FOIA PRODUCTION US Department of Education On PSLF 1 PDF

OBTAINED BY STUDENT BORROWER PROTECTION CENTER AND AMERICAN FEDERATION OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
rb)(5)
From:
To; I ,ongm,Ico Rene
Cc: ~
Subject: FW: American PublicTransportation Assoc1at1on
Date: Monday, November 21, 2016 9:48:23 AM
H1 Rene,
(b)(5)
Thar1ks,
Taneka
From: l(b)(5J D
Sent: Friday, September 09, 2016 1:54 PM
To: Fedloan PSLF """"===,
Cc: Battle, Cynthia;U(b)(5J I7 I
Subject: Re: American Public Transportation Association
Hi Kim,
We also need to forward American Public Transportation Association to OGCfor review. We

will keep you posted.
Thanks,
Taneka
From: .((b-1(-51==="--'
Sent: Thursday, September 1, 2016 8·12·21 AM
To: Fedloan PSLF
Cc: Battle, Cynthia;Wb)(5J ITiongquico, Rene
Subject: RE, American Public Transportation Association
Hi Kirn,
WP. will st;irt our rP.VIP.V,'
I also wanted to update you and let you know that we are meeting internally on the pending
employer escalalion'> arid ':.hould have an updale lo you nexl week.
Thanks,
Taneka
From: Kimberly A Myers [mailto:[email protected]] On Behalf Of Fedloan PSLF

Sel'lt· WedoesdeLJ'August 31, 2016 8:36 AM
To:l'/ib)(5)
Subject: American Public Transportation Association
Hi Tanekal This one is a borrower dispute, so we are forwarding for review.
We originally received the borrower's ECF in May. They certified private not-for-profit performing
emergency management, public safety, public service for individuals with disabilities and public service
for the elderly.
This organization is 501 (c)(6), so they are not-for-profit. After reviewing the services provided, we
determined they advocate for the advancement of public transportation programs and initiatives. Based
on this, we denied, as they do not perform a qualifying public service.
The borrower is now disputing and provided a letter and additional information outlining why they believe
the organization qualifies. We still do not believe the organization provides a qualifying public service. As
always, your input is appreciated.
Password is the same as the previous employer I forwarded over. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
This message contains privileged and confidential information intended for the above
addressees only. If you receive this message in eITor please delete or destroy this message
and/or attachments.
The sender of this message will fully cooperate in the civil and criminal prosecution of any
individual engaging in the unauthorized use of this message.
Code:PHEAA
From: Wast1ington Aaron

To; Tiqngquico Rene
Subject: FW: Quick question on PSLF
Date: Friday, October 21, 2016 11 :02:02 AM
Call me when you can to discuss.
From: Arnold, Nathan

Sent: Friday, October 21, 201611:00 AM
To: Washington, Aaron; Hoblitzell, Barbara
Subject: RE: Quick question on PSLF
Hey Aaron,
b)(5)
Let me know if I'm just confusing things or if I can be of further help
Nathan
From: Washington, Aaron

Sent: Friday, October 21, 2016 9:00 AM
To: Arnold, Nathan; Hoblitzell, Barbara
I Icy Nathan and Barbara-got a question from Peace Corps-hov,.,i docs this draft response sound?
Only µaymenls made on a qualifying direcl consolidal1on loan counl Lowards PSLF Therefore ii lhe
voluntf'er l.'J,1ntsto consolidatnJ thf' nf'wly acqu1rf'd loans into his alrf',1dy f'Xisting dirnt
consolidation loan (that he has been making qualifying PSLFpayments on) he would have to start
PSLFover a O payments Of course, the type of new loans he tries to consolidate will impact eligibility
for PSLF, and because I don'L know Lhe '>µecilic, of his case, I recommend he call'> his Federal loar1
servicer to chat with them ,1bout his options.
From: Edmondson, Samantha [mailto:[email protected]]

Sent: Wednesday, October 19, 2016 3:45 PM
To: Arnold, Nathan; Washington, Aaron
Subject: Quick question on PSLF
Hi Nathan & Aaron,
I just received the following question from a Volunteer and wanted to see if either of you could offer
some clarification for me before I responded.
If a Peace Corps Volunteer returns to School after Peace Corps and accrues more student loans, will
they need to make another 120 qualifying payments for the newly accrued loans after they graduate
or will the qualifying payments made as a volunteer count towards the total 120?
Any insight would be greatly appreciated!
All my best,
Samantha
From:
To; l1lwllr!
Cc: Battle Cynthia: Tiongquico Rene: Chialastri Taneka
Subject: Fw: Re: PSLF- American Bar Assoc1at1on
Date: Friday, October 07, 2016 10:04:38 AM
Attachments: ECF Redacted.pd1
Denial Letter redacted.docx
Hi Jon,
(b)(5)
Thanks,
Taneka
From: Kimberly A Myers <[email protected]>

Sent: Wednesday, April 13, 2016 8.34 AM
To: Foss, Ian
Cc: Diane Freundel; Chialastri, Taneka
Subject: Re Re: PSLF- American Bar Association
Hi Ian! Attached is a redacted copy of the ECF and corresponding retraction letter to the borrower.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From '"Foss. Ian'" <[email protected]>
To Kimberly A Myers <[email protected]>
C~ Diane Freundel <[email protected]>, "Chialastn. Taneka" <[email protected]>
C~llc 04113/2016 08:42 AM
SL,,;.ecl [external]Re. PSLF - American Bar Association
This is very helpful. Thank you!
One last request (for now).

(b)(5)
On Apr 11, 2016, at 15:45, Kimberly A Myers <[email protected]> wrote:
Hi Ian!
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From '"Foss. Ian" <Ian [email protected]>
To "'Kimberly A Myers"' <kmyers@pheaa org>
C~ Diane Freundel <[email protected]>, '"Chialastn. Taneka"' <[email protected]>
C~llc 04108/2016 02:56 PM
SL,,;.ecl [external]RE: RE. PSLF -American Bar Association
(b)(5)
From: Kimberly A Myers [mailto:kmyers@J;Jheaa.org]

Sent: Friday, April 08, 2016 2:12 PM
To: Foss, Ian
Subject: Re: RE: PSLF - American Bar Association
(b)(5)
Thanks!
Kimberly A Myers
Compliance Services
kmyers@J;Jheaa.onJ
(717) 720-2630
From '"Chralastri, Taneka"' <Taneka Chralastrr@ed gov>

To "Foss, Ian·' <Ian [email protected]>. Diane Freundel <dfreunde@pheaa org>. "'Kimberly A Myers"· <[email protected]>
Dc1l~ 04/08/2016 12:02 PM
Si,,; ,xt [external]RE: PSLF - American Bar Association
(b)(5)
TanekJ
From: Foss, Ian

Sent: Friday, April 08, 2016 11 :55 AM
To: Chialastri, Taneka; Diane Freundel; 'Kimberly A Myers'
Subject: PSLF - American Bar Association
Hello all,
b)(5)
Thanks,
addressees only. If you receive this message in error please delete or destroy this message
and/or attachments.
Code:PHEAA
From: l(b)(5)
To; Tiqngquico Rene: Battle Cynthia
Cc: Chialastri Taneka
Subject: Fw: RE: Students First
Date: Friday, August 12. 2016 12:44:29 PM
Attachments: Retraction Letter.doc
b)(5)
From: Kimberly A Myers <[email protected]> on behalf of Fed Loan PSLF

<Fed Loan [email protected]>
Sent: Tuesday, August 9, 2016 2.27 PM
To{bl(51 I
Cc: Battle, Cynthia; Fed Loan PSLF,Tiongquico, Rene
Subject: Re, RE· Students First
Hi Tanekal I reached out to the Business Unit to pull the data for me. Once I receive the query back I will
forward it over to you. In the interim, I wanted to forward the retraction letter that was sent to Ms. Korkes.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
b)(5)
From
fo Fedloan PSLF <[email protected]>

l(b)(5) f.
"Battle, Cynthia"' <[email protected]>, "Tiongquico, Rene"
<[email protected]>
Dc1l~ 08/08/2016 04:08 PM
SL,8_cct [external]RE: Students First
(b)(5)
Th;rnks,
TanekJ
From: Kimberly A Myers (mailto:[email protected]] On Behalf Of Fedloan PSLF

Sent: Thursday
To: rb)(5)
,Jtt
14, 2016 11 :48 AM
Subject: Students First
Hi Taneka! This one is a little complicated.
(b)(5)
Since we now have a dispute, we want to ensure you agree that this employer would not qualify for PSLF
purposes.
Password to follow. Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: Foss Ian

To; Tiqngquico Rene
Subject: Fwd: Public Service Loan Forgiveness Program inquiry
Date: Thursday, September 01, 2016 9:45:27 AM
Can you look at this?
We previously approved a NY corporation that was established for the sole purpose of
employing medical and dental residents.
We have also previously approved non-501(c)(3)s as (c)(s) when they are wholly owned
"disregarded entities" of (c)(3)s.
Begin forwarded message:
From: "Gold, Stephanie J." <[email protected]>

Date: September 1, 2016 at 09:30:10 EDT
To: "Ian,[email protected]" <Ian,[email protected]>
Subject: Public Service Loan Forgiveness Program inquiry
Mr. Foss,
I am writing regarding the Public Service Loan Forgiveness Program ("PSLF Program").
know you recently gave a presentation on the Program at the NASFAAAnnual
Conference. Please let me know, though, if I should direct my question to someone
else at the Department.
We would like to confirm that an employer of medical residents and doctors would be
a qualifying employer for purposes of the PSLFProgram where the employer's sole
member is tax-exempt under section 501(c)(3) of the Internal Revenue Code ("IRC").
As explained below, we believe that in such a circumstance the employer is a qualifying
employer because it is a so-called "disregarded" entity that is effectively a nonprofit,
501(c)(3) tax-exempt organization.
Specifically, the employer of the medical residents and doctors would be a limited
liability company whose sole member is a nonprofit, 501(c)(3) tax-exempt
organization. Under applicable federal tax law (as well as various state and local tax
laws), when a 501(c)(3) tax-exempt organization is the "sole member" of a limited
liability company, then such single member limited liability company (11SMLLC11 ) is
"disregarded" by the IRSfor tax purposes and is treated as an internal branch, division,
program or activity of its 501(c)(3) member. See Treasury Regulation Section
301.7701-2(c)(2)(i). While there can be different reasons for choosing the SMLLC
format, a 501(c)(3) tax-exempt organization typically will choose to have a SMLLC
conduct functions that it could conduct itself -- here, employ health care providers who
perform services at a particular state owned and operated hospital -- In order to limit
its liability exposure. This liability limitation is particularly attractive because the IRS
views the SMLLC as effectively part of its 501(c}(3} tax-exempt member. See Treasury
Regulation Section 301.7701-2{a) nIJf the entity is disregarded, its activities are
treated in the same manner as a sole propr1etorsh1p, branch, or division of the
owner."). Indeed, a 501(c)(3) tax-exempt organization that wholly owns a disregarded
entity must treat the operations and finances of such disregarded entity as its own for
tax and information reporting purposes. See IRSAnnouncement 99-102, 1999-2 C.B.
545. To such end, when an employee of a disregarded SMLLC completes IRS Form W-9
(Le.,_,the form an employer uses for payroll purposes, such as to prepare employee
paychecks and W-2 forms at the end of the year}, the IRSexpressly requires the
employee to reference the limited liability company's sole member (such as its 501(c)
(3) tax-exempt member), and not the limited liability company itself. Moreover, just
this past month, the IRS,through its Office of Chief Counsel, issued advice in the
employee benefits context that confirms that employees of a disregarded SMLLC are
employees of the 501(c)(3} member for employee benefits plan purposes. See Chief
Counsel Advice ILM 201634021, dated July 11, 2016 & released August 19, 2016. The
IRS has also been clear that, for purposes of entitling donors to a charitable
contribution deduction, a donor's contribution to a SMLLC that is wholly owned and
controlled by a 501(c)(3) tax-exempt organization is to be treated as a charitable
contribution to such 501(c){3) tax-exempt organization. ~ IRS Notice 2012-52.
Finally, although not necessary for IRSpurposes, the governing document of the
SMLCC at issue here sets forth the standard language normally seen in the
organizational documents of nonprofit, Section 501(c)(3) tax-exempt organizations,
~, its purpose is to operate exclusively for charitable, sc1entif1cand educational
purposes, it is not to operate for pecuniary profit or financial gain, and it is to act
exclusively as an instrumentality of its 501(c}(3) tax-exempt member.
Given that the PSLFProgram, in effect, looks to the IRSas to its determination of
whether an employer is a Section 501(c){3) tax-exempt organization for purposes of
the PLSFProgram -- and that the IRStreats a disregarded SMLLC as an internal branch,
division, program or activity of the Section 501(c)(3) organization that serves as the
sole member of such a SMLLC-- we would appreciate the Departmenfs confirmation
that under the PSLFProgram a disregarded SMLLC such as the one described above
would be viewed as a 501(c)(3} tax-exempt organization that is a "qualifying employer"
under the Program.
Thank you for your consideration.
Stephanie
Stephanie Gold
P.inier
Hogan Lovells US LLP
C::ilulllb1a SqL.arc
757 Th1,tr)1;nll1 Strcc:. NW
Wash1n(_ron DC 20004
Tel -1 202 637 5600

ll1rcct -1 ?O? 637 5496
F,ix -12(l2fi'.l7591(l
Email [email protected]
Bloq www.hldataprotection.com/
www .ho"anlovelb.com
!-'lease consm'cr //10 cnvrromncnt before pm1t111pth:s c ma.'i
About Hogan Lovells

Hogan Lovells is an international legal practice that includes Hogan Lovells US LLP and Hogan Lovells
International LLP. For more information, see www hoganlovells.com.
CONFIDENTIALITY. This email and any attachments are coniidential. except where the email states it can
be disclosed; it may also be privileged. If received in error, please do not disclose the contents to anyone,
but notify the sender by return email and delete this email (and any attachments) from your system.
From: Chialastri Taneka

To; Tiqngquico Rene
Subject: 1"11be 5 minutes late
Date: Tuesday, October 25, 2016 2:58:01 PM
Attachments: 1maqe001 ono
I'm in another meeting n1be about 5 minutes late.
Thanks,
Taneka
Taneka Chialastri I Management and Program Analyst, Bu~ine~s Operation~ I Federal Student Aid
830 Fir~t Street NE, Wc1~h1ngton, DC 20202
Office: 202-377-4390 I taneka chialastri@ed 1;ov
From: Foss Ian

To; Tiqngquico Rene
Subject: PSLF- AARP
Date: Wednesday, January 04, 2017 2:14:56 PM
Hey Rene,
I gather that we dealt with a PSLF employer escalation regarding AARP while I was away on detail. Could you
forward the last internal email with OPE/OGC about the AARP and PSLF?
Thanks.
Ian
From: Kimberly A Myers on behalf of Fedloan PSLF

To; tb)(5) I
Cc: Battle Cynthia: FedLoan PSLF; Tiqngquico Rene:~
Subject: PW Re: Cherokee Nation Tribal Entites
Date: Thursday, December 01 2016 2:40:44 PM
PSLF_Dec_OI
Thanks I
Kim
and/or attachments.
Code:PHEAA
From: KimberlyA MYArSon behalf of FedLoan PSLF

To; fb)(5) ]
Cc: Battle Cynthia: FedLoan PSLF; Tiqngquico Rene
Subject: PW St Louis Development Corporation
Date: Wednesday, October 19, 2016 2:31 :27 PM
PSLF_Oct_19
Thanks I
Kim
Frrnn "Ll~,b~rr~5,==,------7
To FedLoan PSLF <[email protected]>
r;~ "Battle, Cynthia" <[email protected];,, "Tiongquico. Rene' <[email protected];,
I :-a1e 10/0712016 01 :51 PM
SL,8_cct [external]Re. Re: St Louis Development Corporation
Hi Kim,
You can send a copy after the letter goes out. Moving forward, we will most likely start
requesting a copy of the denial letter that goes out for our records.
Thank you!
Taneka
From: Kimberly A Myers <[email protected]> on behalf of Fed Loan PSLF<[email protected]>

Sent: Friday, October 7, 2016 12:42:59 PM
To,l(b)(5) I I
Cc: Battle, Cynthia, Fedloan PSLF,T1ongquico, Rene
Subject: Re: Re: St Louis Development Corporation
Hi Tanekal I will forward this back to the Business Unit for denial, and will send you a copy of the letter.
Do you want to see the letter prior to going to the borrower, or after?
Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
(b)(5)
From
"Battle, Cynthia" <[email protected]>, "Tiongquico, Rene" <[email protected]>
I :-aIe 10/0712016 01 :12 PM
SL,,;p;l [external]Re. St Louis Development Corporation
Hi Kim,
Rene and I reviewed this employer and agree that this employer does not qualify on the basis
that they do not provide an qualifying service. Could you also send us a copy of the denial
letter that will do out to the borrower?
Thanks,
Taneka
From: Kimberly A Myers <[email protected]> on behalf of Fed Loan PSLF<Fed Loan [email protected]>
Sent: Friday, September 16, 2016 1:19:29 PM
To,l(b)(5) I
Subject: St Louis Development Corporation
Hi Tanekal We received a dispute on this one, so we wanted to escalate for your review
We originally denied this organization in September 2014. The organization is 501 (c)(4). but they do not
provide a qualifying public service. They foster economic development and growth in St. Louis.
They now submitted a letter appealing the denial. They indicated that although they are 501 (c)(4), in
many other cities this function resides within the city/local government. They also indicated that their
website falls within the City of St. Louis' website.
Although the additional information provided doesn't supply any further evidence showing they should be
approved, we wanted to escalate. We believe this organization should remain denied.
Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code PHEAA
From: Kane Rachel

To; Tiqngquico Rene
Subject: RE: AARP
Date: Tuesday, September 13, 20161:50:01 PM
Got it, thanks'
From: Tiongquico, Rene

Sent: Tuesday, September 13, 2016 1 :45 PM
To: FSA.PU
Cc: Kane, Rachel; Utz, Jon
Subject: FW: AARP
Anolher PSLFloans issue lor our PLI-OPE call.

b)(5)
b)(5)
From:tl(
5
l I
Sent:hursday, September 08, 2016 2:33 PM
To: Fedloan PSLF;l(b)(5J II
Cc: Battle, Cynthia; Tiongquico, Rene
Subject: RE: AARP
111l(im,
Rene would like Lo escalate lh1s lo lhe Office of Ger1eral Counsel {OCG). VVe will keep you µosled on
a response
Thanks,
Taneka

Se1: I1iesdav tlptember 06, 2016 9:41 PM
To: (b)(5)
Subject: Fw: AARP
Hi Tanekal Although you probably have this decision saved in your records, I just wanted to forward the
historical exchange for easy reference. Based on Ian's prior decision. it was determined that this
organization doesn't qualify. Although we agree, we now received correspondence disputing the denial
and requesting approval of this organization.
They claimed that they are 501 (c)(3) - which they are not. they are actually 501 (c)(4). They also claimed
that they provide 7 public services for the elderly (which they didn't specifically call out in their
correspondence). They attached their organizing documents as well as some other documents. We still
don't believe they qualify, but due to the escalation, we wanted to forward for your review.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
----- Forwarded by Kimberly A Myers.'PHEAA 01109-'06..-201609:33 PM -
From !(b)(5) lkb)(5)

=~-ll(b)(5)
Tn "Fedloan PSLF"' <FedloanPSLF@pheaa orq>. !(b)(5) ..
'"Sipple-Asher. Bessie"' <Bess1eKo.S1ppleAsher@~ecd~_"g,c,-,,-,7·•J7o'\hcccsco,7,7o7,cbcbc,7.-,,7□c,7bcb,7.7J~oh·[email protected]>. '"N1nem1re,Sandra'"
<Sandra. Ninern [email protected]>
I :-aIe 04/25/2013 11 :06 AM
Sr.:1_~,t RE: AARP
Aft.f-'r furt.hPr: rPVif-'w, I c:ann,;:t. find any f-'Vide:1cp LHt. t.l:f-' or:g'illlZi--\t.ion
.9.tov.1des a qual.1Iy.1:1g service. So, unless Lf'_e bo.rr,::,1,,e.t prese:1Ls add.1Lio:1al
evidence, I don't t:--iink it qualities.
-----Cr:igr:nal MPc:c;,;_gp-----
l".torn: :Jiane l"reundel [r·a 1· __0:dI··eL.:1de''r:Lecta.oL,J] 0:1 Uef'_alf Of l'ed~,::,an PSLl'
Sent: TLirsduy, April 11, 2Cl3 8:50 AM
To: l(b)(5) I
C::;: COi:s,plP-Ac;'.1f-'r, Bf-':c;c:ie; ,Tol::1:c;on, CP:C.::ce; FH:IL:Jan PSLF; ?o:c;c:, Ian; Nr:nPmirP,
Sandra
Subject: Re: AARP
l'-TP'll h-;:ld it..
From:
To: PSLF"
Cc: "l"oss, la:1" <lc-.n.l'o. 0;, 0;roed.go\•.>, "l\inern.1re, Sandra"

<S~na=a.Nine~'=e~ed.g,Jv>, "Sipple-Asher, Bessie"
<P,.-,.';.c;i c," :, , '.",i pp l ,-,,z:..
c,"1r ·r '1 c,rl , :;JO\'>, "Jo :1n c::on, Dcbbc"
<Cd:JbP. , ::-hnc;.:::1r:ip(l _'-Jo·v>
:Ja Le: U4/1Ci2013 12:18 PM
Subject: Re: AA.RP
Jic1:1e,
(b)(5)
Iun
On 4/SIU 12:09, l(b)(5) (b)(5)

~~-----"
>Diane,
b)(5)
>I Ll
0
>-----Original Messaqe-----
>From: Diilne ?rcundci [r'ii 1-,.~: ,--if,-c,-i:,:ir,filp·,r,1,1, :;·rq] On Be:1alf Of FedLoan
>P'.")Lf
.>Se:1L: 11..,n~av. Ma.c:::1 18, 2813 2:49 ?M
>To: .l(b~)(~5)~---~I
>Subject: AAR?
b)(5)
>Diane Frcundcl
>C-;;rnplii--LlCP '.")f-'rviu;c,
.>(717) 728-3267
>tax- (717) 720-3911
>d f, r I in d·--""Ph c,"", o ,cc
>Tl:ic, mec,c,age cont.,;.inc: privilf-'gH;l ,;.:1:i ,-.·;:1fide:1t.ial inf-;arnat-.i-; :1 int.f-':1:iH:I
.>[or Lhe a:Oove addressees only. lf you receive Lf'_.1s messa9e .1n error
>please delete or destroy this message a:1ci/or attac:'!ments.
>
>Tl:f-' c:PndPr -;;f t.hic, mpc;c;,;.gp will f·Jlly :;:JO:S,Pr:'it.P i:1 the c:ivil and
.>cr.1minal 0rosecul.1on of any .1nci.iv.1dual en9ag.1ng i:1 Lhe .1nauL:"1orized use
>ot this mE'ssage.
Tl:ic, mpc;c,agP c:011t-_ni:1:, pr:ivilegP:i n:id c-;;nfidPnt.ial i:1for:rrHt.ion l!1t-.e:idH;l f:ir

Lf'_e a:Oove addressees only. lf you receive Lf'_.1s messa9e .1n error please
delete or destroy t:'lis message and/or attachments.
Tl:e ciPlldf-'r of t.hic; rnPc:c;ngP will fully '"'!:JpPri-lt.P in t.hP :;ivil ,;.11:i :;riminnl
0rosecul.1on of any .1ndiv.1ci.ual en9ag.1n9 i:1 Lhe unaul~orizeci. use of L~.1s
message.
and/or attachments.
Code:PHEAA
-~-~
From: !(b)(5)
To; FedLoanPSLF;!(b)(5)
Cc: Battle Cynthia: Tiongquico Rene
Subject: RE: AARP
Date: Thursday, September 08, 2016 2:33:02 PM
H1 Kim,
Rene would like to escalate this to the Office of General Counsel {OCG). We will keep you posted on
a resporIse
Thanks,
Taneka

Sent: Tuesday, September 06, 2016 9:41 PM
To: !(b)(51 I
Subject: Fw: AARP
Hi Taneka! Although you probably have this decision saved in your records, I just wanted to forward the
historical exchange for easy reference. Based on Ian's prior decision, it was determined that this
They claimed that they are 501 (c)(3) - which they are not, they are actually 501 (c)(4). They also claimed
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pbeaa
oro
(717) 720-2630
----- Forwarded by K11nberlyA Myers/PHEAA 011 09/06..-201 6 09:33 PM -
From kb)/5) jlbl/51

fo "Fedloan PSLF"' <FedloanPSLF@pheaa orq>. !(b)(5) lllbl/51 I
C~ '"Sipple-Asher. Bessie"' <[email protected]>. "'Johnson, Debbe'" <[email protected]>. '"N1nem1re,Sandra'"
<[email protected]>
I:-a1e 04/2512013 11 :06 AM
s,.,1_~,
t RE: AARP
Aft.f-'r furt.hPr: rPVif-'w, I C:iillll·'.!t. find any f-'Vide:1cp LHt. t.l:f-' or:g'illlZi--\t.ion
-----Criginal MPc:c;,;.gp-----
l".torn: :Jiane l"reundel [r·a 1· __0:dI··eL.:1de''r:L:.-aa.oL,J] 0:1 JJef'_alf OI l'ed~,::,an PSLl'
To: l{b)(5) I
C::;: COi:s,plP-Ac;'.1f-'r, Bf-':c;c:ie; ,Tol::1:c;on, CP:C.::ce; FPdL:Jan PSLF; ?o:c;c:, Ian; NinPmirP,
Sandra
Subject: Re: AARP
From:
To: PSLF"
Cc: "l"oss, la:1" <lc-.n.l'c. ;roed.go\•.>,

0;, 0 "l\inern.1re, Sandra"
<S~na=0.Nine~'=e~ed.g,Jv>, "Sipple-Asher, Bessie"
<P,.-,.';.c;i c," :, , '.",i pp l ,-,,z:..
c,"1r '1 c,rl , :;JO\'>,
·r "Jo :1n c::on, Deb be"
<Cd:JbP. , ::-hnc;.:::1r:,pd. '-Jo·v>
:Ja Le: U4/1Ci2013 12:18 PM
Subject: Re: AA.RP
Ji0:1e,
b)(5)
Iu:1
On 4/5/13 12:09, l(b)(5)

~~-----" (b)(5)
>Diane,
b)(5)
>I,;.:1
>-----Oriqinul Mess0qe-----
>From: Diilnc ?rcundci [r'ii 1-,.~: ,--if,·c,-i:,:ir,filp·,,---,1,1, :;·rq] On Bc:1alf Of FcdLoan
>P'.")LF
.>Se:1L: 11..,n~av. Marc:'! 18, 2813 2:49 ?M
>To: .l(b~)(~5)~---~I
>Subject: A.AR?
: b)(5)
>
>
>
>Pleuse let us know it you tl:i:1k tl:ey qu0lity PcJSS';.!Ord to tollow.

>Tr.an kc::!
.>(See aLLached file: AAl-<?.L'.ip)
>Diane Freundel
>Complia:-ice Services
>(717) 728-?267
.>[ax- (717) 728-3911
>,jrreun,jc@nhe~cl.•Jrg
>Ttis message contains privileged a:-ici co:-ifide:-itial informatio:-i inte:-icied
>f.;;r t-.he a:C.:ovf-' addrf-':c;c:ees only. If you receive t-_l:is mec;sage in er:rrn
.>please de le Le or deslroy Lhis message a:18.io.t aLLac:'!menLs.
>Tte sender of this message will f~lly coo~eratc i:-i the civil and
>cr:imir1nl prosec:utiri11 of ar1y i11dividual f-'r1gagi11g i:-i tl1e ·J11aut'.1cirizf-'d use
>of Lhis message.
Ttis message contai:-is privileged a:-id confidential i:-iformation inte:-idcd for

t-.1:e a:C.:ovf-' addre:c;c:ef-'s only. If you receive t-_l:i:c; message in er:ror plf-'ac:e
delele or deslroy L:"1.1s message and/or aLLaehmenls.
Tte sender of this message will fully cooperate in the civil anti criminal
pr:-;;secution -;;f any indiviriual engnging i:1 t-.he unaut.'.rnrizf-'ri uc;f-' of Lnc:
messa9e.
addressees only. If you receive this message in eITorplease delete or destroy this message
and/or attachments.
Code:PHEAA
From: Siegel Brian

To; Tiqngquico Rene: Smith Brian: !J.1.....J.o..!
Cc: Kane Rachel
Subject: RE: AARP
Date: Wednesday, September 21, 2016 4:35:15 PM
(b)(5)

Sent: Wednesday, September 21, 2016 4:30 PM
To: Siegel, Brian; Smith, Brian; Utz, Jon
Cc: Kane, Rachel
Subject: RE: AARP
(b)(5)

To: FSA.PU
Subject: FW: AARP
Another PSLFloans issue for our PLI-OPE call
AARP is claiming they are a public service organization Although they are not a 501(c)(3)-they are a
{c}{l))-Lhey are claiming Lo provide public ':.ervice lor Lhe elderly. "Public ':.ervice lor Lhe elderly" 1s
not a term defined under regul,1t1ons
b)(5)
From: l(bJ(5J
>c--~~,...
Sent: Thursday, September 08, 2016 2:33 PM
To: Fedloan PSLF;l(b)(5J I

Subject: RE: AARP
Hi Kirn,
Rene would like to escalate this to the OffiCf' of General Counsel (OCG) We l.'.illl keep you posted on
a response
Thar1ks,
Taneka

To: !(b)(51 I
Subject: Fw: AARP
They claimed that they are 501 (c)(3) - which they are not, they are actually 501 (c}(4). They also claimed
Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
·---- Forwarded by Kimberly A Myers/PHEAA on 09/06.-'2016 09:33 PM -
Frrnn !(b)(5) lfbl( 5 )

To "Fedloan PSLF"' <FedLoanPSLF@pheaa org>. !(b)(5) I
<p11blicservice@ed gov>
C~ "Sipple-Asher, Bessie" <Bess1eKo [email protected]>, "'Johnson, Debbe" <Debbe.Johnson@ed gov>, "Ninem1re, Sandra'"
Date 04/2512013 11 :06 AM
SL,,;_ecl RE: AARP
After further review, I cannot find any evidc~cc t~at tte organization
:s,r:-;;vr:dPc; a gu,;_lr:fyi:19 c;prvicp. S-;;, unlpc,c, t-_l:P bor:r:JwPr: prpc:p:1\-.c, nddr:t-_i,; :1al
evidence, 1 don' L L:·-unk .1L qua.l.1Iies.
-----Original Mcssagc-----
Fr:-;;rn: =ii'illP FrPundPl [r·n· l-o:dfvpi;:]d,,<Jpl:P,'cti-l.•: rg] 0:1 BPl:,;_lf Of FPd::...:Jan PSLF
SenL: 'l'l _.1rsday,
0
Ap.t.11 11, 2Cl3 8:5U AM
To: l(b)(5) I
Cc::: Si:1ple-As:"1er, 3essie; Jol:::-ison, De:Obe; FedLoo.n ?SLF; ?oss, Io.n; Ninemire,
Sandra
Sul;,jpc;t-_: RP: hl\.RP
We :"10.ve ::-iot sent t:'lis o.pprovo.l yet. We'll hold it. Tl:o.::-iks
fr:,; [Tl:
To:
Cc::: "Foss, Ia:-i" <T"ln,Fcss'""d,qn,,->, "l\incmirc, Sandra"

<'.-)c,n~ivi-l.NlllH"- vp~Jp.:J.go·J.>, "'.-)ipplp-hcil1Pr:, Bpc;c,ip"
< 132 :_c;:_c;.i.e:::o . s .i.r:pl eAs:1e ·· 'd ed. 'Jo,, >, "J o:'ln son, Deb be"
<I>:bb<c-. _ 2hnsc::1,<l<c-d. qc,v>
Jatc: 04/lC/2013 12:18 PM
SuhjPct.: RP: hl\.RP
(b)(5)
So, I'm going to reseo.r:::~ some more. Eo.ve v-:e sent the o.pproval yet?
In:1
C-n 1.,,1:;113 12:09 , l(b)(5) (b)(5) wrote:

~~-----"
>D.1ane
> b)(5)
>Ia::1
>
>-----Or:iginnl MPc;c,,;_gp-----
.>l"rom: D.1ane C'reundel [r·c-. .11·.. c:c,,f•·e.1:1c,,e(Jr::1eaa.o··,J] On Ee:'!alI OI l•'edLoan
>PSLF
>Sc:-it: u,,n~,"v M<'lrc:"1 18, 2013 2:49 ?M
>T-;; · l(b~)(e-5)~==-~I
0
.>Subjecl: AAP.?
(b)(5)
.>D.i.ane l"reundel
>Ccmplio.::-ice Servi:::es
>(717) 72:J-3207
>fax- (717) 720-?911
> ,:!r reun,:ie •3:che c.Gt • ,J rq

>Ttis message contains privileged a7ci co7fide7tial informatio7 inte7cied
>f.;;r t-.he a:C.:ovf-' addrf-'sc:ees only. If you naceivP t-_l:is mec;sagP in Pr:rrn
.>please de le Le or deslroy Lhis message a:18.ior aLLac:'!menLs.
>Tte sender of this message will f~lly coo:ceratc i7 the civil and
>cr:imir1nl pr:osPc:utiri11 of ar1y i11dividual f-'r1gagi11g i7 tl1e ·J11aut'.1cirizf-'d use
>of Lhis message.
Ttis message contai7s privileged a7d confidential i7formation inte7dcd for

t-.1:e a:C.:ovf-' addrPsc:ef-'s only. If you rPceivP t-_l:is message in Pr:ror plf-'ac:e
pr:,;;spcution -;;f any indiviriual Pngnging i:1 t-.he unaut.'.rnr:izf-'ri uc;f-' of Lnc:
messa9e.
and/or attachments.
Code:PHEAA
From: Foss Ian

To; Sydor Katherine: Smith Brian; Appel ,Jeff; Mahaftie Lynn; McLarnon Gail: Siegel Brian; Weisman Annmarie;
Utz Jon: Kane Rachel: Tiongqu1co Rene: Chialasjri Taneka
Subject: RE: ABA Documentation
Date: Friday, June 10, 201611 :05:08 AM
(b)(5)
Brian Siegel, please chime 11, if you ccrn add to this
From: Sydor, Katherine

Sent: Friday, June 10, 2016 10:55 AM
To: Foss, Ian; Smith, Brian; Appel, Jeff; Mahaffie, Lynn; Mclarnon, Gail; Siegel, Brian; Weisman,
Annmarie; Utz, Jon; Kane, Rachel; Tiongquico, Rene; Chialastri, Taneka
b)(5)
From: Foss, Ian

To: Smith, Brian; Appel, Jeff; Mahaffie, Lynn; Mclarnon, Gail; Siegel, Brian; Sydor, Katherine; Weisman,
Subiect: RE: ABA Documentation
(b)(5)
(b)(5)
Docs this change anyone's mind about the AB!\~
Staff Attorne - Children's Pro·ect

Job Title: Staff Attorney - Children's
Project
Job Type: Full-Time
Location: Harlingen, TX
Job Description:
Staff Attorney - Children's Project

Commission on Immigration
Exempt
PK11698
Hiring range: $43,800 - $47,400
To give appropriate legal orientation presentations to immigration

children at risk of deportation, complete detainee intakes following
presentations and prepare and conduct pro se workshops and
individual orientations to assist these children. Recruits, trains, and
mentors pro bona attorneys, and directly represents children in
their cases before the immigration court and/or review boards.
Education
Doctoral Degree (JD, PhD)
Experience
The childrens immigration project attorney should have experience
working with immigrants as well as a fundamental knowledge of
immigration law and immigration court procedures. Must exhibit
strong writing skills, excellent communication skills and client
interviewing abilities as well as the ability to work under pressure.
Must be fluent in Spanish, must have a law degree, and have been
admitted to a bar or have taken a bar examination and be waiting
for the results by the start date of employment. Must have a law
degree, and have been admitted to a bar or have taken a bar
examination and be waiting for the results by the start date of
employment.
From: Smith, Brian

To: Foss, Ian; Kane, Rachel
Cc: Appel, Jeff; Mahaffie, Lynn; Mclarnon, Gail; Siegel, Brian; Sydor, Katherine; Weisman, Annmarie
Subject: FW: ABA Documentation
Th;rnks, Ian
Has FSA/FedLoan Servicing responded to this borrowers request to "appeal the decision" that the
ABA is nol an eligible ernµloyer for PSLFpurposes? If so, I could reference lhal re:,ponse {wilhoul
identifying the specific borrower) 1nthe response I'm dr,1ft1ng to the follow-up letter v,'e received
from Jack Rives.
Brian
From: Foss, Ian

Sent: Wednesday, June 08, 2016 12:14 PM
To: Smith, Brian
Subject: ASA Documentation
Hi Brian,
The only documentation we ever received in response to a denial of the ABA as a qualifying
employer for PSLFis attached. It was from the borrower, not the ASA, itself.
Ian
From: Sydor Katherine

To; ~: Smith Brian; Appel ,Jeff; Mahaffie Lynn; McLarnon Gail; Siegel Brian; Weisman Annmarie: J.!!L...Jo..o.;
Kane Rachel: T1onqqu1co Rene: Ch1alastr1 Taneka
Subject: RE: ABA Documentat1on
Date: Friday, June 10, 201610:54:48 AM
b)(5)
From: Foss, Ian

b)(5)
Does this change anyone's mind about the ABA?

Project
Job Type: Full-Time
Job Description:

Exempt
PK11698
Hiring range: $43,800 - $47,400

Education
Experience
employment.
From: Smith, Brian

Thar1ks, Ian
I las FS;\/Fedloan Servicing responded to this borrov,.,iers request to "appeal the decision" that the
ABA is not an eligible employer for PSLFpurposes"? If so, I could reference that response {without
idenl1fyir1g Lhe specific borrower} ir1 Lhe response I'm draflir1g Lo lhe follow-up leller we received
from J;ick Rives.
Brian
From: Foss, Ian

To: Smith, Brian
Subject: ABA Documentation
H1Brian,
employer for PSLFis attached. It was from the borrower, not the ABA, itself.
Ian
From: Foss Ian

To; Smith Brian; Appel ,Jeff: Mahaftie Lynn; McLarnon Gail: Siegel Brian: Sydor Katherine: Weisman Annmarie;
Date: Friday, June 10, 2016 8:55:05 AM
(b)(5)

Project
Job Type: Full-Time
Job Description:

Exempt
PK11698
Hiring range: $43,800 - $47,400


Education
Experience
employment.
From: Smith, Brian

Thanks, Ian
Has FSA/Fedloar1 Serv1c1ngre:,µor1ded Lo lhi:, borrowers requesl Lo "appeal Lhe decision" lhal Lhe
ABA 1snot an f'l1gible employer for PSLFpurposes I If so, I rnuld rf'ferencf' that rf'sponse (without
identifying the specific borrower) in the response I'm drafting to the follow up letter we received
from Jack Rives.
Brian
From: Foss, Ian

To: Smith, Brian
Hi Brian,
Ian
From: Siegel Brian

To; Sydor Katherine: fu&...!.a.!:l:
Smith Brian; Appel ,Jeff; Mahaffie Lynn; McLarnon Gail; Weisman Annmarie: l.J.1L
Jon: Kane Rachel: Tiongqu1co Rene: Chialasjri Taneka
b)(5)

To: Foss, Ian; Smith, Brian; Appel, Jeff; Mahaffie, Lynn; McLarnon, Gail; Siegel, Brian; Weisman,
b)(5)
From: Foss, Ian

To: Smith, Brian; Appel, Jeff; Mahaffie, Lynn; McLarnon, Gail; Siegel, Brian; Sydor, Katherine; Weisman,
b)(5)
(b)(5)
Does lhis change anyone's rnir1d aboul lhe ABA?

