How long to you expect that the
restrictions will continue to be in place for other users of the
system?
Instructions for Guaranty Agencies and Lenders, including Lender
Servicers, were sent on May 2, 2007 and May 15, 2007, respectively, to
the Chief Operating Officers of each organization via e-mail. As the
entity responds and we review the data, we restore their access. So
far, we have restored NSLDS access for 32 out of 36 Guaranty Agencies
(89%). We anticipate restoring access to the remainder of the Guaranty
Agencies in the near future. We requested additional certifications
from lenders and lender servicers and access to these entities will be
provided when the requested information is received. To date, we have
reinstated access for approximately 11% of the lenders who had accessed
the system within the past year and approximately 24% of the lender
servicers who had accessed the system within the past year. We are
still developing a process to reinstate access for those entities that
participate in the program as Eligible Lender Trustees.
4. Madam Secretary, in conducting investigations into the
relationships between institutions and lenders, the New York Attorney
General submitted notices to many institutions, including an
institution in my home state--Clemson University. It is my
understanding that Clemson received funds that it puts towards need-
based grant aid to students through an arrangement it has with a
private loan lender. The South Carolina Attorney General Henry McMaster
reviewed the agreement, at the urging of Attorney General Andrew Cuomo,
and found nothing wrong with the agreement. Since this is a private
loan arrangement, do you have any authority over these arrangements and
is it an illegal inducement under the HEA?
The HEA proscribes inducements paid by lenders to secure
applications for FFELP loans, and the HEA gives the Department
authority to take action where such inducements are made. We have not
reviewed either the text of, or circumstances surrounding, the
agreement with Clemson University you refer to, and thus, have no
opinion whether this agreement constitutes an inducement within the
scope of the HEA.
5. Do you have suggestions for how the federal government should
respond to issues when attorneys general in 2 different states disagree
about what constitutes inappropriate behavior?
Our understanding is that the attorneys general of New York and
South Carolina do not disagree about the propriety of the Clemson
arrangement. To the contrary, it appears that the facts you describe
show deference by one attorney general to the views and authority of
the attorney general of another state. This conduct is consistent with
the principles of federalism that apply to any response by the
Department: the Department's authority extends under current law only
to determining whether payments were made by lenders to ``...secure
applicants for loans under the [FFELP]'', 20 U.S.C. Sec. 1085(d)(5)(A),
and, if so, taking action regarding the lender and the loans in
question. The authority of state attorneys general extends to whether
conduct by either lenders or schools violated state law(s). In some
instances, the conduct under scrutiny may be the same as examined by
the Department. The respective authorities of the Department and states
differ, and no conflict arises from each pursuing their own
responsibilities with respect to that conduct.
Rep. Tom Petri (R-WI):
I. Department Loan Program Mismanagement
1. Given the prevalence of unethical relationships between lenders
and financial aid offices, would you agree that the Department has
failed to provide sufficient leadership to prevent and identify these
practices?
I do not agree. Under my leadership, the Department raised these
issues in its announced intention to enter into negotiated rulemaking
nearly a year ago.
2. Can you explain the Department's failure to implement gift and
ethics regulations, as it was advised to do in 2001 and again in 2004
after the Financial Aid Administrators Assn' failed to adopt industry
standards?
The Department issued guidance on prohibited inducements to the
student loan community in 1989. That guidance, along with some limited
additional guidance issued in 1995, was incorporated into the Federal
Student Aid Handbook. For most of the intervening period, lenders,
guarantee agencies and institutions appeared to have been abiding by
the Department's guidance.
That began to change, however, as competition for loan volume,
particularly consolidation volume, intensified. The Department began to
observe some lender's practices that did not appear to be compliance
with the prior guidance. In certain instances we directed the offending
lenders to cease the practice and take certain corrective actions.
By late 2004, the Department recognized the need to provide more
definitive guidance and worked on a Dear Colleague letter. However, the
Department determined that, to be more enforceable, the requirements
would need to be incorporated into the student loan regulations and
began to plan for rulemaking when the reauthorization of the Higher
Education Act occurred. However, a comprehensive reauthorization did
not--and still has not--occurred. Despite this fact, the Department
decided in June 2006 to begin rulemaking to address this and other
urgent issues. Rulemaking in the student loan area is governed by
Section 492 of the Higher Education Act of 1965, which requires the
Department, before publishing proposed regulations, to obtain public
involvement in the development of the proposed regulations.
The Department held regional hearings in Berkeley, California;
Chicago, Illinois; Orlando, Florida; and Washington, DC during the fall
of 2006 to determine public interest in topics for negotiated
rulemaking. In addition, we invited parties to submit topics for
consideration in writing.
After obtaining advice and recommendations from individuals and
representatives of groups involved in the Federal student financial aid
programs, the Department must subject proposed regulations to
negotiated rulemaking. On December 8, 2006, we published a notice in
the Federal Register (71 FR 71117) announcing the establishment of two
negotiated rulemaking committees: the Loans Committee, to address
topics related to the Federal student loan programs authorized by Title
IV, Parts B, D, and E of the HEA, and the American Competitiveness
Grants (ACG) and National SMART Grant Committee, to address issues
related to those two new programs. On January 30, 2007, we published
another notice in the Federal Register (72 FR 4221) announcing the
establishment of two more committees: the General Provisions Committee,
to address programmatic, institutional eligibility, and general
provisions topics related to Title IV, Parts A (except for Academic
Competitiveness Grants (ACG) and National SMART Grant programs), C, G,
and H (except subpart 2) of the HEA, and the Accreditation Committee,
to address accreditation topics (Title IV, Part H, Subpart 2 of the
HEA). The Loans Committee met to develop proposed regulations over the
course of several months, beginning in December 2006.
Since the last meeting of the Loans Committee, we developed an NPRM
that we believe fully addresses the issues that have been identified on
preferred lender lists and prohibited inducements. That NPRM was
published on June 12, at 72 FR 32410.
3. It's become increasingly clear that various Department officials
failed to act to prevent subsidy abuse and unethical lender practices
over the last decade. Would you agree that these officials should be
held to account for their mismanagement?
I do not share your view that Department officials have failed to
act to prevent abuses and unethical practices. The Department has
investigated and continues to investigate practices that appear
inappropriate. Let me assure you that we will continue rigorous
oversight of these activities.
II. Nelnet $278 Million Settlement
You recently forgave $278 million to student lender Nelnet, which
manipulated subsidies to bill taxpayers at the 9.5% rate. I received
your response within an hour prior to this hearing:
1. How do you justify your decision, given Nelnet's brazen abuse
and manipulation of taxpayer funds, not to try to fully collect these
payments?
The Department exercises oversight over all higher education
lenders that participate in programs under Title IV, Part B of the HEA.
Indeed, the Department has exercised due care in resolving very complex
questions about the use of special allowance payments (SAP) at the 9.5
percent rate on Federal Family Education Loan Program (FFELP) loans
under Title IV. We continue to carefully scrutinize FFELP loans to
determine whether the loans are from eligible sources, and thus qualify
for the 9.5 percent SAP.
(1) Actions in Regard to Lenders' Use of 9.5 Percent SAP
and Oversight of Additional Lenders.
In our ``Dear Colleague'' letter of January 23, 2007, which
enclosed a more detailed letter that was sent to all lenders claiming
9.5 percent SAP, the Department stated it would not pay any further 9.5
percent SAP on loans other than first-generation or second-generation
loans. We advised each lender that sought the 9.5 percent SAP that an
audit of its loans would be required to verify the loans were first- or
second-generation loans. Additionally, to receive the 9.5 percent SAP,
we advised that a lender must provide, with each billing submitted to
the Department, a management certification that all such loans are
first- or second-generation loans. In a second ``Dear Colleague''
letter issued April 27, which also enclosed a letter sent to all
affected lenders, we provided an Auditor Guide that explained how the
required audit must be conducted, and we explained the methodology on
which the audit procedures are based. Lenders may use an independent
auditor of their choice, or may have the audit conducted by an audit
firm that will be retained by the Department. We enclose copies of
these letters
(2) Nelnet, Inc. (Nelnet) Settlement.
By way of background, the Department's Office of Inspector General
(OIG) issued an audit report on September 29, 2006 analyzing certain
Nelnet practices regarding 9.5 percent SAP (Special Allowance Payments
to Nelnet for Loans Funded by Tax-Exempt Obligations, ED-OIG/A07F0017,
hereinafter ``IG Audit Report ''). The IG Audit Report found that
Nelnet had used an ineligible funding source to acquire loans on which
it had claimed SAP at the 9.5 percent minimum return rate. OIG
estimated that Nelnet was improperly paid as much as $278 million in
special allowance payments for these loans from the quarter ending
March 31, 2003 through the quarter ending June 30, 2005, and that
Nelnet could be improperly paid as much as $882 million for the
ineligible loans in the months and years after June 2005 if Nelnet's
billings are not corrected. OIG recommended that the Chief Operating
Officer (COO) for Federal Student Aid (FSA) instruct Nelnet to exclude
all the affected loans from future claims for payment at the 9.5
percent minimum return rate, and require Nelnet to calculate and repay
the amounts overpaid on these loans.
Nelnet filed a response to the report on November 14, 2006. In its
response, Nelnet argued it was entitled to retain all 9.5 percent SAP
previously paid to it by the Department on FFELP loans. Nelnet further
argued it was entitled to receive the 9.5 percent SAP on billings in
future years over the life of the bond(s), which, as noted earlier, the
IG Audit Report had estimated might total as much as $882 million, or
more than triple what the Department already paid out.
The disputed statute and regulation at issue in the IG Audit Report
involved novel and complex questions of law. No court has rendered any
decision interpreting this specific statutory provision or regulation.
Upon a thorough review of the IG Audit Report, the statute and
regulation in question, and Department practices, and considering
potential litigation risks and costs, the inherent uncertainty pending
a definitive court decision (and any appeals), and the potential for an
unfavorable decision, the Department settled its claims against Nelnet.
The settlement ensured that the estimated $882 million of improper
payments (less amounts paid for the period from July 1, 2005 through
June 30, 2006) would be saved or not paid out by the Department to
Nelnet in future years, while resolving disputed claims over past
payments that could have resulted in protracted and costly litigation,
potentially delaying resolution of these matters for several years.
(3) January 23, 2007 Dear Colleague Letter.
The Department has not changed policy with regard to 9.5 percent
SAP. The regulation governing eligibility of student loans for 9.5
percent SAP dates to 1993. This same regulation was the subject of our
Dear Colleague letter of January 23, 2007. The statutory authority
underlying the regulation has been in place even longer--since 1980.
As stated in the Dear Colleague letter, ``[r]ecent examination of
activities involving tax-exempt financing of [FFELP] loans indicates
that it is appropriate to restate the * * * regulations that control
whether FFELP loans * * * [are] eligib[le] for SAP.'' (emphasis added).
The Dear Colleague letter (and the corresponding letter sent to
lenders) simply advised other lenders that we would not pay 9.5 percent
SAP on loans other than first-generation or second-generation loans, as
set forth in the regulation. Further, the Department required lenders
to take certain actions as a condition for receiving the 9.5 percent
SAP. This approach was consistent with the legal requirements restated
in the Dear Colleague letter that loans other than first-generation and
second-generation loans are not eligible for 9.5 percent SAP.
The Department also offered lenders the opportunity to resolve any
liability for the return of previously received 9.5 percent SAP for
loans other than first- or second-generation loans. To do so, lenders
were required to take the steps specified in the Dear Colleague letter
and forego asserting any claim to continued receipt of 9.5 percent SAP
for loans other than first- or second-generation loans. We further
noted that, should any lender bring a cause of action against the
Department for continued receipt of 9.5 percent SAP on loans that are
neither first- or second-generation loans, the offer in the January 23
Dear Colleague letter to resolve any liability would be retracted. In
such a case, we would confer with the Department of Justice about the
advisability of filing any counterclaim against the lender for all 9.5
percent SAP previously paid to that lender on loans that were neither
first- or second-generation loans. Alternatively, we could exercise the
option of recovering those funds through administrative offset against
any payments then owed the lender.
2. Can you please provide all other lenders, subsidy figures and
loan volume in question with regards to 9.5%?
This information is provided in the enclosed table.
3. You indicated that you would conduct audits of all other
potential 9.5% abusers before offering any further forgiveness.
a. Have any additional settlements been reached and;
b. Do you still intend to offer forgiveness on a case-by-case basis
in accordance to the audit results?
The only written settlement agreement entered into by the
Department regarding 9.5 percent SAP is with Nelnet. The other
``settlements'' will occur by practice on the part of the lenders. The
attached letter to the January 23, 2007 Dear Colleague Letter to
individual lenders sets forth the steps that must be followed for
lenders to receive any additional 9.5 percent SAP, and settle any
potential Department claims on previous overpayments. Therefore, the
Department does not expect, or require, a lender to execute any
document to memorialize acceptance of the offer. A lender can accept
the Department's offer simply by the conduct described in that offer.
4. According to some legal analysts, neither individual taxpayers
nor the Department of Justice has the legal authority to challenge your
settlement, only the lender.
Because the Higher Education Act gives the Secretary independent
authority to compromise claims arising under the FFEL program, we agree
that neither individual taxpayers nor the Department of Justice has
authority to challenge the Department's settlement with Nelnet. That
said, the Department of Justice is not foreclosed from pursuing, as
appropriate, separate remedies under other applicable provisions of the
law, including under the False Claims Act.
5. Would you agree that Congress should include an oversight
mechanism in HEA for future settlements, given the large sums of
taxpayer funds at stake?
An additional oversight mechanism is not necessary. The Department
has authority under the HEA to compromise claims under the FFEL program
and has exercised that authority properly.
III. Guaranteed Loan Program
The Bush Administration's Office of Management and Budget and
Treasury Department along with the Congressional Budge Office and
Government Accountability Office, and private economists have all
agreed that the guaranteed loan program is significantly more expensive
than the Direct Loan alternative--costing taxpayers an estimated $3-5
billion annually in excess subsidies
1. Would you agree that these wasteful subsidies in the guaranteed
program are a product of a structurally broken system?
The Administration strongly supports the continued availability of
both guaranteed and direct student loans. Competition between these
programs, and among lenders in the guaranteed program, enhances
borrower and institutional choice and drives innovation and improved
service in both programs. That said, the President's FY 2008 Budget
includes a comprehensive set of reforms that reduce costs, streamline
operations, and increase efficiency in the guaranteed loan program.
2. Would you agree that a market-based loan guarantee would reduce
wasteful spending by requiring lenders to competitively bid for
taxpayer subsidies?
The Administration believes the comprehensive package of proposals
included in the FY 2008 Budget represents the best approach to
enhancing the efficiency and effectiveness of the student loan programs
for students, schools, and taxpayers.
3. Why did it take the Administration six years to publicly
recognize on the excess subsidies in the guaranteed loan program given
the strong supporting evidence?
The Administration has long proposed structural reforms to improve
the efficiency of the student loan programs. The FY 2005, 2006, 2007,
and 2008 President's Budgets have all included major student loan
proposals to expand risk-sharing, increase efficiency, streamline
operations, and reduce costs to the taxpayer.
4. Can you provide a complete list of FFELP lenders and federal
subsidy payments for the most recent year that data is available?
Attached is a summary of special allowance subsidies (both regular
and tax-exempt) provided to lenders in 2006.
IV. Misc. Direct Loan Question
1. The Higher Education Act (Section 455) mandates that the Direct
Loan program provide ``the same terms, conditions, and benefits'' as
the FFEL program. The only lender to provide federal loan borrowers
lower interest rates in recent years has been MyRichUncle, which has
offered 5.8% rates. Reducing Direct Loan interest rates to 5.8% as
MyRichUncle has would save the typical student borrower $1,000 in
student loan payments.
In 1999, Secretary Riley enforced this provision and lowered Direct
Loan program fees to match the lower origination fees that guaranteed
lenders were offering.
Why hasn't the Bush Administration lowered interest rates for
Direct Loans to match the lower interest rates being offered by
guaranteed lenders like MyRichUncle?
Former Secretary Riley used his authority to provide a reduced
interest rate, in the form of an upfront interest rebate, as a
repayment incentive as provided for under Section 455(a)(8) of the HEA.
He did not provide an across-the-board interest rate reduction as you
suggest because that would have been inconsistent with precise language
of the statute that you referenced, which reads: ``Unless otherwise
specified in this part, loans made to borrowers under this part shall
have the same terms, conditions, and benefits, and be available in the
same amounts, as loans made to borrowers under sections 428, 428B, and
428H of this title.'' Interest rates are clearly specified in the part
and, thus, cannot be reduced except as done by Secretary Riley, as a
repayment incentive.
Rep. Mark Souder (R-IN):
1. Madam Secretary, can you tell us what statutory authority exists
in the Higher Education Act that allows schools in the Direct Loan
program to force students and parents to borrow from the government,
thereby restricting their free choice in selecting a student loan
lender?
The Higher Education Act of 1965, as amended, created the William
D. Ford Federal Direct Loan (DL) program as an alternative to the
Federal Family Education Loan program. By law, institutions must apply
to participate in the DL program. Once the institution is accepted for
participation in the program, the institution can choose to continue to
make FFEL loans available to students or not. That is reflected in the
agreement that each institution has with the Department. The choice of
whether to permit a student (or parent in the case of PLUS) is left to
the institutions subject to the exercise of Secretary's discretion
pursuant to Section 454(a)(4) of the HEA.
2. Considering much of the current discussion began as a result of
lenders complaining that schools were restricting the choices of
students and parents, how do you justify allowing the Direct Loan
program to eliminate all choices and forcing students to borrow from
one lender?
As noted above, by statute, borrower choice is provided for within
the FFEL program. The DL program clearly provides institutions with the
choice to participate in that program.
Institutions have made the choice to participate in the DL program
for a variety of reasons.
When the institution decided to apply to participate in the DL
program, it provided reasonable benefits when compared to the FFEL
program for students attending similar institutions. Many of the
institutions that participate in the DL program are for-profit trade
and technical schools that haven't benefited from the competition for
loan volume that has been evident in recent years. Thus, the terms and
conditions available in DL are comparable to those provided in FFEL for
those schools.
In addition, some institutions found the DL program made it simpler
for them to administer the Federal aid programs by having a single
funding source (ED) and a single mechanism for delivering those funds.
This makes it easier for the financial aid office to package and
disburse aid to students quickly and efficiently.
3. There has been a proposal in Congress that would bribe schools
to join the Direct Loan program with the lure of potential grant funds.
What is your opinion of that proposal? Could the Department of
Education handle a substantial increase in Direct Loan volume? Do you
support bribing schools in this fashion or would you prefer that a
robust level of competition continue to exist between the two loan
programs?
We do not support the proposal that some in Congress have put
forward to encourage institutions to join the DL program. We believe
that grant funds should be increased overall from savings that are
achieved through reductions in lender subsidies in the FFEL program. To
provide grant funds only to institutions that participate in the DL
program, as some have proposed, would be inequitable.
With appropriate notice and resources, the Department could over
time increase operations to accommodate the projected increase in
volume.
Finally, we agree with you that it is important to continue the
robust competition that exists between the two loan programs and among
the FFEL lenders. This competition has greatly improved the quality of
service and reduced costs for borrowers and taxpayers.
4. Included in H.R. 890, The Student Loan Sunshine Act, was a
provision that required institutions with preferred lender lists to
disclose to both you and the public why the lenders were placed on that
list. The Democrats opposed including a provision that was in H.R.
1994, The Financial Aid Accountability & Transparency Act, which
required Direct Loan schools to disclose why they selected the
Department as their lender. It seems to me that if one argues that the
students need to know why a school selected 3 to 4 lenders in the FFEL
program, then it is even more important that students be give that same
information when their school only selects ONE lender for them just
like a school does in the DL program. What do you think about that?
We are not opposed to the inclusion in a Sunshine Act of a
provision that requires institutions to explain their choice to
participate in the DL program either exclusively or in combination with
the FFEL program.
______
[VIA FACSIMILE],
May 23, 2007.
Hon. Margaret Spellings, Secretary of Education,
U.S. Department of Education, Washington, DC.
Dear Secretary Spellings: Following the letter sent to you on May
16, 2007, we have collected further questions the Committee would like
answered for the record.
During the course of the hearing, Members of the Committee asked
questions which you were unable to respond to at the time. We now
respectfully request that you respond to these questions. Additionally,
I have personally asked two final questions so that we may have a total
understanding of the testimony you provided at the May 10, 2007
hearing. Please provide your responses to these questions in Word
format by COB on Friday, May 25, 2007. If you have any questions,
please do not hesitate to contact Michael Zola, Chief Investigative
Counsel for the Committee at (202) 226-9403.
Sincerely,
George Miller,
Chairman.
Ranking Member Howard ``Buck'' McKeon (R-CA) asked you to respond
to the following questions for the record:
1. ``In comparison to the Clinton administration, can you tell us
how many program reviews and audits were handled by the Federal Student
Aid Office during the Clinton administration and the current one?''
2. Additionally, please provide a comparison of the past 20 years
in number of reviews and audits.
3. What actions did the Clinton administration take to limit 9.5
payments following their 1996 ``Dear Colleague'' Letter which increased
the number of loans eligible for 9.5?
Representative Thomas Petri (R-WI) asked you to respond to the
following question for the record:
1. How many other potential claims are there similar to Nelnet?
Representative Luis Fortuno (R-PR) asked you to respond to the
following questions for the record:
1. In your view, what are the chronic problems that plague the
Puerto Rico Department of Education (PRDE) and prevent them from
reaching peak performance? Why are they continuing to fail in providing
a decent education to Puerto Rico's 575,000 public school children?
2. How do you plan for better Federal oversight of the PRDE?
Clearly, the plans they have proposed for improvement are not at all
effective. In your response, I would like to see a detailed timeline, a
list of benchmarks for success, and deadlines for improvement. In
addition, I would like to receive bimonthly written updates upon
receipt of your response.
3. My staff and the Congressional Research Service have had
continual problems obtaining reliable data on NCLB implementation in
Puerto Rico. My staff was advised by your employees that the PRDE only
recently agreed they needed to update their data collection systems.
What progress have they made in that area, and what new data have they
submitted in recent weeks?
4. How is your Department helping to increase the PRDE's staff
retention?
5. As Representative of the 4 million citizens of Puerto Rico, it
is my responsibility to help ensure that Puerto Rican children receive
a quality public school education and that NCLB guidelines are
followed. As we have identified the PRDE's widespread mismanagement,
what recommendations do you have for me in my role as Member of the
Committee to improve Puerto Rico's situation? How do you think I can
serve in the most helpful role in NCLB reauthorization?
I, Chairman George Miller (D-CA) ask that you respond to the
following questions:
1. In your written statement, you note that the Department is
investigating whether there have been violations of the anti-inducement
provisions of the HEA and that FSA has teams performing on-site reviews
of 44 schools and 26 lenders. When were these teams established? For
each of the 44 schools and 26 lenders, please provide the date(s) on
which FSA teams performed an on-site review. Also, please provide the
guidance, standards, and criteria the Department has provided to these
teams to conduct these on-site reviews for the purpose of establishing
violations or potential violations of the anti-inducement provisions of
the HEA.
2. In your written statement, you note that the Department has
issued schools 124 citations and assessments totaling nearly $4.4
million for lack of administrative capability over the last 5 fiscal
years. How many of these citations involved violations or potential
violations of the anti-inducement provisions of the HEA? How many of
these citations involved schools' administration of the title IV
student loan programs? Please specify the number of schools that had
violations, the specific violations, and the number of violations for
each school, by fiscal year. How many of these violations were
identified as a result of on-site reviews conducted by FSA?
______
Responses to May 23, 2007 Written Questions for the Committee on
Education and Labor
Rep. McKeon
1. In comparison to the Clinton Administration, can you tell us how
many program reviews and audits were handled by the Federal Student Aid
Office during the Clinton administration and the current one?
Federal Student Aid monitors schools and lenders that participate
in the Title IV federal student aid programs by reviewing required
annual compliance audits and financial statements, performing on-site
program reviews, and analyzing industry data to detect trends and areas
that could be of concern. Thirty-five thousand eight hundred and
seventy five (35,875) program reviews, on-site program reviews, reviews
of annual compliance audits received and reviews of financial
statements received for schools, lenders, guaranty agencies, and third-
party servicers were completed by Federal Student Aid for six fiscal
years beginning in FY 2001 and continuing through FY 2006. While we do
not have comparable data for the full prior eight-year period, between
FY 1994 and FY 1999, Federal Student Aid completed thirty-five thousand
three hundred and seventy four (35,374) such reviews for schools,
lenders, guaranty agencies, and third-party servicers participating in
our programs.
2. In addition, please provide a comparison of the last 20 years in
number of reviews and audits.
We have data for the past 13 years. Since FY 1994, the Department
has conducted well over 70,000 on-site, annual compliance audit or
financial statement reviews of schools and lenders participating in the
Title IV programs. Thus, the requested comparison shows that about the
same number of program reviews and audits had been conducted during the
six-year period FY 94--FY 99 as were conducted in the six-year period
FY 01--FY 06.
3. What actions did the Clinton administration take to limit 9.5
payments following their 1996 ``Dear Colleague'' letter which increased
the number of loans eligible for 9.5?
We know of no specific government actions, prior to legislative
changes in 2004, to limit increases for any reason in the number of
loans eligible for 9.5 percent SAP. However, the question refers to the
1996 Dear Colleague Letter as increasing the number of loans eligible
for 9.5 percent SAP. Because the Dear Colleague simply interpreted
existing regulations, the letter did not change those regulations to
make eligible for 9.5 percent SAP loans that were not otherwise
eligible for 9.5 percent SAP under the HEA and Department regulations.
The Dear Colleague Letter may have made lenders aware of latitude
already available under those existing regulations, and may have
prompted lenders in later years to engage in practices that increased
the number of loans eligible for 9.5 percent SAP over what they might
otherwise have acquired and treated as eligible for 9.5 percent SAP.
However, the Dear Colleague Letter, as we have explained repeatedly, in
no way supported the practice of Nelnet or other lenders that treated
loans which were neither first-generation nor second-generation loans,
as explained in Dear Colleague Letter FP-07-01, as 9.5 percent SAP-
eligible.
Rep. Thomas Petri
1. How many lenders have made claims similar to Nelnet and what is
the loan volume associated with these claims for 9.5% subsidy?
Nelnet's Project 950 was unique in its scope. The Department has
not conducted reviews to determine whether other lenders made ``similar
claims,'' and if so, to what extent such claims were made. As to the
question of loan volume, please see the 9.5% Summary Excel File
(Attachment 1), which presents all 9.5% volume, billed each year, as of
September 30, 2007.
Rep. Fortuno
1. In your view, what are the chronic problems that plague the
Puerto Rico Department of Education (PRDE) and prevent them from
reaching peak performance? Why are they continuing to fail in providing
a decent education to Puerto Rico's 575,000 public school children?
The major problems that need to be addressed include the following:
the need to improve the functioning of a complex financial management
system; the hiring and retention of qualified management staff to
oversee Federal programs; the establishment of an independent internal
audit capability; and the development of a reliable academic data
management system required for decisions leading to informed academic
instruction decisions and improved student learning. Additional
problems have been identified in annual single audits, and other
monitoring, audits and reviews. For example in the most recent single
audit, the problems identified included the following: delays in
implementing corrective steps in developing internal audit capability;
deficiencies in the time distribution system and in payroll processing;
and deficiencies in procurement documentation, and in equipment
inventory due to transactions not being properly recorded. PRDE is
making progress on some of these items and those mentioned above, but
further progress is important in improving the provision of education
to students in Puerto Rico.
2. How do you plan for better Federal oversight of the PRDE?
Clearly, the plans they have proposed for improvement are not at all
effective. In you response, I would like to see a detailed timeline, a
list of benchmarks for success, and deadlines for improvement. In
addition, I would like to receive bimonthly written updates upon
receipt of your response.
The Department has a risk management team that works very closely
with each of the Department's program offices and PRDE to ensure that
there is appropriate monitoring of these and other issues, to help
provide appropriate technical assistance to PRDE, and to hold PRDE
accountable for progress towards compliance with all applicable Federal
program and fiscal requirements. This team meets with PRDE quarterly to
review progress of the current corrective action plans that were
implemented under the current compliance agreement between the
Department and PRDE, and to provide technical assistance. Based on two
and a half years of implementation of the action plans, the team has
determined that PRDE's plans for improvement were somewhat effective,
and helped PRDE make progress in certain areas. PRDE's expectation,
however, that the improvements needed could be achieved in 3 years was
not, in all cases, realistic. Federal oversight has resulted in several
letters regarding compliance with NCLB, which include timelines and
benchmarks and consequences for noncompliance. The letters are attached
for your reference (Attachment 2).
3. My staff and the Congressional Research Service have had
continual problems obtaining reliable data on NCLB implementation in
Puerto Rico. My staff was advised by your employees that the PRDE only
recently agreed they needed to update their data collection systems.
What progress have they made in that area, and what new data have they
submitted in recent weeks?
PRDE recently submitted their proposed EDFacts Transition Plan for
providing data including NCLB data for 2006-07, 2007-08, and 2008-09.
The Plan is currently being evaluated by the Department. PRDE also
recently submitted a Highly Qualified Teacher Plan, which is currently
being evaluated by the Department.
4. How is your Department helping to increase the PRDE's staff
retention?
Retention of qualified staff is an important area for improvement
that was identified jointly by the Department and PRDE. However, while
the Department is encouraging attention to this problem of staff
retention, the resolution of this concern appears to involve matters
that are primarily ones that should be resolved locally and not through
Federal action.
5. As Representative of the 4 million citizens of Puerto Rico, it
is my responsibility to help ensure that Puerto Rican children receive
a quality public school education and that NCLB guidelines are
followed. As we have identified the PRDE's widespread mismanagement,
what recommendations do you have for me in my role as Member of the
Committee to improve Puerto Rico's situation? How do you think I can
serve in the most helpful role in NCLB reauthorization?
I appreciate that you have shared your concerns for the education
of the children of Puerto Rico. We look forward to working with you to
address the concerns you have expressed in these questions and during
the May 10 hearing as we continue to provide assistance and hold PRDE
accountable for improving the management of Federal grants and
improving student achievement.
Chairman George Miller
1. In your written statement, you note the Department is
investigating whether there have been violations of the anti-inducement
provisions of the HEA and that FSA has teams performing on-site reviews
of 44 schools and 26 lenders. When were these teams established? For
each of the 44 schools and 26 lenders, please provide the date(s) on
which the FSA teams performed an on-site review. Also, please provide
the guidance, standards and criteria the Department has provided to
these teams to conduct these on-site reviews for the purpose of
establishing violations or potential violations of the anti-inducement
provisions of the HEA.
Federal Student Aid established the teams conducting those reviews
referenced in the May 10 testimony in April 2007. Of the reviews
referenced in that testimony, to date, we have conducted inducement
reviews at the University of Wisconsin-Milwaukee, Student Loan Express
and Fifth Third Bank. We are in the process of conducting three
additional school reviews and plan to conduct two additional school,
three lender and one Eligible Lender Trustee reviews later this summer.
We will continue to schedule and perform reviews at the remaining
educational and financial institutions.
In order to ensure effective reviews, we do not disclose the
specifics of the program review procedures that we use to review these
organizations. However, general areas of review will include:
Agreements, policies, practices or procedures between
schools and lenders, loan holders, servicers, software providers or
marketing firms acting on their behalf;
Participation by school personnel on advisory boards of
lenders, loan holders, servicers or software providers;
Consulting or other paid relationships or agreements
between school officials and lenders, loan holders, servicers or
software providers;
Financial interest by school personnel in lender, loan
holders, servicers or software providers; and
Compensation provided to schools personnel by lender, loan
holders, servicers or software providers.
2. In your written statement, you note the Department has issued
schools 124 citations and assessments totaling nearly $4.4 million for
lack of administrative capability over the last 5 fiscal years. How
many of these citations involved violations or potential violations of
the anti-inducement provisions of the HEA? How many of these citations
involved schools' administration of the title IV student loan programs?
Please specify the number of schools that had violations, the specific
violations, and the number of violations for each school, by fiscal
year. How many of these violations were identified as a result of on-
site reviews conducted by FSA?
As we indicated, through our on-site program reviews, we identified
some 236 instances (including the 124 mentioned in the statement) in
which schools demonstrated failures to administer Federal student aid
according to general administrative requirements, as opposed to
violations of specific program rules. These findings were not for
violations of the inducement provisions. In these 236 instances we
cited the schools and we required corrective action, even though the
deficiencies may not have caused a specific, identified misuse of
Federal funds. We also identified in these reviews numerous instances--
totaling some $4.4 million--in which these very deficiencies actually
resulted in improper expenditures of Federal student aid, for which the
school is liable.
The following chart details the number of violations (including the
original 124) cited by deficiency by year; all but 10 of which were
identified in our on-site program reviews.
______
May 11, 2007.
Hon. George Miller, Chairman,
Committee on Education and Labor, Rayburn House Office Building,
Washington, DC.
Dear Chairman Miller: During the May 10 hearing on ``Accountability
for the Department of Education's Oversight of Student Loans and the
Reading First Program,'' in which Secretary of Education Margaret
Spellings testified, you reported that Indiana University left the
Federal Direct Loan Program as a result of receiving a $3 million
dollar line of credit from Sallie Mae. This is incorrect. This false
assertion has appeared in some national media and may have been brought
to your attention without having been verified.
Indiana University is comprised of seven campuses. Prior to 2003,
two of those campuses participated in the Direct Loan Program and five
were in the Federal Family Education Loan Program (FFELP). In 2003,
Indiana University went through a major software conversion. A review
of non-academic services was completed by Arthur Anderson Consultants
in 2001. The recommendation was to use either the Direct Loan Program
or the FFELP for all campuses. Both programs worked well for Indiana
University, but a committee was formed to review the consultants'
recommendations and the decision was made to use the FFELP for all
campuses. This decision was made independently from any relationship
with the lending community.
Indiana University sent a request for proposal for student loan
processing to multiple vendors in June 2003. The request for proposal
did not include any opportunity loan provisions. The $3 million in
opportunity loans was included as a private loan alternative and is not
based on loan volume. These funds are used as a last resort loan for
students with no other options to fund a college education. Indiana
University exhausts all other financing options before suggesting an
opportunity loan.
Indiana University did not receive any funds from Sallie Mae for
transferring from the Direct Loan Program to FFELP. It was determined
that supporting both programs would require additional implementation
and maintenance costs for the new student information system. The
decision to move to a single system was made in the interest of
efficiency, student service and cost savings.
Thank you for the opportunity to respond to the inaccurate
statement about Indiana University and the reason for the transfer to
the FFELP for two of the IU campuses. It is our hope that the official
hearing record would be corrected to reflect the fact that we did not
receive any payments for leaving the Direct Loan Program. We stand
ready to provide any additional information on this matter.
Sincerely,
Thomas C. Healy,
Vice President for Government Relations.
______
[Additional submissions from Secretary Spellings follow:]
2006 9.5 SAP SUMMARY
------------------------------------------------------------------------
Tax Exempt Loans
--------------------------------------
Lender Special Allowance Ending Principal
Payments Balance
------------------------------------------------------------------------
833500 WELLS FARGO ELT NELNET $158,373,973 $2,728,074,557
ED LOAN FUND.
828924 AES/PHEAA............. $59,627,998 $1,196,188,921
826688 KENTUCKY HIGHER ED $40,106,950 $699,065,806
STUDENT LOAN COR.
833948 BANK OF NY ELT EDSOUTH $30,940,457 $564,620,484
830075 VSAC EDUCATION LOAN $28,034,326 $530,904,225
FINANCE PROGRAM.
827825 IOWA STUDENT LOAN $21,291,088 $412,178,900
LIQUIDITY CORP.
832095 WELLS FARGO ELT $18,360,030 $348,849,840
PANHANDLE PLAINS.
825585 MICHIGAN HIGHER $17,561,882 $412,663,043
EDUCATION STUD LOAN.
830630 SOUTHWEST STUDENT SERV $17,235,161 $307,516,895
TRUST WFB EL.
822717 NEW MEXICO EDUC ASST $13,855,233 $259,928,343
FOUNDATION.
834097 WELLS FARGO ELT NTHEA $11,976,579 $251,471,061
INC.
827866 COLLEGEINVEST......... $11,738,633 $253,422,510
833806 US BANK ELT BHEA...... $10,511,074 $254,471,434
828476 UTAH STATE BOARD OF $9,613,279 $163,242,746
REGENTS.
828863 MISSOURI HIGHER $8,878,031 $153,817,735
EDUCATION LOAN AUTH.
833211 BANK OF NY ELT GTHEA.. $7,707,205 $178,406,284
833405 US BANK ELT ED LOANS $7,450,821 $133,316,799
INC.
831245 SOUTHWEST STUDENT SRV $7,400,183 $141,012,628
TRUST WFB ELT.
829769 UTAH STATE BOARD OF $7,039,426 $131,567,279
REGENTS.
899980 INDIANA SECONDARY $6,653,206 $140,764,497
MARKET.
833016 SC STUDENT LOAN-93 RES $6,545,140 $47,205,330
(SL03).
830631 STUDENT LOAN FUNDING $6,089,827 $114,871,881
US BANK ELT.
832934 BANK OF NY ELT GTHEA $5,892,372 $121,595,074
(93AB).
828868 TRUSTMARK BANK ELT $5,808,316 $103,988,173
MHEAC.
805149 BANK OF NY ELT TTEE $5,087,971 $72,942,850
LELA.
826764 INDUSTRIAL COMMISSION. $4,737,974 $60,863,311
826717 UTAH STATE BOARD OF $4,706,039 $103,914,544
REGENTS.
828577 RHODE ISLAND STUDENT $4,217,950 $97,681,990
LOAN AUTHORITY.
833264 WELLS FARGO ELT STHEA $3,608,890 $83,814,523
INC.
831008 STUDENT LOAN FUNDING $3,604,935 $72,552,371
US BANK ELT.
830344 WELLS FARGO ELT MHESAC $3,251,656 $66,350,212
834086 WELLS FARGO ELT BRAZOS $3,096,241 $53,575,742
HEA.
832919 BANK OF NY ELT ALL $3,036,588 $53,246,222
STUDENT LOAN COR.
826351 ILL DESIGNATED ACCOUNT $2,611,876 $52,661,912
PURCHASE PR.
821666 WELLS FARGO ELT FOR $2,567,218 $45,034,222
SLAAA.
827283 WYOMING STUDENT LOAN $2,542,007 $61,487,189
CORPORATION.
826966 ALASKA (ACPE)......... $2,460,035 $50,258,274
829691 ZIONS BANK ELT SLFA-WA $2,087,202 $38,565,684
INC.
833017 S C STUDENT LLR....... $1,881,549 $17,466,740
832339 BANK OF NY ELT GTHEA $1,785,080 $36,960,240
(92AB).
830351 SC STUDENT LOAN CORP $1,604,563 $33,220,877
(SL05).
833691 NELLIE MAE JPMORGAN $1,538,672 $26,697,813
CHASE ELT.
834023 MISSOURI HIGHER $1,529,182 $72,746,901
EDUCATION LOAN AUTH.
820164 UNION BK CA ELT CHELA $1,392,916 $3,168
FUND I (TEFFC).
831692 STUDENT LOAN FUNDING $1,391,900 $7,961,956
US BANK ELT.
833741 WELLS FARGO ELT CTSLC $1,375,356 $29,801,033
LLC.
833347 BANK OF NY ELT $1,321,448 $26,243,226
PANHANDLE PLAINS HEA.
825659 OKLAHOMA STUDENT LOAN $1,253,033 $29,069,493
AUTHORITY.
830628 IDAPP................. $745,832 $28,202,834
808780 FIFTH THIRD ELT SLFR $709,541 $11,900,531
MD 10907A.
832776 JPMORGAN CHASE ELT SMS $687,419 $13,055,632
CORP--HI.
833752 BANK OF NY ELT ALL $684,281 $17,952,418
STUDENT LOAN COR.
805178 BANK OF NY ELT TTEE $600,580 $23,137,957
LELA.
830248 UTAH STATE BOARD OF $572,615 $12,443,094
REGENTS/STNF.
812089 TEXAS HIGHER EDUCATION $424,017 $16,891,628
COORD BOARD.
831300 MELMAC LLC ZIONS BANK $325,853 $18,014,051
ELT.
831785 STUDENT LOAN FUNDING $296,983 $5,440,874
US BANK ELT.
831387 BANK OF MISSISSIPPI $295,997 $12,569,426
ELT MHEAC.
821614 UNION BANK CA ELT $249,317 .................
CHELA FUND I (TEF).
807037 COLLEGE FOUNDATION INC $193,126 $5,484,040
834096 BANCORPSOUTH ELT MHEAC $183,356 $8,482,235
834170 BANK OF NY ELT EDSOUTH $175,307 $3,383,077
833668 SC STUDENT LOAN CORP $124,154 $2,057,939
(LL05).
829189 ALABAMA HIGHER $101,677 $3,074,842
EDUCATION LOAN CORP.
834095 TRUSTMARK ELT MHEAC... $65,978 $4,260,964
828875 COLLEGEINVEST......... $53,595 $1,207,439
821623 UNION BANK CA ELT $37,883 .................
CHELA FUND I (TEF).
813285 UNION BK CA ELT CHELA $34,706 .................
FUND I (TEFFC).
821628 UNION BANK CA ELT $29,916 $0
CHELA FUND I (TEF).
833174 BANK OF NY ELT ALL $23,262 $905,667
STUDENT LOAN COR.
827116 SLF OF IDAHO MARKETING $20,190 $0
ASSN INC.
829064 SOUTHWEST STUDENT SERV $16,503 $521,059
TRUST WFB EL.
820163 UNION BANK CA ELT $12,940 $0
CHELA FUND II (TE).
828200 M H E S A C........... $4,992 $522,781
834246 US BANK ELT $226 .................
KNOWLEDGEFUNDING OHIO.
834225 STUDENT LENDING WORKS $57 .................
INC.
805095 FIRST NATIONAL BANK OF ($5) .................
JEANERETTE.
823817 JPMORGAN CHASE ELT ($14) .................
BRAZOS HEA.
833617 US BANK ELT EFSI...... ($14) .................
834092 M&T BANK ELT PHEAA ($21) $0
LOAN TRUST I.
828148 UNIVERSITY FEDERAL ($29) .................
CREDIT UNION.
833285 US BANK ELT PSFC...... ($43) .................
808717 JPMORGAN CHASE NA ELT ($43) .................
BRAZOS HEA IN.
824573 ZIONS BANK ELT EFS ($87) .................
FINANCE CO.
833495 ZIONS ELT EMT CORP.... ($109) .................
821920 FIRSTRUST SAVINGS BANK ($111) .................
833934 ZIONS BANK ELT NELNET ($151) .................
TRUST.
831453 US BANK ELT EDAMERICA. ($769) .................
825600 NEW JERSEY HIGHER ($1,507) $0
EDUCA ASST AUTH.
834099 UNION BANK CA ELT ($784,111) $0
CHELA FUND I (TEF)).
826509 ARKANSAS STUDENT LOAN ($5,968,655) $74,272,483
AUTHORITY.
--------------------------------------
Total............. $581,296,104 $11,106,045,909
------------------------------------------------------------------------
2005 9.5 SAP SUMMARY
------------------------------------------------------------------------
Tax Exempt Loans
--------------------------------------
Lender Special Allowance Ending Principal
Payments Balance
------------------------------------------------------------------------
833500 WELLS FARGO ELT NELNET $177,688,062 $3,026,977,030
ED LOAN FUND.
828924 AES/PHEAA............. $101,293,604 $1,729,507,729
826688 KENTUCKY HIGHER ED $51,890,219 $810,766,884
STUDENT LOAN COR.
833948 BANK OF NY ELT EDSOUTH $39,282,038 $699,762,255
830075 VSAC EDUCATION LOAN $36,111,916 $718,336,382
FINANCE PROGRAM.
827825 IOWA STUDENT LOAN $31,287,769 $605,324,814
LIQUIDITY CORP.
830630 SOUTHWEST STUDENT SERV $30,968,234 $520,582,111
TRUST WFB EL.
832095 WELLS FARGO ELT $26,747,125 $449,047,641
PANHANDLE PLAINS.
820164 UNION BK CA ELT CHELA $24,467,330 $329,975,617
FUND I (TEFFC).
834097 WELLS FARGO ELT NTHEA $23,323,937 $462,486,498
INC.
833806 US BANK ELT BHEA...... $23,093,916 $393,742,962
825585 MICHIGAN HIGHER $20,376,928 $450,996,409
EDUCATION STUD LOAN.
833211 BANK OF NY ELT GTHEA.. $17,823,455 $220,936,475
832934 BANK OF NY ELT GTHEA $16,361,856 $151,217,885
(93AB).
822717 NEW MEXICO EDUC ASST $16,271,646 $326,534,104
FOUNDATION.
831008 STUDENT LOAN FUNDING $15,899,060 $227,530,128
US BANK ELT.
834071 SLM EDUCATION FINANCE $14,527,226 .................
CREDIT CORP.
827866 COLLEGEINVEST......... $12,629,659 $284,213,538
833691 NELLIE MAE JPMORGAN $12,278,053 $50,311,950
CHASE ELT.
899980 INDIANA SECONDARY $11,943,493 $233,680,646
MARKET.
805149 BANK OF NY ELT TTEE $11,278,126 $107,124,886
LELA.
826509 ARKANSAS STUDENT LOAN $10,966,627 $268,612,484
AUTHORITY.
831245 SOUTHWEST STUDENT SRV $10,547,670 $189,107,512
TRUST WFB ELT.
831593 JPMORGAN CHASE ELT $10,349,941 $0
GTSLC (96AB).
828863 MISSOURI HIGHER $10,331,060 $304,572,569
EDUCATION LOAN AUTH.
833405 US BANK ELT ED LOANS $10,305,698 $174,003,209
INC.
831692 STUDENT LOAN FUNDING $10,182,570 $161,507,049
US BANK ELT.
829769 UTAH STATE BOARD OF $10,102,619 $169,990,910
REGENTS.
833016 SC STUDENT LOAN-93 RES $8,988,615 $144,520,758
(SL03).
830631 STUDENT LOAN FUNDING $8,948,896 $147,542,516
US BANK ELT.
834099 UNION BANK CA ELT $7,627,815 $173,922,158
CHELA FUND I (TEF).
826764 INDUSTRIAL COMMISSION. $6,592,389 $94,111,474
828868 TRUSTMARK BANK ELT $6,128,911 $126,468,029
MHEAC.
826351 ILL DESIGNATED ACCOUNT $5,800,642 $90,634,395
PURCHASE PR.
832919 BANK OF NY ELT ALL $5,093,520 $68,678,726
STUDENT LOAN COR.
828476 UTAH STATE BOARD OF $4,964,739 $133,197,009
REGENTS.
828577 RHODE ISLAND STUDENT $4,748,651 $95,636,652
LOAN AUTHORITY.
830344 WELLS FARGO ELT MHESAC $4,618,439 $120,945,705
833264 WELLS FARGO ELT STHEA $4,374,596 $87,616,895
INC.
834086 WELLS FARGO ELT BRAZOS $4,094,512 $72,051,061
HEA.
821666 WELLS FARGO ELT FOR $4,032,091 $50,896,131
SLAAA.
820163 UNION BANK CA ELT $3,674,599 $4,017,617
CHELA FUND II (TE).
832339 BANK OF NY ELT GTHEA $3,558,893 $45,731,912
(92AB).
833017 S C STUDENT LLR....... $3,485,006 $42,755,080
827283 WYOMING STUDENT LOAN $2,921,208 $70,811,614
CORPORATION.
808780 FIFTH THIRD ELT SLFR $2,491,743 $27,959,915
MD 10907A.
826966 ALASKA (ACPE)......... $2,404,331 $50,235,014
829691 ZIONS BANK ELT SLFA-WA $2,396,153 $45,325,275
INC.
833741 WELLS FARGO ELT CTSLC $2,368,570 $62,465,045
LLC.
826717 UTAH STATE BOARD OF $2,181,643 $145,952,647
REGENTS.
834023 MISSOURI HIGHER $2,161,068 $95,015,441
EDUCATION LOAN AUTH.
825659 OKLAHOMA STUDENT LOAN $1,936,903 $33,256,289
AUTHORITY.
833347 BANK OF NY ELT $1,776,017 $28,990,206
PANHANDLE PLAINS HEA.
821628 UNION BANK CA ELT $1,669,391 $12,800,834
CHELA FUND I (TEF).
830628 IDAPP................. $1,335,648 $40,390,786
812089 TEXAS HIGHER EDUCATION $1,303,147 $25,159,870
COORD BOARD.
830351 SC STUDENT LOAN CORP $1,248,275 $45,878,614
(SL05).
813285 UNION BK CA ELT CHELA $1,154,967 $12,440,671
FUND I (TEFFC).
805178 BANK OF NY ELT TTEE $1,043,293 $28,206,702
LELA.
831640 STUDENT LOAN FUNDING $1,037,846 $0
US BANK ELT.
821623 UNION BANK CA ELT $1,024,679 $21,041,801
CHELA FUND I (TEF).
