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Wells Fargo and Company Responsible Lending Principles for Education Financing

Wells Fargo through its Education Financial Services division (hereinafter "Wells Fargo") has a history since 1968 of providing high quality educational loan products and customer services. We are proud of the millions of customers that we have helped achieve their dream of higher education over the years. We are proud of the many benefits our products provide and will continue to present ourselves to schools as an industry leader in sound and ethical business practices, including fair and responsible lending. We also believe in attracting customers through the quality of our products and services, and in conducting our business in a way that complies with the letter and spirit of the law. To that end, we have adopted the Responsible Lending Principles for Education Financing below.

Wells Fargo Responsible Lending Principles for Education Financing
Wells Fargo’s vision is to satisfy all our customers’ financial needs, help them succeed financially, be the premier provider of education financing solutions for our customers—students and families—and be known as one of America’s great companies. In the context of making education loans to customers, this means helping as many people as possible achieve their educational dreams.

What does this mean in the context of education financing?

  • Offering attractive financing solutions to our customers to assist them in achieving their education dreams
  • Focusing on establishing and maintaining long-term relationships with our customers
  • Providing world-class customer service
  • Complying with the provisions of the Higher Education Act, the Truth in Lending Act, and all applicable consumer lending laws, including intolerance of abusive, misleading, or fraudulent lending practices in our operations

In addition, Wells Fargo also has adopted a set of affirmative responsible lending principles designed to help us fulfill our vision. The specific components of Wells Fargo’s Responsible Lending Principles for Education Financing are detailed below.

  • Informed Choices

    Through www.wellsfargo.com/student, we make available to customers the necessary information to allow them to make informed decisions about the terms of their loans. Customers receive full disclosures about loan options and costs. We will also disclose to customers any agreement between Wells Fargo and any unaffiliated entity to sell loans if the sale will result in Wells Fargo no longer servicing such loan.

    Because final decision making is the customer’s responsibility, we encourage customers to use Wells Fargo’s financial literacy program, Hands on Banking® and El futuro en tus manos®. Available online at www.handsonbanking.org, the program helps all age groups—kids, teens, young adults, and adults—learn the money skills they need for life.

  • Benefit for the Customer
    We offer our customers attractive financing solutions, which include competitive interest rates and other incentives. We will use our best efforts to ensure that all benefits offered during origination of a loan continue in effect, even if the loan is purchased, transferred, sold or if the servicer is changed (e.g., we will use our best efforts to contractually require the purchasers of loans to honor such benefits).

  • The Right Student Loan and Responsible Borrowing
    We promote choice and competition in the marketplace as evidenced by our investment in ELM Resources, a non-profit organization that provides open participation and competition in the student loan industry.

    Wells Fargo agrees that customers should consider all education financing options available to them, including "free money" such as scholarships, federal Work-Study programs, federal student loans, and private student loans. We also recommend that customers understand all of their borrowing options in order to make decisions that match their needs at the best available price. In support of this, we provide customers information on finding scholarships, choosing federal or private loans, options for budgeting and repayment and direction to borrow only what they need to finance their education through www.wellsfargo.com/student.

  • Customer Service
    We strive to provide superior customer service to customers. We want our customers to have a positive experience with Wells Fargo, whether it's in a phone call, face to face in a Wells Fargo banking store, via an online exchange or through correspondence.

    We will proactively contact our customers who may be experiencing repayment difficulties, and we will work with them to seek options to successfully repay their loans.

    Furthermore, we take all customer complaints very seriously. We have longstanding policies and processes for providing customers with timely responses when they have complaints. We carefully and promptly research complaints, and if we have erred, we do what is right for the customer.

  • Product Options
    We offer financing solutions which include private education loans for undergraduate and graduate students; loans for students enrolled full-time, half-time, or part-time; loans for parents to help pay tuition for their students.

Wells Fargo Student Loan Marketing Practices
Wells Fargo recognizes the role that the financial aid offices of the institutions of higher education play in helping students determine the right financing package. We affirm that we follow the practices cited below in conducting our education finance business. These practices are intended to apply to our dealings with all of the institutions of higher education with which we do business, as well as their employees and other representatives (hereinafter referred to as the "school" or "schools").

Prohibition on Revenue Sharing Agreements
Wells Fargo will not enter into agreements with schools to share revenue or profit on its loans or to convey other material financial benefits to the schools in connection with its student lending business.

Prohibition on Use of Opportunity Loans
Wells Fargo will not arrange or agree with any school to provide so-called "opportunity loans."

Prohibition on Referral Fees

Wells Fargo will not give items of value to students or employees of schools or school-related organizations, in exchange for referring students to apply for our education loans.

Items of Value
Wells Fargo will not give items of any value to any school, nor any officer, employee or agent of the school, in exchange for special considerations given to us by the school.
Examples include:

- Gifts
Revenue sharing agreements
- Cash
Providing computer hardware
- Meals & Entertainment
or software at below market cost
- Charitable Donations
Providing printing services
- Stock options
Consulting fees
- Scholarships
Travel & Lodging

Wells Fargo will allow gifts of items of de minimis value that promote our product and foster name brand recognition. Similarly, this gift restriction does not apply to standard informational material related to our product or to promote financial literacy, nor to food, refreshments or informational materials provided at reasonable cost in connection with permissible training of school staff.

Prohibition on Co-Branding

Wells Fargo will not enter into agreements for the right to use the name, emblem, mascot, or logo of a school in the marketing of our education loans in any way that implies that the school endorses our education loans.

Limitations on Lender Advisory Councils
Wells Fargo believes that school financial aid professionals provide valuable market insights which help us improve our products, service and marketing techniques. We will continue to periodically meet with schools to solicit their insights, but schools will not be compensated for their advice. Wells Fargo will not solicit a school to serve on an advisory council and will not offer compensation for such service or reimbursement for lodging or travel.

Prohibition on Personal Entrance Counseling

Wells Fargo will not participate in personal entrance counseling. We will continue to provide general debt counseling, private student loan exit counseling and financial literacy education for students. When participating in on-campus financial literacy activities, we will identify ourselves as Wells Fargo representatives to students and not as representatives of the schools.

Limitations on Personal Exit Counseling
Wells Fargo believes in helping students succeed financially and will help financial aid offices design and deliver customized public exit counseling sessions appropriate for their students. Focusing only on private student loans, these sessions must be authorized and controlled by the financial aid office. Sessions will be offered to both Wells Fargo customers and non-customers. When participating in such sessions, we will identify ourselves as Wells Fargo representatives to students and not as representatives of the schools.

Limitations on Staffing of Financial Aid Offices
Wells Fargo will not provide staff to financial aid offices, assist with call center or financial aid office staffing, or otherwise perform or pay for any school-required function. However, we may assist with professional development training for financial aid administrators.

"School as Lender" Programs
Wells Fargo will not enter into "school as lender" programs.

Disclosure at the Request of Schools
Upon the request of any school, Wells Fargo will provide the school the historical rates of default incurred and range of interest rates charged to that school’s students.

These Responsible Lending Principles and Marketing Practices are intended as Wells Fargo’s global policy for U.S. educational loans. Application of these Principles and Practices may be more restrictive based on individual state laws and may be amended based on changes to existing law.

Last Updated November 26, 2010.

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