Earnings Labs

SLM Corporation (SLM)

Q4 2007 Earnings Call· Wed, Jan 23, 2008

$23.20

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Transcript

Operator

Operator

Good morning, my name is Janice and I’ll be your conference operator today. At this time I would like to welcome everyone to the SLM Corporation’s fourth quarter 2007 earnings call and shareholder meeting conference call. All lines have been placed on mute to prevent any background noise. After the speaker’s remarks, there will be a question and answer session. If you would like to ask a question during this time, simply press star then the number one on your telephone keypad. If you would like to withdraw your question, press the pound key. Now I would like to turn today’s conference over to Mr. Steve McGarry, Vice President of Investor Relations, please go ahead sir.

Steve McGarry

President

Thank you very much. Good morning everybody and thank you for joining us here in person this morning and via the telephone. Before I turn the conference call over to Mr. Tony Terracciano our Chairman, Al Lord, our CEO and Jack Remondi our CFO, I would like to read this Safe Harbor statement. Please note that during the conference call, we may discuss predictions and expectations and may make other forward looking statements. Actual results in the future may differ from those discussed here, perhaps materially based on a variety of factors. Listeners should refer to a discussion of those factors on the company’s form 10K and other filings with the SEC. During the course of this conference call and meeting we will refer to non GAAP measures that we call our core earnings presentation. The description of core earnings, a full reconciliation of the core earnings presentation to GAAP measures and our GAAP results can be found on the fourth quarter 2007 supplemental earnings disclosure accompanying the earnings press release which was posted on the investor’s page at our website, SallieMae.com. Thank you and now I’m going to turn the call over to Tony.

Tony Terracciano

Chairman

Good morning. It seems to be getting harder and harder to remember what a normal operating environment is. If you look back over the past several years you see periods of euphoria and periods of adjustment, panic and almost despair and it’s ironic in a way that what both types of periods have in common is that differentiation of risk sort of evaporates and value becomes elusive. I’ve looked over the past cycles, past events, going all the way back to the LDC debt crisis of the early 80’s to real estate crises, the HLT LBO problem, the Asian crisis, the tech problem and one thing you learn from going through that list is that it’s a little bit difficult to forecast the duration. And therefore and I think you’ll hear this today, when you make your operating assumptions, it pays to some extent to be defensive until you have a better understanding of all the corollary potential, risks involved and the duration of the period and for you in your work it’s very hard to look at an individual franchise in an environment like this and estimate the franchise value coming out of that type of a period. And then of course you always have specific issues involving any company and for us we had the transaction that didn’t happen, we have changes in the legislative environment and we’re a company going through a transition in the types of asset creation that we do and all of that makes your job very, very difficult. And I think at the very least you have a right to understand the nature of the response that management and the board thinks is appropriate for this type of an environment. And that’s what we’re going to try to communicate today, how are we…

Al Lord

Chairman

Good morning. Well we have a large turnout here in the room and I understand we’ve got several hundred people on the phone, I like Tony thank you for your interest in Sallie Mae. It’s been suggested that I’d be happy to see the year 2007 over although I have to say I’m not particularly impressed with the capital markets at the beginning of ’08. As you’re well aware at the end of ’07 we added some capital, that was obviously something that we felt essential at that time. The other thing that was essential at that time and not just the only thing essential but it was to bring some talent into the company and we did that, we did that at the very beginning of January and the new talent is sitting at this table. You’ve heard from Tony, you’ll hear from Jack Remondi. Tony’s nickname is Tony T, Tony’s got an impressive resume, it’s reasonably long resume but what’s impressive about it is it’s accomplishment and not just accomplishment but accomplishment on behalf of shareholders. I’m not quite sure that the T presumably stands for Terracciano, I think it may also stand for talent and for sure it stands for tough. Next to him is Jack Remondi, as you guys probably know, Jack was a CFO some number of years ago, he’s back in the CFO role, although his role is going to be far larger than CFO. Jack brings a lot of intelligence, financial acumens, he’s a student loan veteran, his principle attribute is commons sense and reliability. The three guys on the platform, actually there’s four guys, that’s Somsak Chivavibul, he’s the guy that creates all the numbers for us. But the point was that the guys on the podium are finance guys. Tony mentioned…