830248 UTAH STATE BOARD OF $927,051 $16,965,643
REGENTS/STNF.
831387 BANK OF MISSISSIPPI $848,309 $15,805,618
ELT MHEAC.
831299 STUDENT LOAN FUNDING $807,046 .................
US BANK ELT.
832776 JPMORGAN CHASE ELT SMS $700,352 $16,395,135
CORP--HI.
833668 SC STUDENT LOAN CORP $626,137 $3,890,796
(LL05).
831785 STUDENT LOAN FUNDING $573,244 $7,459,365
US BANK ELT.
831300 MELMAC LLC ZIONS BANK $453,860 $23,016,566
ELT.
807037 COLLEGE FOUNDATION INC $445,779 $8,339,524
834096 BANCORPSOUTH ELT MHEAC $430,433 $11,450,137
821614 UNION BANK CA ELT $276,645 $1,053,869
CHELA FUND I (TEF).
829189 ALABAMA HIGHER $249,645 $4,618,133
EDUCATION LOAN CORP.
834095 TRUSTMARK ELT MHEAC... $177,395 $7,193,421
823817 JPMORGAN CHASE ELT $161,505 .................
BRAZOS HEA.
808717 JPMORGAN CHASE NA ELT $129,245 .................
BRAZOS HEA IN.
828875 COLLEGEINVEST......... $122,282 $1,773,636
827116 SLF OF IDAHO MARKETING $109,817 $3,183,063
ASSN INC.
833174 BANK OF NY ELT ALL $50,134 $1,547,485
STUDENT LOAN COR.
829064 SOUTHWEST STUDENT SERV $41,777 $871,183
TRUST WFB EL.
833752 BANK OF NY ELT ALL $34,905 $7,263,341
STUDENT LOAN COR.
833487 BANK OF NY ELT $22,574 .................
LOANSTAR.
828200 M H E S A C........... $10,165 $904,738
831453 US BANK ELT EDAMERICA. $2,355 $0
888885 SLM ECFC.............. $1,363 .................
831119 MO HIGHER ED LOAN $550 .................
AUTHORITY.
832057 JPMORGAN CHASE ELT $319 $0
GTSLC.
833253 JPMORGAN CHASE ELT $238 .................
SLMA TRUST MS181.
821920 FIRSTRUST SAVINGS BANK $111 $29,950
828148 UNIVERSITY FEDERAL $29 .................
CREDIT UNION.
805095 FIRST NATIONAL BANK OF $5 .................
JEANERETTE.
805079 JP MORGAN CHASE ELT ($123) .................
TTEE LELA.
834092 M&T BANK ELT PHEAA ($192) $0
LOAN TRUST I.
833934 ZIONS BANK ELT NELNET ($254) $0
TRUST.
804959 CLS-NATIONAL CITY BANK ($727) $0
KENTUCKY.
825600 NEW JERSEY HIGHER ($2,121) .................
EDUCA ASST AUTH.
834170 BANK OF NY ELT EDSOUTH ($3,374) $0
833659 US BANK ELT THEA INC.. ($6,148) .................
833495 ZIONS ELT EMT CORP.... ($654,253) $0
833617 US BANK ELT EFSI...... ($830,817) .................
--------------------------------------
Total............. $911,222,291 $15,443,268,122
------------------------------------------------------------------------
2004 9.5 SAP SUMMARY
------------------------------------------------------------------------
Tax Exempt Loans
--------------------------------------
Lender Special Allowance Ending Principal
Payments Balance
------------------------------------------------------------------------
833500 WELLS FARGO ELT NELNET $165,964,491 $3,339,192,122
ED LOAN FUND.
828924 AES/PHEAA............. $94,245,479 $2,311,383,351
833691 NELLIE MAE JPMORGAN $58,945,506 $366,796,730
CHASE ELT.
833948 BANK OF NY ELT EDSOUTH $43,963,416 $797,497,368
826688 KENTUCKY HIGHER ED $41,119,877 $1,070,239,627
STUDENT LOAN COR.
830075 VSAC EDUCATION LOAN $32,826,782 $740,944,702
FINANCE PROGRAM.
831008 STUDENT LOAN FUNDING $31,037,558 $475,709,505
US BANK ELT.
827825 IOWA STUDENT LOAN $30,830,826 $683,631,789
LIQUIDITY CORP.
830630 SOUTHWEST STUDENT SERV $29,684,151 $550,761,841
TRUST WFB EL.
820164 UNION BK CA ELT CHELA $26,896,311 $504,522,280
FUND I (TEFFC).
832095 WELLS FARGO ELT $22,516,965 $514,752,201
PANHANDLE PLAINS.
825585 MICHIGAN HIGHER $21,164,723 $489,247,950
EDUCATION STUD LOAN.
834097 WELLS FARGO ELT NTHEA $18,031,831 $509,801,570
INC.
828863 MISSOURI HIGHER $16,651,011 $317,323,001
EDUCATION LOAN AUTH.
833806 US BANK ELT BHEA...... $13,898,231 $517,184,628
820163 UNION BANK CA ELT $11,262,397 $215,890,951
CHELA FUND II (TE).
826717 UTAH STATE BOARD OF $11,121,882 $244,121,663
REGENTS.
829769 UTAH STATE BOARD OF $10,717,805 $204,570,100
REGENTS.
899980 INDIANA SECONDARY $10,700,910 $271,214,078
MARKET.
827866 COLLEGEINVEST......... $10,679,367 $254,431,325
831692 STUDENT LOAN FUNDING $10,466,391 $166,146,221
US BANK ELT.
833455 ZIONS FNB ELT NMEAF... $10,328,327 .................
833016 SC STUDENT LOAN-93 RES $9,097,091 $201,738,488
(SL03).
830631 STUDENT LOAN FUNDING $8,719,417 $142,499,296
US BANK ELT.
833405 US BANK ELT ED LOANS $8,253,708 $169,965,769
INC.
833211 BANK OF NY ELT GTHEA.. $7,361,585 $164,006,075
826509 ARKANSAS STUDENT LOAN $7,044,031 $182,739,742
AUTHORITY.
826351 ILL DESIGNATED ACCOUNT $6,985,563 $117,024,701
PURCHASE PR.
826764 INDUSTRIAL COMMISSION. $6,596,849 $103,371,995
831245 SOUTHWEST STUDENT SRV $5,934,696 $190,947,186
TRUST WFB ELT.
831299 STUDENT LOAN FUNDING $5,719,413 $93,090,614
US BANK ELT.
830344 WELLS FARGO ELT MHESAC $5,301,677 $114,205,552
822717 NEW MEXICO EDUC ASST $4,999,746 $323,123,068
FOUNDATION.
832934 BANK OF NY ELT GTHEA $4,977,023 $86,411,002
(93AB).
808780 FIFTH THIRD ELT SLFR $4,939,979 $75,846,587
MD 10907A.
821628 UNION BANK CA ELT $4,436,641 $82,972,203
CHELA FUND I (TEF).
832919 BANK OF NY ELT ALL $4,434,016 $77,916,222
STUDENT LOAN COR.
821666 WELLS FARGO ELT FOR $4,204,932 $69,862,785
SLAAA.
828868 TRUSTMARK BANK ELT $3,929,426 $87,712,640
MHEAC.
833088 BANK ONE NA TRUSTEE $3,899,945 .................
FOR NTHEA.
833017 S C STUDENT LLR....... $3,353,552 $56,735,313
828577 RHODE ISLAND STUDENT $3,329,379 $95,024,933
LOAN AUTHORITY.
833264 WELLS FARGO ELT STHEA $3,063,498 $69,366,228
INC.
827283 WYOMING STUDENT LOAN $2,897,287 $70,928,544
CORPORATION.
833741 WELLS FARGO ELT CTSLC $2,883,579 $66,312,905
LLC.
821623 UNION BANK CA ELT $2,596,843 $45,241,468
CHELA FUND I (TEF).
834023 MISSOURI HIGHER $2,490,650 $117,047,788
EDUCATION LOAN AUTH.
828476 UTAH STATE BOARD OF $2,469,654 $52,740,015
REGENTS.
829691 ZIONS BANK ELT SLFA-WA $2,372,818 $41,300,532
INC.
825659 OKLAHOMA STUDENT LOAN $2,173,014 $35,716,015
AUTHORITY.
813285 UNION BK CA ELT CHELA $2,061,163 $41,199,973
FUND I (TEFFC).
834099 UNION BANK CA ELT $1,901,702 $70,847,326
CHELA FUND I (TEF).
833347 BANK OF NY ELT $1,880,185 $32,971,477
PANHANDLE PLAINS HEA.
831387 BANK OF MISSISSIPPI $1,643,182 $27,783,192
ELT MHEAC.
832339 BANK OF NY ELT GTHEA $1,623,020 $33,822,916
(92AB).
812089 TEXAS HIGHER EDUCATION $1,544,534 $29,772,965
COORD BOARD.
831640 STUDENT LOAN FUNDING $1,430,866 $22,186,105
US BANK ELT.
826966 ALASKA (ACPE)......... $1,428,616 $31,348,683
805178 BANK OF NY ELT TTEE $1,374,494 $33,308,294
LELA.
830351 SC STUDENT LOAN CORP $1,300,524 $32,011,598
(SL05).
830628 IDAPP................. $1,257,000 $39,944,500
831593 JPMORGAN CHASE ELT $1,246,822 $16,390,928
GTSLC (96AB).
821614 UNION BANK CA ELT $963,442 $14,727,917
CHELA FUND I (TEF).
830248 UTAH STATE BOARD OF $953,652 $22,537,458
REGENTS/STNF.
831300 MELMAC LLC ZIONS BANK $929,420 $31,794,957
ELT.
833668 SC STUDENT LOAN CORP $877,654 $12,686,042
(LL05).
833617 US BANK ELT EFSI...... $834,516 $0
834086 WELLS FARGO ELT BRAZOS $804,451 $54,471,862
HEA.
807037 COLLEGE FOUNDATION INC $637,097 $11,596,990
832776 JPMORGAN CHASE ELT SMS $562,109 $13,814,741
CORP--HI.
831785 STUDENT LOAN FUNDING $490,083 $7,437,095
US BANK ELT.
832765 WELLS FARGO BANK ELT $470,140 .................
NMEAF.
834096 BANCORPSOUTH ELT MHEAC $422,949 $17,455,990
829189 ALABAMA HIGHER $413,647 $7,026,190
EDUCATION LOAN CORP.
805079 JP MORGAN CHASE ELT $267,789 $5,134
TTEE LELA.
823817 JPMORGAN CHASE ELT $219,454 $0
BRAZOS HEA.
827116 SLF OF IDAHO MARKETING $198,544 $5,087,693
ASSN INC.
828875 COLLEGEINVEST......... $159,206 $2,152,006
834095 TRUSTMARK ELT MHEAC... $137,782 $10,896,666
833174 BANK OF NY ELT ALL $73,994 $2,149,982
STUDENT LOAN COR.
829064 SOUTHWEST STUDENT SERV $68,553 $1,327,959
TRUST WFB EL.
831453 US BANK ELT EDAMERICA. $54,509 $5,109
833495 ZIONS ELT EMT CORP.... $17,408 $0
828200 M H E S A C........... $15,674 $1,388,099
829988 NELLIE MAE JPMORGAN $4,933 $68,418
CHASE ELT.
824573 ZIONS BANK ELT EFS $4,653 .................
FINANCE CO.
808717 JPMORGAN CHASE NA ELT $3,985 $0
BRAZOS HEA IN.
804959 CLS-NATIONAL CITY BANK $2,605 $11,337
KENTUCKY.
831119 MO HIGHER ED LOAN $994 $14,332
AUTHORITY.
832057 JPMORGAN CHASE ELT $445 $30,977
GTSLC.
806466 STATE BANK OF FAIRMONT $41 .................
818119 FARMERS & MERCHANTS $9 .................
STATE BANK.
832775 JP MORGANCHASE ELT USA $2 .................
GROUP SMS.
821347 OREGONIANS CU......... ($11) .................
823990 FAMILY CREDIT UNION... ($30) .................
833078 US BANK ELT BSFC...... ($66) .................
813020 MELLON BANK MARYLAND ($117) .................
REGION.
828384 THE FIRST NATIONAL ($123) .................
BANK/BALLINGER.
809747 MELLON BANK NA ($140) .................
(WESTERN REGION).
828737 COUNTYWIDE FEDERAL ($156) .................
CREDIT UNION.
822239 COMPASS BANK.......... ($228) .................
804091 IOWA FALLS STATE BANK. ($235) .................
805149 BANK OF NY ELT TTEE ($258) $0
LELA.
828729 CENTRAL MICHIGAN ($338) .................
COMMUNITY FED CR U.
828148 UNIVERSITY FEDERAL ($512) $0
CREDIT UNION.
833295 TAIWANESE AMERICAN FCU ($719) .................
834092 M&T BANK ELT PHEAA ($801) $0
LOAN TRUST I.
827291 PEOPLES BANK AND TRUST ($927) .................
COMPANY.
831783 COMMUNITY CHOICE ($1,780) .................
CREDIT UNION.
825600 NEW JERSEY HIGHER ($2,165) $0
EDUCA ASST AUTH.
833659 US BANK ELT THEA INC.. ($2,187) .................
831651 FIRST NATIONAL BANK OF ($2,664) $0
COWETA.
817717 BRIDGETON ONIZED FCU.. ($3,658) .................
834047 UNIVERSITY OF NORTHERN ($4,473) .................
COLORADO.
804655 GREENSBURG STATE BANK. ($4,907) .................
827952 EXCHANGE STATE BANK... ($10,799) .................
804134 UNITED METHOD ($35,323) .................
MINISTERS' CU.
--------------------------------------
Total............. $885,729,480 $18,107,485,580
------------------------------------------------------------------------
2003 9.5 SAP SUMMARY
------------------------------------------------------------------------
Tax Exempt Loans
--------------------------------------
Lender Special Allowance Ending Principal
Payments Balance
------------------------------------------------------------------------
833691 NELLIE MAE JPMORGAN $78,675,283 $1,178,697,172
CHASE ELT.
828924 AES/PHEAA............. $60,831,265 $1,474,903,695
833500 WELLS FARGO ELT NELNET $38,362,110 $1,713,168,009
ED LOAN FUND.
831008 STUDENT LOAN FUNDING $32,625,958 $613,901,913
US BANK ELT.
831453 US BANK ELT EDAMERICA. $27,910,960 $2,818,796
820164 UNION BK CA ELT CHELA $27,340,787 $579,720,816
FUND I (TEFFC).
827825 IOWA STUDENT LOAN $18,218,039 $371,770,704
LIQUIDITY CORP.
830075 VSAC EDUCATION LOAN $16,674,557 $376,722,853
FINANCE PROGRAM.
825585 MICHIGAN HIGHER $16,297,070 $433,979,096
EDUCATION STUD LOAN.
828863 MISSOURI HIGHER $16,115,479 $343,105,897
EDUCATION LOAN AUTH.
820163 UNION BANK CA ELT $14,667,627 $279,486,256
CHELA FUND II (TE).
833088 BANK ONE NA TRUSTEE $14,565,432 $523,844,323
FOR NTHEA.
830630 SOUTHWEST STUDENT SERV $13,606,742 $443,675,943
TRUST WFB EL.
833948 BANK OF NY ELT EDSOUTH $12,409,428 $731,856,034
833455 ZIONS FNB ELT NMEAF... $11,937,524 $264,347,556
832095 WELLS FARGO ELT $10,728,192 $324,372,129
PANHANDLE PLAINS.
831692 STUDENT LOAN FUNDING $9,838,752 $168,001,806
US BANK ELT.
899980 INDIANA SECONDARY $9,263,013 $197,918,837
MARKET.
829769 UTAH STATE BOARD OF $8,544,200 $169,792,082
REGENTS.
830631 STUDENT LOAN FUNDING $8,318,284 $139,643,822
US BANK ELT.
827866 COLLEGEINVEST......... $8,091,712 $208,334,230
826351 ILL DESIGNATED ACCOUNT $7,899,572 $140,511,889
PURCHASE PR.
826717 UTAH STATE BOARD OF $7,861,983 $229,995,733
REGENTS.
833016 SC STUDENT LOAN-93 RES $6,764,299 $68,108,896
(SL03).
833211 BANK OF NY ELT GTHEA.. $6,465,973 $163,391,061
823817 JPMORGAN CHASE ELT $5,883,464 $136,411,025
BRAZOS HEA.
821628 UNION BANK CA ELT $5,408,653 $112,302,037
CHELA FUND I (TEF).
831299 STUDENT LOAN FUNDING $5,089,830 $89,305,736
US BANK ELT.
826688 KENTUCKY HIGHER ED $5,073,105 $136,312,611
STUDENT LOAN COR.
826764 INDUSTRIAL COMMISSION. $4,499,494 $104,907,072
808717 JPMORGAN CHASE NA ELT $4,310,059 $35,280,976
BRAZOS HEA IN.
821666 WELLS FARGO ELT FOR $4,284,619 $68,465,008
SLAAA.
808780 FIFTH THIRD ELT SLFR $4,173,252 $65,719,217
MD 10907A.
830344 WELLS FARGO ELT MHESAC $4,024,835 $108,386,740
832934 BANK OF NY ELT GTHEA $3,860,891 $84,468,523
(93AB).
821623 UNION BANK CA ELT $3,235,656 $61,249,458
CHELA FUND I (TEF).
833405 US BANK ELT ED LOANS $3,173,883 $67,452,344
INC.
832919 BANK OF NY ELT ALL $3,122,903 $60,589,875
STUDENT LOAN COR.
831387 BANK OF MISSISSIPPI $2,692,150 $63,307,248
ELT MHEAC.
833017 S C STUDENT LLR....... $2,532,399 $35,626,528
828868 TRUSTMARK BANK ELT $2,419,052 $77,484,091
MHEAC.
828577 RHODE ISLAND STUDENT $2,400,484 $73,583,427
LOAN AUTHORITY.
833741 WELLS FARGO ELT CTSLC $2,297,619 $58,158,647
LLC.
829691 ZIONS BANK ELT SLFA-WA $2,119,020 $49,083,113
INC.
813285 UNION BK CA ELT CHELA $1,923,004 $48,685,608
FUND I (TEFFC).
826509 ARKANSAS STUDENT LOAN $1,921,244 $74,211,364
AUTHORITY.
812089 TEXAS HIGHER EDUCATION $1,893,581 $36,523,386
COORD BOARD.
825659 OKLAHOMA STUDENT LOAN $1,822,052 $38,174,126
AUTHORITY.
833347 BANK OF NY ELT $1,791,907 $28,743,753
PANHANDLE PLAINS HEA.
833266 BANK ONE ELT STHEA.... $1,773,145 $47,586,033
831640 STUDENT LOAN FUNDING $1,547,340 $22,660,287
US BANK ELT.
805178 BANK OF NY ELT TTEE $1,518,773 $40,763,210
LELA.
831245 SOUTHWEST STUDENT SRV $1,314,890 $43,422,371
TRUST WFB ELT.
821614 UNION BANK CA ELT $1,300,545 $19,643,252
CHELA FUND I (TEF).
830628 IDAPP................. $1,286,647 $41,433,204
832339 BANK OF NY ELT GTHEA $1,285,713 $29,806,824
(92AB).
822717 NEW MEXICO EDUC ASST $1,151,503 $28,272,251
FOUNDATION.
832765 WELLS FARGO BANK ELT $999,725 $21,491,750
NMEAF.
834023 MISSOURI HIGHER $970,155 $129,784,496
EDUCATION LOAN AUTH.
807037 COLLEGE FOUNDATION INC $754,079 $14,997,434
833806 US BANK ELT BHEA...... $693,925 $26,587,035
831593 JPMORGAN CHASE ELT $689,561 $13,148,045
GTSLC (96AB).
830248 UTAH STATE BOARD OF $629,224 $14,979,018
REGENTS/STNF.
831785 STUDENT LOAN FUNDING $558,738 $7,596,011
US BANK ELT.
826966 ALASKA (ACPE)......... $478,661 $14,306,569
832776 JPMORGAN CHASE ELT SMS $432,781 $13,059,569
CORP--HI.
827116 SLF OF IDAHO MARKETING $310,113 $8,096,832
ASSN INC.
830351 SC STUDENT LOAN CORP $259,730 $33,562,244
(SL05).
828476 UTAH STATE BOARD OF $171,218 $11,966,285
REGENTS.
829064 SOUTHWEST STUDENT SERV $106,879 $2,323,599
TRUST WFB EL.
833174 BANK OF NY ELT ALL $101,738 $2,728,290
STUDENT LOAN COR.
828875 COLLEGEINVEST......... $94,662 $2,810,561
833668 SC STUDENT LOAN CORP $88,623 $14,116,397
(LL05).
805079 JP MORGAN CHASE ELT $82,899 $1,459,695
TTEE LELA.
831119 MO HIGHER ED LOAN $65,524 $51,478
AUTHORITY.
828200 M H E S A C........... $24,735 $2,047,943
804134 UNITED METHOD $24,050 $493,504
MINISTERS' CU.
832260 WELLS FARGO ELT MHESAC $8,280 .................
829988 NELLIE MAE JPMORGAN $6,469 $87,443
CHASE ELT.
827952 EXCHANGE STATE BANK... $4,925 $55,617
804655 GREENSBURG STATE BANK. $4,907 $119,397
834047 UNIVERSITY OF NORTHERN $4,556 $756,092
COLORADO.
817717 BRIDGETON ONIZED FCU.. $2,270 .................
831651 FIRST NATIONAL BANK OF $2,066 $29,014
COWETA.
817380 TVA CU................ $1,848 .................
819907 JP MORGAN CHASE ELT $1,841 .................
TTEE LELA.
804959 CLS-NATIONAL CITY BANK $1,201 $26,102
KENTUCKY.
804071 HARTWICK STATE BANK... $1,132 .................
833295 TAIWANESE AMERICAN FCU $839 $15,843
832057 JPMORGAN CHASE ELT $826 $35,060
GTSLC.
827291 PEOPLES BANK AND TRUST $498 $11,009
COMPANY.
830427 JP MORGAN CHASE ELT $313 $0
TTEE LELA.
828729 CENTRAL MICHIGAN $262 $11,279
COMMUNITY FED CR U.
806466 STATE BANK OF FAIRMONT $232 $10,005
828737 COUNTYWIDE FEDERAL $176 $7,463
CREDIT UNION.
828384 THE FIRST NATIONAL $123 $4,175
BANK/BALLINGER.
831455 STUDENT LOAN FUNDING $67 .................
US BANK ELT.
815678 US BANK NA............ $63 .................
808524 CITY BANK & TRUST CO.. $20 .................
821347 OREGONIANS CU......... $11 .................
833193 S C STUDENT LOAN- $10 $814
TAXABLE.
833307 S C STUDENT LOAN $6 .................
TAXABLE-LLR.
833934 ZIONS BANK ELT NELNET $4 $0
TRUST.
805095 FIRST NATIONAL BANK OF $2 .................
JEANERETTE.
833495 ZIONS ELT EMT CORP.... $2 $0
808237 FIRST NATIONAL BANK & $0 $37,252
TRUST COMPANY.
807743 CITIBANK ELT STUDENT ($1) .................
LOAN CORP.
831056 WELLS FARGO ELT ($44) .................
PANHANDLE PLAINS SL.
829486 ESF/TRUSTMARK NATIONAL ($45) .................
BANK.
824821 UNIVERSITY OF DENVER.. ($59) .................
828949 CBW SCHOOLS FEDERAL ($355) $0
CREDIT UNION.
824573 ZIONS BANK ELT EFS ($368) .................
FINANCE CO.
828947 WYSE FEDERAL CREDIT ($713) .................
UNION.
825600 NEW JERSEY HIGHER ($2,894) $0
EDUCA ASST AUTH.
805149 BANK OF NY ELT TTEE ($4,173) $0
LELA.
822648 MICHIGAN RURAL ($6,465) $624,081
REHABILITATION CORPO.
822239 COMPASS BANK.......... ($12,755) $0
826651 UNIVERSITY OF MIAMI... ($56,392) .................
831821 WELLS FARGO ELT ($79,084) .................
PANHANDLE PLAINS.
829189 ALABAMA HIGHER ($518,861) $11,175,694
EDUCATION LOAN CORP.
827283 WYOMING STUDENT LOAN ($867,884) $71,440,289
CORPORATION.
833816 US BANK ELT OHIO ($1,282,246) .................
CENTRIC.
831300 MELMAC LLC ZIONS BANK ($2,788,259) $38,121,088
ELT.
832994 NEW HAMPSHIRE HIGHER ($11,534,867) .................
ED LOAN CORP.
--------------------------------------
Total............. $565,570,456 $13,588,263,365
------------------------------------------------------------------------
2002 9.5 SAP SUMMARY
------------------------------------------------------------------------
Tax Exempt Loans
--------------------------------------
Lender Special Allowance Ending Principal
Payments Balance
------------------------------------------------------------------------
833691 NELLIE MAE JPMORGAN $81,667,972 $1,199,720,541
CHASE ELT.
828924 AES/PHEAA............. $28,291,028 $1,189,679,093
831453 US BANK ELT EDAMERICA. $23,565,189 $765,567,958
831008 STUDENT LOAN FUNDING $19,912,337 $663,041,437
US BANK ELT.
825585 MICHIGAN HIGHER $14,112,086 $497,383,781
EDUCATION STUD LOAN.
833500 WELLS FARGO ELT NELNET $13,309,163 $376,465,236
ED LOAN FUND.
820164 UNION BK CA ELT CHELA $13,234,653 $543,758,155
FUND I (TEFFC).
827825 IOWA STUDENT LOAN $12,547,774 $373,788,651
LIQUIDITY CORP.
828863 MISSOURI HIGHER $12,040,378 $416,594,983
EDUCATION LOAN AUTH.
830075 VSAC EDUCATION LOAN $11,528,341 $393,420,365
FINANCE PROGRAM.
830630 SOUTHWEST STUDENT SERV $9,723,594 $321,041,286
TRUST WFB EL.
833088 BANK ONE NA TRUSTEE $9,247,952 $366,431,965
FOR NTHEA.
829769 UTAH STATE BOARD OF $6,955,446 $192,781,410
REGENTS.
831692 STUDENT LOAN FUNDING $6,935,880 $164,342,909
US BANK ELT.
826351 ILL DESIGNATED ACCOUNT $6,822,046 $183,033,936
PURCHASE PR.
832994 NEW HAMPSHIRE HIGHER $6,618,184 $209,999,546
ED LOAN CORP.
820163 UNION BANK CA ELT $6,411,766 $383,002,395
CHELA FUND II (TE).
827866 COLLEGEINVEST......... $6,293,324 $217,655,698
830631 STUDENT LOAN FUNDING $6,253,642 $141,191,180
US BANK ELT.
899980 INDIANA SECONDARY $6,200,874 $199,779,668
MARKET.
833016 SC STUDENT LOAN-93 RES $6,107,365 $182,447,646
(SL03).
833455 ZIONS FNB ELT NMEAF... $5,776,014 $160,797,721
823817 JPMORGAN CHASE ELT $4,738,633 $155,255,245
BRAZOS HEA.
826688 KENTUCKY HIGHER ED $4,374,446 $143,543,273
STUDENT LOAN COR.
832095 WELLS FARGO ELT $4,333,056 $157,025,862
PANHANDLE PLAINS.
833211 BANK OF NY ELT GTHEA.. $4,332,264 $158,999,495
826717 UTAH STATE BOARD OF $4,272,288 $147,798,283
REGENTS.
831299 STUDENT LOAN FUNDING $3,450,165 $76,792,814
US BANK ELT.
829691 ZIONS BANK ELT SLFA-WA $3,315,020 $39,390,913
INC.
808717 JPMORGAN CHASE NA ELT $2,921,723 $99,166,652
BRAZOS HEA IN.
813285 UNION BK CA ELT CHELA $2,894,412 $62,704,364
FUND I (TEFFC).
821628 UNION BANK CA ELT $2,870,920 $143,926,230
CHELA FUND I (TEF).
830344 WELLS FARGO ELT MHESAC $2,768,850 $95,909,968
821666 WELLS FARGO ELT FOR $2,742,329 $72,532,145
SLAAA.
832934 BANK OF NY ELT GTHEA $2,601,631 $84,339,893
(93AB).
831387 BANK OF MISSISSIPPI $2,509,386 $86,137,540
ELT MHEAC.
832339 BANK OF NY ELT GTHEA $2,359,482 $28,688,240
(92AB).
833741 WELLS FARGO ELT CTSLC $2,214,351 $72,080,828
LLC.
808780 FIFTH THIRD ELT SLFR $2,127,984 $80,246,304
MD 10907A.
828577 RHODE ISLAND STUDENT $2,048,687 $79,105,290
LOAN AUTHORITY.
821614 UNION BANK CA ELT $1,995,256 $35,743,670
CHELA FUND I (TEF).
812089 TEXAS HIGHER EDUCATION $1,955,774 $56,616,863
COORD BOARD.
827283 WYOMING STUDENT LOAN $1,923,118 $68,447,523
CORPORATION.
826764 INDUSTRIAL COMMISSION. $1,879,127 $84,503,279
831300 MELMAC LLC ZIONS BANK $1,877,687 $118,301,571
ELT.
833405 US BANK ELT ED LOANS $1,845,806 $47,947,511
INC.
822717 NEW MEXICO EDUC ASST $1,774,217 $39,853,643
FOUNDATION.
832919 BANK OF NY ELT ALL $1,768,789 $47,272,316
STUDENT LOAN COR.
828868 TRUSTMARK BANK ELT $1,482,907 $66,450,618
MHEAC.
832765 WELLS FARGO BANK ELT $1,407,549 $44,862,141
NMEAF.
825659 OKLAHOMA STUDENT LOAN $1,327,184 $35,151,913
AUTHORITY.
821623 UNION BANK CA ELT $1,311,898 $82,866,729
CHELA FUND I (TEF).
831640 STUDENT LOAN FUNDING $1,165,453 $26,946,686
US BANK ELT.
830628 IDAPP................. $1,098,471 $50,103,526
833017 S C STUDENT LLR....... $1,088,009 $37,743,174
826509 ARKANSAS STUDENT LOAN $1,052,635 $50,377,767
AUTHORITY.
833816 US BANK ELT OHIO $1,047,493 $25,234,323
CENTRIC.
833266 BANK ONE ELT STHEA.... $1,037,952 $47,707,530
829189 ALABAMA HIGHER $937,782 $17,687,180
EDUCATION LOAN CORP.
833347 BANK OF NY ELT $767,074 $33,578,370
PANHANDLE PLAINS HEA.
830427 JP MORGAN CHASE ELT $693,388 $5,804
TTEE LELA.
805178 BANK OF NY ELT TTEE $692,530 $48,737,387
LELA.
807037 COLLEGE FOUNDATION INC $641,218 $19,385,396
833806 US BANK ELT BHEA...... $641,176 $27,940,728
830248 UTAH STATE BOARD OF $552,491 $20,474,252
REGENTS/STNF.
831593 JPMORGAN CHASE ELT $495,021 $12,387,403
GTSLC (96AB).
830351 SC STUDENT LOAN CORP $488,147 $87,161,063
(SL05).
827116 SLF OF IDAHO MARKETING $359,109 $12,985,555
ASSN INC.
831245 SOUTHWEST STUDENT SRV $353,450 $14,560,598
TRUST WFB ELT.
831785 STUDENT LOAN FUNDING $340,856 $10,200,575
US BANK ELT.
832776 JPMORGAN CHASE ELT SMS $265,016 $12,932,655
CORP--HI.
805149 BANK OF NY ELT TTEE $215,634 $36,009
LELA.
833668 SC STUDENT LOAN CORP $186,227 $0
(LL05).
831119 MO HIGHER ED LOAN $110,230 $2,105,226
AUTHORITY.
829064 SOUTHWEST STUDENT SERV $104,709 $3,753,045
TRUST WFB EL.
833174 BANK OF NY ELT ALL $102,152 $3,835,306
STUDENT LOAN COR.
832260 WELLS FARGO ELT MHESAC $94,734 $8,379,925
819907 JP MORGAN CHASE ELT $87,619 $2,408,569
TTEE LELA.
805079 JP MORGAN CHASE ELT $77,102 $2,028,243
TTEE LELA.
826651 UNIVERSITY OF MIAMI... $56,392 $2,749,696
828875 COLLEGEINVEST......... $10,690 $130,472
826966 ALASKA (ACPE)......... $10,628 $2,500,988
804134 UNITED METHOD $8,380 $779,857
MINISTERS' CU.
827952 EXCHANGE STATE BANK... $5,874 $167,485
817380 TVA CU................ $2,545 $63,742
822648 MICHIGAN RURAL $2,506 $50,275
REHABILITATION CORPO.
828200 M H E S A C........... $2,379 $178,199
817717 BRIDGETON ONIZED FCU.. $1,021 $85,886
832057 JPMORGAN CHASE ELT $705 $42,512
GTSLC.
831455 STUDENT LOAN FUNDING $507 $10,500
US BANK ELT.
831651 FIRST NATIONAL BANK OF $503 $48,753
COWETA.
831419 CHASE TEXAS AS TRUSTEE $294 .................
FOR BHEA.
827291 PEOPLES BANK AND TRUST $277 $12,902
COMPANY.
829561 B & V CREDIT UNION.... $229 .................
830308 NELLIE MAE JPMORGAN $178 .................
CHASE ELT.
833295 TAIWANESE AMERICAN FCU $106 $8,124
806466 STATE BANK OF FAIRMONT $80 $14,200
828729 CENTRAL MICHIGAN $77 $12,679
COMMUNITY FED CR U.
829076 NELLIE MAE JPMORGAN $53 .................
CHASE ELT.
822991 MONROE TELCO FEDERAL $20 .................
CREDIT UNION.
831819 JP MORGAN CHASE ELT $6 .................
TTEE LELA.
832775 JP MORGANCHASE ELT USA $5 $0
GROUP SMS.
833702 ZIONS ELT NELNET II... $1 $0
808036 M & T BANK EDUCATIONAL ($0) .................
LENDING.
831484 UNION BANK & TRUST-- ($7) $0
IHELP.
824573 ZIONS BANK ELT EFS ($57) $0
FINANCE CO.
825600 NEW JERSEY HIGHER ($1,324) $0
EDUCA ASST AUTH.
822318 CABOT & NOI EMPLOYEES ($1,482) .................
CREDIT UNION.
833575 EDUCATION SERVICES ($1,913) .................
FOUNDATION.
833789 ZIONS ELT STUDENT LN ($38,903) .................
FIN ASSOC INC.
829988 NELLIE MAE JPMORGAN ($230,280) $150,078
CHASE ELT.
833207 STUDENT LOAN FUNDING ($253,731) .................
US BANK ELT.
829626 STUDENT LOAN FUNDING ($751,211) $0
US BANK ELT.
811077 ZIONS FIRST NATIONAL ($1,592,433) $0
BANK FOR CHELA.
--------------------------------------
Total................. $402,907,734 $12,239,289,319
------------------------------------------------------------------------
2001 9.5 SAP SUMMARY
------------------------------------------------------------------------
Tax Exempt Loans
--------------------------------------
Lender Special Allowance Ending Principal
Payments Balance
------------------------------------------------------------------------
833691 NELLIE MAE JPMORGAN $53,524,019 $2,387,488,335
CHASE ELT.
828924 AES/PHEAA............. $12,793,896 $883,732,849
831453 US BANK ELT EDAMERICA. $10,124,992 $604,533,520
820164 UNION BK CA ELT CHELA $9,827,596 $686,781,785
FUND I (TEFFC).
833500 WELLS FARGO ELT NELNET $6,535,159 $392,997,065
ED LOAN FUND.
825585 MICHIGAN HIGHER $6,347,999 $423,481,750
EDUCATION STUD LOAN.
828863 MISSOURI HIGHER $6,314,979 $430,156,562
EDUCATION LOAN AUTH.
830075 VSAC EDUCATION LOAN $6,121,467 $377,589,887
FINANCE PROGRAM.
827825 IOWA STUDENT LOAN $5,988,363 $378,466,805
LIQUIDITY CORP.
833088 BANK ONE NA TRUSTEE $5,796,546 $400,878,120
FOR NTHEA.
831008 STUDENT LOAN FUNDING $5,239,395 $510,058,708
US BANK ELT.
830630 SOUTHWEST STUDENT SERV $5,009,769 $309,829,380
TRUST WFB EL.
826351 ILL DESIGNATED ACCOUNT $4,174,803 $224,857,602
PURCHASE PR.
831300 MELMAC LLC ZIONS BANK $4,162,222 $402,406,577
ELT.
827866 COLLEGEINVEST......... $3,380,096 $219,952,005
829769 UTAH STATE BOARD OF $3,112,834 $203,785,301
REGENTS.
899980 INDIANA SECONDARY $2,856,104 $189,416,162
MARKET.
823817 JPMORGAN CHASE ELT $2,700,075 $179,705,241
BRAZOS HEA.
833016 SC STUDENT LOAN-93 RES $2,685,642 $249,079,937
(SL03).
833455 ZIONS FNB ELT NMEAF... $2,524,096 $149,800,537
832095 WELLS FARGO ELT $2,396,021 $171,596,119
PANHANDLE PLAINS.
830631 STUDENT LOAN FUNDING $2,374,818 $149,824,308
US BANK ELT.
832994 NEW HAMPSHIRE HIGHER $2,317,468 $140,033,914
ED LOAN CORP.
831692 STUDENT LOAN FUNDING $2,235,889 $149,938,212
US BANK ELT.
826717 UTAH STATE BOARD OF $2,155,198 $131,670,508
REGENTS.
826688 KENTUCKY HIGHER ED $2,154,988 $162,440,981
STUDENT LOAN COR.
833211 BANK OF NY ELT GTHEA.. $2,101,807 $151,622,974
829691 ZIONS BANK ELT SLFA-WA $2,063,603 $149,325,958
INC.
821614 UNION BANK CA ELT $1,920,994 $99,911,567
CHELA FUND I (TEF).
813285 UNION BK CA ELT CHELA $1,629,630 $84,447,675
FUND I (TEFFC).
832339 BANK OF NY ELT GTHEA $1,533,708 $99,814,098
(92AB).
831387 BANK OF MISSISSIPPI $1,469,076 $106,978,561
ELT MHEAC.
831299 STUDENT LOAN FUNDING $1,356,174 $100,243,926
US BANK ELT.
808717 JPMORGAN CHASE NA ELT $1,337,580 $93,774,412
BRAZOS HEA IN.
812089 TEXAS HIGHER EDUCATION $1,280,057 $88,429,490
COORD BOARD.
821666 WELLS FARGO ELT FOR $1,274,373 $72,551,318
SLAAA.
822717 NEW MEXICO EDUC ASST $1,183,798 $85,316,233
FOUNDATION.
828577 RHODE ISLAND STUDENT $1,179,089 $80,993,495
LOAN AUTHORITY.
830344 WELLS FARGO ELT MHESAC $1,121,260 $95,672,803
833405 US BANK ELT ED LOANS $1,103,936 $49,774,209
INC.
827283 WYOMING STUDENT LOAN $1,103,641 $70,386,993
CORPORATION.
832765 WELLS FARGO BANK ELT $882,179 $58,623,647
NMEAF.
826764 INDUSTRIAL COMMISSION. $870,802 $58,332,770
829626 STUDENT LOAN FUNDING $813,579 $74,422,509
US BANK ELT.
833741 WELLS FARGO ELT CTSLC $764,872 $65,820,003
LLC.
828868 TRUSTMARK BANK ELT $743,141 $56,652,891
MHEAC.
811077 ZIONS FIRST NATIONAL $713,868 $41,371,174
BANK FOR CHELA.
830628 IDAPP................. $697,461 $58,588,588
832934 BANK OF NY ELT GTHEA $690,222 $43,100,831
(93AB).
832919 BANK OF NY ELT ALL $684,043 $38,039,909
STUDENT LOAN COR.
829189 ALABAMA HIGHER $659,622 $43,115,591
EDUCATION LOAN CORP.
825659 OKLAHOMA STUDENT LOAN $609,020 $36,549,218
AUTHORITY.
833266 BANK ONE ELT STHEA.... $569,571 $47,154,675
826509 ARKANSAS STUDENT LOAN $550,228 $56,040,820
AUTHORITY.
831593 JPMORGAN CHASE ELT $525,176 $37,823,885
GTSLC (96AB).
833017 S C STUDENT LLR....... $518,309 $31,168,754
831640 STUDENT LOAN FUNDING $452,623 $26,241,986
US BANK ELT.
830427 JP MORGAN CHASE ELT $440,670 $33,132,107
TTEE LELA.
830248 UTAH STATE BOARD OF $433,816 $36,148,666
REGENTS/STNF.
805178 BANK OF NY ELT TTEE $400,247 $22,781,127
LELA.
833816 US BANK ELT OHIO $360,811 $34,042,490
CENTRIC.
807037 COLLEGE FOUNDATION INC $349,386 $23,722,293
833806 US BANK ELT BHEA...... $293,546 $22,819,434
833207 STUDENT LOAN FUNDING $255,185 .................
US BANK ELT.
827116 SLF OF IDAHO MARKETING $246,450 $20,700,161
ASSN INC.
829988 NELLIE MAE JPMORGAN $245,335 $192,118
CHASE ELT.
805149 BANK OF NY ELT TTEE $238,293 $9,975,239
LELA.
832776 JPMORGAN CHASE ELT SMS $237,370 $19,902,582
CORP--HI.
833403 EDUCATION FUNDING $158,623 $0
ASSOCIATION, INC.
833174 BANK OF NY ELT ALL $134,621 $5,068,945
STUDENT LOAN COR.
833347 BANK OF NY ELT $130,289 $9,901,728
PANHANDLE PLAINS HEA.
833668 SC STUDENT LOAN CORP $122,875 $13,033,208
(LL05).
832260 WELLS FARGO ELT MHESAC $107,605 $12,240,521
831119 MO HIGHER ED LOAN $101,081 $6,345,508
AUTHORITY.
831785 STUDENT LOAN FUNDING $87,112 $9,736,091
US BANK ELT.
829064 SOUTHWEST STUDENT SERV $70,190 $5,767,364
TRUST WFB EL.
831419 CHASE TEXAS AS TRUSTEE $66,990 $1,475,736
FOR BHEA.
819907 JP MORGAN CHASE ELT $45,997 $2,895,366
TTEE LELA.
833789 ZIONS ELT STUDENT LN $41,040 $3,493,355
FIN ASSOC INC.
805079 JP MORGAN CHASE ELT $38,090 $2,422,919
TTEE LELA.
832640 CHASE TEXAS AS TRUSTEE $25,065 $0
FOR BHEA.
822239 COMPASS BANK.......... $12,754 .................
821623 UNION BANK CA ELT $2,774 $7,513
CHELA FUND I (TEF).
833575 EDUCATION SERVICES $1,913 $158,685
FOUNDATION.
828200 M H E S A C........... $1,680 $239,257
822648 MICHIGAN RURAL $1,358 $56,982
REHABILITATION CORPO.
817380 TVA CU................ $1,311 $77,335
829561 B & V CREDIT UNION.... $685 $45,031
833078 US BANK ELT BSFC...... $545 $0
822318 CABOT & NOI EMPLOYEES $520 $21,120
CREDIT UNION.
831455 STUDENT LOAN FUNDING $388 $34,725
US BANK ELT.
832057 JPMORGAN CHASE ELT $330 $72,680
GTSLC.
829076 NELLIE MAE JPMORGAN $217 $2,625
CHASE ELT.
832347 BANK OF NY ELT GREATER $211 .................
TX FOUND.
822991 MONROE TELCO FEDERAL $39 $2,625
CREDIT UNION.
831819 JP MORGAN CHASE ELT $24 $2,662
TTEE LELA.
827800 CHASE TEXAS AS TRUSTEE $16 .................
FOR BHEA.
833093 BANK OF NY ELT ($0) $0
COLLEGEINVEST.
831245 SOUTHWEST STUDENT SRV ($17) $0
TRUST WFB ELT.
830308 NELLIE MAE JPMORGAN ($37) $3,401
CHASE ELT.
810742 CITIZENS STATE BANK... ($71) .................
829077 SOUTHWEST STUDENT SERV ($325) .................
TRUST WFB EL.
825600 NEW JERSEY HIGHER ($645) $0
EDUCA ASST AUTH.
--------------------------------------
Total............. $209,912,235 $13,009,314,732
------------------------------------------------------------------------
FY 2006 SAP SUMMARY FOR BOTH TAXABLE AND TAX EXEMPT BY LENDER
[As of February 2007]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Tax Exempt Loans Taxable Loans Total Tax Exempt and Taxable
----------------------------------------------------------------------------------------------------------------------
Lender Special Allowance Ending Principal Special Allowance Ending Principal Special Allowance Ending Principal
Payments Balance (9/30/06) Payments Balance (9/30/06) Payments Balance (9/30/06)
--------------------------------------------------------------------------------------------------------------------------------------------------------
833253 JPMORGAN CHASE ELT $0 $1,802,329,592 $74,940,356,897 $1,802,329,592 $74,940,356,897
SLMA TRUST MS181.
826878 CITIBANK NA ELT $0 $315,682,238 $11,680,757,944 $315,682,238 $11,680,757,944
STUDENT LOAN CORP.
833934 ZIONS BANK ELT ($151) $311,440,494 $11,034,155,191 $311,440,343 $11,034,155,191
NELNET TRUST.
833500 WELLS FARGO ELT $158,373,973 $2,728,074,557 $53,056,233 $1,704,324,001 $211,430,206 $4,432,398,558
NELNET ED LOAN FUND.
807929 CITIBANK ELT SLC $0 $203,924,816 $7,773,270,449 $203,924,816 $7,773,270,449
RECEIVABLES I.
828924 AES/PHEAA........... $59,627,998 $1,196,188,921 $141,365,788 $6,034,052,934 $200,993,786 $7,230,241,855
807176 WELLS FARGO $0 $200,422,957 $8,375,680,811 $200,422,957 $8,375,680,811
EDUCATION FIN SVCS.
833806 US BANK ELT BHEA.... $10,511,074 $254,471,434 $174,175,727 $6,432,933,188 $184,686,801 $6,687,404,622
833835 BANK OF NY ELT $0 $154,423,843 $4,463,175,468 $154,423,843 $4,463,175,468
COLLEGIATE FUNDING
S.
834072 SLM EDUCATION LOAN $0 $125,864,525 $1,171,619,774 $125,864,525 $1,171,619,774
CORP.
833733 JP MORGAN CHASE ELT $0 $121,803,417 $4,181,311,700 $121,803,417 $4,181,311,700
COLLEGE LOAN CO.
833923 DEUTSCHE BANK ELT $0 $120,227,634 $3,910,655,210 $120,227,634 $3,910,655,210
CLC.
833529 US BANK ELT $0 $118,004,365 $2,843,266,812 $118,004,365 $2,843,266,812
NORTHSTAR.
830005 WACHOVIA EDUCATION $0 $113,624,333 $4,551,023,831 $113,624,333 $4,551,023,831
FINANCE INC.
808851 DEUTSCHE BANK ELT $0 $110,906,428 $3,148,735,025 $110,906,428 $3,148,735,025
ACCESS GROUP.
830630 SOUTHWEST STUDENT $17,235,161 $307,516,895 $89,150,081 $1,833,104,447 $106,385,242 $2,140,621,342
SERV TRUST WFB EL.
834071 SLM EDUCATION $0 $84,223,286 $5,953,227,258 $84,223,286 $5,953,227,258
FINANCE CREDIT CORP.
834042 FIFTH THIRD ELT ED $0 $80,884,293 $2,248,300,950 $80,884,293 $2,248,300,950
FUND CAP TRUST.
834023 MISSOURI HIGHER $1,529,182 $72,746,901 $73,983,094 $2,248,440,652 $75,512,276 $2,321,187,553
EDUCATION LOAN AUTH.
833948 BANK OF NY ELT $30,940,457 $564,620,484 $44,019,921 $1,989,870,640 $74,960,378 $2,554,491,124
EDSOUTH.
833955 ZIONS FNB ELT GCO ED $0 $68,007,757 $2,385,571,562 $68,007,757 $2,385,571,562
LOAN FUND TRUS.
834117 BANK OF NY ELT GOAL $0 $65,510,966 $2,843,243,476 $65,510,966 $2,843,243,476
FINANCIAL LLC.
834223 JPMORGAN CHASE BANK $0 $59,630,959 $3,110,590,712 $59,630,959 $3,110,590,712
ELT WACHOVIA LL.
833860 FIFTH THIRD ELT $0 $57,516,028 $1,828,856,055 $57,516,028 $1,828,856,055
STUDENT LOAN XPRESS.
827825 IOWA STUDENT LOAN $21,291,088 $412,178,900 $31,938,669 $1,196,943,101 $53,229,757 $1,609,122,001
LIQUIDITY CORP.
826688 KENTUCKY HIGHER ED $40,106,950 $699,065,806 $11,571,384 $624,357,973 $51,678,334 $1,323,423,779
STUDENT LOAN COR.
833405 US BANK ELT ED LOANS $7,450,821 $133,316,799 $39,479,346 $1,891,047,059 $46,930,167 $2,024,363,858
INC.
