1. CRI- Common Review Initiative Improving Accountability in the FFEL Program Through Cooperation August 27, 2003

2. CRI Concept Guarantors would combine resources to conduct a single review of large lenders and servicers. Each CRI review would go toward meeting the requirements of 682.410(c)(1) for all CRI participating guarantors

3. CRI Progress CRI – great progress in less than one year Concept to Guarantor CEO caucus in November 2002 Steering Committee formed – December 2002 Conference call in February 2003 Face-to-face meeting in March 2003 Workgroups have been meeting ever since

4. Current CRI Status August 27, 2003 Final CRI proposal to ED Week of September 22, 2003 Tentative meeting in DC with Financial Partners September 30, 2003 Suggested deadline for determining CRI participation by signing agreement

5. Current CRI Status October 2003 First meeting of CRI Oversight and Administration Council November 16, 2003 CRI review team member training 2004-2005 biennium Begin conducting CRI reviews

6. Current CRI Status On-going CRI projects Completion of CRI review procedures and review guide Completion of CRI administrative policies and procedures manual Lender selection and review scheduling for 2004-2005 reviews

7. CRI Focus Initial focus – reduce redundancy in lender reviews by guarantors Current focus – improving review quality with added benefit of reducing redundancy

8. CRI – Improving Reviews Current file review process inherently limited Not inclusive of all attributes Sample sizes limited CRI review protocol avoids these limitations Use of attribute testing Statistically valid sampling to provide a 95% confidence level Adoption of best practices

9. CRI – Improving Reviews ED Lender Review Guide is base document for CRI review protocol CRI review teams would test additional attributes not contained in Guide CRI reviews would not test LaRS Proposal calls for ED to test this CRI reviews would track findings back to LaRS where adjustments are necessary

10. CRI Review Selection CRI reviews would be conducted at lenders/servicers required to be reviewed by at least four guarantors Servicer reviews would apply to all lenders contracting with that servicer

11. CRI Reviews - Lenders CRI reviews would tentatively be conducted at the following lenders: Citibank (currently reviewed by 12 GAs) Educaid/Wachovia (14) Wells Fargo (14)

12. CRI Reviews - Servicers CRI reviews would tentatively be conducted at the following servicers: ACS (currently reviewed by 10 GAs) AES (6) Edamerica (7) KHESLC (7) MOHELA (4)

13. CRI Reviews - Servicers CRI reviews would tentatively be conducted at the following servicers: Nelnet (currently reviewed by 24 GAs) Sallie Mae (24) SSSC (5) Suntech (9)

14. CRI Benefits Current focus – improving review quality with added benefit of reducing redundancy Demonstrably better reviews through attribute testing, statistically valid sampling and best practices By conducting 12 CRI reviews, 111 other reviews would be eliminated

15. CRI and Accountability More rigorous CRI reviews provide greater confidence that lenders/servicers are in compliance CRI demonstrates guarantor commitment to oversight role

16. Common Review Initiative Questions?