Staff Attorney - Children's
Job Title:
Project
Job Type: Full-Time
Job Description:

Exempt
PK11698
Hiring range: $43,800 - $47,400

Education
Experience
employment.
From: Smith, Brian


Th;rnks, Ian
from Jack Rives.
Brian
From: Foss, Ian

To: Smith, Brian
Hi Brian,
Ian
From: !(b)(5)
To; FedLoan PSLF ~---
Cc: Battle Cynthia: l{b)(5) I Tiongq11ico Rene
Subject: RE: American Public Transportation Association
H1Kim,
We will start our review.
I also wanted to update you ,1nd let you know that we ,1re meeting intern,1lly on the pending
employer escalations and should have an update to you next v,eck.
1
Thar1ks,
Taneka

Sent: Wednesday, August 31, 2016 8:36 AM
To, !(bl(51 I
Hi Taneka! This one is a borrower dispute, so we are forwarding for review.
for the elderly.
Kimberly A Myers
Compliance Services
kmyers@pbeaa
oro
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; FedLoan PSLF
Cc: l{b)(5) I: Tiongquico Rene: Battle Cynthia
Subject: Re: Cherokee Nation Tribal Entites
Date: Friday, October 07, 2016 2:10:43 PM
Hi K1m1
Rene met with a larger policy group to discuss the Cherokee Nation Tribal Ent1t1esand few of
the other tribJI cJsinos we hJve pending. We believe the that the Cherokee Nation Tribal
entities: Cherokee Nation Technologies, CN MJnJgement & Consulting, and Cherokee NJtion
Business are qualifying employers for the purpose of PSLF The policy group determined that
these entities are governmental so whether the government entity is profit mJking or not
doesn't negate their governmental status
Thanks,
TanekJ
From: Chialastri, Taneka

Sent: Wednesday, August 17, 201610:44 AM
To: !(b)(51 I
Subject: FW: Cherokee Nation Tribal Entites
From: l(b)(5J I
Sent: Wednesday, August 17, 2016 11 :44 AM
To: 'Fedloan PSLF'
Subject: RE: Cherokee Nation Tribal Entites
b)(5)
Thanks,
Tanek;i

Sent: Tuesday, August 16, 2016 9:23 AM
To: !(b)(51 I
Subject: Cherokee Nation Tribal Entites
Hi Tanekal We recently received two more entities that fall under the Cherokee Nation, Cherokee Nation
Technologies and CN Management & Consulting. I'm including them together below for ease in review
since they are within the same tribe.
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; FedLoan PSLF
Date: Wednesday, August 17, 2016 11 :44:31 AM
H1 Kim
(b)(5)
Th;rnks,
Taneka

To: !(bl(51 I
b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: Utz Jon

To; Kane Rachel
Cc: Tiqngquico Rene: Wertenberger Lindsay: Baker ,Jeff
Subject: RE: Direct Loans and Change In Student"s Dependency Status
Date: Monday, May 09, 2016 2:02:48 PM
The issues th,1t ,1re involved here are some1.'Jhatcomplicated, so I think 1t would be easier to discuss
in person Rachel, can we add this to the agenda for our loan issues meeting at 10:00 on Friday and
invite Rene and Lindsay-;,
From: Kane, Rachel

Sent: Monday, May 09, 2016 10:35 AM
To: Tiongquico, Rene; Utz, Jon
Cc: Wertenberger, Lindsay
Subject: RE: Direct Loans and Change in Student's Dependency Status
5
Thanks for summar1zini:, Rene fbl( l
(b)(5)
I
Thanks,
Rachel

To: Utz, Jon
Cc: Wertenberger, Lindsay; Kane, Rachel
Subject: Direct Loans and Change in Student's Dependency Status
H1Jon,
We had a call on PLI Mailbox issues this morning and an interesting topic with a change in the
student's dependency status in a BBAY.
A student was determined to be a dependent student with a 10,000 EFCfor the 15/16 award year.
The school packages the student Direct Loans for a two semester loan period and uses BBAY. If the
first loan disbursement was in the 15/16 award year and the student received funds under the
10,000 EFCas a dependent undergraduate but in the middle of the student's award year the student
has a change in their dependency status (they either reached the age of 24 or they were pregnant
and now have a dependent child; the likely scenario is that their EFCwould also change and in this
example they went from 10,000 to 0 EFC), how does this impact the treatment of their Direct Loans?
We were exploring some options including telling the school to get rid of BBAY altogether and to
shorten the loan period to just 15/16 award year but something tells me that now the student's
disbursements are not substantially equal.
Thoughts?
Rachel and Lindsay, chime in if I missed something.
-Rene
Rene Tiongquico
U.S. Department of Education
Federal Student Aid; Policy Liaison & Implementation
Email: [email protected]
From: Kane Rachel

To; Tiqngquico Rene: l..!1L...J.o..!
Cc: Wertenberger Lindsay
Date: Monday, May 09, 2016 10:35:21 AM
..-J '--j(b)(5)
b)(5)
Thanks,
Rachel

To: Utz, Jon
Hi Jon
We had a call on PU Mailbox issues this morning and an interesting topic with a change in the
has a change in their dependency status {they either reached the age of 24 or they were pregnant
Thoughts?
-Rene
Rene Tiongquico
Federal Student Aid, Policy Liaison & Implementation
From: Kane Rachel

To; l1lwllr!
Will do
From: Utz, Jon

Sent: Monday, May 09, 2016 2:03 PM
To: Kane, Rachel
Cc: Tiongquico, Rene; Wertenberger, Lindsay; Baker, Jeff
The issues lhal are involved here are sornewhal cornplicaled, so I lhir1k il would be easier lo di:,cuss
in pnson R;ichf'I, c;in Wf' ;idd this to thf' ;igpnd;i for our lo;in issuf's mf'f'ting ;it 10:00 on Frid;iy ;ind
invite Rene and Lindsay?
From: Kane, Rachel

(b)(5)
Thanks,
Rachel

To: Utz, Jon
Hi Jon
Thoughts?
-Rene
Rene Tiongquico
From: Kane Rachel

To; Tiqngquico Rene: Smith Brian: Siegel Brian: Hammond Cynthia: Baker ,Jeff; 1!.IL...,,!o_Q
Cc: Weisman Annmarie
Subject: RE: Discuss Questions about Eligible Employers for PSLF
Hi all,
Jeff and Rene's previous call is going long. We will initiJte this cJII once their previous meeting
wrap up.
Thanks,
Rc1chel
-----Original Appointment-----
From: Kane, Rachel
To: Kane, Rachel; Tiongquico, Rene; Smith, Brian; Siegel, Brian; Hammond, Cynthia; Baker, Jeff; Utz,
Jon
Cc: Weisman, Annmarie
Subject: Discuss Questions about Eligible Employers for PSLF
When: Wednesday, September 21, 2016 1 :00 PM-1 :30 PM (UTC-05:00) Eastern Time (US & Canada).
Where: Conference Call: (866) 745-2590; 6957213#,
Are the following organizations eligible employers for PSLF purposes?
• The Cherokee NJtion gJrning fJcility, Bordertown Casino We need to determine

whether the casino Is an enterprise of the tribe and thus a governmental (tribal) entity.
<< Message: FW: Outpost Casino>>
• The AARP They are clJirning thJt, while they are J 501(c)(4), not (c)(3), they
provide public service for the elderly.
« Message· FW: AARP »
From: Utz Jon

To; Kane Rachel; Tiqngquico Rene; Hammond Cynthia
Are we still having this call?
From: Kane, Rachel
Jon; Mclarnon, Gail
When: Wednesday, September 21, 2016 1 :00 PM-1:30 PM (UTC-05:00) Eastern Time (US & Canada).
• The Cherokee Nation gaming fac1l1ty1 Bordertown Casino We need to determine

whether the cJsino is an enterprise of the tribe Jnd thus J governmental (tribal) entity.
« Message· FW: Outpost Casino>>
• The AARP They are claiming that, while they are a SOl(c)(-'1), not (c)(3), they
<< Message: FW: AARP >>
From: Baker Jeff

To; Tiongquico Rene: Kane Rachel
Cc: Smith Brian; Siegel Brian; Hammond Cynthia: !.!IL....J.o..!;
Weisman Annmarie
Ple,1se r;ill In at 1 ·1 .S, sorry.

Sent: Wednesday, September 21, 2016 1 :08 PM
To: Kane, Rachel
Cc: Smith, Brian; Siegel, Brian; Hammond, Cynthia; Baker, Jeff; Utz, Jon; Weisman, Annmarie
Subject: Re: Discuss Questions about Eligible Employers for PSLF
Finishing up a call at 115
Rene Tiongquico
[email protected]
###
On Sep 21, 2016, at 1:07 PM, Kane, Rachel <[email protected]> wrote:
Hi all,
Jeff and Rene's previous call is going long We will in1t1ate this call once their previous
meeting wrap up
Thanks,
Rachel
From: Kane, Rachel
To: Kane, Rachel; Tiongquico, Rene; Smith, Brian; Siegel, Brian; Hammond, Cynthia;
Baker, Jeff; Utz, Jon
When: Wednesday, September 21, 2016 1 :00 PM-1:30 PM (UTC-05:00) Eastern Time (US
& Canada).
Are the following organizations eligible employers for PSLFpurposes-;,
• The Cherokee N,1t1ongaming facility, Bordertown Casino We need to determine

v,hether the casino Is an enterprise oft he tribe and thus a governmental (tribal) entity.
1
« Message: FW: Outpost Casino>>

• The AARP They are claiming lhal, while Lhey are a SOl{c}{I)}, nol (c)(3), lhey provide
public servire for the elderly
« Message: FW: AARP >>

To; Tiqngquico Rene
Subject: RE: Email to OGG about Indian Casinos
111Rene,
Thar1k you for keeping rne updated. I'm goir1g Lo ':.end arI inv1Le for U'> lO rneel on nexl Thursday,
September 8 th to discuss a some of Pl I[1\1\'s outstanding employer escalations. If you arc unable to
meet I can check the calendar for the following week
H;ivf' ,1 good d;iy,
Taneka

Sent: Wednesday, August 31, 2016 5:01 PM
To: Chialastri, Taneka
Subject: Email to OGG about Indian Casinos
Taneka:
I want you to know that this is on my radar and we may discuss this in our policy meeting.
Additionally, I still have to reach out to OGC to inquire about the status of Indian casinos.
Rene Tiongquico
From: !(b)(5)
To; FedLoan PSLF
Cc: l{b)(5) I Tiongquico Rene; Battle Cynthia
Subject: Re: Fair Elections Legal Network
Hi Kim,
We will need to escalate this for an additional review since this will likely PHEAA will need to
issue a retraction. I will keep you posted on a decision.
While we wait, would you be able to tell us how many borrowers have been approved under
the Fair Elections Legal Network and how long the oldest approval is for?
Thanks,
Taneka
From: Kimberly A Myers <[email protected]> on behalf of FedLoan PSLF

<[email protected]>
Sent: Friday, September 16, 2016 12:42 34 PM
To: !(bl(51 I
Subject: Fair Elections Legal Network
(b)(5)
Your guidance is appreciated. Password to follow.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; Tiqngquico Rene
Cc: ~
Subject: FW: American Public Transportation Assoc1at1on
H1 Rene,
(b)(5)
Thar1ks,
Taneka
From: l(b)(5J I
To: Fedloan PSLF
Cc: Battle, Cynthia; l(b)(5J
Subject: Re: Americca~n'-"'P-ub~l~i,~Tc-'ransportation
Association
Hi Kim,
We also need to forward American Public Transportation Association to OGCfor review. We

will keep you posted.
Thanks,
Taneka
From: l(bJ(5J
~---~
Sent: Thursday, September 1, 2016 8·12·21 AM
To: Fedloan PSLF
Cc: Battle, Cynthia; l(b)(5J I
Tiongquico, Rene
Subject: RE, American Public Transportation Association
Hi Kirn,
WP. will st;irt our rP.VIP.V,'
I also wanted to update you and let you know that we are meeting internally on the pending
employer escalalion'> arid ':.hould have an updale lo you nexl week.
Thanks,
Taneka

To: !(b)(51 I
Hi Tanekal This one is a borrower dispute, so we are forwarding for review.
for the elderly.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: Wast1ington Aaron

To; Tiqngquico Rene
Date: Friday, October 21, 2016 11 :02:02 AM
Call me when you can to discuss.
From: Arnold, Nathan

Sent: Friday, October 21, 201611:00 AM
To: Washington, Aaron; Hoblitzell, Barbara
Subject: RE: Quick question on PSLF
Hey Aaron,
(b)(5)
Let me know if I'm just confusing things or if I can be of further help
Nathan
From: Washington, Aaron

To: Arnold, Nathan; Hoblitzell, Barbara
I Icy Nathan and Barbara-got a question from Peace Corps-hov,.,i docs this draft response sound?
b)(5)
From: Edmondson, Samantha [mailto:[email protected]]

To: Arnold, Nathan; Washington, Aaron
Subject: Quick question on PSLF
Hi Nathan & Aaron,
I just received the following question from a Volunteer and wanted to see if either of you could offer
some clarification for me before I responded.
If a Peace Corps Volunteer returns to School after Peace Corps and accrues more student loans, will
they need to make another 120 qualifying payments for the newly accrued loans after they graduate
or will the qualifying payments made as a volunteer count towards the total 120?
Any insight would be greatly appreciated!
All my best,
Samantha
From: !(b)(5)
To; l1lwllr!
Cc: Battle Cynthia: Tiongquico Rene: Chialastri Taneka
Subject: Fw: Re: PSLF- American Bar Assoc1at1on
Attachments: ECF Redacted.pd1
Denial Letter redacted.docx
Hi Jon,
Ian had requested this information from PHEAA back in April (see below and attached). The
retraction letter and an ECFis attached. Rene and I were discussing the lack of information
contained in their retraction letter yesterday for a separate retraction and I will be emailing
PHEAA today to start the discussion on ways they can be more transparent when a borrower
has their approval retracted.
I will also request detailed information for all the borrowers who have been denied (9 in April)
and who received a retraction (19 in April).
Thanks,
Taneka

Sent: Wednesday, April 13, 2016 8.34 AM
To: Foss,Ian
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
C~llc 04113/2016 08:42 AM

(b)(5)
Hi Ian!
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
C~llc 04108/2016 02:56 PM
(b)(5)

To: Foss, Ian
(b)(5)
Thanks!
Kimberly A Myers
Compliance Services
kmyers@J;Jheaa.onJ
(717) 720-2630

Dc1l~ 04/08/2016 12:02 PM
(b)(5)
TanekJ
From: Foss, Ian

Hello all,
(b)(5)
Thanks,
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; Tiqngquico Rene: Battle Cynthia
Cc: Chialastri Taneka
Subject: Fw: RE: Students First
(b)(5)

Sent: Tuesday, August 9, 2016 2.27 PM
To: !(b)(51 I
Cc: Battle, Cynthia; Fed Loan PSLF,Tiongquico, Rene
Subject: Re, RE· Students First
Hi Tanekal I reached out to the Business Unit to pull the data for me. Once I receive the query back I will
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From -~I
kb~J(~5~)
0 <publicserv1ce@ed gov>
To Fedloan PSLF <[email protected]>

!(b)(5) I
<[email protected]>. "Battle, Cynthia"' <[email protected]>, "Tiongquico, Rene"
<[email protected]>
Dc1l~ 08/08/2016 04:08 PM
SL,8_cct [external]RE: Students First
(b)(5)
Th;rnks,
TanekJ

Sent: Thursday, July 14, 2016 11:48 AM
To: !(b)(51 I
Back in March 2012, we received an ECF for this employer (I didn't attach this one). We determined this
organization was 501 (c)(4), which was not-for-profit, but had to perform a qualifying public service. Since
this was at the beginning stages of the PSLF reviews, we approved this organization under the public
education category. This was before our more detailed conversations with Ian regarding public education
and that of an association.
It wasn't until April 2016 that we received another ECF for this employer. Based on our increased
knowledge at this point, we determined that this employer that, although not-for-profit, they actually do not
perform a qualifying public service. They don't actually provide the public education, but defend the
interest of children in public education.
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: Foss Ian

To; Tiqngquico Rene
Subject: Fwd: May 2016 PSLF Monthly Report
Date: Thursday, June 09, 2016 11: 18:33 AM
ATT00001.hlm
ATT00002.hlm
image001 ong
ATT00003 him
ATT00004.hlm
PSLF Reoorls.xlsx
ATT00005 him
From: "Foss. Ian" <lan,[email protected]>

Date: June 8, 2016 at 16:21:28 EDT
To: "Johnson, Debbe" <[email protected]>, "Sessa. Matthew"
<[email protected]>, ''Sipple-Asher, Bessie''
<[email protected]>
Subject: RE: May 2016 PSLF Monthly Report
I've beer1 pulling lhem 1nar1 Excel '>heel, if lhal''> helpful
From: Johnson, Debbe

To: Sessa, Matthew; Sipple-Asher, Bessie; Foss, Ian
Subject: RE: May 2016 PSLF Monthly Report
I h,we them all Here are the May reports for 2012 - 201.S
From: Foss Ian

To; Tiqngquico Rene
Subject: Fwd: Public Service Loan Forgiveness Program inquiry
Can you look at this?
We previously approved a NY corporation that was established for the sole purpose of
employing medical and dental residents.
We have also previously approved non-501(c)(3)s as (c)(s) when they are wholly owned
"disregarded entities" of (c)(3)s.
From: "Gold, Stephanie J." <[email protected]>

Date: September 1, 2016 at 09:30:10 EDT
To: "Ian,[email protected]" <Ian,[email protected]>
Subject: Public Service Loan Forgiveness Program inquiry
Mr. Foss,
I am writing regarding the Public Service Loan Forgiveness Program ("PSLF Program").
know you recently gave a presentation on the Program at the NASFAAAnnual
Conference. Please let me know, though, if I should direct my question to someone
else at the Department.
We would like to confirm that an employer of medical residents and doctors would be
a qualifying employer for purposes of the PSLFProgram where the employer's sole
member is tax-exempt under section 501(c)(3) of the Internal Revenue Code ("IRC").
As explained below, we believe that in such a circumstance the employer is a qualifying
employer because it is a so-called "disregarded" entity that is effectively a nonprofit,
501(c)(3) tax-exempt organization.
Specifically, the employer of the medical residents and doctors would be a limited
liability company whose sole member is a nonprofit, 501(c)(3) tax-exempt
organization. Under applicable federal tax law (as well as various state and local tax
laws), when a 501(c)(3) tax-exempt organization is the "sole member" of a limited
liability company, then such single member limited liability company (11SMLLC11 ) is
"disregarded" by the IRSfor tax purposes and is treated as an internal branch, division,
program or activity of its 501(c)(3) member. See Treasury Regulation Section
301.7701-2(c)(2)(i). While there can be different reasons for choosing the SMLLC
format, a 501(c)(3) tax-exempt organization typically will choose to have a SMLLC
conduct functions that it could conduct itself -- here, employ health care providers who
perform services at a particular state owned and operated hospital -- In order to limit
its liability exposure. This liability limitation is particularly attractive because the IRS
views the SMLLC as effectively part of its 501(c}(3} tax-exempt member. See Treasury
Regulation Section 301.7701-2{a) nIJf the entity is disregarded, its activities are
treated in the same manner as a sole propr1etorsh1p, branch, or division of the
owner."). Indeed, a 501(c)(3) tax-exempt organization that wholly owns a disregarded
entity must treat the operations and finances of such disregarded entity as its own for
tax and information reporting purposes. See IRSAnnouncement 99-102, 1999-2 C.B.
545. To such end, when an employee of a disregarded SMLLC completes IRS Form W-9
(Le.,_,the form an employer uses for payroll purposes, such as to prepare employee
paychecks and W-2 forms at the end of the year}, the IRSexpressly requires the
employee to reference the limited liability company's sole member (such as its 501(c)
(3) tax-exempt member), and not the limited liability company itself. Moreover, just
this past month, the IRS,through its Office of Chief Counsel, issued advice in the
employee benefits context that confirms that employees of a disregarded SMLLC are
employees of the 501(c)(3} member for employee benefits plan purposes. See Chief
Counsel Advice ILM 201634021, dated July 11, 2016 & released August 19, 2016. The
IRS has also been clear that, for purposes of entitling donors to a charitable
contribution deduction, a donor's contribution to a SMLLC that is wholly owned and
controlled by a 501(c)(3) tax-exempt organization is to be treated as a charitable
contribution to such 501(c){3) tax-exempt organization. ~ IRS Notice 2012-52.
Finally, although not necessary for IRSpurposes, the governing document of the
SMLCC at issue here sets forth the standard language normally seen in the
organizational documents of nonprofit, Section 501(c)(3) tax-exempt organizations,
~, its purpose is to operate exclusively for charitable, sc1entif1cand educational
purposes, it is not to operate for pecuniary profit or financial gain, and it is to act
exclusively as an instrumentality of its 501(c}(3) tax-exempt member.
Given that the PSLFProgram, in effect, looks to the IRSas to its determination of
whether an employer is a Section 501(c){3) tax-exempt organization for purposes of
the PLSFProgram -- and that the IRStreats a disregarded SMLLC as an internal branch,
division, program or activity of the Section 501(c)(3) organization that serves as the
sole member of such a SMLLC-- we would appreciate the Departmenfs confirmation
that under the PSLFProgram a disregarded SMLLC such as the one described above
would be viewed as a 501(c)(3} tax-exempt organization that is a "qualifying employer"
under the Program.
Thank you for your consideration.
Stephanie
Stephanie Gold
P.inier
Hogan Lovells US LLP
C::ilulllb1a SqL.arc
757 Th1,tr)1;nll1 Strcc:. NW
Wash1n(_ron DC 20004
Tel -1 202 637 5600

ll1rcct -1 ?O? 637 5496
F,ix -12(l2fi'.l7591(l
Bloq www.hldataprotection.com/
www .ho"anlovelb.com
!-'lease consm'cr //10 cnvrromncnt before pm1t111pth:s c ma.'i
About Hogan Lovells

Hogan Lovells is an international legal practice that includes Hogan Lovells US LLP and Hogan Lovells
International LLP. For more information, see www hoganlovells.com.
CONFIDENTIALITY. This email and any attachments are coniidential. except where the email states it can
be disclosed; it may also be privileged. If received in error, please do not disclose the contents to anyone,
but notify the sender by return email and delete this email (and any attachments) from your system.

To; Tiqngquico Rene
Subject: 1"11be 5 minutes late
I'm in another meeting n1be about 5 minutes late.
Thanks,
Taneka
Taneka Chialastri I Management and Program Analyst, Bu~ine~s Operation~ I Federal Student Aid
830 Fir~t Street NE, Wc1~h1ngton, DC 20202
Office: 202-377-4390 I taneka chialastri@ed 1;ov
From: Foss Ian

To; Tiqngquico Rene
Subject: PSLF- AARP
Hey Rene,
I gather that we dealt with a PSLF employer escalation regarding AARP while I was away on detail. Could you
forward the last internal email with OPE/OGC about the AARP and PSLF?
Thanks.
Ian

To; p11blicservice
Cc: Battle Cynthia: FedLoan PSLF; Tipngquico Rene:~
Subject: PW Re: Cherokee Nation Tribal Entites
Date: Thursday, December 01 2016 2:40:44 PM
PSLF_Dec_OI
Thanks I
Kim
and/or attachments.
Code:PHEAA
From: Kimberly A Myers on behalf of FedLoan PSLF

To; !(b)(5) I
Subject: PW St Louis Development Corporation
Date: Wednesday, October 19, 2016 2:31 :27 PM
PSLF_Oct_19
Thanks I
Kim
Frrnn !(b)(5) lfbl( 5 ) I

r;~ "Battle, Cynthia" <[email protected];,, "Tiongquico. Rene' <[email protected];,
I :-aIe 10/0712016 01 :51 PM
SL,8_cct [external]Re. Re: St Louis Development Corporation
Hi Kim,
Thank you!
Taneka

To: l(b)(5) I
Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From !(b)(5)
I :-aIe 10/0712016 01 :12 PM
Hi Kim,
Thanks,
Taneka
To: l(b)(5) I
b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code PHEAA
From: Kane Rachel

To; Tiqngquico Rene
Subject: RE: AARP
Date: Tuesday, September 13, 20161:50:01 PM
Got it, thanks'

To: FSA.PU
Subject: FW: AARP
Anolher PSLFloans issue lor our PLI-OPE call.
1\1\RPis claiming they arc a public service orgarmatIon Although they arc not a 501(c)(3)-thcy arc a
{c){4)-they are claiming to provide public service for the elderly. "Public service for the elderly" is
nol a lerm defined under regulalions
(b)(5)
From: l(b)(5J
Sent: T""h~u~,,~d-ay-,~s'"eptember
08, 2016 2:33 PM
To: Fedloan PSLF; l(b)(5J I
Subject: RE: AARP
111l(im,
Rene would like Lo escalate lh1s lo lhe Office of Ger1eral Counsel {OCG). VVe will keep you µosled on
a response
Thanks,
Tanek;i

To: !(b)(51 I
Subject: Fw: AARP
b)(5)
b)(5)
Thanks!
KimberlyA Myers
Compliance Services
[email protected]
(717) 720-2630
----- Forwarded by Kimberly A Myers.'PHEAA 01109-'06..-201609:33 PM -

fo "Fedloan PSLF" <FedloanPSLF@pheaa orq>. !(b)(5) b)( 5 ) I
C~ "Sipple-Asher. Bessie" <[email protected]>. "Johnson, Debbe" <[email protected]>. "N1nem1re,Sandra"
I :-aIe 04/2512013 11 :06 AM
Sr.:1_~,t RE: AARP
(b)(5)
••• ' "'- 'c, .

l".torn: :Jiane l"reundel [r·a 1· __0:dI··eL.:1de''r:Lecta.oL,J] 0:1 JJef'_alf OI l'ed~,::,an PSLl'
To: l(b)(5) I
Sandra
Subject: Re: AARP
From:
To: PSLF"
Cc: "l"oss, la:1" <lc-.n.l'c. ;roed.go\•.>,

0;, 0 "l\inern-1re, Sandra"
<P,.-,.';,c;i c," :, , '.",i pp l ,-,,z:..
c,"1r ·r '1 c,rl , :;JO\'>, "Jo :1n c::on, Dcbbc"
<Cd:JbP. , ::-hnc;.:::1r:,pd. '-Jo·v>
:Ja Le: U4/1Ci2013 12:18 PM
Subject: Re: AA.RP
Jia:1e,
b)(5)
On 4/SIU 12:09, l(b)(5) (b)(5)

~~-----"
>Diane,
b)(5)
>
>I Ll
0
>-----Original Messaqe-----
>From: Diilne ?rcundci [r'ii 1-,.~: ,--if,-c,-i:,:ir,filp·,r,1,1, :;·rq] On Be:1alf Of FedLoan
>P'.")Lf
.>Se:1L: 11..,n~av. Ma.c:::1 18, 2813 2:49 ?M
>To: .l(b~)(~5)~---~I
>Subject: AAR?
(b)(5)
>Diane Frcundcl
>C-;;rnplii--LlCP '.")f-'rviu;c,
.>(717) 728-3267
>tax- (717) 720-3911
>d f, r I in d·--""Ph c,"", o ,cc
>Tl:ic, mec,c,age cont.,;.inc: privilf-'gH;l ,;.:1:i ,-.·;:1fide:1t.ial inf-;arnat-.i-; :1 int.f-':1:iH:I
.>[or Lhe a:Oove addressees only. lf you receive Lf'_.1s messa9e .1n error
>please delete or destroy this message a:1ci/or attac:'!ments.
>
>Tl:f-' c:PndPr -;;f t.hic, mpc;c;,;.gp will f·Jlly :;:JO:S,Pr:'it.P i:1 the c:ivil and
.>cr.1minal 0rosecul.1on of any .1nci.iv.1dual en9ag.1ng i:1 Lhe .1nauL:"1orized use
>ot this mE'ssage.
Tl:ic, mpc;c,agP c:011t-_ni:1:, pr:ivilegP:i n:id c-;;nfidPnt.ial i:1for:rrHt.ion l!1t-.e:idH;l f:ir

Lf'_e a:Oove addressees only. lf you receive Lf'_.1s messa9e .1n error please
delete or destroy t:'lis message and/or attachments.
Tl:e ciPlldf-'r of t.hic; rnPc:c;ngP will fully '"'!:JpPri-lt.P in t.hP :;ivil ,;.11:i :;riminnl
0rosecul.1on of any .1ndiv.1ci.ual en9ag.1n9 i:1 Lhe unaul~orizeci. use of L~.1s
message.
and/or attachments.
Code:PHEAA
-~-~
From: !(b)(5)
To; FedLoan PSLF;!(b)(5)
Subject: RE: AARP
H1 Kim,
Rene would like to escalate this to the Office of General Counsel {OCG). We will keep you posted on
a resporIse
Thanks,
Taneka

To: !(b)(51 I
Subject: Fw: AARP
b)(5)
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pbeaa
oro
(717) 720-2630
----- Forwarded by K11nberlyA Myers/PHEAA 011 09/06..-201 6 09:33 PM -
From kb)/5) lfb)(5)

fo "Fedloan PSLF"' <FedloanPSLF@pheaa orq>. !(b)(5) lkbl/5) I
C~ '"Sipple-Asher. Bessie"' <[email protected]>. "'Johnson, Debbe'" <[email protected]>. '"N1nem1re,Sandra'"
<[email protected]>
I :-aIe 04/25/2013 11 :06 AM
s,.,1_~,
t RE: AARP
Aft.f-'r furt.hPr: rPVif-'w, I C:iillll·'.!t. find any f-'Vide:1cp LHt. t.l:f-' org'illlZi--lt.ion
-----Criginal MPc:c;,;.gp-----
l".torn: :Jiane l"reundel [r·a 1· __0:dI··eL.:1de''r:L:.-aa.oL,J] 0:1 JJef'_alf OI l'ed~,::,an PSLl'
To: l{b)(5) I
Sandra
Subject: Re: AARP
From:
To: PSLF"
Cc: "l"oss, la:1" <lc-.n.l'c. 0;, 0 ;roed.go\•.>, "l\inern.1re, Sandra"

<P,.-,.';.c;i c," :, , '.",i pp l ,-,,z:..
c,"1r '1 c,rl , :;JO\'>,
·r "Jo :1n c::on, Deb be"
<Cd:JbP. , ::-hnc;.:::1r:,pd. '-Jo·v>
:Ja Le: U4/1Ci2013 12:18 PM
Subject: Re: AA.RP
Ji0:1e,
b)(5)
On 4/5/13 12:09, l(b)(5)

~~-----" (b)(5)
>Diane,
b)(5)
>I,;.:1
>-----Oriqinul Mess0qe-----
>From: Diilnc ?rcundci [r'ii 1-,.~: ,--if,·c,-i:,:ir,filp·,,---,1,1, :;·rq] On Bc:1alf Of FcdLoan
>P'.")LF
.>Se:1L: 11..,n~av. Marc:'! 18, 2813 2:49 ?M
>To: .l(b~)(~5)~---~I
>Subject: A.AR?
b)(5)
.>(See aLLached file: AAl-<?.L'.ip)
>Diane Freundel
>Complia:-ice Services
>(717) 728-?267
.>[ax- (717) 728-3911
>,jrreun,jc@nhe~cl.•Jrg
>Ttis message contains privileged a:-ici co:-ifide:-itial informatio:-i inte:-icied
>f.;;r t-.he a:C.:ovf-' addrf-':c;c:ees only. If you receive t-_l:is mec;sage in er:rrn
.>please de le Le or deslroy Lhis message a:18.io.t aLLac:'!menLs.
>Tte sender of this message will f~lly coo~eratc i:-i the civil and
>cr:imir1nl prosec:utiri11 of ar1y i11dividual f-'r1gagi11g i:-i tl1e ·J11aut'.1cirizf-'d use
>of Lhis message.
Ttis message contai:-is privileged a:-id confidential i:-iformation inte:-idcd for

t-.1:e a:C.:ovf-' addre:c;c:ef-'s only. If you receive t-_l:i:c; message in er:ror plf-'ac:e
pr:-;;secution -;;f any indiviriual engnging i:1 t-.he unaut.'.rnrizf-'ri uc;f-' of Lnc:
messa9e.
and/or attachments.
Code:PHEAA
From: Siegel Brian

To; Tiqngquico Rene: Smith Brian: !J.1.....J.o..!
Cc: Kane Rachel
Subject: RE: AARP
(b)(5)

To: Siegel, Brian; Smith, Brian; Utz, Jon
Cc: Kane, Rachel
Subject: RE: AARP
Hi All
(b)(5)

To: FSA.PU
Subject: FW: AARP
Another PSLFloans issue for our PLI-OPE call
AARP is claiming they are a public service organization Although they are not a 501(c)(3)-they are a
{c}{l))-Lhey are claiming Lo provide public ':.ervice lor Lhe elderly. "Public ':.ervice lor Lhe elderly" 1s
not a term defined under regul,1t1ons
(b)(5)
From: l(bJ(5J
>c--~~,...

Subject: RE: AARP
Hi Kirn,
Rene would like to escalate this to the OffiCf' of General Counsel (OCG) We l.'.illl keep you posted on
a response
Thar1ks,
Taneka

To: !(b)(51 I
Subject: Fw: AARP
They claimed that they are 501 (c)(3) - which they are not, they are actually 501 (c}(4). They also claimed
Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
·---- Forwarded by Kimberly A Myers/PHEAA on 09/06.-'2016 09:33 PM -
Frrnn !(b)(5)
To "Fedloan PSLF"' <FedLoanPSLF@pheaa org>. !(b)(5) I
<p11blicservice@ed gov>
C~ "Sipple-Asher, Bessie" <Bess1eKo [email protected]>, "'Johnson, Debbe" <Debbe.Johnson@ed gov>, "Ninem1re, Sandra'"
Date 04/2512013 11 :06 AM
SL,,;_ecl RE: AARP
After further review, I cannot find any evidc~cc t~at tte organization
:s,r:-;;vr:dPc; a gu,;_lr:fyi:19 c;prvicp. S-;;, unlpc,c, t-_l:P bor:r:JwPr: prpc:p:1\-.c, nddr:t-_i,; :1al
evidence, 1 don' L L:·-unk .1L qua.l.1Iies.
Fr:-;;rn: =ii'illP FrPundPl [r·n· l-o:dfvpi;:]d,,<Jpl:P,'cti-l.•: rg] 0:1 BPl:,;_lf Of FPd::...:Jan PSLF
SenL: 'l'l _.1rsday,
0
Ap.t.11 11, 2Cl3 8:5U AM
To: l(b)(5) I
Cc::: Si:1ple-As:"1er, 3essie; Jol:::-ison, De:Obe; FedLoo.n ?SLF; ?oss, Io.n; Ninemire,
Sandra
Sul;,jpc;t-_: RP: hl\.RP
We :"10.ve ::-iot sent t:'lis o.pprovo.l yet. We'll hold it. Tl:o.::-iks
fr:,; [Tl:
To:
Cc::: "Foss, Ia:-i" <T"ln,Foss'""d,qo,,->, "l\inemire, Sandra"

<'.-)c,nrivi-l.NlllH"- vp~Jp.:J.go·J.>, "'.-)ipplp-hcil1Pr:, Bpc;c,ip"
< 132:_c;:_c;.i.e:::o . s .i.r:pl eAs:1e •· 'd ed. 'Jo,, >, "J o:'ln son, Deb be"
<I>:bb<c-. _ 2hnse::1,<l<c-d. qc,v>
Jate: 04/lC/2013 12:18 PM
A:::t·.10.ll\·, v-:e ::-ieed to v-:o.lk this one bo.ek. I tound o·.1t tL1t tl:e Leaal Cou::-isel
for the-~lderly is an indc:cendcnt offc:r.oot of the AARP. It is a 50l(c) (3),
b11t. WP C~llllOt. att-r:ibut-p its i-lC:tr:vit.iPs t.rJ t-l1p (c:) (!.,) t-1:nt. applr:Pd.
So, I'm going to reseo.r:::~ some more. Eo.ve v-:e sent the o.pproval yet?
In:1
C-n 1.,,1:;113 12:09 , l(b)(5) (b)(5) wrote:

~~-----"
.>D.1ane,
b)(5)
>Ia::1
>
>-----Or:iginnl MPc;c,~gp-----
.>l"rom: D.1ane C'reundel [r·c-. .11· .. c:c,,f•·e.1:1c,,e(Jr::1eaa.o··,J] On Ee:'!alI Of l•'edLoan
>PSLF
>Se:-it: u,,n~,"v M<'lrc:"1 18, 2013 2:49 ?M
>T-;; · l(b~)(e-5)~==-~I
0
.>Subjecl: AAP.?
(b)(5)
>(Sec attached file: AAR?.zip)

>
.>D.i.ane l"reundel
>Ccmplio.::-iee Servi:::es
>(717) 72:J-3207
>fax- (717) 720-?911
> ,:!r reun,:ie •3:che c.Gt • ,J rq

>Ttis message contains privileged a7ci co7fide7tial informatio7 inte7cied
>f.;;r t-.he a:C.:ovf-' addrf-'sc:ees only. If you naceivP t-_l:is mec;sagP in Pr:rrn
.>please de le Le or deslroy Lhis message a:18.ior aLLac:'!menLs.
>Tte sender of this message will f~lly coo:ceratc i7 the civil and
>cr:imir1nl pr:osPc:utiri11 of ar1y i11dividual f-'r1gagi11g i7 tl1e ·J11aut'.1cirizf-'d use
>of Lhis message.

t-.1:e a:C.:ovf-' addrPsc:ef-'s only. If you rPceivP t-_l:is message in Pr:ror plf-'ac:e
pr:,;;spcution -;;f any indiviriual Pngnging i:1 t-.he unaut.'.rnr:izf-'ri uc;f-' of Lnc:
messa9e.
and/or attachments.
Code:PHEAA
From: Foss Ian

To; Sydor Katherine: Smith Brian; Appel ,Jeff; Mahaftie Lynn; McLarnon Gail: Siegel Brian; Weisman Annmarie;
(b)(5)
Brian Siegel, please chime 11, if you ccrn add to this

To: Foss, Ian; Smith, Brian; Appel, Jeff; Mahaffie, Lynn; Mclarnon, Gail; Siegel, Brian; Weisman,
(b)(5)
From: Foss, Ian

(b)(5)
(b)(5)
Docs this change anyone's mind about the AB!\~

Project
Job Type: Full-Time
Job Description:

Exempt
PK11698
Hiring range: $43,800 - $47,400

Education
Experience
employment.
From: Smith, Brian

Th;rnks, Ian
from Jack Rives.
Brian
From: Foss, Ian

To: Smith, Brian
Hi Brian,
employer for PSLFis attached. It was from the borrower, not the ASA, itself.
Ian
From: Sydor Katherine

To; ~: Smith Brian; Appel ,Jeff; Mahaffie Lynn; McLarnon Gail; Siegel Brian; Weisman Annmarie: J.!!L...Jo..o.;
Kane Rachel: T1onqqu1co Rene: Ch1alastr1 Taneka
Subject: RE: ABA Documentat1on
Date: Friday, June 10, 201610:54:48 AM
b)(5)
From: Foss, Ian

(b)(5)

Project
Job Type: Full-Time
Job Description:

Exempt
PK11698
Hiring range: $43,800 - $47,400

Education
Experience
employment.
From: Smith, Brian

Thar1ks, Ian
I las FS;\/Fedloan Servicing responded to this borrov,.,iers request to "appeal the decision" that the
ABA is not an eligible employer for PSLFpurposes"? If so, I could reference that response {without
idenl1fyir1g Lhe specific borrower} ir1 Lhe response I'm draflir1g Lo lhe follow-up leller we received
from J;ick Rives.
Brian
From: Foss, Ian

To: Smith, Brian
H1Brian,
Ian
From: Foss Ian

To; Smith Brian; Appel ,Jeff: Mahaftie Lynn; McLarnon Gail: Siegel Brian: Sydor Katherine: Weisman Annmarie;
(b)(5)

Project
Job Type: Full-Time
Job Description:

Exempt
PK11698
Hiring range: $43,800 - $47,400


Education
Experience
employment.
From: Smith, Brian

Thanks, Ian
Has FSA/Fedloar1 Serv1c1ngre:,µor1ded Lo lhi:, borrowers requesl Lo "appeal Lhe decision" lhal Lhe
ABA 1snot an f'l1gible employer for PSLFpurposes I If so, I rnuld rf'ferencf' that rf'sponse (without
identifying the specific borrower) in the response I'm drafting to the follow up letter we received
from Jack Rives.
Brian
From: Foss, Ian

To: Smith, Brian
Hi Brian,
Ian
From: Siegel Brian

To; Sydor Katherine: fu&...!.a.!:l:
Smith Brian; Appel ,Jeff; Mahaffie Lynn; McLarnon Gail; Weisman Annmarie: l.J.1L
Jon: Kane Rachel: Tiongqu1co Rene: Chialasjri Taneka
b)(5)

To: Foss, Ian; Smith, Brian; Appel, Jeff; Mahaffie, Lynn; McLarnon, Gail; Siegel, Brian; Weisman,
(b)(5)
From: Foss, Ian

To: Smith, Brian; Appel, Jeff; Mahaffie, Lynn; McLarnon, Gail; Siegel, Brian; Sydor, Katherine; Weisman,
b)(5)
b)(5)
Does lhis change anyone's rnir1d aboul lhe ABA?

