Allowance for Loan Losses | 2. Allowance for Loan Losses Allowance for Loan Losses Metrics Three Months Ended September 30, 2021 (Dollars in millions) FFELP Loans Private Education Loans Total Beginning balance $ 277 $ 976 $ 1,253 Total provision — 22 22 Charge-offs: Net adjustment resulting from the change in the charge-off rate ( 1) — (16 ) (16 ) Net charge-offs remaining ( 2) (8 ) (39 ) (47 ) Total charge-offs ( 2) (8 ) (55 ) (63 ) Decrease in expected future recoveries on charged-off loans ( 3) — 37 37 Allowance at end of period 269 980 1,249 Plus: expected future recoveries on charged-off loans ( 3) — 397 397 Allowance at end of period excluding expected future recoveries on charged-off loans ( 4) $ 269 $ 1,377 $ 1,646 Net charge-offs as a percentage of average loans in repayment, excluding the net adjustment resulting from the change in the charge-off rate ( 1) .07 % .77 % Net adjustment resulting from the change in charge-off rate as a percentage of average loans in repayment ( 1) — % .33 % Allowance coverage of charge-offs ( 4) 8.4 6.3 Allowance as a percentage of the ending total loan balance ( 4) .5 % 6.6 % Allowance as a percentage of the ending loans in repayment ( 4) .6 % 7.0 % Ending total loans $ 54,619 $ 20,998 Average loans in repayment $ 45,201 $ 19,894 Ending loans in repayment $ 44,160 $ 19,795 (1) In third-quarter 2021, the portion of the loan amount charged off at default on Private Education Loans increased from 81.4% to 81.7%. This change resulted in a $16 million reduction to the balance of the expected future recoveries on charged-off loans. ( 2 ) Charge-offs are reported net of expected recoveries. For Private Education Loans, at the time of charge-off, the expected recovery amount is transferred from the education loan balance to the allowance for loan loss and is referred to as the expected future recoveries on charged-off loans. For FFELP Loans, the recovery is received at the time of charge-off. ( 3 ) At the end of each month, for Private Education Loans that are 212 or more days past due, we charge off the estimated loss of a defaulted loan balance. Actual recoveries are applied against the remaining loan balance that was not charged off. We refer to this as the “expected future recoveries on charged-off loans.” If actual periodic recoveries are less than expected, the difference is immediately charged off through the allowance for Private Education Loan losses with an offsetting reduction in the expected future recoveries for charged-off loans. If actual periodic recoveries are greater than expected, they will be reflected as a recovery through the allowance for Private Education Loan losses once the cumulative recovery amount exceeds the cumulative amount originally expected to be recovered. The following table summarizes the activity in the expected future recoveries on charged-off loans: Three Months Ended September 30, (Dollars in millions) 2021 Beginning of period expected recoveries $ 434 Expected future recoveries of current period defaults 6 Recoveries (22 ) Charge-offs (21 ) End of period expected recoveries $ 397 Change in balance during period $ (37 ) ( 4 ) The allowance used for these metrics excludes the expected future recoveries on charged-off loans to better reflect the current expected credit losses remaining in the portfolio. 2. Allowance for Loan Losses (Continued) Three Months Ended September 30, 2020 (Dollars in millions) FFELP Loans Private Education Loans Other Loans Beginning balance $ 302 $ 1,098 $ 1,400 Total provision 4 10 14 Charge-offs: Net adjustment resulting from the change in the charge-off rate ( 1) — (23 ) (23 ) Net charge-offs remaining ( 2) (9 ) (40 ) (49 ) Total charge-offs ( 2) (9 ) (63 ) (72 ) Decrease in expected future recoveries on charged-off loans ( 3) — 46 46 Allowance at end of period 297 1,091 1,388 Plus: expected future recoveries on charged-off loans ( 3) — 503 503 Allowance at end of period excluding expected future recoveries on charged-off loans ( 4) $ 297 $ 1,594 $ 1,891 Net charge-offs as a percentage of average loans in repayment, excluding the net adjustment resulting from the change in the charge-off rate ( 1) .07 % .75 % Net adjustment resulting from the change in charge-off rate as a percentage of average loans in repayment ( 1) — % .44 % Allowance coverage of charge-offs ( 4) 8.8 6.4 Allowance as a percentage of the ending total loan balance ( 4) .5 % 7.1 % Allowance as a percentage of the ending loans in repayment ( 4) .6 % 7.6 % Ending total loans $ 59,856 $ 22,380 Average loans in repayment $ 47,597 $ 20,884 Ending loans in repayment $ 48,716 $ 21,006 (1) In third-quarter 2020, the portion of the loan amount charged off at default on Private Education Loans increased from 81% to 81.4%. This change resulted in a $23 million reduction to the balance of the expected future recoveries on charged-off loans. ( 2 ) Charge-offs are reported net of expected recoveries. For Private Education Loans, at the time of charge-off, the expected recovery amount is transferred from the education loan balance to the allowance for loan loss and is referred to as the expected future recoveries on charged-off loans. For FFELP Loans, the recovery is received at the time of charge-off. ( 3 ) At the end of each month, for Private Education Loans that are 212 or more days past due, we charge off the estimated loss of a defaulted loan balance. Actual recoveries are applied against the remaining loan balance that was not charged off. We refer to this as the “expected future recoveries on charged-off loans.” If actual periodic recoveries are less than expected, the difference is immediately charged off through the allowance for Private Education Loan losses with an offsetting reduction in the expected future recoveries for charged-off loans. If actual periodic recoveries are greater than expected, they will be reflected as a recovery through the allowance for Private Education Loan losses once the cumulative recovery amount exceeds the cumulative amount originally expected to be recovered. The following table summarizes the activity in the expected future recoveries on charged-off loans: Three Months Ended September 30, (Dollars in millions) 2020 Beginning of period expected recoveries $ 549 Expected future recoveries of current period defaults 7 Recoveries (28 ) Charge-offs (25 ) End of period expected recoveries $ 503 Change in balance during period $ (46 ) ( 4 ) The allowance used for these metrics excludes the expected future recoveries on charged-off loans to better reflect the current expected credit losses remaining in the portfolio. 2. Allowance for Loan Losses (Continued) Nine Months Ended September 30, 2021 (Dollars in millions) FFELP Loans Private Education Loans Total Beginning balance $ 288 $ 1,089 $ 1,377 Provision: Reversal of allowance related to loan sales (1) — (107 ) (107 ) Remaining provision — 41 41 Total provision — (66 ) (66 ) Charge-offs: Net adjustment resulting from the change in the charge-off rate (2) — (16 ) (16 ) Net charge-offs remaining (3) (19 ) (109 ) (128 ) Total charge-offs (3) (19 ) (125 ) (144 ) Decrease in expected future recoveries on charged-off loans (4) — 82 82 Allowance at end of period 269 980 1,249 Plus: expected future recoveries on charged-off loans (4) — 397 397 Allowance at end of period excluding expected future recoveries on charged-off loans (5) $ 269 $ 1,377 $ 1,646 Net charge-offs as a percentage of average loans in repayment, excluding the net adjustment resulting from the change in the charge-off rate (2) .06 % .72 % Net adjustment resulting from the change in charge-off rate as a percentage of average loans in repayment (2) — % .11 % Allowance coverage of charge-offs (5) 10.5 8.3 Allowance as a percentage of the ending total loan balance (5) .5 % 6.6 % Allowance as a percentage of the ending loans in repayment (5) .6 % 7.0 % Ending total loans $ 54,619 $ 20,998 Average loans in repayment $ 46,191 $ 20,145 Ending loans in repayment $ 44,160 $ 19,795 (1) In connection with the sale of approximately $1.6 billion of Private Education Loans. ( 2 ) In third-quarter 2021, the portion of the loan amount charged off at default on Private Education Loans increased from 81.4% to 81.7%. This change resulted in a $16 million reduction to the balance of the expected future