Jack Remondi

CFO

Good morning, it’s been about a two and a half year absence for me being on this side of the table, I’ve spent the last two and a half years sitting in the audience like you. I’m glad to be back on this side of the table today. My presentation this morning is going to cover five different areas, I’m going to give you an overview of our 2007 operating results, I’m going to spend an awful lot of time on private credit to help you better frame, give you the perspective of what’s going on in that portfolio and how we have identified the loans that are the major driver of our credit losses in 2007, we’ll talk about our business strategy, what we need to do to change the way we operate in order to return this business to the high growth high quality earnings capabilities that we saw in the past. Given the funding environment, I’m going to spend some time there as well, let you know where we are in our financing vehicles, what our plans are for 2008 and what we have for some spread expectations and the cost and then finally we’ll go through an outlook for 2008 and beyond. The takeaways I’d like to leave you with are you know a clear framing of the issues that we’re facing, not just in private credit but across the funding side and the operational challenges that we have to deal with, the steps that we are taking today to address those issues where some of the big things are easy and have been announced already such as the school issues that Al mentioned but some of the other ones maybe a little bit less obvious and then finally as Tony said to give you a…

Operator

Operator

At this time I would like to remind everyone, in order to ask a question please press star then the number one on your telephone keypad. We’ll pause for just a moment to compile the Q&A roster. [Unknown Analyst]: [Inaudible question]

Jack Remondi

CFO

The question really had to do with is that as the non-traditional loan portfolios are concentrated on balance sheet, what does that mean for capital and risk adjusted related issues associated with that? I think the good news is the rating agencies and our fixed income investors look primarily at our core cash related earnings and in particular the rating agencies and we show them capital allocation models on a managed student loan basis so that they are not segregating between on balance sheet and off balance sheet items. In effect the rating agencies say those securitizations are nothing more than secured financing transactions. Obviously to the extent that we are concentrated in a particular area, you know the risk falls just as proportionately to the unsecured debt holder and that is not what the plan was of course but that is the outcome as a result of the poor performance in this asset class, much poorer than we expected. The good news is we’ve identified that risk, curtailed future lending activities and we believe we are entering 2008 very, very strongly reserved against potential losses in that component. [Unknown Analyst]: [Inaudible question]

Jack Remondi

CFO

8% is not the right capital allocation associated with the non-traditional loans but when you typically look at this you would look at 8% against your net student loan portfolio which is how it’s allocated and that I believe would be appropriate. [Unknown Analyst]: The cost reduction guidance of 20% that you gave, is that off of the current expense [unintelligible] market expenses this year or some sort of lower base number the only 9% top one you mentioned?

Jack Remondi

CFO

We’re looking at 20% off of the $1.4 billion of operating expense. [Unknown Analyst]: Including the [unintelligible] expense.

Jack Remondi

CFO

Yes. [Unknown Analyst]: Thank you. [Unknown Analyst]: Just in terms of your plans on accessing the unsecured debt markets, LIBOR plus 250 is a way away from where your credit swaps are right now, so are you looking to do that in the back end of the year?

Jack Remondi

CFO

The question was, we had on our slide we would do a billion in the term unsecured debt market at a spread of LIBOR plus 250 and the question was, that’s certainly not reflective of where our credit default swaps are today and that is absolutely true, we’re probably more in the LIBOR plus 500 range with the new issuance premium. It is expected, that is targeted to happen in the fourth quarter of 2008. It’s more of a placeholder for us. If the markets stay where they are, it doesn’t make any sense for us to fund at LIBOR plus 500, you know that’s not, we would look stupid frankly if we did that. LIBOR plus 250 doesn’t frankly make a whole lot of sense either but as credit spreads start to tighten you have to start showing some liquidity in the marketplace and this is frankly what’s going on in our FFELP securitization strategy. If we are regular issuers each month we believe it attracts investors into the security because they see fresh prints, they see trading activity going on and we’ll adopt that similar strategy in unsecured if credit spreads get to those levels. [Unknown Analyst]: Thank you, you’ve mentioned on talking about the outlook for ’08 as in the first half a lot of work to do, cost reduction and then the second half, post that, can you give us a sense of your forecast of $1.70-$1.80, how does that [unintelligible] between the first half and the second half?

