Short-term borrowings

March 31, 2020 December 31, 2019
Short-Term Long-Term Total Short-Term Long-Term Total
Unsecured borrowings:
Unsecured debt (fixed-rate) $ — $ 198,362 $ 198,362 $ — $ 198,159 $ 198,159
Total unsecured borrowings — 198,362 198,362 — 198,159 198,159
Secured borrowings:
Private Education Loan term securitizations:
Fixed-rate — 2,912,346 2,912,346 — 2,629,902 2,629,902
Variable-rate — 1,597,328 1,597,328 — 1,525,976 1,525,976
Total Private Education Loan term securitizations — 4,509,674 4,509,674 — 4,155,878 4,155,878
Secured Borrowing Facility — — — 289,230 — 289,230
Total secured borrowings — 4,509,674 4,509,674 289,230 4,155,878 4,445,108
Total $ — $ 4,708,036 $ 4,708,036 $ 289,230 $ 4,354,037 $ 4,643,267

On February 17, 2021, we amended our Secured Borrowing Facility to extend the maturity of the facility. We hold 100 percent of the residual interest in the Secured Borrowing Facility trust. Under the amended Secured Borrowing Facility, we incur financing costs on unused borrowing capacity and on outstanding advances. The amended Secured Borrowing Facility extended the revolving period, during which we may borrow, repay and reborrow funds, until February 16, 2022. The scheduled amortization period, during which amounts outstanding under the Secured Borrowing Facility must be repaid, ends on February 16, 2023 (or earlier, if certain material adverse events occur). At March 31, 2021 and December 31, 2020, there were no secured borrowings outstanding under the Secured Borrowing Facility.

Other Borrowing Sources

We maintain discretionary uncommitted Federal Funds lines of credit with various correspondent banks, which totaled $125 million at March 31, ~~2020.~~2021. The interest rate we are charged on these lines of credit is priced at Fed Funds plus a spread at the time of borrowing and is payable daily. We did not utilize these lines of credit in the three months ended March 31, ~~2020~~2021 or in the year ended December 31, ~~2019.~~2020.

We established an account at the FRB to meet eligibility requirements for access to the Primary Credit borrowing facility at the FRB’s Window. The Primary Credit borrowing facility is a lending program available to depository institutions that are in generally sound financial condition. All borrowings at the Window must be fully collateralized. We can pledge asset-backed and mortgage-backed securities, as well as FFELP Loans and Private Education Loans, to the FRB as collateral for borrowings at the Window. Generally, collateral value is assigned based on the estimated fair value of the pledged assets. At March 31, ~~2020~~2021 and December 31, ~~2019,~~2020, the value of our pledged collateral at the FRB totaled ~~$2.4~~$3.2 billion and ~~$3.2~~$3.8 billion, respectively. The interest rate charged to us is the discount rate set by the FRB. We did not utilize this facility in the three months ended March 31, ~~2020~~2021 or in the year ended December 31, ~~2019.~~2020.

Contractual Loan Commitments

When we approve a Private Education Loan at the beginning of an academic year, that approval may cover the borrowing for the entire academic year. As such, we do not always disburse the full amount of the loan at the time of such approval, but instead have a commitment to fund a portion of the loan at a later date (usually at the start of the second semester or subsequent trimesters). We estimate expected credit losses over the contractual period in which we are exposed to credit risk via a contractual obligation to extend credit, unless that obligation is unconditionally cancellable by us. At March 31, ~~2020,~~2021, we had ~~$450~~$457 million of outstanding contractual loan commitments ~~which~~that we expect to fund during the remainder of the ~~2019/2020~~2020/2021 academic year. At March 31, ~~2020,~~2021, we had a ~~$30~~$19 million reserve recorded in “Other Liabilities” to cover lifetime expected credit losses on these unfunded commitments.

Critical Accounting Policies and Estimates

Management’s Discussion and Analysis of Financial Condition and Results of Operations addresses our consolidated financial statements, which have been prepared in accordance with GAAP. A discussion of our critical accounting policies, which include allowance for ~~loan~~credit losses and derivative accounting, can be found in our ~~2019~~2020 Form 10-K. On January 1, 2020, we adopted FASB’s ASU No. 2016-13, “Financial Instruments-Credit Losses (Topic 326): Measurement of Credit Losses on Financial Instruments,” (“CECL”) which resulted in a significant change to our allowance for loan losses policy, and is outlined below. There were no significant changes to our ~~derivative~~critical accounting ~~policy~~policies during the three months ended March 31, ~~2020.~~2021.

~~Recently Issued and Adopted Accounting Pronouncements~~

~~ASU No. 2016-13, “Financial Instruments-Credit Losses (Topic 326): Measurement of Credit Losses on Financial Instruments”~~

In June 2016, the FASB issued ASU No. 2016-13, which became effective for us on January 1, 2020. This ASU eliminated the previous accounting guidance for the recognition of credit impairment. Under the new guidance, for all loans carried at amortized cost, upon loan origination we are required to measure our allowance for credit losses based on our estimate of all current expected credit losses over the remaining contractual term of the assets. Updates to that estimate each period will be recorded through provision expense. The estimate of credit losses must be based on historical experience, current conditions, and reasonable and supportable forecasts. The ASU does not mandate the use of any specific method for estimating credit loss, permitting companies to use judgment in selecting the approach that is most appropriate in their circumstances.

In addition, Topic 326 made changes to the accounting for available-for-sale debt securities. One such change is to require an assessment of unrealized losses on available-for-sale debt securities that we have the ability and intent to hold for a period of time sufficient to recover the amortized cost of the security, for the purpose of determining credit impairment. If any credit impairment exists, an allowance for losses must be established for the amount of the unrealized loss that is determined to be credit-related.

On January 1, 2020, we adopted CECL using the modified retrospective method and it had a material impact on how we record and report our financial condition and results of operations and on regulatory capital. The following table illustrates the impact of the cumulative effect adjustment made upon adoption of CECL:

8983

January 1, 2020
(Dollars in thousands) As reported under CECL Pre-CECL Adoption Impact of CECL Adoption
Assets:
Allowance for loan losses:
Private Education Loans $ 1,435,130 $ 374,300 $ 1,060,830
FFELP Loans 4,485 1,633 2,852
Personal Loans 145,060 65,877 79,183
Credit Card 290 102 188
Total $ 1,584,965 $ 441,912 $ 1,143,053
Deferred tax asset $ 415,540 $ 109,369 $ 306,171
Liabilities:
Allowance for loan losses:
Off-balance sheet exposures $ 118,239 $ 2,481 $ 115,758
Equity:
Retained Earnings $ 897,873 $ 1,850,512 $ (952,639)

~~This transition adjustment is inclusive of qualitative adjustments incorporated into our CECL allowance as necessary, to address any limitations in the models used.~~

~~Allowance for Credit Losses~~

~~We maintain an allowance for loan losses for the lifetime expected credit losses on loans in our portfolios, as well as for future loan commitments, at the reporting date.~~

In determining the lifetime expected credit losses on our Private Education Loan and Personal Loan portfolios, we use a discounted cash flow model. This method requires us to project future principal and interest cash flows on our loans in those portfolios.

To estimate the future expected cash flows, we use a vintage-based model that considers life of loan loss expectations, prepayments (both voluntary and involuntary), defaults, recoveries and any other adjustments deemed necessary, to determine the adequacy of the allowance at each balance sheet date. These cash flows are discounted at the loan’s effective interest rate to calculate the present value of those cash flows. Management adjusts the effective interest rate used to discount expected cash flows to incorporate expected prepayments. The difference between the present value of those cash flows and the amortized cost basis of the underlying loans is the allowance for loan losses. Entities that measure credit losses based on the present value of expected future cash flows are permitted to report the entire change in present value as credit loss expense, but may alternatively report the change in present value due to the passage of time as interest income. We have elected to report the entire change in present value as credit loss expense.

In determining the loss rates used for the vintage-based approach, we start with our historical loss rates, stratify the loans within each vintage, and then adjust the loss rates based upon exogenous factors over a reasonable and supportable period. The reasonable and supportable period is meant to represent the period in which we believe we can estimate the impact of forecasted economic variables in our expected losses. At the end of the reasonable and supportable period, we immediately revert our forecast of expected losses to our historical averages. We use a two-year reasonable and supportable period, although this period is subject to change as our view evolves on our ability to reasonably estimate future losses based upon economic forecasts.

In estimating our current expected credit losses, we use our historical experience to derive a base case adjusted for any qualitative factors (as described below). We also develop an adverse and favorable economic scenario as well. At each

reporting date, we determine the appropriate weighting of these alternate scenarios based upon the current economic conditions and our view of the risks of alternate outcomes. This weighting of expectations is used in calculating our current expected credit losses recorded each period.

In estimating recoveries, we use both estimates of what we would receive from the sale of defaulted loans as well as historical borrower payment behavior to estimate the timing and amount of future recoveries on charged-off loans.

Our prepayment estimates include the effect of voluntary prepayments and consolidation (if the loans are consolidated to third parties), both of which shorten the lives of loans. Constant Prepayment Rate (“CPR”) estimates also consider the utilization of deferment, forbearance, and extended repayment plans, which lengthen the lives of loans. We regularly evaluate the assumptions used to estimate the CPRs. We use economic forecasts to help in the estimation of future CPRs. As with our loss forecasts, at the end of the two-year reasonable and supportable forecast for CPRs, we immediately revert to our historical long-term CPR rates.

In addition to the above modeling approach, we also take certain other qualitative factors into consideration when calculating the allowance for loan losses. These qualitative factors include, but are not limited to, changes in lending policies and procedures, including changes in underwriting standards and collection, charge-off and recovery practices not already included in the analysis, and the effect of other external factors such as legal and regulatory requirements on the level of estimated current expected credit losses.

The evaluation of the allowance for loan losses is inherently subjective, as it requires material estimates that may be susceptible to significant changes. If actual future performance in delinquency, charge-offs and recoveries is significantly different than estimated, or management assumptions or practices were to change, this could materially affect the estimate of the allowance for loan losses, the timing of when losses are recognized, and the related provision for credit losses on our consolidated statements of income.

~~Below we describe in further detail our policies and procedures for the allowance for loan losses as they relate to our Private Education Loan, Personal Loan, Credit Card and FFELP Loan portfolios.~~

~~Allowance for Private Education Loan Losses~~

We collect on defaulted loans through a mix of in-house collectors, third-party collectors and sales to third-parties. For March 31, 2020 and December 31, 2019, we used both an estimate of recovery rates from in-house collections as well as expectations of future sales of defaulted loans to estimate the timing and amount of future recoveries on charged-off loans.

In addition to the key assumptions/estimates above, some estimates are unique to our Private Education Loan portfolio. Estimates are made on our Private Education Loans regarding when each borrower will separate from school. The cash flow timing of when a borrower will begin making full principal and interest payments is dependent upon when the student either graduates or leaves school. These dates can change based upon many factors. We receive information regarding projected graduation dates from a third-party clearinghouse. The separation from school date will be updated quarterly based on updated information received from the school clearinghouse.

Additionally, when we have a contractual obligation to fund a loan or a portion of a loan at a later date, we make an estimate regarding the percentage of this obligation that will be funded. This estimate is based on historical experience. For unfunded commitments, we recognize the life of loan allowance as a liability. Once the loan is funded, that liability transfers to the allowance for Private Education Loan losses.