recoveries on charged-off loans. ( 3 ) Charge-offs are reported net of expected recoveries. For Private Education Loans, at the time of charge-off, the expected recovery amount is transferred from the education loan balance to the allowance for loan loss and is referred to as the expected future recoveries on charged-off loans. For FFELP Loans, the recovery is received at the time of charge-off. ( 4 ) At the end of each month, for Private Education Loans that are 212 or more days past due, we charge off the estimated loss of a defaulted loan balance. Actual recoveries are applied against the remaining loan balance that was not charged off. We refer to this as the “expected future recoveries on charged-off loans.” If actual periodic recoveries are less than expected, the difference is immediately charged off through the allowance for Private Education Loan losses with an offsetting reduction in the expected future recoveries for charged-off loans. If actual periodic recoveries are greater than expected, they will be reflected as a recovery through the allowance for Private Education Loan losses once the cumulative recovery amount exceeds the cumulative amount originally expected to be recovered. The following table summarizes the activity in the expected future recoveries on charged-off loans: Nine Months Ended September 30, (Dollars in millions) 2021 Beginning of period expected recoveries $ 479 Expected future recoveries of current period defaults 16 Recoveries (69 ) Charge-offs (29 ) End of period expected recoveries $ 397 Change in balance during period $ (82 ) ( 5 ) The allowance used for these metrics excludes the expected future recoveries on charged-off loans to better reflect the current expected credit losses remaining in the portfolio. 2. Allowance for Loan Losses (Continued) Nine Months Ended September 30, 2020 (Dollars in millions) FFELP Loans Private Education Loans Other Loans Beginning balance (after transition adjustment to CECL) $ 324 $ 1,045 $ 1,369 Total provision 13 140 153 Charge-offs: Net adjustment resulting from the change in the charge-off rate ( 1) — (23 ) (23 ) Net charge-offs remaining ( 2) (40 ) (156 ) (196 ) Total charge-offs ( 2) (40 ) (179 ) (219 ) Decrease in expected future recoveries on charged-off loans ( 3) — 85 85 Ending balance 297 1,091 1,388 Plus: expected future recoveries on charged-off loans ( 3) — 503 503 Allowance at end of period excluding expected future recoveries on charged-off loans ( 4) $ 297 $ 1,594 $ 1,891 Net charge-offs as a percentage of average loans in repayment, excluding the net adjustment resulting from the change in the charge-off rate ( 1) .11 % 1.00 % Net adjustment resulting from the change in charge-off rate as a percentage of average loans in repayment ( 1) — % .15 % Allowance coverage of charge-offs ( 4) 5.6 6.7 Allowance as a percentage of the ending total loan balance ( 4) .5 % 7.1 % Allowance as a percentage of the ending loans in repayment ( 4) .6 % 7.6 % Ending total loans $ 59,856 $ 22,380 Average loans in repayment $ 48,065 $ 20,739 Ending loans in repayment $ 48,716 $ 21,006 (1) In third-quarter 2020, the portion of the loan amount charged off at default on Private Education Loans increased from 81% to 81.4%. This change resulted in a $23 million reduction to the balance of the expected future recoveries on charged-off loans. ( 2 ) Charge-offs are reported net of expected recoveries. For Private Education Loans, at the time of charge-off, the expected recovery amount is transferred from the education loan balance to the allowance for loan loss and is referred to as the expected future recoveries on charged-off loans. For FFELP Loans, the recovery is received at the time of charge-off. ( 3 ) At the end of each month, for Private Education Loans that are 212 or more days past due, we charge off the estimated loss of a defaulted loan balance. Actual recoveries are applied against the remaining loan balance that was not charged off. We refer to this as the “expected future recoveries on charged-off loans.” If actual periodic recoveries are less than expected, the difference is immediately charged off through the allowance