CREW: Department of Education: Regarding For-Profit Education: 4/15/11 – 10-01704- Yuan Documents

8/7/2019 CREW: Department of Education: Regarding For-Profit Education: 4/15/11 10-01704- Yuan Documents

1/22

From:Sent :To :

Cc:Subject:Attachments:

Martin, C ar me lFriday , Ma y 28 , 20 10 3:50 PMMiller , Tony ; Ro gers , Marg o t; C unningha m , Pe ter ; Rose , Cha rlie ; Kan ter, Marth a ; Go mez ,Ga briella ; S hireman , Bob ; Yuan , Geo rgiaDuran , MaribelFW : For-profit e ducation indu stryEismanSohnConf er ence.doc ; ED Pr esentation_SOHN .PPT ; ED_GE MATRIX_2 .xls

FYI. (b)(51diiflOi_

- - - - _ .. - - .-_ ._ . ._ -From: Eisman, S teven [mailt o:seisman@fppartners .com]sent: Frida y, May 28, 2 010 3: 14 PMSubject: For -profit e duca ti o n indu stry

Hello,

My nam e is S teven E isman a nd I a m th e P ortfolio Manager a t FrontPoint P artners Finan cial Se rvice s fund . I wan ted t o

inform yo u that I r ecently spo ke at t he Ira S ohn co nference in New Yo rk a nd m y topic wa s the tor -profit e ducationindustry . My presentation w as very negat ive a nd I wa nted t o brin g to yo ur a ttention m any of the u nsaid or unknownas pects of this industry . We have been resea rc hing for-pr ofit schoo ls for ove r a yea r now and a re very familiar w ith everypart of these bu sinesses. Attac hed a re jh e s peech I ga ve and the pre sentation th at was sha red .

I ha ve a lso attac hed a recent a nalysis we com pleted on the ga inful empl oyment proposal being reviewe d currently . O urpurpose in th e a nalysis is merely to raise awa renes s o n th e how critica lly important cho osi ng t he right metrics is to e nactth e intended o utcomes . Our a nalysis highl ights how c hanging th e key m etrics (spec ifically the d ebt se rvice % a nd th erepayment period) drastically affects th e intended r esults . Fo r ex ample , while m any sc hools will have to lower tuit ion(re s ulting i n lower st udent d ebt levels) u nder th e p roposed 8% debt se rvice r atio and 10- yr repayment , und er a 10 % ratioa nd a 15-yr repayment period , man y sc hools will act ually b e abl e to raise tuition b y 5 % o r more . Moving to a 20-y rrep ayment with 10% ratio provides a mu ch lar ger o pportunity f or nearty every sc hool we 've followed to rai se tuitionsu bstantially (in so me cases by 20 % or m ore) . While I don 't c laim t o kno w th e A dministration 's ultimat e o bjectives , I don'tbelieve ra is ing s tudent d ebt levels th rough higher tu ition is th e intended o utcome of the pro posed r egulati on .

Let me be cle ar - th e debate o n g ainfu l e mployment h as nothing to do w ith "s tude nt acces s" , It has everyt hing t o do w ithre venue-per -student ( and thu s , profit-per-student) for th ese sc hools , a nd that is wh y th e for-prof itindustry is fighting sohard to loosen the me trics . I jus t w ant to e nsure th at th e Ad ministration is aware o f how se nsitive th e outco mes a re t othese metri cs . In our opi nion , if the A dmini st rat ion were to move s ubstantially a way from th e initial com bination (8 % rati oa nd a 10-yr repayment period) , th en it wou ld be better off to have no g ainful e mployment ru le at a ll, s ince a diluted vers ionwilt likely result in no changes a t th e schoo ls a nd no r eduction in st udent's d ebt loads.

S hould yo u ha ve a ny question s o n a ny of th e info rmati o n p rovided , I a m ava ilable t o discuss any of our finding s o rass umptions .

S teven Ei smanFrontPoint Financial Se rvices Fund9 17-934 -1770seis man@fppartners .com

1


2/22

IRA SOHN CONFERENCEPresentation by Steve Eisman

SUBPRIME GOES TO COLLEGEMay 26 ,2010

Good Afternoon. I would like to thank the Ira Sohn Foundation for the honor of speakingbefore this audience . My name is Steven Eisman and I am the portfolio manager oftheFrontPoint Financial Services Fund. Until recently , I thought that there would neveragain be an opportunity to be involved with an industry as socially destructive andmorally bankrupt as the subprime mortgage industry. I was wrong. The For-ProfitEducation Industry has proven equal to the task.

The title of my presentation is "Subprime goes to College". The for-profit industry hasgrown at an extreme and unusual rate, driven by easy access to government sponsoreddebt in the form o f Title IV student loans, where the credit is guaranteed by thegovernment. Thus , the government, the students and the taxpayer bear all the risk and thefor-profit industry reaps all the rewards . This is similar to the subprime mortgage sectorin that the subprime originator s bore far less risk than the investors in their mortgagepaper.

In the past 10 years , the for-profit education industry has grown 5-10 times the historicalrate of traditional post secondary education. As o f 2009, the industry had almost 10% ofthe enrolled students but claimed nearly 25 % of the $89 billion of Federal Title IVstudent loans and grant disbursements. At the current pace o f growth , for - profit schoolswill draw 40% of all Title IV aid in 10 years .

How has this been allowed to happen?

The simple answer is that they've hired every lobbyist in Washington D .C. There hasbeen a revolving door between the people who work or lobby for this industry and thehalls of government. One example is Sally Stroup. She was the head lobbyist for theApollo Group - the largest for-profit company in 2001-2002. But from 2002-2006 shebecame Assistant Secretary o f Post-Secondary Education for the DOE under PresidentBush. In other words , she was directly in charge of regulating the industry she hadpreviously lobbied for .

From 1987 through 2000 , the amount oftotal Title IV dollars received by students of forprofit schools fluctuated between $2 and $4 billion per annum. But then when the Bushadministration took over the reigns of government , the DOE gutted many of the rules thatgoverned the conduct ofthis industry. Once the floodgates were opened , the industryembarked on 10 years o f unres tricted massi ve growth.

[Federal dollars flowing to the industry exploded to over $21 billion , a 450 % increase. ]

At many major-for profit instit utions, federal Title IV loan and grant dollars nowcomprise close to 90% of total revenues, up significantly vs. 2001. And this growth has

1


3/22

driven even more spectacular company profitability and wealth creation for industryexecutives. For example, ITT Educational Services (ESI), one of the larger companies inthe industry, has a roughly 40% operating margin vs. the 7%-12% margins of othercompanies that receive major government contracts. ESI is more profitable on a marginbasis than even Apple.