Jack Remondi

CFO

The question relates to how we expect, given our earnings per share guidance of $1.70-$1.80, how we expect to exit the year. Several positives of course, I mean our hope and expectations are that we’ll see a substantially better credit market in the second half of 2008 than what we have today and so funding spreads and profitability associated with new activity going on there will be better. The way our business works from a business cycle or seasonal cycle here, most of our loan origination activities are coming in the second half of the calendar year as students enter school in the September timeframe and so a lot of the improvements that we’ll see on the yield side of the equation and the asset quality performance side won’t be readily apparent in 2008. You’ll see those in future years. On the cost side of the equation, we expect the first half and on the provision side of the equation, we would expect the first half to be a whole lot less interesting or illustrative of our execution risk, our execution quality here and the back half is where you’re going to see exceptional performance against that, so we will be heavily weighted towards the back end of the year. [Unknown Analyst]: Hi, in the December guidance that was given obviously the loan loss provisioning was not that we took today was not part of that guidance and then we had the share capital issuance in December and our firm participated in that and I don’t think at the time we were led to believe that there would be this sort of loan loss provision and I understand the need to get the balance sheet clean, but could you give us some color on whether we had an inkling of an idea that we might need to do this cleanup or did something materially different develop adversely on those core profit loans that you talked about that have been costing 65% of the problem between the capital issuance in December and now.

Jack Remondi

CFO

There’s lots of issues that go on here but clearly the changing economic environment was a big driver. You also have to take into consideration the constraints of GAAP as it relates to loan loss provisioning activities. You know in an ideal world we would be able to establish, particularly on this kind, when we’re exiting a business, a life of loan reserve estimate associated with these loans, but unfortunately that’s not consistent with GAAP. We need to take a look at what kinds of events are occurring on the portfolio and whether those events are triggering likely loss exposure on those loans and in 2007 the economic environment, the deterioration in the economic environment, the deterioration in the economy, allowed us to make that case and recognize those losses earlier than we would have otherwise. In our old model, those losses would have been recognized still, they just would have been recognized further our in future years rather than in 2007. I think if I haven’t conveyed this message I’d like to do it now, it’s not that we expect these loss rates, we adjusted these loss rates in early 2007 and it’s not that we expect these loss rates to be materially higher as a result of this provision taken in the fourth quarter, it’s just that the evidence of that loss exposure is more clear today than it was under our old methodology. [Unknown Analyst]: You had a slide up on the screen about college enrollments going up and given how unprofitable FFELP lending has become, we’ve read stories of people pulling out of this space and private lending becoming clearly more risky, how do you expect those enrollment numbers will come to fruition, who’s going to make the funding gap for students and will that become possibly an issue back half when funding [unintelligible] this spring?

Jack Remondi

CFO

First, I would not say that FFELP lending is going to become unattractive going forward. We just have to make sure we are pricing that product right in the forms of discounts we applied or make available to students in the past and the operating cost environment. We fully expect that the loans we will be originating going forward will produce very healthy risk adjusted returns, primarily because little capital is needed against these student loan assets. That’s kind of one piece. There are however going to be FFELP lenders who will exit the business in 2008 and beyond and they’re going to exit the business because they don’t have the scale to operate efficiently the way Sallie Mae does and more importantly they will not have access to the capital markets the way a company like Sallie Mae does and those two factors, we’ve already seen it, has had people exiting the business, there’s virtually no one making loans in what was the direct to consumer consolidation space, that’s all be re-trenched and we will expect to see a lot of those players move further off of that space. On the private credit side of the equation, the portfolio’s a tale of two cities, right I mean you’ve got this non-traditional lending that has very high default exposure associated with it because the kids don’t graduate at the rates they need to. On the traditional side of the equation, these schools turn out graduates year after year on a consistent basis. They get an economic benefit from the education and the amount of money they borrowed to pay for that education. You know there may be difficult times in the economy where job prospects are lower, but over the life of that loan, the collectability of that asset is…