Staff Attorney - Children's
Job Title:
Project
Job Type: Full-Time
Job Description:

Exempt
PK11698
Hiring range: $43,800 - $47,400

Education
Experience
employment.
From: Smith, Brian


Th;rnks, Ian
from Jack Rives.
Brian
From: Foss, Ian

To: Smith, Brian
Hi Brian,
Ian
From: !(b)(5)
To; FedLoan PSLF ~---
Cc: Battle Cynthia: l{b)(5) I Tiongq11ico Rene
Subject: RE: American Public Transportation Association
H1Kim,
We will start our review.
I also wanted to update you ,1nd let you know that we ,1re meeting intern,1lly on the pending
employer escalations and should have an update to you next v,eck.
1
Thar1ks,
Taneka

To, !(bl(51 I
Hi Taneka! This one is a borrower dispute, so we are forwarding for review.
for the elderly.
Kimberly A Myers
Compliance Services
kmyers@pbeaa
oro
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; FedLoan PSLF
Cc: l{b)(5) I: Tiongquico Rene: Battle Cynthia
Subject: Re: Cherokee Nation Tribal Entites
Hi K1m1
Rene met with a larger policy group to discuss the Cherokee Nation Tribal Ent1t1esand few of
the other tribJI cJsinos we hJve pending. We believe the that the Cherokee Nation Tribal
entities: Cherokee Nation Technologies, CN MJnJgement & Consulting, and Cherokee NJtion
Business are qualifying employers for the purpose of PSLF The policy group determined that
these entities are governmental so whether the government entity is profit mJking or not
doesn't negate their governmental status
Thanks,
TanekJ

To: !(b)(51 I
From: l(b)(5J I
To: 'Fedloan PSLF'
b)(5)
Thanks,
Tanek;i

To: !(b)(51 I
b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; FedLoan PSLF
Date: Wednesday, August 17, 2016 11 :44:31 AM
H1 Kim,
(b)(5)
Th;rnks,
Taneka

To: !(bl(51 I
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: Utz Jon

To; Kane Rachel
The issues th,1t ,1re involved here are some1.'Jhatcomplicated, so I think 1t would be easier to discuss
in person Rachel, can we add this to the agenda for our loan issues meeting at 10:00 on Friday and
invite Rene and Lindsay-;,
From: Kane, Rachel

_fb)(5)
(b)(5)
Thanks,
Rachel

To: Utz, Jon
H1Jon,
We had a call on PLI Mailbox issues this morning and an interesting topic with a change in the
has a change in their dependency status (they either reached the age of 24 or they were pregnant
Thoughts?
-Rene
Rene Tiongquico
Federal Student Aid; Policy Liaison & Implementation
From: Kane Rachel

To; Tiqngquico Rene: l..!1L...J.o..!
Cc: Wertenberger Lindsay
b)(5)
Th;rnks for summ;rnzing, Rf'nf' Jeffs m,1in quf'st1on Sf'f'mf'd to he
(b)(5)
-

To: Utz, Jon
Hi Jon
Thoughts?
-Rene
Rene Tiongquico
From: Kane Rachel

To; l1lwllr!
Will do
From: Utz, Jon

To: Kane, Rachel
Cc: Tiongquico, Rene; Wertenberger, Lindsay; Baker, Jeff
The issues lhal are involved here are sornewhal cornplicaled, so I lhir1k il would be easier lo di:,cuss
in pnson R;ichf'I, c;in Wf' ;idd this to thf' ;igpnd;i for our lo;in issuf's mf'f'ting ;it 10:00 on Frid;iy ;ind
invite Rene and Lindsay?
From: Kane, Rachel

(b)(5)
Th;inks for summ;irizing, Rf'nf' Jpffs m,1in quf'st1on sef'mf'd to he
b)(5)
Thanks,
Rachel

To: Utz, Jon
Hi Jon
Thoughts?
-Rene
Rene Tiongquico
From: Kane Rachel

To; Tiqngquico Rene: Smith Brian: Siegel Brian: Hammond Cynthia: Baker ,Jeff; 1!.IL...,,!o_Q
Hi all,
Jeff and Rene's previous call is going long. We will initiJte this cJII once their previous meeting
wrap up.
Thanks,
Rc1chel
From: Kane, Rachel
Jon
When: Wednesday, September 21, 2016 1 :00 PM-1 :30 PM (UTC-05:00) Eastern Time (US & Canada).
• The Cherokee NJtion gJrning fJcility, Bordertown Casino We need to determine

whether the casino Is an enterprise of the tribe and thus a governmental (tribal) entity.
<< Message: FW: Outpost Casino>>
• The AARP They are clJirning thJt, while they are J 501(c)(4), not (c)(3), they
« Message· FW: AARP »
From: Utz Jon

To; Kane Rachel; Tiqngquico Rene; Hammond Cynthia
Are we still having this call?
From: Kane, Rachel
Jon; Mclarnon, Gail
When: Wednesday, September 21, 2016 1 :00 PM-1:30 PM (UTC-05:00) Eastern Time (US & Canada).
• The Cherokee Nation gaming fac1l1ty1 Bordertown Casino We need to determine

whether the cJsino is an enterprise of the tribe Jnd thus J governmental (tribal) entity.
« Message· FW: Outpost Casino>>
• The AARP They are claiming that, while they are a SOl(c)(-'1), not (c)(3), they
<< Message: FW: AARP >>
From: Baker Jeff

To; Tiongquico Rene: Kane Rachel
Cc: Smith Brian; Siegel Brian; Hammond Cynthia: !.!IL....J.o..!;
Weisman Annmarie
Ple,1se r;ill In at 1 ·1 .S, sorry.

Sent: Wednesday, September 21, 2016 1 :08 PM
To: Kane, Rachel
Cc: Smith, Brian; Siegel, Brian; Hammond, Cynthia; Baker, Jeff; Utz, Jon; Weisman, Annmarie
Subject: Re: Discuss Questions about Eligible Employers for PSLF
Finishing up a call at 115
Rene Tiongquico
[email protected]
###
On Sep 21, 2016, at 1:07 PM, Kane, Rachel <[email protected]> wrote:
Hi all,
Jeff and Rene's previous call is going long We will in1t1ate this call once their previous
meeting wrap up
Thanks,
Rachel
From: Kane, Rachel
To: Kane, Rachel; Tiongquico, Rene; Smith, Brian; Siegel, Brian; Hammond, Cynthia;
Baker, Jeff; Utz, Jon
When: Wednesday, September 21, 2016 1 :00 PM-1:30 PM (UTC-05:00) Eastern Time (US
& Canada).
Are the following organizations eligible employers for PSLFpurposes-;,
• The Cherokee N,1t1ongaming facility, Bordertown Casino We need to determine

v,hether the casino Is an enterprise oft he tribe and thus a governmental (tribal) entity.
1
« Message: FW: Outpost Casino>>

• The AARP They are claiming lhal, while Lhey are a SOl{c}{I)}, nol (c)(3), lhey provide
public servire for the elderly
« Message: FW: AARP >>

To; Tiqngquico Rene
Subject: RE: Email to OGG about Indian Casinos
111Rene,
Thar1k you for keeping rne updated. I'm goir1g Lo ':.end arI inv1Le for U'> lO rneel on nexl Thursday,
September 8 th to discuss a some of Pl I[1\1\'s outstanding employer escalations. If you arc unable to
meet I can check the calendar for the following week
H;ivf' ,1 good d;iy,
Taneka

Subject: Email to OGG about Indian Casinos
Taneka:
I want you to know that this is on my radar and we may discuss this in our policy meeting.
Additionally, I still have to reach out to OGC to inquire about the status of Indian casinos.
Rene Tiongquico
From: !(b)(5)
To; FedLoan PSLF
Cc: l{b)(5) I Tiongquico Rene; Battle Cynthia
Hi Kim,
b)(5)
We will need to escalate this for an additional review
(b)(5)
While we wait, would you be able to tell us how many borrowers have been approved under
the Fair Elections Legal Network and how long the oldest approval is for?
Thanks,
Taneka

<Fed [email protected]>
Sent: Friday, September 16, 2016 12:42 34 PM
To: !(bl(51 I
(b)(5)
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
-~-~
From: !(b)(5)
To; FedLoan PSLF; !(b)(5)
Subject: RE: Outpost Casino
H1 Kim,
b)(5)
hllp://wwvv borderlowr1cas1no corn/laq

https ·/ /vvww facebook.rnm/p;iges/Bordertov,m-Outpost-C;is1no/2188424114 77114

Sent: Thursday, August 11, 2016 12:09 PM
To: !(b)(51 I
Subject: Outpost Casino
Hi Tanekal
(b)(5)
Your assistance is appreciated. Password to follow.
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pbeaa
oro
(717) 720-2630
and/or attachments.
Code:PHEAA
From: Foss Ian

To; Tiqngquico Rene
Subject: RE: PSLF- AARP
Thank yuu!
-----Original Mes~age-----
Frurn: Tiongquicu, Rene
Sent: Wednesday, January 04. 2017 2:26 PM
To: Foss, Ian
Subject: RE: PSLF - i\i\RP
Frurn: Foss, Ian
Sent: Wednesday, January 04. 2017 2:15 PM
To: Tiungquico, Rene
Subject: PSLF - Ai\RP
Hey Rene,
I gather that we dealt with a PSLF employer escalation regarding i\ARP while I was away un detail. Could you
forward the last internal email with OPE/OGC abuut the i\ARP and PSLF?
Thanks,
Ian
From: Grebeldinger Beth

To; Tiqngquico Rene: Hammond Cynthia
Subject: RE: PSLF Control Letter
Attachments: Control Letter-DVicuna-Conqresswoman JudvChu 20 September 2016-RT edits BLG docx
Here are some suggested edits from me. Let me know how else I can assist. Thanks, heth

To: Hammond, Cynthia; Grebeldinger, Beth
Subject: PSLFControl Letter
Hi All:
Attached is the control letter regarding PSLFand whether an employer is an eligible employer. Based
on today's meeting, I am confirming that the employer 1sthe organization that pays the individual.
Please provide edits to me by COB, Friday 9/23/16. The control letter was directed to our office so
Jeff Baker is the signatory. Thank you!
-Rene Tiongquico
Rene T1ongqu1co
From: Grebeldinger Beth

To; Hammond Cynthia: Tiqngq11ico Rene
Subject: RE: PSLFControl Letter
Date: Friday, September 23. 2016 12:25:57 PM
Rene- Once you accept the changes you can forward the electronic version to me and I'll get it on
letterhead for Jeffs signature. Thanks for taking care of this. beth
From: Hammond, Cynthia

To: Grebeldinger, Beth; Tiongquico, Rene
I like Belh':, edib. Please accepl lhern arid lhen µre pare lhe leller for Jeff\ s1gnalure.
From: Grebeldinger, Beth

Sent: Thursday, September 22, 2016 9:16 AM
To: Tiongquico, Rene; Hammond, Cynthia
Here are some suggested edits from me. Let me know how else I can assist. Thanks, heth

To: Hammond, Cynthia; Grebeldinger, Beth
Subject: PSLFControl Letter
Hi All:
Attached is the control letter regarding PSLFand whether an employer is an eligible employer. Based
on today's meeting, I am confirming that the employer 1sthe organization that pays the individual.
Please provide edits to me by COB, Friday 9/23/16. The control letter was directed to our office so
Jeff Baker is the signatory. Thank you!
-Rene Tiongquico
Rene T1ongqu1co

To; Tiqngquico Rene
Subject: RE: PSLF Employer Escalation Meeting
Date: Thursday, June 30, 2016 3:05:19 PM
No, problem I'll send J new invite out shortly.
Sent: Thursday, June 30, 2016 2:47 PM
Subject: Declined: PSLF Employer Escalation Meeting
When: Thursday, July 14, 2016 2:00 PM-2:30 PM (UTC-05:00) Eastern Time (US & Canada).
Where: WDCUCP-T-62D7
Taneka:
I apologize but can we reschedule this meeting?
From: Utz Jon

To; Chialastri Taneka; Battle Cynthia; Tiongq11ico Rene
Subject: RE: PSLF issue involving ABA employees
Taneka, Cindy, and Rene-
See Lhe email below from Briar1 Siegel re la led Lo lhe ABA/PSLF issue lhal I believe you are all familiar
with (if not, let me knov,i) Can one of you provide the 1nform,1t1on that Brian 1sasking for? We v,muld
need this information by early next week at the latest, to allow time for OGC to draft a response. The
request for a legal opinion came from Ted Mitchell's office
Thanks
Jon
From: Siegel, Brian

To: Mclarnon, Gail; Smith, Brian; Utz, Jon
Subject: ABA
(b)(5)
Brian Siegel

To; Battle Cynthia: Tiongquico Rene
l.J..tL....J..Q;
Subject: RE: PSLFissue involving ABA employees
111Jon,
I will or1 pulling lhis 1nlorrnal1on loday.
Thanks,
Taneka
From: Utz, Jon

To: Chialastri, Taneka; Battle, Cynthia; Tiongquico, Rene
Subject: RE: PSLFissue involving ABA employees
Tanekil, Cindy, and Rene -
See the email below from Brian Siegel related to the ABA/PSLF issue that I believe you are all familiar
wilh (1f nol, lel rne know). Can one ol you provide Lhe ir1forrnalion lhal Brian is a:,king lor? We would
need this 1nform;it1on hy e;irly next week at the latest, to ;illov,/ time for OGC to draft a response. The
request for a legal opinion came from Ted Mitchell's office
Thar1ks
Jon
From: Siegel, Brian

To: Mclarnon, Gail; Smith, Brian; Utz, Jon
Subject: ABA
b)(5)
Brian Siegel

To; !(b)(5) I
Cc: Battle Cynthia: FedLoan PSLF;Tiqngquico Rene
Subject: Re: Re: MRP
Date: Tuesday, November 22, 2016 2:56:30 PM
Attachments: AARP Denial Letter-F1nal.docx
Hi Taneka! I apologize for the delay. Attached is the letter that was drafted for the AARP denial.
Since the request for review/dispute was from the AARP organization in general (and not for a specific
borrower), we responded to the individual who submitted the documentation. I didn't zip the file since
there is no specific borrower information. Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
I r0111 !(b)(5) lkb)(5)

I c• Fedloan PSLF <[email protected]>
C~ '"Battle. Cynthia'" <:[email protected]>, 'T1ongqu1co. Rene'" <:[email protected]>
Date 10107/2016 01 :25 PM
Si,,; ,xt [external]Re· AARP
Hi Kim,
OGC and FSAagree that AARP is not an eligible employer. Their primary function seems to be
to negotiate with vendors that provide services and/or discounts for their members.
Can you also forward the denial letter that will go out to the borrower for this escalation so
we can close out the escalated review.
Thanks,
Taneka
From: ~l(b~)(~5)~-~
Sent: Thursday, September 8, 20161:32 PM
To: Fedloan PSLF, l(b)(5) I
Cc: Battle, Cynthia, T1ongqu1co, Rene
Subject: RE AARP
'1.RllP1.vourl like to Pscalate th·s to the Offce of (Jenna Cou1sRI (OCC') We will <ee::i you poctRrl 011., rRSponse
I hanks,
T,111eka

To: !(b)(51 I
Subject: Fw: AARP
(b)(5)
Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
----- Forwarded by Kimberly A Myers/PHEAA on 09/06.-'201609:33 PM -
Frrnn !(b)(5)
5
1l(b)( ) I
I c- "Fedloan PSLF" <[email protected]>. !(b)(5)
01b)(5) 0 0 I
"Sipple-Asher, Bessie" <BessieKo SippleAsher@~e"d+'.g"oc,-,,c,,cJo
h"o"so"o",
o ,cbbc,c,,-<oDc,cbbc,c,cJo"h"os~on@ed
gov>, "Ninemire, Sandra'·
<Sandra. N [email protected]>
C~t" 04125/2013 11:06 AM
SL,8_cct RE: AARP
(b)(5)
Fr:-;;rn: =ii,;.np FrPundf-'l [r·n· l-o:dfvpi;:]d,.,<Jpl:<C-','cti-l.•:;rg] 0:1 BPl:,;.lf Of FPd::...~Ji-lll PSLF
Senl: 'l'l _.1rsday,
0
Ap.t.11 11, 2Cl3 8:5U AM
To: l(b)(5) I
Cc: Si~plc As~cr, Bessie; Jot~son, Dc~~c; FcdLoan PSLF; ?oss, Ian; Nincmirc,
Snndra
Subjecl: P.e: _A_A_P.P
We :"10.ve ::-wt sent t:'lis o.pprovo.l yet. We'll hold it. Tl:o.:1ks
Fr:-; rn:
To:
Cc: "Foss, Ia:1" <T"ln,Fcss'""d,qn,,->, "l\inemirc, Sandra"

<Sn:1~ivn. N- llPr" iu.,<Jpd. go\->, "Sipplp-J1:,hpr:, Bpc,c;if-'"
<Ee. 0;:_c;-1eY.o.:o.i.r:r: eAsLe"" 0 ed.gov>, "Jof'_:1son, De:Cbe"
< lel:,be. J2:1nscL('.'ed. c2v>
Jate: 04/lC/2013 12:18 PM
b)(5)
So, I'm going to reseo.r2~ some more. Eo.ve v,:e sent the o.pproval yet?
In:1
C-n i.,/:";113 12:09 , l{b)(5) (b)(5) wrote:

-~-----"
.>D-1ane,
(b)(5)
>Ia:1
>
>-----Or:iginnl MPc;c,,;_gp-----
.>l"rom: D-1ane C'reundel [r·c-.-11·__c:c,.f•·e.1:1c,.e(Jr::1eaa.o··,J] On Ee:'!alI OI l•'edLoan
>PSLF
>Sc:it: u,,n~,"v M,arc:"1 18, 2013 2:49 ?M
>T-;; · .l(b~)(~5)~---~I
.>Subjecl: AAP.?
(b)(5)
.>D.i.ane l"reundel
>Ccmplio.:1ce Servi2es
>(717) 72:J-3207
>fax- (717) 720-?911
>dILeundc~pheaa.OLC
>Tl:is messo.ge contains privileged c1:1ci.20:1tide:1tio.l intormo.tio:1 inte:1ci.ed
>for the a:Cove addressees only. If you receive tLis message in error
>plf-'iiC:P dPlPt.f-' or df-'c,t-_r:,;;y t-_hic, mpc;c,,;_gp n:1~i/or: at.t-.nc:'.1mPnt.c,.
>Ttc sender of this message will f~lly coo~eratc i7 the civil and
>~rimir1nl prosec:utiri11 of ar1y i11dividual e11gagi11g i7 tl1e ·J11aut'.1cirized use
>of Lhis message.

t-.1:e a:C.:ove addressees only. If you receive t-_l:is message in error please
delele or deslroy L:.-..1s message and/or aLLachmenls.
pr-;;secution -;;f any indiviriual engnging i:1 t-.he unaut.'.rnrizeri uc;e of Lns
messa9e.
and/or attachments.
Code:PHEAA

To; !(b)(5) I
Subject: Re: Re: Cherokee Nation Tribal Ent1tes
Date: Tuesday, October 11, 2016 9:03:17 AM
Attachments: Cherokee Nation Technology Solutions - FSA Response.pd!
Hi Taneka! Thanks for your review and follow-up. I will take care of the below organizations.
b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
I ro111 !(b)(5) lkb)(5)

I c• Fedloan PSLF <[email protected]>
!(b)(5) I
!(b)(5) I
"Tiongquico, Rene" <[email protected]>, '"Battle. Cynthia"
<Cynthia [email protected]>
C~llc 10107/2016 02:10 PM
[external]Re: Cherokee Nation Tribal Entites
Hi Kim,
(b)(5)
Thanks,
Taneka

To: l(b)(5) I
From: ~l(b~)(5~1--~
To: 'Fedloan PSLF'
11l(1rn,
b)(5)
Th;rnks,
TanekJ

To: !(b)(51 I
(b)(5)
Kimberly A Myers
Compliance Services
kmyers@pbeaa
oro
(717) 720-2630
and/or attachments.
Code:PHEAA

To; !(b)(5) I
Subject: Re: Re: Fair Elections Legal Network
Hi Taneka! We only have record of this one borrower being approved under the Fair Elections Legal
Network, and it was approved on 3/5/12. Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

C~ !(b)(5) !(b)(5) I I
"T1ongquico, Rene" <[email protected]>, '"Battle. Cynthia"
<[email protected]>
Date 1010712016 01 :09 PM
SL,8_cct [external]Re. Fair Elections Legal Network
Hi Kim,
(b)(5)
Thanks,
Taneka

To: l(b)(5) I
b)(5)
decision. I included our original research as well as our email exchange with Ian.
Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; FedLoan PSLF
Thanks Kim.
Have a good weekend!

To: !(bl(51 I
Cc: Battle, Cynthia; Fed Loan PSLF;Tiongquico, Rene
Subject: Re Re: Fair Elections Legal Network
Network, and it was approved on 3/5/12. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

Tn FedLoan PSLF <FedloanPSLF@pheaa org>
C8 l{bj/5) I
!(b)(5) I
"'T1ongquico. Rene"' <[email protected]>. '"Battle. Cynthia"'
<[email protected]>
I :-aIe 10/0712016 01 :09 PM
SL,8_cct [external]Re. Fair Elections Legal Network
Hi Kim,
(b)(5)
Thanks,
Taneka
To: l(b)(5) I
Hi Tanekal This employer was last reviewed in March 2012 (during the beginning stages of our PSLF
reviews). We had escalated this one and Ian approved as private not-for-profit, and we categorized it
under public interest legal services.
We now received a recent escalation of this employer. Now knowing more on the public interest legal
services category, we don't believe this employer should qualify. We wanted to escalate to you for a
Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; Kimberly A Myers
Cc: Diane Freundel: Qhialastri Taneka: Tiongquico Rene: Battle Cynthia: FedLoan PSLF;l~lb~J(~5)_~
Subject: Re: Re: PSLF - American Bar Association
Hi Kim,
(b)(5)
Thanks,
Taneka

Sent: Wednesday, April 13, 2016 8 34 28 AM
To: Foss, Ian
Cc: Diane Freundel, Chialastri, Taneka
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
I r0111 '"Foss. Ian" [email protected]>
Tn Kimberly A Myers <kmyers@pheaa org>
C~llc 04113/2016 08:42 AM
(b)(5)
Hi Ian!
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
C~llc 04108/2016 02:56 PM
b)(5)

To: Foss, Ian
(b)(5)
Thanks!
Kimberly A Myers
Compliance Services
kmyers@J;Jheaa.onJ
(717) 720-2630

Dc1l~ 04/08/2016 12:02 PM
(b)(5)
TanekJ
From: Foss, Ian

Hello all,
(b)(5)
Thanks,
and/or attachments.
Code:PHEAA

To; !(b)(5) I
Subject: Re: Re: Re: Fair Elections Legal Network
Hi Taneka! Just wanted to follow-up on this one as well. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

I:-aIe 10/0712016 03:35 PM
SL,,;p;l [external]Re. Re: Fair Elections Legal Network
Thanks Kim.

To: l(b)(5) I
Cc: Battle, Cynthia, Fedloan PSLF,Tiongquico, Rene
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From kb)/5) lkb)(5)

Tn Fedloan PSLF <FedloanPSLF@pheaa org>
C~ !(b)(5) I
!(b)(5) I
"'T1ongquico. Rene"' <[email protected]>. '"Battle. Cynthia"'
<Cynthia, [email protected]>
I :-aIe 10/0712016 01 :09 PM
[external]Re. Fair Elections Legal Network
Hi Kim,
(b)(5)
Thanks,
Taneka

To: l(b)(5) I
Hi Taneka! This employer was last reviewed in March 2012 (during the beginning stages of our PSLF
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA

To; !(b)(5) I
Cc: Battle Cynthia: Diane Freundel: FedLoan PSLF; Tiongquico Rene: Chialastri Taneka
Subject: Re: Re: Re: PSLF- American Bar Assoc1at1on
PSLF_Oct_07
ThanksI
Kim
Frrnn !(b)(5) lkb)(5)

C~ Diane Freundel <[email protected]>, "Chialastri, Taneka" <Taneka [email protected]>. "Tiongquico, Rene"==-~
<[email protected]>. "Battle, Cynthia"' <[email protected]>, Fedloan PSLF <[email protected]>, 01{b 0 )0(5")-~
l{b)(5)
C~llc 10107/201610:28 AM
Si,,; ,xt [external]Re· Re: PSLF - American Bar Association
Hi Kim,
(b)(5)
Thanks,
Taneka

Sent: Wednesday, April 13, 2016 8:34.28 AM
To: Foss, Ian
Cc: Diane Freundel; Ch1alastr1,Taneka
Subject: Re: Re. PSLF- American Bar Assoc1at1on
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
I ro111 "Foss. Ian" [email protected]>
Tc- Kimberly A Myers <[email protected]>
Diane Freundel <[email protected]>, "Chialastri, Taneka'· <[email protected]>
I :-aIe 04/13/2016 08:42 AM
Si,,; ,xt [external]Re· PSLF - American Bar Assoc1at1on

(b)(5)
Hi Ian!
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Frrnn '"Foss. Ian" -dan [email protected]>
Tc- '"'Kimberly A Myers"" <[email protected]>
C~ Diane Freundel <[email protected]>, "Chialastn, Taneka" <Taneka [email protected]>
I :-aIe 04/08/2016 02:56 PM
SL,8_cct [external]RE: RE. PSLF - American Bar Association
I h s s supe' helptu I ha~,ks, <m.
Cc111
you give rnc cl seI1~c of how rnc1I1vl)()rrower~ received cl rel"clclI0°·, Tgcird111g lhe AB1\ clnd how rnc1",Vreceived
outright de~,ials' Also, tor those retracted, how long after the ap:iroval did the retr:iction go out ,:tor the :io"ower
for wl101T1·l wcls lhe lo",gc~l)":'

To: Foss, Ian
(b)(5)
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From '"Ch1alastri. Taneka"' <[email protected]>

Tn "Foss, Ian"' <Ian [email protected]>. Diane Freundel <dfreunde@pheaa orq>. '"Kimberly A Myers"" <[email protected]>
C~llc 04108/201612:02 PM
SL,8_ cct [external]RE: PSLF - American Bar Association
(b)(5)
Thanks,
T,,neka
From: Foss, Ian

Subject: PSLF- American Bar Association
Hello all,
(b)(5)
Thanks,
lac
and/or attachments.
Code:PHEAA

To; !(b)(5) I
Cc: Battle Cynthia: Diane Freundel: FedLoan PSLF; Tiongquico Rene: Chialastri Taneka
Subject: Re: Re: Re: PSLF - American Bar Assoc1at1on
Attachments: American Bar Assoc1at1on.zip
u;
I ' " ... 0
.
b)(5)
If there is anything else you need, please do not hesitate to ask. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

C8 Diane Freundel <[email protected]>, '"Chialastn.Taneka'"<[email protected]>. "'Tiongquico. Rene" ==-- 7
<[email protected]>. "Battle, Cynthia" <Cynthia [email protected]>, Fedloan PSLF <[email protected]>, 0 0)0(5")
1{b __ J
!(b)(5) I
Date 10107/2016 10:28 AM
SL,8_
cct [external]Re. Re: PSLF - American Bar Association
Hi Kim,
b)(5)
My apologies for having to request this on a Friday but if your team can pull this information
as soon as possible we would appreciate it. Please let me know if you have concerns.
Thanks,
Taneka

Sent: Wednesday, April 13, 2016 8:34:28 AM
To: Foss, Ian
Subject: Re: Re: PSLF- American Bar Association
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Frrnn '"Foss. Ian" [email protected]>
1c• Kimberly A Myers <[email protected]>
C~ Diane Freundel <[email protected]>, "Chialastri, Taneka'" <Taneka [email protected]>
Dc1I~ 04/13/2016 08:42 AM
SL,8_cct [external]Re. PSLF-Amencan Bar Assoc1at1on
(b)(5)
Hi Ian!
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From "Foss. Ian" <[email protected]>
Tn "'Kimberly A Myers"' <kmyers@pheaa org>
~;~ Diane Freundel <[email protected]>, "Chialastri, Taneka" <[email protected]>
Date 04/08/2016 02:56 PM
s,.,1.
~'t [external]RE: RE: PSLF - American Bar Association
C;rn vou 1:,iveme a sense at how many borrm~'ers received a ret'actio~, 'e1:,arding the M31\and how m:Viy received
outright dr11als' Alco. for thoc:r rf'trartrd, hO\Nlong aftn tlw ap::iroval did tlw rrtr,,ct1011 go out (forthP :)O"O'Nf'r
tor 'Nhom twas the 10~,gest)?
From: Kimberly A Myers [mailto:[email protected]]

To: Foss, Ian
Subject: Re: RE: PSLF- American Bar Association
(b)(5)
b)(5)
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pbeaa
oro
(717) 720-2630
Frrnn '"Chialastri, Taneka"'< Taneka Qhialastri@ed gov>

I :-aIe 04/08/2016 12:02 PM
Sr.,1.~,t [external]RE: PSLF -American Bar Association
b)(5)
TanekJ
From: Foss, Ian

Hello all,
Can you summarize for me what we've done regarding PSLFand the American Bar Assoc1at1on?We Just got a letter
saying we approved them and then retracted it several years later. I'm not finding record that I worked on it
personally, but that doesn't mean its so.
Thanks,
lac
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; FedLoan PSLF
Cc: Battle Cynthia: Diane Freundel: Tiongquico Rene: Chialastri Taneka: UlL.J..o.D.;
.kb~J(~5)~~
Subject: Re: Re: Re: PSLF - American Bar Assoc1at1on
Hi Kim,
We really appreciate the quick turnaround on this information.
(b)(5)
Thank you,
Taneka

Sent: Friday, October 7, 2016 12·26'29 PM
To: !(b)(51 I
Cc: Battle, Cynthia; Diane Freundel, FedLoan PSLF;Tiongquico, Rene; Chialastri, Taneka
Subject: Re, Re: Re, PSLF- American Bar Association
Hi Tanekal I was able to pull together the information you requested (no pressure for a mid-Friday) : )
(b)(5)
If there is anything else you need, please do not hesitate to ask. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From
j(b)(5)
!(b)(5)
C~ Drane Freundel <[email protected]>, "Chialastri, Taneka'" <Taneka [email protected]>."Tiongquico, Rene"---~
<[email protected]>. "Battle, Cynthia"' <[email protected]>, Fedloan PSLF <[email protected]:>,!(b")"(5")-~
0
<[email protected]:>
Date 1010712016 10:28 AM
Si,,; ,xt [external]Re· Re: PSLF - American Bar Association
Hi Kim,
(b)(5)
Thanks,
Taneka

To: Foss, Ian
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
C~ Drane Freundel <[email protected]>, '"Chialastn. Taneka'" <[email protected]>
Dc1l~ 04/13/2016 08:42 AM
SL,,;_ecl [external]Re. PSLF - American Bar Association

b)(5)
Hi Ian!
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
I r0111 "Foss. Ian" [email protected]>
Diane Freundel <[email protected]>, "Chialastri, Taneka" <Taneka [email protected]>
Date 04/08/2016 02:56 PM
Si,,; ,xt [external]RE: RE· PSLF - American Bar Association
b)(5)

To: Foss, Ian
Subiect: Re: RE: PSLF- American Bar Association
(b)(5)
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From '"Ch1alastri.Taneka"' <[email protected]>

C~llc 04108/201612:02 PM
(b)(5)
Thanks,
T,,neka
From: Foss, Ian

Hello all,
(b)(5)
Thanks,
lac
and/or attachments.
Code:PHEAA

To; !(b)(5) I
Cc: Battle Cynthia: Diane Freundel: FedLoan PSLF; illL....J.Q.o.;
Tiongq11ico Rene: Chialastri Taneka
Subject: Re: Re: Re: Re: PSLF- American Bar Assoc1at1on
(b)(5)
Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
I ro111 !(b)(5) lkb)(5)

Tc- Fedloan PSLF <[email protected]>
r;~ "Battle, Cynthia" <[email protected];,, Diane Freundel <[email protected]>, "Tiongquico. Rene,"·~--,
<[email protected]>."'Ch1alastr1,Taneka'" <[email protected]>. '"Utz, Jon'" <[email protected]>. 0!(b~J(~5~)
-~
!(b)(5)
Dc1l~ 10/07/2016 01 :47 PM
SL,,;_ecl [external]Re. Re: Re: PSLF - American Bar Association
Hi Kim,

(b)(5)
Thank you,
Taneka
From: Kimberly A Myers <[email protected]> on behalf of Fedloan PSLF<[email protected]>

To: l(b)(5) I
Cc: Battle, Cynthia, Diane Freundel, Fedloan PSLF,Tiongquico, Rene, Chialastri, Taneka
Subject: Re: Re: Re PSLF-American Bar Association
Hi Taneka! I was able to pull together the information you requested (no pressure for a mid-Friday) : )
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
I r0111 !(b)(5) lkb)(5)

1c- Kimberly A Myers <[email protected]>
-~-~
Diane Freundel <[email protected]>, "Chialastri, Taneka'· <[email protected]>. "Tiongquico, Rene"==-~
<[email protected]>. "Battle, Cynthia"' <[email protected]>, Fedloan PSLF <[email protected]>, !(b)(5)
!(b)(5)
Dc1l~ 10/07/2016 10:28 AM
s,.,1_~,
t [external]Re: Re: PSLF -American Bar Association
Hi Kim,
b)(5)
b)(5)
Thanks,
Taneka

To: Foss, Ian
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Frrnn ''Foss. Ian" [email protected]>
C~ Diane Freundel <[email protected]>, "Chialastri, Taneka" <Taneka [email protected]>
I :-aIe 04/13/2016 08:42 AM
b)(5)
Hi Ian!
b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Frrnn '"Foss. Ian" -dan [email protected]>
C~ Diane Freundel <[email protected]>, "Chialastn, Taneka" <Taneka [email protected]>
I :-aIe 04/08/2016 02:56 PM
(b)(5)
From: Kimberly A Myers (mailto:[email protected]]

To: Foss, Ian
Subiect: Re: RE: PSLF- American Bar Association
(b)(5)
b)(5)
ThanksI
KimberlyA Myers
Compliance Services
[email protected]
(717) 720-2630
I ro111 '"Chialastri. Taneka"' <[email protected]>

Tc- '"Foss. Ian"' [email protected]>. Diane Freundel <:[email protected]>. ""Kimberly A Myers"" <[email protected]>
Date 04/08/2016 12:02 PM
SL,,;_ecl [external]RE: PSLF - American Bar Association
b)(5)
I hanks,
I ;rneka
From: Foss, Ian

Hello all,
b)(5)
Thanks,
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; FedLoan PSLF
Cc: Battle Cynthia: Diane Freundel: !J.1.....J..Q.o;
Tiongquico Rene: Chialastri Taneka
Subject: Re: Re: Re: Re: PSLF- American Bar Assoc1at1on
Date: Wednesday, October 12, 201610:10:59 AM
Hi Kim,
Thanks again for pulling information regarding the American Bar Association.
b)(5)
Kind Regards,
Taneka