This growth is purely a function of government largesse, as Title IV has accounted formore than 100% of revenue growth. Here is one of the more upsetting statistics. In fiscal2009, Apollo, the largest company in the industry, grew total revenues by $833 million.Ofthat amount, $1.1 billion came from Title IV federally-funded student loans andgrants. More than 100% of the revenue growth came from the federal government. Butof this incremental $1.1 billion in federal loan and grant dollars, the company only spentan incremental $99 million on faculty compensation and instructional costs - that's 9cents on every dollar received from the government going towards actual education. Therest went to marketing and paying the executives.

But leaving politics aside for a moment, the other major reason why the industry hastaken an ever increasing share of government dollars is that it has turned the typicaleducation model on its head. And here is where the subprime analogy becomes veryclear.

There is a traditional relationship between matching means and cost in education.Typically, families oflesser financial means seek lower cost institutions in order tomaximize the available Title IV loans and grants - thereby getting the most out of everydollar and minimizing debt burdens. Families with greater financial resources often seekhigher cost institutions because they can afford it more easily.

The for-profit model seeks to recruit those with the greatest financial need and put themin high cost institutions. This formula maximizes the amount of Title IV loans and grantsthat these students receive.

With billboards lining the poorest neighborhoods in America and recruiters trollingcasinos and homeless shelters (and I mean that literally), the for-profits have becomeincreasingly adept at pitching the dream of a better life and higher earnings to the mostvulnerable of society.

But if the industry in fact educated its students and got them good jobs that enabled themto receive higher incomes and to pay offtheir student loans, everything I've just saidwould be irrelevant.

So the key question to ask is - what do these students get for their education? In manycases, NOT much, not much at all.

Here is one of the many examples of an education promised and never delivered. Thisarticle details a Corinthian Colleges-owned Everest College campus in California whosestudents paid $16,000 for an 8-month course in medical assisting. Upon nearing

2


4/22

completion, the students learned that not only would their credits no t transfer to anycommunity or four-year college, but also that their degree is not recognized by theAmerican Association for Medical Assistants. Hospitals refuse to even interviewgraduates.

But let's leave aside the anecdotal evidence of this poor quality of education. After allthe industry constantly argues that there will always be a few bad apples. So let's putaside the anecdotes and just look at the statistics. If the industry provided the rightservices, drop ou t rates and default rates should be low.

Let's first look at drop ou t rates. Companies don't fully disclose graduation rates, butusing both DOE data, company-provided information and admittedly some of our ownassumptions regarding the level of transfer students, we calculate drop out rates of mostschools are 50%+ per year. As seen on this table, the annual drop out rates of Apollo,ESI and COCO are 50%-100%

How good could the product be i f drop out rates are so stratospheric? These statistics arequite alarming, especially given the enormous amounts of debt most for-profit studentsmust borrow to attend school.

As a result of these high levels of debt, default rates at for profit schools have alwaysbeen significantly higher than community colleges or the more expensive privateinstitutions.

We have every expectation that the industry's default rates are about to explode.Because of the growth in the industry and the increasing search for more students, we arenow back to late 1980s levels of lending to for profit students on a per student basis.Back then defaults were off the charts and fraud was commonplace.

Default rates are already starting to skyrocket. It's just like subprime - which grew atany cost and kept weakening its underwriting standards to grow.

By the way, the default rates the industry reports are art if icially low. There are ways theindustry can and does manipulate the data to make their default rates look better.

But don't take my word for it. The industry is quite c lear what it th inks the default ratestruly are. ESI and COCO supplement Title IV loans with their own private loans. Andthey provision 50%-60% up front for those loans. Believe me, when a student defaultson his or her private loans, they are default ing on their Tit le IV loans too.

[Let me just pause here for a second to discuss manipulation of statistics. There are twokey statistics. No school can get more than 90% of its revenue from the government and2 year cohort default rates cannot exceed 25% for 3 consecutive years. Failure to complywith either of these rules and you lose Title IV eligibil ity. Lose Title IV eligibili ty andyou're company's a zero.

3


5/22

Isn't it amazing that Apollo's percentage of revenue from Title IV is 89% and not over90%. How lucky can they be? We believe (and many recent lawsuits support) thatschools actively manipulate the receipt, disbursement and especially the return of Title IVdollars to their students to remain under the 90/10 threshold.]

The bottom line is that as long as the government continues to flood the for profiteducation industry with loan dollars AND the risk for these loans is borne solely by thestudents and the government, THEN the industry has every incentive to grow at all costs,compensate employees based on enrollment, influence key regulatory bodies andmanipulate reported statistics - ALL TO MAINTAIN ACCESS TO THEGOVERNMENT'S MONEY.

In a sense, these companies are marketing machines masquerading as universities. Andwhen the Bush administration eliminated almost all the restrictions on how the industry isallowed to market, the machine went into overdrive. [Let me quote a bit from a formeremployee of BPI.

"Ashford is a for profitschool and makes a' majority of its money on federal loans students take out. They convenientlyprice tuition at the exact amount that a student can qualify for in federal loan money. There is no regard to whether astudent really belongs in school, the goal is to enroll as many as possible. They also go after GI bill money and currentlyhave separate teams set up to specifically target military students. If a person has money available for schoolAshfordfinds a way to go alterthem. Ashford is just the middle man, profiting of f this money, like milking a cowand working thesystem within the limits of what's technicaJ1y legal, and paying huge salaries while the student suffers with debt that can'teven be forgiven by bankruptcy. We mention tuition prices as little as possible .. this may cause the student to changetheir mind.

While it is illegal to pa y commissions for studentenrollment, Ashford does salary adjustments, basically the same thing.We are given a matrix that shows the number of students we are expectedto enroll. We also have to meet our quotasand these are high quotas.

Because we are under so much pressure, we are forced to do anything necessary to get people to fill out an application -ou r jobs depend on it.

It's a boiler room - selling education to people who really don't want it."

This former employee then gives an example of soliciting a sick old lady to sign up for Ashford tomeet his quota.

"The level of deception is disgusting - and wrong. When someone who can barelyafford to live and feed kids as it is, anddoesn't even have the time or education to be able to enroll, they drop out. Then what? Add $20,000 of debt to theirproblems - what are they gonna do now. They are officiallyscrewed. We know most of these people will drop out, butagain, we have quotas and we have no choice." J

How do such schools stay in business? The answer is to control the accreditationprocess. The scandal here is exactly akin to the rating agency role in subprimesecuritizations.

