Bergeron, David

From:
Sent:
To:
Subject:
David,
Babel, Tom [Tbabel@devry.comJ
Friday, October 22, 2010 9:06AM
Bergeron, David
Meeting follow-up
Good to see you yesterday. In general, we were pleased with the active engagement and hopefully we provided
constructive and useful comments I want to follow-up with you and the team on the question of the impact on the
debt-burden rates for DeVry if the repayment term was extended. How best should this be done 7 Is it a phone
conversation? If I send you information via email, does that have to be entered into the public record? The issue for us,
if it does, it is not information that we have disclosed publicly and we may have to Issue an 8-K with that information.
Please advise. Thanks,
Tom
Thomas Babel
Vice President
Regulatory Affairs
OeVry Inc.
3005 Highland Parkway
Downers Grove, I L 60515
p: 630.515.3133
m:
f: 630.353.9903
e: tbabel@devrv.edu
www.devrv.edu
1
Bergeron, David
From:
Sent:
To:
Subject:
Hi David,
Babel, Tom [Tbabel@devry.com]
Friday, October 15, 2010 4:43 PM
Bergeron, David
Call
Since we seem to be unable to catch each other at our desks, let's try this (alternatively, my cell number is below, feel
free to call me anytime). Deputy Secretary Miller had indicated to our CEO (Daniel Hamburger) that ED would be
following up with schools for additional information and clarification through a series of additional hearings and
meetings. My call was initially designed to get a better perspective of how those would be done and when. Today's
news about the meetings scheduled for 11/4-5 answers some of t hose questions but raises others. The outstanding
question really is will there be any 1-1 meetings scheduled with some institutions or entities or is this the only
opportunity for clarification? For example, what if ED was i ntrigued with something offered by an institution, but that
institution did not register for comment in these public meetings? Is there an alternative process that ED will use to
clarify to proposal? Thanks- hope you're getting some t ime away from reading all of the comments.
Tom
Thomas Babel
Vice President
Regulatory Affairs
DeVry Inc.
3005 Highland Parkway
Downers Grove, IL 60515
p: 630.515.3133
m: ___ _
f: 630.353.9903
e: tbabel@devrv.edu
www.devry.edu
1
J
Bergeron, David
From:
Sent:
To:
Babel , Tom [Tbabel@devry.com]
Monday, September 20, 2010 3:03 PM
Bergeron, David
Subject: Fw: Repayment Rate Reporting from Servicers
Hi David,
Here's a question that I hope is outside of nprm scope. See below? Any reason why? Isn't ED interested in schools
helping borrowers get on track? Thanks?
Tom Babel
Vice President, Regulatory Affairs
(630) 353-3133 (o)
From: Sakos, Tom
To: Babel, Tom
sent: Mon Sep 20 13:56:09 2010
Subject: Repayment Rate Reporting from Servicers
This is odd. Spoke to Nelnet folks about getting a report showing princi pal reductions on loans and they told me that
they were providing t hat reporting to schools that asked for It on ad hoc basis but were told by Dept of Ed to stop. So
they currently are not providing that data until Dept giv.es them green light. Have not heard the same from other
servicers.
Tom Sakos
Director of Student Lending
DeVry Inc
3005 Highland Parkway
Downers Grove, IL 60515
p. 630/353-9923
f. 630/353-9903
c.
e: tsakos@devrv.com
www.devry.edu
1
Bergeron, David
From:
Sent:
To:
Babel, Tom [Tbabel@devry.com]
Monday, August 23, 2010 9:52AM
Bergeron, David
Subject: RE: GE2 repayment rate calculation
Hi any luck with finding a reason why your counts would be so much lower than our CDR
counts?
Tom
Thomas Babel
Vice President
Affairs
DeVry Inc.
3ees Highland Parkway
Downers Grove, IL 6e515
.......
f: 63e. 3s3.99e3
e: t babel@devry.edu
www.devry. edu
- ----Original Message-----
From: David [mailto:David.Bergeron@ed.gov]
Sent: August 15, 2e1e 3:13 PM
To: Babel, Tom
Subject: Re : GE2 repayment rate calculation
Yes, they are. The principal balance is the portion of the consolidation loan associated
with a school. We then observe whether the consolidation loan balance declines . If it does,
the school gets credit for the portion of the consolidation loan associated with the school.