Sent: Friday, October 7, 2016 1;52 PM
To: !(bl(51 I
Cc: Battle, Cynthia; Diane Freundel; FedLoan PSLF;Utz, Jon; Tiongquico, Rene; Chialastri, Taneka
Subject: Re Re; Re Re; PSLF- American Bar Association
b)(5)
Business Unit to "beef" up the denial letters. Any suggestions you have would also be appreciated.
Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

Tn Fedloan PSLF <FedloanPSLF@pheaa org>
C~ "=~-,
"Battle, Cynthia" <Cynthia.Battle@ed gov>, Diane Freundel <[email protected]>, "Tiongquico, Rene,
0
<[email protected]>. "Chialastri, Taneka" <Taneka.Chialastn@ed gov>, "Utz, Jon" <[email protected]>, !(b~J(~5L)
0 -~
!(b)(5)
Dc1l~ 10/07/2016 01 :47 PM
SL,,;_ecl [external]Re. Re: Re: PSLF - American Bar Association
Hi Kim,

b)(5)
Thank you,
Taneka

To: l(b)(5) I
Subject: Re: Re: Re PSLF- American Bar Association
b)(5)
If there is anything else you need, please do not hesitate to ask. Password to follow. Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From !(b)(5)

Diane Freundel <[email protected]:>,"Chialastri, Taneka'· <[email protected]>. "Tiongquico, Rene"---~
<[email protected]>. "Battle, Cynthia"' <[email protected]>, Fedloan PSLF <[email protected]>,!(b")"(5")-~
0
!(b)(5)
I:-aIe 10/071201610:28 AM
SL,8_cct [external]Re. Re: PSLF - American Bar Association
Hi Kim,
(b)(5)
(b)(5)
Thanks,
Taneka

To: Foss, Ian
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Dc1l~ 04/13/2016 08:42 AM
b)(5)
(b)(5)
Hi Ian!
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Date 04/08/2016 02:56 PM
Si,,; ,xt [external]RE: RE· PSLF - American Bar Association
I h s s supe' helptu I ha~,ks,<m.
(b)(5)

To: Foss, Ian
b)(5)
(b)(5)
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From '"Ch1alastri.Taneka"' <[email protected]>

C~llc 04108/201612:02 PM
b)(5)
Thanks,
I ;rneka
From: Foss, Ian

Hello all,
b)(5)
Thanks,
lac
and/or attachments.
Code:PHEAA
-~-~
To; "FedLoan PSLF"; l{bj(5)
Cc: Battle Cynthia: Diane Freundel: !J.1.....J..Q.o;
Tiongquico Rene
Subject: RE: Re: Re: Re: Re: PSLF - American Bar Association
Date: Wednesday, October 12, 2016 11 :22:20 AM
H1 Kim,
b)(5)
Th;rnks,
Taneka
b)(5)
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From l{bj(5) I b)(5)

~;~ "Battle, Cynthia" <[email protected]>, Diane Freundel <[email protected]>, "Utz. Jon"' <[email protected]>. "Tiongquico,
Rene" <eReneT1ongqu1co@edgov>, "'Ch1alastri,Taneka'" <Taneka [email protected]>
C~llc 10112/201610:11 AM
SL,8_cct [external]Re. Re: Re: Re. PSLF-Amencan Bar Assoc1at1on
Hi Kim,
b)(5)
If you have any concerns or questions please let me know.
Kind Regards,
Taneka

Sent: Friday, October 7, 2016 1:52 PM
To: l(b)(5) I
Cc: Battle, Cynthia, Diane Freundel, Fedloan PSLF, Utz, Jon; T1ongqu1co, Rene; Ch1alastr1,Taneka
Subject: Re: Re: Re Re: PSLF- American Bar Association
b)(5)
ThanksI
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From !(b)(5) l(b)(5)

I c• FedLoan PSLF <[email protected]>
"Battle, Cynthia" <Cynthia.Battle@ed gov>, Diane Freundel <[email protected]>, "Tiongquico, Rene "=~-,
0
<:[email protected]>, "Chialastri, Taneka" <:[email protected]>, '"Utz, Jon" ,[email protected]>, !(b~)(~5L)
0 -~
<publ•cservice@ed gov>
I :-aIe 10/0712016 01 :47 PM

SL,,;p;l [external]Re. Re: Re; PSLF - American Bar Association
Hi Kim,
b)(5)
Thank you,
Taneka
From: Kimberly A Myers <[email protected]::, on behalf of Fed Loan PSLF<[email protected]>

To: l(b)(5) I
Cc: Battle, Cynthia, Diane Freundel, Fedloan PSLF, Tiongquico, Rene, Chialastri, Taneka
Subject: Re: Re: Re PSLF - American Bar Association
Hi Tanekal I was able to pull together the information you requested (no pressure for a mid-Friday) : )
b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
I ro111 !(b)(5)

C8 Diane Freundel <[email protected]>, '"Chialastn.Taneka"'<[email protected]>. "'T1ongquico. Rene"'==-~
<[email protected]>. "'Battle. Cynthia"' <[email protected]>. Fedloan PSLF <[email protected]> .•kb"l"/5"1-~
!(b)(5)
C~llc 10107/201610:28 AM
SL,8_cct [external]Re. Re: PSLF - American Bar Association
Hi Kim,
(b)(5)
as soon as possible we would appreciate it. Please let me know if you have concerns.
Thanks,
Taneka

To: Foss, Ian
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pbeaa
oro
(717) 720-2630
Date 04/13/2016 08:42 AM


b)(5)
Hi Ian!
b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
~;~ Diane Freundel <[email protected]>,

"Chialastri, Taneka" <[email protected]>
Date 04/08/2016 02:56 PM

(b)(5)

To: Foss, Ian
(b)(5)
(b)(5)
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From "Chralastri, Taneka" <Taneka Chralastrr@ed gov>

Dc1l~ 04/08/2016 12:02 PM
(b)(5)
TanekJ
From: Foss, Ian

Hello all,
b)(5)
Thanks,
lac
and/or attachments.
Code:PHEAA

To; !(b)(5) I
Cc: Battle Cynthia: Diane Freundel: FedLoan PSLF; illL....J.Q.o.;
Tiongq11ico Rene: Chialastri Taneka
Subject: Re: Re: Re: Re: Re: PSLF - American Bar Association
Date: Wednesday October 12 201610·43·18 AM
(b)(5)
Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
I ro111 !(b)(5) lkb)(5)

r;~ "Battle, Cynthia" <[email protected];,, Diane Freundel <[email protected]>, "Utz. Jon·· <[email protected];,. '"Tiongquico,
Rene" <Rene T1ongqu1co@edgov>, "'Ch1alastri,Taneka'" <Taneka [email protected]>
Dc1l~ 10/12/2016 10:11 AM
s,.,1_
~'t [external]Re: Re: Re: Re: PSLF - American Bar Association
Hi Kim,
b)(5)
(b)(5)
Kind Regards,
Taneka

To: l(b)(5)
Cc: Battle, Cynthia, Diane Freundel, Fedloan PSLF,Utz, Jon; Tiongquico, Rene; Chialastri, Taneka
(b)(5)
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From kb)/5) lkb)(5)

C~ "Battle, Cynthia" <Cynthia.Battle@ed gov>, Diane Freundel <[email protected]>, "Tiongquico, Rene"=~-,
0
<[email protected]>. "Chialastri, Taneka" <[email protected]>, ·utz, Jon" <[email protected]>, !(b~)(~5L)
0 -~
!(bj(5)
Dc1l~ 10/07/2016 01 :47 PM
SL,8_
cct [external]Re. Re: Re: PSLF - American Bar Assoc1at1on
Hi Kim,
b)(5)
Thank you,
Taneka

To: l(b)(5) I
Subject: Re: Re: Re PSLF-American Bar Association
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

r;~ Diane Freundel <[email protected]>, "Chialastri, Taneka'" [email protected]>. "Tiongquico, Rene"
<[email protected]>."'Battle. Cynthia"' <[email protected]>. Fedloan PSLF <[email protected]>, "kb"l"l5"1-~
!(b)(5)
Date 10107/2016 10:28 AM
Sr.,1.~,t [external]Re: Re: PSLF -American Bar Association
Hi Kim,
(b)(5)
Thanks,
Taneka

To: Foss, Ian
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Dc1l~ 04/13/2016 08:42 AM

b)(5)
Hi Ian!
b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
I ro111 '"Foss. Ian" [email protected]>
C~llc 04108/2016 02:56 PM
(b)(5)

To: Foss, Ian
b)(5)
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pbeaa
oro
(717) 720-2630

I :-aIe 04/08/2016 12:02 PM
Sr.,1.~,t [external]RE: PSLF -American Bar Association
(b)(5)
TanekJ
From: Foss, Ian

Hello all,
(b)(5)
Thanks,
lac
and/or attachments.
Code:PHEAA

To; !(b)(5) I
Cc: Battle Cynthia: Diane Freundel: "FedLoan PSLF"';l.J.1L....J.o..;
Tiongquico Rene
Subject: Re: RE: Re: Re: Re: Re: PSLF- American Bar Association
Date: Monday, October 17, 2016 9:57:59 PM
b)(5)
Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

I c•
"""~~~.,c-"""c=~---
"'Fedloan PSLF""'<[email protected]>. !(b)(5) l!(b)(5)
"Battle,Cynthia"<[email protected]>, Diane Freundel <[email protected]>, "Utz, Jon·' <[email protected]>. '"Tiongquico,
Rene'"<[email protected]>
C~llc 10117/201603:52 PM
Si,,; ,xt [external]RE: Re: Re· Re: Re: PSLF - American Bar Assoc1at1on
7i Kim,
just wanted to tollm~' u:i tot nd out it you were a:ile to thd out the aver:ise numbe' ot 'etractions that are ssued
b)' .)H=1\/\
Thanks,

Sent: Wednesday, October 12, 2016 11 :22 AM
To: 'Fedloan PSLF'; l(b)(5J I
Cc: Battle, Cynthia; Diane Freundel; Utz, Jon; Tiongquico, Rene
Subject: RE: Re: Re: Re: Re: PSLF- American Bar Association
b)(5)
b)(5)
Th;rnks,
TanekJ
(b)(5)
ThanksI
KimberlyA Myers
Compliance Services
[email protected]
(717) 720-2630
I r0111
I c•
-~-~
!(b)(5) I.c:;[email protected],-
FedLoan PSLF <[email protected]>
"Battle, Cynthia" <Cynthia.Battle@ed gov>, Diane Freundel <[email protected]>, "Utz, Jon·' <[email protected]>. "Tiongquico,
Rene" <Rene T1ongqu1co@edgov>, "'Ch1alastri,Taneka'" <Taneka [email protected]>
C~llc 10112/201610:11 AM
SL,8_cct [external]Re. Re: Re: Re. PSLF-Amencan Bar Assoc1at1on
Hi Kim,
b)(5)
b)(5)
Kind Regards,
Taneka
From: Kimberly A Myers <[email protected]::, on behalf of Fed Loan PSLF<[email protected]>

To: l(b)(5)
Cc: Battle, Cynthia, Diane Freundel, Fedloan PSLF,Utz, Jon; Tiongquico, Rene; Chialastri, Taneka
(b)(5)
Thanks!
KimberlyA Myers
Compliance Services
[email protected]
(717) 720-2630
I ro111 0 -~I
kb~J(~5~) <[email protected]>

C~ '"Battle. Cynthia" <[email protected]>, Drane Freundel <[email protected]>, 'T1ongqu1co. Rene'"
7 7
<[email protected]>,"Chialastrr, Taneka" <eTaneka.Chialastn@ed gov>, '"Utz, Jon" <[email protected]>, "l{b
)/~5) -~
!(b)(5)
Date 10107/201601:47 PM
SL,,;.ecl [external]Re. Re: Re; PSLF - American Bar Association
Hi Kim,
b)(5)
Thank you,
Taneka

To: l(b)(5) I
Cc: Battle, Cynthia, Diane Freundel, Fedloan PSLF,T1ongquico, Rene, Chialastri, Taneka
Subject: Re: Re: Re PSLF- American Bar Association
(b)(5)
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
To Kimberly A Myers <kmyers@pheaa org>

Diane Freundel <[email protected]>, "Chialastri, Taneka" <Taneka [email protected]>, "Tiongquico, Rene"---~
<[email protected]>, "Battle, Cynthia"' <Cynthia [email protected]>, Fedloan PSLF <[email protected]>. !(b")"(5")-~
0
!(b)(5)
I:-aIe 10/071201610:28 AM
Sr.,1_~,
t [external]Re: Re: PSLF -American Bar Association
Hi Kim,
b)(5)
Thanks,
Taneka

To: Foss, Ian
Thanks!
Kimberly A Myers
Compliance Services
kmyers@pbeaa
oro
(717) 720-2630
Date 04/13/2016 08:42 AM

(b)(5)
Hi Ian!
(b)(5)
IO 111011(11:S 01 e111p1oy111011( \II 0111 0/LO I I co .JILO IL),
Kimberly A Myers
Compliance Services
kmyers@pbeaa oro
(717) 720-2630
I r0111 "Foss. Ian" [email protected]>
Date 04/08/2016 02:56 PM

I h s s supe' helptu I ha~,ks, <m.

(b)(5)
From: Kimberly AMyers[mailto:kmyers@J;Jheaa.oro]

To: Foss, Ian
(b)(5)
(b)(5)
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From "Chralastri, Taneka" <Taneka Chralastrr@ed gov>

Dc1l~ 04/08/2016 12:02 PM
"11la1,
b)(5)
Th;rnks,
I ;rneka
From: Foss, Ian

Hello all,
b)(5)
(b)(5)
Thanks,
and/or attachments.
Code:PHEAA

To; !(b)(5) I
Cc: Battle Cynthia: Diane Freundel: "FedLoan PSLF"';l.J.1L....J.o..;
Tiongquico Rene
Subject: Re: RE: Re: Re: Re: Re: PSLF - American Bar Association
(b)(5)
Please let me know if you have any questions. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From kb)/5) lkb)(5)

fo "'Fedloan PSLF""'<FedloanPSLF@pheaa org>. !(b)(5) lkbl/5) I
C~ '"Battle. Cynthia'" <[email protected]>, Diane Freundel <[email protected]>, '"Utz. Jon"' <[email protected]>. '"Tiongqu1co,
Rene" <[email protected]>
1:-a1e 10/1712016 03:52 PM
SL,,;p;l [external]RE: Re: Re. Re: Re: PSLF - American Bar Association
11l(1rn,
b)(5)
I hanks,
T,,neka

Sent: Wednesday, October 12, 2016 11 :22 AM
To: 'Fedloan PSLF'; l(b)(5J I
Cc: Battle, Cynthia; Diane Freundel; Utz, Jon; Tiongquico, Rene

Subject: RE: Re: Re: Re: Re: PSLF- American Bar Association
b)(5)
Thanks,
I ;rneka
b)(5)
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
~----<(b)(5)
From b 5
Tn Fe;d:L,:e~c~P~S~L~F~<Eiei!lloeeiic5J!B,!ji]iiecese:iiouc
i,,_j
C~ "Battle. Cynthia" <[email protected]>, Diane Freundel <[email protected]>, "Utz, Jon" <[email protected]>. "Tiongquico,
Rene" <Rene Tiqngquico@ed gov>, "'Chialastri, Taneka'· <Taneka [email protected]>
I :-aIe 10/1212016 10:11 AM
Sr.,1_ ~' t [external]Re: Re: Re: Re: PSLF - American Bar Association
Hi Kim,
I believe this already occurs, but wanted to confirm if all retractions of qualifying employment
for PSLFare routed to FSAfor review? If not, we would like to request that in the rare instance
PHEAAbelieves we need to retract an approval FSAis notified through this mailbox so that we
may review the circumstances of the retraction.
Moving forward, we would also like to review a copy of the retraction letter(s) before they are
sent to the borrower regarding their qualifying employment.
On this end, we are in the early stages of discussing ways that FSAcan improve StudentAid.gov
and other outlets to increase transparency regarding the PSLFprocess and eligiblity for non-
501(c)(3) employers providing qualifying public services. I'll make sure to provide PHEAAwith
an update as more information is available.
Kind Regards,
Taneka
From: Kimberly A Myers <kmyers(a!pheaa org> on behalf of Fed Loan PSLF<FedloanPSLF(a!pheaa.org>

To: l(b)(5) I
Cc: Battle, Cynthia, Diane Freundel, Fedloan PSLF, Utz, Jon; T1ongqu1co, Rene; Ch1alastr1,Taneka
Subject: Re: Re. Re Re: PSLF- American Bar Association
Hi Taneka! You are correct in you assumption for the retraction tab. The processed date is the date it
was approved. Essentially it all occurs in one step (the ECF is processed as an approval).
With the retraction letters, we had previously advised that the Business Unit that they need to include
more detail. Previously it was very generic (it just basically stated that the employer was retracted, but
didn't give much explanation as to why). It has gotten better. but we can certainly work more with the
Business Unit to "beef" up the denial letters. Any suggestions you have would also be appreciated.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Frrnn !(b)(5)

~;~ ·=~-,
"Battle, Cynthia" <[email protected];,, Diane Freundel <[email protected];,, "Tiongquico. Rene
0
<[email protected]>. "'Ch1alastrr,Taneka'" <[email protected]>. '"Utz, Jon'" <[email protected]> .•kb~)/~5~1-~
<[email protected]>
Date 10107/2016 01 :47 PM

SL,8_
cct [external]Re. Re: Re: PSLF - American Bar Assoc1at1on
Hi Kim,
b)(5)
Thank you,
Taneka
From: Kimberly A Myers <kmyers(a!pheaa org> on behalf of Fed Loan PSLF<FedloanPSLF(a!pheaa.org>

Sent: Friday, October 7, 2016 12.26.29 PM
To: l(b)(5) I
Cc: Battle, Cynthia, Diane Freundel, Fedloan PSLF;T1ongquico, Rene, Chialastn, Taneka
Subject: Re: Re. Re PSLF-American Bar Association
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Frrnn !(b)(5)
I c• Kimberly A Myers <[email protected]>

~;~ Diane Freundel <[email protected]>,"Chialastri Taneka" <[email protected]>,
"Tiongquico, Rene"
0 0
<[email protected]>,"Battle, Cynthia"'<[email protected]>, Fedloan PSLF <[email protected]>. ) (5°)-~
"!(b
<publ•cservice@edgov>
Date 10107/2016 10:28 AM

SL,,;_ecl [external]Re. Re: PSLF - American Bar Association
Hi Kim,
(b)(5)
(b)(5)
Thanks,
Taneka
From: Kimberly A Myers <kmyers(a!pheaa orfi>

To: Foss, Ian
Subject: Re: Re. PSLF-Amer1can Bar Assoc1at1on
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From "Foss. Ian" <[email protected]>
To Kimberly A Myers <krnyers@pheaa org>
~;~ Diane Freundel ,:;[email protected]>,

"Chialastri, Taneka" <[email protected]>
C~llc 04113/2016 08:42 AM

SL,8_cct [external]Re. PSLF-Arnencan Bar Assoc1at1on

(b)(5)
ones that came in directly from the ABA.
Hi Ian!
b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
~;~ Diane Freundel <[email protected]>,"Chialastri, Taneka" <[email protected]>
C~llc 04108/2016 02:56 PM

SL,8_
cct [external]RE: RE. PSLF - American Bar Association
(b)(5)

To: Foss, Ian
(b)(5)
(b)(5)
ThanksI
KimberlyA Myers
Compliance Services
[email protected]
(717) 720-2630

I c• "Foss, Ian·· <[email protected]:>. Diane Freundel <[email protected]:>. "'Kimberly A Myers"" <[email protected]>
I :-aIe 04/08/2016 12:02 PM
s,.,1.~,
t [external]RE: PSLF -American Bar Association
dori'l ',"WW,rnylh1ng 011record for lhe /\1T1er1cc1··,

B,ir 1\,souc1t1on I onlv lic1vedocu1T1enlc1l·o.., of dcu,·o ..,s ·11c1de
rega'dhg the King Cow,tv '.);n 1\ssoc :itio~,, 8ar Association at San f-'ancisco, State 8:i' ot \,',Jisconsin, ;i~,d the lJist' ct
of ColurnLic1:\cir
Thanks,
T.,neka
From: Foss, Ian

Hello all
(b)(5)
Thanks,
lac
and/or attachments.
Code:PHEAA
From: Sara M Preston on behalf of Fedloan PSLF

To; Tiqngquico Rene
Cc: Battle Cynthia: FedLoan PSLF; !(b
0 0 )0(5")-~
Subject: Re: RE: RE: RE: RE: United Nations Office of Project Service
Date: Wednesday, August 31, 2016 2:47:54 PM
Rene,
(b)(5)
Thank you,
Sara Preston
Assoc. Compliance Coordinator
Compliance Services
(717).720.2808
[email protected]
Frrnn '"Tiongquico, Rene'· <[email protected]>

7 7 0
To Fedloan PSLF <[email protected]>. "!(b")
(5")--"ll"(b 5")-----~
)(
r;~ "Battle, Cynthia" <[email protected]>

I :-aIe 08/30/2016 05:04 PM
SL,8_cct [external]RE: RE. RE: RE: United Nations Office of Project Service
S;c;r,,
1\ny update on whet~,er t~,e individual was a co~,tractor"?
From: Sara M Preston [mailto:[email protected]] On Behalf Of Fedloan PSLF

Sent: Wednesday, August 03, 2016 1 :58 PM
To: !(b)(51 I
Cc: Battle, Cynthia; Fedloan PSLF;Tiongquico, Rene
Subject: Re: RE: RE: RE: United Nations Office of Project Service
Hi Taneka,
We had located that number as well and informed the business unit. but it didn't seem to work either (it
gave some sort of error message). We heard back from the business unit again today after having them
reach out to the borrower for an accurate number, which he provided, however, the official is now on
vacation for two weeks (until 8/18/16). So it seems this one will be on hold for a little longer. We will keep
you updated.
Thank you,
Sara Preston
Compliance Services
(717).720.2808
[email protected]
From kb)/5) lkb)(5)

Tn Fedloan PSLF <FedloanPSLF@pheaa orgc'=~-,,=cc-------,
'"Battle. Cynthia'"<[email protected]>.l{bj/5) I
!(bj(5) I"Trongquico. Rene"
<[email protected]>
I :-aIe 08/03/2016 01 :26 PM
s,.,1.~' t [external]RE: RE: RE: United Nations Office of Project Service
7i S:ira,
t'.Rri to do a rRvnsP ook-up 01 t1R ::ihonP 11rnber t1,,t \Nas provided anrl I tli"n< that the Rmployn ::irov·derl a fax
num::ier (see belov11).If the 3us·ness Uri"le 1s unsuccessful 'idh emalng L·1ecerl1f1/ng offc."a, I believe you may be
ab e to reac~, t~,e Ms S les by calling 212-4'.J/-4000 or the ~,u·n:Jer listed on dealist O'S I han<s, 1a~,ek;i
http~://www.jrnu.edu/c1sr/ pages/re~ec1rch/grnar/scarch/unitcd nation~ office fur project services urrnps.shtrnl

http://www.1dealist.org/v1ew/nonprof1t/32FnZjh3PCJ74/

Sent: Wednesday, July 27, 2016 7:57 AM
To: Tiongquico, Rene
Cc: Battle, Cynthia; Fedloan PSLF;l~(b_)(5_1
__ ~
Subject: Re: RE: RE: United Nations Office of Project Service
Rene,
We found out that the phone number provided, and a subsequent phone number we located, for the
certifying official were not valid, so we have been unable to reach her so far. I requested that the business
unit attempt contact through email or through contacting the borrower to obtain a valid phone number for
the certifying official.
Hopefully, we should hear something soon.
Thank you,
Sara Preston
Compliance Services
(717).720.2808
sr;[email protected]
From '"T1ongqu1co,Rene'" <aR~ec~e~.T~i~oo

0q
0q0o,ic"c®=e"d.~q::ccC,;,.__~==-----~
Tc- Fedloan PSLF <[email protected]>. ,kbalc(5")

__ ,,!lcibo)(c5L)
-----~
C~ "Battle, Cynthia" <Cynth1a.Batjle@ed gov>
C~llc 07126/2016 02:15 PM
SL,8_ cct [external]RE: RE. United Nations Office of Prowet Service
Scira Diel y'Oll JII co·1lacl the cerl"fv1·1goff1c1allo confirm lhJl lhe borrower ,vas ernpoy·ed as a conlrJclor'
-RenP TI01g11Ifrn
-ederal Student /\id
From: Sara M Preston [mailto:[email protected]]On Behalf Of Fedloan PSLF

Sent: Wednesday, July 20, 2016 2:03 PM
To, !(bl(51 I
Subject: Re: RE: United Nations Office of Project Service
Hi Taneka!
I've informed the business unit to contact the certifying official for this borrower in order to confirm his
employment as a contractor. Kim is out of the office this week.
Thank you,
Sara Preston
Compliance Services
(717).720.2808
From
Tn
-~-~
l{bj/5) l<[email protected]>
Fedloan PSLF <FedloanPSLF@pheaa orq>
'T1ongqu1co. Rene'" <[email protected]>. ,kba1L(5")
__ ,,llcib
0)(c5L) -----~I '"Battle. Cynthia"'
I:-a1e 07/18/2016 01 :35 PM
t
SL,:1_~, [external]RE: United Nations Office of Project Service
11l(1rn,
lic1ve coµ1ed Rell(: TilJllg(1UIUJ lo th"s Cllcll He I', lrl lhe prull.'55 of Uc111gc1dded lo tile puiJl1c 5UVIC(.' "Tiell Lox cir1d
v/1 ::ie se 0 ve 111l·1e same ccipciutv JS Ian cl1cl1idh ass1sl111gProgrci·n MJ11Jge·ne·1t ·11rev1e,v111gernp oyer esccilcit1011s.
(b)(5)
Thanks,
TanekJ

To: !(bl(51 I
Subject: United Nations Office of Project Service
Hi Taneka!
We received an ECF for this organization in September 2015 and had denied as, from what we could
determine, the borrower was not working for the U.S. mission to the United Nations.
The borrower disputed the denial in February 2016, but still did not provide any conclusive evidence he
works for the U.S. mission.
Again in June 2016, the borrower sent in additional information. He sent in copies of his tax return, as he
indicated he does not receive W-2s. His tax return shows he is a contractor. Based on no additional
evidence showing he is employed by the U.S. mission to the United Nations, paired with the fact that he is
employed as a contractor and does not receive W-2s, we denied his employment again.
The borrower has now verbally requested re-review of his employment. Just to ensure we are on the
correct path, I wanted to forward along for your review. Any assistance would be appreciated.
Password to follow. Thanksl
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA

To; !(b)(5) I
Cc: FedLoan PSLF; Battle Cynthia: Tiqngquico Rene
Date: Wednesday, September 07, 2016 11 :48:47 AM
Rene,
The business unit has finally been able to reach the certifying official for this borrower. She confirmed
that the borrower is indeed employed by the United Nations Office of Project Service as a contractor.
Thank you,
Sara Preston
Compliance Services
(717).720.2808
[email protected]
Frrnn Fedloan PSLF/PHEAA

To "Tiongquico, Rene" <[email protected]>
C~ "Battle, Cynthia" <Cynthia.Battle@ed gov>, Fedloan PSLF <FedloanPSLF@pheaa org>, loib")(
050) _~
!(b)(5)
Date 08/31/2016 02:47 PM
Si,,; ,xt Re: [external]RE: RE: RE· RE: United Nations Office of Project Service
Srnt hv Sara M Preston
Rene,
The business unit has attempted to contact the certifying official again today and has only received a
busy signal at the number provided by the borrower. They left a voicemail with the borrower, but have not
yet heard back.
In the event that the business unit is unable to get in touch with the certifying official, how would you like
us to proceed with this borrower? Ultimately, based on our research, we believe this employer should
remain denied as we have not yet received any evidence that the employer (or the borrower, based on
his contracted employment) would qualify for PSLF purposes.
Thank you,
Sara Preston
Compliance Services
(717),720,2808
[email protected]
From "T1ongqu1co,Rene" <Rene Tiongquico@ed gov>

To FedLoan PSLF <[email protected]>. "!(b~)~(5~) --1 <[email protected]>
"Battle, Cynthia" <[email protected]>
I :-aIe 08/30/2016 05:04 PM
SL,,;p;l [external]RE: RE. RE: RE: United Nations Office of Project Service
S;c;r,,
1\ny update on whet~,er t~,e individual was a co~,tractor"?

Sent: Wednesday, August 03, 2016 1 :58 PM
To: !(bl(51 I
Hi Taneka,
We had located that number as well and informed the business unit, but it didn't seem to work either (it
vacation for two weeks (until 8/"18/16). So it seems this one will be on hold for a little longer. We will keep
you updated.
Thank you,
Sara Preston
Compliance Services
(717).720.2808
[email protected]

FedLoan PSLF <[email protected]
0,=~-,
"Battle, Cynthia" <[email protected]>, !(b)(5) I<[email protected]>, "Tiongquico, Rene"
<Rene. T [email protected]>
Date 08/03/2016 01 :26 PM
SL,,;p;l [external]RE: RE. RE: United Nations Office of Project Service
11Sar a,
lc·ed tu du cl reverse ouk uµ 0°·, l ·,e uho11e '"1U'11iJerl"Ell wc1,provided cllld I th-rh tlicll the employer
0
uro1/ded cl fc1x
num:ier 1:see below!. It the :)us ness Un te is unsuccessful 'Nth em:i I nr, t~,e certify nr, oft c ;i, I believe you m:iy be
c11J
e lo reclc'", l'",e M,. s·1e, Uv cclll111g212 457 4000 or lhe '",U'noer bled 011 decll1,urg. Thclll\',, Tcl'",ckc1
https://www.jmu.edu/rnr/ pages/research/gmar/search/un1ted-nat1ons-off1ce-for-pro1ect-serv1ces-unops.shtml
http:j/www.ideal1st.org/view/nonprofit/32FnZ1h3PCJ74/

Cc: Battle, Cynthia; Fedloan PSLF;IL(b~)(5~1~~~
Rene,
Thank you,
Sara Preston
Compliance Services
(717).720.2808
From '"T1ongqu1co,Rene'" <DRoeowecTcicoowgcQwo,icao@=ecd~g=o,:',:,,.__~-------~

Tn Fedloan PSLF <FedloanPSLF@pheaa orq>. !(b")"(5")
0 __ ,.ll"ib")("5")
-----~
"Battle, Cynthia" <Cynjhia.Battle@ed QOV>
Dc1l~ 07/26/2016 02:15 PM
Si,,; ,xt [external]RE: RE· United Nations Office of Pro1ect Service
-ederal Student /\id

To: !(b)(51 I
Hi Tanekal
Thank you,
Sara Preston
Compliance Services
(717).720.2808
[email protected]
Frrnn !(b)(5)
FedLoan PSLF <[email protected]>
"Tiongquico, Rene" <[email protected]>, 0 -~I
!(b~J(~5L) J(b~)~(5~)
0
____ _JI·
'"Battle. Cynthia"
<Cynth [email protected]>
C~t" 07118/2016 01:35 PM
SL,8_cct [external]RE: United Nations Office of Pro1ect Service
b)(5)
Th;rnks,
T,,neka
From: Kimberly A Myers [mailto:kmyers@J;Jheaa.org] On Behalf Of Fedloan PSLF

Sent: Thursday, July 14, 2016 11 :30 AM
To, !(bl(51 I
Hi Tanekal
(b)(5)
Kimberly A Myers
Compliance Services
kmyers@J;Jbeaaoro
(717) 720-2630
and/or attachments.
Code:PHEAA

To; !(b)(5) I
Date: Wednesday, August 03, 2016 1 :58:30 PM
Hi Taneka,
vacation for two weeks (until 8/"18/16). So it seems this one will be on hold for a little longer. We will keep
you updated.
Thank you,
Sara Preston
Compliance Services
(717).720.2808
[email protected]

Fedloan PSLF <[email protected]>
--,,I
"Battle, Cynthia" <[email protected]>, "!(b"j("5")
0
!("b"j(
5)______ 1"Tiongquico, Rene"
C~t" 08103/2016 01 :26 PM
Si,,; ,xt [external]RE: RE· RE: United Nations Office of Project Service
7i S:ira,
t' ed to do a reverse oak-up a~, t~,e :ihone ~,u·nber t~,;it was provided and I th n< that the emplover :irov ded a bx
num:ier 1:seebelow!. It the :)us ness Un te is unsuccessful 1N th em:i I nr, t~,e certitv nr, oft c ;i, I believe you m:iv be
c11J
e lo rcc1c·, l··,e M,. s·1c, Uv cc1ll111g
212 457 4000 or lhe ··,u·w1cr bled ori dec1l1,1.o·g. Thc1rh,, Tc1··,ekc1
https·//www.1mu.edu/cisr/ pages/research/gmar/search/united-nations-office-for-proiect-services-unops.shtml
http://www.1dec1list.org/vicw/nor1profit/32FnZjh3PCJ74/

Cc: Battle, Cynthia; Fedloan PSLF; l~(b~)(5~1
__ ~
Rene,
Thank you,
Sara Preston
Compliance Services
(717).720.2808
[email protected]
1 ro,11 '"Tiongquico,Rene·· <cR:":"~.T~oo~c~aa~cLloc~o@-edLl•~go~,;"~-,c=~----,

Tc- Fedloan PSLF <[email protected]>. 0!(b~)L(5~)
-~l.kb~J(.5L) ----~
C8 '"Battle. Cynthia'" <[email protected]>
C~llc 07126/2016 02:15 PM
SL,8_ cct [external]RE: RE. United Nations Office of Project Service
Sar:i lJid you all co~,tact the cert tyhi:; official to confirm that the borru,ver 'Nas emp oyed as a contractor'
=ederJI Sluclenl Aid

To: !lbl(51 I
Hi Taneka!
Thank you,
Sara Preston
Compliance Services
(717).720.2808
[email protected]
Frrnn !(b)(5) I b)(5)

-~-~-~----~·
fo FedLoan PSLF <FedLoanPSLF@pheaa org>
"Tiongquico, Rene" <[email protected]>, !(b)(5) I !(b)(5) "Battle. Cynthia"
<Cynth 1a.Battle@ed .QOV>
Date 07118/2016 01 :35 PM
SL,,;.ecl [external]RE: United Nations Office of Project Service
11l(1rn,
(b)(5)
TanekJ

To: !(b)(51 I
Hi Taneka!
b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA

To; Tiqngquico Rene
Cc: Battle Cynthia: FedLoan PSLF;!(b
0 0 )0(5")-~
Date: Wednesday, July 27, 2016 7:57:23 AM
Rene,
Thank you,
Sara Preston
Compliance Services
(717).720.2808
[email protected]
Frrnn ''Tiongquico, Rene'· <[email protected]>

I c• 0)0(5°)--"ll"ib"J("5°)
Fedloan PSLF <[email protected]>. '!(b -----,
r;~ "Battle, Cynthia" <[email protected]>
Date 07126/2016 02:15 PM
SL,8_
cct [external]RE: RE. United Nations Office of Project Service
Scira Diel y'Oll JII co·1lacl the cerl"fv1·1goff1c1allo confirm lhJl lhe borrower ,vas ernpoy·ed as a conlrJclor'

To: !(b)(51 I
Hi Tanekal
Thank you,
Sara Preston
Compliance Services
(717).720.2808
From !(b)(5) l(b)(5)

Tc Fedloan PSLF <[email protected]>
"Tiongquico, Rene" <[email protected]>, !(b~)(~5L)
0 -~lekb~)(~5L) ----~!..'"Battle.Cynthia"
Dc1l~ 07/18/2016 01 :35 PM
Si,,; ,xt [external]RE: United Nations Office of Pro1ect Service
'"11 KIITI,
b)(5)
I hanks,

To: !lbl(51 I
Hi Taneka!
b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA

To; !(b)(5) I
Hi Taneka! I will forward this back to the Business Unit for denial, and will send you a copy of the letter.
Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

r;~ "Battle, Cynthia" <[email protected]>, "Tiongquico, Rene" <[email protected]>
Date 10107/2016 01 :12 PM
SL,8_cct [external]Re. St Louis Development Corporation
Hi Kim,
Thanks,
Taneka
From: Kimberly A Myers <[email protected]> on behalf of FedLoan PSLF<[email protected]>

To: l(b)(5) I
Hi Taneka! We received a dispute on this one, so we wanted to escalate for your review
b)(5)
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code PHEAA
From: !(b)(5)
To; FedLoan PSLF
Date: Friday, October 07, 2016 1:51 :26 PM
Hi Kim,
Thank you!
Taneka

Sent: Friday, October 7, 2016 12:42 59 PM
To: !(bl(51 I
Cc: Battle, Cynthia; Fed Loan PSLF;Tiongquico, Rene
Subject: Re Re: St Louis Development Corporation
Hi Taneka! I will forward this back to the Business Unit for denial, and will send you a copy of the letter.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

I :-aIe 10/07/2016 01 :12 PM
Hi Kim,
Thanks,
Taneka

To: l(b)(5) I
Hi Taneka! We received a dispute on this one, so we wanted to escalate for your review
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code PHEAA

To; !(b)(5) I
Subject: Re: RE: Students First
Date: Tuesday, August 09, 2016 3:27:31 PM
Hi Taneka! I reached out to the Business Unit to pull the data for me. Once I receive the query back I will
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Frrnn !(b)(5) jtb)(5)

C~ !(b)(5) I
<[email protected]>. "Battle, Cynthia"' <Cynthia [email protected]>, "T1ongquico, Rene"
Date 08/08/2016 04:08 PM
Si,,; ,xt [external]RE: Students First
7i Kim,
b)(5)
Th;rnks,
TanekJ

To: !(b)(51 I
b)(5)
purposes.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA

To; !(b)(5) I
Date: Wednesday, July 20, 2016 2:03:07 PM
Hi Taneka!
Thank you,
Sara Preston
Compliance Services
(717).720.2808
[email protected]

Fedloan PSLF <[email protected]>
"Tiongquico, Rene" <[email protected]>, !(b")"(5")
0 __ ,.ll"ib")("5")
-----~'"Battle.Cynthia"
<:[email protected]>
C~t" 07118/2016 01:35 PM
Si,,; ,xt [external]RE: United Nations Office of Pro1ect Service
7i Kim,
b)(5)
I hanks,
T,,neka

To: !(b)(51 I
Hi Taneka!
b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: Bronstein Andrew

To; Tiqngquico Rene
Subject: RE: Some Things
Date: Monday, November 28, 2016 3:27:54 PM
Thank you so much, Rene. I really appreciate your help with this
Besl,
Andrf'V,'