~~Key Credit Quality Indicators - Private Education Loans~~

We determine the collectability of our Private Education Loan portfolio by evaluating certain risk characteristics. We consider credit score at original approval and periodically refreshed/updated credit scores through the loan’s term, existence of a cosigner, loan status and loan seasoning as the key credit quality indicators because they have the most significant effect on the determination of the adequacy of our allowance for loan losses. Credit scores are an indicator of the creditworthiness of borrowers and the higher the credit scores the more likely it is the borrowers will be able to make all of their contractual payments. Loan status affects the credit risk because a past due loan is more likely to result in a credit loss than a current loan. Additionally, loans in the deferred payment status have different credit risk profiles compared with those in current pay status. Loan seasoning affects credit risk because a loan with a history of making payments generally has a lower incidence of default than a loan with a history of making infrequent or no payments. The existence of a cosigner lowers the likelihood of default as well. We monitor and update these credit quality indicators in the analysis of the adequacy of our allowance for loan losses on a quarterly basis.

Private Education Loans generally do not require borrowers to begin repayment until at least six months after the borrowers have graduated or otherwise separated from school. Consequently, the loss estimates for these loans is generally low while the borrower is in school and then increases upon the end of the six-month grace period after separation from school. At March 31, 2020 and December 31, 2019, 27 percent and 25 percent, respectively, of the principal balance of the Private Education Loan portfolio was related to borrowers who are in an in-school (fully deferred), grace, or other deferment status and not required to make payments.

Our collection policies for Private Education Loans allow for periods of nonpayment for certain borrowers requesting an extended grace period upon leaving school or experiencing temporary difficulty meeting payment obligations. This is referred to as forbearance and is considered in estimating the allowance for loan losses.

As part of concluding on the adequacy of the allowance for loan losses for Private Education Loans, we review key allowance and loan metrics. The most relevant of these metrics considered are the allowance as a percentage of ending total loans, delinquency percentages and forbearance percentages.

~~We consider a Private Education Loan to be delinquent 31 days after the last payment was contractually due.~~

~~Troubled Debt Restructurings~~

In estimating the expected defaults for our Private Education Loans that are considered TDRs, we follow the same discounted cash flow process described above but use the historical loss rates related to past TDR loans. The appropriate gross loss rates are determined for each individual loan by determining loan maturity, risk characteristics and macroeconomic conditions.

The allowance for our TDR portfolio is included in our overall allowance for Private Education Loans. Our TDR portfolio is comprised mostly of loans with interest rate reductions and loans with forbearance usage greater than three months, as further described below.

We adjust the terms of loans for certain borrowers when we believe such changes will help our customers manage their student loan obligations, achieve better student outcomes, and increase the collectability of the loans. These changes generally take the form of a temporary forbearance of payments, a temporary interest rate reduction, a temporary interest rate reduction with a permanent extension of the loan term, and/or a short-term extended repayment alternative. When we give a borrower facing financial difficulty an interest rate reduction, we temporarily reduce the rate (currently to 4.0 percent) for a two-year period and, in the vast majority of cases, permanently extend the final maturity of the loan. The combination of these two loan term changes helps reduce the monthly payment due from the borrower and increases the likelihood the borrower will remain current during the interest rate modification period as well as when the loan returns to its original contractual interest rate.

We classify a loan as a TDR due to forbearance using a two-step process. The first step is to identify a loan that was in full principal and interest repayment status and received more than three months of forbearance in a 24-month period; however, during the first nine months after a loan had entered full principal and interest repayment status, we do not count up to the first six months of forbearance received during that period against the three-month policy limit. The second step is to evaluate the creditworthiness of the loan by examining its most recent refreshed FICO score. Loans that have met the criteria in the first test and have a FICO score above a certain threshold (based on the most recent quarterly FICO score refresh) will not be classified as TDRs. Loans that have met the criteria in the first test and have a FICO score under the threshold (based on the most recent quarterly FICO score refresh) will be classified as TDRs.

A loan also becomes a TDR when it is modified to reduce the interest rate on the loan (regardless of when such modification occurs and/or whether such interest rate reduction is temporary). Once a loan qualifies for TDR status, it remains a TDR for allowance purposes for the remainder of its life. About half of our loans that are considered TDRs involve a temporary forbearance of payments and do not change the contractual interest rate of the loan. As of March 31, 2020 and December 31, 2019, approximately 48 percent and 50 percent, respectively, of TDRs were classified as such due to their forbearance status. For additional information, see Note 6, “Allowance for Loan Losses” in our 2019 Form 10-K.

~~During the first quarter of 2020, COVID-19 began to spread worldwide and has caused significant disruptions to the U.S. and world economies.~~

On March 27, 2020, President Trump signed into law the CARES Act, which, among other things, allows us to (i) elect to suspend the requirements under GAAP for loan modifications related to COVID-19 that would otherwise be categorized as TDRs, and (ii) suspend any determination of a loan modified as a result of the effects of COVID-19 as being a TDR, including impairment for accounting purposes.

We have elected to suspend TDR accounting for modifications of loans that occur as a result of COVID-19 for the applicable period of the CARES Act relief. The relief from TDR guidance applies to modifications of loans that were not more than 30 days past due as of December 31, 2019, and that occur during the period beginning on March 1, 2020, and ending on the earlier of (i) sixty days after the date on which the national emergency related to the COVID-19 outbreak is terminated, or (ii) December 31, 2020.

~~Off-Balance Sheet Exposure for Contractual Loan Commitments~~

When we approve a Private Education Loan at the beginning of an academic year, that approval may cover the borrowing for the entire academic year. As such, we do not always disburse the full amount of the loan at the time of such approval, but instead have a commitment to fund a portion of the loan at a later date (usually the start of the second semester or subsequent trimesters). We estimate expected credit losses over the contractual period in which we are exposed to credit risk via a contractual obligation to extend credit, unless that obligation is unconditionally cancellable by us. The discounted cash flow approach described above includes expected future contractual disbursements. The portion of the allowance for loan losses related to future disbursements is shown as a liability on the face of the balance sheet, and related provision for credit losses is reflected on the income statement.

~~Uncollectible Interest~~

The majority of the total accrued interest receivable on our Private Education Loan portfolio represents accrued interest on deferred loans where no payments are due while the borrower is in- school and on fixed-pay loans where the borrower makes a $25 monthly payment that is smaller than the interest accrued on the loan in that month. The accrued interest on these loans will be capitalized and increase the unpaid principal balance of the loans when the borrower exits the grace period after separation from school. The discounted cash flow approach described above considers both the collectability of principal as well as this portion of accrued interest that is expected to capitalize to the balance of the loan. Therefore, the allowance for this portion of accrued interest balance is included in our allowance for loan losses. The discounted cash flow approach does not consider interest accrued on loans that are in a full principal and interest repayment status or in interest-only repayment status. We separately capture the amount of expected uncollectible interest associated with these loans using historical experience to estimate the uncollectible interest for the next four months at each period-end date. This amount is recorded as a reduction of interest income. Accrued interest receivable is separately disclosed on the face of the balance sheet.

~~Allowance for Personal Loans~~

From late 2016 through mid-2018, we acquired newly-originated Personal Loans from a marketplace lender. In 2018, we began to originate Personal Loans and ceased originating these loans at the end of 2019. We maintain an allowance for Personal Loan losses at an amount sufficient to absorb lifetime expected credit losses using the same discounted cash flow approach described above for Private Education Loans. The difference between the amortized cost basis and the present value of expected cash flows on our Personal Loan portfolio equals the allowance related to this portfolio. At March 31, 2020, and December 31, 2019, we held $747 million and $984 million, respectively, in Personal Loans, net of allowance. At March 31, 2020, there were no Personal Loans classified as TDRs.

We collect on defaulted Personal Loans through a mix of in-house collectors, third-party collectors and sales to third-parties. For March 31, 2020 and December 31, 2019, we used both an estimate of recovery rates from in-house collections as well as expectations of future sales of defaulted Personal Loans to estimate the timing and amount of future recoveries on charged-off Personal Loans.

~~Key Credit Quality Indicators - Personal Loan~~s

For Personal Loans, we consider FICO scores at original approval and periodically refreshed/updated credit scores through the loan’s term, loan seasoning, and loan delinquency status to be our key credit quality indicators for the same reasons discussed above under “— Key Credit Quality Indicators — Private Education Loans.”

As part of concluding on the adequacy of the allowance for Personal Loan losses, we review key allowance and loan metrics. The most relevant of these metrics considered are the allowance as a percentage of ending total loans, delinquency percentages, and forbearance percentages. We consider a Personal Loan to be delinquent 31 days after the last payment was contractually due.

~~Allowance for Credit Card Loans~~

We use the gross loss approach when estimating the allowance for loan losses for our Credit Card portfolio. Because our Credit Card portfolio is new and we do not have historical loss experience, we use estimated loss rates reported by other

financial institutions to estimate our allowance for loan losses for credit cards, net of expected recoveries. In addition, we use a model that utilizes purchased credit card information with risk characteristics similar to those of our own portfolio as a challenger model. We then consider any qualitative factors that may change our future expectations of losses.

~~As all of our Credit Card loans are unconditionally cancelable by us, the issuer, we do not record any estimate of credit losses for unused portions of our Credit Card commitments.~~

~~Allowance for FFELP Loan Losses~~

FFELP Loans are insured as to their principal and accrued interest in the event of default, subject to a risk-sharing level based on the date of loan disbursement. These insurance obligations are supported by contractual rights against the United States. For loans disbursed on or after July 1, 2006, we receive 97 percent reimbursement on all qualifying default claims. For loans disbursed after October 1, 1993, and before July 1, 2006, we receive 98 percent reimbursement on all qualifying claims. For loans disbursed prior to October 1, 1993, we receive 100 percent reimbursement. Because we bear a maximum of three percent loss exposure due to this federal guarantee, our allowance for loan losses for FFELP loans and related periodic provision expense are small.

We use the gross loss approach when estimating the allowance for loan losses for our FFELP Loans. We maintain an allowance for loan losses for our FFELP Loans at a level sufficient to cover lifetime expected credit losses. The allowance for FFELP Loan losses uses historical experience of customer default behavior. We apply the default rate projections, net of applicable risk sharing, to our FFELP Loans for the current period to perform our quantitative calculation. Once the quantitative calculation is performed, we review the adequacy of the allowance for loan losses and determine if qualitative adjustments need to be considered.

~~Loan Interest Income~~

For all loans, including impaired loans, classified as held for investment, we recognize interest income as earned, adjusted for the amortization of deferred direct origination and acquisition costs. Deferred fees or costs are required to be recognized as yield adjustments over the life of the related loans and are recognized by the interest method. The objective of the interest method is to arrive at periodic interest income (including recognition of fees and costs) at a constant effective yield on the net investment in the receivable (i.e., the principal amount of the receivable adjusted by unamortized fess or costs, purchase premium or discount and any hedging activity—these unamortized costs will collectively be referred to as “basis adjustments”). The difference between the periodic interest income so determined and the interest income determined by applying the stated interest rate to the outstanding principal amount of the receivable is the amount of periodic amortization.