There are two kinds o f accreditation -- national and regional. Accreditation bodies arenon-governmental, non-profit peer-reviewing groups. Schools must earn and maintainproper accreditation to remain eligible for Title IV programs. In many instances, the forprofit institutions sit on the boards o f the accrediting body. The inmates run the asylum.

Historically, most for profit schools are nationally accredited but national accreditationholds less value than regional accreditation. The latest trend of for profit institutions is to

4


6/22

acquire the dearly coveted Regional Accreditation through the outright purchase of small ,financially distressed non-profit institutions and then put that school on-line. In March2005, BPI acquired the regionally accredited Franciscan University o f the Prairies andrenamed it Ashford University . [Remember Ashford. The former employee I quotedworked at Ashford.] On the date o f purchase , Franciscan (now Ashford) had 312students. BPI took that school online and at the end of 2009 it had 54 ,000 students.

SOLUTIONS

While the conduct o f the industry is egregious and similar to the subprime mortgagesector in just so many ways, for the investment case against the industry to work requiresthe government to do something -- whereas in subprime all you had to do was wait forcredit quality to deteriorate.

So what is the government going to do? It has already announced that it is exploringways to fix the accreditation process. I t will probably eliminate the 12 safe harbor ruleson sales practices implemented by the Bush Administration. And I hope that it is lookingat everything and anything to deal with this industry.

Most importantly , the DOE has proposed a rule known as Gainful Employment. In afew weeks the DOE will publi sh the rule. There is some controversy as to what theproposed rule will entail but I hope that the DOE will not backtrack on gainfulemployment. Once the rule is published in the federal registrar , the industry has untilNovember to try to get the DO E to back down .

The idea behind the gainful employment rule is to limit student debt to a certain level.Specifically , the suggested rule is that the debt service-to-income-ratio not exceed 8 %.The industry has gotten hysterical over this rule because it knows that to comply, it willprobably have to reduce tuition.

[Before I turn to the impact of the rule, let me discuss what happened last week. Therewas a news report out that Bob Shireman, the Under Secretary o f Education in charge ofthis process was leaving. This caused a massive rally in the stocks under the thesis thatthis signaled that the DOE was backing down from gainful employment. This conclusionis absurd. First, of all , inside D .C. it has been well known for a while that Shiremanalways intended to go home to California after a period o f time. Second , to draw aconclusion about the DOE changing its policy because Shireman is leaving presuppose sthat one government official, o ne man , drives the entire agenda ofthe U.S. government.]

I cannot emphasize enough tha t gainful employment changes the business model. Todate that model has been constant growth in the number of students coupled withoccasional increases in tuition. Gainful employment will cause enrollment levels to gro wless quickly. And the days o f raising tuition would be over; in many cases , tuition will godown.

5


7/22

To illustrate the impact of gainful employment, I've chosen 5 companies , Apollo, ESI ,COCO , EDMC and the Washington Post. Yes , the Washington Post , whose earnings areall driven by this industry.

Assuming gainful emplo yment goes through , the first year it would impact wouldobviously be 20 II. However, because the analysis is so sensitive to tuition levels perschool , it's best to have as much information as possible. So for analytical purposes , weare going to show the impact on actual results in fiscal 2009 and this year ' s estimatesunder the assumption that gainful employment was already in effect .

We employ 2 scenarios. Scenario 1 is static. It takes actual results and then reducestuition costs to get down to the 8% level. Scenario 2 is dynamic. It assumes the samething as scenario I but then assumes the companies can reduce costs by 5%-15%.

Results for each company depend largely on the mix of students , the duration of eachdegree and the price of tuition at each institution

For each company, I show the results under the two scenarios and the correspondingPIEs. Needless to say , the PIE multiples look quite a bit different under either scenario .

Apollo - In fiscal 2009 , the company earned $4.22. The consensus estimate for fiscal2010 is $5.07. Under scenario 1, fiscal 2009 and the fiscal 2010 estimate get cut by 69 %and 57%, respectively . Under scenario 2 , it gets cut 50% and 41 %, respectively.

ESI - In fiscal 2009 , the company earned $7 .91. The consensus estimate for fiscal 2010is $11.05 . Under scenario I, fiscal 2009 turns slightly negative and the fiscal 2010estimate gets cut by 74% . Under scenario 2 , fiscal 2009 declines by 75% and the 2010estimate gets cut by 53%.

COCO - In fiscal 2009, the company earned $0.81. The consensus estimate for fiscal2010 is $1.67. Under scenario 1, fiscal 2009 turns negative and the fiscal 2010 estimategets cut by 94%. Under scenario 2, fiscal 2009 declines by 79% and the 2010 estimategets cut by 38%.

EDMC -- In fiscal 2009 , the company earned $0.87. The consensus estimate for fiscal2010 is $1.51. Under scenario I , fiscal 2009 and the fiscal 2010 estimate turns massivelynegative. Under scenario 2, fiscal 2009 and the fiscal 2010 estimate are also massivelynegative, just less massively than scenario I . The principal reason why the numbers areso bad for EDMC is that they have a lot of debt and that debt has to be serviced andcannot be cut.

Washington Post - The Post's disclosure of Kaplan metrics is slight. Thus , analyzing theimpact from gainful employment is much more difficult and we have confined ouranalysis solely to fiscal 2009 . In fiscal 2009 , WPO earned $9 .78 . Under scenario I , aloss of $33.25 per share occurs . Under scenario 2 , there is still a loss of $6.19. The

6


8/22

principal reason why the numbers are so bad for the Post is that more than 100% of itsEBIDTA comes from this industry through its Kaplan division .

[Let me just add one caveat to our analysis . Implementation of gainful emplo ymentcould result in a cut in marketing budgets. Given the high drop out rates of this industryany such cuts could turn a growth industry into a shrinking industry . The numbers that Ijust showed do not assume that the industry shrinks but grows at a slower pace.]

Under gainful employment, most of the companies still have high operating marginsrelative to other industries. They are just less profitable and significantly overvalued.Downside risk could be as high as 50%. And let me add that I hope that gainfulemployment is just the beginning. Hopefully , the DOE will be looking into ways ofimproving accreditation and of ways to tighten rules on defaults.