Sent: Monday, November 28, 2016 3:21 PM
To: Bronstein, Andrew
Subject: Some Things
FYI:
Undersecretary's response to Sen. Murray:
http://www.help.senate.gov/imo/media/doc/ED%20response%20to%20Senator%20Murray.pdf
The Department's PSLFregulations may be found at 34 CFR685.219. Specifically, in order for a non-
501(c)(3) nonprofit organization to be considered a qualifying employer, it must provide on or more
of the following public services:
Emergency management•
Military service•
Public safety•
Law enforcement•
Public interest law services•
Early childhood education (including licensed or regulated childcare, Head Start, and state-funded
• pre-ki nde rga rten}
Public service for 1ndiv1dualswith disabil1t1esand the elderly•
Public health (including nurses, nurse practitioners, nurses in a clinical setting, and full-time
•professionals engaged in health care practitioner occupations and health care support occupations)
Public education •
Public library services •
School library or other school-based services
Rene T1ongqu1co
From: !(b)(5)
To; FedLoan PSLF
Subject: Re: St Louis Development Corporation
Hi Kim,
Thanks,
Taneka

Sent: Friday, September 16, 2016 1.19.29 PM
To: !(b)(5) I
We originally denied this organization in September 2014. The organization is 501 (c)(4), but they do not
They now submitted a letter appealing the denial. They indicated that although they are 501 (c)(4). in
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code PHEAA
From: !(b)(5)
To; FedLoan PSLF
Cc: l{b)(5) IBattle Cynthia: Tiongq11icoRene
Subject: RE: Students First
Date: Monday, August 08, 2016 4:07:45 PM
H1 Kim,
(b)(5)
Taneka

To: !(b)(51 I

(b)(5)
purposes.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: Ding, Yuanxia

To; McLarnon Gail: ill.L...Jo..o.:
Smith Brian: Qhialastri Taneka; Battle Cynthia; Tiqngquico Rene
Cc: Maha/fie Lynn; O"Bergh ,Ion
Subject: RE: Summary of Actions to Increase PSLF Transparency
Date: Thursday, October 20, 201612:42:54 PM
G,1il ;ind others,

(b)(5)
Yuanx1a
From: Mclarnon, Gail

Sent: Tuesday, October 11, 2016 4:20 PM
To: Utz, Jon; Smith, Brian; Chialastri, Taneka; Battle, Cynthia; Tiongquico, Rene
Cc: Mahaffie, Lynn; Ding, Yuanxia
Subject: Summary of Actions to Increase PSLFTransparency
(b)(5)
Thanks!I
Gail Mclarnon
Senior Director, Policy Development, Analysis,
and Accreditation
Office of Postsecondary Education
Department of Education
202-453-6624
gai I.mcl [email protected]
From: Battle, Cynthia

To; Ding Yuanxia: McLarnon Gail
Cc: Maha/fie Lynn; O"Bergh ,Ion: Chialastri Taneka: Tiqngq11ico Rene: !J.1.....J..o..;
Smith Brian; LaVia Mark; '1a..o..e..
John
Subject: RE: Summary of Actions to Increase PSLF Transparency
Date: Thursday, October 20, 2016 1 :58:07 PM
Gail arid Yuanxia,

b)(5)
Please let me knov,,,i1fyou have questions. Thanks I
From: Ding, Yuanxia

Sent: Thursday, October 20, 2016 12:43 PM
To: Mclarnon, Gail; Utz, Jon; Smith, Brian; Chialastri, Taneka; Battle, Cynthia; Tiongquico, Rene
Cc: Mahaffie, Lynn; O'Bergh, Jon
Subject: RE: Summary of Actions to Increase PSLFTransparency
G,1il ;ind others,
b)(5)
Yuanx1a

To: Utz, Jon; Smith, Brian; Chialastri, Taneka; Battle, Cynthia; Tiongquico, Rene
Cc: Mahaffie, Lynn; Ding, Yuanxia

Subject: Summary of Actions to Increase PSLFTransparency
b)(5)
Thanks!!
Gail Mclarnon
and Accreditation
202-453-6624
gai I.mcl arno [email protected]
From· fbl/51
fo
Cc e,11I,,C;·o·c,acT,c,·;awc,Sea,
OE Tec.•I,e,•J•,•Je,
T-,,,,,o,.,
"'°'""
Sep1eo>L,er,~ e ,, s , <19s· f'r.i
(b)/5)
From: Kimberly A Myers [maIlto:kmyers:§)pl1eaa.org] On Behalf Of Fedloan PSLF

Se~'\YiWnesdey, August 10. 2016 1:36 PM
To:1/h I 1 I
Subject: Teache, Unde, Cont,act
H, Taneka' I wanted to torward lh,s account to you to seek your guidance on how to handle,
(b)/5)
32.1 am a teacher ''./ho does not teach o,1er the summer breaK If I make pa;ments during
the surnrner. do those pa:w1ents count to /,ard PSLF?
Payments you make during the summer will pount if you have a contract for an employment period of at
least eight months and you v.ork an average of 30 hours per ·Neek during that period. and if your
employer still considers you to be employed full-time during the summer break. Of course. the payments
must otherN1se meet all PSLF requirements. In this circumstance. your employer should include the dates
of the summer break when reporting your dates of employment on the PSLF Employment Certification
Form. even though you are not actually teaching during that period.
As always, thanks for your Inpu1I Password to follow
Kimberly A Myers
Compliance Services
[email protected]
•JI 7i 720-2630
Thi, rnew1ge contaui, pri', 1lcgcd and conlidenual mini nrntion ,mended lor the ah,we addressees only. l I you rccei, e 1h1,mes,age Lil c11or please delete or
dcsllo) thl' message and/or anachmclll,.
Code.Pl IEAA
From: !(b)(5)
To; FedLoan PSLF
Cc: -~I
Tiqngquico Rene:!0(bLJ(~5L) Battle Cynthia
Subject: RE: United Nations Office of Project Service
Date: Monday, July18, 2016 1:35:46 PM
H1 Kim,
b)(5)
Thanks,
Tanek;i

To: !(b)(51 I
Hi Tanekal
b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; FedLoan PSLF
Subject: RE: Wayne County Community College
H1 Kim,
We agree that it is likely that the certifying official listed the hours incorrectly, however, before
approving lhis escalal1on could you have someone from lhe Bu:,ir1essOllice wnLKl lhe cerlifying
offic1;il to confirm th,1t based on the requirements for employment with W;iyne County Community
College that the borrower 1sfull time and actually v,mrks at least 30/hrs. per week.
Thar1ks,
Taneka

To, !(bl(51 I
Subject: Wayne County Community College
Hi Tanekal We aren't questioning the actual employer eligibility in this instance. we are questioning the
employment status of the borrower.
(b)(5)
Based on the facts outlined above, we don't believe the form was properly certified for the hours worked
by the borrower, and this borrower should be considered full-time. Your assistance is appreciated.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; FedLoan PSLF
Cc: l{b)(5) IBattle Cynthia: Tiongq11icoRene
Subject: RE: Wind Creek Hospitality
Date: Monday, August 08, 2016 4:42:09 PM
H1 Kim,
b)(5)
Thar1ks,
Taneka

To, !(bl(51 I
Subject: Wind Creek Hospitality
Hi Taneka! We have another tribal entity/casino for you.

b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: Carr. Clorisa (Contractor)

To; ~
Cc: Tiqngquico Rene
Subject: REQ000000439894---RE: .kb~l~l5~)
---~
Date: Tuesday, June 14, 201610:35:53 AM
Hello Ian,
The request below has been completed as requested
Allow up to 2 hours for the server to replicate, after thJt time frJrne the mailbox will appear in
outlook on the left hand side close to the bottom
Please let me know if you have any questions
Thank you,
Clarisa Carr
972-577-7876
Messaging Services Analyst
Clarisa. [email protected]
Clarisa [email protected]
From: FSA IT Service Request

Sent Thursday, June 9, 2016 12 33 PM
To: ED Customer Service
Cc: Chialastri, Taneka; Tiongquico, Rene; Foss, Ian; FSA IT Service Request; FSAAsset Mgmt
Subject: RE L(b~l(~51
______ J
1
Approved. Open ticket under Ian Foss name. Thank you.
Sergio Perez
From. Foss, Ian

Sent Thursday, June 09, 2016 1:02 PM
To: FSA IT Service Request
Cc: Ch1alastri, Taneka; Tiongquico, Rene
Subject: Ll(b~l(~51
______ J
Please grant Rene Tiongquico access to the l(b)(5J

~-------~ Imailbox.

To; !(b)(5) I
Cc: Battle Cynthia: FedLoan PSLF;Tiqngquico Rene
Date: Wednesday, October 19, 2016 2:30:43 PM
Attachments: St Louis Development Corporation Denial Letter.zip
Hi Taneka! Attached is the letter to the borrower in response to the denial for this organization.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

r;~ "Battle, Cynthia" <:[email protected]>, "Tiongquico. Rene' <:[email protected]>
Date 10107/2016 01 :51 PM
SL,8_
cct [external]Re. Re: St Louis Development Corporation
Hi Kim,
Thank you!
Taneka
To: l(b)(5) I
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

C~ "Battle, Cynthia" <Cynthia.Battle@ed gov>, "Tiongquico, Rene" <[email protected]>
C~tlc 10l07/201601:12PM
Sr.,1_~,
t [external]Re: St Louis Development Corporation
Hi Kim,
Thanks,
Taneka

To: l(b)(5) I
Hi Taneka! We received a disoute on this one so we wanted to escalate for vour review
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code PHEAA

To; !(b)(5) I
Attachments: Employer Query (Students First & Not-for-prof1t Public Educetion).z1p
Hi Taneka! Sorry for the delay. Attached is the spreadsheet with the counts you requested. I included
both requests in the same spreadsheet, under separate tabs.
b)(5)
Please let us know if you have any questions. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
I ro111 !(b)(5) lkb)(5)

~;~ !(b)(5) I
!(b)(5) I
"Battle, Cynthia"' <[email protected]>, "Tiongquico, Rene"
<[email protected]>
Dc1l~ 08/08/2016 04:08 PM
s,.,1_~,
t [external]RE: Students First
(b)(5)
I hanks,
T,,neka

To: !(b)(51 I

(b)(5)
purposes.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: Mclarnon Gail

To; l.J..tL....J..Q:
Smith Brian: Chialastri Taneka; Battle Cynthia; Tiqngquico Rene
Cc: Maha/fie Lynn; Ding Yuanxia
Subject: Summary of Actions to Increase PSLF Transparency
b)(5)
Thanks I!
Gail Mclarnon
and Accreditation
202-453-6624
~ai I.mclarnon@ed .~ov

Sent: 21 Feb 201715:17:58 +0000
To: Fedloan PSLF
Cc: l(b)(5J ICynthia;Foss, lan;Odom, Christian
Subject: Community Access - Possible retraction
Hi Kim,
Community Access was listed on the potential retraction list you provided to FSAfor review. FSAwas
unable to determine the organization's non-for-profit status. Could you issue a customized retraction
letter explaining why the organization is no longer eligible for PSLFand request that the borrower
provide evidence of non-profit status. If Fedloan receives additional documentation from Community
Access we would like to review them again through the escalation process.
Thanks,
Taneka
Taneka ChialastriI Management and Program Analyst, Business Operations I Federal Student Aid
830 First Street NE, Washington, DC 20202
Office: 202-377-4390 I Cell: 202-256-7842 I [email protected]
St .. r:,·nt
From: l(b)(5)
Sent: 11 Jun 2014 19:00:39 +ODDO
To: 'Fedloan PSLF'
Cc: l(b)(5J Ilan;Battle, Cynthia;Johnson, Debbe
Subject: RE: Centers for Rehab Services - UPMC
Hi Diane,
Unlike a disregarded entity, an entity that is controlled, but not wholly owned, by a parent 501{c)(3), and
that is taxable as a partnership, but that is not a disregarded entity is not automatically eligible as a
501(c)(3).
What's more, we have no way of knowing whether Core Network LLCis a for-profit or anization or not,
because Penns lvania business filin s for the or anization are not available online. (bl( 5l
b)(5) b)(5)
When I looked at the parent's (UPMC's) financial disclosures, I see this, which clearly indicates that
UPMC overall includes some organization that are for-profits:
UPMCis a Pennsylvania nonprofit corporation and is exempt from federal income tax pursuant
to Section 501(a) of the Internal
Revenue Code ("Code") as an organization described in Section 501(c}(3) of the Code.
Headquartered in Pittsburgh, Pennsylvania, UPMC is one of the leading integrated delivery and
financing systems in the United States. UPMC is an integrated global health enterprise
leveraging medical expertise, geographic reach, and financial stability in a model of care
excellence that can transform health care nationally and internationally. UPMC comprises
nonprofit and for-profit entities offering medical and health care related services, including
health insurance products. Closely affiliated with the University of Pittsburgh ("University") and
with shared academic and research objectives, UPMCpartners with the University's Schools of
the Health Sciences to deliver outstanding patient care, train tomorrow's health care specialists
and biomedical scientists, and conduct groundbreaking research on the causes and course of
disease.
(b)(5)
Ian
-----Original Message-----
From: Diane Freundel [mailto:[email protected]] On Behalf Of Fedloan PSLF
Sent: Wednesday, May 14, 2014 10:50 AM
To: l(b)(5J
Subject: Centers for Rehab Services - UPMC
b)(5)
(See attached file: Centers for Rehab Services_2013.zip) (See attached file: Center for Rehab Services
UPMC_2014.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
[email protected]
This message contains privileged and confidential information intended for the above addressees only.
If you receive this message in error please delete or destroy this message and/or attachments.
The sender of this message will fully cooperate in the civil and criminal prosecution of any individual
engaging in the unauthorized use of this message.
From: l(b)(5)
Sent: 17 Feb 2012 20:19:00 -0600
To: 'Fedloan l(b)(5J I
Cc: Foss, lan;Ninemire, Sandra;Sipple-Asher, Bessie
Subject: RE:Central San Joaquin Water Conservation District
Water Conservation Di~tricts in California arc quasi-governmental in nature

at the local-level. They qualify under the government category.
That being
said, I'm having a difficult time exaclly matching the name "Central Joaquin
Waler Conservation Disl1ict" with anything in pai1icular ~ave for a few
documents that reference it:
http://www.swrcb.ca.gov/board 1nfo/a!!<:ndasi2007/februarvicomrnents 09/reid ro
bert~.pdf and
h tlp ://www.waler.ca. !!O\./ irwm/duc s/Resource~L mksiS ubm1(kd A pp]1cal1ons/ P84
Round I_ Planning/Northeastern SanJoaq uinCountyGroundwater BankingA uthority/ Att2
_PG I_ SJCGBA _ EligDoc _ 3of3 .pdf.
Though this one is a bit less certain, I'm

okay approving it because the other i,,,raterdistricts in California appear to
clearly qualify.
From: Diane Freundel
[mailto:dfreundefli:aessuccess.or 0 ] On Behalf Of FedLoan PSLF
Sent: Thursday,
February 09, 2012 11:39 AM
To: l(b)(5) I
Subject: Central San Joaquin
Water Conservation Di~trict
Good morning!
This employer checked box a.

The only thing we could find in searching for it was on Manta.com that
indicates it's a private company. There is also no indication that it is a
not-for-profit.
Password to follow.
(See attached file: Fredeen_Central

San Joaquin Water Conservation.zip)
Thanks
Diane Freundel
Compliance
Services
(717) 720-3267
fax-(717)
720-3911
[email protected]
--------------------------------
Thi~ message contain~ privileged and

confidential infomrntion intended for the above addrc~~ccs only. If you
receive thi~ mc~~agc in error plca~c delete or dc~troy this message and/or
attachmcnb.
The sender of this message will fully cooperate in the civil

and criminal prosecution of any individual engaging in the unauthoriLed use
of this
message.
From: l(b)(5)
Sent: 8 Jun 2012 09:01:20 -0500
To: Fedloan l(b)(5J I
Cc: Foss, lan;Ninemire, Sandra;Sipple-Asher, Bessie;Johnson, Debbe
Subject: RE: CEPAmerica, Inc.
Diane,
I agree that this is a for-profit entity that doc~ not qualify.

Their wch~itc clearly ~talc~that they di~trihutc profib to the
member~.
And lhanb for the head's up on Dehl My Way.
Ian
>
> From: Diane Freundel
Lmailto:dfreundefa-pheaa.org I On Behalf Of FedLoan
> PSLF
> Sent: Friday, June
08, 2012 9:13 AM
> To: l(b)(5) I
> Subject: CEP America, Inc.
>
>
>
Ian, This is clearly a for profit organization; however, we'd like your
>
concurrence before the issue becomes c~calatcd, a~ we expect Dcht \1y
>Way
may try to contact FSA directly.
>
> Also _1ustas a head's up, Dehl My
Way's website slate~ that they "help"
> borrower~ to better understand and
qualify for !BR and charge the bmrnwer
> if their !BR application is
approved. Their website also discusses helping
> borr01,versmanage their
PSLF papenvork. Our concern is that they may be
> soliciting borrowers who
clearly do not qualify for PSLF, ultimately
> providing a disservice to
these borr01,vers. This may be something we both
> \vant to keep an eye
one.
>
> Passv,rordto follow - no PPI, but just in case our email system
catchc~ a
> 9-digit number that look~ like an SSN. Thanks.
>
> (Sec
attached file: C[P America.zip)
> Diane Freundel

> Compliance Service~
(717) 720-3267
> fax-(717) 720-3911
> dfrcundc((_l'.phcaa.org
>
>
> -----
Forwarded by Diane Freundel/PIIEAA on 06/08/2012 08:45 AM-----
>
1--------->
> I From:
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
!Elizabeth Shepler/PHEAA
>I
>
>---------------------------------------------------------------------------
> ------------------------------------------1
>
1------------>
> I To: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
> Diane
Freundel
> I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
> I Cc: I
> 1------------>
>
>---------------------------------------------------------------------------
> ------------------------------------------1
>
lm~cssa((_l'.phcaa.org,Corey Detar, Kimberly A Mycr~/PHEAA(j_i;phcaa
>I
>
> --------------------------------------------------------------------------
> ---------------------------------------------1
1------------>
> I Date: I
> 1------------>
> --------------------------------------------------------------------------
>
106/07/2012 04:22 PM
> I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
> I Subject: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
> Fw:
Question re: Not-For-Profit, private organization for the Purposes of
>
PSLF program: CEP America, Inc.
>
> --------------------------------------------------------------------------
> ------------------------------------------1
>
>
>
>
> Iii Diane,
>
> Matt received a inquity from Jose at Debt \1y Way asking if
employees at CEP
> America would be eligible for PSLF.
> The inquity 1,vas
originally forwarded to Jody Teter. She stated that after a
> review CEP
America is not an eligible employer.
> Jose is noi,v questioning this answer.
Can you please help me explain our
> logic to Jose?'.1
>
> Thank you
>
>
Elin1bcth Shepler
> FedLoan Servicing
> Pennsylvania Higher Education
/\s~islance Agency
> 717-720-3038
> ----- Forwarded by Elizabeth

Shcplcr/PHEAA on 06/07/2012 04: 17 PM -----
>1------------>
>I horn:
I
> 1------------>
>---------------------------------------------------------------------------
> ---------------------------------------------1
> "Jose
Pacheco" <jose(a;'debtmyway.com>
> I
>---------------------------------------------------------------------------
> ---------------------------------------------1
1------------>
>ITo: I
> 1------------>
>
>---------------------------------------------------------------------------
> ------------------------------------------1
l"[lizahcth Shepler" <cshcplcr((j)acssucccss.org>

>I
> --------------------------------------------------------------------------
> ---------------------------------------------1
>
1--------->
> I Cc: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
> "Dave
Koehler" <dave(~!debtmyway.com>, "Matthew D. Dessa. MSIS,
>MBA
([email protected])" <[email protected]>, "Rick Hernandez"
>I
>
l<[email protected]>
>I
>
> --------------------------------------------------------------------------
> ------------------------------------------1
>
1--------->
> I Date: I
> 1------------>
>
> --------------------------------------------------------------------------
>
106/07/2012 04:15 PM
>I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1--------->
> I Subject: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
> RE:
FW: Question re: Not-For-Profit, private organization for the Purposes
>of
PSLF program: CEP America, Inc.
>
> --------------------------------------------------------------------------
> ------------------------------------------1
>
>
>
>
>
> Iii EliLabcth,
>
> Thank you for your reply.
>
> From your research,
did you read the 'Who We Are 2 section speaking about
> the partnership and
income distribution to the physicians'.'
>
> CEP America is a democratic
physician partnership, \vith ownership of the
> Partnership and our
subsidiaries distributed equitably among the practicing
>physicians.There
are no outside owners or investors. so all income from the
> practice -
after operational expense~ and hilling and malpractice costs
> - i~ fully
returned to our phy~icians.
>
> From the above statement, at the end of the
fiscal year, all income
> generated by CEP America 1~ returned to the
physicians and documented in

> the partners' Schedule K-1 yearly statements.
It appears to be a private,
> Not-for-Profit organin1tion became the
company docs not keep any residual
> income on it~ balance ~beet at the end
ofit~ focal year. It technically docs
> not earn any profit.
>
> Can you
clarify this accounting is~uc with us with organization such as these?
>We
would grcally appreciate it.
>
> Thanks.
>
> Regards,
>
> Jose Pacheco
>
Founder/CEO
>
> Description: FINAL_DebtMyway
>
> 97 South Second Street,
Suite 100
> San .lo~c, Ca 95113
>C 831.905.1768
> r 408.280.7881
>
>
>
>
From: EliLabcth Shepler [mailtu:.:shcplcrr,t11cssl1Cc.:ss.urg]On Behalf Of
>
Matthew Sessa
> Sent: Wednesday, June 06, 2012 12:54 PM
> To: Jose Pacheco
>
Cc: Dave Koehler; Matthew D. Dessa, MSIS, MBA (msessa(iijpheaa.org);
> Matthev.r
Sessa; Rick Hernandez
> Subject: RE: FW: Question re: Not-For-Profit,
private organization for the
> Purposes of PSLF program: CEP America, Inc.
>
> Jose,
>
> After further review, all rc~carch indicates that it is a for
profit, including
> information from their wcb~itc in the "About lh, and Who
We Arc"
> ~cction~. Therefore, it is not a qualifying employer.
>
> Thank
yo"
> Pro "Jo~c Pacheco" <josc½_~·dcbtmyway.com>

> m:
>
>
To: "\1atthcw Sessa" <rnses~a(t1Jaes~ucccss.org>
>
>
> Cc: "Dave Kochler"
<dave(i1;debtmyway.com>, "Matthev., D. Dessa, \1S!S,
>MBA(
>
msessa(i1;pheaa.org)" <msessa(i1;PHEAA.ORG>, "Rick Hernandez"<
>
[email protected]>
>
> Dat 06/04/2012 08:47 AM
> e:
>
> Sub RE: rw:
Question re: Not-For-Profit, private organization for the
> jcc Purposes
of PSLF program: CEP America, Inc.
> t:
>
>
>
>
>
>
>
>
> Hi
Matt,
>
> No Problem. Here is the organization in question.
>
>CEP
America
> 2 I 00 Powell Street, Suite 920
> Emeryville, California 94608
>
>
EIN: 26-0525456
> www.eep.eom
>
>
> It provides the following public
~crv1cc~:
> · Emergency \1anagemcnt
> · Public Ilcalth
(including nurses. nurse practitioners, nurses in a

> clinical setting, and
full-time profc~~ionals engaged in health care practitioner
> and health
care support occupations)
>
> Thanh, \1att for your help. I appreciate it
a lot!
>
> Ilave a nice weekend.
>
> Regards.
>
> Jose Pacheco
>
Founder/CEO
>
> Description: FINAL_DebtMyway
>
> 97 South Second Street,
Suite 100
> San Jose, Ca 95113
>C 831.905.1768
> F 408.280.7881
>
> From:
Matthew Sc~~a [mailto:msc~~a(ii'ac~~ucccss.orgl
> Sent: Friday, June 01. 2012
1:17 P\1
> To: .lose Pacheco
> Cc: Dave Kochler; Matthew D. Dc~sa, MSIS. MBA
(m~essa(a;pheaa.org); Rick
> llcmandeL
> Subject: Re: FW: Que~tion re:
Not-For-Profit, private organiLation for the
> Puq1oses or PSLF program:
CEP America, Inc.
>
> Jose, I did not see your original email. I noticed
this most recent email in my
> quarantine file.
>
> Can you resend the
email with the organization in question?
>
> Thanks, \1att
>
>
>
> Prom:
"Jo~c Pacheco" <josc(ij)dchtmyway.com>
>
>
> To: "Matthew D. Dc~~a, MSIS,
MBA (mses~a(t1Jpheaa.org)"
> <mse~~a(d)PIIEAA.ORG>
>
>
> Cc: "Dave Kochler"
<davc(c(dchtmyway.com>. "Rick Hernandez"<
> rick((j)n2con.com>
>
>
Date: 06/01/2012 04:14 PM
>
>
> Subjc FW: Question re: Nol-For-Profit,
private organiLalion for the
> ct: Purpo~cs of PSLF program: CEP America,
Inc.
>
>
>
>
>
>
>
>
>
>
>
>
>
> Hi Matt,
>
> I hope that you
arc having a good week.
>
> Ilavc you had a chance to lookup the infonnation
regarding the company
> that I provided you la~l week?
>
> Docs it qualify
for the PSLF program as a not-for-profit, private organization
> for the
purposes of the PSLF program'?
>
> Ms. Moran and Ms. Battle, both mentioned
to me at the FSA conference last
> year that FedLoan Servicing would
determine the eligibility of these
> challenging entities.
>
> That is why
I am a~king you, Matt.
>
> Thanh, \1att., your help. I look forward to
your reply.
>
> Regard~,
>
> Jose Pacheco
> Founder/CEO
>
> Dc~cription:
FINAL_ DcbtMyway
>
> 97 South Second Street Suite 100
> San Jo~c, Ca
95113
>C 831.905.1768
> F 408.280.7881
>
>
>
>
>
>
> From: Jose
Pacheco
> Sent: Wednesday, May 23, 2012 11: 11 A\1
> To: Matthev,· D. Dessa,
MSIS, MBA ([email protected])
> Cc: David Koehler ([email protected])
CFO/Founder, Debt \1y Way,
> Inc.; Rick Hernandez, MS. CTO of Debt My Way.
Inc.
> Subject: Quc~tion re: Not-f-or-Profit, private organization for the
Purpose~
> of PSLf, program
> Importance: High
>
> Hi Matt,
>
> I has been
awhile since we la~l ~poke. I hope that everything is going well
> with the
PSLF program at FedLoan Servicing
>
> I have a question for you, Matt.
>
>
I have a prospective customer, a recent medical resident graduate in
>
Emergency Medicine, who has accumulated a massive amount of medical
> school
debt (his loan servicer is ACS) and is planning to work for a private,
>
not-for-profit organization that may qualify as a public service
organization
> for the purpose~ of the PSLF program.
>
> Below i~ details
of the company:
>
> CEP America
> 2100 Powell Street, Suite 920
>
Emeryville, California 94608

>
> [IN: 26-052XXXX
> www.ccp.com
>
>
> It
provides the following public ~erviccs:
> · Emergency \1anagement
Public I lcalth (including nurses, nur~e practitioners, nurses in a

> clinical
selling, and foll-lime proks~ionals engaged in health care practitioner
>
and health care support occupations)
>
> Since Pamela Moran from the
Department of Education, Office of
> Postsecondary Education, stated at last
year FSA conference that identifying
> these private, not-for-profit.
organizations will be a challenge for all patties
> involved, we at Debt My
Way, Inc. are taking a proactive approach to
> identit)'ing these unique
public ~crvice organization~ and verify if they arc
> qualifying employer~
for the purpose~ of the PSLF program with your
> a~~i~tance,of cour~c.
>
>
When you have chance, let me know, ifCEP America qualilic~ as a
qualif'ying
> employer for the purposes of the PSLF program.
>
> Thank you,
Matt.
>
> Regards,
>
> Jose Pacheco
> Founder/CEO
>
> Description:
Description: FINAL_DebtMyway
>
>
> 97 South Second Street, Suite I 00
> San
.lose, Ca 95113
>C 831.905.1768
> r 408.280.7881
>
> This message contain~
privileged and conlidential infonnation intended for
> the above addressees
only. If you receive this message in error please

> delete or destroy this
message and/or attachments.
>
> The sender of this message will fully
cooperate in the civil and criminal
> prosecution of any individual engaging
in the unauthorized u~c of this
> message.
> This message contain~
privileged and conlidcntial infonnation intended for
only. If you receive this mcs~agc in eITor plca~e
>
in the unauthorized use of this
> message.
> This message contains
privileged and confidential information intended for
> delete or dc~troy thi~
>
in the unauthorized u~e or this
> message.
From: l(b)(5)
Sent: 29 Oct 2015 22:55:45 +ODDO
To: Fedloan PSLF
Cc: !(b)(5) I
Subject: RE: Chapter 13 Trustees
Hi Diane,
We agree that Chapter 13 Trustees do not qualify for Public Service Loan Forgiveness (PSLF).Chapter 13
Trustees, are not government employees, even though they are appointed by the United States Trustee
{who is a government employee). We were unable to find any definitive evidence of how these trustees
are organized, but did find Richard V. Fink's profit sharing plan {similar to what you located for Nancy
Grigsby). The fact that Chapter 13 trustees have a controlled budget and compensation that is fixed by
the Department of Justice are also not enough to make them non-profit. Further, as you listed below
even if you they do qualify as a non-profit there is no indication they are "funded in whole or in part by a
local, State, Federal or Tribal government".
I hope this helps. We were hoping to find more evidence. Please let me know if you need us to keep
looking.
Thanks,
Taneka
To: l(b)(5J I
Subject: Chapter 13 Trustees
We have two different employers that are Chapter 13 Trustees.
Nancy Spencer Grigsby Ch 13 Trustee - We originally denied this one in January 2014. In August 2015 we
received another ECFfor the same borrower, certified the same each time - private non-profit providing
public interest legal services. With the 2nd ECFthe borrower provided a letter in which she attempts to
explain why the organization qualifies.
Office of the Chapter 13 Trustee Richard V Fink - We originally received this ECFin August 2015, certified
as private non-profit providing public interest legal services. We requested proof of non-profit status
because our research could not confirm this status. We also do not think that Chapter 13 Trustees could
be considered governmental because the U.S.
Department of Justice website lists that Ch. 13 Trustees are private
parties, not government employees. This borrower provided a letter from
the employer that attempts to explain why the organization qualifies.
We do not believe that Chapter 13 Trustees qualify even ifthey are private non-profit because we don't
believe they provide legal services as defined by the regulations.
Please advise. We appreciate your guidance! Password to follow.
(See attached file: Nancy Spencer Grigsby Chapter 13 Trustee.zip) (See attached file: Office of the
Chapter 13 Trustee Richard V Fink
Trustee.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
[email protected]
This message contains privileged and confidential information intended for the above addressees only. If
you receive this message in error please delete or destroy this message and/or attachments.
Code:PHEAA
From: l(b)(5)
Sent: 21 Feb 2012 14:25:27 -0600

To: Sipple-Asher, c(b~)(~5)~-------~ PSLF
Cc: Ninemire, Sandra
Subject: RE: Charis Ministries
Thanks, Bessie.
Diane, go ahead and hold off on sending out the denial letter, but record the
ultimate rejection of the employer as qualifying.
From: Sipple-Asher, Bessie
Sent: Tuesday, February 21, 2012 3:24 PM
To: l(b)(5) IFedloan PSLF
Subject: RE:Charis Ministries
I think we should hold the ECFand process it with the others when the issue
is resolved.
Bessie Ko Sipple-Asher
Direct Loans Division
Federal Student Aid
Tel: 202-377-3145
[email protected]
From: l(b)(5) I
To: Sipple-Asher, Bessie; l(b)(5) I
Fedloan PSLF
Subiect: RE Charis Ministries
(b)(5)
r,rom: 1pp1e-HSr1er, oess1e

To: l(b)(5) IFedloan PSLF
Cc: Foss, Ian; Ninemire, Sandra
Subject: RE:Charis Ministries
Thanks,
Bessie
Federal Student Aid
Tel: 202-377-3145
[email protected]
From: l(b)(5) I
To: Fedloan PSLF;cl(b~)(~5~)

--~
Cc: Foss,Ian; Ninemire, Sandra;Sipple-Asher,Bessie
Subject: RE: Charis Ministries
I agree that it is a not-for-profit organization; however it is not a 501(c)(3)
organization that is either in Pub 78 or the relevant Business Master File.
And, here's the rub: churches are not required to file for tax-exempt
status; rather, they are automatically tax-exempt (though many, if not
most churches file for the status). Those that claim tax-exemption without
filing for it are not publicly listed.
What's interesting here is that this group is affiliated with the Catholic
Church, which has group tax-exempt status because it filed for an
exemption with the IRS. I say this because the ministry's web site states
that they are an arm of the Chicago-Detroit Province of the Society of
Jesus, which is tax-exempt under the Catholic Church's group exemption
number (928). So, that this is not listed in the Business Master File under
the same group exemption number leads me to believe that it is not a
501(c)(3) organization.
And bear in mind, the exception to the requirement to file to receive
501(c)(3) status is only for churches. Other religious organizations are
required to file for tax-exempt status unless their gross receipts (revenue)
do not exceed $5,000 per year. See page three of the IRS'tax guide for
churches and religious organizations (here: http://www.irs.gov/pub/irs-
pdf/p1828.pdf). Though I'm not sure where the line between church and
religious organization is, Charis Ministry's web site doesn't at all sound like
a church and does not describe itself as a 3 house of worship 2 or anything
similar. And, the annual report that you sent indicates that the
organization's gross annual receipts for 2011 exceeded $5,000 by a wide
margin.
At this point, then, I'm tentatively reaching the conclusion that this
organization is not a 501(c)(3) organization, which means that it can only
be a qualifying employer if it is a private not-for-profit organization that
provides a qualifying public service. The IL corporations database bears out
that the organization is a not-for-profit organization; however, I cannot
see from its website that it provides a qualifying public service.
Therefore, I don't think this employer qualifies unless the borrower has
given us the wrong EIN (though I also did several name searches that were
not fruitful).
Because we are determining that the employer does not qualify, I don't
think there is a need to wait like there has been with the other religious
organizations that are otherwise qualifying.
Bessie,what do you think about this?
> -----Original Message-----
> From: Diane Freundel [mailto:[email protected]] On Behalf Of
> Fedloan PSLF
> Sent: Thursday, February 16, 2012 8:40 PM
> To: l(b)(5J I
> Subject: Charis Ministries
>
>
> Hello, We believe this organization is a non-profit, and may be a 501
> (c)(3) based on its affiliation with the Catholic Church. We assume this
> one will be on hold due to its religious nature. Password to follow.
> Thanks.
>
>
> (See attached file: Scherra_Charis Ministries.zip)
>
> Diane Freundel
> Compliance Services
> (717) 720-3267
> fax- (717) 720-3911
> [email protected]
>=========================================================
> ====================
> This message contains privileged and confidential information intended
for
> the above addressees only. If you receive this message in error please
> delete or destroy this message and/or attachments.
>
> The sender of this message will fully cooperate in the civil and criminal
> prosecution of any individual engaging in the unauthorized use of this
> message.
>=========================================================
>====================
From: Foss, Ian

Sent: 26 May 201715:15:28 +0000
To: !(b)(5) I
Subject: RE:Charter Day School
It looks like the EIN on the ECFmatches the EIN for the (c){3} that is the charter school, itself, suggesting
that the borrower is an employee of the (c}(3). Since we are digging deeper on this school, it may be
worth asking the authorized official who issues W-2s to the borrower; or, rather, who is listed as the
employer on the W-2, but the management agreement, ECF,and Form 990 strongly suggests that it is
the (c){3).
Why would FedLoan have previously denied this organization? On the face of the ECF,everything checks
out.
From: l(bJ(5J
--~~~
Sent: Thursday, May 25, 2017 10:23 AM
To: Foss, Ian
Subject: Fw: Charter Day School
Hi Ian,
This was an organization that I meant to discuss with you yesterday. The write-up below
accurately explains how the charter school is organized. The 501(c)(3) charter school uses a for-
profit organization for management service; however, the school board and non-profit of the
charter school has the authority to hire, fire, and to discipline employees. A portion of the
management agreement is in the zip file. I've also attached the full Form 990 for the Charter
Day School (listed on the ECF). Schedule Lhasa long explanation of the services the
management service provides.
I think this organization should qualify. The Form 990 for the school also lists the employees on
the form. I will send the PW separately.
Thanks,
Taneka

To: l(b)(5J I
Subject: Charter Day School
Hi Taneka! We had previously denied this organization. Although Charter Day School is 501 (c)(3), they
contract with The Roger Bacon Academy, Inc (RBA) for management services. RBA is for-profit.
The school had recently contacted the Business Unit regarding the denial. They indicated that they
indeed have a contractor to handle day to day operations, but the school board is still in charge of the
school and decision making. I requested that the school to provide additional documentation of their
management agreement.
The school faxed in additional documentation (denoted as Additional Information - From Employer in the
attached filed). While it is not the complete agreement, they seemed to include the applicable sections. I
wanted to escalate for your review. If you would like the entire agreement, I can have the Business Unit
reach out to the employer again.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: l(b)(5)
Sent: 28 Apr 2014 18:12:00 +DODO
To: 'Fedloan PSLF'
Cc: l(b)(5J I
lan;Battle, Cynthia;Johnson, Debbe
Subject: RE: Cherokee County Commission on Alcohol and Drug Abuse
Diane,
When looking at Form 990 Schedule A, the foundation a~scrts that the employer is a "private foundation"
(which is what line 7 is about) and which would be tax-exempt under Section 50l(c)(3). But we can find
no record of that. I don't think we have enough for me to agree that thi~ is government, or qualifying under
any other category. We need more documentation or it~ 50 I (c )(3) status.
Ian
From: Diane Freundel Lmailto:dfreunde:11-pheaa.or1tJ
On BehalfOfFedLoan PSLF
Sent: Friday, April 25, 2014 9:08 AM
To:l(b)(5) I
Subject: Cherokee County Commission on Alcohol and Drug Abuse
Hi Ian, We're having some difficulties with this one. We think they may
be quasi-governmental, but we're not sure based on an entry on Schedule A of the Cherokee County
Commission on Alcohol and Drug Abuse Foundation's Form 990.
ECF indicates 501(c)(3)- we could find no evidence of this.
We found a bu~incss filing and Form 990 for the Cherokee County Commission on Alcohol and Drug
Abmc Foundation which i~ 50l(c)(3). Schedule A li~t~the Cherokee County Commi~~ion on Alcohol and
Drug Abmc as a "type 7"
organin1tion - an organization that normally receives a ~ub~tantial part of its support from a governmental
unit or from the general public dc~cribcd
in section l 70(b)( I )(A)(vi). [fit was definitely governmental, we would
have expected it to be listed a~ a "type 6" organiLation - a f'cderaL slate, or local government or
governmental unit described in section 170
(b)(l)(A)(,)
In the South Carolina stale government there is a cabinet level department

- South Carolina Dept of Alcohol and Other Drug Abuse Services (DAODAS).
DAODAS offers a wide array of prevention, intervention, and treatment services through its statewide
network of nationally accredited county alcohol and drug abuse authorities, one ofwhich is the Cherokee
County Commission on Alcohol and Drug Abuse.
The fact that we couldn't locate a business filing also leads us to believe it's government.
We appreciate your thoughts. Password to follow. Thanks!!
(See attached file: Cherokee County Commission on Alcohol and Drug

Abuse.zip)
Diane Frcundcl
Compliance Service~
(717) 720-3267
fax-(717) 720-3911
[email protected]
you receive this message in error pkasc delete or destroy thi~ rnc~~agc and/or attachment~.
The sender of this message will fully cooperate in the civil and criminal pro~ccution of any individual
engaging in the unauthorized me ofthi~ mc~~agc.
From: l(b)(5)
Sent: 30 Oct 2014 15:28:14 -0500
To: Fedloan PSLF
Cc: l(b)(5J I
Cynthia;Johnson, Debbe
Subject: RE: Cherokee Nation Technology Solutions
Hi Diane,
I couldn't find anything more on this one than you could. I would rcquc~t the organizing document~ of the
organin1tion to better understand the n:lation~hip between the tribe and the LLC.
Ian
From: Diane Frcundcl [rnaiHo:dfn::undc:11.phcaa.orn]On BchalfOfFcdLoan PSLF
Sent: Friday, October 03, 2014 10:22 A\1
To: l(b)(5) I
Subject: Cherokee Nation Technology Solutions
Hi Ian, This is another tribal related entity that we're unsure of, although we don't think it qualifies.
1. ECF is certified as government
2. Business filing indicates it's an LLC
3. Cherokee Nation Technology Solutions is wholly O\Vnedby the Cherokee Nation and is part of the
Cherokee Nation Businesses family of companies - pg 2 of Cherokee Nation Businesses - Technology
Divi~ion.pdf
4. Cherokee Nation Bminesse~ i~ a wholly owned corporation of the Cherokee Nation and ~en·c~ a~ the
holding company for all of the Cherokee Nation's for profit cntitic~ - pg 2 of Cherokee Nation Bminess.pdf
llcm 4 is what leads u~ to believe that they don't qualify. We

appreciate your thoughts. Password to follow. Thanks!
(Sec attached file: Cherokee Nation Technology Solutions.Lip)
Diane Frcundcl
Compliance Services
(717) 720-3267
fax-(717) 720-391 I
d freunde(i1;pheaa.org
you receive this message in effor please delete or destroy this message and/or attachments.
From: l(b)(5)
Sent: 25 Sep 2015 18:10:59 +0000
Cc: Battle, Cynthia;Johnson, Debbe
Hi Diane,
We agree that Cherokee Nation Technology Solution~ docs not qualify.
Thanh,
Taneka
From: Diane Freundcl [rnaiHo:dfn::unde:11.pheaa.orn]On BehalfOfFedLoan PSLF
Sent: Tuesday, September 22, 2015 10:06 AM
To:l(b)(5) I
Cc: Battle, Cynthia; Johnson, Debbe; FedLoan PSLF
Hi Taneka, This one is old, but we finally got additional information.