For the amortization of the basis adjustments, we determine the constant effective yield necessary to apply the interest method based upon the payment terms required by the loan contract. Expected prepayments of principal are not included in the determination of the effective interest rate.

For fixed-rate loans, when a prepayment occurs the unamortized balance of the amortized cost adjustments is adjusted so that future amortization (based upon the contractual terms of the loan) will result in constant effective yield equal to the original effective interest rate. Prepayments do not result in a change in the effective interest rate of the loan. We determine the contractual payments on a pool basis; as such, when a prepayment occurs, future contractual payments will be determined assuming the pool will make smaller payments through the original term of the contract. The adjustment to the unamortized basis adjustment balance is recorded in interest income.

For variable-rate loans, the effective interest rate at the time of origination is the loan’s effective interest rate assuming all future contractual payments. The effective interest rate remains the same for that loan until the loan rate changes. If there is no prepayment and no change in the stated interest rate, the periodic amortization of the basis adjustments is equal to the difference between the effective interest rate multiplied by the book basis and the contractual interest due. We determine the contractual payments on a pool basis; as such, when a prepayment occurs, future contractual payments will be determined assuming the pool will make smaller payments through the original term of the contract. The adjustment to the unamortized basis adjustment balance is recorded in interest income.

When the interest rate on a variable-rate loan changes, the effective interest rate is recalculated using the same methodology described in the previous paragraph; however, the future contractual payments are changed to reflect the new interest rate. There is no forecasting of future expected changes in interest rates. The accounting basis used to determine the effective interest rate of the cash flows is equal to the balances of the unpaid principal balance and unamortized basis adjustments at the time of the rate change.

We also pay to the U.S. Department of Education (the “DOE”) an annual 105 basis point Consolidation Loan Rebate Fee on FFELP consolidation loans, which is netted against loan interest income. Additionally, interest earned on education loans reflects potential non-payment adjustments in accordance with our uncollectible interest recognition policy. We do not amortize any adjustments to the basis of loans when they are classified as held-for-sale.

With the adoption of CECL on January 1, 2020, we continue to analyze the collectability of accrued interest associated with loans not currently in full principal and interest repayment status or in interest only repayment status as discussed above; however, we will change the recognition of the allowance for this portion of uncollectible interest (amounts to be capitalized after separation from school and the expiration of the grace period) to the provision for loan losses from our historical practice of recording it as a reduction of interest income, as well as classifying this allowance as part of our allowance for loan losses as opposed to our historical practice of recording it as a reduction of accrued interest income receivable.

~~The allowance for the portion of uncollectible interest on loans making full interest payments will continue to be recorded as a reduction of interest income.~~

We recognize certain fee income (primarily late fees) on education loans when earned according to the contractual provisions of the promissory notes, as well as our expectation of collectability. Fee income is recorded when earned in “other non-interest income” in the accompanying consolidated statements of income.

Item 3. Quantitative and Qualitative Disclosures about Market Risk

Interest Rate Sensitivity Analysis

Our interest rate risk management program seeks to manage and control interest rate risk, thereby reducing our exposure to fluctuations in interest rates and achieving consistent and acceptable levels of profit in any rate environment, and sustainable growth in net interest income over the long term. We evaluate and monitor interest rate risk through two primary methods:

•Earnings at Risk (“EAR”), which measures the impact of hypothetical changes in interest rates on net interest income; and

•Economic Value of Equity (“EVE”), which measures the sensitivity or change in the economic value of equity to changes in interest rates.

A number of potential interest rate scenarios are simulated using our asset liability management system. The Bank is the primary source of interest rate risk within the Company. At present, a significant portion of the Bank’s earning assets and a large balance of deposits are ~~priced off of~~indexed to 1-month LIBOR. Therefore, 1-month LIBOR is considered a core rate in our interest rate risk analysis. Other interest rate changes are correlated to changes in 1-month LIBOR for analytic purposes, with higher or lower correlations based on historical relationships. In addition, key rates are modeled with a floor, which indicates how low each specific rate is likely to move in practice. Beginning April 1, 2021, variable-rate Private Education Loans will be offered based on the 30-day average Secured Overnight Financing Rate (“SOFR”), replacing 1-month LIBOR. As SOFR related exposure grows, SOFR will become a core rate for analysis as well. Rates are adjusted up or down via a set of scenarios that includes both rate shocks and ramps. Rate shocks represent an immediate and sustained change in 1-month LIBOR, with the resulting changes in other indices correlated accordingly. Interest rate ramps represent a linear increase in 1-month LIBOR over the course of 12 months, with the resulting changes in other indices correlated accordingly.

The following tables summarize the potential effect on earnings over the next 24 months and the potential effect on market values of balance sheet assets and liabilities at March 31, ~~2020~~2021 and ~~2019,~~2020, based upon a sensitivity analysis performed by management assuming a hypothetical ~~increase or decrease~~increases in market interest rates of 100 ~~basis points~~ and ~~a hypothetical increase in market interest rates of~~ 300 basis points while credit and funding spreads remain constant. EAR analysis assumes a static balance sheet, with maturities of each product replaced with assumed issuance of new products of the same type. The EVE sensitivity is applied only to financial assets and liabilities, including hedging instruments, that existed at the balance sheet date, and does not reflect any impact of new assets, liabilities, commitments, or hedging instruments that may arise in the future.

~~At today’s levels of~~With current interest rates very low, a 100 or 300-basis point downward rate shock does not provide a meaningful indication of interest rate sensitivity, so results for ~~that scenario~~those scenarios have not been presented. At March 31, ~~2020,~~2021, the full impact of a 100-basis point downward rate shock cannot be ~~realized~~modeled for some instruments on our balance sheet, due to the precipitous fall in many short-term rates ~~during~~since February 2020. The EAR results for March ~~2020.The results below~~31, 2021 indicate a market risk profile ~~that has~~of low sensitivity to rate changes, based on static balance sheet assumptions over the next two years. This position is nearly unchanged from one year ago. Similarly, the EVE metrics have changed slightly from one year ago, showing more negative valuation in the prior year’s results, with the EAR results exhibiting very low levels of variability with rate shocks. Economic Value of Equity sensitivity appears to have increased significantly. However, we believe the risk position has increased less than what the table below indicates and that we maintain a moderate level of risk. Because of the impact of our adoption of the CECL accounting standard in 2020, the dollarmarket value of equity ~~against which~~in response to higher rates. However, use of a new model used to perform the ~~EVE metrics are calculated~~analysis has ~~decreased by one-third, making each dollar~~resulted in modeled results showing higher sensitivity under the new methodology, all other things being equal. In terms of ~~valuation change appear more significant than it would have~~the risk profile in ~~previous periods’ analysis. It is important to note that the EVE measure was sensitive to relatively low levels of interest rate mismatch in the prior year’s analysis and is more sensitive~~place at March 31, ~~2020.~~2021, long-term rate sensitivity has increased only slightly since one year ago.

9684

March 31,
2020 2019
+300
Basis Points +100
Basis Points -100
Basis Points +300
Basis Points +100
Basis Points -100
Basis Points
EAR - Shock +4.3% +1.3% +2.3% +6.0% +1.9% -1.9%
EAR - Ramp +3.7% +1.3% +1.8% +6.3% +2.2% -1.7%
EVE -11.0% -4.2% -1.6% -1.3% -0.6% +0.7%

March 31,

2021

2020

+300
Basis Points

+100
Basis Points

-100
Basis Points

+300
Basis Points

+100
Basis Points

-100
Basis Points

EAR - Shock

+4.0%

+1.4%

N/A

+4.3%

+1.3%

+2.3%

EAR - Ramp

+3.9%

+1.4%

N/A

+3.7%

+1.3%

+1.8%

EVE

-13.7%

-4.9%

N/A

-11.0%

-4.2%

-1.6%

A primary objective in our funding is to manage our sensitivity to changing interest rates by generally funding our assets with liabilities of similar interest rate repricing characteristics. This funding objective is frequently obtained through the use of derivatives. Uncertainty in loan repayment cash flows and the pricing behavior of our non-maturity retail deposits pose challenges in achieving our interest rate risk objectives. In addition to these considerations, we can have a mismatch in the index (including the frequency of reset) of floating-rate debt versus floating-rate assets.

As part of its suite of financial products, the Bank offers fixed-rate Private Education Loans. As with other Private Education Loans, the term to maturity is lengthy, and the customer has the option to repay the loan faster than the promissory note requires. Asset securitization and fixed-rate CDs provide intermediate to long-term fixed-rate funding for some of these assets. Additionally, a portion of the fixed-rate loans have been hedged with derivatives, which have been used to convert a portion of variable-rate funding to fixed-rate to match the anticipated cash flows of these loans. Any unhedged position arising from the fixed-rate loan portfolio is monitored and modeled to ensure that the interest rate risk does not cause the Company to exceed its policy limits for earnings at risk or for the value of equity at risk.

In the preceding tables, the interest rate sensitivity analysis reflects the balance sheet mix of fully variable LIBOR-based loans, ~~which exceeds the mix of~~and fully variable funding, including brokered CDs that have been converted to LIBOR through derivative transactions. The analysis ~~does not anticipate~~assumes that retail MMDAs orand retail savings balances, while relatively sensitive to interest rate changes, will ~~reprice~~not correlate 100 percent to the full ~~extent of~~ interest rate shocks or ramps. Also considered is ~~(i)~~ the impact of FFELP ~~loans,~~Loans, which receive floor income in low interest rate environments and will therefore not reprice fully with interest rate shocks and (ii) the impact of fixed-rate loans that have not been fully match-funded through derivative transactions and fixed-rate funding from CDs and asset securitization. An additional consideration is the implementation of a loan cap of 25 percent on variable-rate loans originated on and after September 25, 2016. As of March 31, 2020, there were $13.3 billion of loans with 25 percent interest rate caps on the balance sheet. The overall slightly asset-sensitive position would generally cause net interest income to increase somewhat when interest rates rise and decrease somewhat when interest rates fall. However, as the position demonstrates very low levels of variability, the sensitivity position will fluctuate somewhat during the year, depending on the funding mix in place at the time of the analysis, and is exhibiting more fully this quarter the impact of loan floors and very low levels of some interest rates.shocks.

Although we believe that these measurements provide an estimate of our interest rate sensitivity, they do not account for potential changes in credit quality, balance sheet mix, and size of our balance sheet. They also do not account for other business developments that could affect net income, or for management actions that could affect net income or could be taken to change our risk profile. Accordingly, we can give no assurance that actual results would not differ materially from the estimated outcomes of our simulations. Further, such simulations do not represent our current view of expected future interest rate movements.

Asset and Liability Funding Gap

The table below presents our assets and liabilities (funding) arranged by underlying indices as of March 31, ~~2020.~~2021. In the following GAAP presentation, the funding gap only includes derivatives that qualify as effective hedges (those derivatives which are reflected in net interest income, as opposed to those reflected in the “gains (losses) on derivatives and hedging activities, net” line on the consolidated statements of income). The difference between the asset and the funding is the funding gap for the specified index. This represents at a high level our exposure to interest rate risk in the form of basis risk and repricing risk, which is the risk that the different indices may reset at different frequencies or may not move in the same direction or at the same magnitude. (Note that all fixed-rate assets and liabilities are aggregated into one line item, which does not capture the differences in time due to maturity.)