Let me end by driving the subprime analogy to its ultimate conclusion. By late 2004, itwas clear to me and my partners that the mortgage industry had lost its mind and asociety-wide calamity was going to occur. I t was like watching a train wreck with noability to stop it. Who could you complain to? -- The rating agencies? - they were partof the machine . Alan Greenspan? - he was busy making speeches that e very Americanshould take out an AR M mortgage loan. The OCC? -- its chairman , John Dugan, wasbusy suing state attorney generals, preventing them from even in vestigating the subprimemortgage industr y.

Are we going to do this all over again? We just loaded up one generation of Americanswith mortgage debt they can ' t afford to pay back. Are we going to load up a newgeneration with student loan debt they can never afford to pay back. The industry is now25% of Title IV money on its way to 40 %. If its growth is stopped now and it is policed ,the problem can be stopped. I t is my hope that this Administration sees the nature of theproblem and begins to act no w . If the gainful employment rule goes through as is, thenthis is only the beginning ofthe policing of this industry.

But if nothing is done , then we are on the cusp of a new social disaster. If present trendscontinue, over the next ten years almost $500 billion of Title IV loans will have beenfunneled to this industry. We estimate total defaults of$275 billion , and because of feesassociated with defaults, for profit students will owe $330 billion on defaulted loans o verthe ne xt lO years .

[Bracketed Sections might be deleted during the verbal speech because oflack oftime.]

7


9/22

Ira Sohn Conference

Pr es ent ation by Steven EismanFr ontP oint Partn ers

M3y 26,2 010

For Profit Education:

Subprime goes to College

In the last 10 year s, thefo r-profit educa tion indus try h as grown ill 5-10 t ime s theh istori cal ra te of t rad itional pos t-seconda ry ed ucation

T h e ~ l I I ' d D P i "i o m i ' lt l l l S l I O l : U ' r > e < 1 l_ p t e p B l e db y . r o r t P c r I IP i l f t~ l L C f f~ , llisirlormallorldoes rllllM w r e g a - d I C l l h e s p t ! C l f l : : ~ ~. 1 ' n o t I C : W I I~ . " l l t h e p a r t" " " '_ a l __ ~ _ l T \ i l } ' f ~thlSinfcIrIo'.atDl Arry stralegydl5o::uo.sed., ttwsreportm", rwxDeSl.Cafllo!olor aipers.an s,andfeCll'll/!l'll5 mvsl.rnak " thoor """"i n w s t ~d . l < : : o s c n sl . U > gt h e i "" " " " ~ ~' i l S t t . yt o e l_ ~ a n db i l l s e d O l l t h e i rs p e c l "o c l W l a n a a lM l ; a l i o r la . ' l d~ c o. : t~ n . ~O ' \C l J ' 1 I_ S l a lf l I ' ! " E I I l t S a lf l J d r e l a tl n ol Ol ! C O l ' \ O I T Ca n dn w k e t~(llel'aIy. A , ' t t ' O . I l ; ht h e s eQ : e m e n : s a ll a c l~ l l e e ' I o t l l a r o e < lf l o o n. < I d ~ ... s a . n : e s ! h < l l t t l e a o . r t r o r t l e ! l l . ' Y e $l o ~reiaDIe ._dorltl!rJUIlRIfItee ll\O!iraa:ww:y IOfld...., .......,lflIof r r C O r mdlt be ftamplel ItDf I:Onllls\sed T h e >e l S , . . , ~ ( I n le o et h a l : t h e~ l I n d~ e o v e s s e dW lU P f l M !t o b e a c o ' i ! O l. ~ . ~ _ ...c .ecDclrtS rnlttfS P ormalllln COl'lStlMel h e ~a l t h e; U h c r _d t h t ' t k l : e" ' n .o o a . n e n l! l f l d_ . ~ I O ~ - . Tn D l l O O. F ~ m s' l O ~1 o ~. r n o d f y... l l I f n e ' l d l h i s~ O I~ rl o( l ly a '~ ...... flOl .. lt>e ewnlltl l l l . " Y _ . e r s:lllle n ds h o ul d c o n su l l~ s o w np mf ~ advisors as t o the legal . tax , r,nlt. C aI, Oflllhel ma l\ef!l, .elevoo tto the s U i t a ~ l r t yo f a n invest men t f or th

F!!pr ptbS4mtJ. nl " " ' ! p 4 1 Ys ' ! ! 9 5 I H g w d IlY ! ! t I I ! I ! ! ! l l

aImosr 10% of s tudentsattend IM-protJr colleges

f2r!!!l>!tt !Mmt!I!...., as 1 'I! q t l1 lF l l U S P5!J!HrnmIirY ln d lMlpm

25 " 01 $ChooIs aretor 'p ' ofirJns tituttom

1


10/22

Despite being less than 10%of total enrollments,for-profits now claim nearly25%ofthe $89billion of Federal Title IV student loans and grantdisbursements

In 2009. For-Profflschoolsc:oll.eted S4A blllionofth . $18.2 billionInFMlenIP.llG ..... ts.orllbout24 %o f aIIP.IIG ..... tfundlng.

doubll!th,proport!onfromfen ve 3a 3 !!9

"', ~

'"'"'"

How is this possible?! Thefor-profit industry has bought almost every lobbyistand has infiltrated the highestlevels ofgovernment...a prime example

S a l ly S t r o u p w a s a p ivo t a l p laye r In the deregulation of the fo r-p ro f i t Indus t ry ...because sh e worked for the forprofitIndustry

Sally StroupBjographv;

2001 - 2002: Director of Indu s try .and GovernmentAff airs for the Apollo Group(topIobbyisf forAPOL)

2002_2006: ASsi stantSeeretaryfor Posts econdary Educ ation, U.S.Dept 01Education (toppo:stsecondaryeducation p o : s i ~ ' o n )

2000 - 2008: GOP Deputy Staff Director.U.S.Houseof R epre sentativesCommittee On Education and Labor (Itltyest recipient of politic ...1c:ontributiom


11/22

Now ma ny of the US for-profi t educa tion com panie s are amo ng t hemos t profitablebusinesses in the wor ld

Thi s gro wth howev er,is primarily a func tion of go vernmen t largesse, as Title IVh as accoun ted f or m ore than 100'X of the reve nu e grow th of the se comp an ies

-- -- - - -~ - -

O t h M h l ~t ~ of s fTlltegfc ImpOf1ance t o the U.S.wh k h . , . ftmd tHIby taJqnye rd oi/a n " " , . . t r ic t lto Io-T opuating m.,-gfns tin con tr ..cts .

-_:==_....---.

_ - ~

..,IH 2 1:1, 4'

1. 11

"'IZ'"

-More th an 100/. or th e

re venue gro wth of APO L,COC O and ESI is d riven byan toce ease In Fed era l 1 m.