The borrower who prompted the email exchange belO\v never responded when \Ve asked for additional
information. Another borrower subsequently submitted an ECF and \Ve asked them for the organizing
documents of the organization.
This borrower responded. Based on the attached. we believe the organization doesn't qualit)"".The
Certificate of Business specifically states it's for
profit. Since FSA looked at this previously, and because it's related to
a tribal organization, we'd like your agreement before we deny. Please let us know. Thank~!
( Sec attached file: A11iclc~of Organization_ CNTS.pdf) (Sec attached file: Certificates of
Bu~incs~_CNTS.pdf)
Diane Freundcl
Compliance Service~
(717) 720-3267
fax-(717) 720-3911
d frcunde(a;pheaa .org
l(b)(5) I(b)(5)
To:"FedLoan PSLF" <FedLoanPSLF(r'1~pheaa.org>
l(b)(5) ll(b)(5) I
"Battle, Cynthia"
<Cynthia.Battle(i1~ed.gov>,"Johnson, Debbe"
<[email protected]>
Date: 10/30/2014 04:29 PM
Subject:RE: Cherokee Nation Technology Solutions
Hi Diane,
I couldn't find anything more on this one than you could. I would rcquc~t the organizing document~ of the
organin1tion to better understand the rclation~hip between the tribe and the LLC.
Ian
-----Original Mc~~agc-----
From: Diane Frcundcl rmailto:dfreundc:ciphcaa.orgl On BchalfOfFcdLoan PSLF
Sent: Frida , October 03, 2014 10:22 A\1
To: (b)(5)
Subject: Cherokee Nation Technology Solutions
Iii Ian, Thi~ 1~another tribal related entity that we're unsure of, although we don't think it qualifies.
I. ECF is certilicd as government
2. Business filing indicates it's an LLC
3. Cherokee Nation Technology Solutions is wholly ovmed by the Cherokee Nation and is part of the
Cherokee Nation Businesses family of companies - pg 2 of Cherokee Nation Businesses - Technology
Division.pdf
4. Cherokee Nation Businesses is a \vholly owned corporation of the Cherokee Nation and serves as the
holding company for all of the Cherokee Nation's for profit entities - pg 2 of Cherokee Nation Business.pdf
Item 4 is \vhat leads us to believe that they don't qualit)'". We

appreciate your thoughts. Password to follow. Thanks!
(Sec attached file: Cherokee Nation Technology Solutions.?ip)
Diane Frcundcl
Compliance Service~
(717) 720-3267
fax-(717) 720-3911
d freunde(a;phcaa .org
This message contain~ privileged and confidential information intended for the above addre~~ees only. If
you receive this message in error please delete or destroy thi~ message and/or allachments.
The sender of this message will fully cooperate in the civil and c1iminal prosecution of any individual
Code:PHEAA
From: Foss, Ian

Sent: 6 May 2014 16:13:45 +DODO
To: 'Fedloan PSLF'
Subject: RE: Chickasaw Nation Industries Inc
I can do tomorrow from 11 to 12 or at or after 3pm.
From: Diane Frcundcl rmailto:dfrcundc:ciphcaa.orgl On BchalfOfFcdLoan PSLF
Sent: Tue~day, May 06, 2014 9:55 A\1
To: l(b)(5) I
Ce: Batlle, Cynthia; Johnson, Debbe; FedLoan PSLF; Fos~, Ian
Iii Ian, Unfortunately our denial letter 1~ fairly generic. lt_1ust says
that the organization doesn't qualify. I've informed the Business Unit
that they need to add more specificity to the denials.
Kim and I would like to talk to you about this one and another tribal
organization - I'll send that one to you before we talk. We're trying to
gain more knowledge of these so 1,vedon't have to escalate them.
Let us knO\v if you have any time this week. A 1/2 hour 1,vouldbe plenty.
Thanks!
Diane Freundel
Compliance Services
(717) 720-3267
fax-(717) 720-3911
dfrcundc((_l'.phcaa.org
From: l(b)(5) I(b)(5)

To: "FedLoan PSLF" <FedLoanPSLF(a;pheaa.org>
Cc: "Battle, Cynthia" <Cynthia.Balllcd)ed. ov>, "John~on, Debbe"
<Debbc.John~on(a;ed.gov>, (b)(5) (b)(5)
~---~•--------~
"Foss, Ian" <lan.Foss(d)ed.gov>
Date: 04/28/2014 11:37 AM
Hi Diane,
I think that Article 1.03 of the chatter makes it pretty clear that this is not tribal government and, as such,
does not qualify. Indeed, the article specifically says that that the corporation is not part of the tribe and its
actions are not the actions of the tribe. Since it's not governmental, it can only qualify as a not-for-profit,
and the borrO\ver specifically says it is a for-profit corporation.
Therefore. it doc~ not qualify.
I'm concerned, though. about the borrower not being told why the organization didn't qualify. What kind of
information was thi~ borrower ~cnt about why we said it was non-qualifying work?
Ian
From: Diane Frcundcl rmailto:dfreundc:cipheaa.orgl On BchalfOfFedLoan PSLF
Sent: Wcdnc~da ·, April 23, 2014 10:56 A\1
To: (b)(5)
Cc: Battle, Cynthia; Johnson, Dcbbc; f-cdLoan PSLF; Fo~~, Ian
Subject: Re: Chickasaw Nation lndust1ies Inc
Iii Ian, Ba~ed on our denial, the bmrnwer provided a copy of the Charier of Incorporation which shows
that the entity is a Federally Chartered Tribal Business Corporation. Based on the guidance you provided
on 12/09/13 for Valley View Casino and IloteL and in light of the new information, we think that the
Chickasaw Nation Industries Inc may be considered a~
government. However, the "for profit" business filing still causes us to
question it Attached is the complete file, including the Chatter of
Incorporation. Passvmrd to follow. Thanks again!
(See attached file: Chickasaw Nation Industries, Inc.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax-(717) 720-3911
[email protected]
From: l(b)(5) I(b)(5)

To: "FcdLoan PSLF" <FcdLoanPSLF(a;phcaa.org>
Cc: l(b)(5) ll(b)(5) I
"Battle, Cynthia"
<Cynlhia.Battlc(a;ed.gov>, "John~on, Debbe"
<Debbe.John~on(a;ed.gov>, "Fos~, Ian" <lan.Foss(d)cd.gov>
Date: 01/27/2014 09:32 AM
Subject: Re: Chickasaw Nation Industries Inc
Hi Diane,
We agree that this one does not qualit)'.
Thanks,
Ian
On 12/4/13, 23:41, 'TcdLoan PSLP <f-cdLoanPSLf-((j)phcaa.org> wrote:
>
>Hi Ian, We're un~ure about thi~ one.
>
> 1. ECF certified as government
>
>2. Website indicates they are a federally chartered corporation wholly

>owned by the Chickasaw Nation.
>
>3. Bminess filing indicate~ they arc for profit.
>
>I don't think they qualify due to for profit ~tatu~, hut I wa~n't ~urc
>if they would be con~idered government since they're owned hy the
>Chickasaw Nation.
>
> Password to follow. Thanks!
>
>(Sec allachcd file: Chickasaw Nation lndust1ies, Inc.Lip)
>
>Diane Frcundcl
>Compliance Services
>(717) 720-3267
>fax- (717) 720-3911
>dfreunde(iijpheaa.org
>This message contains privileged and confidential information intended
>for the above addressees only. If you receive this message in error
>please delete or destroy this message and/or attachments.
>
>The sender of this message will fully cooperate in the civil and
>criminal prosecution of any individual engaging in the unauthorized use
>of this message.
Thi~ message contain~ privileged and confidential information intended for the above addrc~~ccs only. If
you receive this message in error please delete or destroy thi~ mc~~agc and/or attachment~.
The sender of this message will fully cooperate in the civil and niminal prosecution of any individual
From: l(b)(5)
Sent: 27 Jun 2013 09:11:58 -0500
To: Fedloan PSLF
Cc: l(b)(5J I
lan;Johnson, Debbe;Ninemire, Sandra
Subject: Re: Children's Hospital of Michigan
Diane,
Unless the EIN i~just cut off on the scanned version 11m looking at_ we
have a defect in the [CF that is preventing me from isolating who the
employer is. VIIS Children'~ llo~pital of Michigan, the for-profit. seems
lo have purchased (and now operates) the nol-for-prolit that is now
legally called 'Legacy CIIS 2 • Legacy CIIS is still a not-for-profit under
slate law, and still will likely employ people. In addition, Legacy CIIS
is a 501(c)(J)d was tipped off by looking at the restated articb or
organiLation from 2011; it ~ays they arc organiLcd exclu~1vcly for
purposes under section 50 I (c)(3) of the !RC.
That being said. the numbers in the EIN that were provided do not match
the non-profit, the for-profit, or the Detroit Medical Center.
So, we need more infonnation.
Ian
On 5/20/13, 10:56, "Fed loan PSLF" <[email protected]> wrote:
>
>Hi Ian, We're not ~un: of the approval ending date on this one became
>the
>employer became for profit. We also sec what look~ like a discrepancy in
>the bu~incss filing.
>
>ECF indicates private non-profit that provides emergency management and
>public health services.
>
>ECF lists employment from 09/0]/2002 lo 04/24/2013. Approval begin dale
>will be 10/02/2007.
>
>Business filing 2 Ml document shows that Children's Hospital of MI is a
>domestic non-profit with an incorporation/qualification date of
>03/08/ 1922,
>with an active status as of"present".
>
>Business filing MI document shows that VHS Children's Hospital of Ml, Inc
>is a foreign for profit with an incorporation/qualification date of
>06/23/2010, \Vith an active status as of "present".
>
>The childrensdmc document shO\vsthat Children's Hosp of \11 is a member of
>the Detroit Medical Center (DMC).
>
>The wiki article shows that DMC formally became a part of Vanguard Health
>System~ (VHS) on 12/30/2010 as a for profit corporation.
>
>We're not sure if the approved employment ~hould end 06/22/2010 (the day
>before the incorporation/qualification date for VHS Children's Hosp of Ml)

>or 12/29/2010 (the day before D\t!C formally became a part of VHS).
>We're
>also un~ure what to do ~inn; the bminess filing for the non-profit
>Children'~ Ho~p of Ml ~till shows an active statm.
>
>I think the qualifying employment should end 06/22/2010. Appreciate
>your thoughts. Password to follow. Thanks
>
>(Sec allachcd file: Children's Ilospital of\1ichigan.zip)
>
>Diane Frcundd
>(717) 720-3267
>fax- (717) 720-3911
>for the above addressees only. If you
>receive this message in error please delete or destroy this message
>and/or attachments.
>
>The sender of this message will fully cooperate in the civil and criminal
>prosecution of any individual engaging
>in the unauthorized use of this message.
From: l(b)(5)
Sent: 16 Apr 2014 14:38:48 +DODO

To: 'Fedloan PSLF'
Cc: l(b)(5J I
Cynthia;Johnson, Debbe;Foss, Ian
Subject: RE: Citizens Utility Board of Illinois
Hi Diane,
I think thi~ organization is quasi-governmental. It is organized a "body corporate and politic" and performs
a function that i~ conducted by pure governmental cntitie~ in many other ~tatc~. Take a look at the "CUB
/\ct": ht Ip:i .\vww. c itiLensuti 1ity buard. urg/pd bi CU 13_A CT. pd f.
For an example, here's how Maryland is organized: http://www.upc.stak.md.lt~/. llcrc's another example
from San Franci~co: http://www.sr,valcr.org/mudules,\howdocumcnt.aspx?documcnt1d= 1883.
I would expect that many "CUB"s would be organized in a similar fashion. Ilere\ a study that discussc~
them more thoroughly: http://www.cpi1.org/down1ond/CUB Repo1t.pdf.
Ian
From: Diane Freundel Lmnilto:dfreunde:11-phenn.or!!.I
On BehnlfOfFedLoan PSLF
Sent: Tuesdav, April 15. 2014 9:36 AM
To:l(b)(5) I
Subject: Citizens Utility Hoard of Illinois
(b)(5)
Pas~word to follow. Thanks!
(Sec attached file: Citizens Utility Board.zip)
Diane Freundcl
Compliance Service~
(717) 720-3267
fax-(717) 720-391 I
d freunde(i1;phean.org
you receive this message in effor please delete or destroy this message and/or attnchments.
The sender of this message will fully coopernte in the civil nnd criminal prosecution of any individual
From: l(b)(5)
Sent: 11 Aug 2014 19:51:38 +0000
To: 'Fedloan PSLF'
Cc: l(b)(5J I lan;Johnson, Debbe;Battle, Cynthia
Subject: RE: Civitas Schools
Hi Diane,
This one is going to turn on whether the organization is a not-for-profit organization.
In Illinois, charter schools are required to be organized as a separate, non-profit organization. Here, it
seems that we are dealing with a charter school management corporation. Here's what Illinois law says
on the matter:
(h) A charter school may negotiate and contract with a school district, the governing body of a
State college or university or public community college, or any other public or for-profit or
nonprofit private entity for: (i) the use of a school building and grounds or any other real
property or facilities that the charter school desires to use or convert for use as a charter school
site, (ii) the operation and maintenance thereof and (iii) the provision of any service, activity, or
undertaking that the charter school is required to perform in order to carry out the terms of its
charter. However, a charter school that is established on or after the effective date of this
amendatory Act of the 93rd General Assembly and that operates in a city having a population
exceeding 500,000 may not contract with a for-profit entity to manage or operate the school
during the period that commences on the effective date of this amendatory Act of the 93rd
General Assembly and concludes at the end of the 2004-2005 school year. Except as provided in
subsection (i) of this Section, a school district may charge a charter school reasonable rent for
the use of the district's buildings, grounds, and facilities. Any services for which a charter school
contracts with a school district shall be provided by the district at cost. Any services for which a
charter school contracts with a local school board or with the governing body of a State college
or university or public community college shall be provided by the public entity at cost.
As I read it, the prohibition on the contracting with a for-profit organization ended at the end of the
2004-2005 school year, and, as such, we cannot determine from Illinois law whether the organization is
a for-profit or a not-for-profit organization.
Because the organization is an LLC,and because Illinois doesn't make articles of

organization/incorporation publicity available, I looked in the Illinois code to see if an LLCcould be a not-
for-profit organization under state law. Basically, it seems to say that an LLCcould be a not-for-profit
organization (the LLClaw defines "business" with language including "whether or not carried on for
profit"). But between the fact that there is a distinct not-for-profit corporation under Illinois law, and
because the LLChas a 401(k) plan (which a not-for-profit could have, but usually doesn't), I suspect this
is organized as a for-profit organization.
Now, the LLCis wholly owned by a 501(c)(3), the foundation. And, because that is the case, the IRS
treats the LLCas indistinct from its own (as a disregarded entity) unless the 510(cl(3) elects a different
treatment. This causes the disregarded entity (in this case, the LLC)to receive the benefit (and
consequences) of tax-exemption. Therefore, for the period up until the foundation stopped reporting
the LLCas a disregarded entity, I think the LLCqualifies as 501(c)(3). After that point, however, I think
the LLC has to stand on its own, and, as a result, doesn't qualify. The other LLC (Civitas Education
Partners)-the LLCfrom the foundation's 2012 Form 990-is separately organized from Civitas Schools.
Though an EIN search for Education Partners in Westlaw turns up nothing (neither does a name search),
you can find it in the Illinois corporations search. So, I don't think the Education Partners LLC has any
bearing on the eligibility of the Schools LLC.
In short, I agree with you.
Ian
To: !(b)(51 I
Subject: Civitas Schools
Hi Ian, We'd like your input on this one.
L ECF- neither box a, nor b, nor c is checked, but public education is checked. Many times this leads us
to believe that the organization doesn't qualify and the employer is, in effect, not certifying eligibility.
However, we've also seen cases where no box is checked and the organization definitely qualifies.
Employment dates are 8/3/2006 to 7/4/2014.
2. Based on website, Civitas Schools manages 3 Chicago International Charter School campuses.
3. On the Chicago Charter School Foundation's (dba Chicago International Charter School) 2010 and
2011 Form 990 Schedule R (page 29 of 33 in .pdf) Civitas Schools LLCwith the same EIN provided on ECF
is listed as a disregarded entity.
4. On the Chicago Charter School Foundation's 2012 Form 990 Schedule R, Civitas Schools LLC is no
longer named. Instead there is a disregarded entity with the name of Civitas Education Partners LLC
with a different EIN.
5. We believe the employer as certified on the ECFcan be approved through

06/30/2011 because that's the year end date for the 2011 Form 990. Do you agree? Also, can you find
anything regarding the status of this EIN after 06/30/2011? If not, we'll ask the Business Unit to contact
the employer.
(See attached file: Civitas Schools.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
[email protected]
From: l(b)(5)
Sent: 8 Aug 2014 19:37:28 +0000
To: 'Fedloan PSLF'
Cc: Foss, lan;Battle, Cynthia;Johnson, cl(b~)(~5)~----~
Subject: RE: Clark Memorial Hospital/ Clark Physicians Group
Hi Diane,
Thi~ organization doesn't qualify. It a for-profit organization that is ~cparatc and apart from the ho~pital.
The articles of organization for the LLC doesn't even try to anything about it being a not-for-profit. To me,
this ]ooh like the traditional "physician group" arrangement. The hospital has cho~cn to affiliate with a
group of physician~. This generally involves referrals, allowing them attending phy~ician privileges in the
hospital, the u~c of the hospital's more advanced equipment, and, sometimes, office space in the hospital.
Ian
Sent: Monday, August 04, 2014 4:23 PM
To:l(b)(5) I
Subject: Clark Memorial Hospital/ Clark Physicians Group
Hi Ian, Can you please review this one. We kno\v that typically a
physicians group doesn't qualify but we found a fev,· things that made us question this one.
1. Certified as private non-profit providing public health services on ECF.
2. On the Clark County Hospital Foundation's 2012 Form 990 Schedule R, Clark Memorial Hospital is
listed as county owned. GuidcStar Amcx Organization Rcpm1 indicates they arc 501 (c)(3).
3. Bu~incss filing for Clark Memorial Ho~pital indicates they arc not-for-profit, but the statm i~ voluntarily
di~~olvcd.
4. Bu~incss filing for Clark Physicians Group is that it's an LLC. ll also shows many other assumed names,
many with Clark Memorial I lospital Medical Center as part of one of its names, including Clark Memorial
Ilospital
Medical Center - Ilavens \1cdical Group. When we googlcd the address or
Clark Physicians Group, we found llavcns Medical Group, conlim1ing they arc the same entity.
5. An article we found on the Clark Memorial Hospital's website indicates

that the Physicians Group is an "extension" of the hospital. This is what
made us second guess our inclination to deny. We thought about asking for additional proof, but wanted to
run it by you first.
We appreciate your help! Password to follow. Thanks
(See attached file: Clark Memorial Hospital_ Clark Physician's Group.zip)
Diane Freundel
Compliance Service~
(717) 720-3267
fax-(717) 720-3911
d frcundc((_l'.phcaa.
org
Thi~ message contain~ pri\'ilcgcd and confidential information intended for the abo\'c addrc~~ccs only. If
engaging in the unauthorized me ofthi~ me~~age.
From: l(b)(5)
Sent: 6 Feb 2012 08:30:46 -0600

To: Diane L(b~l(~5~1
------~
Cc: [email protected]
Subject: RE: Cleveland Clinic Foundation
Attachments: Cleveland Clinic Foundation.xis
Diane,
Good catch on this on. I'm comfortable allowing it too, a~ a

50l(c)(3) organization. Again, the borrower appears to have ~ccn the list
of qualil)ling ~crvicc~, and checked the wrong hox as a result.
There arc
two EIN~ in Pub 78 that both tic back to the Cleveland Clinic Foundation.
One, listed on the bonowcr\ ECF docs not have an address that attachc~ to
the EIN listed on the ECF. Ilowcvcr, the second EIN, that was not li~tcd on
the ECF, has an address listed on the ECF.
I pulled the relevant Business

Master File from the IRS (see attached for an excerpt) and found that the
EIN listed on the ECF has a group exemption and the other EIN, for the entty
not on the ECF, is affiliated with the group-exempt EIN (are you lost yet).
So. I think it's entirely possible that the EIN listed on the ECF might
cover the location that the borrower is at, despite the address being tied
to the ElN that was not listed on the ECF. 1 might be mistaken, but some
501 (c)(3) organization will do payroll out of the "big pot", or the group
exemption, and will fund other thing~ out of the subordinate exemption.
Really, it'~ all one organization, and it qualific~. so thi~ E(T is valid.
However, I wouldn't be able to find out more without seeing the IRS ruling
that created the subordinate.
More on group exemption~ may he found here:

h tlp ://www. lfs. !!O\. /pu b/Jrs-pd f/p4 57 3 .pd f
Ian
> -----Original
Message-----
> From: Diane Freundel Lmnilto:dfreunde:11-aessuccess.orgI
> Sent:
Friday, February 03, 2012 4:41 PM
> To: l(b)(5) I
> Cc:
[email protected]
> Subject: Cleveland Clinic Foundation
>
>
> Ian, The
issue with the secure emails may be due to me including a 9 digit
> number
(the EIN) - our security sy~tcm recognizes a 9 digit number as an SSN
>and
defaults to '\ccurc". I will put 2 leading zero~ in front of all EINs.
>
>
We believe thi~ is a qualifying organi?ation. hut there arc ~omc
conflicts.
>
> [CF ~how~ it as a private non-profit which ~ccm~ to
correspond with the Ohio
> Corporation detail~ (both in attachment).
>
>
Organization is also li~tcd on the IRS !isl a~ a 50l(c)(3).
>
> The EIN and
addrc~~ on the ECF do not match the IRS list.
>
> ECF:
> EIN -
00-34-0714585
> Address - 9500 Euclid Ave, Cleveland, OH
>
> IRS:
> EIN -
00-34-0714585
> Address - 6801 Brecksville Rd, Independence, OH And EIN -
00-91-2153073
> Addrc~~ - 9500 Euclid Ave, Cleveland, OH
>
> Pas~word in a
~cparatc email.
>
> I think I'm over analyzing thc~c. Thanks.
>
> (Sec
allachcd file: Cleveland Clinic Foundation.zip)
>
> Diane Frcundcl
>
Compliance Services
> (717) 720-3267
> fax-(717) 720-391 I
>
>
--------------------------------
> This message contains privileged and confidential

information intended for
> the above addressees only. If you receive thi~
message in error please
> delete or dc~troy thi~ message and/or
attachmcnb.
>
> The sender of this message will fully cooperate in the
civil and criminal
> prosecution of any individual engaging in the
unauthorized use of this

> message.
>
--------------------------------
>

Sent: 23 Feb 2015 10:45:03 -0600
To: Fedloan PSLF
Cc: Ll(b~l(~51
_____ ~1
Cynthia;Foss, Ian
Subject: RE: Coin Center Inc
Hi Diane,
I agree that this one should be denied on the ba~i~ that Coin Center, Inc. docs not provide a qualifying
public ~crvicc. I pulled thi~ ~ub-rcgulatmy definition from a previous decision that wa~ escalated to PLI:
"For PSLF purpose~. the Department consider~ "public education services" to be services that provide
educational enrichment or support directly to students or their families in a ~chool or school-like ~citing."
Coin Center i~ an advocacy group that provides infonnation to the general public. On their Certificate of
Incoq1oration the company\ purpo~c is listed as: "The purpo~cs for which the Corporation is formed arc to
develop and advocate sound public policy toward and use of ctyptocurrency technologies such as Bitcoin."
Additionally, since the majority Coin Center's limited educational activities are directed primarily to the
general public, and not in a school or school-like setting, Coin Center does not provide public education for
the purposes of the PSLF Program.
Please let me know if you have questions or concerns. Also, just to let you know, I am consulting \vith Ian
and Cindy on these decisions as I continue my transition into handling escalations for the PSLF program.
Thanks,
Taneka
Sent: Frida , January 30, 2015 10:24 A\1
To: (b)(5)
Subject: Coin Center Inc
Iii Ian, We originally denied this employer in October 2014. ECF certified
a~ private non-profit providing public education. At the time we could
find no conclu~1vc evidence of not- for-profit ~talus; however, even if they were not- for-profit we did not
feel that they provide a qualifying public service - definitely not public education.
The borrower sent a dispute and provided a certificate of incorporation in the state of Delaware that
indicates they are organized and operated
exclusively for purposes within the meaning of 501 (c)(4) of the IRC. We
still do not believe that they provide a qualifying service, but since the borrower disputed, we wanted your
input.
Passv,rord to follow. Thanks!
(See attached file: Coin Center Inc.zip)
Diane Frcundcl
Compliance Service~
(717) 720-3267
[email protected]
you receive this message in error pkasc delete or destroy thi~ rnc~~agc and/or attachment~.
From: l(b)(5)
Sent: 15 Jun 2012 12:15:41-0500
Cc: Ninemire, Sandra;Sipple-Asher, Bessie;Foss, lan;Johnson, Debbe
Subject: Re: Colorado Municipal League
Diane,
Since they arc an in~trumcntality of local government~, they qualify

under
the government category. This is our first
intergovernmental
organiLation, I think.
Ian
On 6/6/12 10:53, "FedLoan

PSLF" <[email protected]> 1Nrote:
>
>Hi Ian, I'm having trouble with
this one. They are listed as a
>non-profit and as such I don't believe
they perform a qualit)'ing public
>service. However, they checked the
government box and indicated that they
>are an instrumentality of Colorado
municipalities. Their by-laws also
>indicate that they arc an
in~trumcntality of Colorado cities and towns
>acting through their appointed
official~. I ~cc ~omc comparison to
>state
>bar associations for which we
concluded they were probably all
>quasi-governmental.
>
> I lend lo think
they qualify as government. Your thoughts? Pa~~word to
>fol\01N.
thanks!
>
>(See attached file: Colorado Municipal League.zip)
>
>Diane
Freundel
>(717) 720-3267
>fax- (717)
720-3911
>dfrcundc((j)phcaa.org
>This mc~sagc contain~ privileged and
confidential infomrntion intended
>for the above addrc~~ccs only. If
you
>receive this message in error please delete or destroy this

message
>
>The ~ender of this mc~~agc will fully
>prosecution of any individual
cngagmg
From: l(b)(5)
Sent: 28 Feb 2012 07:45:07 -0600
To: Fedloan PSLF
Cc: ----~I
cl(b~)(~5~) lan;Ninemire, Sandra;Sipple-Asher, Bessie;Johnson,
Debbe
Subject: RE: Columbia Physical Therapy PS
I agree that this is a for-profit entity and therefore docs not qualify. You
may ~top c~calating ca~c~ where the employer i~ clearly for-profit. [fit's
a close case, or you're not sure that it'~ a clear ca~c, then go ahead and
continue c~calating it.

> From: Diane Freundcl
[mailto:dfn::unde(dacssL1cc.:ss.urglOn Behalf Of
> FedLoan PSLF
> Sent: Monday,
February 27, 2012 8:07 PM
> To: l(b)(5) I
> Subject: Columbia Physical
Therapy PS
>
>
> Hi, Please see the attached ECF and information from the
WA Corporations
> Division. This entity is for profit. Please let us know
if you want to
> continue to see entities that checked box c that are for
profit. Pa~~word
> to follow. Thanks!
>
> (Sec attached file: Columbia
Physical Therapy_ Hodgson.zip)
>
> Diane Freundcl
>
(717) 720-3267
> fax-(717) 720-3911
> dfreunde(i1;pheaa.org
>
>

> the above addressees only. If you receive this
> delete or destroy this message and/or
attachments.
>
civil and criminal
unauthorized u~c ofthi~
> message.
>
From: l(b)(5)
Sent: 26 Feb 2013 09:34:33 -0600
To: Fedloan PSLF
Cc: Ll(b~l(~51
____ ~1lan;Johnson, Debbe;Sipple-Asher, Bessie;Ninemire,
Sandra
Subject: Re: Conference on Jewish Material Claims Against Germany
Hi Diane,
We agree that this organin1tion docs not qualify for PSLF. They don't
provide anything that would traditionally be con~idcrcd legal services,
and they do not have clients, as such.
Thanh,
Ian
On 12/27/12 20:48, "FedLoan PSLF" <[email protected]> wrote:
>
>Hi Ian, This is another one that I'm hesitant to deny, but I don't think
>they provide a qualit'ying "public" service. They are a 50l(c)(4) - their
>mission is to secure a small measure of justice for Jewish victims of Nazi
>persecution through a combination of negotiations. disbursing funds to
>individuals and organizations. and seeking the return of Jev,rish property
>lost during the Holocaust. I don't see their eff0rts as being for the
>public, instead they benefit a select group of people. We appreciate your
>thoughts.
>
>Password to follow. I got an error mc~~agc when creating zip file, but
>didn't have any problems opening the documcnb. Let me know if you do.
>Thank~
>
>(Sec attached file: Conference on Jewish Material Claims Against
>Gennany.zip)
>
>
>Diane Freundcl
>(717) 720-3267
>fax- (717) 720-3911
>
From: l(b)(5)
Sent: 1 Mar 2012 09:27:27 -0600
Cc: Foss, lan;Ninemire, Sandra;Johnson, Debbe
Subject: RE: Connecticut Innovations
Hi Diane,
According to their 2011 Annual Report, they operate a~ a venture

capital fund aimed at growing the emerging technology sector in CT. It is a
quasi-public agency, created by the Innovation Capital Act of 1989 of the
Connecticut General Statutes.
http://www.ctmnmatiuns.com/mmual 20 1\ iindex.htmW/2iLoomcd
I am
confident that we can approve them under the government
categ01y.
Thanks,
Bessie
Direct Loans
Division
Federal Student Aid
Tel:
202-377-3145
Be~~ic.Sipp IcAshcr(j_i;cd.
gov
From:
Diane Freundel [mailto:dfreundc:11.acssucccss.org l On Behalf Of FedLoan
PSLF
Sent: Wednesdav, February 29, 2012 9:51 P\1
To: l(b)(5) I
Subject:
Connecticut Innovations
Hi, Another tough one that I think may be

quasi-government.
They checked government. Their \vebsite indicates they

\vere created by the
CT Legislature. Their by-laws state (pg 4) state that
the chairperson of the board is appointed by the governor with the advice
and con~cnt of the General Assembly. An article calls them a "venture
fund". I found them on EDGAR, but I don't understand what the documcnb
mean (~tatcmcnt of acquisition of beneficial ownership by indi\'iduals) - ~cc
link
below.
http ://viV.'V.'.sec. govic g i-b inibrowse-edgar'! act ion-getco mpanv &(_·IK -000 I O1
6008&type-&datcb-&owner-excludc&count-40
Appreciate your help. Pa~~word to

follow. Thanh!
(Sec attached file: Connecticut Innovations.zip)
Diane
Frcundcl
Compliance Service~
(717) 720-3267
fax-(717)
720-3911
This message contains privileged and

confidential information intended for the above addressees only. If you
receive this message in error please delete or destroy this message and/or
attachments.

and criminal prosecution of any individual engaging in the unauthorized use
of this
message.
--------------------------------
From: l(b)(5)
Sent: 31 Dec 2012 09:08:25 -0600
To: Fedloan PSLF
Cc: Ll(b~l(~51
____ ~1
lan;Ninemire, Sandra;Johnson, Debbe;Sipple-Asher,
Bessie
Subject: Re: Connective Intervention Services
Hi Diane,
I agree that this organin1tion i~ not a governmental organization, and

cannot qualify on that ba~i~. I also agree that it would not appear to
qualify on any other basis, as I could lind nothing to support the
conclusion that they arc a not-for-prolit organization.
Ian
On 12/14/12 15:21, "FcdLoan PSLF" <FedLoanPSLF(a/pheaa.org> wrote:
>
>Hi Ian, I'm pretty sure this employer doesn't qualify, but wanted your
>thoughts. They are an LLC. They checked the government box because it
>appears that they provide early intervention services to several PA
>counties. Password to fo!IO\v. Thanks!
>
>(See attached file: Connective Intervention Services.zip)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>This mc~sagc contain~ privileged and confidential information intended
>for the above addrc~~ccs only. If you
>receive thi~ mcs~agc in error plca~c delete or destroy this mc~~agc
>and,..or attachments.
>
>The ~ender of this mc~~agc will fully cooperate in the civil and criminal
From: l(b)(5)
Sent: 18 Feb 2016 13:56:50 +ODDO
To: Foss, Ian
Subject: RE: Consumer Federation of California
Thanh Ian!
From: Fo~~, Ian
Sent: Wcdnc~da ·, Fcbruaty 17, 2016 9:03 AM
To: (b)(5)
Subject: Re: Con~umcr Federation of California
We determined that Cy Pres awards arc not "government fund~" because they arc paid into a fund by a
private party: they arc simply ultimately distributed by the courts, So, thi~ organization doesn't qualify,
> On Feb 16, 2016, at 09:06,l~(b~)(~5)