(Dollars in millions) Index	(Dollars in millions) Index	Frequency of Variable Resets	Assets		Funding⁽¹⁾		Funding Gap		(Dollars in millions) Index	Frequency of Variable Resets	Assets		Funding (1)		Funding Gap
Fed Funds Effective Rate	Fed Funds Effective Rate	daily/weekly/monthly	$	—	$	448.6	$	(448.6)	Fed Funds Effective Rate	daily/weekly/monthly	$	—	$	1,254.5	$	(1,254.5)
SOFR									SOFR	monthly	—		50.6		(50.6)
3-month Treasury bill	3-month Treasury bill	weekly	111.6		—		111.6		3-month Treasury bill	weekly	108.2		—		108.2
Prime	Prime	monthly	8.8		—		8.8		Prime	monthly	12.5		—		12.5
3-month LIBOR	3-month LIBOR	quarterly	—		400.0		(400.0)		3-month LIBOR	quarterly	—		251.1		(251.1)
1-month LIBOR	1-month LIBOR	monthly	11,845.6		10,637.0		1,208.6		1-month LIBOR	monthly	11,314.8		9,220.3		2,094.5
1-month LIBOR	1-month LIBOR	daily	655.4		—		655.4		1-month LIBOR	daily	619.4		526.5		92.9
Non-Discrete reset⁽²⁾	Non-Discrete reset⁽²⁾	daily/weekly	7,493.7		3,541.9		3,951.8		Non-Discrete reset(2)	daily/weekly	6,402.3		4,134.1		2,268.2
Fixed-Rate⁽³⁾	Fixed-Rate⁽³⁾		11,645.8		16,733.4		(5,087.6)		Fixed-Rate(3)		12,170.8		15,190.9		(3,020.1)
Total	Total		$	31,760.9	$	31,760.9	$	—	Total		$	30,628.0	$	30,628.0	$	—


Title of each class	Trading Symbol(s)	Name of each exchange on which registered
Common stock, par value $.20 per share	SLM	The NASDAQ Global Select Market
Floating Rate Non-Cumulative Preferred Stock, Series B, par value $.20 per share	SLMBP	The NASDAQ Global Select Market


		March 31,		December 31,			March 31,		December 31,
		2020		2019			2021		2020
Assets	Assets					Assets
Cash and cash equivalents	Cash and cash equivalents	$	7,292,929	$	5,563,877	Cash and cash equivalents	$	6,207,001	$	4,455,292
Investments:	Investments:					Investments:
Trading investments at fair value (cost of $12,551)		11,360		—
Available-for-sale investments at fair value (cost of $607,867 and $485,756, respectively)		614,582		487,669
Trading investments at fair value (cost of $26,219 and $12,551)						Trading investments at fair value (cost of $26,219 and $12,551)	30,594		16,923
Available-for-sale investments at fair value (cost of $2,116,279 and $1,986,957, respectively)						Available-for-sale investments at fair value (cost of $2,116,279 and $1,986,957, respectively)	2,115,885		1,996,634
Other investments	Other investments	82,853		84,420		Other investments	79,679		80,794
Total investments	Total investments	708,795		572,089		Total investments	2,226,158		2,094,351
Loans held for investment (net of allowance for losses of $1,673,324 and $441,912, respectively)		21,695,851		24,667,792
Loans held for investment (net of allowance for losses of $1,179,021 and $1,361,723, respectively)						Loans held for investment (net of allowance for losses of $1,179,021 and $1,361,723, respectively)	20,368,287		19,183,143
Loans held for sale						Loans held for sale	0		2,885,640
Restricted cash	Restricted cash	189,439		156,883		Restricted cash	164,708		154,417
Other interest-earning assets	Other interest-earning assets	92,968		52,564		Other interest-earning assets	23,592		42,874
Accrued interest receivable	Accrued interest receivable	1,281,746		1,392,725		Accrued interest receivable	1,264,960		1,387,305
Premises and equipment, net	Premises and equipment, net	143,622		134,749		Premises and equipment, net	155,425		154,670
Income taxes receivable, net	Income taxes receivable, net	286,006		88,844		Income taxes receivable, net	169,655		374,706
Tax indemnification receivable	Tax indemnification receivable	27,727		27,558		Tax indemnification receivable	15,678		18,492
Other assets	Other assets	41,812		29,398		Other assets	32,541		19,533
Total assets	Total assets	$	31,760,895	$	32,686,479	Total assets	$	30,628,005	$	30,770,423

Liabilities	Liabilities					Liabilities
Deposits	Deposits	$	24,445,614	$	24,283,983	Deposits	$	22,803,143	$	22,666,039
Short-term borrowings		—		289,230

Long-term borrowings	Long-term borrowings	4,708,036		4,354,037		Long-term borrowings	4,918,670		5,189,217

Upromise member accounts		187,103		192,662
Other liabilities	Other liabilities	299,559		254,731		Other liabilities	297,728		352,332
Total liabilities	Total liabilities	29,640,312		29,374,643		Total liabilities	28,019,541		28,207,588

Commitments and contingencies	Commitments and contingencies					Commitments and contingencies	0		0

Equity	Equity					Equity
Preferred stock, par value $0.20 per share, 20 million shares authorized:	Preferred stock, par value $0.20 per share, 20 million shares authorized:					Preferred stock, par value $0.20 per share, 20 million shares authorized:
Series B: 4 million and 4 million shares issued, respectively, at stated value of $100 per share		400,000		400,000
Common stock, par value $0.20 per share, 1.125 billion shares authorized: 456.4 million and 453.6 million shares issued, respectively		91,288		90,720
Series B: 2.5 million and 2.5 million shares issued, respectively, at stated value of $100 per share						Series B: 2.5 million and 2.5 million shares issued, respectively, at stated value of $100 per share	251,070		251,070
Common stock, par value $0.20 per share, 1.125 billion shares authorized: 431.1 million and 456.7 million shares issued, respectively						Common stock, par value $0.20 per share, 1.125 billion shares authorized: 431.1 million and 456.7 million shares issued, respectively	86,211		91,346
Additional paid-in capital	Additional paid-in capital	1,226,886		1,307,630		Additional paid-in capital	1,052,904		1,331,247
Accumulated other comprehensive income (loss) (net of tax expense (benefit) of ($13,979) and ($3,995), respectively)		(43,274)		(12,367)
Accumulated other comprehensive loss (net of tax benefit of ($7,680) and ($10,908), respectively)						Accumulated other comprehensive loss (net of tax benefit of ($7,680) and ($10,908), respectively)	(24,077)		(34,200)
Retained earnings	Retained earnings	1,243,722		1,850,512		Retained earnings	2,350,986		1,722,365
Total SLM Corporation stockholders’ equity before treasury stock	Total SLM Corporation stockholders’ equity before treasury stock	2,918,622		3,636,495		Total SLM Corporation stockholders’ equity before treasury stock	3,717,094		3,361,828
Less: Common stock held in treasury at cost: 81.3 million and 32.5 million shares, respectively		(798,039)		(324,659)
Less: Common stock held in treasury at cost: 102.7 million and 81.4 million shares, respectively						Less: Common stock held in treasury at cost: 102.7 million and 81.4 million shares, respectively	(1,108,630)		(798,993)
Total equity	Total equity	2,120,583		3,311,836		Total equity	2,608,464		2,562,835
Total liabilities and equity	Total liabilities and equity	$	31,760,895	$	32,686,479	Total liabilities and equity	$	30,628,005	$	30,770,423


	Three Months Ended
	March 31,
	2020		2019
Interest income:
Loans	$	555,277	$	553,479
Investments	2,517		1,421
Cash and cash equivalents	17,139		11,553
Total interest income	574,933		566,453
Interest expense:
Deposits	135,112		125,987
Interest expense on short-term borrowings	4,217		1,165
Interest expense on long-term borrowings	35,488		37,020

Total interest expense	174,817		164,172
Net interest income	400,116		402,281
Less: provisions for credit losses	61,258		63,790
Net interest income after provisions for credit losses	338,858		338,491
Non-interest income:
Gains on sales of loans, net	238,935		—

Gains on derivatives and hedging activities, net	45,672		2,763
Other income	7,487		13,378
Total non-interest income	292,094		16,141
Non-interest expenses:
Compensation and benefits	84,222		78,738
FDIC assessment fees	8,890		7,618
Other operating expenses	54,186		53,791



Total non-interest expenses	147,298		140,147
Income before income tax expense	483,654		214,485
Income tax expense	121,481		56,296
Net income	362,173		158,189
Preferred stock dividends	3,464		4,468
Net income attributable to SLM Corporation common stock	$	358,709	$	153,721
Basic earnings per common share attributable to SLM Corporation	$	0.88	$	0.35
Average common shares outstanding	409,786		434,574
Diluted earnings per common share attributable to SLM Corporation	$	0.87	$	0.35
Average common and common equivalent shares outstanding	412,755		438,248
Declared dividends per common share attributable to SLM Corporation	$	0.03	$	0.03


	Three Months Ended
	March 31,
	2021		2020
Interest income:
Loans	$	431,804	$	555,277
Investments	2,728		2,517
Cash and cash equivalents	1,626		17,139
Total interest income	436,158		574,933
Interest expense:
Deposits	66,598		135,112
Interest expense on short-term borrowings	3,202		4,217
Interest expense on long-term borrowings	35,244		35,488

Total interest expense	105,044		174,817
Net interest income	331,114		400,116
Less: provisions for credit losses	(225,767)		61,258
Net interest income after provisions for credit losses	556,881		338,858
Non-interest income:
Gains on sales of loans, net	399,111		238,935

Gains on derivatives and hedging activities, net	28		45,672
Other income	14,288		7,487
Total non-interest income	413,427		292,094
Non-interest expenses:
Operating expenses:
Compensation and benefits	71,581		84,222
FDIC assessment fees	5,188		8,890
Other operating expenses	47,730		54,186
Total operating expenses	124,499		147,298

Restructuring expenses	1,077		0
Total non-interest expenses	125,576		147,298
Income before income tax expense	844,732		483,654
Income tax expense	203,525		121,481
Net income	641,207		362,173
Preferred stock dividends	1,201		3,464
Net income attributable to SLM Corporation common stock	$	640,006	$	358,709
Basic earnings per common share attributable to SLM Corporation	$	1.77	$	0.88
Average common shares outstanding	361,042		409,786
Diluted earnings per common share attributable to SLM Corporation	$	1.75	$	0.87
Average common and common equivalent shares outstanding	366,240		412,755
Declared dividends per common share attributable to SLM Corporation	$	0.03	$	0.03


		Three Months Ended							Three Months Ended
		March 31,							March 31,
		2020		2019			2021		2020
Net income	Net income	$	362,173	$	158,189	Net income	$	641,207	$	362,173
Other comprehensive income (loss):	Other comprehensive income (loss):					Other comprehensive income (loss):
Unrealized gains (losses) on investments	Unrealized gains (losses) on investments	4,803		2,938		Unrealized gains (losses) on investments	(10,071)		4,803
Unrealized gains (losses) on cash flow hedges	Unrealized gains (losses) on cash flow hedges	(45,694)		(14,117)		Unrealized gains (losses) on cash flow hedges	23,423		(45,694)
Total unrealized gains (losses)	Total unrealized gains (losses)	(40,891)		(11,179)		Total unrealized gains (losses)	13,352		(40,891)
Income tax benefit (expense)		9,984		2,733
Other comprehensive income (loss), net of tax benefit (expense)		(30,907)		(8,446)
Income tax (expense) benefit						Income tax (expense) benefit	(3,229)		9,984
Other comprehensive income (loss), net of tax (expense) benefit						Other comprehensive income (loss), net of tax (expense) benefit	10,123		(30,907)
Total comprehensive income	Total comprehensive income	$	331,266	$	149,743	Total comprehensive income	$	651,330	$	331,266