IVdo (lals

So ". , . . . n " 1JtIe fV.fund od ..dIJc..tJon comp.m.s.- n substallrJ.. lly m o n t mone y th 2fl ",,frly" " " 7oth.,.m a fNU Sb u s ln e u 1

- , ~- - ~= - - - , ,- ~ --- - - - - -

Bur how do theydo it? Ho w a rc for-profit schoo ls grabb ing such a growi ng share ofTItle IV do llars?

f _

'- -I _ _ t - . . . . -

"""'_y--_.-, ,V ll ... _2OOaSt_....... ..._..

-,- , , ~""

" .1 3

. ~$ .. 1

and of thi s Incremental$1.1 biDlon I n TItle IV and$13 3 m illion In rev enue s ,

-ONLY' " m illio n o r ' %

was s pent on educ;a UooaIexpen.s esli ke ht:r.lty

com pens,aUon and ottll"finstruction al costs

~ ' " ' :: : :' := : = : : ' ~ ~ ~ '~ . f t t : o, g . t / i f tg / l J o lf T l O $l o ul o f . " " ' Y _ ' I o ' < l d_ _d , p < J df l l : . x ~f t $. n d.m W m in _ " y d " " '6 _ .

F ." , _ _ P ' " '~ _ W" ' - "Q _ . _ ~ 'coo/" .lrtw""".b""" ..... .. _ y c a n . trod lo Pfy",.J O l. , l gl b l er < J ( ~ n I.. bK . ...... d lh


12/22

Default ra tes - his torica l Nati ona lCohort Default ra tes by instituti on type

O I I U J t h o f l l M ~W .. . . . , . . , t I M r . - ; u l~ ~ _ - . . t m gD n t ,tbd- " ,oo ' tt Fqr-DCOftt , chooh . . tfJI tqhbr 2 K ngtHWpl ' i t do Ia i J I t ,M Q I

Ex hibit 2. NoI:tiol\Ol COhen Oe1:Iult R.:I.-s try I n ~ t l t u t lo n Type (FY1S!1FY 20011

D " " "O _ . _ . E . %. : E I : l ~D : l l l : >O m oD ~ D : r ; , , ; I lO = C I I~

If his tory is a ny guid e, we will return to latc-8O's Cohort Def au lt rates in 1-2 years,the worst period ofre corded default rates in the h istory o f th e OO E

"-. .nge TCII. t . o - . o . r . n b ll'O"Fof ..... . . . . ~ ... . DOEOIJIc.laI COR&,1. T- 2OO!tI cc:lI..., ..-.. c._ e-c>oIalft I

-,

'.

Cu rrently, for -profit inst itut ions pro vision 50 - 60% on loons the y ma ke t o t heirown studcn ts ... these arc stud e n t s w ho a lready h ave Titl e IV loan s

Corrpanies ar e prcM:sion ng for mor e !han ~ + loss on loans ~ ma ke to students ...wt'ich means t h e y expect more than 1 out of ewry 2 loons to go bad

But absent any r~ ltYNt, these ~ c:cMd car e loss if 1h8y e'I/'8fY loan 1neymade went bad because the per -s 1udent protitob1ity at thH models is so tjgh!

BoIh c:ompanies woulcI still be hugely prcfit:;;r,bte en .apet -student basis even wrth 31 00%\c:$sesontNef y1oan they made

We a re back to lat e-80 's level s o f len ding to for-profi t s tude n ts, a key leading indicatorfor loan defau lts . .. back then,.f raud was com monp lace and r egulationw as mi nimal

TtMfi ljona! n Eg[::I![Qfjtd jiby (!PI!ttTJ1Sof T", ry Su lTor" b o.an . a nd PrlI Grant!; ' 911 - 2009. . . . .

........-.. _.....

-~

-~ ~.. -

' h

h

' h

'hS' _ "" ...

Bccausc o f the excess ive d rop-out ra tes and h igh de bt burden s o f gra d ua tes, the cred itsta tistics for governme nt loa ns a t for-profits a rc deterior at ing a t an a larming pace

Reported sta tistics ... Coh orl Default Rates (CDRs)

Cohort Detau!l: Rat es (COR sI

COR$ we '" ~ of ;lls o ; h o o I ' $~ who._ lepaymont on .. f ederal Loon CUing ;llparticularf&dwalfY {Cd 1 to Sep JO).and dlhu l priorlo " - e n d of "- n-lll fY~ .. 2 - y r S l ' l a f 1 S M to l l h el l l t a l~ i n d I r t a u Aa : J R si l 1 l la n i m p o r t a r t ~o t q w o li l y- i fd u l a U t n t a sb re a d l" - l e d e r ~ t t u W l o l do f 2 5%

(soon to blJOII. ),schoohcan 1054lolgi tUtybTe . 1V

eaTa. N ......... l I ' - *a N ~_ _ s,e.f i- ~ " " " p o r _ Il.1lllI

" u o t u l, . ~ ( 2 C O Q IPr In ... C") WJIi

& , . . : t a d- - . s" , ,~ . . . . . . ( S '~~ . . . . . . ,. _ $1,71 2= ' : : " '- : := . - v ~__ .. ~ .D- .,. __

....[I1 ,ll21)

ESl earn, A>Or than 8 limn ~.amountit ell pectsto losefT OIII

" tern;dlo.in. to . tuden ts .

c oc o earns mor e 1han 4 t


13/22

Reported statistics ..the 90/10 rule Reported statistics... completions and placements

Completions (graduation statsl

9OJ10says" for-profit may become inllligibleto parliminstitulions Is to acquire the durly-coveted Regional Accreditation thmugh the outrightpurchanofsmall,flnanclallydlstressOKlnon-pmfitlnstitutions

Regional A c c r e d ~ a t i o nis thehighest stamp of quality(Harvard is Regionally A c c r e d ~ e d ) ,andusuallytakes 5-10 yearstoearnthrougha longpeer review process of educationalmetenats curriculum.teachers. etc

Butwho wants t o w a ~5 years?1

- ---

TheAccrediting Council for IndependentColleges and Schools (ACICSl

ACCSBOARDOF ( ~ . . . . .