807037 COLLEGE FOUNDATION $193,126 $5,484,040 $45,629,583 $1,854,427,408 $45,822,708 $1,859,911,448
INC.
833922 BONY ELT GOAL $0 $45,576,486 $1,399,247,664 $45,576,486 $1,399,247,664
FINANCIAL LLC.
830075 VSAC EDUCATION LOAN $28,034,326 $530,904,225 $17,352,344 $636,445,046 $45,386,669 $1,167,349,271
FINANCE PROGRAM.
824756 CITIBANK (NEW YORK $0 $38,705,014 $1,018,358,417 $38,705,014 $1,018,358,417
STATE) SLC.
834059 BONY ELT COLLEGIATE $0 $38,620,917 $1,296,946,139 $38,620,917 $1,296,946,139
FUND SVCS RI/CF.
825585 MICHIGAN HIGHER $17,561,882 $412,663,043 $17,217,962 $1,123,591,445 $34,779,844 $1,536,254,488
EDUCATION STUD LOAN.
828863 MISSOURI HIGHER $8,878,031 $153,817,735 $25,076,192 $1,860,485,566 $33,954,223 $2,014,303,301
EDUCATION LOAN AUTH.
813830 WACHOVIA EDUCATION $0 $33,565,354 $872,043,214 $33,565,354 $872,043,214
FINANCE INC.
830628 IDAPP............... $745,832 $28,202,834 $32,560,798 $1,582,646,623 $33,306,630 $1,610,849,457
826351 ILL DESIGNATED $2,611,876 $52,661,912 $29,601,493 $995,981,796 $32,213,370 $1,048,643,708
ACCOUNT PURCHASE PR.
834097 WELLS FARGO ELT $11,976,579 $251,471,061 $18,902,055 $828,644,527 $30,878,634 $1,080,115,588
NTHEA INC.
828868 TRUSTMARK BANK ELT $5,808,316 $103,988,173 $24,225,751 $805,120,733 $30,034,067 $909,108,906
MHEAC.
833872 BANK OF NY ELT GOAL $0 $29,978,848 $1,076,047,420 $29,978,848 $1,076,047,420
FINANCIAL LLC.
833078 US BANK ELT BSFC.... $0 $29,569,743 $1,029,806,602 $29,569,743 $1,029,806,602
833220 JPMORGAN CHASE ELT $0 $29,385,932 $1,603,409,143 $29,385,932 $1,603,409,143
KEYCORP.
828476 UTAH STATE BOARD OF $9,613,279 $163,242,746 $18,589,477 $655,079,675 $28,202,756 $818,322,421
REGENTS.
832095 WELLS FARGO ELT $18,360,030 $348,849,840 $8,446,118 $455,385,330 $26,806,148 $804,235,170
PANHANDLE PLAINS.
899980 INDIANA SECONDARY $6,653,206 $140,764,497 $19,868,346 $732,662,069 $26,521,551 $873,426,566
MARKET.
800061 SUNTRUST BANK....... $0 $26,083,968 $165,814,278 $26,083,968 $165,814,278
833193 S C STUDENT LOAN- $0 $26,010,755 $1,194,647,372 $26,010,755 $1,194,647,372
TAXABLE.
834092 M&T BANK ELT PHEAA ($21) $0 $25,626,796 $802,776,693 $25,626,775 $802,776,693
LOAN TRUST I.
834226 BANK OF NY ELT GOAL $0 $25,204,317 $837,741,813 $25,204,317 $837,741,813
CAP FUND TRUST.
827866 COLLEGEINVEST....... $11,738,633 $253,422,510 $13,239,892 $743,823,698 $24,978,525 $997,246,208
831008 STUDENT LOAN FUNDING $3,604,935 $72,552,371 $19,822,008 $703,116,150 $23,426,943 $775,668,521
US BANK ELT.
829691 ZIONS BANK ELT SLFA- $2,087,202 $38,565,684 $20,973,552 $704,782,171 $23,060,754 $743,347,855
WA INC.
832994 NEW HAMPSHIRE HIGHER $0 $22,482,534 $886,569,918 $22,482,534 $886,569,918
ED LOAN CORP.
811304 SUNTRUST BANK....... $0 $22,239,514 $309,498,641 $22,239,514 $309,498,641
802218 WILMINGTON TRUST ELT $0 $21,059,715 $1,778,156,962 $21,059,715 $1,778,156,962
SLMA ED.
811078 ZIONS BANK ELT SLM $0 $20,755,606 $422,507,350 $20,755,606 $422,507,350
RESOURCES LLC.
809921 PNC EDUCATION LOAN $0 $20,486,663 $783,584,233 $20,486,663 $783,584,233
CTR.
834202 BANK OF NY ELT CIT $0 $20,187,612 $829,269,302 $20,187,612 $829,269,302
ED LOAN TRUST.
830344 WELLS FARGO ELT $3,251,656 $66,350,212 $16,873,999 $633,139,162 $20,125,656 $699,489,374
MHESAC.
825659 OKLAHOMA STUDENT $1,253,033 $29,069,493 $17,917,474 $781,134,433 $19,170,507 $810,203,926
LOAN AUTHORITY.
822717 NEW MEXICO EDUC ASST $13,855,233 $259,928,343 $4,815,728 $245,062,012 $18,670,962 $504,990,355
FOUNDATION.
832775 JP MORGANCHASE ELT $0 $17,973,952 $1,175,213,494 $17,973,952 $1,175,213,494
USA GROUP SMS.
832919 BANK OF NY ELT ALL $3,036,588 $53,246,222 $14,892,044 $535,045,597 $17,928,633 $588,291,819
STUDENT LOAN COR.
829076 NELLIE MAE JPMORGAN $0 $16,385,510 $1,083,851,451 $16,385,510 $1,083,851,451
CHASE ELT.
824421 BOA STUDENT BANKING/ $0 $16,169,392 $841,912,619 $16,169,392 $841,912,619
CA9-169-04-01.
800097 REGIONS BANK........ $0 $16,076,023 $793,864,927 $16,076,023 $793,864,927
834170 BANK OF NY ELT $175,307 $3,383,077 $15,586,708 $685,230,403 $15,762,014 $688,613,480
EDSOUTH.
833960 DEUTSCHE BANK ELT $0 $15,525,146 $394,691,369 $15,525,146 $394,691,369
ACCESS GROUP INC.
899989 SLM ECFC............ $0 $15,220,474 $1,004,571,050 $15,220,474 $1,004,571,050
820177 JP MORGAN CHASE BANK $0 $14,864,455 $554,265,414 $14,864,455 $554,265,414
NA.
834159 ZIONS FNB ELT GCO ED $0 $14,475,354 $122,650,717 $14,475,354 $122,650,717
LN FUND & AFF.
833211 BANK OF NY ELT GTHEA $7,707,205 $178,406,284 $6,661,187 $393,933,234 $14,368,392 $572,339,518
832260 WELLS FARGO ELT $0 $14,205,021 $502,213,947 $14,205,021 $502,213,947
MHESAC.
834278 BANK OF NY ELT ED $0 $14,000,127 $842,491,931 $14,000,127 $842,491,931
LOAN TRUST IV LLC.
834076 DEUTSCHE BANK ELT $0 $12,386,519 $790,373,139 $12,386,519 $790,373,139
ACADEMIC LOAN GRO.
824690 JPMORGAN CHASE ELT $0 $12,068,798 $1,361,648,985 $12,068,798 $1,361,648,985
SMS.
826717 UTAH STATE BOARD OF $4,706,039 $103,914,544 $7,320,399 $390,715,417 $12,026,437 $494,629,961
REGENTS.
834250 DEUTSCHE BANK ELT $0 $12,001,382 $546,631,041 $12,001,382 $546,631,041
SUNTRUST.
831067 CITIBANK (NEW YORK $0 $11,971,695 $398,288,582 $11,971,695 $398,288,582
STATE) SLC.
831245 SOUTHWEST STUDENT $7,400,183 $141,012,628 $4,339,276 $245,487,022 $11,739,458 $386,499,650
SRV TRUST WFB ELT.
834119 BANK OF NY ELT GOAL $0 $11,361,449 $3,243,823 $11,361,449 $3,243,823
FINANCIAL LLC.
833670 WELLS FARGO BANK ELT $0 $11,080,984 $470,859,927 $11,080,984 $470,859,927
NHELP III.
834145 BANK OF NY ELT US $0 $10,959,501 $270,232,708 $10,959,501 $270,232,708
EDUCATION LOAN TR.
829739 WACHOVIA EDUCATION $0 $10,583,735 $524,546,198 $10,583,735 $524,546,198
FINANCE INC.
811303 SUNTRUST BANK....... $0 $10,484,724 $177,526,126 $10,484,724 $177,526,126
810691 SUNTRUST BANK NA.... $0 $10,430,396 $436,175,451 $10,430,396 $436,175,451
834086 WELLS FARGO ELT $3,096,241 $53,575,742 $7,120,401 $488,775,847 $10,216,642 $542,351,589
BRAZOS HEA.
833617 US BANK ELT EFSI.... ($14) $10,180,699 $352,142,260 $10,180,685 $352,142,260
816386 BANK OF NORTH DAKOTA $0 $10,103,644 $376,079,579 $10,103,644 $376,079,579
805149 BANK OF NY ELT TTEE $5,087,971 $72,942,850 $4,856,997 $255,393,418 $9,944,968 $328,336,268
LELA.
806746 BANK OF AMERICA N A. $0 $9,873,261 $435,605,399 $9,873,261 $435,605,399
829769 UTAH STATE BOARD OF $7,039,426 $131,567,279 $2,660,773 $124,595,069 $9,700,199 $256,162,348
REGENTS.
833264 WELLS FARGO ELT $3,608,890 $83,814,523 $6,038,460 $322,017,126 $9,647,350 $405,831,649
STHEA INC.
828577 RHODE ISLAND STUDENT $4,217,950 $97,681,990 $5,401,630 $239,294,653 $9,619,580 $336,976,643
LOAN AUTHORITY.
828614 CSLF/SUSIE MAE...... $0 $9,508,801 $419,755,866 $9,508,801 $419,755,866
830351 SC STUDENT LOAN CORP $1,604,563 $33,220,877 $7,493,857 $234,577,224 $9,098,419 $267,798,101
(SL05).
819873 SUNTRUST BANK....... $0 $8,788,364 $526,278,762 $8,788,364 $526,278,762
833838 US BANK ELT EDINVEST $0 $8,243,928 $240,724,570 $8,243,928 $240,724,570
CO.
833016 SC STUDENT LOAN-93 $6,545,140 $47,205,330 $1,377,356 $586,640 $7,922,496 $47,791,970
RES (SL03).
830492 ASSOCIATED BANK NA.. $0 $7,862,009 $346,870,502 $7,862,009 $346,870,502
822904 CITIBANK ELT STUDENT $0 $7,843,123 $554,769,727 $7,843,123 $554,769,727
LOAN CORP.
811925 JPMORGAN CHASE BANK $0 $7,613,852 $89,508,303 $7,613,852 $89,508,303
NA.
821654 US BANK NA.......... $0 $7,577,909 $131,357,144 $7,577,909 $131,357,144
833659 US BANK ELT THEA INC $0 $7,561,049 $201,875,314 $7,561,049 $201,875,314
807807 JP MORGAN CHASE BANK $0 $7,384,789 $44,764,395 $7,384,789 $44,764,395
899995 SLM ECFC............ $0 $7,127,303 $320,848,659 $7,127,303 $320,848,659
833770 US BANK ELT USEFC... $0 $6,938,059 $234,529,690 $6,938,059 $234,529,690
832733 BANK OF AMERICA NA.. $0 $6,833,225 $336,637,005 $6,833,225 $336,637,005
827283 WYOMING STUDENT LOAN $2,542,007 $61,487,189 $4,223,420 $226,727,729 $6,765,427 $288,214,918
CORPORATION.
818334 BANK OF AMERICA N A. $0 $6,683,652 $285,051,406 $6,683,652 $285,051,406
832934 BANK OF NY ELT GTHEA $5,892,372 $121,595,074 $777,078 $39,647,285 $6,669,450 $161,242,359
(93AB).
833880 CITIZENS BANK C/O $0 $6,527,206 $252,951,986 $6,527,206 $252,951,986
EDUCATION FINANCE.
827273 PNC EDUCATION LOAN $0 $6,436,913 $452,051 $6,436,913 $452,051
CTR C/O G REITER.
830631 STUDENT LOAN FUNDING $6,089,827 $114,871,881 $261,454 $22,160,434 $6,351,281 $137,032,315
US BANK ELT.
834081 BANK OF NY ELT US $0 $6,335,464 $195,316,428 $6,335,464 $195,316,428
EDUCATION LOAN TR.
813760 KEY BANK NA......... $0 $6,323,068 $103,907,975 $6,323,068 $103,907,975
833457 ZIONS FNB ELT NELNET $0 $5,945,741 $589,066,763 $5,945,741 $589,066,763
I.
831846 BANK OF AMERICA N A. $0 $5,776,305 $217,143,227 $5,776,305 $217,143,227
807743 CITIBANK ELT STUDENT $0 $5,720,879 $1,427,187 $5,720,879 $1,427,187
LOAN CORP.
808047 HSBC BANK USA NA.... $0 $5,720,657 $298,675,840 $5,720,657 $298,675,840
831821 WELLS FARGO ELT $0 $5,603,161 $173,403,679 $5,603,161 $173,403,679
PANHANDLE PLAINS.
815502 NAVY FEDERAL CREDIT $0 $5,502,235 $239,737,649 $5,502,235 $239,737,649
UNION.
833067 AMS EDUCATION LOAN $0 $5,401,041 $405,536,647 $5,401,041 $405,536,647
TRUST.
834064 WELLS FARGO ELT $0 $5,357,733 $134,336 $5,357,733 $134,336
STUD. ASST. MT.
833285 US BANK ELT PSFC.... ($43) $5,289,227 $58,005,609 $5,289,184 $58,005,609
826764 INDUSTRIAL $4,737,974 $60,863,311 $485,663 $34,717,169 $5,223,638 $95,580,480
COMMISSION.
801871 BOA STDNT BKNG CA9- $0 $5,204,274 $124,383,392 $5,204,274 $124,383,392
169-04-01.
830308 NELLIE MAE JPMORGAN $0 $5,165,708 $218,183,144 $5,165,708 $218,183,144
CHASE ELT.
833890 FIFTH THIRD ELT $0 $5,039,685 $308,601,940 $5,039,685 $308,601,940
STUDENT LOAN XPRESS.
808780 FIFTH THIRD ELT SLFR $709,541 $11,900,531 $4,159,863 $221,009,292 $4,869,403 $232,909,823
MD 10907A.
833307 S C STUDENT LOAN $0 $4,729,031 $318,724,549 $4,729,031 $318,724,549
TAXABLE-LLR.
831453 US BANK ELT ($769) $4,597,629 $209,391,740 $4,596,861 $209,391,740
EDAMERICA.
831455 STUDENT LOAN FUNDING $0 $4,578,795 $315,259,912 $4,578,795 $315,259,912
US BANK ELT.
831300 MELMAC LLC ZIONS $325,853 $18,014,051 $4,239,761 $225,659,716 $4,565,614 $243,673,767
BANK ELT.
833079 AMS EDUCATION LOAN $0 $4,559,506 $272,276,821 $4,559,506 $272,276,821
TRUST.
813979 COMMERCE BANK N A... $0 $4,552,243 $170,634,968 $4,552,243 $170,634,968
810509 WELLS FARGO $0 $4,355,406 $165,660,440 $4,355,406 $165,660,440
EDUCATIONAL FIN
SVCS.
831495 BANK OF AMERICA..... $0 $3,897,795 $220,149,785 $3,897,795 $220,149,785
821666 WELLS FARGO ELT FOR $2,567,218 $45,034,222 $1,042,270 $77,606,303 $3,609,488 $122,640,525
SLAAA.
833347 BANK OF NY ELT $1,321,448 $26,243,226 $2,090,023 $105,610,457 $3,411,471 $131,853,683
PANHANDLE PLAINS
HEA.
830310 BNY ELT COLLEGE $0 $3,337,847 $1,845,448 $3,337,847 $1,845,448
BOARD.
829626 STUDENT LOAN FUNDING $0 $3,284,350 $228,192,651 $3,284,350 $228,192,651
US BANK ELT.
833228 US BANK ELT BEA INC. $0 $3,228,731 $5,306,245 $3,228,731 $5,306,245
833207 STUDENT LOAN FUNDING $0 $3,154,060 $196,950,834 $3,154,060 $196,950,834
US BANK ELT.
807745 CITIZENS BANK NA.... $0 $3,118,154 $128,759,891 $3,118,154 $128,759,891
824515 UNIVERSITY OF $0 $3,098,468 $243,243 $3,098,468 $243,243
PENNSYLVANIA.
829030 CAPITAL ONE NA...... $0 $3,021,454 $176,911,479 $3,021,454 $176,911,479
833495 ZIONS ELT EMT CORP.. ($109) $3,015,239 $89,980,020 $3,015,130 $89,980,020
818611 UNIVERSITY OF $0 $2,905,647 $92,497,824 $2,905,647 $92,497,824
WISCONSIN CU.
833471 AMS EDUCATION LOAN $0 $2,883,360 $97,914,831 $2,883,360 $97,914,831
TRUST JPMORGAN E.
834124 DEUTSCHE BANK ELT $0 $2,867,731 $118,801,666 $2,867,731 $118,801,666
K2FINANCIAL LLC.
832547 WACHOVIA EDUCATION $0 $2,845,505 $271,569,898 $2,845,505 $271,569,898
FINANCE INC.
834218 ARIZONA HIGHER ED $0 $2,783,783 $72,745,288 $2,783,783 $72,745,288
LOAN AUTHORITY.
834308 DEUTSCHE BANK ELT $0 $2,766,238 $168,749,813 $2,766,238 $168,749,813
NEXTSTUDENT ELF/M.
814548 US BANK NA.......... $0 $2,753,069 $117,403,693 $2,753,069 $117,403,693
834051 DEUTSCHE BANK ELT $0 $2,730,608 $417,175 $2,730,608 $417,175
NEXTSTUDENT/NS IN.
830694 US BANK NA.......... $0 $2,698,011 $156,208,209 $2,698,011 $156,208,209
833074 JPMORGAN CHASE ELT $0 $2,692,677 $169,891,428 $2,692,677 $169,891,428
WELLS FARGO TRUS.
825600 NEW JERSEY HIGHER ($1,507) $0 $2,679,446 $123,716,298 $2,677,939 $123,716,298
EDUCA ASST AUTH.
834127 US BANK ELT $0 $2,672,481 $122,924,298 $2,672,481 $122,924,298
EDUCATIONAL FUNDING
SVC.
808959 KEY BANK NA......... $0 $2,664,862 $14,840,181 $2,664,862 $14,840,181
820192 UNION BANK CA ELT $0 $2,611,956 $52,853 $2,611,956 $52,853
CHELA FUND I (TEF).
833921 MASSACHUSETTS ED $0 $2,538,132 $116,385,653 $2,538,132 $116,385,653
FINANCING.
826966 ALASKA (ACPE)....... $2,460,035 $50,258,274 $9,697 $1,554,330 $2,469,731 $51,812,604
824135 SUNTRUST BANK....... $0 $2,439,223 $14,461,226 $2,439,223 $14,461,226
832347 BANK OF NY ELT $0 $2,383,656 $183,551,524 $2,383,656 $183,551,524
GREATER TX FOUND.
833017 S C STUDENT LLR..... $1,881,549 $17,466,740 $497,673 $263,528 $2,379,222 $17,730,268
833741 WELLS FARGO ELT $1,375,356 $29,801,033 $1,002,634 $75,770,804 $2,377,990 $105,571,837
CTSLC LLC.
829640 SLM ECFC............ $0 $2,373,440 $157,668,238 $2,373,440 $157,668,238
888885 SLM ECFC............ $0 $2,351,575 $180,245,373 $2,351,575 $180,245,373
826509 ARKANSAS STUDENT ($5,968,655) $74,272,483 $8,284,678 $299,373,748 $2,316,023 $373,646,231
LOAN AUTHORITY.
833032 NOVA SOUTHEASTERN $0 $2,221,131 $16,614,420 $2,221,131 $16,614,420
UNIVERSITY.
828154 CITIBANK NA......... $0 $2,195,298 $216,035,775 $2,195,298 $216,035,775
803688 FIFTH THIRD BANK OF $0 $2,167,514 $123,720,822 $2,167,514 $123,720,822
CENTRAL INDIANA.
830868 UNION BANK & TRUST $0 $2,158,514 $18,176,484 $2,158,514 $18,176,484
COMPANY ASAP.
809081 STILLWATER NATIONAL $0 $2,121,695 $74,082,909 $2,121,695 $74,082,909
BANK & TRUST CO.
827269 US BANK NA.......... $0 $2,118,347 $108,401,453 $2,118,347 $108,401,453
833702 ZIONS ELT NELNET II. $0 $2,096,280 $357,205,490 $2,096,280 $357,205,490
820164 UNION BK CA ELT $1,392,916 $3,168 $582,322 $331,193 $1,975,238 $334,361
CHELA FUND I
(TEFFC).
816086 US BANK NA.......... $0 $1,962,883 $111,563,725 $1,962,883 $111,563,725
834131 BANK OF NY ELT $0 $1,957,501 $189,988 $1,957,501 $189,988
GOLDMAN SACHS.
830731 NOTRE DAME CREDIT $0 $1,950,330 $71,465,903 $1,950,330 $71,465,903
UNION.
833881 CITIZENS BANK C/O $0 $1,918,082 $88,997,882 $1,918,082 $88,997,882
EDUCATION FINANCE.
810513 WELLS FARGO $0 $1,910,139 $6,038,015 $1,910,139 $6,038,015
EDUCATIONAL FIN
SVCS.
833691 NELLIE MAE JPMORGAN $1,538,672 $26,697,813 $359,871 $32,469,911 $1,898,543 $59,167,724
CHASE ELT.
808877 NATIONAL CITY BANK $0 $1,877,327 $12,703,518 $1,877,327 $12,703,518
OF OHIO.
810388 US BANK NA.......... $0 $1,866,176 $84,463,646 $1,866,176 $84,463,646
809582 PNC EDUCATION LOAN $0 $1,856,504 $2,860,121 $1,856,504 $2,860,121
CTR.
830604 HSBC BANK USA....... $0 $1,828,112 $43,115,212 $1,828,112 $43,115,212
813298 WELLS FARGO $0 $1,812,613 $102,513,578 $1,812,613 $102,513,578
EDUCATION FIN SVCS.
808037 JP MORGANCHASE BANK. $0 $1,805,888 $2,844,847 $1,805,888 $2,844,847
820682 SAN ANTONIO FCU..... $0 $1,801,427 $129,612,699 $1,801,427 $129,612,699
814321 JPMORGAN CHASE BANK $0 $1,793,414 $9,200,269 $1,793,414 $9,200,269
NA.
832339 BANK OF NY ELT GTHEA $1,785,080 $36,960,240 $1,990 $780,758 $1,787,070 $37,740,998
(92AB).
817729 CITIZENS BANK C/O $0 $1,763,691 $70,465,282 $1,763,691 $70,465,282
EDUCATION FINANCE.
831692 STUDENT LOAN FUNDING $1,391,900 $7,961,956 $352,334 $31,423,824 $1,744,234 $39,385,780
US BANK ELT.
813894 WELLS FARGO $0 $1,725,450 $81,363,754 $1,725,450 $81,363,754
EDUCATION FIN SVCS.
822583 DOLLAR BANK......... $0 $1,691,616 $12,643,205 $1,691,616 $12,643,205
832776 JPMORGAN CHASE ELT $687,419 $13,055,632 $990,276 $54,377,983 $1,677,695 $67,433,615
SMS CORP--HI.
833128 SC STUDENT LOAN $0 $1,665,457 $8,916 $1,665,457 $8,916
TAXABLE.
833864 US BANK ELT ACADEMIC $0 $1,592,920 $108,775,186 $1,592,920 $108,775,186
FIN CORP.
819414 BENEFICIAL SAVINGS $0 $1,590,920 $71,898,895 $1,590,920 $71,898,895
BANK.
833570 US BANK ELT ACCESS $0 $1,567,997 $59,191,082 $1,567,997 $59,191,082
GROUP.
833752 BANK OF NY ELT ALL $684,281 $17,952,418 $863,612 $59,908,581 $1,547,893 $77,860,999
STUDENT LOAN COR.
821359 FIRST NATIONAL BANK $0 $1,544,988 $39,351,990 $1,544,988 $39,351,990
OF BRYAN.
810612 REGIONS BANK........ $0 $1,501,607 $17,431,726 $1,501,607 $17,431,726
805317 BANK OF AMERICA..... $0 $1,498,939 $7,622,306 $1,498,939 $7,622,306
811698 US BANK NA.......... $0 $1,485,878 $74,835,812 $1,485,878 $74,835,812
831056 WELLS FARGO ELT $0 $1,484,071 $89,084,720 $1,484,071 $89,084,720
PANHANDLE PLAINS SL.
822573 GEORGIA STUDENT $0 $1,472,832 $69,263,687 $1,472,832 $69,263,687
FINANCE AUTHORITY.
823011 ANCHORBANK F S B.... $0 $1,429,720 $93,734,160 $1,429,720 $93,734,160
821728 TCF NATIONAL BANK... $0 $1,420,971 $3,496,978 $1,420,971 $3,496,978
811323 WACHOVIA EDUCATION $0 $1,397,569 $6,603,030 $1,397,569 $6,603,030
FINANCE INC.
833356 YORK BK CNS ELT 97I $0 $1,373,195 $96,980,273 $1,373,195 $96,980,273
EDUCAID/WACHOVI.
820564 SUNTRUST BANK....... $0 $1,356,653 $42,507,133 $1,356,653 $42,507,133
829988 NELLIE MAE JPMORGAN $0 $1,325,244 $63,702,208 $1,325,244 $63,702,208
CHASE ELT.
834082 WELLS FARGO NA ELT $0 $1,319,689 $84,839,990 $1,319,689 $84,839,990
EDUCAP INC.
801890 US BANK NA.......... $0 $1,315,323 $71,814,047 $1,315,323 $71,814,047
834105 FINANCE AUTHORITY OF $0 $1,303,124 $84,797,360 $1,303,124 $84,797,360
MAINE.
815745 SIMMONS FIRST $0 $1,283,663 $63,487,446 $1,283,663 $63,487,446
NATIONAL BANK.
828141 NORTHWEST SAVINGS $0 $1,266,337 $66,448 $1,266,337 $66,448
BANK.
804267 US BANK NA.......... $0 $1,241,231 $46,712,572 $1,241,231 $46,712,572
803909 UNION BANK & TRUST.. $0 $1,213,916 $65,533,889 $1,213,916 $65,533,889
833668 SC STUDENT LOAN CORP $124,154 $2,057,939 $1,087,813 $61,281,871 $1,211,966 $63,339,810
(LL05).
808036 M & T BANK $0 $1,202,253 $288,568 $1,202,253 $288,568
EDUCATIONAL LENDING.
805204 CITIZENS BANK C/O $0 $1,180,637 $45,536,303 $1,180,637 $45,536,303
EDUCATION FINANCE.
833456 ZIONS FNB ELT NHELP $0 $1,174,786 $39,685,480 $1,174,786 $39,685,480
II INC.
824206 JPMORGAN CHASE BANK $0 $1,164,667 $7,186,088 $1,164,667 $7,186,088
NA.
824650 WELLS FARGO $0 $1,146,631 $62,854,858 $1,146,631 $62,854,858
EDUCATION FIN SVCS.
834011 FIFTH THIRD ELT $0 $1,126,717 $76,841,810 $1,126,717 $76,841,810
STUDENT LOAN XPRESS.
831416 ANCHORBANK FSB...... $0 $1,108,530 $95,895,899 $1,108,530 $95,895,899
834172 US BANK ELT GRADUATE $0 $1,105,957 $16,763,617 $1,105,957 $16,763,617
LEVERAGE.
828707 SOVEREIGN BANK...... $0 $1,104,340 $45,894,529 $1,104,340 $45,894,529
807674 BANK OF AMERICA N A. $0 $1,102,626 $47,605,912 $1,102,626 $47,605,912
833883 CITIZENS BANK C/O $0 $1,052,872 $21,971,422 $1,052,872 $21,971,422
EDUCATION FINANCE.
833816 US BANK ELT OHIO $0 $1,047,102 $36,488,233 $1,047,102 $36,488,233
CENTRIC.
810148 CLS--NATIONAL CITY $0 $1,009,846 $5,050,766 $1,009,846 $5,050,766
BANK PITTSBURG.
806773 BOONE COUNTY $0 $1,009,678 $19,921,177 $1,009,678 $19,921,177
NATIONAL BANK.
826079 BANK OF AMERICA N A. $0 $996,456 $40,344,830 $996,456 $40,344,830
834158 BANK OF NY ELT $0 $991,247 $659,745 $991,247 $659,745
COLLEGE SOLUTIONS
NE.
829503 PA HIGHER ED ASST $0 $962,633 $21,228,386 $962,633 $21,228,386
AGENCY.
804609 US BANK NA.......... $0 $960,725 $47,155,192 $960,725 $47,155,192
808258 US BANK NA.......... $0 $955,083 $54,642,469 $955,083 $54,642,469
833732 US BANK ELT $0 $934,110 $3,145,736 $934,110 $3,145,736
AMERIFUND.
813385 MEMBERS 1ST FEDERAL $0 $926,491 $34,267,174 $926,491 $34,267,174
CREDIT UNION.
824514 UNIVERSITY OF $0 $892,757 $25,838,212 $892,757 $25,838,212
CHICAGO.
821920 FIRSTRUST SAVINGS ($111) $889,420 $32,254,627 $889,310 $32,254,627
BANK.
831221 SC STUDENT LOAN $0 $856,898 $0 $856,898 $0
CORPORATION.
808626 JPMORGAN CHASE BANK $0 $856,378 $85,362 $856,378 $85,362
NA.
834093 WEBSTER UNIVERSITY.. $0 $850,828 $2,029,694 $850,828 $2,029,694
808140 CHARTER ONE BANK NA. $0 $835,765 $37,148,049 $835,765 $37,148,049
834246 US BANK ELT $226 $834,584 $58,592,235 $834,809 $58,592,235
KNOWLEDGEFUNDING
OHIO.
810883 FROST NATIONAL BANK. $0 $828,510 $19,098,314 $828,510 $19,098,314
817455 ZIONS BANK.......... $0 $823,376 $36,693,546 $823,376 $36,693,546
811949 M&I MARSHALL & $0 $816,884 $4,563,367 $816,884 $4,563,367
ILSLEY BANK.
819590 SECURITY SERVICE FCU $0 $813,973 $44,148,006 $813,973 $44,148,006
822373 AMERICA FIRST CREDIT $0 $804,989 $36,175,943 $804,989 $36,175,943
UNION.
833820 ZIONS ELT EDUCATION $0 $800,735 $3,036,199 $800,735 $3,036,199
SOLUTIONS INC.
834132 HANCOCK BANK ELT $0 $798,930 $37,662,768 $798,930 $37,662,768
MHEAC.
805178 BANK OF NY ELT TTEE $600,580 $23,137,957 $196,885 $13,444,894 $797,465 $36,582,851
LELA.
808543 UNION BANK & TRUST.. $0 $792,752 $5,424,546 $792,752 $5,424,546
806361 BREMER BANK NA...... $0 $786,220 $36,115,943 $786,220 $36,115,943
829077 SOUTHWEST STUDENT $0 $772,177 $48,595,148 $772,177 $48,595,148
SERV TRUST WFB EL.
804435 COMMERCE BANK AND $0 $759,942 $43,789,998 $759,942 $43,789,998
TRUST.
819958 FARMERS SAVINGS BANK $0 $759,369 $15,252,377 $759,369 $15,252,377
823584 BANK OF LAKE MILLS.. $0 $731,683 $3,600,131 $731,683 $3,600,131
833789 ZIONS ELT STUDENT LN $0 $728,851 $43,831,618 $728,851 $43,831,618
FIN ASSOC INC.
812265 CITIZENS BANK C/O $0 $726,467 $31,010,542 $726,467 $31,010,542
EDUCATION FINANCE.
810457 FNB SIOUX FALLS..... $0 $720,050 $9,062 $720,050 $9,062
833214 STUDENT LOAN FUNDING $0 $718,588 $39,819,685 $718,588 $39,819,685
US BANK ELT.
820043 WASHINGTON MUTUAL $0 $716,020 $415,735 $716,020 $415,735
BANK FA.
802445 WACHOVIA EDUCATION $0 $714,772 $11,365,416 $714,772 $11,365,416
FINANCE INC.
834006 KEY BANK NA ELT $0 $688,571 $2,633,540 $688,571 $2,633,540
INDIANA SECONDARY M.
827954 GUARANTY BANK....... $0 $676,733 $4,724,332 $676,733 $4,724,332
812089 TEXAS HIGHER $424,017 $16,891,628 $251,411 $16,112,294 $675,428 $33,003,922
EDUCATION COORD
BOARD.
833331 USC CREDIT UNION.... $0 $673,880 $29,306,292 $673,880 $29,306,292
802176 BANK OF AMERICA..... $0 $659,382 $1,890,601 $659,382 $1,890,601
833443 COMPASS BANK........ $0 $652,746 $34,424,569 $652,746 $34,424,569
834004 FIRST NATIONAL BANK. $0 $636,552 $4,542,076 $636,552 $4,542,076
833908 FIFTH THIRD ELT $0 $623,214 $5,703,629 $623,214 $5,703,629
STUDENT LOAN XPRESS.
829771 TCF NATIONAL BANK... $0 $620,503 $141,566 $620,503 $141,566
833487 BANK OF NY ELT $0 $0 $619,173 $24,257,024 $619,173 $24,257,024
LOANSTAR.
810240 CITIZENS BANK C/O $0 $612,565 $30,834,135 $612,565 $30,834,135
EDUCATION FINANCE.
820163 UNION BANK CA ELT $12,940 $0 $594,319 $439,200 $607,259 $439,200
CHELA FUND II (TE).
828893 PENNSYLVANIA STATE $0 $605,136 $25,980,472 $605,136 $25,980,472
EMPLOYEES CREDIT.
818260 FIRST HAWAIIAN BANK. $0 $604,450 $30,109,871 $604,450 $30,109,871
824246 CONNECTICUT STUDENT $0 $604,034 $22,645,855 $604,034 $22,645,855
LOAN FOUNDATION.
816376 TINKER FEDERAL $0 $600,361 $34,106,833 $600,361 $34,106,833
CREDIT UNION.
821614 UNION BANK CA ELT $249,317 $342,927 $107,157 $592,244 $107,157
CHELA FUND I (TEF).
834040 WELLS FARGO ELT OPUS $0 $588,256 $989,146 $588,256 $989,146
FINANCIAL INC.
827427 MISSION FEDERAL $0 $579,561 $21,973,311 $579,561 $21,973,311
CREDIT UNION.
834204 FIFTH THIRD BANK ELT $0 $573,416 $25,001,032 $573,416 $25,001,032
FINANSURE STUD.
830248 UTAH STATE BOARD OF $572,615 $12,443,094 $0 $572,615 $12,443,094
REGENTS/STNF.
805156 JPMORGAN CHASE BANK $0 $571,243 $3,142,300 $571,243 $3,142,300
NA.
828957 PHILADELPHIA FEDERAL $0 $570,306 $23,769,305 $570,306 $23,769,305
CREDIT UNION.
808190 TEACHERS FCU........ $0 $570,091 $24,459,881 $570,091 $24,459,881
808857 JPMORGAN CHASE BANK $0 $560,748 $6,538,059 $560,748 $6,538,059
NA.
831543 WASHINGTON MUTUAL $0 $558,840 $2,680,739 $558,840 $2,680,739
BANK FA.
833174 BANK OF NY ELT ALL $23,262 $905,667 $535,552 $68,339,754 $558,814 $69,245,421
STUDENT LOAN COR.
828875 COLLEGEINVEST....... $53,595 $1,207,439 $500,090 $27,629,717 $553,684 $28,837,156
810815 FIRST NATIONAL BANK. $0 $549,131 $33,695,801 $549,131 $33,695,801
833585 JPMORGANCHASE ELT $0 $548,273 $27,978,860 $548,273 $27,978,860
AMS FINANCING ENT.
831428 MIDWESTERN $0 $546,465 $2,077,022 $546,465 $2,077,022
UNIVERSITY.
811978 WELLS FARGO $0 $540,224 $32,240,818 $540,224 $32,240,818
EDUCATIONAL FIN
SVCS.
800635 BOA STUDENT BANKING/ $0 $537,944 $24,001,213 $537,944 $24,001,213
CA9-169-04-01.
809063 BANK OF OKLAHOMA.... $0 $532,789 $7,749,693 $532,789 $7,749,693
828148 UNIVERSITY FEDERAL ($29) $525,861 $521,259 $525,832 $521,259
CREDIT UNION.
828078 COMPASS BANK........ $0 $523,061 $33,549,363 $523,061 $33,549,363
806965 US BANK NA.......... $0 $520,642 $23,502,153 $520,642 $23,502,153
805987 COMERICA BANK....... $0 $517,134 $333,522 $517,134 $333,522
834101 US BANK ELT SCHOOL $0 $516,005 $16,357,111 $516,005 $16,357,111
LOANS CORP.
809478 M &T BANK $0 $512,935 $1,046,750 $512,935 $1,046,750
EDUCATIONAL LENDING.
808622 FIRSTMERIT BANK N. $511,245 $24,050,927 $511,245 $24,050,927
A$0.
833751 BANK OF NY ELT ALL $0 $503,284 $53,546,992 $503,284 $53,546,992
STUDENT LOAN COR.
830445 AGGIELAND CREDIT $0 $488,915 $21,004,285 $488,915 $21,004,285
UNION.
813721 TRUSTMARK NATIONAL $0 $487,581 $332,109 $487,581 $332,109
BANK.
823291 FIRSTMARK CREDIT $0 $486,518 $2,658 $486,518 $2,658
UNION.
807329 CITIZENS BANK C/O $0 $464,394 $16,836,386 $464,394 $16,836,386
EDUCATION FINANCE.
833364 JPMORGAN CHASE ELT $0 $462,979 $94,605,451 $462,979 $94,605,451
PNC.
819628 JPMORGAN CHASE BANK $0 $461,600 $1,512,004 $461,600 $1,512,004
NA.
804581 EMPRISE BANK........ $0 $460,964 $24,387,568 $460,964 $24,387,568
832384 WELLS FARGO $0 $456,230 $30,059,956 $456,230 $30,059,956
EDUCATION FIN SVCS.
831387 BANK OF MISSISSIPPI $295,997 $12,569,426 $156,170 $26,424,912 $452,166 $38,994,338
ELT MHEAC.
824289 LASALLE BANK........ $0 $446,335 $1,290,887 $446,335 $1,290,887
818464 SUNCOAST SCHOOLS FCU $0 $446,262 $18,732,294 $446,262 $18,732,294
801764 WELLS FARGO $0 $444,805 $60,114 $444,805 $60,114
EDUCATION FIN SVCS.
819480 EDUCATORS CREDIT $0 $443,003 $21,579,334 $443,003 $21,579,334
UNION.
833669 UNION BANK & TRUST $0 $438,967 $1,393,835 $438,967 $1,393,835
ELT NAT'L ED LNS.
817546 MOUNTAIN AMERICA $0 $438,437 $19,582,424 $438,437 $19,582,424
CREDIT UNION.
806627 BANCORPSOUTH........ $0 $435,975 $74,787 $435,975 $74,787
820238 BANC FIRST.......... $0 $435,412 $24,189,367 $435,412 $24,189,367
831726 BANC FIRST.......... $0 $430,097 $13,149,428 $430,097 $13,149,428
833930 UNION BANK ELT $0 $427,032 $13,410,499 $427,032 $13,410,499
TROJAN FINANCIAL.
828352 JPMORGAN CHASE BANK $0 $426,109 $1,225,455 $426,109 $1,225,455
NA.
803143 ALBANY BANK AND $0 $423,235 $757,113 $423,235 $757,113
TRUST CO.
828062 DOW CHEMICAL $0 $421,514 $17,296,566 $421,514 $17,296,566
EMPLOYEES' CU.
810753 COMMERCIAL BANK OF $0 $420,455 $19,879,101 $420,455 $19,879,101
TEXAS N A.
811353 SUNTRUST BANK....... $0 $410,913 $14,305,335 $410,913 $14,305,335
810088 FULTON BANK......... $0 $409,154 $18,652,555 $409,154 $18,652,555
815678 US BANK NA.......... $0 $399,267 $17,115,477 $399,267 $17,115,477
811025 KEY BANK NA......... $0 $399,222 $10,008,059 $399,222 $10,008,059
822135 TCF NATIONAL BANK... $0 $398,077 $3,076,875 $398,077 $3,076,875
823459 ROYAL CREDIT UNION.. $0 $388,700 $18,133,551 $388,700 $18,133,551
811735 BANK OF AMERICA NA.. $0 $387,926 $12,167,032 $387,926 $12,167,032
805243 BANK OF AMERICA..... $0 $382,275 $1,326,982 $382,275 $1,326,982
824565 NORTHWESTERN $0 $381,068 $11,748,595 $381,068 $11,748,595
UNIVERSITY.
810166 UNIVEST NATIONAL $0 $377,389 $14,102,649 $377,389 $14,102,649
BANK & TRUST.
808865 JPMORGAN CHASE BANK $0 $375,719 $8,484,936 $375,719 $8,484,936
NA.
810710 AMARILLO NATIONAL $0 $374,534 $16,700,717 $374,534 $16,700,717
BANK.
826861 CITIZENS BANK C/O $0 $374,086 $18,316,088 $374,086 $18,316,088
EDUCATION FINANCE.
833130 SUMMIT CREDIT UNION. $0 $364,823 $13,278,282 $364,823 $13,278,282
819129 BANK MUTUAL......... $0 $361,719 $16,317,046 $361,719 $16,317,046
831459 WESTCONSIN CREDIT $0 $360,860 $14,853,331 $360,860 $14,853,331
UNION.
825509 JPMORGAN CHASE BANK $0 $358,836 $1,185,978 $358,836 $1,185,978
N A.
802828 NATIONAL CITY BANK $0 $357,631 $10,292,596 $357,631 $10,292,596
MI-IL.
829257 PURDUE EMPLOYEES F C $0 $351,402 $67,394 $351,402 $67,394
U.
824821 UNIVERSITY OF DENVER $0 $344,761 $0 $344,761 $0
824945 MICHIGAN STATE $0 $342,803 $0 $342,803 $0
UNIVERSITY.
833575 EDUCATION SERVICES $0 $338,511 $909,020 $338,511 $909,020
FOUNDATION.
800301 ARVEST BANK......... $0 $338,231 $1,073,618 $338,231 $1,073,618
811930 US BANK NA.......... $0 $338,023 $17,475,823 $338,023 $17,475,823
809070 BANC FIRST.......... $0 $336,822 $13,580,878 $336,822 $13,580,878
825163 GEORGE WASHINGTON $0 $332,016 $282,293 $332,016 $282,293
UNIVERSITY.
833416 FIRST NAT'L BANK-- $0 $323,684 $17,347,345 $323,684 $17,347,345
HUNTSVILLE.
808238 FIRST NATIONAL BANK $0 $323,189 $12,845,187 $323,189 $12,845,187
OF OMAHA.
834058 DEUTSCHE BANK ELT $0 $322,888 $14,573,121 $322,888 $14,573,121
MEDPREFERRED.
807878 FIRST NIAGARA $0 $322,697 $20,613,004 $322,697 $20,613,004
FINANCIAL GROUP.
829505 WASHINGTON MUTUAL $0 $322,420 $112,712 $322,420 $112,712
BANK FA.
834036 UNION BANK ELT WAYNE $0 $316,460 $316,460 $0
STATE U.
812967 PENN SECURITY BANK & $0 $314,750 $12,919,099 $314,750 $12,919,099
TRUST CO.
820605 KLEBERG FIRST $0 $313,277 $15,362,989 $313,277 $15,362,989
NATIONAL BANK.
807772 FIVE STAR BANK...... $0 $312,808 $63,634 $312,808 $63,634
831785 STUDENT LOAN FUNDING $296,983 $5,440,874 $10,675 $1,150,439 $307,659 $6,591,313
US BANK ELT.
824697 OXFORD BANK & TRUST. $0 $307,115 $14,763,688 $307,115 $14,763,688
829123 UTAH COMMUNITY $0 $306,941 $13,757,613 $306,941 $13,757,613
CREDIT UNION.
808956 JPMORGAN CHASE BANK $0 $303,536 $48,044,014 $303,536 $48,044,014
NA.
831003 ARVEST BANK NORMAN.. $0 $300,059 $12,536,082 $300,059 $12,536,082
823546 UNIVERSITY OF $0 $299,362 $721,773 $299,362 $721,773
MISSOURI-KANSAS
CITY.
828943 ERIE FCU............ $0 $293,041 $10,244,155 $293,041 $10,244,155
820807 REGIONS BANK........ $0 $291,707 $15,313,057 $291,707 $15,313,057
833314 PLAINSCAPITAL BANK.. $0 $289,121 $0 $289,121 $0
809514 FIRST COMMONWEALTH.. $0 $288,503 $11,045,786 $288,503 $11,045,786
833197 DAUPHIN CNS ELT 95I $0 $286,311 $3,369 $286,311 $3,369
EDUCAID/WACHOVI.
803238 THE NATIONAL BANK... $0 $284,281 $5,245 $284,281 $5,245
807015 FIRST INTERSTATE $0 $283,468 $8,599,921 $283,468 $8,599,921
BANK OF MONTANA.
831643 ROSALIND FRANKLIN $0 $281,128 $61,950 $281,128 $61,950
UNIV/MED&SCIENCE.
831836 ORANGE COUNTY $0 $280,900 $13,218,986 $280,900 $13,218,986
TEACHERS FCU.
833963 US BANK ELT ACAPITA. $0 $280,785 $16,085,468 $280,785 $16,085,468
834037 TUFTS UNIVERSITY.... $0 $280,602 $22,222 $280,602 $22,222
821628 UNION BANK CA ELT $29,916 $0 $249,643 $652,584 $279,558 $652,584
CHELA FUND I (TEF).
803310 JPMORGAN CHASE BANK $0 $278,414 $3,245,543 $278,414 $3,245,543
NA.
826651 UNIVERSITY OF MIAMI. $0 $270,515 $453,832 $270,515 $453,832
810563 FIRST TENNESSEE BANK $0 $265,627 $126,555 $265,627 $126,555
804189 SECURITY NATIONAL $0 $263,829 $9,321,387 $263,829 $9,321,387
BANK.
821375 ALTRA FCU........... $0 $261,028 $9,353,314 $261,028 $9,353,314
802560 SUNTRUST BANK....... $0 $260,367 $10,228,961 $260,367 $10,228,961
808628 US BANK NA.......... $0 $259,679 $14,337,251 $259,679 $14,337,251
818093 JPMORGAN CHASE BANK $0 $259,433 $1,194,043 $259,433 $1,194,043
NA.
833102 TSB MCALLEN- ELT $0 $254,236 $12,015,251 $254,236 $12,015,251
COSTEP.
834060 US BANK ELT $0 $249,538 $1,651,785 $249,538 $1,651,785
EDAMERICA.
809094 ARVEST BANK......... $0 $248,682 $12,973,914 $248,682 $12,973,914
821176 KANSAS STATE BANK OF $0 $248,607 $159,716 $248,607 $159,716
MANHATTAN KS.
824310 WASHINGTON $0 $248,527 $8,460 $248,527 $8,460
UNIVERSITY.
805974 JPMORGAN CHASE BANK $0 $245,518 $682,789 $245,518 $682,789
NA.
824890 REGIS UNIVERSITY.... $0 $241,519 $60,486 $241,519 $60,486
830674 WELLS FARGO $0 $240,149 $16,171,173 $240,149 $16,171,173
EDUCATION FIN SVCS.
831036 INDEPENDENCE FSB.... $0 $238,206 $4,920,253 $238,206 $4,920,253
833738 PALMER COLLEGE OF $0 $237,751 $0 $237,751 $0
CHIROPRACTIC.
830526 ST LOUIS COMMUNITY $0 $237,154 $8,623,664 $237,154 $8,623,664
CREDIT UNION.
834096 BANCORPSOUTH ELT $183,356 $8,482,235 $51,173 $3,849,670 $234,529 $12,331,905
MHEAC.
811111 SUNTRUST BANK....... $0 $234,449 $132,375,855 $234,449 $132,375,855
827305 UNIVERSITY CREDIT $0 $232,857 $10,223,683 $232,857 $10,223,683
UNION.
833895 ZIONS ELT NELNET $0 $230,573 $724,431,823 $230,573 $724,431,823
MGMT CORP-1 & AFF.
830489 COMERICA BANK....... $0 $227,181 $10,433,934 $227,181 $10,433,934
810742 CITIZENS STATE BANK. $0 $224,727 $5,866,170 $224,727 $5,866,170
834111 US BANK ELT PCOM $0 $224,594 $44,351 $224,594 $44,351
STUDENT LOAN LLC.