		Common Stock Shares
	Preferred Stock Shares	Issued	Treasury	Outstanding	Preferred Stock		Common Stock		Additional Paid-In Capital		Accumulated Other Comprehensive Loss		Retained Earnings		Treasury Stock		Total Equity
Balance at December 31, 2019	4,000,000	453,599,926	(32,506,562)	421,093,364	$	400,000	$	90,720	$	1,307,630	$	(12,367)	$	1,850,512	$	(324,659)	$	3,311,836
Cumulative adjustment for the adoption of ASU No. 2016-13 (CECL)	—	—	—	—	—		—		—		—		(952,639)		—		(952,639)
Balance at January 1, 2020	4,000,000	453,599,926	(32,506,562)	421,093,364	400,000		90,720		1,307,630		(12,367)		897,873		(324,659)		2,359,197
Net income	—	—	—	—	—		—		—		—		362,173		—		362,173
Other comprehensive loss, net of tax	—	—	—	—	—		—		—		(30,907)		—		—		(30,907)
Total comprehensive income	—	—	—	—	—		—		—		—		—		—		331,266
Cash dividends declared:
Common stock ($0.03 per share)	—	—	—	—	—		—		—		—		(12,595)		—		(12,595)
Preferred Stock, Series B ($0.87 per share)	—	—	—	—	—		—		—		—		(3,464)		—		(3,464)

Dividend equivalent units related to employee stock-based compensation plans	—	—	—	—	—		—		265		—		(265)		—		0
Issuance of common shares	—	2,837,562	—	2,837,562	—		568		2,304		—		—		—		2,872
Stock-based compensation expense	—	—	—	—	—		—		13,610		—		0		—		13,610
Common stock repurchased	—	—	(47,736,847)	(47,736,847)	—		—		(96,923)		—		—		(461,244)		(558,167)
Shares repurchased related to employee stock-based compensation plans	—	—	(1,105,119)	(1,105,119)	—		—		—		—		—		(12,136)		(12,136)
Balance at March 31, 2020	4,000,000	456,437,488	(81,348,528)	375,088,960	$	400,000	$	91,288	$	1,226,886	$	(43,274)	$	1,243,722	$	(798,039)	$	2,120,583


Cash, cash equivalents and restricted cash at beginning of period						Cash, cash equivalents and restricted cash at beginning of period	4,609,709		5,720,760
Cash, cash equivalents and restricted cash at end of period						Cash, cash equivalents and restricted cash at end of period	$	6,371,709	$	7,482,368
Cash disbursements made for:	Cash disbursements made for:					Cash disbursements made for:
Interest	Interest	$	151,017	$	147,235	Interest	$	76,491	$	151,017
Income taxes paid	Income taxes paid	$	3,630	$	3,700	Income taxes paid	$	887	$	3,630
Income taxes refunded	Income taxes refunded	$	(2,890)	$	(41)	Income taxes refunded	$	(1,049)	$	(2,890)
Reconciliation of the Consolidated Statements of Cash Flows to the Consolidated Balance Sheets:	Reconciliation of the Consolidated Statements of Cash Flows to the Consolidated Balance Sheets:					Reconciliation of the Consolidated Statements of Cash Flows to the Consolidated Balance Sheets:
Cash and cash equivalents	Cash and cash equivalents	$	7,292,929	$	2,156,257	Cash and cash equivalents	$	6,207,001	$	7,292,929
Restricted cash	Restricted cash	189,439		153,552		Restricted cash	164,708		189,439
Total cash, cash equivalents and restricted cash	Total cash, cash equivalents and restricted cash	$	7,482,368	$	2,309,809	Total cash, cash equivalents and restricted cash	$	6,371,709	$	7,482,368


	January 1, 2020
	As reported under CECL		Pre-CECL Adoption		Impact of CECL Adoption
Assets:
Allowance for loan losses:
Private Education Loans	$	1,435,130	$	374,300	$	1,060,830
FFELP Loans	4,485		1,633		2,852
Personal Loans	145,060		65,877		79,183
Credit Card	290		102		188
Total	$	1,584,965	$	441,912	$	1,143,053

Deferred tax asset	$	415,540	$	109,369	$	306,171

Liabilities:
Allowance for loan losses:
Off-balance sheet exposures	$	118,239	$	2,481	$	115,758

Equity:
Retained Earnings	$	897,873	$	1,850,512	$	(952,639)


													March 31, 2021
													Amortized Cost		Allowance for credit losses(1)		Gross Unrealized Gains		Gross Unrealized Losses		Estimated Fair Value
Available-for-sale:												Available-for-sale:
Mortgage-backed securities												Mortgage-backed securities	$	348,080	$	0	$	3,492	$	(6,545)	$	345,027
Utah Housing Corporation bonds												Utah Housing Corporation bonds	8,375		0		80		(15)		8,440
U.S. government-sponsored enterprises and Treasuries												U.S. government-sponsored enterprises and Treasuries	1,560,848		0		2,581		(146)		1,563,283
Other securities												Other securities	198,976		0		769		(610)		199,135
Total												Total	$	2,116,279	$	0	$	6,922	$	(7,316)	$	2,115,885

		March 31, 2020																			December 31, 2020
		Amortized Cost		Allowance for credit losses⁽¹⁾		Gross Unrealized Gains		Gross Unrealized Losses		Estimated Fair Value			Amortized Cost		Allowance for credit losses(1)		Gross Unrealized Gains		Gross Unrealized Losses		Estimated Fair Value
Available-for-sale:	Available-for-sale:											Available-for-sale:
Mortgage-backed securities	Mortgage-backed securities	$	206,640	$	—	$	6,400	$	—	$	213,040	Mortgage-backed securities	$	308,913	$	0	$	6,095	$	(134)	$	314,874
Utah Housing Corporation bonds	Utah Housing Corporation bonds	15,931		—		156		(74)		16,013		Utah Housing Corporation bonds	12,357		0		210		0		12,567
U.S. government-sponsored enterprises	U.S. government-sponsored enterprises	306,491		—		3,206		(8)		309,689		U.S. government-sponsored enterprises	1,596,890		0		3,395		0		1,600,285
Other securities	Other securities	78,805		—		—		(2,965)		75,840		Other securities	68,797		0		462		(351)		68,908
Total	Total	$	607,867	$	—	$	9,762	$	(3,047)	$	614,582	Total	$	1,986,957	$	0	$	10,162	$	(485)	$	1,996,634

		December 31, 2019
		Amortized Cost		Allowance for credit losses⁽¹⁾		Gross Unrealized Gains		Gross Unrealized Losses		Estimated Fair Value
Available-for-sale:
Mortgage-backed securities		$	215,888	$	—	$	1,895	$	(658)	$	217,125
Utah Housing Corporation bonds		19,474		—		145		(83)		19,536
U.S. government-sponsored enterprises		250,394		—		635		(21)		251,008
Total		$	485,756	$	—	$	2,675	$	(762)	$	487,669


		Less than 12 months						12 months or more							Total							Less than 12 months				12 months or more		Total
		Gross Unrealized Losses		Estimated Fair Value		Gross Unrealized Losses		Estimated Fair Value		Gross Unrealized Losses		Estimated Fair Value				Gross Unrealized Losses		Estimated Fair Value		Gross Unrealized Losses		Estimated Fair Value		Gross Unrealized Losses		Estimated Fair Value
As of March 31, 2020:
As of March 31, 2021:														As of March 31, 2021:
Mortgage-backed securities														Mortgage-backed securities		$	(6,545)	$	242,386	$	0	$	0	$	(6,545)	$	242,386
Utah Housing Corporation bonds														Utah Housing Corporation bonds		(15)		4,357		0		0		(15)		4,357
U.S. government-sponsored enterprises and Treasuries														U.S. government-sponsored enterprises and Treasuries		(146)		114,870		0		0		(146)		114,870
Other securities														Other securities		(339)		89,603		(271)		12,776		(610)		102,379
Total														Total		$	(7,045)	$	451,216	$	(271)	$	12,776	$	(7,316)	$	463,992

As of December 31, 2020:														As of December 31, 2020:
Mortgage-backed securities	Mortgage-backed securities	$	—	$	—	$	—	$	—	$	—	$	—	Mortgage-backed securities		$	(134)	$	46,011	$	0	$	0	$	(134)	$	46,011
Utah Housing Corporation bonds	Utah Housing Corporation bonds	—		—		(74)		8,965		(74)		8,965		Utah Housing Corporation bonds		0		0		0		0		0		0
U.S. government-sponsored enterprises	U.S. government-sponsored enterprises	(8)		16,823		—		—		(8)		16,823		U.S. government-sponsored enterprises		0		0		0		0		0		0
Other securities	Other securities	(2,965)		75,840		—		—		(2,965)		75,840		Other securities		(351)		30,441		0		0		(351)		30,441
Total	Total	$	(2,973)	$	92,663	$	(74)	$	8,965	$	(3,047)	$	101,628	Total		$	(485)	$	76,452	$	0	$	0	$	(485)	$	76,452

As of December 31, 2019:
Mortgage-backed securities		$	(218)	$	25,624	$	(440)	$	42,448	$	(658)	$	68,072
Utah Housing Corporation bonds		—		—		(83)		11,097		(83)		11,097
U.S. government-sponsored enterprises		(21)		14,977		—		—		(21)		14,977
Total		$	(239)	$	40,601	$	(523)	$	53,545	$	(762)	$	94,146


Year of Maturity	Year of Maturity	Amortized Cost		Estimated Fair Value		Year of Maturity	Amortized Cost		Estimated Fair Value
2020		$	94,048	$	94,320
2021	2021	145,340		147,711		2021	$	293,759	$	294,232
2022	2022	54,127		54,317		2022	1,018,268		1,019,960
2023	2023	12,977		13,341		2023	148,822		149,166
2024						2024	100,000		99,925
2038	2038	175		192		2038	76		88
2039	2039	2,457		2,668		2039	1,601		1,773
2042	2042	7,115		7,172		2042	4,201		4,206
2043	2043	11,130		11,560		2043	7,415		7,711
2044	2044	16,149		16,684		2044	10,133		10,610
2045	2045	16,896		17,286		2045	8,870		9,179
2046	2046	27,641		28,385		2046	14,414		14,797
2047	2047	39,927		40,313		2047	18,646		18,992
2048	2048	10,248		10,664		2048	4,362		4,545
2049	2049	84,282		87,458		2049	36,368		37,683
2050	2050	6,550		6,671		2050	174,919		170,740
2051						2051	75,449		73,143
2053						2053	134,414		134,289
2054	2054	78,805		75,840		2054	64,562		64,846
Total	Total	$	607,867	$	614,582	Total	$	2,116,279	$	2,115,885