M. MOfYHoIoB."Y5eniarVicepr. idonl.ClofAc.domioOffcorK n t . . , j ; I ~ , d l l c " I < > I ' l

M " . R ' ; g . r S - ~ l d o r

E > c o c o . ( l " " V i c. P r. " d . n l , ~ I C. . . . . . . I .r>oldM."".1 \ M I > l ' n l V i c. P r o " d o n l , A c o r _ " " . 1 d U ~ ; , gC ~ l r I n C < > l ~ , n c

Accreditationhelps ensure thmeducaticmprovided by institutions of highereducationITIlMltsacceptable le\IGls of quality

TheAccredilalU>n bodie:l are non-govemmenlal(nol'l-profit)peer-reviewing groups

Schools must eemand maintainproperAccreditation to remain eligible to participateinTiUerIJPrograms

Howo\l(lf, duG o the peer-basedcomposition oftheAccroditationboards, they cannot functionasatrutyindependont3f'lpartyreviewsyslem

Inmanyinstances,for.pl"ofitinstitution'srepresentatives s it on the boards of theirown Accrediting body, inevitablyinfluoncingthe approval process ando\IGrsight of their owninstitutions!

What isAccreditation and why is rt mportant?

5


14/22

Summary an d solutions: Its all about incentives...

Solutions - Gainful employment

Gainful employmentgets at part of the problem because it deals with debt loads, butverification isproblematic

Programs DONOT have to be shut down for schools to remain compliant with new regulations

Companies can restructuretheir business to accommodate the regulation and schools wouldbecome more affordable and student debt loads would be lower

However, a gainful employment metric would structurallyreset theearnings power of companies

Gainful employment and APOL- - - - -

Summary

The pace of thegrowth of thefor-profiteducation industry and their growing claim to Federal monieswillrequire greater scrutiny to protect students and theintegrityof Title IV lending

The primary revenue and profitability driver forthe for-profit companies is unrestrictedaccess to Title

IVJoansand grants

For-profit education companies are now among the most prof i table businesses in the wor ld due togovernment largesse

Regulations built around company-reported statistics are ineffective, and theAccreditationprocessforfor.profitschools and programs is compromised

Disaggregat ion ofr i sk f rom reward is the fundamenta l cause of a ll problems

Solutions - Gainful employment analysis impact (key assumptions)

1. Cost of programs based on reported cost I credit hour and programlength

2. Percent of degree financed assumes Tit le IV % revenues less 10% (transfer credits andcash)

3. Debt service payment based on 7.5% interest rate (6.8% government loans 112% private) and 10yr repayment period

4 Starting salaries taken from appl icable BLS codes , by programcategory and job typo

5. Debt service I income ratio of 8% based on Gainful Employment proposed regulation

6. Student mix by program level and program type used tocalcula te total revenue impact

7 Cost cuts es timatedon a per-schoolbasis, based on disc losed cost categories and industry experts

8. EPS impacts and PIEratios based on existing reported information, share counts, and currentstreet EPS estimates

9. Scenario 1: Gainful Employment with no Offsetting Cost Cuts

10.Scenario 2: Gainful Employment with 5%-15% Cost Cuts

- - - - - - - - - - - - - - - - - , . -

Gainful employment and ESI

Actual 2009 EPS2009 EPS{adjusted)2009 EPS I m ~ c t

Street 2010 EPS estimate

EPSlmpact2010 EPS (adjusted)2009 EPS Impact

CurrentP!E{2010EPS)2010 Pro-formll pIE

$4.22

$1.32

-69%

$5.07

($2.90)$2.1757%

1 0. 8 X25:4 x

$4.22$2.12

-50%

$5.07

($2.10)$2.97-41%

10 .8 X18.5 x

Actual 2009 EPS2009 EPS (adjustedl2009 EPSlmpact

St ree t 2010 ees Estimate

EPSlmpact2010 EPS(lIIdjusted)2009 EPS impact

Current PIE(2010 EPS)Pro-forma piE

$7.91($0.22)

-103%

$11.05

($8.13)$2.92

-74%

10.0x37.6 x

$7.91$2.02

-74%

$11.05

($5,89)$5.16

-53%

10.0 X21.3 x

_ : C ~ _ ,_ _ .__ . ~ < O l I > , _ E P S _ . _ ~ , P n > ~ _ b o " '.._ .....1o. . _ ~ I o t m p / f _ a " '_ _ .. IIo_ _ 7 0 p p / i 0 > ~ 1 J " < O t I < U I , . . " ".. ,' u < . I i o n _ S G ~ " o I b.. " ' _ N < I i f > o .

6


15/22

Gainful e mployment an d COCO

Ac.tual 2009 EPSEPS C.cI usted)

..... -tnet 2010 EPS EsCIm.t.EPSlmpac:t2 01 0 I PS ( _ djus:tecf)2009 EPS Impict

Current PIE(2010 [PS IPTo- onn.pIF

l m w I t l - - . z$0 .11 $0.&'

($0 .16) $0.17. 194% .-1.67 $L 6 7

(5 1.57) (50.64)$0.10 SU ... " -38 %9.0 x 9.0 x

153.5 x .. 14.6 x

Gain ful e mployment an d EDMC

ActwI I 2009 EPSEPSladJusted )EPS Impact

$trMJt 2010 EPS EstIm.ttJEPSlmpact

20 10 PS (.djusted)2009 EPSI mpllct

Cu r re n t P IE (2010 EPSIPro-form . piF

$0 .37($5 .501 732%

S U '(553 7 )($4 .86)-42 '"

14.6 x4 .5 x

$0 .17($2.2,) 35 3%

SU I(53 .08)($L57)204"

14 .6 x14.0 x

_ C ~ ~ _ " ' t o o" " " .... __ ...... _ ,,., _ . _ - . __~ _ .._,,,,_ ..._ ......~ ...- " " Y _ ~ , . ."".._ l _ ,.I,._ ..........._ "'- _SG...._",......... __

Gainful employment and WPO ( Kaplan)Ifthe se t rends continue, we be liev e-the DOE wi ll face ncarly $275Bi n d efaults ove rthe n ext 10 yca rs o n a h alf-a-trillion doll ar s o f lending to the For-P rofit Industry

I " r a~ C w r u b U wS&arlwdlollrn; '" I ( l I I lans lande- ...l t f t ~Dobn.f O I ' "F w- h o f t ~ ~ t s . 2 0 0 1. : Z O Z O

A


16/22

From:Sent:To:

Cc:Subject:Attachments:

FYI. Attached and below.

