Risk Factors Update Summary

• Transition from LIBOR to alternative reference rates could adversely affect business and financial results.
• Expanded internal controls and procedures to mitigate legal risk and reputational harm. Failure can have a material adverse effect.
• Increase in consolidation loans may result from competition, impacting loan portfolios.
• Increased focus on unpredictable catastrophic events, including natural disasters, labor disputes, and climate change.
• Changes in accounting standards could adversely affect capital levels, results of operation, and financial condition.
• Enhanced attention to climate change risks and potential impacts on financial condition and operations.
• Failure to meet regulatory capital requirements may lead to mandatory actions affecting cost of capital.
• Increased competition in the Private Education Loan market may lead to consolidation or refinancing risks.
• Failure or interruption of third-party vendors could adversely affect business, financial condition, and results of operations.
• Increased regulatory scrutiny and supervision may result in additional compliance costs and impact operations.