		Allowance for Loan Losses																										Allowance for Credit Losses
		Three Months Ended March 31, 2020																										Three Months Ended March 31, 2021
		FFELP Loans			Private Education Loans			Personal Loans			Credit Cards			Total			FFELP Loans			Private Education Loans			Credit Cards			Total
Allowance for Loan Losses
Allowance for Credit Losses																Allowance for Credit Losses
Beginning balance	Beginning balance	$	1,633		$	374,300		$	65,877		$	102		$	441,912	Beginning balance	$	4,378		$	1,355,844		$	1,501		$	1,361,723
Day 1 adjustment for the adoption of CECL		2,852			1,060,830			79,183			188			1,143,053
Transfer from unfunded commitment liability		—			142,075			—			—			142,075
Transfer from unfunded commitment liability(1)																Transfer from unfunded commitment liability(1)	0			126,880			0			126,880
Provisions:	Provisions:															Provisions:
Provision for current period	Provision for current period	37			143,862			25,318			291			169,508		Provision for current period	29			(254,942)			(86)			(254,999)
Loan sale reduction to provision	Loan sale reduction to provision	—			(161,793)			—			—			(161,793)		Loan sale reduction to provision	0			(8,858)			0			(8,858)
Total provision⁽¹⁾		37			(17,931)			25,318			291			7,715
Loan transfer from held-for-sale																Loan transfer from held-for-sale	0			1,887			0			1,887
Total provisions(2)																Total provisions(2)	29			(261,913)			(86)			(261,970)
Net charge-offs:	Net charge-offs:															Net charge-offs:
Charge-offs	Charge-offs	(226)			(51,469)			(19,247)			(7)			(70,949)		Charge-offs	(89)			(55,139)			(88)			(55,316)
Recoveries	Recoveries	—			7,976			1,542			—			9,518		Recoveries	0			7,703			1			7,704
Net charge-offs	Net charge-offs	(226)			(43,493)			(17,705)			(7)			(61,431)		Net charge-offs	(89)			(47,436)			(87)			(47,612)

Loan sales																Loan sales	0			0			0			0
Ending Balance	Ending Balance	$	4,296		$	1,515,781		$	152,673		$	574		$	1,673,324	Ending Balance	$	4,318		$	1,173,375		$	1,328		$	1,179,021
Allowance:	Allowance:															Allowance:
Ending balance: individually evaluated for impairment	Ending balance: individually evaluated for impairment	$	—		$	150,822		$	—		$	—		$	150,822	Ending balance: individually evaluated for impairment	$	0		$	95,536		$	0		$	95,536
Ending balance: collectively evaluated for impairment	Ending balance: collectively evaluated for impairment	$	4,296		$	1,364,959		$	152,673		$	574		$	1,522,502	Ending balance: collectively evaluated for impairment	$	4,318		$	1,077,839		$	1,328		$	1,083,485
Loans:	Loans:															Loans:
Ending balance: individually evaluated for impairment	Ending balance: individually evaluated for impairment	$	—		$	1,518,763		$	—		$	—		$	1,518,763	Ending balance: individually evaluated for impairment	$	0		$	1,225,604		$	0		$	1,225,604
Ending balance: collectively evaluated for impairment	Ending balance: collectively evaluated for impairment	$	766,954		$	20,107,984		$	899,704		$	7,234		$	21,781,876	Ending balance: collectively evaluated for impairment	$	727,664		$	19,516,236		$	11,309		$	20,255,209
Net charge-offs as a percentage of average loans in repayment (annualized)⁽²⁾⁽³⁾	Net charge-offs as a percentage of average loans in repayment (annualized)⁽²⁾⁽³⁾	0.15		%	1.05		%	7.27		%	0.52		%			Net charge-offs as a percentage of average loans in repayment (annualized)⁽²⁾⁽³⁾	0.06		%	1.29		%	2.92		%
Allowance as a percentage of the ending total loan balance	Allowance as a percentage of the ending total loan balance	0.56		%	7.01		%	16.97		%	7.93		%			Allowance as a percentage of the ending total loan balance	0.59		%	5.66		%	11.74		%
Allowance as a percentage of the ending loans in repayment⁽²⁾⁽³⁾	Allowance as a percentage of the ending loans in repayment⁽²⁾⁽³⁾	0.74		%	10.11		%	16.97		%	7.93		%			Allowance as a percentage of the ending loans in repayment⁽²⁾⁽³⁾	0.80		%	7.94		%	11.74		%
Allowance coverage of net charge-offs (annualized)	Allowance coverage of net charge-offs (annualized)	4.75			8.71			2.16			20.50					Allowance coverage of net charge-offs (annualized)	12.13			6.18			3.82
Ending total loans, gross	Ending total loans, gross	$	766,954		$	21,626,747		$	899,704		$	7,234				Ending total loans, gross	$	727,664		$	20,741,840		$	11,309
Average loans in repayment⁽²⁾⁽³⁾	Average loans in repayment⁽²⁾⁽³⁾	$	600,534		$	16,521,356		$	973,772		$	5,364				Average loans in repayment⁽²⁾⁽³⁾	$	554,510		$	14,743,508		$	11,909
Ending loans in repayment⁽²⁾⁽³⁾	Ending loans in repayment⁽²⁾⁽³⁾	$	581,997		$	14,988,345		$	899,704		$	7,234				Ending loans in repayment⁽²⁾⁽³⁾	$	540,903		$	14,777,939		$	11,309


	Allowance for Loan Losses
	Three Months Ended March 31, 2019
	FFELP Loans			Private Education Loans			Personal Loans			Total
Allowance for Loan Losses
Beginning balance	$	977		$	277,943		$	62,201		$	341,121
Total provision	1,017			41,883			22,760			65,660
Net charge-offs:
Charge-offs	(234)			(39,577)			(15,251)			(55,062)
Recoveries	—			5,697			909			6,606
Net charge-offs	(234)			(33,880)			(14,342)			(48,456)

Ending Balance	$	1,760		$	285,946		$	70,619		$	358,325
Allowance:
Ending balance: individually evaluated for impairment	$	—		$	132,442		$	—		$	132,442
Ending balance: collectively evaluated for impairment	$	1,760		$	153,504		$	70,619		$	225,883
Loans:
Ending balance: individually evaluated for impairment	$	—		$	1,327,668		$	—		$	1,327,668
Ending balance: collectively evaluated for impairment	$	828,640		$	20,463,954		$	1,162,874		$	22,455,468
Net charge-offs as a percentage of average loans in repayment (annualized)⁽¹⁾	0.14		%	0.89		%	4.88		%
Allowance as a percentage of the ending total loan balance	0.21		%	1.31		%	6.07		%
Allowance as a percentage of the ending loans in repayment⁽¹⁾	0.27		%	1.87		%	6.07		%
Allowance coverage of net charge-offs (annualized)	1.88			2.11			1.23
Ending total loans, gross	$	828,640		$	21,791,622		$	1,162,874
Average loans in repayment⁽¹⁾	$	650,196		$	15,165,072		$	1,175,356
Ending loans in repayment⁽¹⁾	$	641,658		$	15,310,560		$	1,162,874


Consolidated Statements of Income Provisions for Credit Losses Reconciliation
	Three Months Ended March 31, 2021
Private Education Loan provisions for credit losses:
Provisions for loan losses	$	(261,913)
Provisions for unfunded loan commitments	36,203
Total Private Education Loan provisions for credit losses	(225,710)

Other impacts to the provisions for credit losses:
FFELP Loans	29
Credit Cards	(86)
Total	(57)
Provisions for credit losses reported in consolidated statements of income	$	(225,767)


Consolidated Statements of Income Provisions for Credit Losses Reconciliation
	Three Months Ended March 31, 2020
Private Education Loan provisions for credit losses:
Provisions for loan losses	$	(17,931)
Provisions for unfunded loan commitments	53,543
Total Private Education Loan provisions for credit losses	35,612

Other impacts to the provisions for credit losses:
Personal Loans	25,318
FFELP Loans	37
Credit Cards	291
Total	25,646
Provisions for credit losses reported in consolidated statements of income	$	61,258


1.			~~Significant Accounting Policies (Continued)~~


1.			~~Significant Accounting Policies (Continued)~~


1.			~~Significant Accounting Policies (Continued)~~


1.			~~Significant Accounting Policies (Continued)~~


	Recorded Investment		Unpaid Principal Balance		Allowance

March 31, 2020
TDR Loans	$	1,550,600	$	1,518,763	$	150,822

December 31, 2019
TDR Loans	$	1,612,896	$	1,581,966	$	186,697


	Three Months Ended March 31,
	2020						2019
	Average Recorded Investment		Interest Income Recognized		Average Recorded Investment		Interest Income Recognized

TDR Loans	$	1,615,764	$	26,488	$	1,312,729	$	21,566


	Three Months Ended March 31, 2020										Three Months Ended March 31, 2019
	Modified Loans⁽¹⁾		Charge-offs		Payment- Default		Modified Loans⁽¹⁾		Charge-offs		Payment- Default

TDR Loans	$	132,815	$	19,375	$	30,725	$	111,208	$	16,005	$	25,462


	Three Months Ended March 31, 2021						Three Months Ended March 31, 2020
	Modified Loans(1)		Charge-offs		Payment- Default		Modified Loans(1)		Charge-offs		Payment- Default

TDR Loans	$	3,717	$	17,948	$	4,869	$	132,815	$	19,375	$	30,725


	Private Education Loans Held for Investment - Credit Quality Indicators
	March 31, 2021
Year of Origination	2021(1)		2020(1)		2019(1)		2018(1)		2017(1)		2016 and Prior(1)		Total(1)		% of Balance

Cosigners:
With cosigner	$	640,909	$	3,954,261	$	3,331,066	$	2,431,585	$	2,137,418	$	5,799,561	$	18,294,800	88	%
Without cosigner	109,163		623,156		531,211		359,769		259,981		563,760		2,447,040		12
Total	$	750,072	$	4,577,417	$	3,862,277	$	2,791,354	$	2,397,399	$	6,363,321	$	20,741,840	100	%

FICO at Origination(2):
Less than 670	$	46,437	$	253,657	$	283,992	$	217,921	$	189,704	$	505,347	$	1,497,058	7	%
670-699	103,191		607,789		576,077		423,618		388,607		1,061,435		3,160,717		15
700-749	243,607		1,472,919		1,260,902		921,338		799,597		2,138,263		6,836,626		33
Greater than or equal to 750	356,837		2,243,052		1,741,306		1,228,477		1,019,491		2,658,276		9,247,439		45
Total	$	750,072	$	4,577,417	$	3,862,277	$	2,791,354	$	2,397,399	$	6,363,321	$	20,741,840	100	%


FICO Refreshed(2)(3):
Less than 670	$	64,349	$	313,569	$	325,235	$	290,041	$	283,988	$	952,223	$	2,229,405	11	%
670-699	107,242		573,430		473,331		322,446		271,224		707,135		2,454,808		12
700-749	241,091		1,442,851		1,186,242		813,884		684,467		1,715,802		6,084,337		29
Greater than or equal to 750	337,390		2,247,567		1,877,469		1,364,983		1,157,720		2,988,161		9,973,290		48
Total	$	750,072	$	4,577,417	$	3,862,277	$	2,791,354	$	2,397,399	$	6,363,321	$	20,741,840	100	%

Seasoning(4):
1-12 payments	$	419,655	$	2,510,639	$	426,229	$	396,679	$	392,391	$	718,899	$	4,864,492	24	%
13-24 payments	0		267,856		2,034,191		254,139		221,863		599,435		3,377,484		16
25-36 payments	0		0		146,616		1,343,321		250,078		581,741		2,321,756		11
37-48 payments	0		0		0		93,298		978,808		618,454		1,690,560		8
More than 48 payments	0		0		0		0		64,660		3,029,214		3,093,874		15
Not yet in repayment	330,417		1,798,922		1,255,241		703,917		489,599		815,578		5,393,674		26
Total	$	750,072	$	4,577,417	$	3,862,277	$	2,791,354	$	2,397,399	$	6,363,321	$	20,741,840	100	%

2021 Current period(5) gross charge-offs	$	(6)	$	(911)	$	(4,483)	$	(8,116)	$	(8,793)	$	(32,830)	$	(55,139)
2021 Current period(5) recoveries	0		43		452		1,009		1,133		5,066		7,703
2021 Current period(5) net charge-offs	$	(6)	$	(868)	$	(4,031)	$	(7,107)	$	(7,660)	$	(27,764)	$	(47,436)

Total accrued interest by origination vintage	$	8,317	$	147,329	$	291,579	$	258,813	$	206,734	$	335,703	$	1,248,475
______ (1)Balance represents gross Private Education Loans. (2)Represents the higher credit score of the cosigner or the borrower. (3)Represents the FICO score updated as of the first-quarter 2021. (4)Number of months in active repayment (whether interest only payment, fixed payment, or full principal and interest payment status) for which a scheduled payment was due. (5)Current period refers to period from January 1, 2021 through March 31, 2021.


