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 retaliation against anyone acting in good faith when asking a question, reporting a concern or for participating in an investigation. ECMC Group, Inc. has established an anonymous telephone hotline and website administered by an outside vendor to report concerns. 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 2019, 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 Conflict of Interest Policy. The affirmation specifically references that the individual will comply with the directives of the Conflict of Interest Policy. Officers, Directors and key employees are also required to complete an annual Form 990 relationship disclosure document to identify any potential conflicts of interest. Finally, the company's vendor procurement process includes questions of business unit contract owners to determine if any conflicts of interest may exist. Monitoring and enforcement of the policy are accomplished through the policy reaffirmation process, affirmative disclosure requests and the policy requirement that all conflicts of interest be reported. In cases where a potential conflict exists at the officer and key employee levels, the issue is disclosed to the ECMC Group, Inc. CEO, General Counsel, and/or Vice President, Deputy General Counsel. For potential or real conflicts involving Directors or officers, the disclosure is made to the Board Chair. The Director or officer 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), ECMC Education, Inc. (formerly 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 2019, 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 an 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), ECMC Education, Inc. (formerly 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 2019, 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 an 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.”

“Roberta Cooper Ramo and I. King Jordan, former Directors, had consulting agreements in 2019.”

“(Expenses $ 419,207 including grants of $ 419,207)(Revenue $ 0) Grants and sponsorships supplied by ECMC Group, Inc. to schools and individuals in support of its tax-exempt purpose.”

“Other liabilities at December 31, 2019, include $691,875,570 ECMC Foundation deposits in the ECMC Group, Inc. Apportioned Investment Pool ("Apportioned Investment Pool"). A portion of ECMC Group, Inc.'s assets are held in the ECMC Group, Inc. Investment Portfolio Asset Pool which is managed by ECMC Group, Inc. Participation in the Apportioned Investment Pool is available to ECMC Group, Inc. and its eligible subsidiaries. Investments in the Apportioned Investment Pool represent an ownership interest in the investment pool, not in the underlying assets themselves, and are generally redeemable to the eligible subsidiary upon request. Unapportioned Investments, net, are not subject to participation by ECMC Group, Inc.'s subsidiaries.”

“Net unrealized loss on investment in the ECMC Group, Inc. Apportioned Investment Pool are $7,047,453.”

“$21,322,640 Other Changes in Net Assets or Fund Balances. $32,865,351 Provision for Loss on Note Receivable. $11,542,711 Cumulative Net Unrealized Gain Adjustment at January 1, 2019, for the Initial Adoption of Accounting Standards Update (ASU) No. 2016-01, Financial Instruments-Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial Liabilities, issued by the Financial Accounting Standards Board (FASB). This Initial Adoption Adjustment represents the difference in the carrying value and fair value of the Impact Investments and Other Direct Investments in the ECMC Group, Inc. Apportioned Investment Pool as of December 31, 2018.”

“Provision for Loss on Note Receivable - -32865351; Adjustment for Initial Adoption of Accounting Standards Update (ASU) No. 2016-01 - 11542711;”