Pauline Abernathy [pabernathy@ticas .org]Thursday , October 28,201010 :17 AMKvaal, James ; Madzelan , Dan; Arsenault , Leigh; Hamilton, Justin; Gomez, Gabriella ; Yuan,Georgia; Bergeron, David; Kolotos, John; Smith, Zakiya; Robert_M._Gordon@omb .eop.gov;[email protected] Asher ; Connie Myers; Jennifer WebberFW: TICAS statement on final 13 regsTICAS statement on program integrity rules .docx

Final Rules Curb Student Aid Fraud and Aggressive Marketing

Additional changes needed to protect students and taxpayers

"The final rules issued today are a big win for students and taxpayers. It is especially significant that these rulesrestore the ban on incentive compensation, so that college representatives can no longer be paid based on thenumber of students they enroll. This important change closes loopholes that led to boiler -room style sales tacticsat some colleges , with recruiters doing and saying whatever it took to get students to sign on the bottom line. Arecent undercover investigation by the U.S. Government Accountability Office (GAO) showed how commonaggressive and abusive recruiting tactics have become at for-profit colleges. GAO investigators found that 15out ofthe 15 for-profit colleges they visited engaged in fraudulent, misleading and/or deceptive recruitingpractices . The new rules also tackle other areas of fraud and abuse , including the falsification of test results tomake unqualified students eligible for federal grants and loans.

"These rules are an important start , but much more needs to be done to protect students and taxpayers . Theongoing Senate hearings , GAO reports , and recent actions by two state attorneys general all point to the needfor further action so that taxpayers are not subsidizing career education programs that routinely leave students

deep in debt they cannot repay. A broad coalition o f student , consumer, college access and civil rightsorganizations is counting on the Obama Administration to issue a strong and effective definition of gainfulemployment that goes into effect in 2012. The Education Department should also use every tool at its disposal,including administrative and enforcement actions , to put additional protections in place for students andtaxpayers beginning in 2011.

"The final rules issued today will also streamline the process o f verifying the accuracy of students ' financial aidapplications , which will help more students receive the aid they qualify for. Under the final regulations ,financial aid offices must only confirm the accuracy of specific items flagged for possible errors , rather than afixed list of items regardless o f their relevance. The rules also clarify that schools do not ha ve to verify tax datafrom the Internal Revenue Service that students electronically transfer into the Free Application for Federal

Student Aid (FAFSA). This will be particularly helpful for schools and students once all applicants are able touse their IRS data in this way. These are important steps in the right direction , and we urge the Department toprovide colleges with clear guidance so that the new rules do not iriadvertently increase, rather than decrease ,verification burdens for both students and schools. "

# # # #

1


17/22

An independent , nonprofit organization , the Institute fo r College A ccess & Success works to mak e higher education mor e availabl eand affordable for peop le o f all backgrounds . For more about our programs and initiatives , including the Project on Student D ebt , seehttp ://ti cas .org . Fo llow us on Twitter : http ://twitter .comITICAS org

TICAS statement on p rogram integrity ru les.docx

2


18/22

Mayes. Edgar

From:Sent:To:Subject:

Dear Ms., Asher:

Mayes,Edgar on behalfof Duncan, ArneThursday, May 20, 2010 1:46 PM'Lauren Asher'RE: Letterfrom broad coalition seeking strong regulation ofcareer education programs

Thank you for your e-mail to Secretary of Education Arne Duncan. We appreciate hearing from you.Your message has been forwarded to the appropriate staff member for review.

Thank you again for contacting us.

Sincerely,

Edgar MayesDirector of Correspondence andCommunications Control UnitOffice of the SecretaryU.S. Department of EducationWashington, DC 20202

From: Lauren Asher [mailto:[email protected]]sent: Thursday, May 20 t 2010 1:07 PMTo: Duncan, ArneCc: Kanter, Martha; Plotkin,Hal; Gomez, Gabriella; Shireman Bob; Madzelan, Dan; Arsenault, Leigh; Manheimert Ann;

Hamilton, Justin; [email protected]: letter from broad coalition seeking strong regulation of career education programs

Dear Secretary Duncan,

Please find attached a letter from a diverse coalition of more than 30 student, college, consumer and civil rightsorganizations seeking strong an d effective regulation of career education programs. Those signing the letterrepresent many public institutions that are subject to the gainful employment an d incentive compensation rules,as well as advocates for college access for African-American, Hispanic an d low-income students.

Thank you for your initiative in reviewing the Department's current program integrity regulations to ensuretheir consistency with federal la w and to protect both students and taxpayers. We support your efforts and stand

ready to assist you in improving the Department's regulations. Please feel free to contact me or any of the stafflisted below should you or your staff have any questions about this letter or the issues it addresses.

Institute for College Access & Success: Pauline Abernathy ([email protected]) or Debbie Cochrane([email protected]), 510-318-7900Florida State College at Jacksonville: Susan Lehr ([email protected]) or Jim Simpson ([email protected],904-632-3391National Association for College Admission Counseling: David Hawkins ([email protected]) orAmanda Madar ([email protected]), 703/836-2222National Consumer Law Center: Deanne Loonin ([email protected]), (617) 542-8010

1


19/22

Public Advocates: Jamienne Studley ([email protected]), (415) 431-7430United States Students Association: Angela Peoples ([email protected]. (202) 640-6570U.S. PIRG: Chris Lindstrom ([email protected]), 617) 747-4330

Sincerely,

Lauren AsherPresident, Institute for College Access & Success

(P19ase nota our new phone number snd address!)lauren AsherPresidentThe Institute for College Access & Success405 14th St., 11th FloorOakland, CA 94612(510) 318-7900. [email protected]

www.ticas.orgwww.projectonstudentdebt.orgwww.college-insight.org

2


20/22

May 20, 2010

The Honorable Arne DuncanSecretary of EducationU.S. Department of Education400 Maryland Avenue, SWWashington, DC 20202

Dear Secretary Duncan:

As organizations representing students, higher education. consumers and civil rights, wewrite to express our support for the Department of Education's efforts to make itsregulations more consistent with the program integrity provisions in Title IV o f the HigherEducation Act. In particular, we urge you to propose regulations on incentivecompensation and gainful employment that will more effectively protect students from

high-pressure and deceptive sales tactics for educational programs oflittle or no benefit tothem, and will ensure that taxpayer dollars do not subsidize such practices and programs.