	Private Education Loans Credit Quality Indicators
	March 31, 2020
Year of Origination	2020		2019		2018		2017		2016		2015 and Prior		Total		% of Balance

Cosigners:
With cosigner	$	698,291	$	4,527,042	$	3,311,178	$	2,869,295	$	2,515,751	$	5,295,854	$	19,217,411	89	%
Without cosigner	126,138		676,071		489,070		353,832		268,799		495,426		2,409,336		11
Total	$	824,429	$	5,203,113	$	3,800,248	$	3,223,127	$	2,784,550	$	5,791,280	$	21,626,747	100	%

FICO at Origination:
Less than 670	$	62,064	$	363,345	$	274,016	$	237,052	$	197,390	$	446,246	$	1,580,113	7	%
670-699	123,512		757,806		555,719		502,930		435,075		955,404		3,330,446		15
700-749	268,388		1,688,114		1,243,712		1,068,091		937,643		1,933,589		7,139,537		33
Greater than or equal to 750	370,465		2,393,848		1,726,801		1,415,054		1,214,442		2,456,041		9,576,651		45
Total	$	824,429	$	5,203,113	$	3,800,248	$	3,223,127	$	2,784,550	$	5,791,280	$	21,626,747	100	%


FICO Refreshed:
Less than 670	$	86,212	$	544,160	$	442,893	$	419,466	$	400,833	$	1,029,741	$	2,923,305	14	%
670-699	127,503		735,546		495,808		400,096		324,334		651,732		2,735,019		13
700-749	261,585		1,633,986		1,145,724		952,467		795,350		1,542,487		6,331,599		29
Greater than or equal to 750	349,129		2,289,421		1,715,823		1,451,098		1,264,033		2,567,320		9,636,824		44
Total	$	824,429	$	5,203,113	$	3,800,248	$	3,223,127	$	2,784,550	$	5,791,280	$	21,626,747	100	%

Seasoning⁽²⁾:
1-12 payments	$	460,330	$	2,838,628	$	469,314	$	529,441	$	460,742	$	715,809	$	5,474,264	25	%
13-24 payments	—		255,403		1,979,761		277,499		258,606		580,426		3,351,695		15
25-36 payments	—		—		169,436		1,494,597		268,357		538,209		2,470,599		11
37-48 payments	—		—		—		117,409		1,194,038		568,792		1,880,239		9
More than 48 payments	—		—		—		—		87,201		2,714,272		2,801,473		13
Not yet in repayment	364,099		2,109,082		1,181,737		804,181		515,606		673,772		5,648,477		27
Total	$	824,429	$	5,203,113	$	3,800,248	$	3,223,127	$	2,784,550	$	5,791,280	$	21,626,747	100	%

Current period gross charge-offs	$	—	$	(1,597)	$	(5,241)	$	(8,136)	$	(10,284)	$	(26,211)	$	(51,469)
Current period recoveries	—		92		599		1,080		1,505		4,700		7,976
Current period net charge-offs	$	—	$	(1,505)	$	(4,642)	$	(7,056)	$	(8,779)	$	(21,511)	$	(43,493)

Total accrued interest by origination vintage	$	9,927	$	181,551	$	281,619	$	279,039	$	217,988	$	288,627	$	1,258,751
______ ⁽¹⁾Balance represents gross Private Education Loans. ⁽²⁾Represents the higher credit score of the cosigner or the borrower. ⁽³⁾Represents the FICO score updated as of the first-quarter 2020. ⁽⁴⁾Number of months in active repayment (whether interest only payment, fixed payment, or full principal and interest payment status) for which a scheduled payment was due.


	Private Education Loan Delinquencies by Origination Vintage
	March 31, 2020
	2020		2019		2018		2017		2016		2015 and Prior		Total

Loans in-school/grace/deferment⁽¹⁾	$	364,100	$	2,109,092	$	1,181,737	$	804,181	$	515,606	$	673,761	$	5,648,477
Loans in forbearance⁽²⁾	4,370		51,418		144,691		180,617		186,362		422,467		989,925
Loans in repayment:
Loans current	454,436		3,020,099		2,422,162		2,162,435		1,999,047		4,458,032		14,516,211
Loans delinquent 31-60 days⁽³⁾	1,524		15,771		27,690		40,349		43,630		125,661		254,625
Loans delinquent 61-90 days⁽³⁾	—		4,760		15,016		22,286		24,645		69,189		135,896
Loans delinquent greater than 90 days⁽³⁾	—		1,983		8,952		13,259		15,260		42,159		81,613
Total Private Education Loans in repayment	455,960		3,042,613		2,473,820		2,238,329		2,082,582		4,695,041		14,988,345
Total Private Education Loans, gross	824,430		5,203,123		3,800,248		3,223,127		2,784,550		5,791,269		21,626,747
Private Education Loans deferred origination costs and unamortized premium/(discount)	4,958		20,484		12,515		9,491		7,960		9,859		65,267
Total Private Education Loans	829,388		5,223,607		3,812,763		3,232,618		2,792,510		5,801,128		21,692,014
Private Education Loans allowance for losses	(59,208)		(369,890)		(275,259)		(234,085)		(195,324)		(382,015)		(1,515,781)
Private Education Loans, net	$	770,180	$	4,853,717	$	3,537,504	$	2,998,533	$	2,597,186	$	5,419,113	$	20,176,233

Percentage of Private Education Loans in repayment	55.3 %		58.5 %		65.1 %		69.4 %		74.8 %		81.1 %		69.3 %
Delinquencies as a percentage of Private Education Loans in repayment	0.3 %		0.7 %		2.1 %		3.4 %		4.0 %		5.0 %		3.2 %
Loans in forbearance as a percentage of loans in repayment and forbearance	0.9 %		1.7 %		5.5 %		7.5 %		8.2 %		8.3 %		6.2 %


	Personal Loans Credit Quality Indicators
	March 31, 2020
Year of Origination	2020⁽¹⁾		2019⁽¹⁾		2018⁽¹⁾		2017⁽¹⁾			2016⁽¹⁾		Total⁽¹⁾		% of Balance

FICO at Origination:
Less than 670	$	—	$	7,501	$	26,745	$	5,072		$	—	$	39,318	4	%
670-699	—		70,479		128,797		21,295			47		220,618		25
700-749	40		195,857		215,424		37,261			456		449,038		50
Greater than or equal to 750	—		91,012		84,726		14,708			284		190,730		21
Total	$	40	$	364,849	$	455,692	$	78,336		$	787	$	899,704	100	%

Seasoning⁽²⁾:
1-12 payments	$	40	$	331,474	$	400	$	—		$	—	$	331,914	37	%
13-24 payments	—		33,375		393,608		6			—		426,989		48
25-36 payments	—		—		61,684		76,924			—		138,608		15
37-48 payments	—		—		—		1,406			787		2,193		—
More than 48 payments	—		—		—		—			—		—		—
Not yet in repayment	—		—		—		—			—		—		—
Total	$	40	$	364,849	$	455,692	$	78,336		$	787	$	899,704	100	%

Current period gross charge-offs	$	—	$	(2,885)	$	(13,758)	$	(2,563)	��	$	(41)	$	(19,247)
Current period recoveries	—		15		1,127		389			11		1,542
Current period net charge-offs	$	—	$	(2,870)	$	(12,631)	$	(2,174)		$	(30)	$	(17,705)

Total accrued interest by origination vintage	$	—	$	3,161	$	3,443	$	414		$	3	$	7,021


	Personal Loan Delinquencies by Origination Vintage
	March 31, 2020
	2020			2019			2018			2017			2016			Total			% of Balance

Loans in Forbearance	$	—		$	12,380		$	7,137		$	—		$	—		$	19,517
Loans in repayment:
Loans current	40			346,123			433,664			76,188			787			856,802			97.4	%
Loans delinquent 31-60 days⁽¹⁾	—			3,321			7,448			810			—			11,579			1.3
Loans delinquent 61-90 days⁽¹⁾	—			991			2,663			701			—			4,355			0.5
Loans delinquent greater than 90 days⁽¹⁾	—			2,034			4,781			636			—			7,451			0.8
Total Personal Loans in repayment	40			352,469			448,556			78,335			787			880,187			100.0	%
Total Personal Loans, gross	40			364,849			455,693			78,335			787			899,704
Personal Loans deferred origination costs and unamortized premium/(discount)	—			335			78			—			—			413
Total Personal Loans	40			365,184			455,771			78,335			787			900,117
Personal Loans allowance for loan losses	(6)			(51,280)			(89,194)			(12,110)			(83)			(152,673)
Personal Loans, net	$	34		$	313,904		$	366,577		$	66,225		$	704		$	747,444

Delinquencies as a percentage of Personal Loans in repayment	—		%	1.8		%	3.3		%	2.7		%	—		%	2.6		%


	Private Education Loans
	Accrued Interest Receivable
	Total Interest Receivable		90 Days and Greater Past Due		Allowance for Uncollectible Interest

March 31, 2021	$	1,248,475	$	3,695	$	4,405
December 31, 2020	$	1,168,895	$	4,354	$	4,467











	Three Months Ended March 31,
	2021				2020
	Allowance		Unfunded Commitments		Allowance		Unfunded Commitments

Beginning Balance	$	110,044	$	1,673,018	$	2,481	$	1,910,603
Day 1 adjustment for the adoption of CECL	0		0		115,758		0
Balance at January 1	110,044		1,673,018		118,239		1,910,603
Provision/New commitments - net(1)	40,197		843,161		49,561		834,946
Other provision items	(3,994)		0		3,982		0
Transfer - funded loans(2)	(126,880)		(2,058,726)		(142,075)		(2,295,742)
Ending Balance	$	19,367	$	457,453	$	29,707	$	449,807