David A. Bergeron
Sent using BlackBerry
- --- - Original Message -----
From: Babel, Tom <Tbabel@devry.com>
To: Bergeron, David
Sent: Sun Aug 15 14:28:41 2e1e
Subject: Re: GE2 repayment rate cal culation
David, I'm confused about how consolidation loans are treated. Can you clarify whether they
are in the repayment rate and if so, how the original outstanding principal balance is
calculated for these. Thanks, Tom Babel Vice President, Regulatory Affairs
(63e) 353-3133 (o)
1
----- Ori ginal Message -----
From: Bergeron, Davi d <David. Bergeron@ed.gov>
To: Babel, Tom
Sent: Sat Aug 14 10:32:20 2010
Subject: Re : GE2 repayment rate calculation
The treat ment of consolidation loans is critical. A consolidation loan generally is a paid
in full. It is for cdr purposes) for example. SoJ we look at whether the consolidation is
being paid down for this purpose even if there are multiple consolidations . We know that
cdrs are suppressed because of consolidation. We'll conti nue to look at the data but the
experts tested and re-tested the query, we benchedmarked agai nst known national numbers, and
tried to ensure the accuracy of the estimates.
David A. Bergeron
Sent using BlackBerry
- ---- Original Message -----
From: BabelJ Tom <Tbabel@devry.com>
To: Bergeron) David
Sent: Fri Aug 13 22:98:22 2919
Subject: Re: GE2 repayment rate calculation
David, thanks for the quick response . I know you guys are working hard to get this right.
Fundamentally, I don't object to this metric ( repay rate) . But, its got to be right. At
first glance, I've got several big disconnects :
1. The 27,099 difference is more than 1 year's denominator in our cdr cohorts.
2. There is such a huge difference between the complement of our 3-yr cdr (85 pet) v. Our 37
pet repay rate.
3. Our analysis of nslds dat a from LRDR reports puts our repay rate quite a bit higher, for
which we thought we were using some pretty conservative assumptions.
4. Finally, the rates at some very selective traditional school s are much lower than I would
expect - even those which appear to have very manageable debt levels.
I l ook forward to discussing with you further. Thanks again, Tom Babel Vice President)
Regulatory Affairs
(639) 353- 3133 (o)
-- --- Original Message -----
From: Bergeron, David <David.Bergeron@ed.gov>
To: Babel, Tom
Sent: Fri Aug 13 21:28:39 2919
Subject: RE: GE2 repayment rate calculation
Thank for the feedback Tom. In our esti mates, we gave borrowers 6 months after entering
repayment before looking to see if their balance was declini ng. This may not be well
articulated in the proposed rule but we didn't think it fair to count those recently entering
repayment in the repayment rate calculation. That coul d certai nly explain the missing 27,ee9
but I'll look into this further next week. The other issue is the treatment of consolidation
loans but that treatment is less likely to explain what you've observed. David
From: Babel, Tom [Tbabel@devry. com]
2
Sent: Friday, August 13, 2010 7:02 PM
To: Bergeron, David
Subject: GE2 repayment rate calculation
Hi David,
I'm wondering if we can talk a bit more on your methodology - no comments about
appropriateness or anything that would be better made in our official comment. We see quite
a bit of inconsistency in some of the rates reported out today and that which we were able to
calculate right off NSLDS and with lender information. I also note quite a difference in the
cohorts reported in today's release and those in our last four CDR's. For example, DeVry
University cohorts in the repayment reports sums up to about 75,000 students. Yet in the
last 4 CDR's it sums up to more than 102,000. Where did the 27,000 go? Thanks,
Tom
Thomas Babel
Vice President
Regulatory Affairs
DeVry Inc . .