833901 BANK OF NY ELT US $0 $223,376 $0 $223,376 $0
EDUCATION LOAN TR.
834048 KANSAS CITY UNIV MED $0 $223,038 $0 $223,038 $0
& BIO SCI.
831506 COMMUNITY TRUST BANK $0 $221,775 $12,026,509 $221,775 $12,026,509
827526 MISSOULA FEDERAL $0 $220,717 $6,467,257 $220,717 $6,467,257
CREDIT UNION.
830132 UNIVERSITY OF UTAH $0 $219,517 $9,590,992 $219,517 $9,590,992
CU.
824837 AMERICAN UNIVERSITY. $0 $214,843 $110,030 $214,843 $110,030
813331 CHARLEROI FEDERAL $0 $210,665 $7,997,110 $210,665 $7,997,110
SAVINGS & LOAN.
834129 UNIVERSITY OF SAN $0 $210,610 $2,258 $210,610 $2,258
FRANCISCO.
833965 UNIVERSITY OF MD $0 $209,449 $0 $209,449 $0
BALTIMORE.
815961 UNITED MISSOURI BANK $0 $209,126 $7,561,724 $209,126 $7,561,724
OF KANSAS CITY.
826910 COMMUNITY FIRST $0 $208,876 $9,329,203 $208,876 $9,329,203
CREDIT UNION.
820718 INTERNATIONAL BANK $0 $208,669 $5,217,099 $208,669 $5,217,099
OF COMMERCE.
831925 ZIONS BANK (OREGON $0 $206,450 $2,513,359 $206,450 $2,513,359
FIRST).
808588 JPMORGAN CHASE BANK $0 $205,354 $27,863,404 $205,354 $27,863,404
NA.
829441 MARINE CREDIT UNION. $0 $203,596 $8,372,756 $203,596 $8,372,756
820998 SPOKANE TEACHERS $0 $202,909 $9,076,496 $202,909 $9,076,496
CREDIT UNION.
831366 CITIBANK NA ELT $0 $200,903 $7,322,637 $200,903 $7,322,637
STUDENT LOAN CORP.
831011 SUN EAST FCU........ $0 $199,397 $7,881,858 $199,397 $7,881,858
829443 WRIGHT-PATT CREDIT $0 $195,709 $10,706,997 $195,709 $10,706,997
UNION INC.
805148 WHITNEY NATIONAL $0 $194,333 $777,802 $194,333 $777,802
BANK.
829384 WAKEFIELD CO- $0 $188,978 $4,472,263 $188,978 $4,472,263
OPERATIVE BANK.
831216 JP MORGANCHASE BANK. $0 $187,955 $6,445,332 $187,955 $6,445,332
831555 US BANK NA.......... $0 $186,450 $4,086,339 $186,450 $4,086,339
810778 FIRST FINANCIAL BANK $0 $184,266 $229,964 $184,266 $229,964
NA.
803799 FIRST FINANCIAL BANK $0 $183,874 $8,695,757 $183,874 $8,695,757
808942 CLS-NATIONAL CITY $0 $181,431 $781,461 $181,431 $781,461
BANK.
820946 US BANK NA.......... $0 $179,170 $7,485,273 $179,170 $7,485,273
822466 CASE WESTERN RESERVE $0 $178,456 $288,963 $178,456 $288,963
UNIVERSITY.
822660 COMERICA BANK....... $0 $172,358 $1,237,646 $172,358 $1,237,646
831083 A.T. STILL UNIV OF $0 $170,972 $29,437 $170,972 $29,437
HEALTH SCI.
834231 US BANK ELT AFFINITY $0 $170,808 $1,943,288 $170,808 $1,943,288
DIRECT.
830612 A.T. STILL UNIV OF $0 $169,242 $0 $169,242 $0
HEALTH SCI.
800246 ARKANSAS RURAL $0 $169,087 $169,087 $0
ENDOWMENT FUND INC.
833395 JPMORGAN CHASE ELT $0 $168,003 $20,575,107 $168,003 $20,575,107
FIRST UNION NAT'.
820622 JPMORGAN CHASE BANK $0 $165,862 $13,566,008 $165,862 $13,566,008
NA.
828454 ADELPHI UNIVERSITY.. $0 $164,920 $23,038 $164,920 $23,038
834182 UNIVERSITY OF NEW $0 $163,144 $77,558 $163,144 $77,558
MEXICO.
824705 PATRIOT FEDERAL $0 $161,742 $6,209,907 $161,742 $6,209,907
CREDIT UNION.
806722 CADENCE BANK NA..... $0 $161,221 $6,563,556 $161,221 $6,563,556
825175 UNIVERSITY OF DAYTON $0 $159,614 $13,969 $159,614 $13,969
833946 US BANK ELT 1ST $0 $159,045 $9,124,946 $159,045 $9,124,946
STUDENT FINANCIAL.
830977 POLICE & FIRE $0 $158,241 $9,443,803 $158,241 $9,443,803
FEDERAL CREDIT
UNION.
833599 WACHOVIA EDUCATION $0 $157,104 $5,967,876 $157,104 $5,967,876
FINANCE INC.
828341 TEXAS STATE BANK.... $0 $156,891 $7,650,844 $156,891 $7,650,844
811076 ZIONS BANK $0 $154,815 $2,508,573 $154,815 $2,508,573
(WASHINGTON FIRST).
802486 SUNTRUST BANK....... $0 $154,751 $154,751 $0
821623 UNION BANK CA ELT $37,883 $115,310 $113,914 $153,194 $113,914
CHELA FUND I (TEF).
833918 SOUTHERN METHODIST $0 $152,748 $41,668 $152,748 $41,668
UNIVERSITY.
833750 WESTERN UNIV OF $0 $152,584 $618,085 $152,584 $618,085
HEALTH SCIENCES.
801891 US BANK NA.......... $0 $152,242 $3,095 $152,242 $3,095
831824 US BANK NA.......... $0 $150,818 $5,660,015 $150,818 $5,660,015
832215 NET FCU............. $0 $149,801 $5,512,386 $149,801 $5,512,386
809643 HARLEYSVILLE NAT'L $0 $149,172 $7,910,371 $149,172 $7,910,371
BANK AND TRUST.
827242 HOME SAVINGS & LOAN $0 $149,064 $7,000 $149,064 $7,000
CO YOUNGSTOWN.
831122 THE INDEPENDENT $0 $148,550 $6,451,709 $148,550 $6,451,709
BANKERS BANK.
803634 JPMORGAN CHASE BANK $0 $147,689 $148,804 $147,689 $148,804
NA.
812187 UNIVERSITY OF $0 $147,610 $0 $147,610 $0
OKLAHOMA LEW WENTZ
FO.
813389 FIRST COMMONWEALTH F $0 $147,192 $5,374,625 $147,192 $5,374,625
C U.
829189 ALABAMA HIGHER $101,677 $3,074,842 $42,896 $2,915,872 $144,573 $5,990,714
EDUCATION LOAN CORP.
830186 JP MORGAN CHASE BANK $0 $142,652 $6,418,076 $142,652 $6,418,076
809685 LAFAYETTE BANK...... $0 $142,173 $5,632,003 $142,173 $5,632,003
823699 ASSOCIATED BANK $141,984 $141,984 $0
N.A$0.
833810 CARNEGIE INSURANCE $0 $139,948 $574,430 $139,948 $574,430
COMPANY.
824721 DUKE UNIVERSITY..... $0 $139,463 $38,125 $139,463 $38,125
832748 OMEGA FCU........... $0 $138,183 $5,427,096 $138,183 $5,427,096
809870 PEOPLES NATIONAL $0 $134,626 $5,204,439 $134,626 $5,204,439
BANK.
834121 PACE UNIVERSITY..... $0 $132,801 $20,486 $132,801 $20,486
834074 UNIVERSITY OF $0 $132,766 $132,766 $0
LAVERNE.
828562 MUNICIPAL TRUST & $0 $132,578 $7,874,273 $132,578 $7,874,273
SAVINGS BANK.
804959 CLS-NATIONAL CITY $0 $132,321 $647,269 $132,321 $647,269
BANK KENTUCKY.
811325 FIRST UNION NATIONAL $0 $132,226 $0 $132,226 $0
BANK.
819524 PLATTE VALLEY STATE $0 $131,990 $5,306,405 $131,990 $5,306,405
BANK & TRUST CO.
827985 STATE NATIONAL BANK. $0 $131,548 $6,337,962 $131,548 $6,337,962
811911 FIRST NATIONAL BANK $0 $130,951 $7,173,588 $130,951 $7,173,588
OF RIVER FALLS.
823422 BOEING EMPLOYEES $0 $130,912 $5,884,548 $130,912 $5,884,548
CREDIT UNION.
833624 GEORGIA STUDENT $0 $130,746 $7,578,445 $130,746 $7,578,445
FINANCE AUTH.
806695 KEESLER FEDERAL $0 $130,715 $5,930,296 $130,715 $5,930,296
CREDIT UNION.
833371 AUSTIN BANK N A..... $0 $130,007 $6,233,002 $130,007 $6,233,002
832364 SANFORD INSTITUTION $0 $129,174 $5,768,242 $129,174 $5,768,242
FOR SAVINGS.
809507 FIRST NATIONAL BANK $0 $128,073 $6,634,779 $128,073 $6,634,779
& TRUST CO.
821087 JPMORGAN CHASE BANK $0 $127,987 $5,798,539 $127,987 $5,798,539
NA.
833892 ILLINOIS COLLEGE OF $0 $126,620 $126,620 $0
OPTOMETRY.
833361 STUDENT LOAN FUNDING $0 $125,591 $8,039,480 $125,591 $8,039,480
US BANK ELT.
834014 PARKER COLLEGE OF $0 $124,698 $0 $124,698 $0
CHIROPRACTIC.
818659 GREAT WISCONSIN $0 $123,621 $4,622,403 $123,621 $4,622,403
CREDIT UNION.
834166 LOGAN COLLEGE OF $0 $122,879 $0 $122,879 $0
CHIROPRACTIC.
813532 FIRST FEDERAL $0 $122,281 $6,554,571 $122,281 $6,554,571
SAVINGS AND LOAN
ASSO.
833815 PENNSYLVANIA COLLEGE $0 $122,181 $26,707 $122,181 $26,707
OF OPTOMETRY.
834057 INDIANA WESLEYAN $0 $121,877 $2,397,243 $121,877 $2,397,243
UNIVERSITY.
828910 BELCO COMMUNITY $0 $121,240 $4,485,550 $121,240 $4,485,550
CREDIT UNION.
834136 BASTYR UNIVERSITY... $0 $119,924 $4,123,317 $119,924 $4,123,317
802844 US BANK NA.......... $0 $119,870 $6,647,421 $119,870 $6,647,421
834062 SANTA CLARA $0 $119,187 $0 $119,187 $0
UNIVERSITY.
810725 BROADWAY NATIONAL $0 $117,092 $5,934,817 $117,092 $5,934,817
BANK.
831929 WOODFOREST NATIONAL $0 $116,030 $5,142,116 $116,030 $5,142,116
BANK.
832123 UNIVERSITY CREDIT $0 $115,954 $76,691 $115,954 $76,691
UNION.
819256 FOX COMMUNITIES $0 $115,006 $6,481,880 $115,006 $6,481,880
CREDIT UNION.
831059 HSBC BANK USA....... $0 $112,709 $16,888,518 $112,709 $16,888,518
833964 LIFE CHIROPRACTIC $0 $111,981 $2,424,925 $111,981 $2,424,925
COLLEGE WEST.
817558 CAMPUS FEDERAL $0 $111,791 $4,564 $111,791 $4,564
CREDIT UNION.
805979 COMERICA BANK....... $0 $111,764 $1,030,081 $111,764 $1,030,081
832398 LIFE UNIVERSITY..... $0 $111,641 $3,636,886 $111,641 $3,636,886
832600 SB1 FEDERAL CREDIT $0 $111,578 $4,302,237 $111,578 $4,302,237
UNION.
831678 ILLINOIS INSTITUTE $0 $111,356 $111,356 $0
OF TECHNOLOGY.
828969 AMERICO CU.......... $0 $111,080 $3,950,869 $111,080 $3,950,869
801953 FIRST NATIONAL BANK. $0 $110,596 $7,243,888 $110,596 $7,243,888
831970 THREE RIVERS FEDERAL $0 $110,449 $5,999,111 $110,449 $5,999,111
CREDIT UNION.
809456 ADAMS COUNTY $0 $109,378 $3,761,985 $109,378 $3,761,985
NATIONAL BANK.
828912 USSCO JOHNSTOWN FED $0 $108,991 $4,609,721 $108,991 $4,609,721
CREDIT UNION.
809479 LEBANON VALLEY $0 $108,182 $4,621,473 $108,182 $4,621,473
FARMERS BANK.
833956 NATIONAL-LOUIS $0 $107,906 $0 $107,906 $0
UNIVERSITY.
834178 UNION BANK ELT $0 $107,370 $0 $107,370 $0
UNIVERSITY OF
NEBRAS.
806689 HANCOCK BANK........ $0 $107,128 $241,077 $107,128 $241,077
834187 UNIVERSITY OF $0 $106,642 $839,827 $106,642 $839,827
ARIZONA.
803478 CLS-NATIONAL CITY $0 $106,479 $629,447 $106,479 $629,447
BANK.
834045 MICHIGAN STATE UNIV $0 $104,970 $0 $104,970 $0
COLLEGE OF LAW.
819133 BLACK HILLS FEDERAL $0 $103,442 $4,952,974 $103,442 $4,952,974
CREDIT UNION.
833072 TOWN & COUNTRY BANK. $0 $103,109 $5,488,177 $103,109 $5,488,177
834044 KANSAS STATE BANK $0 $103,059 $7,587 $103,059 $7,587
ELT KSU FOUNDATIO.
834095 TRUSTMARK ELT MHEAC. $65,978 $4,260,964 $37,060 $2,935,058 $103,037 $7,196,022
834028 FLORIDA STATE $0 $102,842 $2,664 $102,842 $2,664
UNIVERSITY.
818478 EL PASO AREA $0 $102,550 $4,836,051 $102,550 $4,836,051
TEACHERS FCU.
833011 WACOPSE FCU......... $0 $102,181 $3,491,122 $102,181 $3,491,122
834016 NORTHWESTERN HEALTH $0 $101,789 $4,250 $101,789 $4,250
SCI UNIVERSITY.
809817 NATIONAL PENN BANK.. $0 $101,766 $5,342,790 $101,766 $5,342,790
824573 ZIONS BANK ELT EFS ($87) $101,196 $1,894,938 $101,109 $1,894,938
FINANCE CO.
828302 SERVICE 1ST FCU..... $0 $100,405 $4,292,640 $100,405 $4,292,640
809674 IRWIN BANK & TRUST $0 $100,297 $4,312,965 $100,297 $4,312,965
COMPANY.
805811 UNION TRUST CO-- $0 $99,381 $6,305,428 $99,381 $6,305,428
ELLSWORTH.
824518 JOHNSON BANK........ $0 $98,837 $3,795,255 $98,837 $3,795,255
833252 LEGACYTEXAS BANK.... $0 $97,697 $4,764,757 $97,697 $4,764,757
834133 UNION BANK ELT MUO $0 $96,746 $1 $96,746 $1
FOUNDATION.
806723 RENASANT BANK....... $0 $96,429 $13,666 $96,429 $13,666
899996 SLMA................ $0 $93,579 $6,138,361 $93,579 $6,138,361
804657 SECURITY BANK OF $0 $93,445 $3,865,459 $93,445 $3,865,459
KANSAS CITY.
833828 DESERET FIRST CREDIT $0 $92,554 $3,969,697 $92,554 $3,969,697
UNION.
805801 SKOWHEGAN SAVINGS $0 $92,400 $3,689,723 $92,400 $3,689,723
BANK.
810819 FIRST NATIONAL BANK $0 $91,919 $72,591 $91,919 $72,591
OF CENTRAL TX.
833869 WESTERN ILLINOIS $0 $91,907 $4,103,401 $91,907 $4,103,401
UNIVERSITY.
834021 SHERMAN COLLEGE OF $0 $91,783 $2,657,122 $91,783 $2,657,122
STRAIGHT CHIRO.
829651 TEXAS TECH FEDERAL $0 $91,110 $3,645,479 $91,110 $3,645,479
CREDIT UNION.
807802 EMPOWER FEDERAL $0 $90,891 $3,921,333 $90,891 $3,921,333
CREDIT UNION.
831361 VIEWPOINT BANK...... $0 $89,152 $4,225,418 $89,152 $4,225,418
809402 PNC EDUCATION LOAN $0 $88,726 $10,701,085 $88,726 $10,701,085
CTR.
826943 ISU FEDERAL CREDIT $0 $88,034 $102,041 $88,034 $102,041
UNION.
830168 ARIZONA FCU......... $0 $87,794 $3,761,607 $87,794 $3,761,607
831403 CLS-NATIONAL CITY $0 $87,548 $1,348,535 $87,548 $1,348,535
BANK OF OHIO.
831784 INTERNATIONAL BANK $0 $86,834 $24,830 $86,834 $24,830
OF COMMERCE.
833305 BANK OF TEXAS NA.... $0 $86,061 $1,731,769 $86,061 $1,731,769
831259 US BANK NA.......... $0 $85,753 $3,349,168 $85,753 $3,349,168
828972 TIMBERLAND FEDERAL $0 $85,604 $3,305,757 $85,604 $3,305,757
CREDIT UNION.
807809 CHEMUNG CANAL TRUST $0 $84,462 $3,664,589 $84,462 $3,664,589
COMPANY.
834068 DUQUESNE UNIVERSITY. $0 $84,036 $84,036 $0
830317 STATE EMPLOYEES FCU. $0 $83,176 $3,404,933 $83,176 $3,404,933
833560 ERIE INSURANCE $0 $82,879 $3,228,489 $82,879 $3,228,489
EXCHANGE CU.
833742 SIMMONS COLLEGE..... $0 $82,334 $64,050 $82,334 $64,050
823561 MICHIGAN STATE $0 $82,263 $4,629,884 $82,263 $4,629,884
UNIVERSITY FCU.
805803 OCEAN COMMUNITIES $0 $82,129 $3,856,196 $82,129 $3,856,196
FCU.
820685 INDIANA UNIVERSITY $0 $81,307 $5,377,208 $81,307 $5,377,208
EMPLOYEES FCU.
832139 JPMORGAN CHASE BANK $0 $80,855 $65,402,442 $80,855 $65,402,442
ELT SLFC INC.
834015 DREXEL UNIVERSITY... $0 $80,732 $1,383,985 $80,732 $1,383,985
822897 WESTBY CO-OP CREDIT $0 $80,496 $3,273,828 $80,496 $3,273,828
UNION.
827888 WINGS FINANCIAL FCU. $0 $80,320 $3,638,387 $80,320 $3,638,387
809321 APOLLO TRUST COMPANY $0 $80,263 $4,683,684 $80,263 $4,683,684
833426 UW OSHKOSH CREDIT $0 $79,850 $3,833,559 $79,850 $3,833,559
UNION.
834001 CLEVELAND $0 $79,289 $0 $79,289 $0
CHIROPRACTIC
COLLEGE.
834141 WESTERN STATES CHIRO $0 $79,135 $0 $79,135 $0
COLLEGE.
826895 KOHLER CREDIT UNION. $0 $78,516 $4,512,589 $78,516 $4,512,589
815483 NORSTATE FEDERAL $0 $77,695 $2,868,798 $77,695 $2,868,798
CREDIT UNION.
802069 TD BANKNORTH NA..... $0 $76,802 $272,764 $76,802 $272,764
823619 COVANTAGE CREDIT $0 $76,548 $3,419,990 $76,548 $3,419,990
UNION.
808888 NATIONAL CITY BANK $0 $75,337 $1,310,391 $75,337 $1,310,391
OF OHIO.
822531 SUSQUEHANNA VALLEY $0 $75,211 $2,417,453 $75,211 $2,417,453
FEDERAL CREDIT U.
834194 OHIO NORTHERN $0 $74,947 $0 $74,947 $0
UNIVERSITY.
822218 TRI CITY NATIONAL $0 $74,727 $4,288,731 $74,727 $4,288,731
BANK.
810864 HAPPY STATE BANK.... $0 $74,063 $3,610,827 $74,063 $3,610,827
824674 NORWAY SAVINGS BANK. $0 $73,810 $641,304 $73,810 $641,304
899986 SLM ECFC............ $0 $73,804 $4,283,679 $73,804 $4,283,679
834154 UNIVERSITY OF $0 $73,521 $0 $73,521 $0
BRIDGEPORT.
833344 FIRST NATIONAL BK & $0 $73,483 $2,346,198 $73,483 $2,346,198
TR/WEATHERFORD.
822429 SOUTHSIDE STATE BANK $0 $73,246 $3,663,775 $73,246 $3,663,775
821995 YALE UNIVERSITY--A. $0 $72,192 $0 $72,192 $0
GALLAGHER.
821446 SANDY SPRING BANK... $0 $71,887 $2,484,445 $71,887 $2,484,445
833458 SUNTRUST BANK....... $0 $71,754 $0 $71,754 $0
834126 TEXAS CHIROPRACTIC $0 $71,510 $90,998 $71,510 $90,998
COLLEGE.
824192 BANK OF NEW ORLEANS. $0 $71,509 $1,953,003 $71,509 $1,953,003
822551 VISIONS FEDERAL $0 $71,502 $4,385,150 $71,502 $4,385,150
CREDIT UNION.
831775 ATLANTIC REGIONAL $0 $71,353 $2,832,011 $71,353 $2,832,011
FCU.
826592 CTCE FEDERAL CREDIT $0 $70,912 $2,751,407 $70,912 $2,751,407
UNION.
828954 MERHO FEDERAL CREDIT $0 $70,632 $2,812,286 $70,632 $2,812,286
UNION.
805595 WACHOVIA BANK NA.... $0 $70,333 $38,003,327 $70,333 $38,003,327
819451 US BANK NA.......... $0 $70,127 $2,173,142 $70,127 $2,173,142
834140 TEXAS CHRISTIAN $0 $69,214 $0 $69,214 $0
UNIVERSITY.
825597 COMMERCE BANK NA.... $0 $68,915 $2,724,976 $68,915 $2,724,976
824038 HUDSON VALLEY $0 $68,256 $4,002,864 $68,256 $4,002,864
FEDERAL CREDIT
UNION.
834005 UNIVERSITY OF $0 $67,941 $14,250 $67,941 $14,250
MISSOURI ST. LOUIS.
829565 CREIGHTON FCU....... $0 $67,814 $2,686,848 $67,814 $2,686,848
834078 UNIVERSITY OF $0 $66,875 $66,875 $0
CENTRAL FLORIDA.
828965 AMERICAN HERITAGE $0 $66,545 $3,959,131 $66,545 $3,959,131
FEDERAL CREDIT UN.
809713 MARS NATIONAL BANK.. $0 $66,469 $3,381,765 $66,469 $3,381,765
833920 NAT'L COLLEGE OF $0 $66,043 $0 $66,043 $0
NATURPATHIC MED.
833089 THE UNIVERSITY OF $0 $65,995 $0 $65,995 $0
TULSA.
833418 WOODFOREST NATIONAL $0 $65,367 $3,107,094 $65,367 $3,107,094
BANK.
808664 PARK NATIONAL BANK.. $0 $64,551 $4,100,311 $64,551 $4,100,311
828953 COMMERCE BANK....... $0 $64,547 $2,578,581 $64,547 $2,578,581
818613 CAPITAL CREDIT UNION $0 $64,260 $3,539,858 $64,260 $3,539,858
834160 FIFTH THIRD ELT $0 $64,082 $6,949,246 $64,082 $6,949,246
STUDENT LOAN XPRESS.
831622 SAN ANGELO NATIONAL $0 $63,981 $21,749 $63,981 $21,749
BANK.
831157 THRIVENT FINANCIAL $0 $63,385 $3,682,295 $63,385 $3,682,295
FOR LUTHERANS.
820872 ESB BANK............ $0 $63,063 $3,653,689 $63,063 $3,653,689
810173 AMERISERV FINANCIAL. $0 $62,883 $2,534,503 $62,883 $2,534,503
833731 SOUTHWEST COLLEGE OF $0 $62,522 $0 $62,522 $0
NATUROPATHIC.
830307 WEOKIE CREDIT UNION. $0 $62,449 $3,605,180 $62,449 $3,605,180
834091 BONY ELT COLLEGIATE $0 $61,854 $189,623 $61,854 $189,623
FUND SVCS RI/CF.
811000 FIRST FINANCIAL BANK $0 $61,648 $23,875 $61,648 $23,875
808118 M&T BANK EDUCATIONAL $0 $61,595 $42,700 $61,595 $42,700
LENDING.
805784 OXFORD FCU.......... $0 $61,487 $2,692,691 $61,487 $2,692,691
833387 SUMMIT BANK......... $0 $61,417 $286,868 $61,417 $286,868
813571 FIVEPOINT CREDIT $0 $61,168 $2,862,236 $61,168 $2,862,236
UNION.
832467 MAINE STATE CU...... $0 $61,015 $2,528,606 $61,015 $2,528,606
828931 TRI COUNTY AREA FCU. $0 $60,191 $2,761,284 $60,191 $2,761,284
834128 TRINITY $0 $60,070 $88,160 $60,070 $88,160
INTERNATIONAL
UNIVERSITY.
805798 MAINE FAMILY CREDIT $0 $59,722 $2,038,390 $59,722 $2,038,390
UNION.
834019 CLAREMONT GRADUATE $0 $59,691 $0 $59,691 $0
UNIVERSITY.
806931 STOCKMAN BANK OF $0 $59,358 $15,763 $59,358 $15,763
MONTANA.
809998 EPHRATA NATIONAL $0 $59,269 $3,026,150 $59,269 $3,026,150
BANK.
827999 SMART FINANCIAL $0 $59,265 $2,222,027 $59,265 $2,222,027
CREDIT UNION.
810731 CITIZENS NATIONAL $0 $58,899 $2,803,873 $58,899 $2,803,873
BANK.
826855 PIONEER SAVINGS BANK $0 $58,598 $3,382,529 $58,598 $3,382,529
821132 GREAT SOUTHERN $0 $58,508 $2,939,311 $58,508 $2,939,311
SAVINGS BANK.
820278 PITTSBURGH $0 $58,243 $1,916,020 $58,243 $1,916,020
FIREFIGHTERS
FEDERAL CRE.
805621 BAR HARBOR BANKING & $0 $57,899 $2,447,886 $57,899 $2,447,886
TRUST COMPANY.
834073 UNIVERSITY OF $0 $57,785 $635,244 $57,785 $635,244
PHOENIX.
806700 MERCHANTS & FARMERS $0 $57,572 $61,699 $57,572 $61,699
BANK.
833610 UNION BANK ELT $0 $57,517 $5,669,932 $57,517 $5,669,932
COLLEGE BOUND LOANS.
833957 NATIONAL UNIV OF $0 $56,967 $288,715 $56,967 $288,715
HEALTH SCIENCES.
807510 WACHOVIA EDUCATION $0 $56,361 $2,636,399 $56,361 $2,636,399
FINANCE INC.
833081 US BANK ELT SLFC.... $0 $56,335 $3,507,528 $56,335 $3,507,528
832723 LEE HOSPITAL CREDIT $0 $56,111 $2,157,464 $56,111 $2,157,464
UNION.
828560 WEST BEND SAVINGS $56,083 $2,868,056 $56,083 $2,868,056
BANK S. A$0.
810007 FIRST NATIONAL BANK $0 $55,707 $2,120,634 $55,707 $2,120,634
OF DANVILLE.
811571 JPMORGAN CHASE BANK $0 $55,316 $3,232,082 $55,316 $3,232,082
NA.
829114 OTIS FCU............ $0 $55,183 $2,208,921 $55,183 $2,208,921
832196 TOBYHANNA ARMY DEPOT $0 $55,113 $1,716,079 $55,113 $1,716,079
810104 THE MERCHANTS $0 $54,948 $3,045,108 $54,948 $3,045,108
NATIONAL BANK OF
KITT.
831222 PENN EAST FCU....... $0 $54,931 $1,774,612 $54,931 $1,774,612
833294 BANK OF GLOUCESTER $0 $54,647 $1,949,693 $54,647 $1,949,693
CO /FULTON BNK.
825446 UNISON CREDIT UNION. $0 $54,521 $2,157,741 $54,521 $2,157,741
833804 KEY BANK NA......... $0 $54,388 $1,141,078 $54,388 $1,141,078
800241 JPMORGAN CHASE BANK $0 $54,383 $5,062,741 $54,383 $5,062,741
NA.
832053 AMERICAN SAVINGS $0 $54,244 $119,753 $54,244 $119,753
BANK FSB.
833928 NAROPA UNIVERSITY... $0 $54,136 $54,136 $0
831606 FIRST CONVENIENCE $0 $53,484 $2,509,246 $53,484 $2,509,246
BANK.
812041 WAUKESHA STATE BANK. $0 $53,208 $2,690,906 $53,208 $2,690,906
830146 USU CHARTER FCU..... $0 $53,159 $2,488,620 $53,159 $2,488,620
828937 G A P FCU........... $0 $53,143 $2,035,515 $53,143 $2,035,515
831179 WELLS FARGO $0 $52,939 $1,788,257 $52,939 $1,788,257
EDUCATION FIN SVCS.
833247 EDUCATIONFIRST $0 $52,530 $2,625,653 $52,530 $2,625,653
FEDERAL CREDIT
UNION.
833868 SECU EMPLOYEES CU... $0 $52,208 $2,322,851 $52,208 $2,322,851
831908 CITY & COUNTY CREDIT $0 $51,905 $2,329,114 $51,905 $2,329,114
UNION.
833634 BANK OF ALBUQUERQUE $0 $51,842 $2,096,116 $51,842 $2,096,116
NA.
818493 CONNEXUS CU......... $0 $51,709 $2,203,484 $51,709 $2,203,484
821215 PEOPLES BANK OF $0 $51,661 $501,371 $51,661 $501,371
KANKAKEE COUNTY.
813414 SCOTTDALE BANK & $0 $51,408 $2,649,598 $51,408 $2,649,598
TRUST CO.
819770 FIRST FINANCIAL BANK $0 $51,228 $3,254,670 $51,228 $3,254,670
USA.
820284 SOVEREIGN BANK...... $0 $50,868 $2,269,072 $50,868 $2,269,072
805800 SEABOARD FEDERAL $0 $50,290 $2,123,694 $50,290 $2,123,694
CREDIT UNION.
832678 WASHINGTON AREA $0 $50,157 $1,814,810 $50,157 $1,814,810
TEACHERS FCU.
821549 SCHUYLKILL COUNTY $0 $50,020 $2,121,195 $50,020 $2,121,195
SCHOOLEMPLOYEES C.
827171 ANDROSCOGGIN SAVINGS $0 $49,806 $32,191 $49,806 $32,191
BANK.
833674 PALMER COLLEGE OF $0 $49,561 $2,646,080 $49,561 $2,646,080
CHIROPRACTIC WEST.
831476 BLACKHAWK CREDIT $0 $48,621 $2,852,743 $48,621 $2,852,743
UNION.
827767 YORK COUNTY FCU..... $0 $48,597 $2,033,468 $48,597 $2,033,468
834114 CARDINAL STRITCH $0 $48,537 $1,176,005 $48,537 $1,176,005
UNIVERSITY.
832163 CORNERSTONE $0 $48,409 $2,033,974 $48,409 $2,033,974
COMMUNITY FCU.
829929 IDEPENDENT ORDER OF $0 $48,318 $2,648,163 $48,318 $2,648,163
FORESTERS.
833099 WASHINGTON COMMUNITY $0 $48,165 $1,839,097 $48,165 $1,839,097
FCU.
831258 CITIZENSFIRST CREDIT $0 $47,288 $2,244,322 $47,288 $2,244,322
UNION.
831171 CO-OP CREDIT UNION.. $0 $47,288 $1,706,340 $47,288 $1,706,340
828917 HERITAGE VALLEY F C $0 $47,019 $1,911,775 $47,019 $1,911,775
U.
810643 FIRST HORIZON BANK.. $0 $46,844 $18,685 $46,844 $18,685
832955 KEYSTONE FCU........ $0 $46,634 $1,744,756 $46,634 $1,744,756
803348 CLS-NATIONAL CITY $0 $45,052 $45,933 $45,052 $45,933
BANK INDIANA.
832742 TRI BORO FCU........ $0 $44,698 $1,749,203 $44,698 $1,749,203
813285 UNION BK CA ELT $34,706 $9,793 $7,462 $44,499 $7,462
CHELA FUND I
(TEFFC).
824264 COMMONWEALTH ONE $0 $44,494 $1,727,685 $44,494 $1,727,685
FEDERAL CREDIT UNI.
803674 CLS-NATIONAL CITY $0 $44,426 $764,884 $44,426 $764,884
BANK INDIANA.
828898 JSTC EMPLOYEES FCU.. $0 $44,417 $1,728,204 $44,417 $1,728,204
809659 HONESDALE NATIONAL $0 $44,411 $2,524,595 $44,411 $2,524,595
BANK.
817440 FAMILY FIRST FEDERAL $0 $44,170 $1,976,595 $44,170 $1,976,595
CREDIT UNION.
805727 KATAHDIN FEDERAL $0 $43,975 $1,844,927 $43,975 $1,844,927
CREDIT UNION.
828853 UNITEDONE CU........ $0 $43,852 $1,865,285 $43,852 $1,865,285
805126 JEFF DAVIS BANK & $0 $43,839 $1,925,460 $43,839 $1,925,460
TRUST COMPANY.
810997 LAREDO NATIONAL BANK $0 $43,815 $2,298,370 $43,815 $2,298,370
823400 ARVEST BANK......... $0 $43,306 $0 $43,306 $0
833821 UNION BANK & TRUST $0 $42,758 $0 $42,758 $0
ELT HRB.
823181 OKLAHOMA CITY $0 $42,100 $42,100 $0
UNIVERSITY.
833643 TEXAS BANK.......... $0 $41,769 $1,977,498 $41,769 $1,977,498
826104 OZAUKEE BANK........ $0 $41,738 $2,339,851 $41,738 $2,339,851
826294 BATH SAVINGS $0 $41,663 $2,374,384 $41,663 $2,374,384
INSTITUTION.
832611 N F G #2 FCU........ $0 $41,358 $1,619,107 $41,358 $1,619,107
810981 FARMERS STATE BANK.. $0 $41,251 $1,729,478 $41,251 $1,729,478
833012 HORIZON FEDERAL $0 $41,052 $1,623,118 $41,052 $1,623,118
CREDIT UNION.
826584 CENTRAL CITY CREDIT $0 $41,026 $2,488,657 $41,026 $2,488,657
UNION.
833682 CLARION ONIZED $0 $40,545 $1,748,065 $40,545 $1,748,065
FEDERAL CREDIT
UNION.
833417 POLONIA BANK........ $0 $40,260 $2,077,592 $40,260 $2,077,592
833882 CITIZENS BANK C/O $0 $40,133 $2,365,054 $40,133 $2,365,054
EDUCATION FINANCE.
832615 LEHIGH VALLEY $0 $39,983 $2,380,874 $39,983 $2,380,874
EDUCATORS CU.
833840 EDUCATION CREDIT $0 $39,828 $2,083,470 $39,828 $2,083,470
UNION.
829340 MEMBERS CREDIT UNION $0 $39,665 $2,015,959 $39,665 $2,015,959
814142 MIDCOAST FEDERAL $0 $39,475 $1,446,081 $39,475 $1,446,081
CREDIT UNION.
832743 P & G MEHOOPANY $0 $39,399 $1,463,175 $39,399 $1,463,175
EMPLOYEES FCU.
832203 PARK VIEW FEDERAL $0 $39,146 $1,838,316 $39,146 $1,838,316
CREDIT UNION.
826191 FIRST NEW YORK FCU.. $0 $39,096 $1,524,536 $39,096 $1,524,536
827165 MATANUSKA VALLEY $0 $39,085 $2,213,234 $39,085 $2,213,234
FEDERAL CREDIT UNI.
834137 US BANK ELT $0 $39,020 $0 $39,020 $0
MEDINVEST LLC.
830544 MAINE HIGHLANDS FCU. $0 $38,883 $1,509,558 $38,883 $1,509,558
829246 SHORELINE CREDIT $0 $38,477 $1,698,445 $38,477 $1,698,445
UNION.
828564 MIDWEST AMERICA $0 $38,288 $0 $38,288 $0
FEDERAL CREDIT UNI.
828099 GLACIER HILLS CREDIT $0 $37,998 $1,684,608 $37,998 $1,684,608
UNION.
828535 STATE NATIONAL BANK. $0 $37,921 $1,860,294 $37,921 $1,860,294
833652 FIRST NATIONAL BANK $0 $37,674 $2,281,567 $37,674 $2,281,567
WICHITA FALLS.
810012 COMMUNITY BANKS NA.. $0 $37,633 $2,390,695 $37,633 $2,390,695
805734 ANDROSCOGGIN SVGS $0 $37,630 $16,496 $37,630 $16,496
BANK.
823864 HCSB................ $0 $37,588 $1,881,838 $37,588 $1,881,838
817545 GRANITE CREDIT UNION $0 $37,487 $1,545,184 $37,487 $1,545,184
807002 FIRST SECURITY BANK $0 $37,191 $1,445,686 $37,191 $1,445,686
OF BOZEMAN.
831488 FIRST TEXOMA NAT'L $0 $37,014 $1,425,482 $37,014 $1,425,482
BANK.
823936 HARVARD UNIVERSITY.. $0 $36,952 $3,564,694 $36,952 $3,564,694
833540 FIRSTBANK........... $0 $36,928 $1,793,620 $36,928 $1,793,620
834151 FOREST INST OF PROF $0 $36,532 $0 $36,532 $0
PSYCHOLOGY.
819539 FIRST FINANCIAL BANK $0 $36,444 $29,933 $36,444 $29,933
822908 US BANK NA.......... $0 $36,300 $2,182,583 $36,300 $2,182,583
834206 PACIFIC GRADUATE $0 $35,993 $117,049 $35,993 $117,049
SCHOOL OF PSYCHOLO.
813381 RIVERFRONT FCU...... $0 $35,788 $2,002,062 $35,788 $2,002,062
831576 LANDMARK BANK NA.... $0 $35,757 $1,606,322 $35,757 $1,606,322
812880 MERCER COUNTY STATE $0 $35,741 $2,021,941 $35,741 $2,021,941
BANK.
828303 M-C FEDERAL CREDIT $0 $35,728 $1,741,233 $35,728 $1,741,233
UNION.
810721 FIRSTBANK SOUTHWEST. $0 $35,597 $1,828,345 $35,597 $1,828,345
828478 ASSOCIATED BANK NA.. $0 $35,572 $2,224,382 $35,572 $2,224,382
810895 HERRING BANK........ $0 $35,421 $16,250 $35,421 $16,250
827597 COMMUNITY CREDIT $0 $35,320 $1,653,842 $35,320 $1,653,842
UNION.
821806 WASHINGTON STATE $0 $35,045 $1,840,699 $35,045 $1,840,699
EMPLOYEES CU.
823730 FREED-HARDEMAN $0 $34,988 $34,988 $0
UNIVERSITY.
807779 GHS FEDERAL CREDIT $0 $34,916 $1,434,962 $34,916 $1,434,962
UNION.
834100 ZIONS FNB ELT NELNET $0 $34,706 $123,341 $34,706 $123,341
ACADEMIC SVCS.
888887 SLM ECFC............ $0 $34,630 $2,605,673 $34,630 $2,605,673
812095 PARAGON FEDERAL $0 $34,471 $2,539,160 $34,471 $2,539,160
CREDIT UNION.
830791 JORDAN CREDIT UNION. $0 $34,453 $1,496,461 $34,453 $1,496,461
806757 BANK OF KIRKSVILLE.. $0 $34,345 $860,909 $34,345 $860,909
800305 REGIONS BANK........ $0 $33,989 $235,034 $33,989 $235,034
814096 ACHIEVA CREDIT UNION $0 $33,977 $1,838 $33,977 $1,838
826947 NATIONAL CITY BANK $0 $33,865 $1,965,898 $33,865 $1,965,898
MI-IL.
819514 FIRST UNITED BANK & $0 $33,746 $1,481,200 $33,746 $1,481,200
TRUST CO.
813373 PP&L G O L D CREDIT $0 $33,664 $1,161,214 $33,664 $1,161,214
UNION.
832883 K OF C FEDERAL $0 $33,439 $1,317,788 $33,439 $1,317,788
CREDIT UNION.
811959 NATIONAL EXCHANGE $0 $33,413 $1,640,696 $33,413 $1,640,696
BANK & TRUST.
831413 PARKER COMMUNITY $0 $33,288 $1,561,599 $33,288 $1,561,599
CREDIT UNION.
822239 COMPASS BANK........ $0 $33,204 $2,316,384 $33,204 $2,316,384
833309 ARMSTRONG BANK...... $0 $33,188 $0 $33,188 $0
815727 FIRST PREMIER BANK.. $0 $33,012 $1,529,118 $33,012 $1,529,118
828949 CBW SCHOOLS FEDERAL $0 $33,006 $1,401,793 $33,006 $1,401,793
CREDIT UNION.
828718 ALLIANCE BANK....... $0 $32,835 $1,721,547 $32,835 $1,721,547
829158 WEBER STATE FEDERAL $0 $32,716 $14,125 $32,716 $14,125
CREDIT UNION.
832729 BUTLER ARMCO $0 $32,679 $1,744,097 $32,679 $1,744,097
EMPLOYEES C U.
820174 DUPONT COMMUNITY CU. $0 $32,653 $1,895,232 $32,653 $1,895,232
824905 UNIVERSAL 1 CREDIT $0 $32,628 $1,500,009 $32,628 $1,500,009
UNION INC.
833938 FIFTH THIRD ELT $0 $32,504 $32,504 $0
EDUCATION FUNDING C.
827656 LANDMARK CREDIT $0 $32,263 $1,984,079 $32,263 $1,984,079
UNION.
833051 GREAT VALLEY SVNGS $0 $31,980 $1,158,496 $31,980 $1,158,496
BNK % FULTON BNK.
808426 FREMONT NATIONAL $0 $31,927 $2,632 $31,927 $2,632
BANK & TRUST CO.
834047 UNIVERSITY OF $0 $31,705 $31,705 $0
NORTHERN COLORADO.
804339 BALDWIN STATE BANK.. $0 $31,625 $31,625 $0
832943 FRANKLIN JOHNSTOWN $0 $31,581 $1,406,264 $31,581 $1,406,264
FCU.
812886 MUNCY BANK AND TRUST $0 $31,564 $1,967,673 $31,564 $1,967,673
COMPANY.
832286 ACMG FEDERAL CREDIT $0 $31,550 $1,063,183 $31,550 $1,063,183
UNION.
833953 UNION BANK ELT CHELA $0 $31,533 $3,681,110 $31,533 $3,681,110
EDUCATIONAL FU.
823021 PENN STATE FEDERAL $0 $31,510 $1,139,364 $31,510 $1,139,364
CREDIT UNION.
826492 CCSD FEDERAL CREDIT $0 $31,240 $1,948,948 $31,240 $1,948,948
UNION.
818590 JPMORGAN CHASE BANK $0 $31,175 $2,539,066 $31,175 $2,539,066
NA.
834212 CALIFORNIA BAPTIST $0 $31,129 $31,129 $0
UNIVERSITY.
831703 CO-OP CREDIT UNION $0 $31,058 $1,231,771 $31,058 $1,231,771
OF MONTEVIDEO.
831923 POINTBANK........... $0 $30,975 $1,530,261 $30,975 $1,530,261
820200 TOOELE FEDERAL $0 $30,860 $1,599,187 $30,860 $1,599,187
CREDIT UNION.
827610 STANFORD UNIVERSITY. $0 $30,787 $30,787 $0
823508 ST MARY'S UNIVERSITY $0 $30,663 $8,158 $30,663 $8,158
826185 NEW CUMBERLAND $0 $30,630 $1,184,811 $30,630 $1,184,811
FEDERAL CREDIT
UNION.
828911 PALCO FEDERAL CREDIT $0 $30,626 $1,362,075 $30,626 $1,362,075
UNION.
818596 METABANK............ $0 $30,601 $1,483,266 $30,601 $1,483,266
829414 HARBOR CREDIT UNION. $0 $30,528 $1,337,742 $30,528 $1,337,742
833489 ERIE GENERAL $0 $30,197 $1,813,558 $30,197 $1,813,558
ELECTRIC EMP FCU.
832086 GENESEE CO-OP $0 $30,020 $1,136,430 $30,020 $1,136,430
FEDERAL CREDIT
UNION.
832887 MARSHFIELD MEDICAL $0 $30,005 $1,165,850 $30,005 $1,165,850
CENTER CREDIT UN.
832201 GREAT RIVER FEDERAL $0 $29,966 $1,800,187 $29,966 $1,800,187
CREDIT UNION.
820393 TIER ONE BANK....... $0 $29,934 $24,063 $29,934 $24,063
810458 FIRST BANK & TRUST.. $0 $29,911 $0 $29,911 $0
828582 CROSS VALLEY FCU.... $0 $29,862 $1,724,511 $29,862 $1,724,511
824856 MID-KANSAS CREDIT $0 $29,641 $949,172 $29,641 $949,172
UNION.
834192 DEUTSCHE BANK ELT $0 $29,465 $3,018,525 $29,465 $3,018,525
STUDENT CAP CORP.
826986 VANTAGE CU.......... $0 $29,253 $1,114,244 $29,253 $1,114,244
812773 MOBILOIL FCU........ $0 $29,076 $1,499,754 $29,076 $1,499,754
828785 CREDIT UNION OF $0 $28,952 $1,392,911 $28,952 $1,392,911
DENVER.
816027 PARKVALE SAVINGS $0 $28,798 $9,832 $28,798 $9,832
ASSN.
805069 JPMORGAN CHASE BANK $0 $28,794 $0 $28,794 $0
NA.
806658 CLEVELAND STATE BANK $0 $28,725 $120,645 $28,725 $120,645
831156 ADVANTAGE CREDIT $0 $28,687 $1,395,023 $28,687 $1,395,023
UNION.
832948 PARKVIEW COMMUNITY $0 $28,650 $1,080,548 $28,650 $1,080,548
FCU.
810617 FIRST FARMERS & $0 $28,596 $1,174,334 $28,596 $1,174,334
MERCHANTS NA.
820280 BENCHMARK FEDERAL CU $0 $28,582 $1,296,006 $28,582 $1,296,006
828936 FREEDOM UNITED FCU.. $0 $28,544 $1,004,820 $28,544 $1,004,820
809110 CORNERSTONE BANK.... $0 $28,365 $1,316,719 $28,365 $1,316,719
828496 KENNEBEC SAVINGS $0 $28,140 $1,413,423 $28,140 $1,413,423
BANK.
812555 WELLS FARGO $0 $28,042 $799,412 $28,042 $799,412
EDUCATION FIN SVCS.
830336 MN VALLEY FEDERAL $0 $27,940 $1,089,340 $27,940 $1,089,340
CREDIT UNION.
827116 SLF OF IDAHO $20,190 $0 $7,671 $1,944,643 $27,861 $1,944,643
MARKETING ASSN INC.
811717 US BANK NA.......... $0 $27,639 $719,148 $27,639 $719,148
808316 HERITAGE BANK....... $0 $27,621 $1,162,163 $27,621 $1,162,163
834035 CITY BANK........... $0 $27,505 $51,533 $27,505 $51,533
834198 CHICAGO SCHOOL OF $0 $27,299 $8,645 $27,299 $8,645
PROF PSYCHOLOGY.
803463 JPMORGAN CHASE BANK $0 $27,066 $151,671 $27,066 $151,671
NA.
820808 CENTRIS FEDERAL $0 $27,057 $1,656,273 $27,057 $1,656,273
CREDIT UNION.
808260 FIRST NATIONAL BANK $0 $26,795 $1,040,804 $26,795 $1,040,804
& TRUST COMPANY.
833262 NAVIGATOR CREDIT $0 $26,757 $1,421,227 $26,757 $1,421,227
UNION.
825116 BELLCO FEDERAL $0 $26,744 $1,058,589 $26,744 $1,058,589
CREDIT UNION.
833501 WELLS FARGO BNK ELT $0 $26,734 $2,128,832 $26,734 $2,128,832
NHELP I INC.
832499 WINSLOW COMMUNITY $0 $26,658 $1,085,735 $26,658 $1,085,735
FCU.
804866 BANK MIDWEST N A.... $0 $26,643 $804,689 $26,643 $804,689
820181 BEST ADVANTAGE $0 $26,444 $1,246,652 $26,444 $1,246,652
CREDIT UNION.
834088 US BANK ELT BOSQUE $0 $26,260 $3,237,662 $26,260 $3,237,662
HEA INC.
830538 DANE COUNTY CREDIT $0 $25,873 $850,372 $25,873 $850,372
UNION.
823129 LISTERHILL CREDIT $0 $25,846 $1,790,801 $25,846 $1,790,801
UNION.