Issue	Date Issued	Total Issued		Weighted Average Cost of Funds⁽¹⁾		Weighted Average Life (in years)

Private Education:














2019-A	March 2019	$	453,000	1-month LIBOR plus 0.92%		4.26
2019-B	June 2019	657,000		1-month LIBOR plus 1.01%		4.41
Total notes issued in 2019				$	1,110,000

Total loan and accrued interest amount securitized at inception in 2019				$	1,208,963

2020-A	February 2020	$	636,000	1-month LIBOR plus 0.88%		4.18
Total notes issued in 2020		$	636,000

Total loan and accrued interest amount securitized at inception in 2020				$	676,089


		March 31, 2020																											March 31, 2021
		Debt Outstanding										Carrying Amount of Assets Securing Debt Outstanding															Debt Outstanding				Carrying Amount of Assets Securing Debt Outstanding
		Short-Term		Long-Term		Total		Loans		Restricted Cash		Other Assets⁽¹⁾		Total			Short-Term		Long-Term		Total		Loans		Restricted Cash		Other Assets(1)		Total
Secured borrowings:	Secured borrowings:															Secured borrowings:
Private Education Loan term securitizations	Private Education Loan term securitizations	$	—	$	4,509,674	$	4,509,674	$	5,594,488	$	172,546	$	370,795	$	6,137,829	Private Education Loan term securitizations	$	0	$	4,225,571	$	4,225,571	$	5,343,243	$	164,708	$	355,949	$	5,863,900
Secured Borrowing Facility	Secured Borrowing Facility	—		—		—		—		9,316		1,835		11,151		Secured Borrowing Facility	0		0		0		0		0		2,496		2,496
Total	Total	$	—	$	4,509,674	$	4,509,674	$	5,594,488	$	181,862	$	372,630	$	6,148,980	Total	$	0	$	4,225,571	$	4,225,571	$	5,343,243	$	164,708	$	358,445	$	5,866,396


	March 31, 2021						December 31, 2020
	Debt Interests(1)		Equity Interests(2)		Total Exposure		Debt Interests(1)		Equity Interests(2)		Total Exposure
Private Education Loan term securitizations	$	199,135	$	30,594	$	229,729	$	68,908	$	16,923	$	85,831


			Cash Flow Hedges						Fair Value Hedges						Trading							Total							Cash Flow Hedges				Fair Value Hedges				Trading	Total
			March 31,		December 31,		March 31,		December 31,		March 31,		December 31,		March 31,		December 31,				March 31,		December 31,		March 31,		December 31,		March 31,		December 31,		March 31,		December 31,
			2020		2019		2020		2019		2020		2019		2020		2019				2021		2020		2021		2020		2021		2020		2021		2020
Fair Values⁽¹⁾	Fair Values⁽¹⁾	Hedged Risk Exposure																	Fair Values(1)	Hedged Risk Exposure

Derivative Assets:⁽²⁾	Derivative Assets:⁽²⁾																		Derivative Assets:(2)
Interest rate swaps	Interest rate swaps	Interest rate	$	—	$	715	$	2,902	$	—	$	751	$	—	$	3,653	$	715	Interest rate swaps	Interest rate	$	809	$	0	$	245	$	594	$	0	$	135	$	1,054	$	729
Derivative Liabilities:⁽²⁾	Derivative Liabilities:⁽²⁾																		Derivative Liabilities:(2)
Interest rate swaps	Interest rate swaps	Interest rate	(275)		—		—		(896)		—		(268)		(275)		(1,164)		Interest rate swaps	Interest rate	0		(287)		0		0		(451)		0		(451)		(287)
Total net derivatives	Total net derivatives		$	(275)	$	715	$	2,902	$	(896)	$	751	$	(268)	$	3,378	$	(449)	Total net derivatives		$	809	$	(287)	$	245	$	594	$	(451)	$	135	$	603	$	442


		Cash Flow						Fair Value						Trading							Total							Cash Flow				Fair Value				Trading	Total
		March 31,		December 31,		March 31,		December 31,		March 31,		December 31,		March 31,		December 31,			March 31,			December 31,		March 31,		December 31,		March 31,		December 31,		March 31,		December 31,
		2020		2019		2020		2019		2020		2019		2020		2019			2021			2020		2021		2020		2021		2020		2021		2020
Notional Values	Notional Values																	Notional Values

Interest rate swaps	Interest rate swaps	$	1,117,945	$	1,150,518	$	5,193,323	$	5,031,429	$	3,452,241	$	3,744,917	$	9,763,509	$	9,926,864	Interest rate swaps	$	1,535,718		$	1,018,976	$	4,637,654	$	4,845,543	$	2,393,364	$	2,693,364	$	8,566,736	$	8,557,883


Line Item in the Balance Sheet in Which the Hedged Item is Included:	Carrying Amount of the Hedged Assets/(Liabilities)						Cumulative Amount of Fair Value Hedging Adjustment Included in the Carrying Amount of the Hedged Assets/(Liabilities)
	March 31,		December 31,		March 31,		December 31,
	2020		2019		2020		2019

Deposits	$	(5,391,335)	$	(5,085,426)	$	(206,396)	$	(63,148)


		Three Months Ended March 31,							Three Months Ended March 31,
(Shares and per share amounts in actuals)	(Shares and per share amounts in actuals)	2020		2019		(Shares and per share amounts in actuals)	2021		2020
Common stock repurchased under repurchase program⁽¹⁾⁽²⁾		47,736,847		5,435,476
Common stock repurchased under repurchase programs(1)(2)(3)						Common stock repurchased under repurchase programs(1)(2)(3)	48,702,830		47,736,847
Average purchase price per share⁽³⁾⁽⁴⁾	Average purchase price per share⁽³⁾⁽⁴⁾	$	9.66	$	11.04	Average purchase price per share⁽³⁾⁽⁴⁾	$	15.75	$	9.66
Shares repurchased related to employee stock-based compensation plans⁽⁴⁾⁽⁵⁾	Shares repurchased related to employee stock-based compensation plans⁽⁴⁾⁽⁵⁾	1,105,119		1,289,391		Shares repurchased related to employee stock-based compensation plans⁽⁴⁾⁽⁵⁾	1,059,980		1,105,119
Average purchase price per share	Average purchase price per share	$	10.98	$	10.95	Average purchase price per share	$	13.50	$	10.98
Common shares issued⁽⁵⁾⁽⁶⁾	Common shares issued⁽⁵⁾⁽⁶⁾	2,837,562		3,470,664		Common shares issued⁽⁵⁾⁽⁶⁾	2,826,387		2,837,562


		Fair Value Measurements on a Recurring Basis																															Fair Value Measurements on a Recurring Basis
		March 31, 2020														December 31, 2019															March 31, 2021				December 31, 2020
		Level 1		Level 2		Level 3		Total		Level 1		Level 2		Level 3		Total			Level 1		Level 2		Level 3		Total		Level 1		Level 2		Level 3		Total

Assets	Assets																	Assets
Trading investments																		Trading investments	$	0	$	0	$	30,594	$	30,594	$	0	$	0	$	16,923	$	16,923
Available-for-sale investments	Available-for-sale investments	$	—	$	538,742	$	75,840	$	614,582	$	—	$	487,669	$	—	$	487,669	Available-for-sale investments	0		2,115,885		0		2,115,885		0		1,996,634		0		1,996,634
Derivative instruments	Derivative instruments	—		3,653		—		3,653		—		715		—		715		Derivative instruments	0		1,054		0		1,054		0		729		0		729
Total	Total	$	—	$	542,395	$	75,840	$	618,235	$	—	$	488,384	$	—	$	488,384	Total	$	0	$	2,116,939	$	30,594	$	2,147,533	$	0	$	1,997,363	$	16,923	$	2,014,286

Liabilities	Liabilities																	Liabilities
Derivative instruments	Derivative instruments	$	—	$	(275)	$	—	$	(275)	$	—	$	(1,164)	$	—	$	(1,164)	Derivative instruments	$	0	$	(451)	$	0	$	(451)	$	0	$	(287)	$	0	$	(287)
Total	Total	$	—	$	(275)	$	—	$	(275)	$	—	$	(1,164)	$	—	$	(1,164)	Total	$	0	$	(451)	$	0	$	(451)	$	0	$	(287)	$	0	$	(287)


		Actual						U.S. Basel III Minimum Requirements Plus Buffer⁽¹⁾⁽²⁾								Actual					U.S. Basel III Minimum Requirements Plus Buffer(1)(2)
		Amount		Ratio		Amount			Ratio			Amount		Ratio		Amount			Ratio
As of March 31, 2020:
As of March 31, 2021:											As of March 31, 2021:
Common Equity Tier 1 Capital (to Risk-Weighted Assets)	Common Equity Tier 1 Capital (to Risk-Weighted Assets)	$	3,112,763	12.4	%	$	1,757,168	>	7.0	%	Common Equity Tier 1 Capital (to Risk-Weighted Assets)	$	3,164,962	13.5	%	$	1,637,155	>	7.0	%
Tier 1 Capital (to Risk-Weighted Assets)	Tier 1 Capital (to Risk-Weighted Assets)	$	3,112,763	12.4	%	$	2,133,704	>	8.5	%	Tier 1 Capital (to Risk-Weighted Assets)	$	3,164,962	13.5	%	$	1,987,974	>	8.5	%
Total Capital (to Risk-Weighted Assets)	Total Capital (to Risk-Weighted Assets)	$	3,428,154	13.7	%	$	2,635,752	>	10.5	%	Total Capital (to Risk-Weighted Assets)	$	3,230,743	13.8	%	$	2,455,732	>	10.5	%
Tier 1 Capital (to Average Assets)	Tier 1 Capital (to Average Assets)	$	3,112,763	9.4	%	$	1,326,107	>	4.0	%	Tier 1 Capital (to Average Assets)	$	3,164,962	10.0	%	$	1,271,568	>	4.0	%

As of December 31, 2019:
As of December 31, 2020:											As of December 31, 2020:
Common Equity Tier 1 Capital (to Risk-Weighted Assets)	Common Equity Tier 1 Capital (to Risk-Weighted Assets)	$	3,264,309	12.2	%	$	1,876,050	>	7.0	%	Common Equity Tier 1 Capital (to Risk-Weighted Assets)	$	3,579,005	14.0	%	$	1,794,780	>	7.0	%
Tier 1 Capital (to Risk-Weighted Assets)	Tier 1 Capital (to Risk-Weighted Assets)	$	3,264,309	12.2	%	$	2,278,060	>	8.5	%	Tier 1 Capital (to Risk-Weighted Assets)	$	3,579,005	14.0	%	$	2,179,375	>	8.5	%
Total Capital (to Risk-Weighted Assets)	Total Capital (to Risk-Weighted Assets)	$	3,600,668	13.4	%	$	2,814,074	>	10.5	%	Total Capital (to Risk-Weighted Assets)	$	3,849,820	15.0	%	$	2,692,169	>	10.5	%
Tier 1 Capital (to Average Assets)	Tier 1 Capital (to Average Assets)	$	3,264,309	10.2	%	$	1,284,642	>	4.0	%	Tier 1 Capital (to Average Assets)	$	3,579,005	11.3	%	$	1,264,424	>	4.0	%