__ ~1,~(b~)(5~)
______ ~wrote:
>
> I believe this should be denied but my issue is not so much with the decision as it is with the denial letter
the borrower most likely received, They letter should have pointed to the fact that the issue is not 1Niththe
organization providing public interest law services but in that we have no way to determine that the
organization is funded "in ,,,,..holeor in part by a local, State, Federal or Tribal government," I feel like they
are wasting the borrower's time by not telling them exactly what they what they need to prove for
reconsideration. The organization is a 501(c)(4) and any donation made to this organization is not tax
deductible. They also do not have to disclose any of their gifl:s so I don't kno\v if there is any other way to
determine how they are fonded,
>
> From: Kimberly A Myers [mailto:kmvcr~:ciphcmuirgl On BchalfOfFcdLoan PSLF
> Sent: Frida , February 05, 2016 9:15 AM
> To: (b)(5)
,-~~-~
> Subject: Con~umcr f-cdcration of California
>
> Hi Taneka, Although we still don't believe thi~ one qualific~ we arc forwarding to you since the
borrower 1~asking for reconsideration to our prcviou~ denial,
>
> The original ECF was cc11ilicda~ p1ivatc non-profit providing public intcrc~t law services, The
organiLation is a 50l(c)(4), but we could find no evidence that the organization is funded by any branch of
the government, Based on this, we didn't believe they qualified because 685,219(b) Definition~. Public
Interest Law refer~ to legal services provided by a public service organiLation funded in whole or in part by
a local, State, Federal or Tribal government We denied the borrower's employment in August 2014,
>
> Just last week, the borr01,verreached out directly to a member of our staff asking for reconsideration of
his denial, He outlined his job duties and indicated a significant proportion of his duties involve the
practice oflaw, While we agree that this organization does, in fact, perfonn legal services, we don't believe
the services qualify in respect to the PSLF Program. We attached the borrower's correspondence as well as
the research we performed.
>
> Your guidance is appreciated. Passv,rordto follow. Thanks!
>
>
>
> Kimberly A Myer~
> kmycr~½_~-phcaa.org<mailto:kmycrs((j)phcaa,org>
> (717) 720-2630
>
~~----~-~~-~~-
> This message contains privileged and confidential information intended for the above addressees only. If
you receive this message in error pkasc delete or destroy thi~ mc~~agc and/or attachment~.
>
> The sender of this message will fully cooperate in the civil and criminal pro~ccution of any individual
>
> Codc:PHEAA
> <Consumer Federal of California for FSA.Lip>
From: l(b)(5)
Sent: 18 Feb 2016 19:31:05 +0000
To: Fedloan PSLF
Cc: Battle, Ll(b~)(5~1
_____ ~
Hi Kirn,
Consumer Federation of California does not qualify since they are not,·- funded in whole or in
part by a local, State, Federal or Tribal government." OGC quickly determined that the Cy Pres
awards are not "government funds" because they are paid into a fund by a private party and
ultimately distributed by the courts.
Thanks,
Taneka
From: l~(b~l(~51--~
Sent: Tuesday, February 16, 2016 11:47 AM
To: Fedloan PSLF
Cc: l(bJ(5J I
Battle, Cynthia
Hi Kim,
We are forwarding this escalation to the Office of General Counsel (OGC) for a final determination after
1
coming across the Consumer Federation of California s Articles of Incorporation, Bylaws and funding
sources. On page 74, the CFClists "Court Ordered CY Pres Awards in Consumer Litigation" as a funding
source and we want to check if that could potentially make them governmental. The hyperlink for the
document is below.
https://www.google.com/url?sa-t&rct-j&q-&esrc-s&source-web&cd-9&ved-OahUKEwivsNr-
2PzKAhVDnlMKHYQ7B58QFghSMAg&ur1-https%3A%2F%2Ffanyv88.com%3A443%2Fhttp%2Fwww.insurance.ca.gov%2F01-
consu mers%2F150-other -prog%2F01-
i ntervenor%2Fup load%2 FReguestForFi ndi ngOfEligi bl ityF romConsumerFederationOfCa Iifornia.pdf&usg-
AFQjCNHpZeSt9nc6ymdvSyQT9R3iELnsug&sig2- kTyKl7 gAyETOXIYS3m uGQ&cad-rja
Thanks,
Taneka
From: Kimberly A Myers [mailto:[email protected] l On Behalf Of Fedloan PSLF
Sent: Frida , February 05, 2016 9:15 AM
To: (b)(5)
Subject: Consumer Federation of California
Hi Taneka, Although we still don't believe this one qualifies we are forwarding to you since the borrower is
asking for reconsideration to our previous denial.
The original ECF was certified as private non-profit providing public interest law services. The
organization is a 501(c)(4), but we could find no evidence that the organization is funded by any branch of
the government. Based on this, we didn't believe they qualified because 685.219(b) Definitions, Public
Interest Law refers to legal services provided by a public service organization funded in whole or in part
by a local, State, Federal or Tribal government. We denied the borrower's employment in August 2014.
Just last week, the borrower reached out directly to a member of our staff asking for reconsideration of his
denial. He outlined his job duties and indicated a significant proportion of his duties involve the practice of
law. While we agree that this organization does, in fact, perform legal services, we don't believe the
services qualify in respect to the PSLF Program. We attached the borrower's correspondence as well as
the research we performed.
Your guidance is appreciated. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
This message contains privileged and confidential infonnation intended for the above addressees
only. If you receive this message in error please delete or destroy this message and/or
attachments.
Code:PHEAA
From: l(b)(5)
Sent: 4 May 2017 15:04:11 +DODO
To: Fedloan PSLF
Cc: l(b)(5J I
Cynthia;Foss, lan;Odom, Christian
Subject: Re: Cumberland River Behavioral Health
Hi Kim,
Can Fed Loan go back to the authorizing official for Cumberland River Behavior Health to
confirm the EIN that should be used on the ECFs on the borrower. During our research
we also came across another EIN for Cumberland River Behavioral Health which is a
501(c)(3) also located in Kentucky. The organizations seem to be connected by the
Executive Director and website; however as you noted the EIN listed an EIN that ties to
the PEO.
https :// www .gu idesta r .org/profi Ie/23- 7313241
http://www.buzzfile.com/business/Cumberland-River-Behavioral-Health,-lnc.-606-528-7010
Thanks,
Taneka

Sent: Thursday, March 30, 2017 12:27:14 PM
To, !(b)(51 I
Subject: Cumberland River Behavioral Health
Hi Taneka! We are requesting your assistance on this one. This one is very similar to the
Riverbend Center for Mental Health I escalated a couple weeks ago; however, this one has a
twist to it.
Cumberland River Behavioral Health is a mental health facility; therefore, their primary purpose is
to provide counseling services which would not typically qualify for PSLF (but want to clarify in
light of the most recent guidance). However, the EIN ties to Erigo Inc, which appears to be a
PEO. We would need to reach out to determine the relationship between Cumberland River
Behavioral Health and Erigo Inc to determine if Erigo Inc solely acts as a PEO; however, I don't
want to unnecessarily request additional information if the organization wouldn't qualify in the first
place.
As always, your assistance is appreciated. Same password as Medica Health Plan. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
addressees only. If you receive this message in error please delete or destroy this
The sender of this message will fully cooperate in the civil and criminal prosecution of
any individual engaging in the unauthorized use of this message.
Code:PHEAA
From: l(b)(5)
Sent: 18 May 2012 13:32:31-0500
To: FedLoan l(b)(5J I
Cc: Foss, lan;Ninemire, Sandra;Sipple-Asher,
Bessie;Johnson, Debbe
Subject: RE: Curious Kids
Attachments: ION(38-6001950)_5-18-12_1322.pdf, EntityReport.pdf
Diane,
Believe it or not, this is part of the LEA.The EIN is tied to Portage Public
Schools. See attached {file starting "ION").
What's more, the Michigan Department of Education's database of schools
lists Curious Kids as an early childhood education center that is part of the LEA.
See attached (file starting "Entity").
The for-profit business that you found was dissolved in 2009, outside the
certification period--so I wouldn't worry about it. See here.
Ian
> From: Diane Freundel [mailto:[email protected]] On Behalf Of FedLoan
> PSLF
> Sent: Thursday, May 17, 2012 12:09 PM
> To: l(b)(5) I
> Subject: Curious Kids
>
>
> Hi everyone, I've been debating this one and have decided to seek your
> input.
>
> The certifying official listed them as a 501(c)(3). I couldn't find them in Pub
78
> or the BMF for Michigan. All of my research, including a google
> of the EIN, points to the public school system. However, there is a
> Curious Kids, Inc business filing in Ml that is for profit - different address and
I
> could find no association with the Curious Kids on the ECF.
> I don't know if it's possibly a franchise??
>
> As always, we appreciate your guidance. Password to follow. Thanks
>
> (See attached file: Curious Kids.zip)
>
> Diane Freundel
> (717) 720-3267
> fax- (717) 720-3911
> [email protected]
> This message contains privileged and confidential information intended for
>
> message.
Westlaw DeJh,eQ Summar)' Report for FOSS,IAN
Your Search: ID:-J{J8-6001950J

Date/Time of Request: Friday, May 18. 2012 13:22 Central
Client Identifier: 10660928S:-JGR
Database: FEIN-ALL
Lines: 4
Documents:
Image~: 0
The material accompanying this ~ummary is ~ubject to copyright. u~age i~ governed by contract with Thomson Reuter~.
West and their affiliates.
Westlaw
Page I
FEIN Record
Source Information
Information Current Through: 12/31/2011

Database Last Updated: 03/20/2012
Update t'requency: QUARTERLY
Current Date: 05/18/2012
Source: Copyright O 2012 by Dun & Brad~treet, Inc.
Business Information
Company '.',lame: PORT AGE PUBLIC SCHOOLS

Address: IOIOW MILHAM AVE
PORT AGE, Ml 49024
FEIN Number: 38-6001950
D&H Source: PORT AGE PUBLIC SCHOOLS
D&B Company Name: PORT AGE PUBLIC SCHOOLS
DUNS Number: 78-781-9783
SIC: 82110300 PUBLIC ELEMENTARY AND SECONDARY
SCHOOLS
Executive Information
Executive Name: CRAIG ROSS

Title: BRANCH MA:-.JAGER
END OF DOCL'MENT
0 2012 CENTER
OBTAINED BY STUDENT BORROWER PROTECTION Thom~onAND
Reuters. No Claim
AMERICAN to Orig. OF
FEDERATION USTEACHERS
Gov. Works.
UNDER THE FREEDOM OF INFORMATION ACT
Entity Report
Official Name of Entity Entity Code Entity Type
Curious Kids Child Care 00872 LEA Non-Instructional Ancillary Facility
Status Agreement Number Ownership
Open-Active 391400872 Owned
ISDName County (Code) Phone Number
Kalamazoo RESA (39000) Kalamazoo (39) (269) 323-6765
Phone Extension Fax Number Fax Extension
(269) 323-6790
E-mail Address FIPS code NCES School Code
tkarmon@portageps org 26077
REMCCode Entity Open Date Entity Close Date
12W 07/01/1988
Shared Educational Entity (SEE} Shared Educational Entity (SEE) Functions

Participation Subtype
None None Other Facility
Member Entities Web Site Address of Entity
curiouskidsportage. com
Report generated on 5/18/2012 Page 1 of 2
Contact Type Name Contact Information
Coordinator Name: Ms. Tammy Karmon

Phone: (269) 323-6765
Fax: (269) 323-6790
Address:
1010 W. Milham Ave.
Portage Ml 49024-9024
Adm1n1strator Name: Mr. Craig Ross
Phone: (269) 323-6755
Fax: (269) 323-6790
Address:
1010 W. Milham
Address Type Name Address Information
Mailing 1010 W. Milham

Physical 1010 W. Milham
Relationship Parent Entity Type Parent Entity
Belongs within LEA D1stnct Portage Public Schools (39140)
Report generated on 5/18/2012 Page 2 of 2
From: l(b)(5)
Sent: 25 May 201713:41:59 +0000

To: Fedloan PSLF
Cc: l(b)(5J I
Subject: Re: Dayton Bar Association
Hi Kim,
We agree that this organization likely does not qualify for PSLF.The ECFthat was
provided for the borrower listed that the organization was not a 501(c)(3 ); however,
since the employer specifically letter states that the organization is a 501(c)(3), Fed Loan
should reach out to the organization to request documentation of the organization's
501(c)(3) status.
Thanks,
Taneka
From: Kimberly A Myers on behalf of Fcdloan PSLF

Sent: Wednesda7, May 3, 2017 1:05 PM
To: l(b)(5J -
Subject: Dayton Bar Association
Hi Taneka! We had previously denied this organization as they are not-for-profit, 501(c)(6), but
they do not provide a qualifying public service.
The employer has written a letter and is disputing the denial indicating they are eligible. They
indicated in their letter that they qualify because they are a 501 (c)(3) organization. They further
state the applicable qualifying job functions of the borrower.
While their rationale of qualifying seems to be incorrect (they are 501 (c)(6) rather than 501 (c)(3)),
I still could not find evidence that they are a qualifying organization and the additional job
functions listed do not prove their eligibility. Since it was a dispute, I am escalating for your
review.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Code:PHEAA
From: l(b)(5)
Sent: 9 Nov 2015 14:08:54 +0000

To: Foss, Ian
Subject: RE: DC 37 Health and Security Plan update
Thanh for rc~ponding! :)
- Taneka
From: Fos~, Ian
Sent: Friday, November 06, 2015 4:42 PM
To: FedLoan PSLF
Cc: l(b)(5) I
Batlle, Cynthia; John~on, Debbe
Subject: Re: DC 37 lleallh and Security Plan update
They are a non-(c)(3) not-for-profit providing public interest legal services.
> On Nov 6, 2015, at 15: 15, Fed Loan PSLF <FedLoanPSLF(iijpheaa.org> wrote:
>
> Hi Taneka, Yes, we'll take care of this. What type of organization
> should we approve them under'? Their letter seems to infer they are government.
> Please let us know.
>
> Thanks and have a great weekend!
>
> Diane
>
>
>
> From: l(b)(5) I
(b)(5)
> To: FcdLoan PSLF <FcdLoanPSLf-(i!)Phcaa.org>
> Cc: "Johnson, Dcbbc" <Dcbbc.Johnson(j_i;cd.gov>, "Foss, Ian"
> <Ian.Foss(a;ed.gov>, "Baltic, Cvnthia" <Cynthia.Battlc(a;'ed.gov>,
> !(b)(5) ll(b)(5) I
> Date: I l/05/2015 05:15 PM
> Subject: [cxternal]DC 37 Ilcalth and Security Plan update
>
>
>
> Hi Diane,
>
> DC 37 Health and Security Plan sent in an updated Public Service Loan
> Forgiveness (PSLF) escalation directly to FSA. In the appeal DC 37
> provided additional information on \vhat the organization does and how
> the legal services provided are not just for union members (see
> attached). FSA fo1warded the appeal to the Office of General Counsel
> (OGC) for a final decision and based on the new information received,
> OGC determined that DC
> 37 Health and Security Plan should be considered as a qualifying
> employer for the purposes of PSLF.
>
> Can FcdLoan ~end the borrower a retraction letter for the prior denial?
> Also attached i~ the rc~pon~c that Ian pro\'idcd to Ms. Jarvis with an
> explanation that the approval docs not mean that f-SA completely agreed
> \vith the ?rationale or statutory/regulatory interpretation that was

> provided by the organization?s counsel.'?
>
> Below arc a few ?highlighb? from the letter if you arc intcrc~tcd:
> DC 37 provides ~ervicc~ nearly identify to those provided by legal aid
> offices, at no co~t to the individual rcprc~cntcd. By ca~c volume, DC
> 37?~ legal ~crvicc~department is primarily involved in reprc~cnting
> thi~ population in hou~ing cases (nearly 3,000 o\'er the pa~t year),
> helping to keep public servants in their home~. Bui DC 37 abo
> provides representation for bankruptcy or other debt issues, parental
> right~ cases, consumer protection cases, cases lo help individuals
> secure entitlements like food ~lamps and social ~ccurily, case~
> a~~1~lingwith citizenship or immigration issues, and case~ involving securing services for public utilitic~.
>[***]
> The population served by DC 37 is made up largely of economic and
> demographic groups kno\vn to face significant barriers in accessing
> adequate legal representation and health services. Economically, the
> public servants who receive public services from DC 37 are among the
> lowest paid of city workers, many of\vhom struggle just to make ends
> meet (some actually live in shelters and are on public assistance)
> while contending with remarkably high cost of living in the region.
> [***l
>Finally.DC 37 does not only provide services to union members. DC 37
> services are provided to all NYC public servants (and their families)
> \vorking in or retired from specific job titles. and union membership
> is not a criterion for eligibility for ~crvicc~.
>
> If you have any concern~ or quc~tions please let me know.
>
> Thanh,
>
> Taneka
>
> (Sec attached lilc: PSLF Il&S.pdl)
>
> ----- \1cssagc from "Fo~~-Ian" <lan.Foss(d)cd.gov> on Thu, 5 Nov 2015
> ] 7:20:2 J I 0000 -----
>
> To: Heather Jarvis
> <heatherwellsjarvis(i1;gmail.com>
>
> Subject: RE: PSLF employment certification
>
>
>
> Hi Heather,
>
> Good nev,·s. After considering the fact that the organization does not
> only provide legal as~istancc a~ a benefit of union membership, we arc
> ~atisficd that the organization qualific~.
>
> FcdLoan Servicing will be sending a letter to the borrower retracting
> the prior denial.
>
> Note that our determination that thi~ organization is a qualifying
> organiLation doc~ not mean that we necessarily agree with the
> rationale or statutory/regulatory interpretation that was provided by

> the organization?s counsel.
>
> Also, undcr~tand that, while I am happy to serve a~ a recipient of
> inquiries like thc~c if you think that FcdLoan Servicing i~ not being
> rc~ponsivc or is reaching incorrect conclusion~ about employers (I
> think it?s good to have an independent check), I am confident that, if
> the organization had provided either of ib letter~ to Fed Loan
> Servicing instead ofme, that FedLoan Servicing would have c~calated
> the employer again, and we would have reached the ~ame decision.
>
> Ian
>
> From: Ileather Jarvis [maillo:heatherwells1an.i~((1,gmail.cumJ
> Sent: Wednesday, November 04, 2015 5:58 PM
> To: Foss, Ian
> Subject: PSLF employment certification
>
> Ian,
>
> Thanks again for your careful attention to these important issues.
> Please find attached a letter including information relevant to the
> Department's analysis of H&S as a public interest organization.
>
> We \viii look forward to hearing back as your schedule permits. Don't
> hesitate to be in touch if quc~tions arise or any additional
> information i~ needed.
>
> All my hc~C
> Heather
>
>===================================================
> This message contain~ privileged and confidential information intended for the above addres~ees only. If
you receive this message in error please delete or destroy thi~ message and/or allachments.
>
> The sender of this message will fully cooperate in the civil and niminal prosecution of any individual
>
> Code:PHEAA
> <PSLF H&S.pdf>
From: l(b)(5)
Sent: 28 May 2015 07:03:54 -0500

To: Fedloan PSLF
Cc: Battle, Cynthia;Johnson, l~(b~l(~51
_____ ~
Subject: RE: DC 37 Health and Security Plan
Hi Diane,
OGC came back with a rcspon~c. The DC 37 Health and Security Plan i~ denied for the purpose~ of PSLf-.
Ba~ically the organization i~ not providing public ~crvicc~ but i~ providing bcncfib to union members a~
part of the benefits of union mcmbcr~hip. On the medical ~idc, il is nol providing medical ~crvicc~ but is
acting a~ an insurer. On the legal services ~idc, il is nol practicing public interest law but is providing basic
legal services to union members or relatives.
Thanh,
Taneka
-----Ori inal Messa e-----

From: (b)(5)
~~--~
Sent: Monday, April 27, 2015 8:04 AM
To: FedLoan PSLF
Cc: l(b)(5) IBattle, Cynthia; Johnson, Deb be
Subject: RE: DC 37 Health and Security Plan
Hi Diane,
I just wanted to let you know that Ian and L escalated the DC 37 Health and Security Plan to OGC. The DC
37 Health and Security Plan Trust doc~ not qualify for the ba~i~ of providing public health services ~incc it
contract~ these service~ to for-profit profcs~ional corporations.
There is an oubtanding quc~tion, however, if the employer provides, "public intcrc~t legal ~crvicc~"-
Attomcy~ of the plan work with member~ to prepare contracts, real estate tran~action documents, and c~tatc
planning document~. It would seem that, because they arc fonded in part by New York City, that they may
provide public interest legal ~crvicc~.
We arc specifically checking with OGC for an opinion lo dclcnninc if lhc~c services arc in fact provided lo
"the public" (member-based organizations arc not necessarily disqualified) and if they arc "free" since the
cost is included into the in~urancc premium~ that member~ of the plan pay.
I'll update you when a decision is made.
Thanks,
Taneka
From: Diane Freundel [mailto:dfreundefa'.pheaa.orgl On BehalfOfFedLoan PSLF
Sent: Mondav, \tlarch 23, 2015 2:13 PM
To:l(b)(5) I
Subject: DC 37 Health and Security Plan
Hi Taneka, We may have incorrectly denied thi~ employer. It is a 501

(c)(9) entity that seem~ to be a part of the DC 37 - New York City's
largest Public Employee Union. I denied due to being a labor union. The
borrower has disputed the denial via a letter from the DC 37 Municipal Employees Legal Services.
Can you please review? If they potentially qualify a~ a health plan, we

need to determine if they employ any acccptahlc positions under the Standard Occupational Classification~
Sy~tcm and whether those employee~ provide any qualifying service~. Ba~cd on our review. we can't find
any joh po~tings. Not sure if you could find anything.
(Sec attached file: DC37 Health and Security Plan.Lip)
Diane Frcundcl
Compliance Service~
(717) 720-3267
From: l(b)(5)
Sent: 16 Apr 2014 14:08:08 +DODO

To: 'Fedloan PSLF'
Cc: !(b)(5) I
Subject: RE: DEAR Foundation Inc
Hi Diane,
I think thi~ organization filed for 501(c)(3) ~talus but has not yet been approved with the IRS. That being
~aid, I think it qualific~ a~ a not-for-profit providing public intcrc~t legal services. Bccau~c information
about funding resources is rarely available unlc~~ the organization ha~ received a federal income tax
exemption, I think we can rely on the ~elf-certification of the organiLation in this case. Obviously, we'll
want to keep our eyes peeled for anything suspicious, and we might want to belier incorporate these
definitions in this section of the form, but I think thi~ one qualifies.
Ian
From: Diane Freundel Lmailto:dfreunde:11-pheaa.or1tlOn BehalfOfFedLoan PSLF
Sent: Wednesda 1 , April 09, 2014 9:27 AM
To: (b)(5)
Subject: DEAR Foundation Inc
Hi Ian, We are still having trouble grasping the concept of public interest law services. After our last
conversation a few months ago. we thought \Ve understood. HO\vever. we reviewed the regulations again
and saw the following:
Public interest law refers to legal ~crvicc~ provided by a public ~crvicc organization that arc funded in
whole or in part by a local, State, f-cdcral, or Tribal government.
We can't typically tell how an entity i~ funded. We don't want to deny all of these for additional proof Arc
there any other pointer~ you can give us.
Ilerc is one we're un~ure of.
Employer checked 50 I (c )(3 ). We could find no evidence of 50 I (c )(3) statu~.
Bu~iness filing indicate~ they arc non-profit.
One of their goals (page 3 of "About" pdt) is to Provide legal services at low cost and pro-bona according
to the immigrants' needs. The main goal of service is to fill the gap between immigrant rights and the
ability of the immigrant community to exercise these rights effectively.
We can't find anything on their ,,,,,ebsitethat references funding - www.dearfoundation.or1t
password to follow. Thanks!
(See attached file: DEAR Foundation Inc.zip)
Diane Frcundcl
Compliance Service~
(717) 720-3267
fax-(717) 720-3911
dfrcundc(cfphcaa.org
From: l(b)(5)
Sent: 24 Jun 2013 15:52:17 -0500
To: Fedloan PSLF
Cc: l(b)(5J I
lan;Ninemire, Sandra;Johnson, Debbe
Subject: Re: Deer Park Ambulance, Inc
Hi Diane,
Thi~ one qualific~ under 'emergency management'. f-inally, there i~ one!

1 m puzzled why the organization i~ a (c)(4), though.
1
Ian
On 5/20/l 3, 11:55, "FedLoan PSLF" <FedLoanPSLF(d!pheaa.org> wrote:
>
>Hi Ian, We never defined ,,,,..hat"emergency management" is; however, I assume
>it would cover an ambulance service. They indicated they are a private
>non-profit that provides emergency management. We verified they are a
>501
>(c)(4). Please confirm our assumption that an ambulance service
>provides emergency management services.
>
>Password to follow. Thanks!
>(See attached file: Deer Park Ambulance Inc.zip)

>
>Diane Freundel
>Compliance Service~
>(717) 720-3267
>fax- (717) 720-3911
>for the above addres~ees only. If you
>receive this message in error please delete or destroy this mc~~agc
>and,..orattachments.
>
From: l(b)(5)
Sent: 31 Dec 2012 08:57:26 -0600
To: Fedloan PSLF
Cc: cl(b~)(~5~)----~I lan;Ninemire, Sandra;Sipple-Asher, Bessie;Johnson,
Debbe
Subject: Re: Defense Contract Audit Agency
Diane,
If the borrower i~ employed hy the Federal government, then he or she may

work anywhere in the world. That there i~ an agreement between the US and
other countric~ to share ~ome of the responsibility for auditing defen~e
contracts doesn't change things(the bmrnwer still worb for the Federal
government.
Ian
On 12/ 13/12 16: 12, "Fed Loan PSLF" <[email protected]> wrote:
>
>Hi Ian, Here is another one - sorry for the volume today - I'm 11ying to
>get caught up. This is a government entity. The only reason I'm
>questioning it is because the borrO\ver is located in Israel. The
>Agency's
>office locator for offices outside the continental US does list an office
>in Israel. I'm questioning it because it says that the DCAA has full or
>pa1tial contract audit responsibilities based on contracts/agreements \vith
>the foreign countries' governments. I think that the borrower qualifies,
>hut wanted your opinion. Pa~sword to follow. Thanb!
>
>
>(Sec attached file: Dcfcn~c Contract Audit Agcncy.?ip)
>
>Diane Frcundcl
>(717) 720-3267
>fax- (717) 720-3911
>dfreunde(d)pheaa.org
>This me~sage contains privileged and confidential information intended
>
From: l(b)(5)
Sent: 3 Jun 2013 10:05:36 -0400
To: Fedloan PSLF
Cc: l(b)(5J I
lan;Ninemire, Sandra;Johnson, Debbe
Subject: Re: Delta Dental of Iowa
Diane,
I agree that this organin1tion doc~ not appear to provide any qualifying
~erv1ce~.
Ian
On 5/1Oil 3 15:54, "FcdLoan PSLF" <FcdLoanPSLF(d!phcaa.org> wrote:
>
>Hi Ian, We're not sure about this one. Delta Dental of I01,vais a 501
>(c)(4), so we're trying to determine if they provide a qualifying service.
>The employer didn't check any box, so we were just going to deny, but I
>thought I'd see what you think. Delta Dental of Iowa currently only has
>3 job postings, none ofwhich would put them in the "public health"
>category. I checked the main Delta Dental ,,,,..ebsite(Delta Dental Plans
>Association) and they have a resident dentist on staff that biogs about
>oral health issues.
>Password to follow. thanks
>(See attached file: Delta Dental of[01,va.zip)
>Diane Frcundcl
>(717) 720-3267
>fax- (717) 720-3911
>dfrcunde(d)phcaa.org
>for the above addrcs~ees only. If you
>
From: l(b)(5)
Sent: 17 Oct 2012 11:47:32 -0500

To: Fedloan PSLF
Cc: Foss, c(b~l(~5~1
________ JSandra;Sipple-Asher, Bessie;Johnson,
Debbe
Subject: Re: Delta Sigma Theta Sorority
Hi Diane,
Though 501 (c )(7) organization~ arc non-profib hy definition, they must

provide a qualifying ~crvicc. Notwith~tanding what the ~orority doc~, I
cannot sec on their website that they actually provide any sort of service
lo the public. Again, that's nol lo say that they don't "bring about
good", hut we're looking for ~omc ~011of active ~crvicc.
Ian
On 1Oi10/12 16: 18, "Fed Loan PSLF" <[email protected]> wrote:
> (b)(5)
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>~------------------------------~
>Your thoughts'.' Password to follov.,, Thanks!
>
>(See attached file: Delta Sigma Theta Sorority, Inc.zip)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>d freunde(,}ipheaa.org
>for the above addressees only, If you
>

From: l(b)(5)
Sent: 31 Dec 2012 09:25:36 -0600
To: Fedloan PSLF
Cc: Ll(b~l(~51
____ ~1lan;Johnson, Debbe;Ninemire, Sandra;Sipple-Asher,
Bessie
Subject: Re: Detroit 90/90
b)(5)
Regardless, I thmk 1,vecan approve them as a non-50l(c)(3) not-for-pro1ft

organization that provides "school-based services"; I don't think it fits
neatly into "public education", either, as it is a centralized management
organization.
Ian
On 12/24/12 19: 14, "FedLoan PSLF" <[email protected]> wrote:

(b)(5)
>Password to follow. I got an error mcs~agc during encryption, but I was

>able to open the documents. Let me know if you have any problems.Thanks!
>
>(Sec allachcd file: Detroit 90 90.zip)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>
>in the unauthorized me ofthi~ mcs~agc.
From: l(b)(5)
Sent: 14 Apr 2016 15:29:35 +0000
To: Fedloan PSLF
Cc: l(b)(5J I
Cynthia
Subject: RE: Detroit Economic Growth Corporation
Hi Kim,
After deliberating, OCG determined that Detroit Economic Growth Corporation does not qualify for the
purposes of PSLF.
Thanks,
Taneka

Sent: Friday, February 12, 2016 3:58 PM
To: !(bl(51 I
Subject: Detroit Economic Growth Corporation
Hi Taneka!
This should be the last one for now!
The borrower is disputing a previous denial. The ECF was certified as private not-for-profit. They attached
a supplemental document attempting to outline the services they provide (they did not select a service on
the form). The supplemental document doesn't give great detail, but mainly focuses on the fact that they
are 501(c)(4). We denied the employer in December 2015. Their mission is to promote economic growth
in the City of Detroit, which does not fall under any of the eligible public service categories.
The borrower sent in a letter in January requesting re-evaluation of the employer's eligibility. They
indicate that this organization is under the auspice of the city of Detroit. Although the DEGC isn't
specifically found in the financial statements for the city, the statements mention Economic Development
Corporation (EDC). This is indicated to be a legally separate entity. In addition, the website for DEGC
states that they are a "private, non-profit organization" and they are "not part of the city of Detroit's
government."
We still do not believe that this organization qualifies.
Same password as other employer. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
This message contains privileged and confidential infomiation intended for the above addressees
attachments.
Code:PHEAA
From: l(b)(5)
Sent: 14 Nov 2013 09:08:40 -0600
To: Fedloan PSLF
Subject: Re: Detroit Education and Research
Hi Diane,
Sorry for the delay on these.
If you found an EIN match in the BMF showing that the organization is a 501(c)(4), then we know it's
not-for-profit notwithstanding that DMC was bought by a for-profit corporation. Remember, for-
profit corporations can incorporate not-for-profit arms of which they are the only
shareholder /member. After that, it just becomes a matter of ensuring that the individual is actua Ily
employed by the not-for-profit instead of the for-profit. Given the EIN match to the not-for-profit,
I'm satisfied.
Also, I think it's fairly obvious that this is public health. The articles indicate that the organization
provides health care to underserved communities. It also appear to, accord to this, operate a medical
residency program. You didn't ask, but I thought I'd add my confirmation anyway.
Ian
On 10/18/13, 21:31, "Fed Loan PSLF"<[email protected]> wrote:
Hi Ian, last one for today!
ECFcertified as private non-profit providing public health.
Active business filing within an incorporation/qualification date of

3/30/12 shows non-profit - articles of incorporation included
Address is the same as Detroit Receiving Hospital/ University Health

Center
Certifying official is the Executive Director of Academic Affairs at

Detroit Medical Center Osteopathic Division - bottom of website says The
Detroit Medical Center (DMC) - Osteopathic Division is a multi-specialty
hospital system affiliated with Michigan State University College of
Osteopathic Medicine.
We previously determined that the Detroit Medical Center was bought by

Vanguard Health Systems on 12/30/10. Vanguard is for profit.
I think we talked one time that a for profit entity could have a non-profit
"within" it.
Do you think the employer qualifies? I tend to say yes because it was
incorporated after the DMC was purchased by Vanguard. Password to

follow. Thanks
{See attached file: Detroit Education & Research.zip)
Diane Freundel
Compliance Services
{717) 720-3267
fax- (717) 720-3911
dfreu [email protected]
This message contains privileged and confidential information intended for the above addressees
only. If you
receive this message in error please delete or destroy this message and/or attachments.
individual engaging
in the unauthorized use of this message.
From: l(b)(5)
Sent: 4 Apr 2012 07:59:54 -0500
Subject: RE: Disability Attorneys of Michigan
The name of this employer is really 3 Stu Johnson & Associates, P.C.2 lt 1s very
common for (especially) law firms to have a name like 3 Disability Attorneys of
Michigan 2 to market themselves but really be named something rather
mundane like 3 Stu Johnson & Associates, P.C.2 You can find it in the Michigan
Corporations Database under its real name or ID 462422.
The P.C. indicates that this is a professional services corporation, which is a
type of business entity that is intended to offer a corporation configuration for
those who are "professionals" in the traditional sense of the term<those that
require licensure to practice their occupation, while preserving certain
required features of individual liability that are required by the profession.
They are usually operated for-profit, like any law firm.
I found the firm 1s articles of incorporation in the Michigan database and found
that it issued 60,000 shares of common stock that are wholly owned by the
president (managing partner) of the firm, Stuart Johnson.
Though the employer could arguably provide a public service, as would be
necessary since it is neither governmental nor a 501(c)(3) organization,
because it operates for-profit, it does not qualify.
Know that, if the borrower comes back to argue with you, and states that at
least part of his work is pro bono or funded either in full or in part with
government funds via the attorney1s Interest on Lawyer Trust Account (IOLTA),
that 1s not sufficient. We spoke to that in the preamble to the final PSLF
regulation. See 73 FR 63232, 63242, third column, paragraph starting 3Several
commenters 2 (available here: http://www.gpo.gov/fdsys/pkg/FR-2008-10-
23/pdf /E8·24922. pdf).
And, I just saw your email retracting the request for assistance. But, having
already typed this up, 1111send it along anyway.
> From: Diane Freundel [mailto:[email protected]] On Behalf Of Fedloan
> PSLF
> Sent: Tuesday, April 03, 2012 10:42 PM
> To: l(b)(5J I
> Subject: Disability Attorneys of Michigan
>
>
> Hi, We're having trouble with this one. I think it's probably for profit, but I
> can't find any indication of for profit or non-profit status. I checked Pub 78,
> BMF, and state business filings - can't find anything other
> than their website. Appreciate your thoughts - thanks! Password to
> follow.
>
> (See attached file: Disability Attorneys of Michigan.zip)
>
> Diane Freundel
> (717) 720-3267
> fax- (717) 720-3911
> [email protected]
>
> message.
From: l(b)(5)
Sent: 31 Dec 2012 09:57:12 -0600
To: Fedloan PSLF
Cc: ----~I
cl(b~)(~5~) lan;Ninemire, Sandra;Sipple-Asher, Bessie;Johnson,
Debbe
Subject: Re: Discovery Point Pre-Kand Kids R Kids escalation
Diane,
I agree with your a~scssmcnt. Both employers to be for-profit

corporation~ (they both offer franchi~ing, as well, which make~ thing~
pretty clear). They do not qualify.
Ian
On 12/27/12 20:33, "FedLoan PSLF" <FedLoanPSLF(a/pheaa.org> wrote:
>
>Hi Ian. This is another escalated case - one borrower i two employers.
>Both employers are for profit based on their business filings. In her
>escalation letter she advises that she should qualify because her job
>(pre-K instruction) is funded by the state of Georgia, not a for profit
>entity. She goes on to say that due to space issues in public facilities.
>private facilities (that may be for profit) have partnered with the state
>to offer classrooms for public pre-k education. The private facilities
>also have separate. for profit, day care programs and the EIN is
>associated
>with them. If these entities are her employers, then I don't think she
>qualific~, hut since she c~calatcd our denial. we'd like your opinion.
>
>Password to follow. Thanks.
>
>( Sec attached file: [sea lated info_ Discovery Point.zip)
>
>
>Diane Freundcl
>(717) 720-3267
>fax- (717) 720-3911
>
From: Foss, Ian on behalf of cl(b~)(~5)~-~

Sent: 27 Jan 2014 16:58:23 -0500
To: Fedloan PSLF
Cc: l(b)(5J I
Subject: Re: District 1199J Benefit and Pension Fund
Hi Diane,
Thi~ organization i~ not a 50l(c)(3); it i~ tax-exempt under Section

50l(a) of the IRC, I think based on Section 402(a). I found it by pulling
fom1 990s for related organizations.
This mean~ that the organization must provide a qualifying service. Since
it's a pension, I'd be templed to argue that it provide~ public service lo
the elderly; however, this pension is something that the employees earned
a~ part of their employment. So, I don't sec how it could be construed as
a public service.
Note also that District 11991, itself_ is a labor union. I'm not sure
1Nhetherthat would automatically disqualify the pension fund, since it's
separately organization, but it's another reason to be extra cautious 1Nith
this one.
Ian
On 1/5,..14. 19:29, "FedLoan PSLF" <[email protected]> wrote:
>
>Hi Ian, We found this one to be very confusing.
b)(5)
>think they provide qualit)'ing public service. Do you agree? Pass\vord

>to follow. Thanks!
>
>(Sec attached file: Di~trict l 199J Benefit and Pcn~ion Fund.zip)
>
>Diane Frcundcl
>(717) 720-3267
>fax- (717) 720-3911
>dfrcunde(d)pheaa .org
>receive this message in error please delete or destroy this me~~age
>
From: l(b)(5)
Sent: 16 Apr 2014 09:16:46 -0500

To: Fedloan PSLF
Subject: RE: District of Columbia Bar
Attachments: RE: State Bar of Wisconsin
Hi Diane,
I think thi~ i~ the ~amc ~ituation a~ the State Bar ofWi~consin (attached) and thus qualifies. Let me know if
you disagree.
Ian
From: Diane Freundcl [rnaiHo:dfn::unde:11.pheaa.orn]On BehalfOfFedLoan PSLF
Sent: Tue~day, April 15, 2014 9: 18 AM
To: l(b)(5) I
Subject: District of Columbia Bar
(b)(5)
Employer certified as private non-profit providing pub Iic interest law services.
(Sec attached file: District of Columbia Bar.?ip)
Diane Frcundcl
Compliance Service~
(717) 720-3267
fax-(717) 720-3911
From: l(b)(5)
Sent: 13 Mar 2012 08:42:35 -0500
Subject: RE: State Bar of Wisconsin
I think this one is quasi-governmental, as will be many, if not most State Bars.
The relationship between the State Bar and the government, is, in a way, set
up in most state Constitutions. In Wisconsin, see Article VII, Secs. 3{1) and 4(3)
(page 55, here: http://legis.wisconsin.gov/statutes/wisconst.pdf), which
establishes the highest court as the head of the judiciary, and authorizing it to
promulgate rules on the administrations of the courts. Then see those rules;
specifically, 10.01, which creates the State Bar of Wisconsin, membership in
which is a condition on practicing law in the State of Wisconsin.
The relationship between attorneys and the judiciary is such because

attorneys are considered officers of the court and the judicial system
therefore has an "inherent right" to exercise control over attorneys/legal
profession in the state in which it had jurisdiction. That's also made clear in
the rules
The rules are available here:

http://wicourts.gov/sc/scrule/DisplayDocument.pdf?content=pdf&seqNo=763
40.
Note: there may be a difference between a State Bar and the Bar Association
in the State. The former is what we discussed in this email, the latter is a
voluntary association of attorneys that typically is organized as a 501(c)(3) or
(4) and provides attorney-related services related to the practice of law.
1
1 11provide the example of Maryland, since that 1s what 11m familiar with. The
Maryland Board of Law Examiners (here:
http://www.courts.state.md.us/ble/index.html) is the Maryland equivalent of
the Wisconsin State Bar, that you escalated. The Maryland State Bar
Association (here: http:j/www.msba.org/) is the example of the non-profit
organization, which may ultimately qualify, but should not be confused with
the state.