828025 AMERICAN FEDERAL $0 $25,827 $937,917 $25,827 $937,917
SAVINGS BANK.
832817 HOPEWELL JOINT $0 $25,826 $744,724 $25,826 $744,724
SCHOOL EMP FCU.
807197 FIRST INTERNATIONAL $0 $25,748 $1,264,243 $25,748 $1,264,243
BANK.
828997 ROCKY MOUNTAIN $0 $25,699 $1,039,848 $25,699 $1,039,848
CREDIT UNION.
806651 THE CITIZENS BANK OF $0 $25,649 $5,375 $25,649 $5,375
PHILADELPHIA.
822475 PEOPLES STATE BANK.. $0 $25,393 $0 $25,393 $0
830922 SHEBOYGAN AREA $0 $25,386 $991,714 $25,386 $991,714
CREDIT UNION.
809342 CB GROVE CITY FCU... $0 $25,189 $923,953 $25,189 $923,953
807744 ADIRONDACK TRUST $0 $25,118 $905,001 $25,118 $905,001
COMPANY.
829676 SERVU FCU........... $0 $25,070 $1,514,840 $25,070 $1,514,840
831520 GARDINER FCU........ $0 $25,006 $909,794 $25,006 $909,794
833302 BANK OF THE WEST.... $0 $24,955 $902,654 $24,955 $902,654
821013 FORT HOOD NATIONAL $0 $24,925 $1,557,917 $24,925 $1,557,917
BANK.
808972 ALVA STATE BANK & $0 $24,865 $900,057 $24,865 $900,057
TRUST CO.
828545 HOME FEDERAL SAVINGS $0 $24,750 $55,248 $24,750 $55,248
AND LOAN ASSOC.
833276 FRIONA STATE BANK... $0 $24,656 $1,095,599 $24,656 $1,095,599
828877 BERKS COMMUNITY FCU. $0 $24,653 $1,157,587 $24,653 $1,157,587
829088 N.E.W. CREDIT UNION. $0 $24,443 $1,042,301 $24,443 $1,042,301
821449 HAGERSTOWN TRUST $0 $24,282 $852,776 $24,282 $852,776
COMPANY.
832724 PITTSBURGH CENTRAL $0 $24,257 $752,918 $24,257 $752,918
FCU.
828090 FIRST NAT'L BANK OF $0 $24,246 $1,351,974 $24,246 $1,351,974
PALMERTON.
832241 SALT LAKE CITY CU... $0 $24,134 $1,275,179 $24,134 $1,275,179
823065 CREIGHTON UNIVERSITY $0 $23,924 $13,500 $23,924 $13,500
826319 BVA FEDERAL CREDIT $0 $23,900 $1,067,506 $23,900 $1,067,506
UNION.
832262 NEWPORT NEWS $0 $23,779 $1,258,057 $23,779 $1,258,057
SHIPBUILDING ECU.
829174 CALIFORNIA BANK & $0 $23,756 $247,329 $23,756 $247,329
TRUST C/O ZIONS B.
824983 CINFED EMPLOYEES $0 $23,694 $1,511,175 $23,694 $1,511,175
FEDERAL CREDIT UNI.
834161 PHILIPS GRADUATE $0 $23,666 $23,666 $0
INSTITUTE.
821973 FIVE COUNTY CREDIT $0 $23,591 $975,508 $23,591 $975,508
UNION.
833189 BANK OF ARKANSAS NA. $0 $23,482 $1,005,453 $23,482 $1,005,453
832722 JESSOP EMPLOYEES FCU $0 $23,297 $725,246 $23,297 $725,246
832916 UFCW FCU............ $0 $23,177 $23,177 $0
819105 CITIZENS BANK OF $0 $23,138 $1,433,818 $23,138 $1,433,818
MUKWONAGO.
806952 FARMERS STATE BANK.. $0 $22,923 $959,175 $22,923 $959,175
830332 RIVERWOOD MARITIME $0 $22,919 $1,057,356 $22,919 $1,057,356
CU.
809087 CITIZENS SECURITY $0 $22,916 $926,609 $22,916 $926,609
BANK & TRUST CO.
830100 UNITED EDUCATORS $0 $22,801 $819,252 $22,801 $819,252
CREDIT UNION.
803538 JPMORGAN CHASE BANK $0 $22,553 $18,500 $22,553 $18,500
NA.
818505 BANK OF PRAIRIE DU $0 $22,473 $1,211,064 $22,473 $1,211,064
SAC.
807838 BANK OF NEW YORK.... $0 $22,286 $0 $22,286 $0
834190 LOYOLA UNIVERSITY... $0 $22,212 $22,212 $0
819253 SUPERIOR CHOICE $0 $22,141 $1,052,959 $22,141 $1,052,959
CREDIT UNION.
830510 FIRST ALLIANCE $0 $21,958 $762,093 $21,958 $762,093
CREDIT UNION.
809547 FIRST NATL BK PORT $0 $21,918 $1,366,808 $21,918 $1,366,808
ALLEGANY.
827096 FIRST NATIONAL $0 $21,882 $1,064,162 $21,882 $1,064,162
COMMUNITY BANK.
828338 FORT COMMUNITY $0 $21,879 $990,372 $21,879 $990,372
CREDIT UNION.
816228 ROBINS FEDERAL $0 $21,777 $1,096,680 $21,777 $1,096,680
CREDIT UNION.
822366 PINNACLE BANK OF $0 $21,698 $3,338 $21,698 $3,338
PAPILLION.
831394 OAKDALE CREDIT UNION $0 $21,515 $937,522 $21,515 $937,522
821497 AMERICAN PRIDE $0 $21,410 $978,611 $21,410 $978,611
CREDIT UNION.
828082 WESTERN COOPERATIVE $0 $21,390 $1,162,753 $21,390 $1,162,753
CREDIT UNION.
813853 FIRST NATIONAL BANK $0 $21,386 $1,221,471 $21,386 $1,221,471
OF HUDSON.
833058 MEADVILLE AREA FCU.. $0 $21,341 $1,023,437 $21,341 $1,023,437
831269 JP MORGAN CHASE BANK $0 $21,300 $33,041 $21,300 $33,041
827751 BADGER GLOBE CREDIT $0 $21,117 $855,334 $21,117 $855,334
UNION.
806959 ROCKY MOUNTAIN BANK. $0 $21,111 $1,017,047 $21,111 $1,017,047
832823 FRICK TRI COUNTY FCU $0 $21,070 $735,849 $21,070 $735,849
830935 ACADIA FCU.......... $0 $21,048 $1,232,773 $21,048 $1,232,773
832202 CITIZENS COMMUNITY $0 $20,969 $971,029 $20,969 $971,029
CU.
831870 CITIZENS BANK OF $0 $20,953 $1,844 $20,953 $1,844
EDMOND.
828956 WEST PENN PNP FCU... $0 $20,904 $855,561 $20,904 $855,561
832124 ASSOCIATED SCHOOL $0 $20,784 $814,387 $20,784 $814,387
EMPLOYEES CREDIT.
827145 MID AMERICA BANK FSB $0 $20,752 $86,247 $20,752 $86,247
833646 FIRST FINANCIAL OF S $0 $20,722 $816,951 $20,722 $816,951
ARKANSAS.
828463 MARQUETTE SAVINGS $0 $20,695 $1,157,800 $20,695 $1,157,800
ASSOCIATION.
832675 ERIE TIMES EMPLOYEES $0 $20,504 $636,022 $20,504 $636,022
FCU.
832540 TRUMARK FINANCIAL CU $0 $20,493 $1,273,821 $20,493 $1,273,821
828227 CONCHO EDUCATORS $0 $20,463 $898,061 $20,463 $898,061
FEDERAL CREDIT UN.
820680 RANDOLPH-BROOKS $0 $20,422 $0 $20,422 $0
FEDERAL CREDIT UNIO.
827567 FIRST STATE BANK $0 $20,412 $738,267 $20,412 $738,267
KEENE INC.
828855 EVERGREEN CREDIT $0 $20,349 $844,821 $20,349 $844,821
UNION.
834134 US BANK ELT XAVIER $0 $20,347 $0 $20,347 $0
UNIVERSITY.
809420 COUNTY NATIONAL BANK $0 $20,287 $108,291 $20,287 $108,291
825602 RIPCO CREDIT UNION.. $0 $20,239 $902,369 $20,239 $902,369
821921 NORWIN TEACHERS $0 $20,237 $807,699 $20,237 $807,699
FEDERAL CREDIT UN.
832617 CLARION UNIVERSITY $0 $20,214 $819,905 $20,214 $819,905
FCU.
817895 MONTANA FEDERAL $0 $20,103 $686,971 $20,103 $686,971
CREDIT UNION.
805725 CPORT CU............ $0 $19,973 $1,265,728 $19,973 $1,265,728
821362 TEXAS DOW EMPLOYEES $0 $19,902 $587,437 $19,902 $587,437
CREDIT UNION.
833359 BCM FEDERAL CREDIT $0 $19,883 $714,057 $19,883 $714,057
UNION.
805815 WINTHROP AREA FCU... $0 $19,680 $703,486 $19,680 $703,486
807857 ESL FEDERAL CREDIT $0 $19,661 $1,637,311 $19,661 $1,637,311
UNION.
833093 BANK OF NY ELT $0 $19,412 $1,531,443 $19,412 $1,531,443
COLLEGEINVEST.
827967 CHARTWAY FEDERAL C U $0 $19,117 $1,183,428 $19,117 $1,183,428
810532 SIOUX FALLS FEDERAL $0 $19,091 $903,135 $19,091 $903,135
CREDIT UNION.
809322 AUTO WORKERS FEDERAL $0 $19,079 $1,160,446 $19,079 $1,160,446
CREDIT UNION.
815901 EVANSVILLE TEACHERS $0 $19,054 $688,337 $19,054 $688,337
FCU.
804575 COMMERCIAL FEDERAL $0 $19,050 $19,050 $0
BANK.
831946 CAPITAL ONE NA...... $0 $19,045 $1,286,152 $19,045 $1,286,152
815994 MEMBERS ALLIANCE $0 $18,946 $754,334 $18,946 $754,334
CREDIT UNION.
833077 TCF NATIONAL BANK... $0 $18,889 $24,100 $18,889 $24,100
831484 UNION BANK & TRUST-- $0 $18,853 $1,019,432 $18,853 $1,019,432
IHELP.
831552 KEY BANK NA......... $0 $18,853 $3,986,596 $18,853 $3,986,596
829260 FIRST SOURCE FCU.... $0 $18,821 $894,772 $18,821 $894,772
814671 STATEWIDE FEDERAL $0 $18,784 $726,684 $18,784 $726,684
CREDIT UNION.
808170 SIDNEY FEDERAL $0 $18,767 $968,815 $18,767 $968,815
CREDIT UNION.
823417 CINCO FAMILY FCU.... $0 $18,654 $881,510 $18,654 $881,510
833324 WEST TEXAS NATIONAL $0 $18,564 $918,454 $18,564 $918,454
BANK.
833258 AMERICAN NATIONAL $0 $18,555 $988,659 $18,555 $988,659
BANK.
830772 STANFORD FCU........ $0 $18,389 $72,612 $18,389 $72,612
833034 FIRST FINANCIAL $0 $18,360 $937,801 $18,360 $937,801
COMMUNITY CU.
833084 METRO CREDIT UNION.. $0 $18,333 $698,237 $18,333 $698,237
811881 FARMERS & MERCHANTS $0 $18,323 $1,036,415 $18,323 $1,036,415
BANK OF TOMAH.
819191 RAINBOW FCU......... $0 $18,315 $1,102,250 $18,315 $1,102,250
813421 NEXTIER BANK........ $0 $18,179 $14,450 $18,179 $14,450
815951 MILLS COUNTY STATE $0 $18,082 $879,136 $18,082 $879,136
BANK.
812155 FIRST BETHANY BANK.. $0 $18,061 $392,962 $18,061 $392,962
832486 ENTRUST FEDERAL $0 $18,057 $750,519 $18,057 $750,519
CREDIT UNION.
831722 TOWN NORTH NATIONAL $0 $18,001 $727,977 $18,001 $727,977
BANK.
811613 KITSAP BANK......... $0 $17,995 $1,078,980 $17,995 $1,078,980
828715 LA-TEC CREDIT UNION. $0 $17,975 $1,164,399 $17,975 $1,164,399
830267 MIDWEST COMMUNITY $0 $17,961 $838,989 $17,961 $838,989
FCU.
808995 FARMERS & MERCHANTS $0 $17,889 $755,848 $17,889 $755,848
BANK & TRUST CO.
819967 SEAWAY NATIONAL BANK $0 $17,772 $1,041,034 $17,772 $1,041,034
823116 KEARNEY FEDERAL $0 $17,657 $970,447 $17,657 $970,447
CREDIT UNION.
808028 ASTORIA FEDERAL $0 $17,500 $14,306 $17,500 $14,306
SAVINGS.
832101 CHOICE 1 FEDERAL $0 $17,499 $961,794 $17,499 $961,794
CREDIT UNION.
832992 IBEW LOCAL UNION 712 $0 $17,486 $676,716 $17,486 $676,716
FCU.
830130 BEAR PAW CREDIT $0 $17,404 $850,677 $17,404 $850,677
UNION.
809025 FIRST NATIONAL BANK $0 $17,226 $793,039 $17,226 $793,039
& TRUST CO OF M.
830809 CAPITAL CREDIT UNION $0 $17,206 $915,819 $17,206 $915,819
830957 TAYLOR CREDIT UNION. $0 $17,183 $692,349 $17,183 $692,349
833562 PRICE CREDIT UNION.. $0 $17,110 $645,842 $17,110 $645,842
818690 BLAIR COUNTY FEDERAL $0 $17,106 $1,043,520 $17,106 $1,043,520
CREDIT UNION.
833596 MARATHON COUNTY EMP $0 $16,984 $533,418 $16,984 $533,418
CU.
832318 DAKOTA WEST CREDIT $0 $16,949 $763,396 $16,949 $763,396
UNION.
833316 LUTHERAN CREDIT $0 $16,936 $495,256 $16,936 $495,256
UNION OF AMERICA.
827908 NORTHWEST FEDERAL $0 $16,855 $912,357 $16,855 $912,357
CREDIT UNION.
832415 FREMONT FEDERAL $0 $16,853 $1,058,024 $16,853 $1,058,024
CREDIT UNION.
826423 NORTHSTAR BANK OF $0 $16,834 $882,340 $16,834 $882,340
TEXAS.
833114 WINNEBAGO COMMUNITY $0 $16,812 $670,282 $16,812 $670,282
CU.
809097 FIRST NATIONAL BANK. $0 $16,754 $0 $16,754 $0
833273 DELAWARE NATIONAL $0 $16,746 $615,109 $16,746 $615,109
BANK/FULTON BANK.
833318 FORT DAVIS STATE $0 $16,733 $874,972 $16,733 $874,972
BANK.
805090 CAPITAL ONE NA...... $0 $16,725 $0 $16,725 $0
808732 JPMORGAN CHASE BANK $0 $16,722 $1,345,272 $16,722 $1,345,272
NA.
807306 UNION STATE BANK.... $0 $16,662 $855,245 $16,662 $855,245
833602 WHEATLAND FEDERAL $0 $16,581 $543,354 $16,581 $543,354
CREDIT UNION.
832746 YOUR CHOICE FCU..... $0 $16,571 $762,040 $16,571 $762,040
820593 FIRST NATIONAL BANK $0 $16,564 $1,106,875 $16,564 $1,106,875
OF BROWNFIELD.
832861 BUFFALO POSTAL $0 $16,546 $710,308 $16,546 $710,308
COMMUNITY FCU.
828200 M H E S A C......... $4,992 $522,781 $11,541 $0 $16,533 $522,781
829064 SOUTHWEST STUDENT $16,503 $521,059 $0 $16,503 $521,059
SERV TRUST WFB EL.
812205 LASALLE BANK NA..... $0 $16,500 $3,313 $16,500 $3,313
830241 CHRISTIAN COMMUNITY $0 $16,430 $694,019 $16,430 $694,019
CREDIT UNION.
823099 WESBANCO WHEELING... $0 $16,347 $589,871 $16,347 $589,871
828909 MIFFLIN COUNTY $0 $16,303 $783,434 $16,303 $783,434
SAVINGS BANK.
832959 WAUWATOSA CREDIT $0 $16,228 $637,808 $16,228 $637,808
UNION.
825240 YS FCU.............. $0 $16,197 $657,001 $16,197 $657,001
832438 WESTAR FEDERAL $0 $16,153 $546,867 $16,153 $546,867
CREDIT UNION.
832035 US BANK NA.......... $0 $16,146 $503,679 $16,146 $503,679
807968 GLENS FALLS NATIONAL $0 $16,145 $1,917 $16,145 $1,917
BANK & TRUST.
818819 FIRST SECURITY BANK. $0 $16,138 $694,585 $16,138 $694,585
828841 CITIZENS AND $0 $16,118 $153,207 $16,118 $153,207
NORTHERN BANK.
806958 FIRST NATIONAL BANK $0 $16,098 $715,360 $16,098 $715,360
OF MONTANA.
813517 FIRST FEDERAL $0 $16,075 $228,909 $16,075 $228,909
SAVINGS BANK.
833927 A+ FEDERAL CREDIT $0 $16,005 $976,139 $16,005 $976,139
UNION.
829489 ZIONS FNB ELT NAT'L $0 $15,832 $28,180 $15,832 $28,180
ED LOANS NETWOR.
810454 FIRST DAKOTA $0 $15,770 $0 $15,770 $0
NATIONAL BANK.
832950 MARATHON ROTHSCHILD $0 $15,740 $547,377 $15,740 $547,377
CU.
822206 NATIONAL BANK & $0 $15,739 $4,349 $15,739 $4,349
TRUST OF SYCAMORE.
827623 PROSPERA CREDIT $0 $15,669 $683,141 $15,669 $683,141
UNION.
828479 DAIRYLAND POWER $0 $15,665 $524,443 $15,665 $524,443
CREDIT UNION.
818130 THE RIVERBANK....... $0 $15,657 $993,685 $15,657 $993,685
824305 HORIZONS FEDERAL $0 $15,655 $593,217 $15,655 $593,217
CREDIT UNION.
832760 ST PIUS TENTH CHURCH $0 $15,531 $535,232 $15,531 $535,232
FCU.
832768 EDUCATIONAL $0 $15,523 $952,090 $15,523 $952,090
EMPLOYEES CU.
823888 FIRST LIBERTY $0 $15,497 $694,542 $15,497 $694,542
FEDERAL CREDIT
UNION.
833146 GOLDEN RULE $0 $15,417 $778,502 $15,417 $778,502
COMMUNITY CREDIT
UNION.
819515 CASCADE CENTRAL $0 $15,415 $356,056 $15,415 $356,056
CREDIT UNION.
833893 PROVINCIAL BANK $0 $15,367 $2,377,871 $15,367 $2,377,871
ACADEMIC FUNDING GR.
810785 LEGEND BANK......... $0 $15,338 $788,892 $15,338 $788,892
834027 AMERICAN AIRLINES $0 $15,332 $713,741 $15,332 $713,741
FCU.
825641 FARMERS BANK OF COOK $0 $15,217 $663,924 $15,217 $663,924
823761 BULLS EYE CU........ $0 $15,215 $788,776 $15,215 $788,776
804456 EMPORIA STATE BANK & $0 $15,212 $448 $15,212 $448
TRUST CO.
822312 TEXANS CU........... $0 $15,210 $683,390 $15,210 $683,390
809027 FIRST NATIONAL BANK. $0 $15,202 $534,400 $15,202 $534,400
828812 FORWARD FINANCIAL CU $0 $15,202 $762,492 $15,202 $762,492
828366 COMMUNITY CREDIT $0 $15,096 $630,202 $15,096 $630,202
UNION.
805809 STE CROIX REGIONAL $0 $15,078 $728,340 $15,078 $728,340
FCU.
827619 NE PA COMMUNITY $0 $14,899 $623,180 $14,899 $623,180
FEDERAL CREDIT UN.
813376 COPPER AND GLASS FCU $0 $14,895 $480,134 $14,895 $480,134
830511 CAPITOL FEDERAL S&L $0 $14,764 $3,312 $14,764 $3,312
ASSC.
832842 TOWER CREDIT UNION.. $0 $14,743 $524,634 $14,743 $524,634
832407 BUFFALO METROPOLITAN $0 $14,654 $613,974 $14,654 $613,974
FCU.
827616 TOMAH AREA CREDIT $0 $14,650 $969,373 $14,650 $969,373
UNION.
811884 FARMERS & MERCHANTS $0 $14,640 $604,787 $14,640 $604,787
UNION BANK.
829928 AFFINITY PLUS CREDIT $0 $14,593 $668,361 $14,593 $668,361
UNION.
818869 BANK OF ELMWOOD..... $0 $14,563 $885,945 $14,563 $885,945
818128 OOSTBURG STATE BANK. $0 $14,543 $848,084 $14,543 $848,084
829512 GPO FEDERAL CREDIT $0 $14,430 $657,001 $14,430 $657,001
UNION.
831652 THE BANKERS BANK.... $0 $14,399 $542,396 $14,399 $542,396
833132 IRVIN WORKS FCU..... $0 $14,387 $532,470 $14,387 $532,470
833460 OKLAHOMA EMPLOYEES $0 $14,375 $368,753 $14,375 $368,753
CREDIT UNION.
833902 PACIFIC COLLEGE OF $0 $14,373 $14,373 $0
ORIENTAL MEDICIN.
829800 HIGHMARK FEDERAL $0 $14,344 $628,286 $14,344 $628,286
CREDIT UNION.
818085 JACKSON COUNTY BANK. $0 $14,263 $819,378 $14,263 $819,378
832390 ADDISON AVENUE FCU.. $0 $14,246 $599,946 $14,246 $599,946
822553 AMERICAN BANK....... $0 $14,213 $679,473 $14,213 $679,473
832807 SUNMARK FEDERAL $0 $14,096 $965,331 $14,096 $965,331
CREDIT UNION.
810432 DACOTAH BANK........ $0 $14,091 $6,625 $14,091 $6,625
821154 PHELPS COUNTY BANK.. $0 $14,086 $551,101 $14,086 $551,101
809100 COPPERMARK BANK..... $0 $14,060 $487,592 $14,060 $487,592
802759 OAK BROOK BANK...... $0 $14,045 $901,359 $14,045 $901,359
824047 A-K VALLEY FEDERAL $0 $14,032 $899,133 $14,032 $899,133
CREDIT UNION.
834033 FORT SILL FCU....... $0 $14,028 $776,198 $14,028 $776,198
832487 ONTARIO SHORES $0 $14,012 $540,371 $14,012 $540,371
FEDERAL CREDIT
UNION.
833463 HEMPFIELD AREA FCU.. $0 $13,999 $398,027 $13,999 $398,027
823827 HEARTLAND CREDIT $0 $13,997 $40,034 $13,997 $40,034
UNION.
813471 HANSCOM FEDERAL $0 $13,996 $884,401 $13,996 $884,401
CREDIT UNION.
828555 EDUCATORS CREDIT $0 $13,986 $893,931 $13,986 $893,931
UNION.
832727 UNIV OF SOUTHERN $0 $13,972 $789,341 $13,972 $789,341
MISS CU.
833352 COMMUNITY BANK-- $0 $13,959 $13,959 $0
MISSOULA INC.
832676 MERIT FEDERAL CREDIT $0 $13,931 $0 $13,931 $0
UNION.
815854 JP MORGAN CHASE BANK $0 $13,798 $0 $13,798 $0
828837 WEST-AIRCOMM FCU.... $0 $13,794 $986,452 $13,794 $986,452
822234 ALTOONA VA HOSPITAL $0 $13,780 $547,664 $13,780 $547,664
FCU.
832848 NORTH DAKOTA AIR $0 $13,697 $475,557 $13,697 $475,557
NATIONAL GUARD CU.
811958 NATIONAL BANK OF $0 $13,673 $934,162 $13,673 $934,162
WAUPUN.
810436 GREAT WESTERN BANK.. $0 $13,665 $14,999 $13,665 $14,999
828546 LIFETIME CREDIT $0 $13,522 $544,327 $13,522 $544,327
UNION.
813476 MASSBANK............ $0 $13,510 $672,772 $13,510 $672,772
819855 SOUTHPOINT FEDERAL $0 $13,506 $671,993 $13,506 $671,993
CREDIT UNION.
832105 NIAGARA COUNTY FCU.. $0 $13,471 $596,774 $13,471 $596,774
818089 DENMARK STATE BANK.. $0 $13,452 $639,884 $13,452 $639,884
827531 GREAT FALLS TEACHERS $0 $13,408 $624,041 $13,408 $624,041
FEDERAL CU.
833633 BROKAW CREDIT UNION. $0 $13,383 $706,315 $13,383 $706,315
824824 NORTH MILWAUKEE $0 $13,369 $839,504 $13,369 $839,504
STATE BANK.
816177 HERITAGEBANK OF THE $0 $13,358 $791,861 $13,358 $791,861
SOUTH.
810798 INTERNATIONAL BANK $0 $13,336 $617,795 $13,336 $617,795
OF COMMERCE-EAGL.
832648 FIRST CAPITAL CREDIT $0 $13,331 $548,304 $13,331 $548,304
UNION.
826495 CORNERSTONE FCU..... $0 $13,319 $402,036 $13,319 $402,036
833167 GOVERNMENTAL $0 $13,268 $585,049 $13,268 $585,049
EMPLOYEES CU.
821925 FOX VALLEY SAVINGS $0 $13,256 $718,786 $13,256 $718,786
BANK.
832718 N B A CREDIT UNION.. $0 $13,199 $471,101 $13,199 $471,101
808923 NATIONAL CITY BANK.. $0 $13,157 $37,734 $13,157 $37,734
832711 CATHOLIC FAMILY FCU. $0 $13,122 $389,400 $13,122 $389,400
833931 EAST CENTRAL CU..... $0 $13,106 $13,106 $0
828714 FIRST AMERICAN $0 $13,093 $630,916 $13,093 $630,916
CREDIT UNION.
821916 KEYSTONE UNITED $0 $13,067 $692,585 $13,067 $692,585
METHODIST FCU.
831848 KEY BANK NA......... $0 $12,998 $4,372 $12,998 $4,372
817284 EDCO COMMUNITY $0 $12,954 $699,765 $12,954 $699,765
CREDIT UNION.
817551 CAMERON STATE BANK.. $0 $12,921 $0 $12,921 $0
828906 P G &W EMPLOYEES F C $0 $12,916 $602,838 $12,916 $602,838
U.
805782 NEW DIMENSIONS FCU.. $0 $12,730 $513,146 $12,730 $513,146
823343 FIRST BANK FINANCIAL $0 $12,729 $807,068 $12,729 $807,068
CENTER.
824714 TCF NATIONAL BANK... $0 $12,719 $1,183,815 $12,719 $1,183,815
822814 MON VALLEY COMMUNITY $0 $12,702 $657,034 $12,702 $657,034
FEDERAL CREDIT.
813916 SECURITY STATE BANK $0 $12,660 $475,583 $12,660 $475,583
& TRUST.
832290 TRUWEST CU.......... $0 $12,556 $634,326 $12,556 $634,326
801894 WELLS FARGO $0 $12,553 $893,589 $12,553 $893,589
EDUCATION FIN SVCS.
830999 INDIANHEAD CREDIT $0 $12,514 $477,487 $12,514 $477,487
UNION.
823384 COASTAL COMMUNITY & $0 $12,486 $0 $12,486 $0
TEACHERS CU.
819526 WESTERN STATE BANK.. $0 $12,469 $621,279 $12,469 $621,279
828768 EAGLE BK & TRUST CO $0 $12,421 $521,175 $12,421 $521,175
OF JEFF CO.
830924 PEOPLES CHOICE $0 $12,356 $440,758 $12,356 $440,758
CREDIT UNION.
821067 MECHANICS SAVINGS $0 $12,354 $825,557 $12,354 $825,557
BANK.
816026 AEDC FEDERAL CREDIT $0 $12,334 $796,647 $12,334 $796,647
UNION.
833805 REDSTONE FCU........ $0 $12,268 $2,626 $12,268 $2,626
822480 SKY BANK............ $0 $12,245 $722,286 $12,245 $722,286
825633 UNITED PRAIRIE BANK- $0 $12,205 $630,948 $12,205 $630,948
SLAYTON.
817409 MONROE COUNTY $0 $12,161 $770,903 $12,161 $770,903
COMMUNITY CREDIT
UNIO.
823247 BFG FEDERAL CREDIT $0 $12,083 $407,329 $12,083 $407,329
UNION.
832650 AMERICHOICE FCU..... $0 $12,034 $648,173 $12,034 $648,173
806778 CABOOL STATE BANK... $0 $12,019 $428,993 $12,019 $428,993
812355 TELCO TRIAD CREDIT $0 $12,000 $662,958 $12,000 $662,958
UNION.
832630 OUR COMMUNITY CREDIT $0 $11,979 $611,476 $11,979 $611,476
UNION.
828948 1ST CHOICE COMMUNITY $0 $11,881 $676,006 $11,881 $676,006
FCU.
818219 AMERICAN BANK & $0 $11,870 $749,996 $11,870 $749,996
TRUST WISCONSIN.
809231 FIRST TECHNOLOGY $0 $11,839 $562,996 $11,839 $562,996
CREDIT UNION.
827117 RICHLAND COUNTY BANK $0 $11,825 $748,104 $11,825 $748,104
833169 FIRST WESTERN BANK $0 $11,812 $0 $11,812 $0
OF STURGIS.
827196 STATE DEPARTMENT FCU $0 $11,807 $1,169,961 $11,807 $1,169,961
830547 CLS-NATIONAL CITY $0 $11,805 $48,375 $11,805 $48,375
BANK OF PA.
828887 FIRST COMMONWEALTH $0 $11,696 $616,992 $11,696 $616,992
FCU.
810226 VANTAGE TRUST FCU... $0 $11,691 $621,030 $11,691 $621,030
832404 ALCO FEDERAL CREDIT $0 $11,685 $561,269 $11,685 $561,269
UNION.
833866 FIFTH THIRD ELT EIC. $0 $11,678 $0 $11,678 $0
810995 1ST NAT'L BANK OF $0 $11,662 $39,829 $11,662 $39,829
CANADIAN.
832275 UNIVERSITY OF $0 $11,656 $800,292 $11,656 $800,292
MICHIGAN CU.
832626 LANCASTER RED ROSE $0 $11,618 $365,508 $11,618 $365,508
CU.
828876 SCIENCE PARK $0 $11,598 $683,122 $11,598 $683,122
EMPLOYEES C U.
832000 UMB BANK............ $0 $11,589 $321,826 $11,589 $321,826
828477 VANTAGE WEST CREDIT $0 $11,555 $152,215 $11,555 $152,215
UNION.
813317 MAX FEDERAL CREDIT $0 $11,535 $914,163 $11,535 $914,163
UNION.
826585 STATE CENTRAL CREDIT $0 $11,530 $575,446 $11,530 $575,446
UNION.
832090 DALE EMPLOYEES $0 $11,526 $432,767 $11,526 $432,767
CREDIT UNION.
810479 FIRST STATE BANK.... $0 $11,486 $588,803 $11,486 $588,803
832816 Y T W FEDERAL CREDIT $0 $11,471 $402,612 $11,471 $402,612
UNION.
808441 HASTINGS STATE BANK. $0 $11,462 $2,062 $11,462 $2,062
833038 MEMBERS CHOICE $0 $11,416 $403,254 $11,416 $403,254
CREDIT UNION.
805152 PEOPLES STATE BANK.. $0 $11,407 $0 $11,407 $0
831897 TRI-COUNTY CREDIT $0 $11,384 $442,115 $11,384 $442,115
UNION.
832116 FIREFIGHTERS $0 $11,342 $552,994 $11,342 $552,994
COMMUNITY CU.
833306 MINNCO CREDIT UNION. $0 $11,329 $549,471 $11,329 $549,471
833595 NORTHWOODS COMMUNITY $0 $11,327 $580,143 $11,327 $580,143
CU.
817517 CENTRA CREDIT UNION. $0 $11,321 $399,460 $11,321 $399,460
824411 HURON AREA EDUCATION $0 $11,315 $413,882 $11,315 $413,882
FEDERAL CREDIT.
820231 FIRST NATIONAL BANK $0 $11,299 $605,291 $11,299 $605,291
AT DARLINGTON.
827708 US BANK NA.......... $0 $11,156 $366,196 $11,156 $366,196
832292 UNITED CREDIT UNION. $0 $11,143 $501,102 $11,143 $501,102
833609 CLASS ACT FCU....... $0 $11,133 $602,696 $11,133 $602,696
816480 GEORGIA TELCO CREDIT $0 $11,117 $594,665 $11,117 $594,665
UNION.
825153 RIVER VALLEY CREDIT $0 $11,092 $468,646 $11,092 $468,646
UNION.
832838 CACL FEDERAL CREDIT $0 $11,077 $11,077 $0
UNION.
832627 MINNESOTA POWER $0 $11,074 $478,116 $11,074 $478,116
EMPLOYEES CREDIT UN.
808335 NEBRASKA ENERGY FCU. $0 $10,990 $506,622 $10,990 $506,622
832705 NESC FEDERAL CREDIT $0 $10,938 $407,290 $10,938 $407,290
UNION.
832803 TRI-STATE FCU....... $0 $10,901 $631,594 $10,901 $631,594
828580 GREAT MIDWEST BANK $10,871 $579,605 $10,871 $579,605
S.S.B$0.
830845 UNO FEDERAL CREDIT $0 $10,839 $12,274 $10,839 $12,274
UNION.
831595 CUDAHY- SOUTHSHORE $0 $10,816 $357,331 $10,816 $357,331
CU.
832264 WESTERN DIVISION FCU $0 $10,777 $719,934 $10,777 $719,934
832063 UNIVERSITY OF $0 $10,774 $458,672 $10,774 $458,672
NEBRASKA FEDERAL CU.
834186 SOUTHERN CALIF INST $0 $10,743 $0 $10,743 $0
OF ARCH.
824608 WACHOVIA BANK NA.... $0 $10,721 $596,829 $10,721 $596,829
832561 NIAGARA'S CHOICE FCU $0 $10,715 $430,163 $10,715 $430,163
833095 FALCON NATIONAL BANK $0 $10,696 $663,303 $10,696 $663,303
829911 PCM EMPLOYEES CU.... $0 $10,652 $514,644 $10,652 $514,644
831875 AVANTA FEDERAL $0 $10,583 $468,978 $10,583 $468,978
CREDIT UNION.
832582 SUN FEDERAL CREDIT $0 $10,561 $578,595 $10,561 $578,595
UNION.
820888 BANK OF BRODHEAD.... $0 $10,490 $639,729 $10,490 $639,729
827104 EQUITABLE BANK SSB.. $0 $10,471 $546,383 $10,471 $546,383
822440 BAY SHORE CREDIT $0 $10,467 $622,106 $10,467 $622,106
UNION.
803609 OLD NATIONAL BANK... $0 $10,450 $81,725 $10,450 $81,725
829951 ABERDEEN FEDERAL $0 $10,444 $464,501 $10,444 $464,501
CREDIT UNION.
832234 WHITEFISH CREDIT $0 $10,408 $409,907 $10,408 $409,907
UNION.
833204 ONPOINT COMMUNITY CU $0 $10,321 $537,242 $10,321 $537,242
813419 PEOPLESBANK A $0 $10,248 $405,577 $10,248 $405,577
CODORUS VALLEY
COMPAN.
829795 EMORY FEDERAL CREDIT $0 $10,121 $300,632 $10,121 $300,632
UNION.
817804 MCDOWELL COUNTY $0 $10,117 $638,563 $10,117 $638,563
NATIONAL BANK.
822928 FRANKLIN SAVINGS AND $0 $10,106 $552,893 $10,106 $552,893
LOAN COMPANY.
810536 STATE BANK OF $0 $10,096 $456,061 $10,096 $456,061
ALCESTER.
826408 CORTRUST BANK....... $0 $10,087 $3,408 $10,087 $3,408
829299 WEA CREDIT UNION.... $0 $10,028 $456,288 $10,028 $456,288
833047 CORRY JAMESTOWN $0 $9,969 $391,006 $9,969 $391,006
CREDIT UNION.
827468 BANK OF WASHINGTON.. $0 $9,943 $403,158 $9,943 $403,158
822022 CORNHUSKER BANK..... $0 $9,939 $5,132 $9,939 $5,132
833625 HEARTLAND CREDIT $0 $9,920 $371,703 $9,920 $371,703
UNION.
822818 CENTURY HERITAGE FCU $0 $9,892 $502,719 $9,892 $502,719
833205 UNION BANK & TRUST $0 $9,851 $90,432 $9,851 $90,432
ELT NELNET.
817864 NORTHEAST ARKANSAS $0 $9,850 $505,080 $9,850 $505,080
FEDERAL CREDIT U.
829994 NORTHERN HILLS FCU.. $0 $9,849 $427,839 $9,849 $427,839
826405 SYCAMORE BANK....... $0 $9,840 $290,436 $9,840 $290,436
809695 LEBANON VALLEY $0 $9,804 $443,211 $9,804 $443,211
FARMERS BANK.
809323 WEST BRANCH VALLEY $0 $9,800 $505,049 $9,800 $505,049
CU.
834179 FIFTH THIRD ELT $0 $9,768 $503,884 $9,768 $503,884
BUSINESS FIN SOLUTI.
833709 ARVEST BANK......... $0 $9,765 $422,016 $9,765 $422,016
833096 KENMORE TEACHERS $0 $9,748 $387,611 $9,748 $387,611
FEDERAL CREDIT UNI.
833469 LAREDO FEDERAL $0 $9,700 $465,764 $9,700 $465,764
CREDIT UNION.
832314 EDUCATIONAL $0 $9,673 $487,573 $9,673 $487,573
COMMUNITY CU.
817696 FIRST CHOICE AMERICA $0 $9,656 $614,202 $9,656 $614,202
COMMUNITY FCU.
830525 LASALLE BANK........ $0 $9,650 $0 $9,650 $0
832715 UNIVERSITY DR VAH $0 $9,620 $363,548 $9,620 $363,548
FCU.
830649 SLM ECFC............ $0 $9,602 $2,082,578 $9,602 $2,082,578
816358 DELTA COMMUNITY CU.. $0 $9,589 $687,865 $9,589 $687,865
820694 SACO VALLEY CREDIT $0 $9,561 $294,945 $9,561 $294,945
UNION.
830513 DETROIT EDISON $0 $9,558 $448,492 $9,558 $448,492
CREDIT UNION.
807805 M & T BANK $0 $9,556 $509,632 $9,556 $509,632
EDUCATIONAL LENDING.
828142 SCHUYLKILL FEDERAL $0 $9,550 $431,465 $9,550 $431,465
CREDIT UNION.
808018 LAKE SHORE SAVINGS $0 $9,542 $374,757 $9,542 $374,757
AND LOAN ASSN.
810928 FIRST NATIONAL BANK. $0 $9,530 $1,774 $9,530 $1,774
810948 RED RIVER EMPLOYEES $0 $9,487 $370,623 $9,487 $370,623
FEDERAL CREDIT.
832074 GREATER MN CREDIT $0 $9,485 $451,622 $9,485 $451,622
UNION.
833932 NEW ALLIANCE FCU.... $0 $9,471 $600,302 $9,471 $600,302
832741 PRR SOUTH FORK FCU.. $0 $9,468 $424,206 $9,468 $424,206
812918 NEW TRIPOLI BANK.... $0 $9,448 $420,129 $9,448 $420,129
832148 VIRGINIA UNITED $0 $9,439 $329,656 $9,439 $329,656
METHODIST CU.
833824 DODGE CENTRAL CREDIT $0 $9,408 $580,463 $9,408 $580,463
UNION.
814108 REGIONS BANK........ $0 $9,407 $51,145 $9,407 $51,145
834201 US BANK ELT UNIV OF $0 $9,379 $0 $9,379 $0
TX TEXAS EXES.
833480 PRINCIPAL BANK...... $0 $9,363 $243,694 $9,363 $243,694
816116 FAA EMPLOYEES CREDIT $0 $9,297 $561,404 $9,297 $561,404
UNION.
832355 ERIE SHORES CREDIT $0 $9,251 $480,246 $9,251 $480,246
UNION INC.
821498 TRI VALLEY SERVICE $0 $9,233 $340,141 $9,233 $340,141
FCU.
810903 JOURDANTON STATE $0 $9,209 $545,984 $9,209 $545,984
BANK.
813891 ZIONS BANK (IDAHO $0 $9,184 $46,584 $9,184 $46,584
FIRST).
814651 SIOUX EMPIRE FEDERAL $0 $9,180 $484,657 $9,180 $484,657
CREDIT UNION.
826001 WALWORTH STATE BANK. $0 $9,119 $614,667 $9,119 $614,667
832512 BOSSIER FEDERAL $0 $9,118 $345,703 $9,118 $345,703
CREDIT UNION.
832288 C&G SAVINGS $0 $9,105 $591,563 $9,105 $591,563
ASSOCIATION.
818246 ARVEST BANK......... $0 $9,091 $462,649 $9,091 $462,649
826679 ELI LILLY FEDERAL $0 $9,051 $284,029 $9,051 $284,029
CREDIT UNION.
823777 ROSE ROCK BANK...... $0 $9,021 $295,430 $9,021 $295,430
814627 COMMERCIAL TRUST $0 $9,001 $320,483 $9,001 $320,483
COMPANY.
832432 AURORA CREDIT UNION. $0 $8,980 $400,013 $8,980 $400,013
832174 NASSAU FINANCIAL FCU $0 $8,958 $514,931 $8,958 $514,931
832551 SHAREFAX CREDIT $0 $8,925 $467,982 $8,925 $467,982
UNION INC.
828836 PHOENIXVILLE FEDERAL $0 $8,858 $444,935 $8,858 $444,935
SVGS & LOAN.
832560 AURORA BURLINGTON $0 $8,831 $203,474 $8,831 $203,474
CREDIT UNION.
833013 UGI EMPLOYEES FCU... $0 $8,793 $338,081 $8,793 $338,081
816098 THE CITIZENS BANK OF $0 $8,765 $287,537 $8,765 $287,537
CLOVIS.
808237 FIRST NATIONAL BANK $0 $8,734 $403,027 $8,734 $403,027
& TRUST COMPANY.
810225 WILKES BARRE POSTAL $0 $8,695 $395,172 $8,695 $395,172
FCU.
812950 FIRST NATIONAL BANK $0 $8,679 $107,140 $8,679 $107,140
OF BERWICK.
816319 ATLANTA POSTAL $0 $8,666 $481,550 $8,666 $481,550
CREDIT UNION.
832184 SUMMIT CU........... $0 $8,657 $356,280 $8,657 $356,280
834112 US BANK ELT BAYLOR $0 $8,630 $0 $8,630 $0
UNIV ALUMNI ASSO.
828416 UNITED FEDERAL CU... $0 $8,611 $451,927 $8,611 $451,927
833912 MERCER COUNTY $0 $8,585 $451,827 $8,585 $451,827
COMMUNITY FCU.
811946 LAONA STATE BANK.... $0 $8,573 $512,594 $8,573 $512,594
833355 CREDIT UNION $0 $8,569 $365,643 $8,569 $365,643
NORTHWEST.
831825 INDEPENDENT BANKERS $0 $8,544 $13,775 $8,544 $13,775
BANK.
832826 MEDICAL AREA FCU.... $0 $8,539 $488,295 $8,539 $488,295
832223 MONONA STATE BANK... $0 $8,530 $479,537 $8,530 $479,537
818280 LIBERTY FEDERAL $0 $8,519 $279,695 $8,519 $279,695
SAVINGS BANK.
832877 RIVER CITY COMMUNITY $0 $8,518 $284,466 $8,518 $284,466
CREDIT UNION.
832075 RICHFIELD $0 $8,513 $410,179 $8,513 $410,179
BLOOMINGTON CREDIT
UNION.
823618 ASSOCIATED BANK NA.. $0 $8,498 $8,498 $0
833774 XEROX FEDERAL CREDIT $0 $8,467 $430,040 $8,467 $430,040
UNION.
810468 FIRST SAVINGS BANK.. $0 $8,449 $335,881 $8,449 $335,881
830837 UNITED SAVINGS $0 $8,436 $337,699 $8,436 $337,699
CREDIT UNION.
829825 HARDIN COMMUNITY $0 $8,431 $404,470 $8,431 $404,470
FEDERAL CREDIT UNI.
811513 CITIZENS NATIONAL $0 $8,410 $659,200 $8,410 $659,200
BANK OF BERKELEY.
828024 FIRST COMMUNITY $0 $8,409 $408,297 $8,409 $408,297
CREDIT UNION.
832935 CY-FAIR FCU......... $0 $8,381 $392,807 $8,381 $392,807
833120 AREA COMMUNITY $0 $8,365 $319,360 $8,365 $319,360
CREDIT UNION.
827902 STERLING UNITED FCU. $0 $8,346 $447,058 $8,346 $447,058
822189 FIBERGLAS FEDERAL $0 $8,329 $418,201 $8,329 $418,201
CREDIT UNION.
832745 EC & EE EMPLOYEES $0 $8,288 $310,584 $8,288 $310,584
FCU.
806481 MINNWEST BANK $0 $8,271 $336,416 $8,271 $336,416
LUVERNE.
827675 DULUTH TEACHERS $0 $8,270 $290,872 $8,270 $290,872
CREDIT UNION.
804091 IOWA FALLS STATE $0 $8,266 $317,723 $8,266 $317,723
BANK.
833507 MERIDIA COMMUNITY $0 $8,250 $257,927 $8,250 $257,927
FCU.
832091 ST CLOUD FEDERAL $0 $8,235 $529,678 $8,235 $529,678
CREDIT UNION.
810482 FIRST NATIONAL BANK. $0 $8,222 $380,656 $8,222 $380,656
808273 WESTERN HERITAGE $0 $8,212 $394,947 $8,212 $394,947
CREDIT UNION.
828907 R-S BELLCO FEDERAL $0 $8,154 $477,964 $8,154 $477,964
CREDIT UNION.
816190 DOCO REGIONAL FCU... $0 $8,145 $527,744 $8,145 $527,744
825230 COMERICA BANK....... $0 $8,117 $2,770 $8,117 $2,770
809966 CORRY FCU........... $0 $8,092 $561,707 $8,092 $561,707
832350 HEALTHFIRST FCU..... $0 $8,074 $363,998 $8,074 $363,998
827348 GUARDIAN CREDIT $0 $8,065 $399,109 $8,065 $399,109
UNION.
832868 HERMANTOWN FCU...... $0 $8,033 $335,619 $8,033 $335,619
833041 CANTON SCHOOL EFCU.. $0 $8,019 $318,110 $8,019 $318,110
832033 UNITED STATES SENATE $0 $8,000 $480,967 $8,000 $480,967
FEDERAL CREDIT.
832433 PRIMEFINANCIAL CU... $0 $7,979 $523,756 $7,979 $523,756
810463 FIRST NATIONAL BANK $0 $7,945 $328,838 $7,945 $328,838
IN PHILIP.
808425 FREMONT FIRST $0 $7,923 $349,997 $7,923 $349,997
CENTRAL FEDERAL
CREDI.
803947 CENTRAL BANK........ $0 $7,913 $258,947 $7,913 $258,947
826004 ORNL FEDERAL CREDIT $0 $7,883 $10,836 $7,883 $10,836
UNION.
828732 CAPITAL $0 $7,859 $449,436 $7,859 $449,436
COMMUNICATIONS
FEDERAL CRED.
833637 NORTHERN COMMUNITIES $0 $7,854 $300,706 $7,854 $300,706
CU.
831706 PIONEER CU.......... $0 $7,852 $266,611 $7,852 $266,611
830720 VAC EMPLOYEES FCU... $0 $7,796 $362,768 $7,796 $362,768
818506 STATE BANK OF $0 $7,781 $373,940 $7,781 $373,940
ARCADIA.
820277 DISCOVERY FCU....... $0 $7,772 $505,952 $7,772 $505,952
823762 AB CREDIT UNION..... $0 $7,714 $293,216 $7,714 $293,216
802814 CITIZENS NATIONAL $0 $7,635 $7,635 $0
BANK.
833614 BADGER CREDIT UNION. $0 $7,630 $321,260 $7,630 $321,260
809947 VALLEY FIRST COMM $0 $7,627 $7,627 $0
FCU.
817856 THE FIRST NATIONAL $0 $7,625 $264,145 $7,625 $264,145
BANK AT PARIS.
829509 SOUTHWEST RESEARCH $0 $7,619 $510,161 $7,619 $510,161
CENTER FCU.
831535 WYOMING STUDENT LOAN $0 $7,598 $421,547 $7,598 $421,547
CORP GEN FUND.
831301 SOUTHPOINTE CREDIT $0 $7,576 $223,786 $7,576 $223,786
UNION.
833898 PITTSBURGH POLICE $0 $7,571 $404,209 $7,571 $404,209
FCU.