Al Lord

Chairman

The short answer is very, very little, I mean there’s some back end, you can charge collection fees associated with delinquent accounts but very small and we already frankly do that already. Our job is going to be to demonstrate to Washington that they cut too far and there is going to be an access issue for some types of borrowers and some types of lenders who just can’t compete in this space and they’re hearing that story today, they’re hearing it from lenders, obviously. They’re hearing it from schools as well which is more important. [Unknown Analyst]: And just a follow up. You talked about the non-traditional schools and how unfortunate the credit performance is there, is FFELP lending attractive at non-traditional schools or will it be necessary to step back, even on the FFELP front from some of those schools.

Al Lord

Chairman

Whereas it’s clear cut on the private credit side, there’s a little bit of grey area on the FFELP side. But look the bottom line here is if we’re lending money and earning a 60 basis points reduced yield from what you saw in there during the in school period and that borrower leaves school early, goes through a six month grace period and defaults, there’s very little any kind of credit spread environment where that’s an attractive asset today. [Unknown Analyst]: Thank you.

Al Lord

Chairman

Operator, we’ll take some questions from those on the phone.

Operator

Operator

Your first question comes from the line of Matt Snowling with FBR Capital Markets. Matt Snowling – FBR Capital Markets: Yeah, hi guys, I was just wondering beyond the moves you’re making in the non-traditional schools, are you able or are you at a point now that you can start raising pricing on some of the other private loans?

Al Lord

Chairman

Yes, we believe that for a combination of reasons the credit spread environment but probably more importantly the competitive landscape and the availability of capital to support competitors in the private credit space will be limited and we will have pricing power capability there. Matt Snowling – FBR Capital Markets: To the extent you could offset your prior funding costs?

Al Lord

Chairman

Well, as a business person, I would never say you should take a look at the current spread environment which I think almost everyone in this room would say is temporary, some might say it might get worse before it gets better, but it’s hopefully temporary, and we should never price a long term business relationship off of short term credit spread environment, we need to take a look at what we think the spreads will be over the long term. We know they’re not going back to 25 anytime soon that I showed you earlier but I don’t expect them to be in the 100 plus range that we’re seeing today either. Matt Snowling – FBR Capital Markets: Okay, one quick question, it looks like you have about $1.1 billion of purchase mortgage paper on balance sheet, are you seeing any sort of deterioration in the collection rate on that?

Jack Remondi

CFO

The performance in that portfolio collection was actually very strong in the fourth quarter and we do every quarter end a detailed valuation analysis of those loans. At year end in fact we hired an outside firm to do that for us and our valuation that came back was well within the range of what we’re carrying those assets at today. That is an attractive business, what’s happened with it is the collection process has become a little bit more elongated as you would typically see work outs arranged when you dealt with these troubled mortgage assets and now more of it turns into REO. Matt Snowling – FBR Capital Markets: Well how much of that paper was purchased in 2006?

Jack Remondi

CFO

That, I don’t have the answer, we’ll have to get you that offline. Matt Snowling – FBR Capital Markets: Okay, thanks.

Operator

Operator

Your next question comes from the line of Cyril Battini with Credit Suisse. Cyril Battini – Credit Suisse: Yes, hi, thank you for the conference but my first question is just to get, what’s the size of your balance sheet and IO strip exposure to the non-traditional portfolio and what’s your loss assumption from this asset class?

