Ecmc Group Inc.

“ECMC Group, Inc. has a code of ethics and business conduct policy that is affirmed annually by all ECMC Group, Inc. and affiliated companies' officers and employees. While there is not a specific whistleblower policy, there is a provision incorporated into the code of ethics and business conduct policy that binds all employees that states there can be no repercussions for good faith reporting of potential illegal practices or violations of corporate policies. ECMC Group, Inc. has established an anonymous whistleblower telephone hotline and website administered by an outside vendor. The hotline and website are available and accessible to ECMC Group, Inc. directors, officers, employees and vendors.”

“Each Director of the ECMC Group, Inc.'s Board of Directors is a member of ECMC Group, Inc. At year end 2016, there were eight members of the Board of Directors and, therefore, eight members of the corporation. Membership terminates upon the termination of such member's director status on the Board of Directors. There are no stockholders.”

“The members of ECMC Group, Inc. Board of Directors are nominated by the Governance & Compensation Committee of the Board and elected by the Board of Directors. The Governance & Compensation Committee consists of such independent members appointed to it by the ECMC Group, Inc. Board of Directors.”

“All members of the Board of Directors and executive management of ECMC Group, Inc. and its disregarded entities are provided a copy of Form 990 to review and provide comments prior to filing. All members of the Board of Directors and executive management are provided with a copy of the final version of Form 990 before it has been filed.”

“Officers, Directors, and all employees of ECMC Group, Inc. and ECMC Shared Services Company, LLC, a disregarded entity of ECMC Group, Inc., are required to reaffirm on an annual basis their understanding of the company's Code of Ethics and Business Conduct. The affirmation specifically references that the individual will comply with the directives of the Code of Ethics and Business Conduct. Conflicts of Interest and disclosure of potential conflicts are included in the Code of Ethics and Business Conduct. Monitoring and enforcement of the policy are accomplished through the reaffirmation process. In cases where a potential conflict exists at the officer and key employee levels, the issue is disclosed to the CEO and Director of Corporate Compliance. For potential or real conflicts involving the CEO or a member of the Board of Directors, the disclosure is made to the Board Chairman. The Board member or CEO will be required to excuse themselves from deliberation and voting on matters which they may have a conflict of interest.”

“The following describes the Educational Credit Management Corporation (ECMC), Zenith Education Group, Inc. and ECMC Group, Inc., including ECMC Shared Services Company, LLC, executive compensation methodology. The Governance & Compensation Committee of the ECMC Group, Inc. Board of Directors is wholly comprised of independent, outside directors. In 2016, the Committee retained executive compensation experts from Grant Thornton, a global compensation consulting organization, through Arnold & Porter LLP to identify appropriate CEO and senior executive compensation packages. Arnold & Porter LLP provided a written opinion on the reasonableness of this compensation. The market analysis performed by Grant Thornton for Arnold & Porter LLP includes salary and incentive data from an appropriate peer group under IRS regulations and includes both nonprofit and for-profit entities.”

“The following describes the Educational Credit Management Corporation (ECMC), Zenith Education Group, Inc. and ECMC Group, Inc., including ECMC Shared Services Company, LLC, executive compensation methodology. The Governance & Compensation Committee of the ECMC Group, Inc. Board of Directors is wholly comprised of independent, outside directors. In 2016, the Committee retained executive compensation experts from Grant Thornton, a global compensation consulting organization, through Arnold & Porter LLP to identify appropriate CEO and senior executive compensation packages. Arnold & Porter LLP provided a written opinion on the reasonableness of this compensation. The market analysis performed by Grant Thornton for Arnold & Porter LLP includes salary and incentive data from an appropriate peer group under IRS regulations and includes both nonprofit and for-profit entities.”

“No documents are made available to the public.”

“Robert Stein, a former Director, had a consulting agreement in 2016.”

“(Expenses $ 319,234 including grants of $ 0)(Revenue $ 0) THROUGH THE PUBLIC POLICY PROGRAM, ECMC GROUP, INC. SHARES INFORMATION AMONG ECMC GROUP-RELATED MEMBERS ON LEGISLATIVE PROPOSALS AND GOVERNMENTAL REGULATIONS THAT IMPACT THEIR OPERATIONS. THE PROGRAM ENABLES ECMC GROUP, INC. AFFILIATES TO MONITOR PUBLIC POLICY MATTERS AND PROVIDE NONPARTISAN ANALYSIS AND RESEARCH TO POLICYMAKERS, THOUGHT LEADERS AND THE GENERAL PUBLIC.”

“Net unrealized loss on investment in the ECMC Group, Inc. Investment Pool are $1,046,735.”

“Transfer of Net Assets - 10424162;”

“$10,424,162. Transfer of Net Assets. $5,948,508. On January 1, 2016, approximately 246 Educational Credit Management Corporation (ECMC) employees in the information technology, finance and accounting, human resources, and other corporate support departments were hired into ECMC Shared Services Company, LLC, a wholly owned subsidiary of ECMC Group, Inc. Additionally, property, equipment and leasehold improvements of approximately $3.59 million, net of accumulated depreciation and amortization, and prepaid expenses and other assets of approximately $2.36 million, were transferred into ECMC Shared Services Company, LLC, a wholly owned subsidiary of ECMC Group, Inc. $4,475,654. On January 1, 2016 approximately 175 Zenith Education Group, Inc. employees in the information technology, finance and accounting, human resources, and other corporate support departments were hired into ECMC Shared Services Company, LLC, a wholly owned subsidiary of ECMC Group, Inc. Additionally, the related property, equipment, and leasehold improvements of approximately $2.91 million and prepaid expenses and other assets of approximately $1.57 million were transferred into ECMC Shared Services Company, LLC, a wholly owned subsidiary of ECMC Group, Inc.”