833794 CONE CREDIT UNION... $0 $7,570 $223,004 $7,570 $223,004
832610 HAR-CO MARYLAND $0 $7,560 $390,931 $7,560 $390,931
FEDERAL CREDIT UNIO.
831513 UNIVERSITY OF $0 $7,548 $7,548 $0
COLORADO.
832584 KEMBA CU............ $0 $7,533 $7,533 $0
819166 JP MORGANCHASE BANK. $0 $7,519 $12,934 $7,519 $12,934
809459 ELDERTON STATE BANK. $0 $7,515 $558,723 $7,515 $558,723
829513 DOT FEDERAL CREDIT $0 $7,504 $326,642 $7,504 $326,642
UNION.
832343 ABCO FEDERAL CREDIT $0 $7,489 $544,484 $7,489 $544,484
UNION.
832850 FEDERATED FAMILY CU. $0 $7,486 $273,721 $7,486 $273,721
832454 UNITED BANK OF $0 $7,479 $509,952 $7,479 $509,952
PHILADELPHIA.
828001 EAST TEXAS $0 $7,467 $363,262 $7,467 $363,262
PROFESSIONAL CU.
827885 APPLETREE CREDIT $0 $7,422 $415,169 $7,422 $415,169
UNION.
813574 CUMBERLAND COUNTY $0 $7,412 $495,002 $7,412 $495,002
FCU.
827066 INNER LAKES FCU..... $0 $7,390 $319,804 $7,390 $319,804
829624 ENTERPRISE CREDIT $0 $7,357 $377,384 $7,357 $377,384
UNION.
832335 GOWANDA AREA FCU.... $0 $7,324 $249,099 $7,324 $249,099
832026 OPCS FEDERAL CREDIT $0 $7,285 $329,218 $7,285 $329,218
UNION.
833628 PEPPERDINE $0 $7,274 $7,274 $0
UNIVERSITY.
828851 MUNICIPAL CREDIT $0 $7,245 $250,732 $7,245 $250,732
UNION.
826322 CINCINNATI $0 $7,215 $291,632 $7,215 $291,632
INTERAGENCY FEDERAL
CRED.
832825 WACHOVIA NAT'L BANK $0 $7,210 $433,127 $7,210 $433,127
DE NA.
820758 SALEM VA MEDICAL $0 $7,199 $586,483 $7,199 $586,483
CENTER FED CR UNIO.
832538 NORTHLAND EDUCATORS $0 $7,199 $338,258 $7,199 $338,258
FCU.
833118 ELM RIVER CREDIT $0 $7,194 $290,715 $7,194 $290,715
UNION.
807612 WASHINGTON MUTUAL $0 $7,189 $0 $7,189 $0
BANK FA.
830294 FIRST COMMUNITY $0 $7,181 $345,426 $7,181 $345,426
FEDERAL CREDIT UNIO.
818220 STATE BANK OF $0 $7,179 $359,100 $7,179 $359,100
CHILTON.
819769 PENINSULA FEDERAL $0 $7,151 $524,390 $7,151 $524,390
CREDIT UNION.
832800 FAYETTE FEDERAL $0 $7,151 $322,250 $7,151 $322,250
EMPLOYEES FCU.
833837 LONE STAR NATIONAL $0 $7,109 $378,390 $7,109 $378,390
BANK.
829390 SEACOMM FEDERAL $0 $7,105 $577,450 $7,105 $577,450
CREDIT UNION.
808521 SAC FEDERAL CREDIT $0 $7,088 $290,088 $7,088 $290,088
UNION.
832059 CHAMPION CREDIT $0 $7,088 $270,539 $7,088 $270,539
UNION.
832719 BLUE CHIP FCU....... $0 $7,083 $388,826 $7,083 $388,826
832254 CAPITAL TRUST $0 $7,028 $276,186 $7,028 $276,186
FEDERAL CREDIT
UNION.
833112 GREATER LATROBE $0 $7,016 $192,317 $7,016 $192,317
SCHOOLS FCU.
814495 MAQUOKETA STATE BANK $0 $6,997 $420,408 $6,997 $420,408
832749 TOPMARK FCU......... $0 $6,995 $202,170 $6,995 $202,170
832886 TONAWANDA FCU....... $0 $6,993 $309,159 $6,993 $309,159
824046 PA CENTRAL FCU...... $0 $6,984 $326,011 $6,984 $326,011
829086 COMMUNITY FCU....... $0 $6,968 $265,612 $6,968 $265,612
827711 FIRST SERVICE CU.... $0 $6,952 $252,995 $6,952 $252,995
808990 FIRST FIDELITY BANK $0 $6,942 $0 $6,942 $0
NA.
832846 AUSTIN TELCO FCU.... $0 $6,936 $6,936 $0
827802 EDTECH FEDERAL $0 $6,923 $276,209 $6,923 $276,209
CREDIT UNION.
830555 COMMUNITY BANK...... $0 $6,915 $253,395 $6,915 $253,395
819745 SOUND CREDIT UNION.. $0 $6,914 $357,750 $6,914 $357,750
824693 FINGER LAKES FEDERAL $0 $6,911 $459,472 $6,911 $459,472
CREDIT UNION.
833660 ULSTER FEDERAL $0 $6,901 $380,999 $6,901 $380,999
CREDIT UNION.
833905 EASTERN MAINE MED $0 $6,889 $591,726 $6,889 $591,726
CENTER FCU.
819585 MERIDIAN TRUST FCU.. $0 $6,877 $258,396 $6,877 $258,396
812889 FIRST NAT'L BANK OF $0 $6,873 $379,926 $6,873 $379,926
LILLY.
823524 MILLER ELECTRIC $0 $6,865 $267,937 $6,865 $267,937
CREDIT UNION.
826396 EMPLOYEES CREDIT $0 $6,859 $415,350 $6,859 $415,350
UNION.
814465 TEXAS FEDERAL CREDIT $0 $6,840 $527,361 $6,840 $527,361
UNION.
833781 CAPITAL AREA FCU.... $0 $6,838 $385,891 $6,838 $385,891
820274 WESTMORELAND FEDERAL $0 $6,833 $257,138 $6,833 $257,138
EMP FCU.
830320 FIRST NATIONAL BANK. $0 $6,830 $308,065 $6,830 $308,065
825257 KALSEE CREDIT UNION. $0 $6,827 $295,314 $6,827 $295,314
824795 INDEPENDENCE BANK... $0 $6,824 $252,962 $6,824 $252,962
833853 ARKANSAS SUPERIOR $0 $6,802 $6,802 $0
FCU.
833249 CITY NATIONAL BANK $0 $6,779 $338,057 $6,779 $338,057
OF TAYLOR.
822870 HOUSTON POLICE FCU.. $0 $6,704 $367,960 $6,704 $367,960
833491 BOEING WICHITA $0 $6,696 $389,052 $6,696 $389,052
CREDIT UNION.
832957 PRINCE GEORGES FCU.. $0 $6,660 $268,005 $6,660 $268,005
824432 APPLE FEDERAL CREDIT $0 $6,645 $305,693 $6,645 $305,693
UNION.
819817 PLAINS COMMERCE BANK $0 $6,645 $359,705 $6,645 $359,705
832870 STATE CS EMPLOYEES $0 $6,625 $227,612 $6,625 $227,612
FEDERAL CREDIT U.
813409 OMEGA BANK N A...... $0 $6,604 $6,604 $0
833701 AVESTAR CU.......... $0 $6,601 $252,033 $6,601 $252,033
830931 MISSOURI HIGHER $0 $6,583 $338,353 $6,583 $338,353
EDUCATION LOAN AUTH.
819818 RAPID CITY TELCO $0 $6,576 $307,886 $6,576 $307,886
FEDERAL CREDIT UNI.
833384 UNILEVER FEDERAL $0 $6,568 $216,057 $6,568 $216,057
CREDIT UNION.
830530 OSHKOSH CENTRAL $0 $6,531 $329,338 $6,531 $329,338
CREDIT UNION.
833374 LADISH COMMUNITY CU. $0 $6,524 $333,949 $6,524 $333,949
823466 GULF COAST BANK..... $0 $6,512 $356,282 $6,512 $356,282
819575 STANWOOD AREA FCU... $0 $6,489 $320,320 $6,489 $320,320
832974 KILOWATT CREDIT $0 $6,482 $171,714 $6,482 $171,714
UNION.
819648 UNIVERSITY NATIONAL $0 $6,477 $0 $6,477 $0
BANK OF CHICAGO.
832915 UFCW LOCAL 1776 FCU. $0 $6,469 $243,824 $6,469 $243,824
830523 GATES CHILI FEDERAL $0 $6,456 $183,377 $6,456 $183,377
CREDIT UNION.
825435 BANK OF MONTICELLO.. $0 $6,429 $377,921 $6,429 $377,921
829212 TEACHERS CREDIT $0 $6,389 $314,026 $6,389 $314,026
UNION.
819012 BANK OF UTICA....... $0 $6,355 $389,130 $6,355 $389,130
818402 FIRST NATIONAL BANK-- $0 $6,344 $377,842 $6,344 $377,842
FOX VALLEY.
811908 FIRST BANK OF $0 $6,324 $352,444 $6,324 $352,444
BALDWIN.
832928 MONEY FEDERAL CREDIT $0 $6,310 $247,623 $6,310 $247,623
UNION.
833631 UTILITIES EMPLOYEES $0 $6,298 $6,298 $0
CREDIT UNION.
833588 THE ALTOONA HOSPITAL $0 $6,291 $353,687 $6,291 $353,687
FCU.
832984 ONE SOURCE FCU...... $0 $6,272 $322,696 $6,272 $322,696
827361 BLUE GRASS SAVINGS $0 $6,271 $206,980 $6,271 $206,980
BANK.
815708 FIRST NATIONAL BANK $0 $6,265 $200,815 $6,265 $200,815
VALPARAISO.
814540 UNION BANK & TRUST $0 $6,264 $6,264 $0
COMPANY.
832537 TAPCO CREDIT UNION.. $0 $6,240 $315,896 $6,240 $315,896
832954 SCRANTON TIMES EMP $0 $6,232 $6,232 $0
FCU.
831913 WESTERN CREDIT UNION $0 $6,222 $211,878 $6,222 $211,878
INC.
832287 CUMBERLAND COUNTY $0 $6,220 $466,888 $6,220 $466,888
FCU.
833411 OKLAHOMA EDUCATORS $0 $6,192 $274,747 $6,192 $274,747
CU.
833745 HONEYWELL FCU....... $0 $6,190 $290,808 $6,190 $290,808
819504 NUMERICA CREDIT $0 $6,188 $357,791 $6,188 $357,791
UNION.
832651 GLATCO CREDIT UNION. $0 $6,184 $216,292 $6,184 $216,292
814381 VALLEY EXCHANGE BANK $0 $6,162 $244,064 $6,162 $244,064
830930 CENTRAL VIRGINIA $0 $6,121 $240,698 $6,121 $240,698
FEDERAL CREDIT UNI.
824852 EASTERN BANK........ $0 $6,118 $423,923 $6,118 $423,923
833710 OZONA NATIONAL BANK. $0 $6,105 $268,490 $6,105 $268,490
803967 UNITED COMMUNITY $0 $6,089 $187,795 $6,089 $187,795
BANK.
829703 BORDER CAPITAL BANK. $0 $6,069 $266,968 $6,069 $266,968
830387 WEBSTER FEDERAL CU.. $0 $6,057 $185,391 $6,057 $185,391
813583 FARMERS & MERCHANTS $0 $6,043 $246,250 $6,043 $246,250
STATE BANK.
833839 STAR CHOICE CREDIT $0 $6,042 $300,319 $6,042 $300,319
UNION.
819657 TIFFIN SAINT JOSEPH $0 $6,041 $354,162 $6,041 $354,162
FEDERAL CREDIT.
832492 PACIFIC NORTHWEST $0 $6,022 $320,993 $6,022 $320,993
FEDERAL CREDIT UN.
833354 KNIFE RIVER CREDIT $0 $5,934 $186,767 $5,934 $186,767
UNION.
833506 ALLEGIANCE CREDIT $0 $5,906 $314,962 $5,906 $314,962
UNION.
810417 COMMERCIAL STATE $0 $5,892 $233,732 $5,892 $233,732
BANK.
819155 FARMERS & MERCHANTS $0 $5,870 $147,606 $5,870 $147,606
BANK.
815780 INGERSOLL RAND $0 $5,849 $347,445 $5,849 $347,445
FEDERAL CREDIT
UNION.
805810 TACONNET FEDERAL $0 $5,841 $395,275 $5,841 $395,275
CREDIT UNION.
830564 SACO AND BIDDEFORD $0 $5,830 $263,632 $5,830 $263,632
SVGS INST.
826977 PYRAMAX BANK........ $0 $5,806 $355,946 $5,806 $355,946
833282 FIRST VICTORIA $0 $5,800 $345,266 $5,800 $345,266
NATIONAL BANK.
833407 BRONCO FEDERAL $0 $5,784 $405,852 $5,784 $405,852
CREDIT UNION.
832331 CHAMPLAIN VALLEY $0 $5,782 $278,884 $5,782 $278,884
CREDIT UNION.
833878 CITY-COUNTY FCU..... $0 $5,781 $287,778 $5,781 $287,778
832750 MISSISSIPPI POSTAL $0 $5,747 $373,440 $5,747 $373,440
EMPLOYEES FCU.
828634 DORT FEDERAL CREDIT $0 $5,733 $400,292 $5,733 $400,292
UNION.
824461 TEACHER FEDERAL $0 $5,703 $308,018 $5,703 $308,018
CREDIT UNION.
821347 OREGONIANS CU....... $0 $5,697 $210,330 $5,697 $210,330
806378 FIRST STATE BANK OF $0 $5,697 $248,875 $5,697 $248,875
ST JOSEPH.
832391 TOLEDO AREA $0 $5,685 $367,893 $5,685 $367,893
COMMUNITY CU.
819511 SAVINGS BANK........ $0 $5,652 $407,527 $5,652 $407,527
828798 M & T BANK $0 $5,644 $348,008 $5,644 $348,008
EDUCATIONAL LENDING.
833284 WEST POINTE BANK.... $0 $5,629 $323,998 $5,629 $323,998
831859 WESTERN VISTA $0 $5,593 $233,345 $5,593 $233,345
FEDERAL CREDIT
UNION.
832897 OWEGO HERITAGE FCU.. $0 $5,589 $238,025 $5,589 $238,025
828975 WESTMORELAND $0 $5,588 $332,978 $5,588 $332,978
COMMUNITY FCU.
826556 LOGAN COUNTY BANK... $0 $5,577 $219,829 $5,577 $219,829
832377 PORTLAND REGIONAL $0 $5,540 $189,642 $5,540 $189,642
FEDERAL CREDIT UN.
825568 UKRAINIAN $0 $5,534 $151,893 $5,534 $151,893
SELFRELIANCE OF W
PA FCU.
831119 MO HIGHER ED LOAN $0 $5,526 $838,203 $5,526 $838,203
AUTHORITY.
820726 HUTCHINSON CREDIT $0 $5,526 $204,527 $5,526 $204,527
UNION.
810489 FULTON STATE BANK... $0 $5,525 $228,033 $5,525 $228,033
832340 AUBURN COMMUNITY FCU $0 $5,523 $267,712 $5,523 $267,712
833240 FARGO PUBLIC SCHOOLS $0 $5,520 $282,746 $5,520 $282,746
FEDERAL CREDIT.
833233 US BANK ELT PHEA INC $0 $5,511 $703,430 $5,511 $703,430
810462 FIRST STATE BANK OF $0 $5,504 $272,551 $5,504 $272,551
MILLER.
828826 CENTRAL BANK OF $0 $5,498 $190,121 $5,498 $190,121
LEBANON.
814440 COMMUNITY FIRST CU $0 $5,478 $287,226 $5,478 $287,226
OF FLORIDA.
834107 FRANKLIN OIL REGION $0 $5,472 $228,884 $5,472 $228,884
CU.
833899 BANGOR FCU.......... $0 $5,439 $338,645 $5,439 $338,645
821715 MAGNOLIA FCU........ $0 $5,432 $410,800 $5,432 $410,800
823079 HOME SAVINGS & LOAN $0 $5,410 $303,241 $5,410 $303,241
ASSOCIATION.
832881 LEWISTON PORTER FCU. $0 $5,393 $222,006 $5,393 $222,006
819350 UNITUS COMMUNITY CU. $0 $5,391 $250,308 $5,391 $250,308
832522 MILESTONE FCU....... $0 $5,384 $249,171 $5,384 $249,171
819088 POWER COOP EMPLOYEES $0 $5,378 $232,825 $5,378 $232,825
CREDIT UNION.
832356 BISSELL EMPLOYEES $0 $5,373 $176,217 $5,373 $176,217
CREDIT UNION.
833687 CLASSIC FEDERAL $0 $5,362 $338,850 $5,362 $338,850
CREDIT UNION.
833739 CALIFORNIA CREDIT $0 $5,360 $277,887 $5,360 $277,887
UNION.
813148 MACOMB SCH & $0 $5,301 $356,332 $5,301 $356,332
GOVERNMENT CREDIT
UNIO.
833727 BUFFALO SERVICE $0 $5,290 $183,706 $5,290 $183,706
CREDIT UNION.
812008 STATE BANK OF $0 $5,281 $393,573 $5,281 $393,573
CAZENOVIA.
823895 LANSING AUTOMAKERS $0 $5,279 $284,706 $5,279 $284,706
FCU.
832913 LITTLE GIANT FEDERAL $0 $5,270 $307,074 $5,270 $307,074
CREDIT UNION.
812688 M & T BANK $0 $5,265 $0 $5,265 $0
EDUCATIONAL LENDING.
810466 FIRST NATIONAL BANK $0 $5,258 $223,666 $5,258 $223,666
OF VOLGA.
833320 CO-OPERATIVE CREDIT $0 $5,253 $192,604 $5,253 $192,604
UNION.
832942 TEMCO EMPLOYEES FCU. $0 $5,250 $5,250 $0
810533 PIONEER BANK & TRUST $0 $5,224 $0 $5,224 $0
833396 TEXAS DPS CREDIT $0 $5,222 $367,187 $5,222 $367,187
UNION.
833083 RACINE MUNICIPAL $0 $5,219 $254,862 $5,219 $254,862
EMPLOYEES CREDIT U.
826730 CENTURY FEDERAL $0 $5,213 $5,213 $0
CREDIT UNION.
834219 US BANK ELT $0 $5,186 $23,038 $5,186 $23,038
STUDENTONE LLC.
833651 MENASHA EMP CU...... $0 $5,173 $211,402 $5,173 $211,402
810518 PEOPLES STATE BANK.. $0 $5,158 $263,509 $5,158 $263,509
809015 SOUTHWEST NATIONAL $0 $5,150 $219,619 $5,150 $219,619
BANK.
827445 THIRD FEDERAL $0 $5,127 $305,891 $5,127 $305,891
SAVINGS BANK.
832905 MOHAWK VALLEY FCU... $0 $5,125 $151,523 $5,125 $151,523
833510 NEENAH FOUNDRY $0 $5,122 $214,530 $5,122 $214,530
CREDIT UNION.
830665 MUNICIPAL CREDIT $0 $5,120 $458,008 $5,120 $458,008
UNION.
819245 HOMETOWN BANK....... $0 $5,095 $281,418 $5,095 $281,418
832490 DPL FEDERAL CREDIT $0 $5,087 $136,354 $5,087 $136,354
UNION.
833555 LIBERTY FIRST CREDIT $0 $5,087 $314,878 $5,087 $314,878
UNION.
833746 CLEARVIEW FCU....... $0 $5,085 $311,423 $5,085 $311,423
828125 ST PAUL POSTAL EMP $0 $5,074 $284,370 $5,074 $284,370
CU.
826375 AMERICAN STATE BANK. $0 $5,059 $189,657 $5,059 $189,657
833157 JP MORGAN CHASE SMS $0 $5,059 $525,374 $5,059 $525,374
TRUST 1994-B.
809874 PEOPLES STATE BANK.. $0 $5,051 $10,542 $5,051 $10,542
832523 WEST VIRGINIA $0 $5,019 $179,214 $5,019 $179,214
CENTRAL CREDIT
UNION.
833348 COMMUNITYAMERICA $0 $5,016 $321,399 $5,016 $321,399
CREDIT UNION.
832302 SENTRY FCU.......... $0 $5,014 $175,470 $5,014 $175,470
832452 NEWPORT NEWS $0 $5,005 $185,941 $5,005 $185,941
MUNICIPAL ECU.
829967 BAYER HERITAGE FCU.. $0 $5,004 $292,719 $5,004 $292,719
823588 AURGROUP FINANCIAL $0 $4,965 $275,167 $4,965 $275,167
CREDIT UNION.
828527 OMAHA FEDERAL CREDIT $0 $4,965 $270,981 $4,965 $270,981
UNION.
833300 THE PEOPLES $0 $4,956 $4,956 $0
COMMUNITY BANK.
830488 AMPLIFY FCU......... $0 $4,956 $219,757 $4,956 $219,757
812762 CROSSROADS CU....... $0 $4,929 $251,890 $4,929 $251,890
832263 HAMPTON ROADS $0 $4,917 $237,119 $4,917 $237,119
EDUCATORS CU.
832255 SWEET HOME FEDERAL $0 $4,896 $255,823 $4,896 $255,823
CREDIT UNION.
829346 MEMBERS' ADVANTAGE $0 $4,881 $269,585 $4,881 $269,585
CU.
820418 SECU FEDERAL CREDIT $0 $4,875 $425,598 $4,875 $425,598
UNION.
819169 YOAKUM NATIONAL BANK $0 $4,869 $354,707 $4,869 $354,707
832256 ST JOSEPHS PARISH $0 $4,839 $161,875 $4,839 $161,875
BUFFALO FCU.
816367 ASSOCIATED CREDIT $0 $4,829 $272,485 $4,829 $272,485
UNION.
823990 FAMILY CREDIT UNION. $0 $4,822 $182,326 $4,822 $182,326
823296 SCHOOL EMP. LOR CU.. $0 $4,819 $317,864 $4,819 $317,864
832806 ROUNTREE CREDIT $0 $4,815 $210,261 $4,815 $210,261
UNION.
826969 METROPOLITAN CREDIT $0 $4,802 $343,846 $4,802 $343,846
UNION.
832442 OSU FEDERAL CREDIT $0 $4,768 $228,752 $4,768 $228,752
UNION.
831489 RUSHMORE ELECTRIC $0 $4,761 $275,932 $4,761 $275,932
FEDERAL CREDIT UN.
832495 FIREFIGHTERS CU..... $0 $4,760 $197,298 $4,760 $197,298
831252 STATE BANK OF CROSS $0 $4,731 $292,897 $4,731 $292,897
PLAINS.
832278 GREATER PORTLAND $0 $4,731 $304,202 $4,731 $304,202
MUNICIPAL FCU.
832759 H-F CREDIT UNION.... $0 $4,718 $198,184 $4,718 $198,184
829641 POWERCO CREDIT UNION $0 $4,712 $167,861 $4,712 $167,861
INC.
822648 MICHIGAN RURAL $0 $4,704 $342,328 $4,704 $342,328
REHABILITATION
CORPO.
828340 FIRST EDUCATION FCU. $0 $4,683 $254,306 $4,683 $254,306
833175 STUDENT LOAN FUNDING $0 $4,683 $96,843 $4,683 $96,843
US BANK ELT.
805804 K V FEDERAL CREDIT $0 $4,635 $290,954 $4,635 $290,954
UNION.
805071 CHURCH POINT BANK & $0 $4,615 $302,407 $4,615 $302,407
TRUST COMPANY.
829262 METRO HEALTH SERVICE $0 $4,594 $172,705 $4,594 $172,705
FCU.
817943 HUDSON RIVER COMM CU $0 $4,589 $333,914 $4,589 $333,914
806802 CU COMMUNITY CU..... $0 $4,577 $132,756 $4,577 $132,756
832330 ROYAL FEDERAL CREDIT $0 $4,576 $0 $4,576 $0
UNION.
833832 BANKNORTH........... $0 $4,569 $4,569 $0
833916 GRAPHIC $0 $4,564 $121,396 $4,564 $121,396
COMMUNICATORS &
MACH FCU.
805788 MAINE MEDIA FEDERAL $0 $4,556 $169,873 $4,556 $169,873
CREDIT UNION.
833453 IBEW LOCAL #56 $0 $4,541 $143,432 $4,541 $143,432
FEDERAL CREDIT
UNION.
832975 NEW ENGLAND UNITED $0 $4,538 $149,030 $4,538 $149,030
METHODIST FCU.
833444 FORT WORTH COMMUNITY $0 $4,533 $220,906 $4,533 $220,906
CU.
830311 A M COMMUNITY CREDIT $0 $4,530 $218,343 $4,530 $218,343
UNION.
833924 LIVERPOOL CENTRAL $0 $4,521 $351,126 $4,521 $351,126
SCHOOLS FCU.
829432 WHG-PGH STEEL $0 $4,521 $362,569 $4,521 $362,569
COMMFCU.
829833 M O FEDERAL CREDIT $0 $4,506 $169,798 $4,506 $169,798
UNION.
832402 MERCY HEALTH $0 $4,502 $196,625 $4,502 $196,625
PARTNERS FCU.
807669 WOODSTOWN NATI BANK $0 $4,480 $166,695 $4,480 $166,695
& TRUST CO.
832637 TELHIO CREDIT UNION. $0 $4,461 $266,562 $4,461 $266,562
832043 LINCOLN COUNTRY CU.. $0 $4,459 $154,542 $4,459 $154,542
832674 MERCK SHARP & DOHME $0 $4,431 $343,029 $4,431 $343,029
FCU.
833342 WEST OHIO UNITED $0 $4,429 $316,729 $4,429 $316,729
METHODIST CU.
819438 HORIZON CREDIT UNION $0 $4,411 $339,402 $4,411 $339,402
824843 CHESTERFIELD FEDERAL $0 $4,402 $148,531 $4,402 $148,531
CREDIT UNION.
818223 COMMUNITY STATE BANK $0 $4,400 $328,765 $4,400 $328,765
833940 SHIPBUILDERS CU..... $0 $4,397 $306,545 $4,397 $306,545
832293 BOULDER MUNICIPAL $0 $4,392 $150,550 $4,392 $150,550
EFCU.
814345 EATON NATIONAL BANK $0 $4,349 $287,183 $4,349 $287,183
& TRUST CO.
832903 LEDGE LIGHT FCU..... $0 $4,313 $150,581 $4,313 $150,581
834156 FRANKLIN MINT FCU... $0 $4,297 $394,783 $4,297 $394,783
831609 GUARANTY BANK....... $0 $4,296 $152,072 $4,296 $152,072
830370 EVERGREEN CREDIT $0 $4,290 $266,222 $4,290 $266,222
UNION.
832717 ARMSTRONG COUNTY $0 $4,270 $4,270 $0
EMPL FCU.
830443 TRUSTAR FCU......... $0 $4,264 $238,823 $4,264 $238,823
832120 EATON FAMILY CREDIT $0 $4,256 $200,863 $4,256 $200,863
UNION.
832294 OHIO EDUCATIONAL $0 $4,253 $287,351 $4,253 $287,351
CREDIT UNION INC.
818896 AMERISTATE BANK..... $0 $4,252 $110,078 $4,252 $110,078
819383 MARATHON STATE BANK. $0 $4,245 $204,392 $4,245 $204,392
833888 WYROPE WILLIAMSPORT $0 $4,230 $299,373 $4,230 $299,373
FCU.
805624 NORWAY SAVINGS BANK. $0 $4,218 $164,304 $4,218 $164,304
833639 WAT FEDERAL CREDIT $0 $4,207 $255,186 $4,207 $255,186
UNION.
832658 RIVERSIDE FCU....... $0 $4,180 $206,000 $4,180 $206,000
833783 TRUCHOICE FCU....... $0 $4,179 $269,621 $4,179 $269,621
833735 QUEENS POSTAL FCU... $0 $4,161 $169,262 $4,161 $169,262
832047 NMA FCU............. $0 $4,160 $227,477 $4,160 $227,477
833488 ISLAND FEDERAL $0 $4,157 $290,918 $4,157 $290,918
CREDIT UNION.
832938 ACCESS FEDERAL $0 $4,155 $236,244 $4,155 $236,244
CREDIT UNION.
834070 WICHITA FALLS $0 $4,154 $275,246 $4,154 $275,246
TEACHER FCU.
832332 ESM-NS FEDERAL $0 $4,148 $267,646 $4,148 $267,646
CREDIT UNION.
827971 MACO EDUCATORS $0 $4,145 $171,373 $4,145 $171,373
FEDERAL CREDIT
UNION.
832520 PEOPLES FCU......... $0 $4,138 $256,133 $4,138 $256,133
834108 PARTNERS FCU........ $0 $4,135 $245,995 $4,135 $245,995
829385 CITIES CREDIT UNION. $0 $4,121 $165,185 $4,121 $165,185
833317 OHIO EDISON-PENN $0 $4,106 $261,284 $4,106 $261,284
POWER CU.
830936 PEPPERELL BANK & $0 $4,075 $239,695 $4,075 $239,695
TRUST.
818609 PORT WASHINGTON $0 $4,054 $253,639 $4,054 $253,639
STATE BANK.
804860 M&I BANK............ $0 $4,032 $4,032 $0
832712 KANSAS TEACHERS $0 $4,031 $125,054 $4,031 $125,054
CREDIT UNION.
833155 FRANCISCAN SKEMP $0 $4,029 $248,637 $4,029 $248,637
CREDIT UNION.
832874 NIAGARA WHEATFIELD $0 $4,016 $165,585 $4,016 $165,585
FCU.
816028 POSTMARK CREDIT $0 $4,014 $253,158 $4,014 $253,158
UNION.
832820 TRONA VALLEY FCU.... $0 $4,010 $113,262 $4,010 $113,262
832470 SNO FALLS CREDIT $0 $4,004 $133,676 $4,004 $133,676
UNION.
832389 RIVER VALLEY CREDIT $0 $3,995 $175,218 $3,995 $175,218
UNION.
828216 PUBLIC EMPLOYEES $0 $3,992 $274,743 $3,992 $274,743
CREDIT UNION.
831392 ALLCO CREDIT UNION.. $0 $3,983 $278,867 $3,983 $278,867
823964 UNION BANK & TRUST $0 $3,971 $248,854 $3,971 $248,854
CO.
822446 MEMBER'S CHOICE OF $0 $3,970 $188,326 $3,970 $188,326
CENTRAL TX FCU.
833158 EMPLOYMENT SECURITY $0 $3,964 $198,698 $3,964 $198,698
CREDIT UNION.
830350 EASTMILL FEDERAL $0 $3,948 $201,428 $3,948 $201,428
CREDIT UNION.
802261 EGLIN FEDERAL CREDIT $0 $3,940 $220,584 $3,940 $220,584
UNION.
822349 CITIZENS NATIONAL $0 $3,939 $277,209 $3,939 $277,209
BANK.
822605 CES CREDIT UNION INC $0 $3,938 $266,733 $3,938 $266,733
806279 LAKE REGION BANK.... $0 $3,936 $227,713 $3,936 $227,713
832291 P & C EMPLOYEES FCU. $0 $3,930 $182,284 $3,930 $182,284
833049 NEW HAMPSHIRE POSTAL $0 $3,929 $308,982 $3,929 $308,982
CU.
808467 MINDEN EXCHANGE BANK $0 $3,910 $205,569 $3,910 $205,569
& TRUST COMPAN.
806964 FIRST COMMUNITY BANK $0 $3,898 $3,898 $0
833050 WESTCO FCU.......... $0 $3,889 $246,241 $3,889 $246,241
809978 S A M P SCRANTON FCU $0 $3,878 $3,878 $0
815661 PANTEX FEDERAL $0 $3,874 $159,635 $3,874 $159,635
CREDIT UNION.
834030 LAKES AREA CU....... $0 $3,855 $232,292 $3,855 $232,292
829324 STARK FEDERAL CREDIT $0 $3,854 $262,262 $3,854 $262,262
UNION.
833753 PARTNERS CREDIT $0 $3,822 $165,391 $3,822 $165,391
UNION.
828854 FIRST COMMUNITY CU.. $0 $3,819 $186,882 $3,819 $186,882
825495 EDUCATION PLUS $0 $3,791 $225,755 $3,791 $225,755
CREDIT UNION.
800062 WHITNEY NATIONAL $0 $3,788 $0 $3,788 $0
BANK.
832505 FIRST PEOPLES $0 $3,785 $142,665 $3,785 $142,665
COMMUNITY FCU.
832099 BILLINGS FEDERAL $0 $3,776 $242,427 $3,776 $242,427
CREDIT UNION.
822093 ALTOONA BUTTERICK $0 $3,767 $128,880 $3,767 $128,880
FCU.
833680 ALTURA CREDIT UNION. $0 $3,766 $249,642 $3,766 $249,642
820828 MEMPHIS AREA $0 $3,763 $244,682 $3,763 $244,682
TEACHERS CREDIT
UNION.
829179 MAINE EDUCATION $0 $3,763 $164,842 $3,763 $164,842
CREDIT UNION.
832085 OMAHA DOUGLAS FCU... $0 $3,761 $252,695 $3,761 $252,695
830717 DAKOTA TERRITORY $0 $3,758 $172,747 $3,758 $172,747
FEDERAL CREDIT UNI.
833656 POINT PLUS CREDIT $0 $3,747 $234,831 $3,747 $234,831
UNION.
810546 FIRST NATIONAL BANK $0 $3,729 $91,857 $3,729 $91,857
SOUTH DAKOTA.
824566 VISIONARY FEDERAL $0 $3,727 $235,035 $3,727 $235,035
CREDIT UNION.
833836 SOUTHWEST OKLAHOMA $0 $3,726 $244,393 $3,726 $244,393
FCU.
834225 STUDENT LENDING $57 $3,667 $0 $3,724 $0
WORKS INC.
828143 CAMBRIA COUNTY $0 $3,720 $204,516 $3,720 $204,516
FEDERAL SAVINGS &
LO.
826528 FIDELITY DEPOSIT & $0 $3,715 $0 $3,715 $0
DISCOUNT BANK.
834233 CANISIUS COLLEGE.... $0 $3,707 $3,707 $0
833406 FOREST PARK FEDERAL $0 $3,705 $82,921 $3,705 $82,921
CREDIT UNION.
829981 LOUVIERS FEDERAL $0 $3,692 $123,423 $3,692 $123,423
CREDIT UNION.
805806 GREATER WATERVILLE $0 $3,671 $211,535 $3,671 $211,535
AREA FCU.
833483 CANANDAIGUA SCHOOL $0 $3,666 $135,358 $3,666 $135,358
DISTRICT FCU.
830883 VERMILLION FEDERAL $0 $3,661 $177,114 $3,661 $177,114
CREDIT UNION.
810427 BANK STAR FINANCIAL. $0 $3,656 $164,010 $3,656 $164,010
808682 THE EDUCATION CREDIT $0 $3,654 $129,774 $3,654 $129,774
UNION INC.
810450 FARMERS STATE BANK.. $0 $3,633 $131,269 $3,633 $131,269
813377 GREATER GREENSBURG $0 $3,631 $189,575 $3,631 $189,575
INDUSTRIAL CR UN.
832218 HOWLAND-ENFIELD $0 $3,628 $178,986 $3,628 $178,986
FEDERAL CREDIT UNIO.
822096 BORDER TRUST COMPANY $0 $3,625 $477,763 $3,625 $477,763
827735 BANK OF WHITMAN..... $0 $3,622 $324,650 $3,622 $324,650
831030 CENTRAL MINNESOTA $0 $3,589 $5,579 $3,589 $5,579
FCU.
810416 CITIZENS STATE BANK. $0 $3,572 $191,199 $3,572 $191,199
806529 STATE BANK OF $0 $3,569 $195,887 $3,569 $195,887
CHANDLER.
810900 THE HONDO NATIONAL $0 $3,547 $104,899 $3,547 $104,899
BANK.
832028 COLUMBIA-GREENE $0 $3,535 $180,814 $3,535 $180,814
FEDERAL CREDIT UNIO.
831655 NEWAYGO COUNTY $0 $3,532 $127,404 $3,532 $127,404
SERVICE ECU.
831407 KIMCENTRAL CREDIT $0 $3,516 $195,442 $3,516 $195,442
UNION.
812757 HEARTLAND STATE BANK $0 $3,514 $144,506 $3,514 $144,506
820105 COMMERCIAL BANK..... $0 $3,479 $202,322 $3,479 $202,322
832952 WOODLANDS CREDIT $0 $3,479 $315,372 $3,479 $315,372
UNION.
834184 FREEDOM CU.......... $0 $3,478 $328,244 $3,478 $328,244
813494 NORTHWEST SAVINGS $0 $3,476 $0 $3,476 $0
BANK.
833713 SOO LINE CREDIT $0 $3,475 $158,576 $3,475 $158,576
UNION.
833514 CUMCO FEDERAL CREDIT $0 $3,463 $178,168 $3,463 $178,168
UNION.
827203 SECURITY NATIONAL $0 $3,456 $17,063 $3,456 $17,063
LIFE INS CO.
828913 NORTHWEST SAVINGS $0 $3,450 $0 $3,450 $0
BANK.
805147 JPMORGAN CHASE BANK $0 $3,450 $47,278 $3,450 $47,278
NA.
813146 FAMILY COMMUNITY $0 $3,443 $131,890 $3,443 $131,890
CREDIT UNION.
831933 FIRST NATIONAL BANK $0 $3,416 $143,055 $3,416 $143,055
OF COKATO.
829210 ROANOKE POSTAL $0 $3,378 $3,378 $0
EMPLOYEES F C U.
832455 ROCKLAND S&L $0 $3,377 $181,265 $3,377 $181,265
ASSOCIATION.
830232 KENT CREDIT UNION... $0 $3,367 $199,843 $3,367 $199,843
832061 SOUTHEAST NEBRASKA $0 $3,364 $180,561 $3,364 $180,561
FEDERAL CREDIT U.
834147 HAWTHORNE CU........ $0 $3,358 $114,306 $3,358 $114,306
833801 OHIO VALLEY FCU..... $0 $3,349 $113,551 $3,349 $113,551
833534 MIDLAND CO-OP CREDIT $0 $3,345 $84,262 $3,345 $84,262
UNION.
820283 FIRST COMMONWEALTH $0 $3,337 $4,364 $3,337 $4,364
BANK.
820002 GOLDEN CIRCLE CREDIT $0 $3,336 $162,381 $3,336 $162,381
UNION INC.
834039 WELLS FARGO ELT $0 $3,335 $3,335 $0
AMERICAN OPTOMETRIC.
808435 SPIRIT OF AMERICA $0 $3,325 $186,424 $3,325 $186,424
FCU.
818790 POSTAL FEDERAL $0 $3,325 $187,297 $3,325 $187,297
COMMUNITY CREDIT
UNI.
819675 MINNWEST BANK SOUTH. $0 $3,321 $94,964 $3,321 $94,964
824329 AMARILLO COMMUNITY $0 $3,320 $195,705 $3,320 $195,705
FEDERAL CREDIT U.
805805 DOWN EAST FCU....... $0 $3,306 $216,231 $3,306 $216,231
810973 BRADY NATIONAL BANK. $0 $3,303 $219,154 $3,303 $219,154
832811 COMMUNITY RESOURCE $0 $3,295 $124,654 $3,295 $124,654
FCU.
831485 DUPONT GOODRICH FCU. $0 $3,292 $190,549 $3,292 $190,549
805735 THE COUNTY FEDERAL $0 $3,287 $199,112 $3,287 $199,112
CREDIT UNION.
832930 MONAD FEDERAL CREDIT $0 $3,274 $71,436 $3,274 $71,436
UNION.
832333 SYRACUSE FCU........ $0 $3,264 $195,790 $3,264 $195,790
829743 OAKLAND COUNTY $0 $3,262 $156,613 $3,262 $156,613
EMPLOYEES CU.
834185 US BANK ELT TX ASSC $0 $3,246 $1,153 $3,246 $1,153
COMM COLLEGES.
832912 BCE FEDERAL CREDIT $0 $3,244 $120,925 $3,244 $120,925
UNION.
804912 CREDIT UNION OF $0 $3,237 $235,180 $3,237 $235,180
AMERICA.
833822 IRCO COMMUNITY FCU.. $0 $3,223 $139,099 $3,223 $139,099
832940 MCKINNEY SCRANTON $0 $3,221 $124,668 $3,221 $124,668
FCU.
832873 CINCINNATI EMPLOYEES $0 $3,219 $179,989 $3,219 $179,989
CU.
832062 TCT FEDERAL CREDIT $0 $3,187 $182,543 $3,187 $182,543
UNION.
820130 MARKESAN STATE BANK. $0 $3,164 $101,536 $3,164 $101,536
832453 ST HELENS COMMUNITY $0 $3,161 $107,955 $3,161 $107,955
FEDERAL CREDIT.
806566 STEARNS BANK NA..... $0 $3,159 $110,435 $3,159 $110,435
833612 TRI-CO FEDERAL $0 $3,137 $227,005 $3,137 $227,005
CREDIT UNION.
820104 UNITY BANK.......... $0 $3,134 $135,619 $3,134 $135,619
828947 WYSE FEDERAL CREDIT $0 $3,132 $131,572 $3,132 $131,572
UNION.
821656 FIRST FEDERAL $0 $3,126 $158,292 $3,126 $158,292
SAVINGS & LOAN
ASSOCI.
832791 U S EMPLOYEES CREDIT $0 $3,116 $69,948 $3,116 $69,948
UNION.
806465 PEOPLES STATE BANK $0 $3,107 $233,897 $3,107 $233,897
OF WELLS.
828966 UNION ELECTRIC STEEL $0 $3,101 $3,101 $0
FED CREDIT UN.
810420 COMMUNITY BANK...... $0 $3,091 $130,073 $3,091 $130,073
832242 FOUNDERS FEDERAL $0 $3,083 $231,406 $3,083 $231,406
CREDIT UNION.
824911 FLOODWOOD AREA $0 $3,062 $57,136 $3,062 $57,136
CREDIT UNION.
815675 PALISADES FCU....... $0 $2,996 $176,454 $2,996 $176,454
832346 LONG REACH EMPLOYEES $0 $2,985 $98,605 $2,985 $98,605
FCU.
803928 CITIZENS STATE BANK. $0 $2,966 $93,780 $2,966 $93,780
819113 WEST MILTON STATE $0 $2,959 $0 $2,959 $0
BANK.
832209 MEMBERSTRUST CREDIT $0 $2,952 $112,967 $2,952 $112,967
UNION.
833125 FOUR FOUR CREDIT $0 $2,943 $174,551 $2,943 $174,551
UNION.
823113 JACKSON AREA FEDERAL $0 $2,937 $128,954 $2,937 $128,954
CREDIT UNION.
833712 1ST COMMUNITY FCU... $0 $2,933 $0 $2,933 $0
833715 BREWERY CREDIT UNION $0 $2,929 $156,642 $2,929 $156,642
810406 FIRST FIDELITY BANK. $0 $2,927 $0 $2,927 $0
822427 NORTH CENTRAL CREDIT $0 $2,927 $172,249 $2,927 $172,249
UNION.
833744 SHAMROCK FEDERAL $0 $2,911 $136,411 $2,911 $136,411
CREDIT UNION.
822056 SPRING MILL EMP FED $0 $2,904 $153,460 $2,904 $153,460
CR UNION.
829223 US FEDERAL CREDIT $0 $2,901 $187,738 $2,901 $187,738
UNION.
831910 NATIONAL BANK OF $0 $2,884 $112,197 $2,884 $112,197
ANDREWS.
828944 ESSA BANK & TRUST... $0 $2,884 $2,884 $0
814668 F&M BANK & TRUST.... $0 $2,882 $44,589 $2,882 $44,589
833867 UNITED BANK OF EL $0 $2,881 $2,881 $0
PASO NORTE.
822383 SHELBY STATE BANK... $0 $2,868 $172,143 $2,868 $172,143
833087 ST VINCENT HOSPITAL $0 $2,857 $175,348 $2,857 $175,348
EMPLOYEES' CU.
833279 PASADENA SERVICE FCU $0 $2,857 $177,434 $2,857 $177,434
834003 ZIONS BANK ELT $0 $2,829 $0 $2,829 $0
EDUCATION LOAN CO.
834143 ELK HORN BANK & $0 $2,816 $0 $2,816 $0
TRUST CO.
806399 GLENWOOD STATE BANK. $0 $2,805 $182,406 $2,805 $182,406
806258 FARMERS & MERCHANTS $0 $2,804 $130,599 $2,804 $130,599
STATE BANK.
831144 JP MORGANCHASE BANK. $0 $2,796 $0 $2,796 $0
825419 WITTENBERG $0 $2,791 $130,462 $2,791 $130,462
UNIVERSITY FCU.
832699 SELH FEDERAL CREDIT $0 $2,789 $122,278 $2,789 $122,278
UNION.
806477 UNITY BANK NORTH.... $0 $2,784 $97,912 $2,784 $97,912
800802 BOA STUDENT BANKING/ $0 $2,783 $0 $2,783 $0
CA9-169-04-01.
818870 COMMUNITY STATE BANK $0 $2,780 $2,780 $0
822147 TEXAS TRUST CREDIT $0 $2,776 $132,488 $2,776 $132,488
UNION.
834146 NORTH MEMORIAL FCU.. $0 $2,775 $84,105 $2,775 $84,105
828639 WEXFORD COMMUNITY CU $0 $2,747 $162,307 $2,747 $162,307
818340 GTE FCU............. $0 $2,742 $177,391 $2,742 $177,391
803925 CITIZENS BANK....... $0 $2,741 $177,748 $2,741 $177,748
820881 FIRST STATE BANK OF $0 $2,739 $146,899 $2,739 $146,899
ROSEMOUNT.
803068 IAA CREDIT UNION.... $0 $2,723 $42,327 $2,723 $42,327
830776 SIMPLY SERVICE FCU.. $0 $2,718 $117,288 $2,718 $117,288
833618 BIG BEAR/MEMBERS $0 $2,707 $159,520 $2,707 $159,520
FIRST CU.
834169 UNION BANK ELT NAT'L $0 $2,686 $231,540 $2,686 $231,540
ED LOAN NEW EN.
832541 HERITAGE FAMILY $0 $2,685 $181,911 $2,685 $181,911
CREDIT UNION.
833358 TWO HARBORS FCU..... $0 $2,685 $117,870 $2,685 $117,870
831548 CORUS BANK.......... $0 $2,685 $2,685 $0
832661 FAIRFAX COUNTY $0 $2,674 $175,120 $2,674 $175,120
FEDERAL CREDIT
UNION.
833133 UNITED NATIONS FCU.. $0 $2,672 $142,770 $2,672 $142,770
832999 BANGOR HYDRO FCU.... $0 $2,649 $147,969 $2,649 $147,969
832393 FIRST CHOICE CU..... $0 $2,646 $180,681 $2,646 $180,681
830782 SERVICES CENTER FCU. $0 $2,642 $129,126 $2,642 $129,126
803827 THE NAPOLEON STATE $0 $2,642 $143,752 $2,642 $143,752
BANK.
832098 RAVALLI COUNTY $0 $2,634 $194,655 $2,634 $194,655
FEDERAL CREDIT
UNION.
822654 MINER COUNTY BANK... $0 $2,627 $70,158 $2,627 $70,158
833743 RIVERVIEW FCU....... $0 $2,611 $117,572 $2,611 $117,572
823966 FALLS CITY NATIONAL $0 $2,605 $162,453 $2,605 $162,453
BANK.
832345 TEMPE SCHOOLS CREDIT $0 $2,603 $158,521 $2,603 $158,521
UNION.
832208 NORTHERN STAR CU INC $0 $2,602 $116,958 $2,602 $116,958
820753 BELLEVUE STATE BANK. $0 $2,594 $57,618 $2,594 $57,618
832233 CLEVELAND POLICE $0 $2,593 $110,699 $2,593 $110,699
CREDIT UNION INC.
832588 BUTTE COMMUNITY FCU. $0 $2,585 $105,820 $2,585 $105,820
832388 WHITE RIVER CREDIT $0 $2,573 $68,154 $2,573 $68,154
UNION.
832366 KENSINGTON VALLEY $0 $2,573 $128,128 $2,573 $128,128
COMM CU.
810499 MENNO STATE BANK.... $0 $2,557 $84,625 $2,557 $84,625
824462 PRIMESOURCE CREDIT $0 $2,552 $118,138 $2,552 $118,138
UNION.
817970 COULEE DAM FEDERAL $0 $2,552 $179,358 $2,552 $179,358
CREDIT UNION.
833549 SEBASTICOOK VALLEY $0 $2,549 $187,399 $2,549 $187,399
FCU.
828684 BAKER'S FEDERAL $0 $2,546 $110,484 $2,546 $110,484
CREDIT UNION.
833123 KENNEDY SPACE CENTER $0 $2,537 $130,955 $2,537 $130,955
FEDERAL CREDIT.
832295 ROCKY MT LAW $0 $2,536 $104,927 $2,536 $104,927
ENFORCEMENT FCU.
831131 STUDENT LOAN $0 $2,534 $146,673 $2,534 $146,673
MARKETING ASSN LOLR.