Jack Remondi

CFO

Excellent question, thank you. As I mentioned earlier, we don’t securitize, we securitize very little of our non-traditional portfolio so although we took a large core cash provision associated with these loans in the fourth quarter and during the course of the year of 2007, the GAAP provision was substantially smaller because these loans are not in the asset backed trust, the IO or the residual which first of all does carry a life of loan default expectation assumption in it, was no materially impacted at quarter end. Cyril Battini – Credit Suisse: So what was the balance sheet size of the exposure to non-traditional assets?

Al Lord

Chairman

I think the non-traditional loans and most of these are just more of the schools than they are the lower tier credit from the trust, is probably on average around 5% of the portfolio, maybe a little bit higher. 15% was the right number there, but that’s a school type not a non-traditional. We’re mixing pieces here, we’ll have to get back to you with exact percentage on the non-traditional component. And the reason this is important is as I said, there are for-profit schools that are very attractive businesses that generate college degrees, generate graduates with college degrees that have very good earnings and credit profile, so the largest for-profit university in the country is a good example of that. We’re not saying for-profits are a segment we’re exiting, we’re exiting those schools within both the for-profit as well as the non-profit that don’t generate graduates. Cyril Battini – Credit Suisse: Okay and the other income line in your core earnings schedule, what does that include?

Jack Remondi

CFO

In the other category is the business lines that are not in our segment reporting, so things like our guarantor servicing related activities and our late fees associated with both our Federal and private portfolios. Those are the principle drivers. Also in 2006 the acquisition of UPromise comes into that component as well. That’s probably what’s driving the significant increase in ’07 versus ’06 is UPromise came in the fourth quarter I believe of 2006. Cyril Battini – Credit Suisse: Okay thank you very much.

Operator

Operator

Once again, ladies and gentlemen, if you would like to ask a question, please press star one on your telephone keypad. Your next question comes from the line of Don Jones with Credit Suisse. Don Jones – Credit Suisse: Good morning and thanks for hosting this call. A couple questions on the liquidity side. The sources of liquidity seem to include the remaining balance of that ABC [unintelligible] facility through a couple of banks. What sources are you looking to use possibly to replace that and or to the effect of replacing that facility, how successful are you getting in negotiating similar forward levels in terms of committing assets? Are your counter parties accepting the collateral that’s currently in that asset back commercial paper facility or are you looking to commit additional assets?

Al Lord

Chairman

Well the existing $6 billion asset backed program has fixed terms and criteria associated with it and those don’t change during the life of that transaction. As we are developing our funding plan to replace the $26 billion in outstandings under the interim financing vehicle associated with the [audio interrupt] transaction, that is going to be an asset backed conduit vehicle. There will be two separate vehicles, one for Federal loans, one for private. Advance rates and funding levels, et cetera, are the types of things that get negotiated here and this kind of credit environment, credit departments look not only at pricing fees and interest rates but also advance rates. There’s nothing kind of worse that’s happened to the asset backed world than the complete collapse of the super senior tranches that were marketed so heavily over the last couple of years. People believed these things had virtually no credit risk and of course they do. And so credit departments today are, you told me this had no credit risk and so I don’t believe you now, but now you’re coming to me with a FFELP student loan asset backed transaction and you’re telling me there’s no credit risk, why should I believe you this time when I made a mistake and believed you last time? It’s those kind of discussions and issues that are going on frankly and the environment that we’re in, no one is standing up to be a hero. That’s why this pricing is going to be very expensive for us. The answer of course is to do it in a short term or shorter term facility at 364 day facility so that we can recover for this as we move our business forward in 2009 and beyond. Don Jones – Credit Suisse: Okay, secondly on your cash position, it looks like it has gone up quite a bit year over year, how much of that $7.5 billion in your funding would you actually say, given it’s about $5 billion more than it was a year earlier period, how much of that would you say is part of your funding strategy going forward, because you can’t obviously draw down on all of that, but what would you [overlay].