for Private Education Loan losses with an offsetting reduction in the expected future recoveries for charged-off loans. If actual periodic recoveries are greater than expected, they will be reflected as a recovery through the allowance for Private Education Loan losses once the cumulative recovery amount exceeds the cumulative amount originally expected to be recovered. The following table summarizes the activity in the expected future recoveries on charged-off loans: Nine Months Ended September 30, (Dollars in millions) 2020 Beginning of period expected recoveries $ 588 Expected future recoveries of current period defaults 28 Recoveries (84 ) Charge-offs (29 ) End of period expected recoveries $ 503 Change in balance during period $ (85 ) ( 4 ) The allowance used for these metrics excludes the expected future recoveries on charged-off loans to better reflect the current expected credit losses remaining in the portfolio. 2. Allowance for Loan Losses (Continued) Troubled Debt Restructurings (“TDRs”) We sometimes modify the terms of loans for customers experiencing financial difficulty. Certain Private Education Loans for which we have granted either a forbearance of greater than three months, an interest rate reduction or an extended repayment plan are classified as TDRs. Approximately 74% and 72% of the loans granted forbearance have qualified as a TDR loan at September 30, 2021 and December 31, 2020, respectively. The unpaid principal balance of TDR loans that were in an interest rate reduction program as of September 30, 2021 and December 31, 2020 was $785 million and $948 million, respectively. The following table provides the amount of loans modified in the periods presented that resulted in a TDR. Additionally, the table summarizes charge-offs occurring in the TDR portfolio, as well as TDRs for which a payment default occurred in the current period within 12 months of the loan first being designated as a TDR. We define payment default as 60 days past due for this disclosure. Three Months Ended September 30, Nine Months Ended September 30, (Dollars in millions) 2021 2020 2021 2020 Modified loans $ 40 $ 51 $ 109 $ 216 Charge-offs $ 37 $ 43 $ 90 $ 136 Payment default $ 6 $ 7 $ 15 $ 39 2. Allowance for Loan Losses (Continued) Key Credit Quality Indicators We assess and determine the collectability of our education loan portfolios by evaluating certain risk characteristics we refer to as key credit quality indicators. Key credit quality indicators are incorporated into the allowance for loan losses calculation. FFELP Loans FFELP Loans are substantially insured and guaranteed as to their principal and accrued interest in the event of default. The key credit quality indicators are loan status and loan type. FFELP Loan Delinquencies September 30, 2021 December 31, 2020 September 30, 2020 (Dollars in millions) Balance % Balance % Balance % Loans in-school/grace/deferment ( 1) $ 2,430 $ 2,791 $ 3,038 Loans in forbearance ( 2) 8,029 7,725 8,102 Loans in repayment and percentage of each status: Loans current 40,404 91.5 % 43,623 90.8 % 44,175 90.7 % Loans delinquent 31-60 days ( 3) 1,181 2.7 1,374 2.9 1,876 3.9 Loans delinquent 61-90 days ( 3) 665 1.5 836 1.7 930 1.9 Loans delinquent greater than 90 days ( 3) 1,910 4.3 2,223 4.6 1,735 3.5 Total FFELP Loans in repayment 44,160 100 % 48,056 100 % 48,716 100 % Total FFELP Loans 54,619 58,572 59,856 FFELP Loan allowance for losses (269 ) (288 ) (297 ) FFELP Loans, net $ 54,350 $ 58,284 $ 59,559 Percentage of FFELP Loans in repayment 80.9 % 82.0 % 81.4 % Delinquencies as a percentage of FFELP Loans in repayment 8.5 % 9.2 % 9.3 % FFELP Loans in forbearance as a percentage of loans in repayment and forbearance 15.4 % 13.8 % 14.3 % (1) Loans for customers who may still be attending school or engaging in other permitted educational activities and are not yet required to make payments on their loans, e.g., residency periods for medical students or a grace period for bar exam preparation, as well as loans for customers who have requested and qualify for other permitted program deferments such as military, unemployment, or economic hardships. (2) Loans for customers