To protect both students and taxpayers, federal law prohibits "any commission, bonus, orother incentive payment based directly or indirectly on success in securing enrollments orfinancial aid," and requires vocational programs and nearly all programs at for-profitinstitutions to "prepare students. for gainful employment in a recognized occupation." Yet,examples of overly aggressive recruiting are plentiful. Some for-profit institutions recentlymade headlines by targeting homeless shelters in their recruitment efforts. i Another forprofit institution paid $78.5 million to settle a whistleblower False Claim Act lawsuit ii andanother $9.8 million to the Department of Education to resolve claims that it was payingimproper incentive compensation to its recruiters. ii i Yet another large for-profit institutionpaid $6.5 million to settle a lawsuit brought by the California Attorney General charging "apersistent pattern of unlawful conduct," including the inflation of jo b placement andstarting salary information in order to recruit students to enroll in costly vocationalprograms, and falsification of records provided to the government. iv

While most schools may no t engage in such practices, federal data suggest these are notisolated incidents. Students at for-profit schools are the most likely to borrow and borrowthe most. According to the most recent federal data, one in five for-profit school studentsdefaults on their federal loans. A full 44% of all defaulters attended for-profit institutions,even though just 7% of all students attend for-profit schools. v Low-income, firstgeneration and minority students attend for-profit institutions at disproportionate rates,

making them particularly vulnerable to illegal or unscrupulous acts by these schools. VI

Incentive Compensation. In direct conflict with federal law prohibiting institutions ofhigher education from providing "any commission, bonus, or other incentive paymentbased directly or indirectly on success in securing enrollments or financial aid," currentregulations permit incentive payments that are not "based solely" on the number ofstudents recruited, admitted, enrolled or awarded financial aid. Some schools haveaggressively exploited this and other loopholes in the current regulations to do just whatthe statute is intended to prohibit. Consistent with the Department's proposals during thenegotiated rulemaking process, the proposed new regulations should conform to the law


21/22

and prohibit any employee or contractor compensation "based directly or indirectly" onsuccessfully securing student enrollments or aid. To avoid creating additional loopholes, itis important that the prohibition include compensation based directly or indirectly onapplications or enrollment up to and including completion, as well as payments forprospective student contact information.

Gainful Employment. Each year, students borrow and taxpayers spend billions of dollarsto subsidize attendance at programs required to "prepare students for gainful employmentin a recognized occupation." Yet, the Department's current regulations include no officialdefinition of "gainful employment." We urge you to develop regulations that definegainful employment in a way that is measurable, enforceable, not overly burdensome toschools, and is aligned with the following principles:

Include all debt incurred at an y affiliated school. All debt incurred at a schoolunder the same control structure must be included in any measure of gainfulemployment that considers debt. Otherwise, schools controlled by the same

company could simply move students from one school or program toanother. Excluding debt from unaffiliated schools also has the benefit of allowinglow-cost schools to enroll and graduate students with high debt from unaffiliatedschools without fear of penalty.

Include all private loans known to th e school an d its affiliates. Debt-relatedmeasures of gainful employment must include all private loans that should beknown to the school. Excluding private loans would create a perverse incentive forschools to promote risky private loans before students have exhausted their saferfederal loan options. Private loans that should be known to the school must includeall credit provided by any school under the same control structure as well as any

loans provided by lenders with which the school has a preferred lenderarrangement.

Avoid loopholes for programs with hoth high student horrowing and lowcompletion rates. A low completion rate is one of the ways schools can fail toprepare students for gainful employment. Students who borrow but do notcomplete are often left carrying substantial debt without the increased earningpower that should come from a completed degree or certificate. The definition ofgainful employment should not create a loophole for schools to discouragecompletion by students they consider likely to have trouble repaying their loans.

Use only data that are accurate and consistent across colleges and programs.Existing requirements for the calculation and reporting of completion andplacement rates are not sufficient for use in any success-based measure of gainfulemployment. Accrediting agency requirements vary widely and allow forsubstantial variation in the calculation of rates, and some schools have been foundto have falsified and manipulated their placement data. It is therefore essential thatthe data and reporting standards are clear, consistent and independently verified.

Again, we applaud your initiative in reviewing the Department's current program integrityregulations to ensure their consistency with federal law and to protect both students and

2


22/22

taxpayers. We support your efforts and stand ready to assist you in improving theDepartment's regulations.

Sincerely,

American Association of Collegiate Registrars and Admissions OfficersAmerican Association of University WomenAmerican Federation o f TeachersAmerican Medical Student AssociationCalifornia Community College Student Financial Aid Administrators AssociationCalifornia TomorrowCampus Progress ActionCenter for Law and Social PolicyCommunity College League of CaliforniaConsumer ActionConsumer Federation o f California

Crittenton Women's UnionDemos: A Network for Ideas & ActionEmpire Justice CenterFlorida State College at JacksonvilleGreater Boston Interfaith OrganizationThe Greenlining InstituteThe Institute for College Access & Success and its Project on Student DebtNAACPNational Association for College Admission CounselingNational Association o f Consumer Bankruptcy AttorneysNational Center for Public Policy and Higher Education

National Consumer Law Center (on behalfo f

its low-income clients)National Consumers LeagueNational Council o f La RazaNeighborhood Economic Development Advocacy Project (NEDAP)New York Community College Association o f PresidentsPublic Advocates Inc.Public Higher Education Network of MassachusettsRainbow PUSH CoalitionStudent Senate for California Community CollegesU.S.PIRGUnited States Student Association

i Golden, Daniel,"Homeless Dropouts FromHigh School Luredby For-Profit Colleges," Bloomberg.com,April 30,20I O. Available at hI1P"l!www blQ!)mberg CQrn/aPPi(news"pjd=newsarcbiye&sjd-aA2 FlYDs2Skii O'Reilly, Cary and DanielGolden,"ApolloSettlesUniversity of Phoenix Recruiting Suit:' Bloomberg.com,December 14,2009. Available at hltp'(i www bloom!:lergcornfappslnews?pjd=206QI087&sid=sO TscSKjRBI&pQs=5iii Gilbertson, Dawn, "Student-recruitment tacticsat University of Phoenix blasted by feds," The ArizonaRepublic,September 14, 2004. Available at bttp'l!www mentea l oom/&pecjals(specjal421anjcJeslO9J4,pol!o14 html"&wjredi. California Attorney General's office: July31, 2007pressrelease on settlementwith Corinthian Schools athttp'Hag ca goy(oewsDlerufre'ease php9jd,.1444

Y TICAS pressreleaseavailableat hlW;lInTQjeclonsludentdebt.Q[!!lDul!yiew.phD?idx=537vi Basedoncalculations by the Projecton StudentDebton datafromthe 2008NationalPostsecondaryStudent AidStudy (NPSAS).

Date post:	08-Apr-2018
Category:	Documents
Upload:	crew
View:	217 times
Download:	0 times