832168 NICKEL STEEL FEDERAL $0 $2,534 $86,351 $2,534 $86,351
CREDIT UNION.
833574 WABELLCO FEDERAL $0 $2,530 $150,316 $2,530 $150,316
CREDIT UNION.
833830 CCS FEDERAL CREDIT $0 $2,525 $119,535 $2,525 $119,535
UNION.
826538 VALLEY BANK......... $0 $2,524 $114,529 $2,524 $114,529
813161 SAINT FRANCIS X FCU. $0 $2,518 $110,560 $2,518 $110,560
829815 PARDA FEDERAL CREDIT $0 $2,516 $133,235 $2,516 $133,235
UNION.
833819 LOS ANGELES FIREMENS $0 $2,500 $180,955 $2,500 $180,955
CU.
831645 DAKOTALAND FCU...... $0 $2,497 $2,497 $0
830503 FLASHER COMMUNITY $0 $2,492 $148,604 $2,492 $148,604
CREDIT UNION.
832334 EXCELSIOR CREDIT $0 $2,488 $167,275 $2,488 $167,275
UNION.
815862 NEW ALLIANCE BANK... $0 $2,480 $2,480 $0
827367 MERRILL FEDERAL $0 $2,472 $173,337 $2,472 $173,337
SAVINGS & LOAN.
833969 GALLUP FEDERAL $0 $2,463 $72,036 $2,463 $72,036
CREDIT UNION.
832396 MEMBERS FIRST CREDIT $0 $2,454 $163,922 $2,454 $163,922
UNION OF NH.
828289 FIRST CREDIT UNION.. $0 $2,451 $101,555 $2,451 $101,555
832892 SPOKANE FEDERAL $0 $2,434 $149,585 $2,434 $149,585
CREDIT UNION.
832681 MIDWEST INDEPENDENT $0 $2,433 $51,784 $2,433 $51,784
BANK.
822454 FIRELANDS FEDERAL $0 $2,430 $111,206 $2,430 $111,206
CREDIT UNION.
832968 FIRST CATHOLIC FCU.. $0 $2,428 $183,229 $2,428 $183,229
833755 IRON COUNTY COMM CU. $0 $2,426 $151,347 $2,426 $151,347
832891 FIRST EAGLE FCU..... $0 $2,419 $148,570 $2,419 $148,570
832464 BATTLE CREEK POSTAL $0 $2,418 $92,191 $2,418 $92,191
CREDIT UNION.
823585 BENTON STATE BANK... $0 $2,416 $140,884 $2,416 $140,884
806251 EXCHANGE STATE BANK $0 $2,406 $81,428 $2,406 $81,428
OF HILLS.
833375 ATLANTIC CITY $0 $2,400 $158,385 $2,400 $158,385
ELECTRIC CO EFCU.
832773 NORTHWOOD CREDIT $0 $2,399 $82,993 $2,399 $82,993
UNION.
833787 ASSOCIATED CU OF TX. $0 $2,397 $166,807 $2,397 $166,807
833760 WILSERV CU.......... $0 $2,383 $163,691 $2,383 $163,691
806960 MONTANA STATE BANK.. $0 $2,378 $113,881 $2,378 $113,881
833566 VALLEY CREDIT UNION. $0 $2,373 $115,304 $2,373 $115,304
833758 PEOPLES CHOICE FCU.. $0 $2,370 $122,346 $2,370 $122,346
816474 GEORGIA METHODIST $0 $2,356 $122,644 $2,356 $122,644
FCU.
829918 AIR GUARD FEDERAL $0 $2,353 $103,958 $2,353 $103,958
CREDIT UNION.
817362 BLENCOE STATE BANK.. $0 $2,345 $149,803 $2,345 $149,803
809994 SWINEFORD NATIONAL $0 $2,328 $185,537 $2,328 $185,537
BANK.
832400 FREMONT FCU......... $0 $2,325 $215,391 $2,325 $215,391
833564 CLACKAMAS COMMUNITY $0 $2,322 $143,886 $2,322 $143,886
FCU.
806208 CITIZENS NATIONAL $0 $2,312 $77,065 $2,312 $77,065
BANK.
833304 FIRST FEDERAL SVINGS $0 $2,303 $152,521 $2,303 $152,521
& LOAN OF BATH.
827966 NSWC FEDERAL CREDIT $0 $2,296 $101,265 $2,296 $101,265
UNION.
832511 MUNICIPAL EMPLOYEES $0 $2,292 $120,490 $2,292 $120,490
& TEACHERS CU.
819788 BRAINERD B N CREDIT $0 $2,292 $72,002 $2,292 $72,002
UNION.
816976 MIDFIRST BANK....... $0 $2,291 $0 $2,291 $0
832361 CREDIT UNION OF THE $0 $2,286 $98,390 $2,286 $98,390
ROCKIES.
830160 SC STUDENT LOAN CORP $0 $2,282 $152,192 $2,282 $152,192
(TLP).
832647 FERGUSON FCU........ $0 $2,279 $159,989 $2,279 $159,989
829798 DAKOTA STAR FCU..... $0 $2,276 $71,093 $2,276 $71,093
817313 CME FEDERAL CREDIT $0 $2,270 $165,954 $2,270 $165,954
UNION.
808814 FIRST NATIONAL BANK $0 $2,262 $88,411 $2,262 $88,411
OF BELLEVUE.
832601 SAFE CREDIT UNION... $0 $2,257 $202,522 $2,257 $202,522
806949 DUTTON STATE BANK... $0 $2,257 $94,591 $2,257 $94,591
821876 FIRST STATE BANK.... $0 $2,255 $90,379 $2,255 $90,379
828793 METRO NORTH FCU..... $0 $2,254 $2,254 $0
829938 MAINE SAVINGS FCU... $0 $2,247 $2,247 $0
833014 CORRY AREA SCHOOLS $0 $2,243 $2,243 $0
FCU.
810816 FIRST TEXAS BANK.... $0 $2,223 $120,660 $2,223 $120,660
825104 WATERMARK CREDIT $0 $2,215 $151,282 $2,215 $151,282
UNION.
826936 NORTHEAST CREDIT $0 $2,214 $105,058 $2,214 $105,058
UNION.
833697 RIVERSIDE BEARER $0 $2,211 $91,776 $2,211 $91,776
COUNTY FCU.
833369 MINNEQUA WORKS $0 $2,196 $75,185 $2,196 $75,185
CREDIT UNION.
813390 KENNAMETAL EMPLOYEES $0 $2,193 $169,010 $2,193 $169,010
FEDERAL CREDIT.
831078 MEMBERS UNITED CU... $0 $2,192 $147,467 $2,192 $147,467
834022 OHIO CATHOLIC FCU... $0 $2,189 $107,649 $2,189 $107,649
829845 AMERICAN CREDIT $0 $2,177 $141,471 $2,177 $141,471
UNION--MILWAUKEE.
833966 UWSP CREDIT UNION... $0 $2,177 $2,177 $0
811577 AMERICAN LAKE CREDIT $0 $2,172 $172,133 $2,172 $172,133
UNION.
824825 GOLDEN PLAINS CREDIT $0 $2,168 $83,824 $2,168 $83,824
UNION.
832363 ST CLARES HOSPITAL $0 $2,167 $167,131 $2,167 $167,131
EFCU.
822051 SABATTUS REGIONAL $0 $2,165 $136,885 $2,165 $136,885
CREDIT UNION.
833949 ALLIANCE FCU........ $0 $2,160 $78,958 $2,160 $78,958
810439 FARMERS STATE BANK.. $0 $2,156 $116,496 $2,156 $116,496
826820 JUSTICE FEDERAL $0 $2,151 $133,065 $2,151 $133,065
CREDIT UNION.
805593 PEOPLES BANK OF $0 $2,146 $73,092 $2,146 $73,092
ELKTON.
832065 URW 831 COMMUNITY $0 $2,143 $86,591 $2,143 $86,591
FCU.
805899 EATON FEDERAL $0 $2,143 $112,968 $2,143 $112,968
SAVINGS BANK.
817575 ALLIANCE CREDIT $0 $2,142 $148,363 $2,142 $148,363
UNION.
819625 PORT CREDIT UNION... $0 $2,137 $174,307 $2,137 $174,307
833947 YORK EDUCATION FCU.. $0 $2,132 $148,918 $2,132 $148,918
834130 ST. PAUL FCU........ $0 $2,131 $138,159 $2,131 $138,159
819918 STATE BANK OF CROSS $0 $2,120 $0 $2,120 $0
PLAINS.
830502 INFINITY FEDERAL $0 $2,118 $2,118 $0
CREDIT UNION.
832164 ENER G COMM FEDERAL $0 $2,115 $109,966 $2,115 $109,966
CREDIT UNION.
832805 OUR FAMILY FEDERAL $0 $2,115 $2,115 $0
CREDIT UNION.
824716 UNITY ONE FEDERAL $0 $2,115 $107,595 $2,115 $107,595
CREDIT UNION.
828970 HAZELTON SCHOOL $0 $2,109 $2,109 $0
EMPLOYEES CR UN.
832755 MEDICAL EMPLOYEES CU $0 $2,108 $171,198 $2,108 $171,198
833000 PBC CU.............. $0 $2,107 $124,106 $2,107 $124,106
820879 RAY COOPERATIVE $0 $2,100 $37,661 $2,100 $37,661
CREDIT UNION.
832878 EAST TRAVERSE $0 $2,099 $136,613 $2,099 $136,613
CATHOLIC FCU.
832794 COMMUNITY FINANCIAL $0 $2,097 $146,735 $2,097 $146,735
CREDIT UNION.
832473 COLUMBINE FEDERAL $0 $2,096 $89,492 $2,096 $89,492
CREDIT UNION.
832166 KELLOGG COMPANY EFCU $0 $2,095 $129,698 $2,095 $129,698
832232 BAY AREA CREDIT $0 $2,090 $77,942 $2,090 $77,942
UNION INC.
832910 CITY CREDIT UNION... $0 $2,089 $139,957 $2,089 $139,957
833493 FIRST LOCKHART $0 $2,079 $81,717 $2,079 $81,717
NATIONAL BANK.
816128 DENVER FIRE DEPT FCU $0 $2,070 $122,346 $2,070 $122,346
833338 WESTEX FEDERAL $0 $2,064 $101,657 $2,064 $101,657
CREDIT UNION.
805088 FARMERS STATE BANK & $0 $2,061 $145,210 $2,061 $145,210
TRUST CO.
832236 LOS ANGELES FEDERAL $0 $2,058 $188,860 $2,058 $188,860
CREDIT UNION.
810004 FARMERS NAT'L BANK $0 $2,040 $129,162 $2,040 $129,162
OF NEWVILLE.
825043 SUPERIOR FCU........ $0 $2,038 $101,049 $2,038 $101,049
833547 AMERICAN 1 FCU...... $0 $2,035 $132,903 $2,035 $132,903
820891 NECEDAH BANK........ $0 $2,034 $107,914 $2,034 $107,914
813157 PENINSULA FEDERAL $0 $2,032 $0 $2,032 $0
CREDIT UNION.
826512 ADVANTAGE BANK...... $0 $2,027 $233,167 $2,027 $233,167
834252 LINDENWOOD $0 $2,021 $0 $2,021 $0
UNIVERSITY.
833215 GREAT FALLS REGIONAL $0 $2,017 $120,745 $2,017 $120,745
FCU.
832444 NORTHWEST ADVENTIST $0 $2,007 $71,753 $2,007 $71,753
FCU.
814435 JAX FEDERAL CREDIT $0 $2,006 $132,300 $2,006 $132,300
UNION.
808758 THE FARMERS & $0 $2,000 $207,362 $2,000 $207,362
MERCHANTS BANK.
833811 TYCO FCU............ $0 $1,991 $58,865 $1,991 $58,865
827438 MIDLAND FEDERAL S&L. $0 $1,990 $124,214 $1,990 $124,214
806232 CLINTON STATE BANK.. $0 $1,985 $89,024 $1,985 $89,024
831120 INNER LAKES FEDERAL $0 $1,981 $93,425 $1,981 $93,425
CREDIT UNION.
833381 LOS ANGELES POLICE $0 $1,980 $149,418 $1,980 $149,418
FCU.
818576 OAHE FEDERAL CREDIT $0 $1,972 $109,428 $1,972 $109,428
UNION.
833467 GENCO FEDERAL CREDIT $0 $1,970 $64,537 $1,970 $64,537
UNION.
832227 SKY FCU............. $0 $1,968 $132,486 $1,968 $132,486
824919 CATHOLIC FEDERAL $0 $1,968 $1,968 $0
CREDIT UNION.
823823 ANNANDALE STATE BANK $0 $1,962 $68,506 $1,962 $68,506
807025 WESTERN BANK OF WOLF $0 $1,949 $1,949 $0
POINT.
833800 CONCORD DIABLO FCU.. $0 $1,949 $156,110 $1,949 $156,110
821561 HAMLER STATE BANK... $0 $1,947 $132,904 $1,947 $132,904
825489 THE SAVINGS BANK.... $0 $1,929 $129,015 $1,929 $129,015
822613 CENTRAL PA SAVINGS $0 $1,922 $98,465 $1,922 $98,465
ASSOCIATION.
833692 PARTNERS FINANCIAL $0 $1,919 $109,416 $1,919 $109,416
FCU.
831596 APL FEDERAL CREDIT $0 $1,909 $96,746 $1,909 $96,746
UNION.
826625 NORTHLAND AREA $0 $1,904 $1,904 $0
FEDERAL CREDIT
UNION.
830301 RIVER CITY FEDERAL $0 $1,891 $90,561 $1,891 $90,561
CREDIT UNION.
816874 SOUTHEASTERN FEDERAL $0 $1,881 $121,487 $1,881 $121,487
CREDIT UNION.
827930 FIRST DAY FINANCIAL $0 $1,879 $140,923 $1,879 $140,923
CU.
819655 US EMPLOYEES OC FCU. $0 $1,877 $75,703 $1,877 $75,703
810738 AMEGY BANK NA....... $0 $1,867 $130,884 $1,867 $130,884
831750 BEACH MUNICIPAL EFCU $0 $1,863 $121,304 $1,863 $121,304
827044 COMMUNITY FIRST BANK $0 $1,861 $1,861 $0
832474 ALABAMA TELCO CREDIT $0 $1,853 $119,052 $1,853 $119,052
UNION.
804743 M&I BANK............ $0 $1,849 $36,974 $1,849 $36,974
826931 FIRST MIDWEST BANK $0 $1,849 $45,683 $1,849 $45,683
OF POPLAR BLUFF.
810123 M&T BANK EDUCATIONAL $0 $1,839 $1,839 $0
LENDING.
832518 FIRST COMMERCIAL $0 $1,833 $0 $1,833 $0
BANK N A.
833343 BLUEBONNET FEDERAL $0 $1,822 $123,404 $1,822 $123,404
CREDIT UNION.
829836 NORTHWEST GEORGIA $0 $1,820 $133,964 $1,820 $133,964
CREDIT UNION.
833059 OKLAHOMA STUDENT $0 $1,812 $100,840 $1,812 $100,840
LOAN AUTHORITY.
814827 AIR ACADEMY FCU..... $0 $1,806 $50,532 $1,806 $50,532
832298 DELTA COUNTY FCU.... $0 $1,779 $79,742 $1,779 $79,742
828737 COUNTYWIDE FEDERAL $0 $1,775 $63,529 $1,775 $63,529
CREDIT UNION.
832814 MALHEUR FEDERAL $0 $1,773 $96,657 $1,773 $96,657
CREDIT UNION.
832266 ABNB FCU............ $0 $1,772 $125,053 $1,772 $125,053
833532 SHAMROCK BANK....... $0 $1,770 $77,567 $1,770 $77,567
826830 FIRST SOUTH CU...... $0 $1,764 $126,395 $1,764 $126,395
830989 LAKESIDE CREDIT $0 $1,758 $122,284 $1,758 $122,284
UNION.
831978 MICHIGAN CATHOLIC CU $0 $1,755 $60,044 $1,755 $60,044
833476 PLYMOUTH COUNTY $0 $1,754 $128,712 $1,754 $128,712
TEACHERS FCU.
810398 ANDES STATE BANK.... $0 $1,745 $77,571 $1,745 $77,571
815584 NORTH ALABAMA $0 $1,742 $54,976 $1,742 $54,976
EDUCATORS CU.
832276 SEASONS FCU......... $0 $1,734 $90,134 $1,734 $90,134
826094 MONTANA FIRST CREDIT $0 $1,727 $1,727 $0
UNION.
817326 HANCOCK COUNTY $0 $1,720 $2,564 $1,720 $2,564
SAVINGS BANK FSB.
832312 ROME TEACHERS FCU... $0 $1,719 $102,479 $1,719 $102,479
832700 ROANOKE COUNTY $0 $1,718 $98,714 $1,718 $98,714
SCHOOL EFCU.
814657 LOUISIANA CATHOLIC $0 $1,707 $70,109 $1,707 $70,109
FCU.
827945 MASON NATIONAL BANK. $0 $1,701 $52,907 $1,701 $52,907
815517 MEMBERS FIRST CU OF $0 $1,694 $104,428 $1,694 $104,428
FLORIDA.
832162 BUFFALO FIRE $0 $1,691 $101,101 $1,691 $101,101
DEPARTMENT FCU.
818163 COMTRUST FCU........ $0 $1,689 $175,823 $1,689 $175,823
806947 DANIELS-SHERIDAN FCU $0 $1,683 $46,113 $1,683 $46,113
831556 MCCONE COUNTY FCU... $0 $1,674 $72,554 $1,674 $72,554
804078 HOME STATE BANK..... $0 $1,673 $70,115 $1,673 $70,115
831764 GREATER MILWAUKEE CU $0 $1,673 $121,972 $1,673 $121,972
818170 FARGO VA FEDERAL $0 $1,672 $62,936 $1,672 $62,936
CREDIT UNION.
818120 FERGUS COUNTY $0 $1,671 $80,421 $1,671 $80,421
FEDERAL CREDIT
UNION.
832735 ARLINGTON VIRGINIA $0 $1,662 $78,865 $1,662 $78,865
FCU.
829529 VAN CORTLANDT COOP $0 $1,643 $95,774 $1,643 $95,774
FCU.
824001 WEST SPRINGFIELD FCU $0 $1,641 $87,004 $1,641 $87,004
823366 HEW EMPLOYEES FCU... $0 $1,641 $5,013 $1,641 $5,013
830918 TURTLE CREEK FEDERAL $0 $1,640 $85,299 $1,640 $85,299
CREDIT UNION.
832628 HOPKINS SCHOOLS $0 $1,633 $84,194 $1,633 $84,194
CREDIT UNION.
834139 FRANKLIN COUNTY $0 $1,633 $137,025 $1,633 $137,025
TEACHERS CU.
833481 COSDEN EMPLOYEES $0 $1,631 $48,583 $1,631 $48,583
FEDERAL CREDIT UNI.
813776 VERMONT STATE $0 $1,630 $163,517 $1,630 $163,517
EMPLOYEES CREDIT
UNIO.
832468 COMMUNITY EDUCATORS $0 $1,629 $102,193 $1,629 $102,193
CREDIT UNION.
832860 TELEPHONE CREDIT $0 $1,626 $112,165 $1,626 $112,165
UNION OF NEW HAMPS.
833823 HIGHGROVE COMMUNITY $0 $1,624 $96,336 $1,624 $96,336
FCU.
833706 COMO NORTHTOWN COMM $0 $1,623 $58,720 $1,623 $58,720
CU.
832564 SCHOOL DISTRICT #3 $0 $1,618 $64,738 $1,618 $64,738
FCU.
814667 UNISTAR FEDERAL $0 $1,617 $90,202 $1,617 $90,202
CREDIT UNION.
832321 YAVAPAI FEDERAL $0 $1,615 $42,992 $1,615 $42,992
CREDIT UNION.
818365 ATLANTIC COAST $0 $1,612 $120,309 $1,612 $120,309
CREDIT UNION.
833826 HARLINGEN AREA $0 $1,612 $65,316 $1,612 $65,316
TEACHERS FCU.
833782 BOWDOINHAM FCU...... $0 $1,608 $61,769 $1,608 $61,769
819311 BAY ATLANTIC FCU.... $0 $1,605 $87,068 $1,605 $87,068
829217 BANK OF SALEM....... $0 $1,601 $40,369 $1,601 $40,369
832670 EPA CREDIT UNION.... $0 $1,594 $70,431 $1,594 $70,431
816570 MIDSOUTH FEDERAL $0 $1,587 $94,114 $1,587 $94,114
CREDIT UNION.
832941 PENNSTAR FCU........ $0 $1,559 $1,559 $0
828512 EMERALD GROUP CU INC $0 $1,558 $75,318 $1,558 $75,318
828080 WCTA FEDERAL CREDIT $0 $1,557 $250,377 $1,557 $250,377
UNION.
810723 BIG SPRING EDUCATION $0 $1,556 $77,018 $1,556 $77,018
EFCU.
818831 AMERICA'S CHRISTIAN $0 $1,552 $94,788 $1,552 $94,788
CREDIT UNION.
832909 CASCADE COMMUNITY $0 $1,551 $91,351 $1,551 $91,351
FCU.
832424 COMMUNITY 1 FCU..... $0 $1,544 $61,988 $1,544 $61,988
832463 HARVEST FEDERAL CU.. $0 $1,540 $59,458 $1,540 $59,458
811938 ASSOCIATED BANK NA.. $0 $1,536 $1,536 $0
810522 ROBERTS COUNTY $0 $1,529 $96,395 $1,529 $96,395
NATIONAL BANK OF
SIS.
827544 CONTINENTAL NATIONAL $0 $1,529 $60,745 $1,529 $60,745
BANK.
833521 STRUTHERS FCU....... $0 $1,528 $61,891 $1,528 $61,891
830673 COUNTY CREDIT UNION. $0 $1,527 $95,943 $1,527 $95,943
833516 SUN PACIFIC FEDERAL $0 $1,526 $113,905 $1,526 $113,905
CREDIT UNION.
832827 CHESHIRE COUNTY FCU. $0 $1,525 $53,546 $1,525 $53,546
833379 FORT SNELLING FCU... $0 $1,519 $85,935 $1,519 $85,935
833023 TELEPHONE WORKERS $0 $1,519 $102,622 $1,519 $102,622
CREDIT UNION.
832108 KEMBA FINANCIAL CU.. $0 $1,519 $156,222 $1,519 $156,222
827064 LA CAPITOL FEDERAL $0 $1,517 $108,630 $1,517 $108,630
CREDIT UNION.
834138 WELLS FARGO ELT $0 $1,513 $1,513 $0
CALIFORNIA DENTAL A.
834122 MOUNTAIN HIGH FCU... $0 $1,511 $86,267 $1,511 $86,267
833391 COOS EDUCATORS $0 $1,508 $40,780 $1,508 $40,780
FEDERAL CREDIT
UNION.
822169 FIRST FEDERAL $0 $1,505 $37,454 $1,505 $37,454
SAVINGS & LOAN ASSO.
822927 ADVANTAGE BANK...... $0 $1,501 $19,348 $1,501 $19,348
819591 CELCO FEDERAL CREDIT $0 $1,493 $64,772 $1,493 $64,772
UNION.
831783 COMMUNITY CHOICE $0 $1,493 $26,776 $1,493 $26,776
CREDIT UNION.
828811 GREATER TEXAS FCU... $0 $1,492 $105,370 $1,492 $105,370
830500 GRANT COUNTY $0 $1,492 $71,864 $1,492 $71,864
COMMUNITY FCU.
833829 MPO FCU............. $0 $1,492 $96,850 $1,492 $96,850
833234 MARTIN FEDERAL $0 $1,486 $58,788 $1,486 $58,788
CREDIT UNION.
833550 THE RICHMOND POSTAL $0 $1,483 $113,406 $1,483 $113,406
CU.
827781 OAK TRUST CU........ $0 $1,472 $117,060 $1,472 $117,060
819366 FIRST STATE BANK OF $0 $1,469 $38,875 $1,469 $38,875
CLAREMONT.
825247 EASTERN PITTSBURGH $0 $1,466 $79,482 $1,466 $79,482
BELL FEDERAL C U.
832925 KONE EMPLOYEES $0 $1,460 $111,006 $1,460 $111,006
CREDIT UNION.
833409 HIGH PEAKS FCU...... $0 $1,460 $52,654 $1,460 $52,654
831888 DACOTAH FEDERAL $0 $1,457 $82,810 $1,457 $82,810
CREDIT UNION.
833473 POINT LOMA CREDIT $0 $1,453 $90,270 $1,453 $90,270
UNION.
812091 SOUTH JERSEY FCU.... $0 $1,450 $1,450 $0
815469 FAMILY SECURITY $0 $1,446 $116,606 $1,446 $116,606
CREDIT UNION.
826236 ALLIANCE CREDIT $0 $1,440 $94,321 $1,440 $94,321
UNION.
828760 M & T BANK $0 $1,418 $1,418 $0
EDUCATIONAL LENDING.
806562 F & M BANK OF $0 $1,412 $49,773 $1,412 $49,773
SPRINGFIELD MORGAN
O.
826201 POSTAL FAMILY $0 $1,411 $113,771 $1,411 $113,771
FEDERAL CREDIT
UNION.
817766 RICHLAND FEDERAL $0 $1,410 $79,128 $1,410 $79,128
CREDIT UNION.
832239 MIDWEST UNITED $0 $1,407 $64,918 $1,407 $64,918
CREDIT UNION.
813618 FREEPORT STATE BANK-- $0 $1,401 $72,757 $1,401 $72,757
STEVE NOTCH.
834032 TITAN FCU........... $0 $1,399 $105,301 $1,399 $105,301
833219 FIRST BRISTOL $0 $1,396 $63,866 $1,396 $63,866
FEDERAL CREDIT
UNION.
833696 CALAIS FEDERAL S&L.. $0 $1,380 $140,864 $1,380 $140,864
833716 LEHIGH VALLEY FCU... $0 $1,378 $75,060 $1,378 $75,060
818644 WESTERN DAKOTA BANK. $0 $1,377 $50,252 $1,377 $50,252
832280 MEMBERS CREDIT UNION $0 $1,374 $197,504 $1,374 $197,504
833427 SARASOTA COASTAL CU. $0 $1,373 $86,411 $1,373 $86,411
833539 BAYOU FEDERAL CREDIT $0 $1,370 $32,153 $1,370 $32,153
UNION.
832261 MCAS BEAUFORT CREDIT $0 $1,348 $67,064 $1,348 $67,064
UNION.
834008 HIGH DESERT FCU..... $0 $1,341 $42,362 $1,341 $42,362
831966 TRANSMISSION $0 $1,337 $36,846 $1,337 $36,846
BUILDERS FEDERAL
CREDI.
834031 NEIGHBORS FCU....... $0 $1,328 $38,983 $1,328 $38,983
833559 N. MASS TELEPHONE $0 $1,328 $91,035 $1,328 $91,035
WORKERS CU.
830400 COLONIAL SAVINGS F A $0 $1,324 $76,290 $1,324 $76,290
833747 ATLANTIC FCU........ $0 $1,321 $133,331 $1,321 $133,331
810446 FARMERS STATE BANK.. $0 $1,313 $1,313 $0
833635 CENTRAL STAR CREDIT $0 $1,313 $54,394 $1,313 $54,394
UNION.
805737 CASCO FEDERAL CREDIT $0 $1,298 $97,687 $1,298 $97,687
UNION.
831997 BANK OF EASTERN $0 $1,295 $162,380 $1,295 $162,380
IDAHO.
832521 COLLEGEDALE CREDIT $0 $1,295 $67,659 $1,295 $67,659
UNION.
833303 BULLDOG FEDERAL $0 $1,293 $72,072 $1,293 $72,072
CREDIT UNION.
833437 1ST UNIVERSITY CU $0 $1,291 $1,291 $0
GARY PARKER.
833775 EAST OHIO UNITED $0 $1,288 $80,458 $1,288 $80,458
METHODIST CONF CU.
828845 FBC FCU............. $0 $1,283 $1,283 $0
834254 FIFTH THIRD ELT $0 $1,256 $0 $1,256 $0
STUDENT LEND WORKS.
825033 MN HIGHER EDUCATION $0 $1,254 $127,227 $1,254 $127,227
SERVICES OFFICE.
828482 SECURITY BANK....... $0 $1,254 $1,254 $0
824122 WISCOR CREDIT UNION. $0 $1,250 $75,351 $1,250 $75,351
810488 FT RANDALL FEDERAL $0 $1,250 $76,502 $1,250 $76,502
CREDIT UNION.
831508 CONSUMERS FEDERAL $0 $1,243 $45,209 $1,243 $45,209
CREDIT UNION.
832394 ACCO PRINCETON FCU.. $0 $1,242 $91,554 $1,242 $91,554
815822 ALCOA PITTSBURGH FCU $0 $1,231 $81,865 $1,231 $81,865
833144 KEY BANK NA......... $0 $1,226 $1,635,695 $1,226 $1,635,695
821866 M&I BANK FSB........ $0 $1,224 $72,137 $1,224 $72,137
833039 AMALGAMATED CREDIT $0 $1,221 $85,125 $1,221 $85,125
UNION.
823688 FIRST SECURITY BANK $0 $1,214 $63,200 $1,214 $63,200
OF ROUNDUP.
800023 WACHOVIA BANK NA.... $0 $1,209 $1,209 $0
818749 FIRST TRUST AND $0 $1,208 $66,302 $1,208 $66,302
SAVINGS BANK.
832344 PENOBSCOT FCU....... $0 $1,206 $86,781 $1,206 $86,781
833177 U A L U FCU......... $0 $1,199 $1,199 $0
832121 EXTRACO BANKS N.A$0. $1,198 $59,414 $1,198 $59,414
810485 FIRST STATE BANK OF $0 $1,195 $43,454 $1,195 $43,454
WARNER.
801943 SPACE AGE FEDERAL $0 $1,190 $82,933 $1,190 $82,933
CREDIT UNION.
833470 SANTA ANA FCU....... $0 $1,185 $77,799 $1,185 $77,799
832146 TOLEDO METRO FEDERAL $0 $1,185 $81,869 $1,185 $81,869
CREDIT UNION.
815953 SUNRISE BANK DAKOTA. $0 $1,184 $60,432 $1,184 $60,432
830713 WOODSTONE CREDIT $0 $1,182 $67,877 $1,182 $67,877
UNION.
828873 WASHINGTON TELEPHONE $0 $1,182 $83,943 $1,182 $83,943
FCU.
829535 WOLF POINT FEDERAL $0 $1,181 $49,561 $1,181 $49,561
CREDIT UNION.
834080 FULTON BANK......... $0 $1,177 $51,315 $1,177 $51,315
824700 SANBORN SAVINGS BANK $0 $1,175 $18,938 $1,175 $18,938
810444 FARMERS STATE BANK.. $0 $1,173 $0 $1,173 $0
818417 LACAMAS COMMUNITY $0 $1,172 $54,712 $1,172 $54,712
CREDIT UNION.
806268 EASTWOOD BANK-- $0 $1,171 $0 $1,171 $0
ROCHESTER.
833690 NORTHERN LIGHTS FCU. $0 $1,171 $1,171 $0
825297 CORTRUST BANK....... $0 $1,165 $1,165 $0
833629 CHOCOLATE BAYOU COMM $0 $1,161 $71,170 $1,161 $71,170
FCU.
832851 KNOXVILLE POST $0 $1,155 $33,554 $1,155 $33,554
OFFICE CREDIT UNION.
832972 GESA CU............. $0 $1,146 $61,501 $1,146 $61,501
804538 FIRST NATIONAL BANK $0 $1,146 $1,146 $0
OF OLATHE.
832297 SOUTH CAROLINA TELCO $0 $1,137 $48,947 $1,137 $48,947
FCU.
833468 MEADOWS CREDIT UNION $0 $1,136 $65,996 $1,136 $65,996
832419 STAMFORD CREDIT $0 $1,133 $100,871 $1,133 $100,871
UNION INC.
803968 DUBUQUE BANK & TRUST $0 $1,132 $352 $1,132 $352
COMPANY.
832813 KASTCO CREDIT UNION. $0 $1,121 $1,121 $0
824210 ITT EMPLOYEES (FT $0 $1,119 $110,202 $1,119 $110,202
WAYNE DIV) FCU.
832969 JACKSON CITY COUNTY $0 $1,117 $40,103 $1,117 $40,103
CU.
813509 M & T BANK $0 $1,113 $31,832 $1,113 $31,832
EDUCATIONAL LENDING.
811010 WEST TEXAS STATE $0 $1,112 $5,829 $1,112 $5,829
BANK.
830849 ST VRAIN VALLEY $0 $1,110 $105,227 $1,110 $105,227
CREDIT UNION.
833060 CHELSEA EMPLOYEES $0 $1,109 $66,554 $1,109 $66,554
FCU.
805182 UNION BANK.......... $0 $1,105 $73,020 $1,105 $73,020
834038 OAK BANK............ $0 $1,102 $41,301 $1,102 $41,301
833577 AMERICA FAMILY FCU.. $0 $1,097 $6,625 $1,097 $6,625
833370 SCHOOL SYSTEMS $0 $1,096 $110,468 $1,096 $110,468
FEDERAL CREDIT
UNION.
832896 CWA LONG ISLAND FCU. $0 $1,095 $84,543 $1,095 $84,543
809444 DOWNINGTOWN NATIONAL $0 $1,093 $1,093 $0
BANK.
834200 ARMSTRONG ASSOCIATES $0 $1,087 $94,680 $1,087 $94,680
FCU.
833606 LEADERS CREDIT UNION $0 $1,086 $32,225 $1,086 $32,225
819542 THINK FCU........... $0 $1,080 $1,080 $0
832336 CONSUMERS $0 $1,072 $70,252 $1,072 $70,252
PROFESSIONAL CU.
812141 FARMERS EXCHANGE $0 $1,066 $44,946 $1,066 $44,946
BANK.
810886 GRAHAM NATIONAL BANK $0 $1,064 $42,512 $1,064 $42,512
828033 FIRST NATIONAL BANK $0 $1,063 $0 $1,063 $0
OF LEESPORT.
833272 ALAMEDA CREDIT UNION $0 $1,054 $32,197 $1,054 $32,197
832971 BEACON FEDERAL...... $0 $1,053 $69,174 $1,053 $69,174
829797 SENTINEL FEDERAL $0 $1,045 $0 $1,045 $0
CREDIT UNION.
818491 PEOPLES STATE BANK.. $0 $1,045 $1,045 $0
832828 ALTOONA VEEDER ROOT $0 $1,020 $1,020 $0
FCU.
800016 FIRST EDUCATORS $0 $1,018 $79,279 $1,018 $79,279
CREDIT UNION.
806262 FARMERS & MERCHANTS $0 $1,005 $60,158 $1,005 $60,158
STATE BANK OF N.
819915 ASSOCIATED BANK NA.. $0 $1,005 $1,005 $0
822318 CABOT & NOI $0 $997 $41,267 $997 $41,267
EMPLOYEES CREDIT
UNION.
833855 BETHEX FCU.......... $0 $996 $996 $0
833092 KEY BANK NA......... $0 $994 $1,487,965 $994 $1,487,965
817071 GREATER NORWALK AREA $0 $993 $61,969 $993 $61,969
CREDIT UNION.
819665 FIRST LIGHT FCU..... $0 $991 $58,136 $991 $58,136
833429 PARK COMMUNITY FCU.. $0 $988 $58,697 $988 $58,697
833448 CSC EMPLOYEE'S $0 $987 $106,911 $987 $106,911
FEDERAL CREDIT
UNION.
832284 REMINGTON ARMS FCU.. $0 $978 $68,144 $978 $68,144
801897 FITZSIMONS COMMUNITY $0 $977 $59,241 $977 $59,241
FCU.
806345 THE FIRST NATIONAL $0 $973 $30,250 $973 $30,250
BANK OF HENNING.
833862 NORTH CAROLINA LOCAL $0 $972 $29,959 $972 $29,959
GOVERNMENT EFC.
828871 SAGELINK CU......... $0 $972 $41,274 $972 $41,274
802968 REGIONS BANK........ $0 $972 $972 $0
832639 LIBERTY ALLIANCE FCU $0 $969 $91,824 $969 $91,824
834155 PETIT JEAN STATE $0 $969 $0 $969 $0
BANK.
833718 GLENDALE AREA SCHOOL $0 $966 $23,246 $966 $23,246
FCU.
815849 FARMINGTON SAVINGS $0 $965 $965 $0
BANK.
806548 STATE BANK OF LAKE $0 $960 $31,625 $960 $31,625
PARK.
831356 UNITED METHODIST $0 $956 $956 $0
FIRST CHOICE FCU.
828386 DEACON CU........... $0 $955 $32,590 $955 $32,590
833871 STANDARD STEEL EFCU. $0 $953 $70,419 $953 $70,419
833129 ACCO YORK FCU....... $0 $951 $65,251 $951 $65,251
832528 NORTHWEST RESOURCE $0 $944 $42,343 $944 $42,343
FCU.
832514 MISSION PARTNERS $0 $942 $72,822 $942 $72,822
EMPLOYEES CREDIT U.
832608 CTECU............... $0 $937 $33,086 $937 $33,086
833894 MONONGAHELA VALLEY $0 $935 $53,405 $935 $53,405
FCU.
830632 SHARE ADVANTAGE $0 $934 $78,581 $934 $78,581
CREDIT UNION.
817132 WATERBURY CT $0 $930 $3,750 $930 $3,750
TEACHERS FED CR
UNION.
818185 ASSOCIATED BANK NA.. $0 $924 $924 $0
832272 FLOWER CITY FCU..... $0 $918 $26,043 $918 $26,043
830464 HEALTHCARE PLUS FED $0 $917 $917 $0
CREDIT UNION.
832815 MONTCLAIR POSTAL EMP $0 $917 $32,347 $917 $32,347
CU.
813125 ALPENA ALCONA AREA $0 $914 $10,495 $914 $10,495
CREDIT UNION.
833615 MEMBERS CHOICE $0 $906 $64,552 $906 $64,552
CREDIT UNION.
829820 GABRIELS COMMUNITY $0 $903 $48,987 $903 $48,987
CU.
832649 ALLEGHENY-KISKI $0 $902 $902 $0
POSTAL FCU.
817854 ARSENAL CREDIT UNION $0 $900 $11,250 $900 $11,250
833777 NCPD FEDERAL CREDIT $0 $900 $53,583 $900 $53,583
UNION.
828286 MIDWEST PARTNERS FED $0 $899 $53,439 $899 $53,439
CREDIT UNION.
833593 THE COCA-COLA CO $0 $898 $33,678 $898 $33,678
FAMILY FCU.
830640 NAPUS FEDERAL CREDIT $0 $897 $59,928 $897 $59,928
UNION.
833185 FIRST CLASS AMERICAN $0 $895 $37,817 $895 $37,817
CREDIT UNION.
820213 TAHQUAMENON AREA $0 $893 $59,632 $893 $59,632
CREDIT UNION.
804655 GREENSBURG STATE $0 $892 $54,716 $892 $54,716
BANK.
806260 MINNWEST BANK SOUTH. $0 $892 $892 $0
833404 STERLING BANK....... $0 $890 $890 $0
806406 JANESVILLE STATE $0 $887 $35,490 $887 $35,490
BANK.
816082 MUTUAL SAVINGS $0 $883 $36,339 $883 $36,339
CREDIT UNION.
831022 L. C. E. FEDERAL $0 $880 $39,863 $880 $39,863
CREDIT UNION.
819203 COMMUNITY STATE BANK $0 $880 $36,078 $880 $36,078
832770 MISSOURI VALLEY $0 $877 $17,690 $877 $17,690
FEDERAL CREDIT UNIO.
831362 IEC FEDERAL CREDIT $0 $871 $48,952 $871 $48,952
UNION.
832857 UMASS/FIVE COLLEGE $0 $862 $80,997 $862 $80,997
FCU.
824924 OHIO UNIVERSITY CU.. $0 $858 $65,803 $858 $65,803
819630 GREAT PLAINS BANK... $0 $856 $47,388 $856 $47,388
828311 THE UNION BANKING $0 $856 $56,202 $856 $56,202
COMPANY.
833776 SANTA MONICA SCHOOLS $0 $855 $44,027 $855 $44,027
EMPLOYEES FEDE.
810492 IPSWICH STATE BANK.. $0 $855 $0 $855 $0
833401 NORTHERN SCHOOLS FCU $0 $854 $33,981 $854 $33,981
827501 NEBRASKA STATE $0 $854 $50,397 $854 $50,397
EMPLOYEES CREDIT
UNI.
832533 GWINNETT FCU........ $0 $854 $57,174 $854 $57,174
802160 FAIRFIELD COUNTY $0 $853 $71,553 $853 $71,553
CREDIT UNION.
808616 THE FIRST NATIONAL $0 $847 $48,659 $847 $48,659
BANK OF SYCAMORE.
816266 STATE BANK OF LUCAN. $0 $847 $15,357 $847 $15,357
832665 QUIMPER COMMUNITY $0 $843 $56,192 $843 $56,192
FCU.
827666 NORTH JERSEY FEDERAL $0 $841 $83,375 $841 $83,375
CREDIT UNION.
818179 ASSOCIATED BANK NA.. $0 $840 $840 $0
833929 GALLERIA CU......... $0 $839 $30,995 $839 $30,995
832392 WEYERHAEUSER CREDIT $0 $818 $61,320 $818 $61,320
UNION.
828925 MEM FCU............. $0 $815 $63,927 $815 $63,927
820970 SIOUX FALLS BELL $0 $811 $811 $0
FEDERAL CREDIT UNI.
813411 COMMERCIAL BANK & $0 $808 $0 $808 $0
TRUST OF PA.
833767 PARKS HERITAGE FCU.. $0 $807 $70,962 $807 $70,962
833763 MINNWEST BANK SIOUX $0 $806 $44,389 $806 $44,389
FALLS.
832507 MERCER COUNTY NJ $0 $803 $59,109 $803 $59,109
TEACHERS FCU.
822591 TIC FEDERAL CREDIT $0 $803 $66,704 $803 $66,704
UNION.
831640 STUDENT LOAN FUNDING $0 $802 $13,889 $802 $13,889
US BANK ELT.
833450 SEMC FEDERAL CREDIT $0 $801 $58,702 $801 $58,702
UNION.
826526 RIVER VALLEY CREDIT $0 $800 $800 $0
UNION.
833665 CATSKILL REGIONAL $0 $798 $65,600 $798 $65,600
FCU.
813953 ELKHORN FEDERAL $0 $796 $796 $0
CREDIT UNION.
833704 THE BANK OF THE RIO $0 $795 $38,745 $795 $38,745
GRANDE NA.
832795 HOLY CROSS HOSPITAL $0 $792 $43,951 $792 $43,951
EMPLOYEES' CU.
830567 VACAP FEDERAL CREDIT $0 $787 $21,143 $787 $21,143
UNION.
806373 CENTER NATIONAL BANK $0 $787 $50,995 $787 $50,995
807581 BANK OF NEW YORK.... $0 $787 $0 $787 $0
832311 NYM FEDERAL CREDIT $0 $787 $41,858 $787 $41,858
UNION.
825280 AP FEDERAL CREDIT $0 $786 $41,969 $786 $41,969
UNION.
821891 OTERO FEDERAL CREDIT $0 $783 $46,518 $783 $46,518
UNION.
833362 FARMERS & MERCHANTS $0 $782 $782 $0
STATE BANK.
833336 HINGHAM FEDERAL $0 $779 $36,204 $779 $36,204
CREDIT UNION.
823866 RAYTOWN-LEE'S SUMMIT $0 $777 $28,361 $777 $28,361
COMMUNITY CRED.
817876 ARKANSAS EMPLOYEES $0 $775 $45,635 $775 $45,635
FCU.
825582 NJ GATEWAY FEDERAL $0 $772 $52,719 $772 $52,719
CREDIT UNION.
834054 ACCESS CU........... $0 $770 $19,703 $770 $19,703
806541 STATE BANK OF BIRD $0 $766 $45,966 $766 $45,966
ISLAND.
820136 GREATER ALLIANCE FCU $0 $765 $765 $0
820198 FIRST STATE BANK OF $0 $764 $152,108 $764 $152,108
MIDDLEBURY.
817718 GLOUCESTER COUNTY $0 $764 $40,123 $764 $40,123
FSB.
833951 EMSBLA CU........... $0 $761 $38,437 $761 $38,437
834240 US BANK ELT $0 $760 $84,227 $760 $84,227
COLLEGIATE
SOLUTIONS.
833845 HTM AREA CU......... $0 $758 $38,831 $758 $38,831
834175 FIRST FEDERAL....... $0 $758 $758 $0
832526 ADVANTIS CU......... $0 $757 $39,591 $757 $39,591
832308 LEWISTON MUNICIPAL $0 $753 $54,090 $753 $54,090
FEDERAL CREDIT U.
832761 ALHAMBRA CREDIT $0 $752 $0 $752 $0
UNION.
832489 ALABAMA TEACHERS CU. $0 $748 $40,773 $748 $40,773
832659 ALLEGANY COMMUNITY $0 $746 $45,322 $746 $45,322
FCU.
813989 BANK OF ROTHVILLE... $0 $743 $8,000 $743 $8,000
832246 LOUDOUN CREDIT UNION $0 $739 $26,950 $739 $26,950
820003 THE CORN CITY STATE $0 $736 $29,855 $736 $29,855
BANK.
833383 ROHM & HAAS MONUMENT $0 $732 $62,069 $732 $62,069
AREA FCU.
814151 SAINT AGATHA FEDERAL $0 $731 $731 $0
CREDIT UNION.
819119 EAST RIVER FCU...... $0 $729 $729 $0
833392 ROSWELL COMM FCU.... $0 $728 $26,752 $728 $26,752
832772 BELL CREDIT UNION... $0 $727 $56,617 $727 $56,617
830613 NORTH RIDGE $0 $726 $19,125 $726 $19,125
COMMUNITY CU.
832443 NORTHWEST COMMUNITY $0 $726 $726 $0
CU.
827310 SUN SECURITY BANK OF $0 $722 $722 $0
AMERICA.
833561 TRANSTAR FCU........ $0 $719 $68,600 $719 $68,600
832631 SPERRY MARINE FCU... $0 $717 $50,089 $717 $50,089
814459 FARMERS STATE BANK $0 $717 $717 $0
FLANDREAU SOUTH.
817801 FIRST UNITED BANK... $0 $716 $716 $0
832117 HEALTHCARE SYSTEMS $0 $705 $50,208 $705 $50,208
FEDERAL CREDIT U.
832618 MISSISSIPPI TELCO $0 $704 $29,783 $704 $29,783
FCU.
823745 BANK OF NEW CAMBRIA. $0 $703 $53,070 $703 $53,070
806089 PENINSULA BANK...... $0 $701 $43,809 $701 $43,809
832767 CATHOLIC PARISHES $0 $694 $37,637 $694 $37,637
FCU.
825545 GUARDIAN FEDERAL $0 $692 $39,729 $692 $39,729
CREDIT UNION.
830284 ARAPAHOE CREDIT $0 $687 $44,402 $687 $44,402
UNION.
832456 OREGON FIRST $0 $684 $52,845 $684 $52,845
COMMUNITY CU.
832849 I AND M (TANNERS $0 $683 $51,334 $683 $51,334
CREEK) EFCU.
830704 EASTERN NEW YORK FCU $0 $677 $30,858 $677 $30,858
833151 SPOKANE CITY CREDIT $0 $676 $48,660 $676 $48,660
UNION.
830347 CITIZENS STATE BANK $0 $669 $29,538 $669 $29,538
OF SHAKOPEE.
832252 CPM FEDERAL CREDIT $0 $669 $44,011 $669 $44,011
UNION.
834017 DEPARTMENT OF $0 $668 $57,293 $668 $57,293
COMMERCE FCU.
813774 VERMONT FEDERAL $0 $666 $74,105 $666 $74,105
CREDIT UNION.
804494 MARQUETTE FARMERS $0 $663 $65,256 $663 $65,256
STATE BANK.
833900 LINCOLN MAINE FCU... $0 $658 $40,094 $658 $40,094
803258 JPMORGAN CHASE BANK $0 $657 $0 $657 $0
NA.
833018 SECURITY ONE FCU.... $0 $653 $48,906 $653 $48,906
833632 ROCHESTER & MONROE $0 $651 $29,591 $651 $29,591
CTY FCU.
828942 UTI EMPLOYEES CREDIT $0 $650 $40,934 $650 $40,934
UNION.
832277 NORTH EAST ALLIANCE $0 $650 $45,598 $650 $45,598
FEDERAL CREDIT.
806219 FLAGSHIP BANK....... $0 $649 $19,625 $649 $19,625
832403 WESTERN REGION FED $0 $647 $10,463 $647 $10,463
CREDIT UNION.
832951 SEAPORT CU.......... $0 $646 $40,205 $646 $40,205
833939 FARM BUREAU BANK.... $0 $645 $24,125 $645 $24,125
832687 KC FAIRFAX FCU...... $0 $643 $47,425 $643 $47,425
833538 FIRST JERSEY CU..... $0 $640 $60,793 $640 $60,793
828444 BANK OF BROOKFIELD- $0 $639 $28,584 $639 $28,584
PURDIN N A.