Al Lord

Chairman

That’s correct, I mean look in this environment, liquidity is kind and we are conducting a funding plan in 2008 that doesn’t say, we have just enough liquidity to make our plans work, we want to demonstrate in size facilities that say we have more than enough liquidity to make things work and if something doesn’t happen, a term ABS transaction can’t take place, there’s enough in the plan to absorb that and deal with it. In addition, we have a significant number of steps that we can take that would reduce our funding even further in 2008 and those again are another form of kind of reserve if you will in the liquidity equation to make sure that we maintain adequate cash balances, adequate credit line availability. So for example in 2008 we would expect the cash balance position to hold relatively constant during the course of the year. And the $6.5 billion of uncommitted lines that we have with banks will remain undrawn during the course of the year so that will always be there as sort of standby liquidity. Don Jones – Credit Suisse: Okay and lastly, how much traction would you say, I mean you can just characterize without giving specific, how much traction are you getting with rating agencies? It seems like they all have credit watch negative on the ratings and S&P actually gave a time line from December 14 when they did the report, about 45 days they were going to meet with you guys and so on, I mean are you getting positive traction with the three agencies or how would you [overlay].

Al Lord

Chairman

We are just going to have our first, we’ve obviously been in regular almost daily contact with them to update them as to what we’re doing, particularly on the liquidity side of the equation. On the private credit reserves that we took, that’s all been discussed and reviewed with them, but over the next couple of days we’re going to spend much more significant time with them, walking them through our business strategy and funding plans, then we’ll see what comes out. Remember though the ratings actions that are still outstanding on the company do reflect the merger transaction, the buyout transaction that was on the table. Now, we’re under no allusion that we’re ready [packed] with single A anytime soon here and we need to re-earn that letter. We’re just committed to getting there. Don Jones – Credit Suisse: Great, thank you.

Operator

Operator

And there are no further questions at this time sir.

Al Lord

Chairman

Great, I think we have time for maybe one or two questions here in the room if there are some, in the back there. [Unknown Analyst]: How much of a facility is flowing through the income statement for the $25 billion plus in financing in ’08 and how do you see that shrinking as we go into ’09?

Jack Remondi

CFO

Unfortunately it won’t be shrinking going into ’09 because the replacement facility that will take that deal out will be more expensive than the interim facility is today. I mean that deal was priced in March-April timeframe when credit spreads were at all time lows. There’s about $44 million running through that line item in 2007 for the fees, it’s a one year transaction so basically all amortized during the course of the year. But it’s going to be more expensive, the replacement is going to be more expense. No one’s doing deals like they did in July and earlier. And you’re seeing that in our earnings forecast. That’s fully accounted for. And I’m sorry in 2009 you were saying going forward. Well again that will be a function of what the credit environments look like at the end of 2008 as we get ready to replace this and we do expect to do that with term financing predominately and there will be some carryover in the short term market but very little expense will show up in ’09 as a result of what we do in ’08. [Unknown Analyst]: Jack can you talk about some of the other sort of for lack of a better way of saying it, ancillary opportunities that you might have to leverage Sallie Mae’s platform potentially doing servicing for other lenders?

Jack Remondi

CFO

Sure, we think that’s a significant opportunity for us but in the current credit markets that we’re in, those players that would want to take advantage of that are having difficulty funding themselves and so once those markets return, we would expect to be able to do that. Now in an event that liquidity in the Federal student loan business becomes an issue, we do expect and have made clear that Sallie Mae stands ready to lend operational support to the Department of Education or other entities that need it to make sure that students get loans in 2008. [Unknown Analyst]: Thank you. [Unknown Analyst]: Jack, I wonder if you can take us out to after this transition year, when the dust settles, we’ve sort of worked in the implications that the legislative changes, we’ve gotten past this dislocated credit environment. How do you see the industry shaping out, how do you see Sallie Mae’s position and you know you talked about having a greater focus on the private loan side, you know the private loans become 20%-25% of managed receivables going forward, when you look at your FFELP business you predominately relied on the school channel. Is the school channel still a competitive advantage? You talked about 140 basis points forecast spread in 2008, that’s going to rebound hopefully when financing costs stabilize but do we get back to 180 basis points which used to be the normalized? So just give us a view of where you see things going with a slightly longer term outlook. Thank you.

