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Education loan examination procedures

Updated Jan. 20, 2022

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This update to the education loan servicing examination procedures incorporates a change to the Fair Credit Reporting Act (FCRA) created under the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA).


These procedures include guidance for examination of all aspects of private education loans and examination of servicing practices in connection with all types of student loans.

The examination procedures contain a series of modules, grouping similar requirements together. In many cases, the examination scope will focus on either origination or servicing. Depending on the scope, and in conjunction with the compliance management system and consumer complaint response review procedures, each examination will cover one or more of the following modules. The modules include: 

  1. Advertising, Marketing, and Lead Generation 
  2. Customer Application, Qualification, Loan Origination, and Disbursement
  3. Student Loan Servicing
  4. Borrower Inquiries and Complaints
  5. Collections, Accounts in Default, and Credit Reporting
  6. Information Sharing and Privacy
  7. Examination Conclusion and Wrap-Up