832359 ISHPEMING COMMUNITY $0 $639 $41,260 $639 $41,260
FEDERAL CREDIT.
820377 FIRST BANK AND TRUST $0 $634 $634 $0
COMPANY.
831023 ALLEGHENY VALLEY FED $0 $633 $633 $0
CR UNION.
833367 CREDIT UNION OF NEW $0 $628 $23,358 $628 $23,358
JERSEY.
823635 HANNIBAL NATIONAL $0 $627 $627 $0
BANK.
829744 BALLINGER NATIONAL $0 $627 $3,937 $627 $3,937
BANK.
832269 SPENCERPORT FCU..... $0 $625 $22,367 $625 $22,367
832779 LEXINGTON AVENUE $0 $624 $41,163 $624 $41,163
FEDERAL CREDIT UNI.
832204 CAROLINA TRUST FCU.. $0 $624 $27,345 $624 $27,345
832310 FORT MCCLELLAN $0 $623 $26,609 $623 $26,609
CREDIT UNION.
820528 BENCHMARK CREDIT $0 $623 $103,540 $623 $103,540
UNION.
829440 LEGENDS BANK........ $0 $622 $9,250 $622 $9,250
832783 Bank @LANTEC........ $0 $620 $30,918 $620 $30,918
812747 STRAIT-VIEW CREDIT $0 $616 $41,918 $616 $41,918
UNION.
831365 WELCOME CREDIT UNION $0 $614 $121,533 $614 $121,533
832629 WOODCO FEDERAL $0 $612 $44,437 $612 $44,437
CREDIT UNION.
824104 LATVIAN CLEVELAND $0 $611 $21,146 $611 $21,146
CREDIT UNION.
833551 TEANECK FEDERAL $0 $604 $40,509 $604 $40,509
CREDIT UNION.
832604 NORTHEAST DENVER $0 $601 $49,089 $601 $49,089
FEDERAL CREDIT UNI.
804692 CREDIT UNION OF $0 $598 $42,792 $598 $42,792
JOHNSON COUNTY.
822774 SNYDER NATIONAL BANK $0 $595 $25,722 $595 $25,722
832118 TPS CREDIT UNION INC $0 $592 $60,276 $592 $60,276
834113 LUZERNE COUNTY FCU.. $0 $587 $47,260 $587 $47,260
832145 IBEW 76............. $0 $587 $41,518 $587 $41,518
825532 WATERFORD COMMERCIAL $0 $585 $39,199 $585 $39,199
& SAV BANK.
832983 TAYLOR COMMUNITY CU. $0 $579 $35,986 $579 $35,986
819447 VALLEYSTONE CU...... $0 $579 $35,694 $579 $35,694
833877 MINNESOTA MUTUAL $0 $578 $578 $0
COMPANIES CU.
832713 BARAGA COUNTY $0 $576 $25,812 $576 $25,812
FEDERAL CREDIT
UNION.
816050 BLUE RIDGE BANK AND $0 $574 $574 $0
TRUST CO.
831632 HUNTINGTON SCHOOLS $0 $572 $572 $0
FCU.
831219 VIRGINIA EDUCATORS' $0 $569 $0 $569 $0
CU.
834176 COMMUNITY SERVICE CU $0 $565 $27,143 $565 $27,143
832728 CHISHOLM TRAIL FCU.. $0 $564 $42,197 $564 $42,197
832019 TVA CU.............. $0 $562 $36,016 $562 $36,016
833906 KNOX COUNTY FCU..... $0 $557 $557 $0
805648 ALLIANCE OF MAINE $0 $555 $112,329 $555 $112,329
FCU.
833522 OK MEMBERS FIRST FCU $0 $553 $36,188 $553 $36,188
834135 UNITED POLICE FCU... $0 $552 $12,288 $552 $12,288
822490 JEFFERSON PARISH $0 $551 $23,087 $551 $23,087
EFCU.
833430 BN WEST CREDIT UNION $0 $548 $33,162 $548 $33,162
819099 SUN CREDIT UNION.... $0 $547 $38,813 $547 $38,813
832325 BENNINGTON COUNTY $0 $542 $542 $0
TEACHERS CREDIT U.
806407 KANABEC STATE BANK.. $0 $537 $38,552 $537 $38,552
810832 FIRST NATIONAL BANK $0 $537 $30,534 $537 $30,534
BELLVILLE.
834228 ARIZONA STATE $0 $537 $537 $0
UNIVERSITY.
832299 PROMEDICA FEDERAL $0 $535 $34,378 $535 $34,378
CREDIT UNION.
833229 BOULDER VALLEY $0 $533 $14,475 $533 $14,475
CREDIT UNION.
830060 PARIS NATIONAL BANK. $0 $526 $30,527 $526 $30,527
834284 SOUTHERN ILLINOIS $0 $519 $70,180 $519 $70,180
UNIVERSITY.
833541 UNIVERSAL FCU....... $0 $516 $0 $516 $0
832178 DEER LODGE COUNTY $0 $511 $511 $0
SCHOOL EFCU.
833590 WENATCHEE VALLEY FCU $0 $509 $40,009 $509 $40,009
806851 FOCUS BANK.......... $0 $508 $21,710 $508 $21,710
819564 FIRST NATIONAL BANK. $0 $507 $507 $0
833851 APPALACHIAN $0 $506 $37,778 $506 $37,778
COMMUNITY FCU.
832667 CHESTNUT COMMUNITY $0 $505 $32,838 $505 $32,838
CREDIT UNION.
833645 STARTRUST FCU....... $0 $505 $0 $505 $0
829464 UNITED FCU.......... $0 $501 $501 $0
832757 STREATOR ONIZED $0 $501 $30,979 $501 $30,979
CREDIT UNION.
811906 ASSOCIATED BANK NA.. $0 $499 $499 $0
826415 WANIGAS FEDERAL $0 $498 $14,009 $498 $14,009
CREDIT UNION.
832134 KOOTENAI VALLEY FCU. $0 $497 $15,917 $497 $15,917
832567 TLC FEDERAL CREDIT $0 $495 $27,762 $495 $27,762
UNION.
820889 BURGER FEDERAL $0 $494 $32,805 $494 $32,805
CREDIT UNION.
818422 FLORIDA COMMERCE $0 $494 $32,211 $494 $32,211
CREDIT UNION.
834109 FIRST BANK & TRUST $0 $493 $32,025 $493 $32,025
CO.
834053 MS FCU.............. $0 $488 $22,946 $488 $22,946
833684 BAYLANDS FCU........ $0 $481 $33,445 $481 $33,445
832434 LINN-CO FEDERAL $0 $479 $35,111 $479 $35,111
CREDIT UNION.
804146 REGIONS BANK........ $0 $478 $478 $0
833569 ILLINOIS VALLEY $0 $476 $21,528 $476 $21,528
CREDIT UNION.
831850 INDEPENDENT BANK.... $0 $475 $32,708 $475 $32,708
824858 BURBANK FEDERAL $0 $475 $26,910 $475 $26,910
CREDIT UNION.
820166 WESTAMERICA BANK.... $0 $474 $22,959 $474 $22,959
832924 CHADWICK FCU........ $0 $471 $48,819 $471 $48,819
832657 TAFT CARBIDE FCU.... $0 $470 $29,036 $470 $29,036
829095 SOUTHCOAST HEALTH $0 $467 $17,686 $467 $17,686
SYSTEM FCU.
820323 WEST COMMUNITY $0 $467 $13,250 $467 $13,250
CREDIT UNION.
834083 CORE ONE CU INC..... $0 $459 $459 $0
810538 PREMIER BANK........ $0 $458 $458 $0
831499 VANTRIA FEDERAL $0 $456 $55,297 $456 $55,297
CREDIT UNION.
832448 WALKER COUNTY $0 $455 $22,020 $455 $22,020
EDUCATORS FCU.
833714 COSTA MESA FCU...... $0 $454 $27,300 $454 $27,300
821966 US NEW MEXICO $0 $451 $28,101 $451 $28,101
FEDERAL CREDIT
UNION.
831015 SODES FEDERAL CREDIT $0 $451 $23,250 $451 $23,250
UNION.
833793 MILL TOWN CU........ $0 $450 $15,603 $450 $15,603
833425 DALLAS COUNTY CU.... $0 $450 $450 $0
807756 BANK OF AKRON....... $0 $449 $14,089 $449 $14,089
806810 COMMUNITY STATE BANK $0 $448 $11,597 $448 $11,597
833729 POSTEL FAMILY CREDIT $0 $446 $26,679 $446 $26,679
UNION.
816914 MILFORD FCU......... $0 $442 $41,674 $442 $41,674
833897 PRESIDENTS FEDERAL $0 $442 $54,636 $442 $54,636
CREDIT UNION.
824354 NORTH OAKLAND $0 $439 $34,891 $439 $34,891
COMMUNITY CREDIT
UNIO.
832469 ONE COMMUNITY FCU... $0 $438 $14,148 $438 $14,148
811948 ASSOCIATED BANK NA.. $0 $437 $437 $0
823469 PIONEER BANK........ $0 $437 $0 $437 $0
806747 BANK OF BELTON...... $0 $436 $23,063 $436 $23,063
804166 PEOPLES SAVINGS BANK $0 $435 $23,619 $435 $23,619
834056 AMBRIDGE SCHOOL $0 $426 $32,000 $426 $32,000
TEACHERS FCU.
833261 KINGSPORT PRESS $0 $426 $11,987 $426 $11,987
CREDIT UNION.
828130 PULASKI BANK........ $0 $426 $19,491 $426 $19,491
833192 STAR USA FEDERAL $0 $426 $18,613 $426 $18,613
CREDIT UNION.
824769 JOHNS HOPKINS $0 $426 $0 $426 $0
UNIVERSITY.
830571 ELECTRICAL WORKERS $0 $423 $20,966 $423 $20,966
CREDIT UNION.
833393 PINNACLE FCU........ $0 $420 $26,800 $420 $26,800
810437 FARMERS & MERCHANTS $0 $419 $419 $0
STATE BANK.
828642 ASCENSION SCHOOL ECU $0 $418 $24,189 $418 $24,189
803427 CLIFTY CREEK $0 $416 $24,780 $416 $24,780
EMPLOYEES FCU.
834197 FULTON COUNTY FCU... $0 $410 $38,828 $410 $38,828
807009 BANK OF BAKER....... $0 $408 $408 $0
812763 UNITED CREDIT UNION. $0 $405 $24,640 $405 $24,640
833319 C.C.S.E. FCU........ $0 $402 $57,105 $402 $57,105
833386 SOUTH BERGEN FCU.... $0 $397 $32,769 $397 $32,769
832571 OLD OCEAN FCU....... $0 $395 $395 $0
813133 COPOCO CREDIT UNION. $0 $395 $395 $0
833523 PLUS4 CU............ $0 $394 $23,640 $394 $23,640
819993 WESTERRA CU......... $0 $393 $9,349 $393 $9,349
833849 KEARNEY EATON $0 $393 $26,229 $393 $26,229
EMPLOYEES FCU.
833756 UNCLE CREDIT UNION.. $0 $393 $21,495 $393 $21,495
815648 TAMPA BAY FEDERAL $0 $392 $27,131 $392 $27,131
CREDIT UNION.
829953 FAIRLEIGH DICKINSON $0 $391 $6,950 $391 $6,950
UNIVERSITY FCU.
832753 UNIVERSITY HEALTH $0 $391 $10,440 $391 $10,440
FCU.
833879 COOPERATIVE CU...... $0 $390 $26,218 $390 $26,218
833235 AMERICAN SAVINGS $0 $388 $20,131 $388 $20,131
CREDIT UNION.
833173 ST. MARYS BANK...... $0 $388 $388 $0
830798 INVESTEX CU......... $0 $387 $25,587 $387 $25,587
832317 MEMBERS ADVANTAGE $0 $387 $48,988 $387 $48,988
COMMUNITY CU.
833825 CP FCU.............. $0 $386 $10,626 $386 $10,626
833677 PACIFIC RESOURCE CU. $0 $385 $7,754 $385 $7,754
825299 LORMET COMMUNITY $0 $383 $21,515 $383 $21,515
FEDERAL CREDIT UNI.
827952 EXCHANGE STATE BANK. $0 $382 $20,513 $382 $20,513
830730 FIRST CENTRAL CU.... $0 $380 $24,772 $380 $24,772
833563 COOPER'S CAVE FCU... $0 $380 $23,567 $380 $23,567
833942 SCHNEIDER COMMUNITY $0 $378 $27,230 $378 $27,230
CU.
833676 COMMUNITY 1ST CREDIT $0 $375 $47,915 $375 $47,915
UNION.
804257 UNION STATE BANK.... $0 $373 $373 $0
806252 FARMERS & MERCHANTS $0 $370 $370 $0
STATE BANK.
832603 WATERFRONT FCU...... $0 $367 $31,645 $367 $31,645
806322 FIRST NATIONAL BANK $0 $366 $7,713 $366 $7,713
OSAKIS.
831964 CAPITAL COMMUNITY CU $0 $366 $28,810 $366 $28,810
819110 G I C FEDERAL CREDIT $0 $365 $21,907 $365 $21,907
UNION.
832235 HILLSIDE HOSPITAL $0 $365 $10,797 $365 $10,797
FEDERAL CREDIT UN.
832519 SOFCU............... $0 $363 $11,935 $363 $11,935
815504 INDEPENDENT $0 $361 $21,793 $361 $21,793
EMPLOYERS GROUP FCU.
833587 BENTON COUNTY $0 $360 $56,623 $360 $56,623
SCHOOLS CU.
832322 ACHIEVE FINANCIAL $0 $359 $32,541 $359 $32,541
CREDIT UNION.
830504 PRICECHOPPER $0 $355 $22,125 $355 $22,125
EMPLOYEES FED CR UN.
832530 CENTRAL GEORGIA $0 $355 $17,676 $355 $17,676
REGIONAL CU.
834077 UFIRST FCU.......... $0 $352 $15,070 $352 $15,070
833678 CENTRAL WILLAMETTE $0 $351 $23,983 $351 $23,983
CU.
814008 THE MARIES COUNTY $0 $348 $348 $0
BANK.
832898 ALLEGANY COUNTY $0 $347 $20,475 $347 $20,475
SCHOOLS FCU.
802198 AFL-CIO EMPLOYEES $0 $341 $672 $341 $672
FCU.
813975 CITIZENS BANK & $0 $340 $18,850 $340 $18,850
TRUST.
832926 PRECISION CU........ $0 $337 $12,965 $337 $12,965
833544 MONMOUTH FCU........ $0 $333 $333 $0
832441 SEAFORD FEDERAL $0 $333 $35,057 $333 $35,057
CREDIT UNION.
832329 AOD FEDERAL CREDIT $0 $330 $27,514 $330 $27,514
UNION.
832430 BIG VALLEY FEDERAL $0 $329 $17,482 $329 $17,482
CREDIT UNION.
819422 SOUTH LAFOURCHE BANK $0 $328 $328 $0
& TRUST CO.
824699 SANDIA LABORATORY $0 $328 $8,579 $328 $8,579
FCU.
833423 EDUCATIONAL COMM CU. $0 $327 $20,765 $327 $20,765
833504 LAKEVIEW CREDIT $0 $327 $327 $0
UNION.
832506 IQ CREDIT UNION..... $0 $327 $9,945 $327 $9,945
833936 GNC COMMUNITY FCU... $0 $325 $31,265 $325 $31,265
806858 GATEWAY NAT'L BANK $0 $323 $323 $0
OF ST LOUIS.
826355 PLANTERS BANK & $0 $322 $322 $0
TRUST COMPANY.
818156 ALABAMA CREDIT UNION $0 $320 $24,712 $320 $24,712
834207 HOLY FAMILY MEMORIAL $0 $316 $37,830 $316 $37,830
CU.
821987 PEOPLES STATE BANK $0 $315 $33,278 $315 $33,278
OF MUNISING.
808058 M & T BANK $0 $314 $26,894 $314 $26,894
EDUCATIONAL LENDING.
832381 EAST IDAHO CU....... $0 $314 $2,000 $314 $2,000
830853 COMMUNITY $0 $309 $19,335 $309 $19,335
EDUCATIONAL FCU.
832265 STEEL VALLEY FCU.... $0 $309 $34,081 $309 $34,081
832638 PARSONS PITTSBURG CU $0 $308 $26,034 $308 $26,034
833695 SCENIC FALLS FCU.... $0 $305 $17,210 $305 $17,210
832793 COMMUNITY HEALTHCARE $0 $305 $55,715 $305 $55,715
FCU.
832921 SOUTHLAND CIVIC $0 $305 $26,691 $305 $26,691
CREDIT UNION.
829370 BANK OF OLD MONROE.. $0 $303 $14,961 $303 $14,961
828728 IOSCO COMMUNITY $0 $300 $10,954 $300 $10,954
CREDIT UNION.
834298 ST. LOUIS UNIVERSITY $0 $300 $0 $300 $0
830474 U.S. ALLIANCE CU.... $0 $299 $20,286 $299 $20,286
817519 MON-OC FEDERAL $0 $299 $35,549 $299 $35,549
CREDIT UNION.
820394 LAKE COUNTY BANK.... $0 $296 $296 $0
833937 CY-CO FCU........... $0 $296 $19,602 $296 $19,602
818630 SUMA YONKERS FCU.... $0 $296 $18,502 $296 $18,502
833850 MOHAWK PROGRESSIVE $0 $294 $8,566 $294 $8,566
FEDERAL CREDIT U.
833472 UNIVERSAL CITY $0 $291 $33,899 $291 $33,899
STUDIOS CU.
830041 ALL CITY EMPLOYEES $0 $290 $3,286 $290 $3,286
CREDIT UNION.
822170 WHEELING NATIONAL $0 $286 $15,863 $286 $15,863
BANK.
804658 GREAT PLAINS FEDERAL $0 $285 $21,700 $285 $21,700
CREDIT UNION.
828777 MITCHELL BANK....... $0 $283 $6,125 $283 $6,125
803999 FARMERS STATE BANK.. $0 $283 $283 $0
832462 CORNERSTONE $0 $282 $9,646 $282 $9,646
COMMUNITY FIN FCU.
833814 ANOKA HENNEPIN $0 $281 $19,231 $281 $19,231
CREDIT UNION.
817719 RARITAN BAY FEDERAL $0 $281 $15,886 $281 $15,886
CREDIT UNION.
832812 FRANKENMUTH CU...... $0 $280 $19,114 $280 $19,114
833843 UNITED FINANCIAL CU. $0 $278 $33,485 $278 $33,485
833213 PARSONS FEDERAL $0 $276 $29,505 $276 $29,505
CREDIT UNION.
821562 CARNEGIE MELLON $0 $269 $36,319 $269 $36,319
UNIVERSITY.
832698 ROGUE FEDERAL CREDIT $0 $266 $18,221 $266 $18,221
UNION.
810449 FARMERS STATE BANK.. $0 $262 $262 $0
823108 MIDSTATE CREDIT $0 $261 $22,277 $261 $22,277
UNION.
824220 CONSOLIDATED BANK & $0 $254 $12,673 $254 $12,673
TRUST COMPANY.
832494 SYMPHONY ORCHESTRA $0 $252 $27,588 $252 $27,588
EFCU.
832922 KENNEWICK COMMUNITY $0 $250 $9,490 $250 $9,490
FCU.
813981 MIDWEST BANKCENTRE.. $0 $249 $249 $0
829868 FINANCIAL PLUS FCU.. $0 $245 $37,415 $245 $37,415
812335 FIRST CHOICE CREDIT $0 $245 $10,763 $245 $10,763
UNION.
833490 MELROSE CREDIT UNION $0 $245 $11,098 $245 $11,098
832808 MEMBERS OWN FCU..... $0 $241 $14,454 $241 $14,454
828971 NEW VISIONS $0 $241 $241 $0
COMMUNITY FCU.
814817 BANK OF AMERICA NA.. $0 $238 $0 $238 $0
828261 CAPITOL REGION FCU.. $0 $234 $234 $0
833390 BLACKSTONE RIVER FCU $0 $231 $8,860 $231 $8,860
833524 CAROLINAS TELCO FCU. $0 $228 $13,912 $228 $13,912
810698 UNION PLANTERS $0 $226 $226 $0
NATIONAL BANK.
804402 CITIZENS STATE BANK. $0 $225 $26,323 $225 $26,323
823388 TEXAS RURAL $0 $225 $9,000 $225 $9,000
COMMUNITIES.
833328 TOWNE BANK.......... $0 $220 $11,125 $220 $11,125
833115 JP MORGAN CHASE SMS $0 $219 $129,802 $219 $129,802
TRUST 1994-A.
826376 FEDCOM CU........... $0 $216 $18,750 $216 $18,750
832888 NEW SPIRIT CREDIT $0 $216 $13,030 $216 $13,030
UNION.
816044 FARMERS & MERCHANTS $0 $215 $15,408 $215 $15,408
BANK.
832830 RIVERDALE CREDIT $0 $213 $14,299 $213 $14,299
UNION.
832004 NORFOLK FIRE $0 $212 $33,897 $212 $33,897
DEPARTMENT FCU.
834120 WORTHINGTON NAT'L $0 $212 $14,463 $212 $14,463
BANK.
834277 NATIONAL UNIVERSITY. $0 $208 $49,780 $208 $49,780
833349 COUNTY SCHOOLS $0 $205 $18,160 $205 $18,160
FEDERAL CREDIT
UNION.
832634 RCU 1500 FEDERAL $0 $203 $18,662 $203 $18,662
CREDIT UNION.
812012 STATE BANK OF LA $0 $201 $201 $0
CROSSE.
820814 PEOPLES STATE BANK.. $0 $196 $9,886 $196 $9,886
816773 FIRST NEW ENGLAND $0 $194 $14,745 $194 $14,745
FCU.
832418 WINDSOR COUNTY SOUTH $0 $194 $8,750 $194 $8,750
CREDIT UNION.
834098 SILVER STATE SCHOOLS $0 $193 $21,000 $193 $21,000
CU.
834279 LOYOLA COLLEGE...... $0 $188 $188 $0
821496 CANTON STATE BANK... $0 $188 $3,500 $188 $3,500
805623 NORTHEAST BANK FSB.. $0 $188 $12,806 $188 $12,806
833759 A/C CREDIT UNION INC $0 $187 $26,565 $187 $26,565
832423 AMH CREDIT UNION.... $0 $187 $17,067 $187 $17,067
832320 GRANITE HILLS CREDIT $0 $187 $12,286 $187 $12,286
UNION.
829497 ALOHA AIRLINES FCU.. $0 $182 $9,104 $182 $9,104
832872 STREATOR COMMUNITY $0 $180 $10,703 $180 $10,703
CREDIT UNION.
830063 MICHIGAN FIRST CU... $0 $174 $12,258 $174 $12,258
805923 THE FIRST NATIONAL $0 $174 $174 $0
BANK & TRUST.
817414 ST PAULS LATVIAN FCU $0 $173 $173 $0
827371 ARC CREDIT UNION.... $0 $173 $19,253 $173 $19,253
831651 FIRST NATIONAL BANK $0 $170 $170 $0
OF COWETA.
834287 ARCADIA UNIVERSITY.. $0 $168 $0 $168 $0
832183 ANDERSON FEDERAL $0 $167 $955 $167 $955
CREDIT UNION.
834013 LONG ISLAND $0 $165 $34,279 $165 $34,279
COMMUNITY FCU.
833773 AMF KENNEDY EMP FCU. $0 $165 $10,912 $165 $10,912
833477 PRIORITY ONE CU..... $0 $164 $9,864 $164 $9,864
832894 UNITED 1ST FCU...... $0 $164 $5,393 $164 $5,393
822662 MARQUETTE COMMUNITY $0 $164 $5,078 $164 $5,078
FCU.
822031 1ST SUMMIT BANK..... $0 $161 $348,098 $161 $348,098
834208 TEXAS BAY AREA $0 $158 $158 $0
CREDIT UNION.
832643 GRS EMPLOYEES CREDIT $0 $158 $20,504 $158 $20,504
UNION.
804448 DOWNS NATIONAL BANK. $0 $158 $2,919 $158 $2,919
817717 BRIDGETON ONIZED FCU $0 $158 $158 $0
803997 FARMERS SAVINGS BANK $0 $156 $18,058 $156 $18,058
833327 UNITED SAVINGS $0 $156 $10,140 $156 $10,140
FEDERAL CREDIT
UNION.
830548 CITIBANK ELT SLC.... $0 $156 $31,913 $156 $31,913
832709 WOLVERINE EMPLOYEES $0 $151 $13,048 $151 $13,048
CU.
833528 1ST PACIFIC CREDIT $0 $151 $8,750 $151 $8,750
UNION.
812264 GOLDMARK FEDERAL $0 $150 $11,328 $150 $11,328
CREDIT UNION.
833722 CERTIFIED FCU....... $0 $149 $9,236 $149 $9,236
833717 ALLIED HEALTHCARE $0 $148 $9,167 $148 $9,167
FCU.
832589 MOUNTAIN HERITAGE $0 $147 $10,848 $147 $10,848
FCU.
834061 NEW ENGLAND COLLEGE $0 $147 $37,000 $147 $37,000
OF OPTOMETRY.
815723 SAFE HARBOR CREDIT $0 $147 $8,811 $147 $8,811
UNION.
818200 THEO DAVIES FEDERAL $0 $147 $3,619 $147 $3,619
CREDIT UNION.
833494 FEDSTAR FEDERAL $0 $147 $10,500 $147 $10,500
CREDIT UNION.
804206 SECURITY STATE BANK. $0 $145 $11,398 $145 $11,398
806870 SHOW ME CREDIT UNION $0 $144 $9,526 $144 $9,526
821660 ABILENE CHRISTIAN $0 $144 $0 $144 $0
UNIVERSITY.
808279 CENTRIS FCU......... $0 $143 $9,058 $143 $9,058
833007 MERIWEST CREDIT $0 $143 $10,902 $143 $10,902
UNION.
833784 CENTRAL HUDSON $0 $142 $8,802 $142 $8,802
EMPLOYEES FEDERAL
CU.
823007 UNIVERSITY OF $0 $142 $19,442 $142 $19,442
PITTSBURGH.
823760 66 FCU.............. $0 $142 $9,516 $142 $9,516
832778 PROVIDENCE HEALTH $0 $142 $11,359 $142 $11,359
SYSTEM FCU.
832354 LIMESTONE FEDERAL $0 $141 $9,350 $141 $9,350
CREDIT UNION.
823066 NEW YORK INSTITUTE $0 $141 $0 $141 $0
OF TECHNOLOGY.
830091 PATENT AND TRADEMARK $0 $140 $7,802 $140 $7,802
OFFICE FCU.
834253 DOWLING COLLEGE..... $0 $139 $139 $0
828978 OTTUMWA SCH EMPL $0 $139 $139 $0
CREDIT UNION.
833573 BAYONNE HOSPITAL EMP $0 $138 $5,010 $138 $5,010
FCU.
828801 THE BANK OF $0 $138 $138 $0
CARBONDALE.
834260 UNIVERSITY OF MD CP. $0 $137 $137 $0
805907 FARMERS STATE BANK $0 $135 $16,219 $135 $16,219
OF BRECKENRIDGE.
813466 FRAMINGHAM MUNICIPAL $0 $135 $9,432 $135 $9,432
FEDERAL CREDIT.
832313 LOUVAH FEDERAL $0 $134 $8,951 $134 $8,951
CREDIT UNION.
832927 NORTH SHORE HEALTH $0 $132 $9,365 $132 $9,365
SYSTEM FCU.
814658 LOUISIANA CENTRAL $0 $131 $11,136 $131 $11,136
CREDIT UNION.
832457 GREATER OREGON FCU.. $0 $131 $8,352 $131 $8,352
832042 DOWAGIAC AREA FCU... $0 $129 $6,910 $129 $6,910
830480 BANK OF STOCKTON.... $0 $129 $6,871 $129 $6,871
822237 UNIVERSITY OF $0 $128 $128 $0
ILLINOIS.
813671 UNION BANK & TRUST $0 $127 $6,479 $127 $6,479
COMPANY.
832510 AUBURN S&L $0 $127 $127 $0
ASSOCIATION.
827057 BANKERS FIDELITY $0 $126 $126 $0
LIFE INSURANCE CO.
812744 FIRST NATIONAL BANK $0 $126 $10,026 $126 $10,026
OF BERRYVILLE.
833124 THE NATIONAL BANK OF $0 $125 $125 $0
INDIANAPOLIS.
817380 TVA CU.............. $0 $124 $8,667 $124 $8,667
808064 COMMUNITY MUTUAL $0 $123 $123 $0
SAVINGS BANK.
800029 WACHOVIA BANK NA.... $0 $123 $123 $0
833040 NORTHEASTERN $0 $122 $19,781 $122 $19,781
ENGINEERS FCU.
828453 REGISTER-GUARD FCU.. $0 $122 $122 $0
816516 RETAIL EMPLOYEES CU. $0 $120 $7,605 $120 $7,605
824574 1ST GARLAND $0 $119 $7,654 $119 $7,654
COMMUNITY FCU.
820787 FREEDOM CREDIT UNION $0 $117 $11,993 $117 $11,993
830016 SECNY FCU........... $0 $117 $10,425 $117 $10,425
815880 NEW ALLIANCE BANK... $0 $117 $117 $0
831053 SLM ECFC............ $0 $117 $86,147 $117 $86,147
834294 UNIVERSITY OF $0 $115 $4,845 $115 $4,845
SCRANTON.
833703 ST. JOHN'S OF LITTLE $0 $115 $16,332 $115 $16,332
CANADA CU.
834214 SOUTHERN ILLINOIS $0 $114 $114 $0
UNIVERSITY.
820212 CHIPPEWA COUNTY $0 $114 $8,345 $114 $8,345
EMPLOYEES CU.
826478 EMORY UNIVERSITY.... $0 $112 $112 $0
832119 PRIME CARE CREDIT $0 $110 $6,727 $110 $6,727
UNION.
834280 NORTHEASTERN $0 $110 $110 $0
UNIVERSITY.
819332 WEPCO FEDERAL CREDIT $0 $107 $6,797 $107 $6,797
UNION.
829253 EQUITABLE SAVINGS & $0 $106 $8,299 $106 $8,299
LOAN COMPANY.
832508 COOPERATIVE CENTER $0 $105 $6,621 $105 $6,621
FCU.
830306 MARSHLAND COMMUNITY $0 $105 $10,322 $105 $10,322
FCU.
832427 MICHIGAN TECH EFCU.. $0 $104 $5,265 $104 $5,265
834164 TRI-LAKES FCU....... $0 $103 $14,081 $103 $14,081
834249 WELLS FARGO ELT $0 $103 $0 $103 $0
WALDEN UNIVERSITY.
833525 LOCAL 144 S.E.I.U. $0 $103 $5,207 $103 $5,207
FCU.
832268 COUNTRY HERITAGE $0 $102 $6,326 $102 $6,326
CREDIT UNION.
833581 EDWARDS FEDERAL $0 $100 $6,419 $100 $6,419
CREDIT UNION.
831298 COMMUNITY FIRST FCU. $0 $100 $100 $0
830592 CONSOLIDATED HUB-CO $0 $99 $8,787 $99 $8,787
FCU.
832431 WINTHROP FEDERAL $0 $99 $33,149 $99 $33,149
CREDIT UNION.
834286 CONCORDIA SEMINARY.. $0 $99 $16,500 $99 $16,500
833764 DEXSTA FEDERAL $0 $98 $6,541 $98 $6,541
CREDIT UNION.
833591 SEATTLE METROPOLITAN $0 $97 $10,042 $97 $10,042
CU.
834213 SOMERSET VALLEY BANK $0 $96 $0 $96 $0
827810 US FIRST FEDERAL $0 $95 $5,981 $95 $5,981
CREDIT UNION.
834065 HVHS CU............. $0 $94 $80,362 $94 $80,362
833904 HI-LAND HOSPITAL $0 $93 $6,084 $93 $6,084
FEDERAL CREDIT UNI.
831882 HORIZON BANK........ $0 $92 $5,250 $92 $5,250
834220 VALLEY COMMUNITIES $0 $90 $6,125 $90 $6,125
CU.
833464 SOURCEONE CREDIT $0 $90 $28,339 $90 $28,339
UNION.
833790 KERR COUNTY FCU..... $0 $89 $89 $0
833813 SUNSET SCIENCE PARK $0 $88 $88 $0
FEDERAL CREDIT.
819519 SPCO FCU............ $0 $86 $6,125 $86 $6,125
834274 LAKE ERIE COLLEGE OF $0 $84 $84 $0
OSTEO MED.
832936 EDUCATIONAL & $0 $83 $3,748 $83 $3,748
GOVERNMENTAL EFCU.
813766 STATE BANK OF SLATER $0 $83 $0 $83 $0
823448 GEORGETOWN $0 $82 $82 $0
UNIVERSITY.
832967 WY-SOUTH FCU........ $0 $82 $5,488 $82 $5,488
834075 DELAWARE STATE $0 $82 $6,125 $82 $6,125
POLICE FCU.
829263 JEFFERSON BANK & $0 $80 $2,625 $80 $2,625
TRUST COMPANY.
829874 SAGINAW AUTOMOTIVE $0 $75 $75 $0
EFCU.
834291 JOHN CARROLL $0 $75 $1,860 $75 $1,860
UNIVERSITY.
832769 ESCU FEDERAL CREDIT $0 $74 $6,108 $74 $6,108
UNION.
834276 FORDHAM UNIVERSITY.. $0 $74 $74 $0
819462 KEARNEY TRUST $0 $72 $0 $72 $0
COMPANY.
832440 LOUISE E MILLS $0 $72 $5,159 $72 $5,159
FEDERAL CREDIT
UNION.
832856 ST JEANS CREDIT $0 $71 $0 $71 $0
UNION.
834177 MONTEREY COUNTY EMP $0 $71 $5,500 $71 $5,500
CU.
819406 HURON CNW FCU....... $0 $71 $3,251 $71 $3,251
816484 1ST CHOICE CREDIT $0 $71 $71 $0
UNION.
832240 FRONT ROYAL FCU..... $0 $70 $4,228 $70 $4,228
832596 SOUTHWEST AIRLINES $0 $70 $5,064 $70 $5,064
FEDERAL CREDIT U.
834304 FLORIDA COASTAL $0 $70 $9,250 $70 $9,250
SCHOOL OF LAW.
832167 GREENVILLE FEDERAL $0 $69 $4,813 $69 $4,813
CREDIT UNION.
833554 TOWN OF HEMPSTEAD $0 $69 $13,882 $69 $13,882
EMP FCU.
833440 LBS FINANCIAL CREDIT $0 $68 $4,303 $68 $4,303
UNION.
817308 COLORADO UNITED $0 $65 $0 $65 $0
CREDIT UNION.
824872 CENTRAL KANSAS CU... $0 $65 $4,753 $65 $4,753
831605 COUNTY OF HENRICO $0 $65 $65 $0
FCU.
832491 MARKET USA FEDERAL $0 $65 $7,604 $65 $7,604
CREDIT UNION.
834296 UNIVERSITY OF $0 $64 $15,790 $64 $15,790
NORTHWESTERN OHIO.
834288 ROBERT MORRIS $0 $64 $64 $0
UNIVERSITY.
833357 OHIO VALLEY CREDIT $0 $63 $9,514 $63 $9,514
UNION.
825487 BOSTON COLLEGE...... $0 $63 $63 $0
822384 INDEPENDENT BANK.... $0 $62 $24,307 $62 $24,307
813136 HOMETOWN COMMUNITY $0 $61 $5,557 $61 $5,557
CU.
827559 EQUITABLE SAVINGS $0 $61 $61 $0
AND LOAN ASSOCIAT.
814431 MINNWEST BANK $0 $61 $5,438 $61 $5,438
MONTEVIDEO.
834232 PERMACULTURE CU..... $0 $61 $6,611 $61 $6,611
832425 CARRAWAY METHODIST $0 $60 $60 $0
FCU.
822449 VANDERBILT $0 $60 $60 $0
UNIVERSITY.
817209 VALLEY CATHOLIC FCU. $0 $60 $1,819 $60 $1,819
827291 PEOPLES BANK AND $0 $60 $60 $0
TRUST COMPANY.
832756 SHERATON HAWAII FCU. $0 $60 $17,217 $60 $17,217
813145 CREDIT UNION ONE.... $0 $59 $8,602 $59 $8,602
827202 E&A CREDIT UNION.... $0 $57 $4,940 $57 $4,940
834180 ENERGY CAPITAL CU... $0 $57 $2,625 $57 $2,625
834195 BAPTIST CREDIT UNION $0 $56 $4,200 $56 $4,200
810894 HEREFORD STATE BANK. $0 $56 $56 $0
822686 SANTANDER DE PUERTO $0 $55 $11,599 $55 $11,599
RICO.
832237 PALMETTO TRUST $0 $53 $4,756 $53 $4,756
FEDERAL CREDIT
UNION.
832691 QUALSTAR CU......... $0 $53 $3,563 $53 $3,563
831367 OLD DOMINION $0 $53 $24,457 $53 $24,457
UNIVERSITY CREDIT
UNIO.
833377 CAMPUS CREDIT UNION. $0 $52 $905 $52 $905
817180 STAMFORD POSTAL EFCU $0 $52 $7,704 $52 $7,704
833935 VIRGINIA BEACH $0 $51 $10,379 $51 $10,379
SCHOOLS FCU.
802182 WATERBURY $0 $49 $49 $0
FIREFIGHTERS MUNI
FCU.
832379 NORTHWEST HILLS $0 $49 $1,615 $49 $1,615
CREDIT UNION INC.
832853 SOUTH DIVISION $0 $49 $9,410 $49 $9,410
CREDIT UNION.
833126 MILLSTREAM AREA CU.. $0 $47 $5,955 $47 $5,955
832831 LOCO CREDIT UNION... $0 $47 $3,507 $47 $3,507
816869 GE0RGIA COASTAL FCU. $0 $47 $3,103 $47 $3,103
815516 HONOLULU CITY & $0 $47 $3,500 $47 $3,500
COUNTY FEDERAL CRED.
822338 PEOPLES ALLIANCE FCU $0 $45 $3,370 $45 $3,370
834297 DEPAUL UNIVERSITY... $0 $45 $6,166 $45 $6,166
833621 DEPT OF VETERANS $0 $45 $45 $0
AFFAIRS FCU.
832852 RIVER WORKS CREDIT $0 $44 $2,118 $44 $2,118
UNION.
823132 UNION THEOLOGICAL $0 $44 $3,895 $44 $3,895
SEMINARY.
828384 THE FIRST NATIONAL $0 $43 $43 $0
BANK/BALLINGER.
833290 SYRACUSE FCU........ $0 $42 $42 $0
810809 FIRST NATIONAL BANK. $0 $42 $2,691 $42 $2,691
825138 UNIVERSITY OF CA SAN $0 $42 $42 $0
FRANCISCO.
805943 CLS-NATIONAL CITY $0 $41 $4,000 $41 $4,000
BANK (FOA).
832271 MEMBER'S CHOICE CU.. $0 $40 $2,882 $40 $2,882
833725 PORT ALLIANCE FCU... $0 $40 $0 $40 $0
833700 LA FINANCIAL FCU.... $0 $40 $2,626 $40 $2,626
821517 PURDUE UNIVERSITY... $0 $37 $37 $0
820411 BANK INDEPENDENT.... $0 $37 $0 $37 $0
804776 HILLSBORO STATE BANK $0 $36 $36 $0
827132 SKY BANK............ $0 $35 $3,236 $35 $3,236
816323 PINNACLE CREDIT $0 $35 $2,972 $35 $2,972
UNION.
832466 ALLEGIS CREDIT UNION $0 $34 $2,744 $34 $2,744
834085 LAKE ERIE COMMUNITY $0 $34 $34 $0
FCU.
834270 POINT PARK $0 $33 $0 $33 $0
UNIVERSITY.
829426 DUPONT FIBERS $0 $33 $33 $0
FEDERAL CREDIT
UNION.
813171 NW CONSUMERS FCU.... $0 $31 $2,338 $31 $2,338
826782 FLAGSTAR BANK FSB... $0 $31 $31 $0
828554 CAPITAL CITY BANK... $0 $31 $31 $0
834168 MINUTEMAN COMMUNITY $0 $30 $3,312 $30 $3,312
FCU.
811008 HORIZON CAPITAL BANK $0 $29 $29 $0
809556 BANK OF AMERICA..... $0 $29 $29 $0
834283 ASHLAND UNIVERSITY.. $0 $29 $3,893 $29 $3,893
820449 ST MICHAEL'S FALL $0 $29 $1,888 $29 $1,888
RIVER FCU.
833021 KEY BANK NA......... $0 $28 $63,564 $28 $63,564
833640 LOCAL 804 FCU....... $0 $28 $0 $28 $0
832970 RED LAKE CO-OP FCU.. $0 $28 $1,714 $28 $1,714
833478 SAINT FRANCIS $0 $27 $1,802 $27 $1,802
EMPLOYEES FCU.
833008 GTA CREDIT UNION.... $0 $27 $27 $0
832057 JPMORGAN CHASE ELT $0 $27 $27 $0
GTSLC.
810953 SANTA ANNA NATIONAL $0 $26 $26 $0
BANK.
812106 MERCK EMPLOYEES FCU. $0 $26 $2,667 $26 $2,667
810067 COMMUNITY BANK & $0 $26 $4,239 $26 $4,239
TRUST CO.
834090 JEANNE D'ARC CU..... $0 $26 $2,582 $26 $2,582
808178 COMMUNITY BANK NA... $0 $25 $25 $0
832714 STONEHAM MUNICIPAL $0 $25 $1,348 $25 $1,348
EFCU.
834295 UNIVERSITY OF THE $0 $25 $3,214 $25 $3,214
INCARNATE WORD.
834209 EDWARD VIA VIRGINIA $0 $25 $25 $0
COL. OF OSTEOPA.
816473 HUMAN SERVICES $0 $24 $1,257 $24 $1,257
EMPLOYEE CU.
831749 WACHOVIA BANK NA.... $0 $21 $21 $0
810960 STATE BANK OF DEKALB $0 $21 $16,915 $21 $16,915
806063 SAND RIDGE BANK..... $0 $21 $21 $0
833693 TCP CREDIT UNION.... $0 $20 $3,782 $20 $3,782
831927 ADVANTIS CU......... $0 $20 $20 $0
834262 NEW MEXICO STATE $0 $19 $2,200 $19 $2,200
UNIVERSITY.
834268 ROBERT MORRIS $0 $18 $1,780 $18 $1,780
COLLEGE.
834275 UNIVERSITY OF $0 $18 $2,432 $18 $2,432
COLORADO COLORADO
SPR.
809997 DENVER NATIONAL BANK $0 $18 $1,256 $18 $1,256
833434 DELAWARE ALLIANCE $0 $17 $885 $17 $885
FCU.
816217 SYLVESTER BANKING $0 $17 $1,540 $17 $1,540
COMPANY.
833944 DEVRY UNIVERSITY.... $0 $17 $0 $17 $0
832961 JOPLIN METRO CREDIT $0 $17 $1,210 $17 $1,210
UNION.
816845 THE PEOPLES BANK.... $0 $16 $2,616 $16 $2,616
824822 TEMPLE UNIVERSITY... $0 $16 $2,230 $16 $2,230
829436 INTERSTATE UNLIMITED $0 $16 $1,439 $16 $1,439
FCU.
829140 FIRST COMMUNITY BANK $0 $15 $1,164 $15 $1,164
OF WINDSOR.
808765 THE FARMERS & $0 $14 $14 $0
MERCHANTS STATE
BANK.
805704 FIRST NATIONAL BANK $0 $14 $14 $0
OF BAR HARBOR.
802913 US BANK NA.......... $0 $14 $14 $0
805849 CENTURY BANK AND $0 $14 $14 $0
TRUST.
832197 CONNECTS FEDERAL $0 $14 $0 $14 $0
CREDIT UNION.
810527 FIRST AMERICAN BANK $0 $13 $13 $0
& TRUST.
833568 DETOUR DRUMMOND $0 $13 $557 $13 $557
COMMUNITY CU.
832326 CASWELL CREDIT UNION $0 $13 $0 $13 $0
828677 FIRST HERITAGE $0 $13 $1,386 $13 $1,386
FEDERAL CREDIT
UNION.
829796 MEMBERS FIRST CU.... $0 $12 $531 $12 $531
828729 CENTRAL MICHIGAN $0 $12 $3,101 $12 $3,101
COMMUNITY FED CR U.
832524 AMERICAN SPIRIT FCU. $0 $12 $1,093 $12 $1,093
833027 AMERICAN NICKELOID $0 $11 $236 $11 $236
EMP CU.
833962 US BANK ELT $0 $11 $1,312 $11 $1,312
AFFORDIAN INC.
818553 AMERICAN EAGLE $0 $11 $11 $0
CREDIT UNION.
816687 HARTFORD HEALTHCARE $0 $10 $10 $0
CREDIT UNION.
832690 CAPITAL POWER FCU... $0 $10 $10 $0
834266 OHIO UNIVERSITY $0 $9 $1,000 $9 $1,000
COLLEGE OF OSTEO ME.
827671 QUINCY MUNICIPAL $0 $9 $9 $0
CREDIT UNION.
834293 CENTRAL MICHIGAN $0 $9 $9 $0
UNIVERSITY.
834306 WASHBURN UNIVERSITY. $0 $9 $1,200 $9 $1,200
899993 SLMA/LSC NEW ENGLAND $0 $9 $3,921 $9 $3,921
818712 FIRST NAT'L BANK OF $0 $7 $7 $0
SLIPPERY ROCK.
832319 MARKETPLACE FEDERAL $0 $7 $437 $7 $437
CREDIT UNION.
815816 HAMILTON HORIZONS $0 $7 $1,143 $7 $1,143
FCU.
830938 UNITED BRANCH OF $0 $6 $196 $6 $196
BENNINGTON STATE B.
834020 EASTERN MICHIGAN $0 $6 $6 $0
UNIVERSITY.
832754 IBEW #317 FCU....... $0 $5 $5 $0
833711 FANNIN BANK......... $0 $5 $5 $0
832360 ENTERTAINMENT $0 $5 $5 $0
INDUSTRIES FCU.
826264 AMERICU............. $0 $5 $5 $0
834290 KANSAS STATE BANK $0 $4 $4 $0
ELT UNIV KANSAS S.
822734 UNIVERSITY OF $0 $4 $4 $0
MINNESOTA.
806185 AMERICAN BANK OF $0 $4 $4 $0
NASHWAUK.
825136 UCLA................ $0 $3 $3 $0
821737 OKLAHOMA STATE $0 $3 $3 $0
UNIVERSITY.
827174 MALVERN TRUST & $0 $3 $3 $0
SAVINGS BANK.
832871 LANECO FEDERAL $0 $3 $0 $3 $0
CREDIT UNION.
829817 FLINT AREA SCHOOL $0 $3 $3 $0
EMPL CU.
809678 FIRST NATIONAL BANK $0 $2 $2 $0
OF PENNSYLVANIA.
827521 LIFEWAY CREDIT UNION $0 $2 $2 $0
834305 UNIVERSITY OF $0 $1 $1 $0
VERMONT.
802033 AMERICAN EAGLE FCU.. $0 $1 $1 $0
816332 FIDELITY FCU........ $0 $1 $1 $0
832792 DECATUR STANOLIND $0 $1 $1 $0
CREDIT UNION.
829293 MASSMUTUAL FEDERAL $0 $0 $85,076 $0 $85,076
CREDIT UNION.
803917 CENTRAL STATE BANK.. $0 $0 $7,948 $0 $7,948
806466 STATE BANK OF $0 $0 $4,428 $0 $4,428
FAIRMONT.
815644 PANHANDLE EDUCATORS $0 ($1) ($1) $0
FCU.
807806 CITIBANK ELT SLC $0 ($3) ($3) $0
RECEIVABLES I.
805095 FIRST NATIONAL BANK ($5) $0 ($5) $0
OF JEANERETTE.
823817 JPMORGAN CHASE ELT ($14) ($10) $0 ($24) $0
BRAZOS HEA.
808717 JPMORGAN CHASE NA ($43) ($5) $0 ($48) $0
ELT BRAZOS HEA IN.
822685 SANTANDER NATIONAL $0 ($81) $21,208 ($81) $21,208
BANK.
815844 HUDSON UNITED BANK.. $0 ($84) ($84) $0
822982 NEW JERSEY HIGHER $0 ($4,371) $171,699 ($4,371) $171,699
EDUCN ASST AUTH.
834099 UNION BANK CA ELT ($784,111) $0 $662,906 $1,052,570 ($121,206) $1,052,570
CHELA FUND I (TEF).
----------------------------------------------------------------------------------------------------------------------
Total........... $581,296,104 $11,106,045,909 $6,532,862,906 $251,176,218,814 $7,114,159,010 $262,282,264,723
--------------------------------------------------------------------------------------------------------------------------------------------------------
[Whereupon, at 1:38 p.m., the committee was adjourned.]