Jack Remondi

CFO

We see, I mean the business strategies that I’ve outline as how we plan to compete in the FFELP student loan marketplace and the private credit student loan marketplace, we think in a 2009 environment we’ll generate very attractive risk adjust returns. We think the advantages that we bring to that space are numerous, our operating structure is already today if not the most efficient, probably number two in the industry overall but I think its number one. And we’re going to make it more efficient going forward. Our funding capacity and capabilities are going to be far greater than anyone else out there. Frankly in 2006 and 2007 you get these newly created loan consolidation shops that had an 18 month life cycle history, were issuing ABS transactions that might have been 5 wide as Sallie Mae and it’s a disturbing trend, how can that possibly be true, someone with a 35 history doesn’t get more credit than that in that credit environment. We think that’s going to be far more reflected in spreads for competitors in future years. And on the private credit side of the equation, Sallie Mae is unique in how we manage this portfolio. We manage it as a credit exposure portfolio. Virtually everyone else in this space manages it in connection with their FFELP student loan assets and as a result collection activities and performance tend to be compliance focused versus collection focused. We think those advantages are very strong, our school relationships will continue to allow us to capture market share at those institutions and be viewed frankly as one of the strong entities that stood up and performed during adverse times. [Unknown Analyst]: I’ve got two questions. One, can you give us at least some color on what kind of financing costs the $26 billion facility is baked into your $1.70-$1.80 guidance and I have a follow up.

Jack Remondi

CFO

It’s a rapidly moving target to some extent but it is you know the numbers right up until 8 o’clock this morning are fully reflected in there is probably the best guidance I can give you. We don’t believe we’re missing where the deal will ultimately price in that financial forecast. Once the deal closes we’ll be able to provide you with a little bit more guidance as to what exactly it cost. [Unknown Analyst]: Alright, my longer term question which hopefully you can give us a good answer for is a key to your future is going to be the private credit business and as I think both Al and Tony mentioned, an important part of that is developing a credit culture to be able to do that well and to forecast where the good schools are and so on. Can you give us a better feeling for how you’re going to make that big cultural change at this organization?

Jack Remondi

CFO

Well, I think it’s begun already, its already happened. I mean the business in the last couple of years was focused more on volume, less on quality. That has already changed. It was changing, the process of changing began in 2007 and we’ve accelerated it in 2008 with the termination of some of those schools that Al referred to. It’s moving forward. Everyone is 100% on top of this, it is not a sales driven process, it’s a financial return driven process. And the numbers are here, it’s not one that one can argue with, it’s just gee we think these loans are going to default at only X percent, no, they’re defaulting at much higher levels than that and it’s no longer a guess based on relationships to FFELP, to more traditional schools, it’s based on actual experience.

Tony Terracciano

Chairman

As Jack said, the process has already begun. You’ve probably seen a fair number of senior executives at the company, some have left and some are in the process of leaving and frankly they are people whose entire career were devoted and were incredibly in many cases, incredibly good folks, who were dedicated to generating FFELP volume. Obviously, one of the parts of the culture that has to change is that FFELP volume was unilaterally profitable, we made loans, we bought loans, we bought loans retail, we bought them wholesale and we processed them. We’re still good at processing, just less balance sheet than we had before. But the issue is in the end is an execution issue and we’ve got to execute this plan and the heart and soul of it in my view is going to be a change in specific people and then change in approach from everybody else and the precise steps that need to be taken, little difficult to enumerate now, but it is very much underway. And the cost cutting that we’re talking about is going to be, I think a word that comes to mind is wrenching, we’re talking about 20%.

Jack Remondi

CFO

I think that allocates the time, it takes up all the time we allocated. Thank you all very much for coming, we appreciate your interest, look forward to working with you going forward.

Operator

Operator

Ladies and gentlemen, this concludes today’s conference call, you may now disconnect.