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Education loan examination procedures

Updated September 2022

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This update to the education loan servicing examination procedures clarifies that when determining whether we have authority to supervise a private student lender, we will look only to the definition of private education loan in the Truth in Lending Act and not also to Regulation Z.


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