3005 Highland Parkway
Downers Grove, IL 60515
p: 630.515.3133
f: 630.353 . 9903
e: tbabel@devry. edu<mailto:tbabel@devry.eom>
www.devry.edu<http://www.devry.com/>
lfid:image001.png@01CB3B11. 9223BE90]
3
Bergeron, David
From:
Sent:
To:
Babel, Tom [Tbabel@devry.com]
Sunday, August 15, 2010 5:34PM
Bergeron, David
Subject: Re: GE2 repayment rate calculation
Thanks. Then my question about my missing 27,eee students still stands.
Tom Babel
Regulatory Affairs
----- Original Message -----
From: Bergeron, David <David.Bergeron@ed.gov>
To: Babel, Tom
Sent: Sun Aug 15 15:12:31 2010
Subject: Re: GE2 repayment rate calculation
Yes, they are. The principal balance is the portion of the consolidation loan associated
with a school . We then observe whether the consolidation loan balance declines. If it does,
the school gets credit for the portion of the consolidation loan associated with the school.
David A. Bergeron
Sent using BlackBerry
----- Original Message -----
From: Babel, Tom <Tbabel@devry.com>
To: Bergeron, David
Sent: Sun Aug 15 14:20:41 2010
Subject: Re: GE2 repayment rate calculation
David, I'm confused about how consolidation loans are treated. Can you clarify whether they
are in the repayment rate and if so, how the original outstanding principal balance is
calculated for these. Thanks, Tom Babel Vice President, Regulatory Affairs
----- Original Message -----
From: Bergeron, David <David.Bergeron@ed.gov>
To: Babel, Tom
Sent: Sat Aug 14 10:32:20 2010
Subject: Re: GE2 repayment rate calculation
The treatment of consolidation loans is critical. A consolidation loan generally is a paid
in full. It is for cdr purposes, for example. So, we look at whether t _he consolidation is
being paid down for this purpose even if there are multiple consolidations. We know that
cdrs are suppressed because of consolidation. We'll continue to look at the data but the
experts tested and re-tested the query, we benchedmarked against known national numbers, and
tried to ensure the accuracy of the estimates.
David A. Bergeron
1
Sent using BlackBerry
-- - -- Original Message -----
From: Babel, Tom <Tbabel@devry.com>
To: Bergeron, David
Sent: Fri Aug 13 22:08:22 2010
Subject: Re: GE2 repayment rate calculation
David, thanks for the quick response. I know you guys are working hard to get this right.
Fundamentally, I don't object to this metric ( repay rate). But, its got to be right. At
first glance, I've got several big disconnects:
1. The 27,000 difference is more than 1 year's denominator in our cdr cohorts.
2. There is such a huge difference between the complement of our 3-yr cdr (85 pet) v. Our 37
pet repay rate.
3. Our analysis of nsl ds data from LRDR reports puts our repay rate quite a bit higher, for
which we thought we were using some pretty conservative assumptions.
4. Finally, the rates at some very selective traditional schools are much lower than I would
expect - even those which appear to have very manageable debt levels.
you further. Thanks again, Tom Babel Vice President,
---- - Original Message -----
From: Bergeron; David <David.Bergeron@ed.gov>
To: Babel, Tom
Sent: Fri Aug 13 21:28: 39 2010
Subject: RE: GE2 repayment rate calculation
Thank for the feedback Tom. In our estimates , we gave borrowers 6 months after entering
repayment before looking to see if their balance was declining. This may not be well
articulated in the proposed rule but we didn't think it fair to count those recently entering
repayment in the repayment rate calculation. That could certainly explain the missing 27,000
but I'll look into this further next week. The other issue is the treatment of consolidation
loans but that 'treatment is less likely to explain what you ' ve observed. David
From: Babel, Tom [Tbabel@devry.com]
Sent: Friday, August 13, 2010 7:02 PM
To: Bergeron, David
Subject: GE2 repayment rate calculation
Hi David,
I'm wondering if we can talk a bit more on your methodology - no comments about
appropriateness or anything that would be better made in our official comment . We see quite
a bit of inconsistency in some of the rates reported out today and that which we were able to
calculate right off NSLDS and with lender information. I also note quite a difference in the
cohorts reported in today's release and those in our last four CDR's. For example, DeVry
University cohorts in the repayment reports sums up to about 75,000 students. Yet in the
l ast 4 CDR's it sums up to more than 102,000. Where did the 27,000 go? Thanks,
Tom
Thomas Babel
Vice President
2
Regulatory Affairs
DeVry Inc.