who have used their allowable deferment time or do not qualify for deferment, that need additional time to obtain employment or who have temporarily ceased making full payments due to hardship or other factors such as disaster relief, including COVID-19 relief programs, consistent with established loan program servicing policies and procedures. (3) The period of delinquency is based on the number of days scheduled payments are contractually past due. Loan type : (Dollars in millions) September 30, 2021 September 30, 2020 Change Stafford Loans $ 16,719 $ 18,011 $ (1,292 ) Consolidation Loans 33,143 36,876 (3,733 ) Rehab Loans 4,757 4,969 (212 ) Total $ 54,619 $ 59,856 $ (5,237 ) 2. Allowance for Loan Losses (Continued) Private Education Loans The key credit quality indicators are credit scores (FICO scores), loan status, loan seasoning, whether a loan is a TDR, the existence of a cosigner and school type. The FICO score is the higher of the borrower or co-borrower score and is updated at least every six months while school type is assessed at origination. The other Private Education Loan key quality indicators are updated quarterly. Private Education Loan Credit Quality Indicators by Origination Year September 30, 2021 (Dollars in millions) September 30, 2021 2020 2019 2018 2017 Prior Total % of Total Credit Quality Indicators FICO Scores: 640 and above $ 4,049 $ 2,228 $ 2,064 $ 762 $ 233 $ 10,021 $ 19,357 92 % Below 640 28 10 33 20 8 1,542 $ 1,641 8 Total $ 4,077 $ 2,238 $ 2,097 $ 782 $ 241 $ 11,563 $ 20,998 100 % Loan Status: In-school/grace/ deferment/forbearance $ 32 $ 34 $ 45 $ 19 $ 8 $ 1,065 $ 1,203 6 % Current/90 days or less delinquent 4,044 2,203 2,049 762 232 10,289 $ 19,579 93 Greater than 90 days delinquent 1 1 3 1 1 209 216 1 Total $ 4,077 $ 2,238 $ 2,097 $ 782 $ 241 $ 11,563 $ 20,998 100 % Seasoning ( 1) 1-12 payments $ 4,058 $ 1,017 $ 37 $ 5 $ 1 $ 142 $ 5,260 25 % 13-24 payments — 1,201 1,330 20 4 167 $ 2,722 13 25-36 payments — — 709 385 12 273 $ 1,379 7 37-48 payments — — — 364 133 417 $ 914 4 More than 48 payments — — — — 89 10,245 $ 10,334 49 Loans in-school/ grace/deferment 19 20 21 8 2 319 389 2 Total $ 4,077 $ 2,238 $ 2,097 $ 782 $ 241 $ 11,563 $ 20,998 100 % TDR Status: TDR $ 1 $ 5 $ 26 $ 27 $ 30 $ 7,323 $ 7,412 35 % Non-TDR 4,076 2,233 2,071 755 211 4,240 13,586 65 Total $ 4,077 $ 2,238 $ 2,097 $ 782 $ 241 $ 11,563 $ 20,998 100 % Cosigners: With cosigner ( 2) $ 12 $ 34 $ 13 $ — $ 37 $ 7,560 $ 7,656 36 % Without cosigner 4,065 2,204 2,084 782 204 4,003 13,342 64 Total $ 4,077 $ 2,238 $ 2,097 $ 782 $ 241 $ 11,563 $ 20,998 100 % School Type: Not-for-profit $ 3,850 $ 2,137 $ 1,957 $ 721 $ 231 $ 9,607 $ 18,503 88 % For-profit 227 101 140 61 10 1,956 2,495 12 Total $ 4,077 $ 2,238 $ 2,097 $ 782 $ 241 $ 11,563 $ 20,998 100 % Allowance for loan losses (980 ) Total loans, net $ 20,018 (1) Number of months in active repayment for which a scheduled payment was received. (2) Excluding Private Education Refinance Loans, which do not have a cosigner, the cosigner rate was 2. Allowance for Loan Losses (Continued) Private Education Loan Credit Quality Indicators by Origination Year September 30, 2020 (Dollars in millions) September 30, 2020 2019 2018 2017 2016 Prior Total % of Total Credit Quality Indicators FICO Scores: 640 and above $ 3,135 $ 3,341 $ 1,212 $ 388 $ 82 $ 11,950 $ 20,108 90 % Below 640 14 39 25 10 3 2,181 2,272 10 Total $ 3,149 $ 3,380 $ 1,237 $ 398 $ 85 $ 14,131 $ 22,380 100 % Loan Status: In-school/grace/ deferment/forbearance $ 19 $ 53 $ 26 $ 12 $ 3 $ 1,261 $ 1,374 6 % Current/90 days or less delinquent 3,130 3,325 1,210 386 82 12,738 20,871 93 Greater than 90 days delinquent — 2 1 — — 132 135 1 Total $ 3,149 $ 3,380 $ 1,237 $ 398 $ 85 $ 14,131 $ 22,380 100 % Seasoning ( 1) 1-12 payments $ 3,141 $ 2,191 $ 10 $ 2 $ — $ 193 $ 5,537 25 % 13-24 payments 1 1,169 602 10 1 252 2,035 9 25-36 payments — — 613 225 5 417 1,260 6 37-48 payments — — — 158 64 642 864 4 More than 48 payments — — — — 14 12,163 12,177 54 Loans in-school/ grace/deferment 7 20 12 3 1 464 507 2 Total $ 3,149 $ 3,380 $ 1,237 $ 398 $ 85 $ 14,131 $ 22,380 100 % TDR Status: TDR $ 1 $ 8 $ 22 $ 30 $ 11 $ 8,508 $ 8,580 38 % Non-TDR 3,148 3,372 1,215 368 74 5,623 13,800 62 Total $ 3,149 $ 3,380 $ 1,237 $ 398 $ 85 $ 14,131 $ 22,380 100 % Cosigners: With cosigner ( 2) $ 2 $ 14 $ 1 $ 53 $ 23 $ 9,259 $ 9,352 42 % Without cosigner 3,147 3,366 1,236 345 62 4,872 13,028 58 Total $ 3,149 $ 3,380 $ 1,237 $ 398 $ 85 $ 14,131 $ 22,380 100 % School Type: Not-for-profit $ 2,995 $ 3,160 $ 1,144 $ 380 $ 85 $ 11,675 $ 19,439 87 % For-profit 154 220 93 18 — 2,456 2,941 13 Total $ 3,149 $ 3,380 $ 1,237 $ 398 $ 85 $ 14,131 $ 22,380 100 % Allowance for loan losses (1,091 ) Total loans, net $ 21,289 (1) Number of months in active repayment for which a scheduled payment was received. (2) Excluding Private Education Refinance Loans, which do not have a cosigner, the cosigner rate was 2. Allowance for Loan Losses (Continued) Private Education Loan Delinquencies TDRs September 30, 2021 December 31, 2020 September 30, 2020 (Dollars in millions) Balance % Balance % Balance % Loans in-school/grace/deferment ( 1) $ 210 $ 280 $ 294 Loans in forbearance ( 2) 667 703 691 Loans in repayment and percentage of each status: Loans current 5,988 91.6 % 6,952 93.4 % 7,152 94.1 % Loans delinquent 31-60 days ( 3) 224 3.5 185 2.5 196 2.6 Loans delinquent 61-90 days ( 3) 124 1.9 114 1.5 127 1.7 Loans delinquent greater than 90 days ( 3) 198 3.0 197 2.6 120 1.6 Total TDR loans in repayment 6,534 100 % 7,448 100 % 7,595 100 % Total TDR loans 7,411 8,431 8,580 TDR loans allowance for losses (814 ) (929 ) (930 ) TDR loans, net $ 6,597 $ 7,502 $ 7,650 Percentage of TDR loans in repayment 88.2 % 88.3 % 88.5 % Delinquencies as a percentage of TDR loans in repayment 8.4 % 6.6 % 5.9 % Loans in forbearance as a percentage of TDR loans in repayment and forbearance 9.3 % 8.6 % 8.3 % (1) Deferment includes customers who have returned to school or are engaged in other permitted educational activities and are not yet required to make payments on their loans, e.g., residency periods for medical students or a grace period for bar exam preparation. (2) Loans for customers who have requested extension of grace period generally during employment transition or who have temporarily ceased making full payments due to hardship or other factors such as disaster relief, including COVID-19 relief programs, consistent with established loan program servicing policies and procedures. (3) The period of delinquency is based on the number of days scheduled payments are contractually past due. 2. Allowance for Loan Losses (Continued) Private Education Loan Delinquencies Non-TDRs September 30, 2021 December 31, 2020 September 30, 2020 (Dollars in millions) Balance % Balance % Balance % Loans in-school/grace/deferment ( 1) $ 179 $ 203 $ 213 Loans in forbearance ( 2) 147 141 176 Loans in repayment and percentage of each status: Loans current 13,208 99.6 % 13,335 99.6 % 13,355 99.6 % Loans delinquent 31-60 days ( 3) 23 .2 26 .2 28 .2 Loans delinquent 61-90 days ( 3) 12 .1 12 .1 13 .1 Loans delinquent greater than 90 days ( 3) 18 .1 20 .1 15 .1 Total non-TDR loans in repayment 13,261 100 % 13,393 100 % 13,411 100 % Total non-TDR loans 13,587 13,737 13,800 Non-TDR loans allowance for losses (166 ) (160 ) (161 ) Non-TDR loans, net $ 13,421 $ 13,577 $ 13,639 Percentage of non-TDR loans in repayment 97.6 % 97.5 % 97.2 % Delinquencies as a percentage of non-TDR loans in repayment .4 % .4 % .4 % Loans in forbearance as a percentage of non- TDR loans in repayment and forbearance 1.1 % 1.0 % 1.3 % (1) Deferment includes customers who have returned to school or are engaged in other permitted educational activities and are not yet required to make payments on their loans, e.g., residency periods for medical students or a grace period for bar exam preparation. (2) Loans for customers who have requested extension of grace period generally during employment transition or who have temporarily ceased making full payments due to hardship or other factors such as disaster relief, including COVID-19 relief programs, consistent with established loan program servicing policies and procedures. (3) The period of delinquency is based on the number of days scheduled payments are contractually past due. |