3ees Highland Parkway
Downers Grove, IL 6e515
f: 63e.3S3.99e3
e: tbabel@devry.edu<mailto:tbabel@devry. eom>
www.devry.edu<http://www.devry.com/>
[cid: imageeel.png@e1CB3B11.9223BE9el
3
Bergeron, David
From:
Sent:
To:
Subject:
Hi David,
Babel, Tom [Tbabel@devry.comJ
Friday, August 13, 2010 7:02PM
Bergeron, David
GE2 repayment rate calculation
I'm wondering if we can talk a bit more on your methodology - no comments about appropriateness or anything that
would be better made in our official comment. We see quite a bit of inconsistency i n some of the rates reported out
today and that which we were able to calculate right off NSLDS and with lender information. I also note quite a
difference in t he cohorts reported in today's release and those in our last four CDR's. For example, DeVry University
cohorts in t he repayment reports sums up to about 75,000 students. Yet i n the last 4 CDR's it sums up to more than
102,000. Where did the 27,000 go? Thanks,
Tom
Thomas Babel
Vice President
Regulatory Affairs
DeVry Inc.
3005 Highland Parkway
Downers Grove, IL 60515
p: 630.515.3133
f: 630.353.9903
e: tbabel@devry.edu
www.devry.edu
1
Bergeron, David
From:
Sent:
To:
Babel, Tom [Tbabel@devry.com]
Friday, August 13,2010 11 :08 PM
Bergeron, David
Subject: Re: GE2 repayment rate calculation
David, thanks for the quick response. I know you guys are working hard to get this right.
Fundamentally, I don't object to this metric ( repay rate). But, its got to be right. At
first glance, I've got several big disconnects:
1. The 27,000 difference is more than 1 year's denominator in our cdr cohorts.
2. There is such a huge difference between the complement of our 3-yr cdr (85 pet) v. Our 37
pet repay rate.
3. Our analysis of nslds data f rom LRDR r e p o ~ t s puts our repay rate quite a bit higher, for
which we thought we were using some pretty conservative assumptions.
4. Finally, the rates at some very selective traditional schools are much lower than I would
expect - even those which appear to have very manageable debt levels .
I look forward to discussing with you further . Thanks again, Tom Babel Vice President,
Regulatory Affairs
(630) 353-3133 (o)
----- Original Message -----
From: Bergeron, David <David.Bergeron@ed.gov>
To: Babel, Tom
Sent: Fri Aug 13 21:28:39 2010
Subject: RE: GE2 repayment rate calculation
Thank for the feedback Tom. In our estimates, we gave borrowers 6 months after entering
repayment before looking to see if their balance was declining. This may not be well
articulated in the proposed rule but we didn ' t think it fair to count those recently entering
repayment in the repayment rate calculation. That could certainly explain the missing 27,000
but I'll look into this further next week. The other issue is the treatment of consolidation
loans but that treatment is less likely to explain what you've observed. David
From: Babel, Tom (Tbabel@devry.com]
Sent: Friday, August 13, 2010 7:02 PM
To: Bergeron, David
Subject: GE2 repayment rate calculation
Hi David,
I'm wondering if we can talk a bit more on your methodology - no comments about
appropriateness or anything that would be better made in our official comment. We see quite
a bit of inconsistency in some of the rates reported out today and that which we were able to
calculate right off NSLDS and with lender information. I also note quite a difference in the
cohorts reported in today,s release and those in our last four CDR,s. For example, DeVry
University cohorts in the repayment reports sums up to about 75,000 students. Yet in the
last 4 CDR's it sums up to more than 102,000. Where did the 27,000 go? Thanks,
Tom
Thomas Babel
Vice President
Regulatory Affairs
1
DeVry Inc.
3885 Highland Parkway
Downers G r o v e ~ IL 68515
f: 638.353 . 9983
e: tbabel@devry.edu<mailto:tbabel@devry.eom>
www.devry.edu<http://www.devry.com/>
[cid:imageeel . png@01CB3811.9223BE98l
2