> Fedloan PSLF
> Sent: Monday, March 12, 2012 10:09 PM
> To: l(b)(5) I
> Subject: State Bar of Wisconsin
>
>
> Hi, I don't think we ever discussed a State Bar. I'm fairly certain it qualifies,
> but I can't confirm. They checked box c and public education.
> I can't find anything to confirm their non-profit status. I checked the BMF
> and the state corporation website with no results. I also thought they could
> be quasi-government, but their overview shows they were originally
> organized as a voluntary association (in 1878) and I can't find any direct
> relationship with the state government. Password to follow. Thanks.
>
> (See attached file: State Bar of Wisconsin.zip)
>
> Diane Freundel
> (717) 720-3267
> fax- {717) 720-3911
> [email protected]
>==========================================================
>====================
>
> message.
>==========================================================
>====================
From: l(b)(5)
Sent: 16 Apr 2014 09:55:54 -0500
To: Fedloan PSLF
Cc: l(b)(5J I
Subject: RE: Downtown Durham Inc
Attachments: RE: Riverfront Business District
Hi Diane,
I ~cc no difference between thi~ organization and another "bmincss di~trict", which didn't qualify. Sec
attached.
Ian
From: Diane Freundcl [rnaiHo:dfreunde:11.pheaa.orn] On BehalfOfFedLoan PSLF
Sent: Thursdav, March 06, 2014 10:32 PM
To:l(b)(5) I
Subject: Downtown Durham Inc
Hi Ian, Can you please take a look at this one. Employer certified private non-profit providing public
safety (one of those services \Ve can't really define) - they're a 50 I(c )(6 ). They included a copy of their
contract with the city of Durham, NC. See section 5.2 "Security" on page
5120of the ECF pdf. Although they aren't authorized to perform security or law enforcement activities.
they may be required to report to the Durham police any incidents involving what appear to be suspicious.
unsafe, or criminal activities. \Ve don't think this would be considered as providing public safety, but we
\vanted to get your thoughts.
(Sec attached file: Downtown Durham Inc.zip)
Diane Frcundcl
Compliance Service~
(717) 720-3267
fax-(717) 720-3911
d freunde(a;pheaa .org
From: l(b)(5)
Sent: 12 Sep 2012 11:19:49 -0500
Cc: Ninemire, Sandra;Sipple-Asher, Bessie;Johnson, Debbe;Foss, Ian
Subject: RE: Riverfront Business District
Attachments: RE: Public Service Loan Forgiveness
Diane,
I don't think this qualifies.
It's not yet a 501(c)(3), and though a non-profit, it does not appear to provide any qualifying service.
The organization is not unlike the one discussed in the attached email. To the organization's point that
it provides public safety services--it does not do so directly. It does not actually renovate the buildings;
it provides funding to others to renovate the buildings. Even if it did directly renovate buildings, the
argument that this equates to public safety is tenuous as best. As to public education, being a
"resource" or providing "seminars" is not "public education"-we're looking for something more formal,
in a pedagogical setting.
Though this organization may ultimately become a 501(c)(3), I would note that business districts are
usually more like chambers of commerce, which are 501(c)(4) or 501(c)(6)s.
What's more, though I would note that the Main Street Fort Madison site says that their predecessor
was the Riverfront Business District, the business filings support the opposite conclusion (Main Street
organized in 1988, was administrative dissolved in 1998, and never reformed; Riverfront organized in
2006). In addition, I don't know what being under the "auspices" means, but I don't think that's
availing. This is not one organization that is wholly owned by another. Riverfront is separately
organized, and the officers of one are not the officers of the other organization. And, in the articles of
organization for each, there is no mention of other organization. So, this couldn't even be a
"disregarded entity" situation.
I can find Main Street Fort Madison, Inc. in Westlaw under EIN 42-1310798, which is different than the
"Fort Madison Main Street" on their website, I cannot find it in the IRSdatabase of tax-exempt entities,
either Pub 78 or the BMF.
Ian
To, !(b)(51 I
Subject: Riverfront Business District
Hi Ian, Another difficult one. She is one of the "QP" borrowers. ECF
indicates the organization is a 501(c)(3). We could find no indication of that status, but verified they are
a not-for-profit - their business filing still shows them as active. A google search associates them with
Fort Madison Main Street -website indicates it was founded in 2009, following its predecessor the
Riverfront Business District -website also indicates they are not-for-profit.
We asked the Business Unit to contact the employer for additional information. Employer indicated
they are working on their application for 501(c)(3). They are related to Main Street Fort Madison and are
a private non-profit. Borrower spends a lot of time working on securing grants and funding.
Representative went over the list of qualifying public services to determine if the Riverfront Business
District provides any of them.
Employer stated they work to get decaying 170 year old downtown buildings renovated and as such
would touch on public safety. Employer also said they touch on public education because they are a "go
to" organization and also do some seminars for building owners regarding available tools to get help
renovating and complying with building codes. Employer indicated they are under the "auspices" of
Main Street which he believes is a 501(c)(3).
I could not confirm Main Street's status.
b)(5)
We appreciate your guidance. Password to follow. Thanks
(See attached file: Riverfront Business District.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
[email protected]
engaging in the unauthorized use ofthis message.
From: Foss, Ian

Sent: 17 Feb 201219:57:52 +0000
To: rla [email protected]
Subject: RE: Public Service Loan Forgiveness
Dear Ms. Larson,
For employment to qualify for the Public Service Loan Forgiveness Program, you must be a full-time
employee of (1) a governmental organization, (2) a not-for-profit organization that is tax-exempt under
section 501{c)(3) of the Internal Revenue Code, or (3) a not-for-profit organization that provides a
qualifying public service.
From what I can discern, you work at the National Equity Fund, Inc. (EIN: 36-3490231), which, as you
stated {and I confirmed), is a 501{c)(4) organization. Although it is wholly owned by a 501{c)(3)
organization, that relationship, in and of itself, is insufficient for your employment to qualify as working
for a 501(c)(3) organization.
If you work for a 501(c)(4) organization, your employment will qualify if you work for (1) a not-for-profit
organization, (2) the organization provides a qualifying public service (see list below), (3) the
organization is not a labor union, and (4) the organization is not a partisan political organization. As a
general matter, 501(c)(4) organizations are not-for-profit and non-partisan (though they can lobby for or
against legislation). This would mean that your employer at least meets criteria (1) and (4), above.
Qualifying public services include:
• Emergency management,
• Military service,
• Public safety,
• Law enforcement,
• Public interest law services,
• Early childhood education (including licensed or regulated child care, Head Start, and State-
funded pre-kindergarten),
• Public service for individuals with disabilities and the elderly,
• Public health (including nurses, nurse practitioners, nurses in a clinical setting, and full-time
professionals engaged in health care practitioner occupations and health support
occupations, as such terms are defined by the Bureau of Labor Statistics),
• Public education,
• Public library services,
• School library services, or
• Other school-based services.
Assuming the National Equity Fund, Inc. (NEF) is your employer, I cannot determine what qualifying
service the organization might provide. Though I cannot be sure at this point, it might provide public
interest law services. However, from NEF's website, it appears as though NEF plays the role of the
syndicator in the Low-Income Housing Tax Credit (LIHTC) Program. My understanding of the role of the
syndicator (in the context of the LIHTC market) is that it is one who passes investor equity to a real
estate developer and returns tax credits to back to those investors. I'm honestly not sure whether this
includes the provision of public interest legal services. Certainly, the services NEF provides are
ultimately in the public interest, but I don't know whether they are legal in nature and exactly what legal
services NEF might provide and to whom.
I realize that this still leaves your broader question unanswered (in a definitive sense). Please feel free
to give me a call and explain more what NEFdoes, or, if you think your employment qualifies based on
this email, please complete and submit the Employment Certificationfor PublicService Loan Forgiveness
form, available here.
Regards,
fan Foss
US Department of Education
Federal Student Aid
Policy Liaison & Implementation
202-377-3681
From: Rene Larson [mailto:[email protected]]

To: IC DocketMgr
Subject: Public Service Loan Forgiveness
I work for a 501(c)(4) organization that is wholly owned by a 501{c)(3) organization.

Does this still qualify me for the loan forgiveness program? Thank you.
Sincerely,
Rene Larson
Compliance Attorney
(312) 697-6148
120 S Riverside Plaza Fl 15
Chicago, IL
60606
From: l(b)(5)
Sent: 31 Jan 2012 06:27:51 -0600

To: 'Fedloan PSLF'
Cc: l(bl(5l I
Sandra;Sipple-Asher, Bessie;Foss, Ian
Subject: RE: Eastern Suffolk BOCES
Diane,
[a~tcm Suffolk BOC[S i~ an Educational Service Agency, all of which

qualify as employer~ for PSLF in the governmental category, like they do for
receiving Teacher Loan Forgiveness and carrying out one\ agreement to ~crvc
aller receiving a TEACII Grant.
Educational Service Agencies arc tricky to

identify u~ually, and especially when they don't come out and say so on
their websites.
See here for more on ESAs in New York State. There are 37
BOCES, and all qualify.
http://www.p 12.nvsed.!!.O\,..mgtserviboces/
Regards,
Ian
-----Original
Message-----
From: Diane Freundel [mailto:dfreundefa'.aessuccess.orgl On Behalf
Of FedLoan PSLF
Sent: Monday, January 30, 2012 3:59 P\1
To:
l(b)(5)
Subject: Ea~tcrn Suffolk BO(TS
W c believe the following

organiLation is a qualifying private not for profit employer that provide~
school-based services. We did not find them on the IRS !isl a~ a 501(3)(c).
We arc concerned that it was abo not on the NY Department of State's li~t
of corporationsibu~iness entities.
I know we've requested a face to face

meeting to walk through some ECFs and basic research tools. However, ifwe
receive phone inquiries in the meantime, we'd like to be able to get back to
the borrower. We received this one via a phone call.
Organization Name:
Eastern Suffolk BOCES (Board of Cooperative Educational Services)
ElN:
11-6000 I 29
Building Location: 351 Martha Ave, Bellport, NY 11713 Human
Resources Office Location: 201 Sunrise Highway, Pathogue, NY
11772
Organization's website - Eastern Suffolk BO(TS i~ one of 37 BOC[S in

the state of New York:
http: '/www.c~boccs.org/about us.a~px
NY Dept of
State site we
used:
http:i/www.dos.nv.gov/crnv~ibu~ cntitv ~carch.html#
Thank you!
Diane
Frcundel
Compliance Service~
(717) 720-3267
fax-(717)
720-3911
This message contains privileged and

confidential information intended for the above addressees only. If you
attachments.

of this
message.
--------------------------------
From: l(b)(5)
Sent: 9 Feb 2012 13:29:33 -0600

To: Fedloan l(bl( 5l I
Subject: RE: Emerson College
I agree that it qualific~, though hccau~c it'~ a 50\(c)(J). I found it in

Puh 78. And, though then Puh 78 entry ~ay~ "Emmcr~on College Dept of
Finance", I confirmed that it's the same employer hy looking at the
college's by-law~ (~cc Section 1.2, here:
h tlp ://www.crn.:rson.cd u/ s itcsi de fau 1t/ fi1cs/ .:mcrsun-cu 1lcgc-by laws. pd I)
>
> From: Diane Frcundcl
[mailto:dfrcundc(dacssL1cc.:ss.urgl On Behalf Of
> FedLoan PSLF
> Sent:
Wednesda 1 , Februaty 08, 2012 3:49 PM
> To: (b)(5)
,-~~-~
> Subject: Emerson
College
>
>
> We believe this is a qualifying private non-profit school.
They checked box c
> and public education.
>
> EIN - 00-04-1286950.
>
>
Accreditation
>
>
> Emerson is a private, independent, nonprofit college
fully accredited by the
> New England /\s~ociation of Schools & Colleges a~
authoriLcd by the
> Commission on Institutions of Ilighcr Education. Emerson
is also accredited
> by the Council on Academic Accreditation of the
American Speech-Language-
> Hearing Association (for its master's degree in
communication disorders), and
> the Massachusetts Department of Education
(education preparation
> programs in the Departments of Communication
Sciences and Disorders and
> Performing Arts).
>
>
> [mcr~on was
rcaccrcditcd hy N[ASC in 2002 and will undergo review for
> rcaccrcditation
in 2012. The rcaccrcditation procc~s involve~ review,
> reflection,
assessment, and planning by administrators, faculty, students,
> and members
of the profc~~ional community. The N[ASC Self-Study Report
> provides a
review of Emcrson 1s programs from 1993 to 2002. In August 2007,
> the
College ~ubmittcd a Fifth-Year Interim Report to NEAS(', updating
>
information from the 2002 report and addre~~ing ~everal i~~uesthe
>
reviewers had rai~ed.
>
>
> Thanks.
>
>
>
> Diane Freundel
> Compliance
Services
> (717) 720-3267
> fax- (717) 720-3911
> [email protected]
>
--------------------------------
>
> This message contain~ privileged and confidential

allaehment~.
>
civil and criminal
> message.
>
>

Sent: 27 Jan 2017 22:36:06 +0000
To: Foss, lan;Battle, Cynthia
Cc: !(b)(5) I
Subject: RE: Employer Escalation Core Requirements
(b)(5)
We will see what they say on Monday.
From: Foss, Ian

Sent: Friday, January 27, 2017 5:07 PM
To: Chialastri, Taneka; Battle, Cynthia
Cc: l(bJ(5J I
• □ .
(b)(5)

To: Foss, Ian; Battle, Cynthia
Cc: l(bl(5l I
Chialastri, Taneka
Subject: Employer Escalation Core Requirements
Hi Cindy and Ian,
Below are the core requirements that discuss what employers to escalate to FSA.Attached is Fedloan's
ECFprocessing guide. I highlighted the areas were Fedloan's Business Unit should escalate though most
of the areas do not make a clear distinction between Compliance or FSA(pgs. 32, 41, 45). I'm still looking
for the ECFprotocol that Bessie drafted. I'm having issues getting into the network drive so will try again
on Monday morning. Thanks, Taneka
The PSLF servicer shall determine whether an

PSLF Single Servicer employer is a qualifying public service
202.00
Requirements organization, based on the submitted
Emolovment Certification form.
The PSLF servicer shall follow procedure for
validating qualifying public service, according to a
validation process approved by FSA , which will
PSLF Single Servicer include looking up employers in a searchable
202.01
Requirements databases, based on the type of public service
organization, See Appendix B (Draft) Instruction
for Validating a Qualifying Public Service
Oraanization
The PSLF servicer shall escalate to FSA cases for
PSLF Single Servicer which a public service organization cannot be
202.02
Requirements determined to be qualifying or non-qualifying,
based n the orovided validation orocess.
From: l(b)(5)
Sent: 13 Apr 2017 19:50:30 +DODO
To: FedLoan PSLF
Cc: Odom, Christian;Battle, Cynthia;Foss, Ian
Subject: Re: Employer Escalations -APTA and Fair Elections Legal
Attachments: Retraction_Fair Elections Legal Network_20170413_Foss.docx
Hi Kim,
Ian had the opportunity to review the letter. See attached.
Thanks,
Taneka

<FcdLoanPSLF('!]phcaa.org>
Sent: Wednesda,. April 12, 2017 I :20:34 PM
To: l(b)(5J -
Cc: Odom, Christian; l3attlc, Cynthia; FcdLoan PSLF; foss, Ian
Subject: Re: Employer Escalations - APT A and Fair Elections Legal
Hi Taneka! Attached is the letter that was drafted for the Fair Elections Legal Network. Please
let me know if you are ok with the letter or if changes are needed.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
hrnn i(b)(5) li(b)(5) I

Io FedLoan PSLF <[email protected]>
Cc !(b)(5) U(b)(5) !"Battle, Cynthia" <[email protected]>, "Foss, Ian" <[email protected]>,
"Odom, Christian" <[email protected]>
D,itr, 03/14/2017 02·18 PM
Sub,r,ct [external]RE· Employer Escalations - APT A and Fair Elections Legal
Hi Kim
American Public Transportation Association (APT A)
PU reviev,red this escalation and the American Public Transportation Association (APT A) can be denied
for not providing a qualifying service for PSLF. Below is a list of the APTA's objectives which do not
include any PSLF qualifying services as the organization's primary purpose:
A. To represent the public intcrc~t in improving public transit for all persons.
B. To repre~ent the interests, common policie~. requirement~. and purposes of public transit.
C. To provide a medium for exchange of experience~. discussion, and comparative ~tudy of public transit
affairs.
D. To promote research and investigation to the end of improving public transit.
E. To aid member~ in dealing with special issues.
F. To encourage cooperation among it~ members, their employees, and the general public.
G. To encourage compliance with the letter and spirit of equal opportunity principles.
H. To collect, compile, and make available to members data and information relative to public transit.
I. To assist in the training. education, and professional development of all persons involved in public
transit.
J. To engage in any lav.-folactivities which will serve the members and promote public transit.
Can Compliance draft a customized denial letter listing the objectives found in the
APT As bylmvs and explain why the organization doesn't qualify? FSA \vould like to
review the letter before it goes to the borrower.
Fair Elections Legal Network (FELN)
In regards to Fair Elections Legal Network, we agree that borrO\vers who are paid
through Ne\V Venture should continue to be approved for PSLF. Borrowers paid through
the management company do not qualify. As you're aware when an organization
contracts for services of another organization, the services are rendered by employees of
the contracted organization; it is not, in our experience, common for the employees of the
contracted organization to become employees of the contracting organization. Moreover,
the PSLF definition of what it means to be an employee mirrors the definition of what it
means to be an employee for IRS purposes, and the outcome of the determination that an
individual is an employee of the organization is the issuance of the W-2. Therefore, the
borrO\vers who have W-2s associated with the management company are not employees
of New Venture Fund for PSLF purposes, and therefore do not work in qualifying
employment.
FSA would also like to review the denial letter before the communication goes out to the
borrower.
Thanks,
Taneka

Sent: Wednesday, February 08, 2017 11:59 AM
To: l(bJ(5J I
Subject: Employer Escalations
Hi Taneka! I believe these may have both been escalated to OGC, but I just wanted to follow-up
on these escalations so they don't slip through the cracks. They are several months old at this
point. I included the employer as well as the date we escalated.
American Public Transportation Association - escalated 8/31/16

Fair Elections Legal Network- escalated 9/16/16
Also, do you know if a determination has been made with the Center for Excellence in Higher
Education? Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
The sender of this message \Vill fully cooperate in the civil and criminal prosecution of
Code:PHEAA
f SERVICING
www.MyFedLoan.org
Phone: 1-800-699-2908 Fax: 717-720-1628
April 11. 2017
RE: Public Service Loan Forgiveness
Dear Ms. Taylor:
Thank you for your correspondence regarding your student loan account serviced by us, on
behalf of the U.S. Department of Education (the Department), detailed belmv.
Loan Disbursement Loan Original Principal Current Principal

Seouence Date T•~e Balance Balance
I I 09/21/2006 II Direct Unsubsidized Stnfford II $2.625.00 I S3.886.56*
2 09/18/2007 I Direct Unsubsidized Stnfford II $3.500.00 I S4.940.86*
J 09/17/2008 Direct Unsubsidized Stnfford $6.500.00 S8.730.87*
4 09/23/2009 Direct Un~ubsi<liLe<lStafford $7.500.00 S9556.69*
5 08/!6.-"2010 Direct Subsi<liLe<lStafford $8.500.00 $8,500.00
6 08/16.-"2010 Direct Un~ubsi<liLe<lStaffor<l $12-000.00 S 14,610.22*
7 08/16/2011 Direct Suh~i<li1c<lStaffor<l I $8,)00.00 I $8,500.00
8 08/16/2011 Direct lJn~uh~i<li1cd Staffor<l $12.000.00 II S 13,788.87*
9 0i/29/2012 Direct Suh~i<li1cd Staffor<l $8,500.00 II $8,500.00
10 I 05/29/2012 II Direct Unsubsidi1ed Stafford II $12.000.00 I S l 3,076.29*
II I 08/23/2010 II Direct Graduate Pl .US II $22.759.00 I S28,4.'i3.02*
12 08/17/2011 II Direct Graduate Pl .US II $29.2\3.00 II $34,234.44*
13 08il7i2012 II Direct Graduate PLUS II $28.500.00 II $31, 130.42*
14 02/05/2013 I Direct Graduate PLUS II $3.500.00 I S3.746.84*
'
l+i!!wm D. Ford Federal D1rcc/ lmm Pmgmm rD1rcc/J Parc11/loan/or L:mlergrndm1/e S1udrn1s (PLL:SJ
*f!low1.1c 111pmrcipo/ ha/o!/cc i.1tlri' rc,ult of [11/cr('l'f c11p1w/1:otim1.
On November 25, 2016. \Ve received your Public Service Loan Forgiveness (PSLF) Employment
Certification Fom1 (ECF) for the employer, Fair Elections Legal Network, which is a project of
the New Venture Fund. After reviewing your ECF, \Ve informed you that Fair Elections Legal
Network \Vas a qualifying organization for the purposes of the PSLF Program.
Fedloan Servicing• PO Box 69184 Harrisburg PA 17106-9184

Pa e 2
(b)(5)
FcdLoan Servicing
Customer Service Department
3563./-29()/!(/
1:,·11clo.111re
F:LIGIBLITY CRITERIA FOR PARTICIPATIO~ I~ THE Pt.:BLIC SERVICE LOA~

FORGIVE:\'ESS PROGRA:\-1
You must have made 120 on-time. separate. monthly payments aficr October I. 2007. on the Direct Loan
Program loans for which l'nrgiveness is requested. Payments made prior to October 2. 2007 do not count
toward meeting this requirement. Each or the 120 monthly payments must he made for the l'ulL scheduled
installment amount within 15 days ufthc due dale.
The 120 required payments must be made under one or more ufthe following Direct Loan Program repayment
plans:
• Income-Based Repayment (IBR) Plan (nut available for parent Direct PLUS Loans or Direct
Consolidation Loans that repaid a parent PLUS Loan)
• Income Contingent Repayment (!CR) Plan (not available for parent Direct PLUS Loans or Direct
PLUS Consolidation Loans)
• Pay As You ram Repayment Plan (not available for parent Direct PI.US Loam or Direct
• Rniscd Pay As You ram Repayment Plan (nut m·ailablc fur parent Direct Pl.US Loans or Direct
Comolidation Loans that repaid a parent Pl.US Loan)
• Standard Repayment Plan with a 10-year repayment period
• Any other Direct Loan Program repayment plan; hut only payments that are at least equal to the
monthly payment amount that would have been required under the Standard Repayment Plan with a
10-year repayment period may he counted toward the required 120 payments.
You must be employed full-time (in any position) by a public service organization, or must be serving in a full-
time AmeriCorps or Peace Corps position at the time you make each qualif)"ing payment. Organizations that
meet the definition of"public service organization" for purposes of the !'SL!- Program are listed below.
• A government organization (including a federal. state. local or tribal organization. agency. or entity; a
public child or family service agency: or a tribal college or university):
• A non-profit, tax-exempt organization* under Section 50l(c)(3) of the Internal Revenue Code
(includes most not-for-profit private schools. colleges, and universities):
• A private. non-profit organi;,ation* (that is not a labor union ur a partisan political organi1:ation) that
provides one or more of the following public services:
• Emergency management
• Military service
• Public safety
• Law enforcement
• Public interest law services
• Early childhood education (including licensed or regulated health care, ! lead Start, and state-
funded prekindergarten)
• Public service for individuals with disabilities and the elderly
• Public health (including nurses, nurse practitioners, nurses in a clinical setting. and full-time
professionals engaged in health care practitioner occupations and health care support
occupations)
• Public education
• Public library services
• School library nr other school-based services
Fedloan Servicing• PO Box 69184, Harrisburg, PA 17106-9184

Pa e 2
*NOTF. For p111poses of rlwfull-rime requirement (Section 3. !rem 7 & fl o(rhe FCI'), _vour qualifring
cmploymcnt docs nor include time .1pent on_joh duties that arc related to religious i111·tructio11.
irorship
services, or a11J·j(mn of'prose!J·rizing
From: Foss, Ian

Sent: 13 Jun 2017 21:16:17 +0000
To: !(b)(5) I
Subject: Re: Employer Retraction 04/10/2017
Attachments: 2007 _MA.pdf, 2015_FL.pdf
There are two EINs at issue. Here's what I found:
• 86-0658004 is approved as a 501(c)(3); however, the school is now closed.

The formal name of the corporation is Hillcrest Academy, Inc. Business
filing is here.
• 04-3466383 is now approved as a 501(c)(3); however, it has not always

been tax-exempt The formal name of the corporation is Imagine Schools,
Inc. Business filing is available through a search of the Delaware business
records (you can't link to a corporation directly). We need to reach out to
the authorized official to find out the effective date for when the
organization became tax-exempt through the IRS and when it became an
"exempt" organization under Delaware law.
o If the effective date of the IRS status pre-dates when they became
an "exempt" organization under Delaware law, then the
organization will qualify as a non-profit providing public education.
o If the effective date of when they became an exempt organization
under Delaware law predates their formation in 1999 (it does, see
below), then they can be approved only from the date of becoming
"exempt" under Delaware law forward.
o I found records from 2007 in their MA business filings that they
issued common stock, indicating that they were for-profit in 2007;
however, I also found records that they were certified as exempt in
DE in 2015. So, we know the organization qualifies, we just need to
find the cutover date.
From: Foss, Ian

Sent: Tuesday, June 13, 2017 15:46
To;!(b)(51 I
Subject: Re: Employer Retraction 04/10/20 I 7
You are making sense. I was just forgetting.
From: "l(b_l(_51~-~
Sent: Tuesday, June 13, 2017 3:37:29 PM
To: Foss, Ian

Subject: Re: Employer Retraction 04/10/2017
Imagine schools was for-profit and they have a series of charter schools classified as
501(c)(3) that fall under their umbrella. Fedloan has been denying the schools that are
classified as a 501(c)(3) or that were non-profit providing Public Education.
You were going to help me look at the school in the zip file to determine if the
organizations listed under Imagine schools could qualify for PSLFbased on their
classifications.
Please let me know if I'm still not making sense.
From: Foss, Ian

Sent: Tuesday, June 13, 2017 1:37 PM
To: !(b)(51 I
Subject: Re: Employer Retraction 04/ I 0/2017
I confess, I sat on this because I wasn't really quite sure what question needed to
be answered. Can you clarify for me?
From: 1(b_l(_51
0
__ ~
Sent: Thursday, May 25, 201710:55:51 AM
To: Foss, Ian
Subject: Fw: Employer Retraction 04/10/2017
Hi Ian,
Imagine Schools is included in this zip file. We previously determined that another
school that fell under their umbrella, Sullivant Avenue Community School, qualified as a
501(c)(3). There are a few different school EINs listed on the ECFslisted in the zip file.
Imagine Schools recently attained their 501(c)(3) status and Fedloan is currently
reaching out to determine the date of their ruling.
Thank you so much for your help. I'll send the PW separately.
Taneka

<[email protected]>
Sent: Monday, April 10. 2017 12:16 PM
To: l(b)(5J
Subject: Employer Retraction 04/10/2017
Hi Taneka! I wanted to forward over a couple more employers that need reviewed for possible
retraction.
If you have any questions, please let me know. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Code:PHEAA
MA SOC Filing Number: 200979845750 Date: 11/12/2009 4:46 PM
The Commonwealth of Massachusetts Minimum Fee: $100.00

William Francis Galvin
Secretaryof the Commonwealth,C0111orations
Division
One Ashburton Place, 17th floor
Boston, MA 02108-1512
Telephone: (617) 727-9640
Annual Report
(General Laws, Chapter 156D, Section 16.22; 950 CMR 113.57)
Federal Employer Identification Number: 043466383 (must be 9 digits)
1. Exact name of the corporation: IMAGINE SCHOOLS INC.
2. Jurisdiction of Incorporation: State: DE Country: USA
3,4. Street address of the corporation registered office in the commonwealth and the name of the registered
agent at that office:
Name: CORPORATION SERVICE COMPANY
No. and Street: 84 STATE STREET
City or Town: BOSTON State: MA Zip: 02109 Country: USA
5. Street address of the corporation's principal office:

No. and Street: 1005 NORTH GLEBE ROAD
SUITE 610
City or Town: ARLINGTON State: VA Zip: 22201 Country: USA
6. Provide the name and business street address of the officers and of all the directors of the corporation:
(A president, treasurer. secretary and at least one director are required.)
0-8371-0
Title Individual Name Address (no PO Box)

First Middle, Last Suffix Address. City or Town, State, Zip Code
VICE PRESIDENT OCTAVIO VISIEDO 1005 N GLEBE RD .. STE 610

ARLINGTON, VA 22201 USA
VICE PRESIDENT STEVE HASE
1005 N GLEBE RD. STE 610
ARLILNGTON, VA 22201 USA
PRESIDENT DENNIS W BAKKE
1005 N GLEBE RD .. STE 610
DIRECTOR EILEEN BAKKE
SECRETARY EILEEN BAKKE

DIRECTOR DENNIS W BAKKE
VICE PRESIDENT EILEEN BAKKE

DIRECTOR ROGER NAILL 1005 N GLEBE RD .. STE 610

ARLILNGTON, VA 22201 USA
DIRECTOR JOHN RUGGIRELLO 1005 N GLEBE RD. STE 610
DIRECTOR PASTOR CHARLES WHITAKER
DIRECTOR ROBERT HAFT

DIRECTOR SARAH SLUSSER 1005 N GLEBE RD .. STE 610

7. Briefly describe the business of the corporation:
EDUCATION
8. Capital stock of each class and series:
Par Value Per Share Total Authorized by Articles Total Issued

Enter O if no Par of Organization or Amendments and Outstanding
Class of Stock Num of'Shures Tow! Por Vo!ue N11111
of Shores
CWP $0.00100 30,000 $30.00 10,000
PWP $0.00100 10,000 $1 0 00 10,000
PWP $0.00100 20,000 $20.00 10,000
9. Check here if the stock of the corporation is publicly traded:
10. Report is filed for fiscal year ending: 06/30/2007
Signed by EILEEN BAKKE , its OTHER O~'FICER

on this 12 Day of November, 2009
© 2001 - 2009 Commonwealth of Massachusetts

OBTAINED All
BYRights
STUDENT BORROWER PROTECTION CENTER AND AMERICAN FEDERATION OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT
Reserved
(Requester's Name)
(Address)
(Address)
700273366957
(City!State!Zip!Phone #)
□ PICK-UP OwAIT □ MAIL
~-:,
<□
(Business Entity Name) ~;; :-,1
~ ,,, :::0
::.~f~1
(Document Number) '"---
--~-ir•i
('")
·.::,·<
-,,.~·:;' ~'r•r1
,--·--.
,-,
Certified Copies __ _ Certificates of Status __ _
Special Instructions to Filing Officer:
Office Use Only
a r ....... NATIONAL NCR Notlona/ Corporote Rtsea«h (Hang Konr,) Llmltttl,
~ a Honp Kong UmiUd Comp0ny
I'-
-•
~ I. CORPORATE
RESEARCH, LTD.®
The Right Responae at the Right Time, Every Time:•
NCR Notlonaf Corporate Resecm;h(UK} limited,
Registered in England and Wales, Registry /18010712
-------------------------------------···
Albany • Charlotte • Chicago • Dover • Los Angeles • New York • Sacramento • Springfield • Tallahassee • Washington, O.C. • Hong ICong • London
•••
Date: 06/16/2015 Account#:120000000088
Name: Michelle Walker
Reference#: D272751
ENTITY NAME: IMAGINE SCHOOLS, INC. (FILE SECOND)
III Artides of Incorporation/Authorization to Transact Business
□ Amendment
D Annual Report
D Change of Agent
D Reinstatement
D Conversion
□ Merger
D Dissol ution/WiLhdrawal
D Fictitious Name
Oother: ________________________ _
Authorized Amount:
Signature:
115 North Calhoun Street, Suite #4, Tallahassee, FL32301.

Telephone: /866) 625-0838 Fax: /866) 625-0839 lnternotionol +1 /212) 947-7200
E-Mail: [email protected] Website: www.nationalcorp.com
APPLICATION BY FOREIGN NOT FOR PROFIT CORPORATION FOR AUTHORIZATION TO

CONDUCT ITS AFFAIRS IN FLORIDA
IN COMPLIANCE WITH SECTION 617.1503, FLORIDA STATUTES, THE FOLLOWING IS SUBMITTED TO

REGISTERA FOREIGN NOT FOR PROFIT CORPORATIONFORAUTHORJZATIONTO CONDUCTITS AFFAIRS IN
THE STATE OF FLORJDA:
1. """- i n<c SohcDh, '.)'.'nc.

ameofcorporet1on:mustincu ct ewo 'lNCO '0 TED"or"CORPORATION"orwordsore rcviallonso I e
import in langu11gcas will cleurly indicate that !tis a corporation insleadofa natural person or partnership if not so contained
in the name at present. "Company" or "Co," may not be used as a corporatesuffix by a nonprofit corporation.)
:r;MA!) i n-<. '$ 0hoo IS a-FD <.lowCCI'-le , :C:"1 C

(If name unavailable in Florida, enter alternate corporate name adopted for the purpose oftransac:tingbusiness in Florida)
2. -ekwu"'- ,. 0'-1- '3Lfl,t,'3'i,~

Staieor countryunderthe lawofwhlch it is mcorporntcd)·--=~~-'.('"F"Erl
,",~m~b2,,~."lf~,~,,~,r.1,",6crl",).-------
l"\.,,_,..J-,
\q I qq 9 v.,J__
4
--~=-iis'~itcc=~~-----
(Daleoflncorporntmn) '-~~,!""~"°°========-
car corp.w1 ceaseto existor "perpctua"
6. 1,, q I 19q9 ~s ._ Mr r1>t;1 -ent . 11,, ..rtb h,1Cl>ni~wL -b '--OD.-. ,i,(;+ "MsfocLCorporo..\im.
in Floridaif priorto rcgi rntion.Sel!seclis6/7.J501 &617.f5 2, .~.to elerminepcnoty ia
(DatefostcondoctcdafTa1rs 1/ily.)
7. IODS IY'.ll
o4h C.,-k\,,,
KL Sc:.\;(Prlnc1pal
/,,JO, Aidl'~+oo,YA:
olncc R re$
2:i.:u, I
00 r \.c.lx c..,.t_(,\O rl n +oo VA £.,L,"Lll l

urrentma1mga
"
8.
9. Name and street addres~ of Florida registered agent: (P.O. Box NOT acceptable)
115 North C-alhoun Street. Suite 4

Office Address:
C:."·(J; N
,~s;!
10. Registered agent's 11cceptance: co o-•
'l:>nl
Havi11gbee111m111e,f as registered t1ge11t
a11dto acceptservice of proce.s.,;
for tile ohove stated corporat/011at tlle pince
desig11«1ed 111tills app/icatfrm,I ltereby accepttlte appoi11tme11t
as regfrteredage11ta11dag,·eeto net ill this capacity. I
further agree to comply with tfle provislo11sof all statutes relativeJo the prnpe1·amt completeperforma11ceof my
,Julies,nmf I amfamiflm· with and accept lite obflgat/011s ofmy poslt/011as registered agent.
I!. Attached is a certificate of existence duly authenticated, not more than 90 days prior to delivc1y of this application to
the Deparlment of State, by the Secretary of State or other official having custody of corporate records in the
jurisdiction under the law of which it is incorporated.
12., NarriCSand e.ddresscsof officers and/or directors
A, DIRECTORS
.i!:f,:?
¥:~l:i...+ ~ill -~~,""·
(,7
Add,o,s, I DOS: Nodh (,-1,,J,,,}?,d,.swt.lolO

ArLl "~", YA nw I
'.};;:~. Ir,.,f
John JSV3'j lo
Add'"" I OOS\li:orth (,-\,,\,..llJ.. Sw.tloiO
Add=" loo.: tlo,,!l, (-,-1..Jx]J,.s,,

;t., lPJO
Arll'\foVJ, VA :J.i¾I
Director: Y \ Ie, a.,k.
Add,oss, IDos Uodh C-,-l,,k]?.J.S1,,f,(,Jo
A c\.Jngtrn,V/t a,;,.;i-oI
B. OFFICERS
:Tosti(\1:2c~
President:
RJ..s0-+LG:JD
Add""' \QoS Ncclb(,-lg..l,e
A di ~-t,,"
A"'""·--'l-"00"--'-5-11\-.il,o"'r±h=-'(."'.,."'l..k""'-:R.uoJ+,-S"'w,J.Jr<._,
.,,&"'10'-------------
Ac.~ ;,.a
T5g,JJ..JJj.e,iw
Secretary:
SwkG,10,AcLn1,-:n,VA
Add"'"loos Noc±b r.,,1,m.?.d, :n~,
Treasurer: ~ Mt.S::a.dckn
Add,os, ::i?,J-.s...:..+..
1005 blor1±, (.,-6.b< /,ID, Arlio'.)b, \IA p---01
NOTE: If ne ssflry, you may attach nn e.ddendum to the application listing additional officers 1md/or directors,
13. _ __:"'2,~~~J=::~===c-cc============--
' ice Chairman, or any o ficer listed in number 12 ofthe application)
14. -:C
apacity of person signing app 1calion)
Officers & Directors Imagine Schools, Inc. Continued
Chancellor, Dennis Bakke

I 005 No11hGlebe Road, Suite 610, Arlington, VA 22201
Chief Financial Officer, Barry Sharp

1005 No11hG!ebe Road, Suite 610, Arlington, VA 22201
Senior Vice President/Secretary, Isabel Berio

JOOSNo1ih Glebe Road, Suite 6 ! 0, Arlington, VA 22201
Senior Vice President, Eileen Bakke

1005 Notth Glebe Road, Suite 610, Arlington, VA 22201
Senior Vice President,Rhonda Cagle ;>'er>

--,-.
-· rr:
--
S:.J'I
(_
1005 Nmth Glebe Road, Snite 610, Ar!inglon, VA 22201 re.::)'.', C
... ,. z
Senior Vice President, Octavio Visiedo rn
I 005 North G!ebe Road, Suite 610, Arlington, VA 22201
ExecutiveVice President, Diane Beatty

1005 North Glebe Road, Suite 610, Arlington, VA 22201
ExecutiveVice President, Amy Buttke

1005 No11hOlebe Road, Suite 610, Arlington, VA 22201
Executive Vice President,Monte Lange

1005 No1th Glebe Road, Suite 610, Arlington, VA 22201
Executive Vice President, Rod Sasse

I 005 North Glebe Road, Suite 610, Arlington, VA 22201
Executive Vice President, Brad Uchacz

1005 North Glebc Road, Suite 610, Arlington, VA 22201
Chief Academic Officer, Nancy Hall

!005 North Glcbe Road, Suite 610, Arlington, VA 22201
Executive Vice President, Shawn Toler

1005 No,th Glebe Road, Suite 610, Arling-ton,VA 2220 l
f})e[aware PAGE 1
'Ifie :FirstState
I, JEFFREY W. BULLOCK, SECRETARY OF STATE OF THE STATE OF
DELAWARE, DO HEREBY CERTIFY "IMAGINE SCHOOLS, INC. " IS DULY
INCORPORATED UNDER THE LAWS OF THE STATE OF DELAWARE AND IS IN
GOOD STANDING AND HAS A LEGAL CORPORATE EXISTENCE SO FAR AS THE
RECORDS OF THIS OFFICE SHOW, AS OF THE SIXTEENTH DAY OF JUNE,

A.D. 2015.
AND I DO HEREBY FURTHER CERTIFY THAT THE AFORESAID

CORPORATION IS AN EXEMPT CORPORATION.
3019372 8300C
150928001 DATE: 06-16-15

You ""'Y varify this c01rtiflc1<te onl.tne
at c,:,rp. del.aw .. re. gov/authver .&html
From: Foss, Ian

Sent: 25 May 201717:12:04 +0000
To: !(b)(5) I
Subject: RE: Employer Retractions_2017.05.15_Email 15
We need to not retract these borrowers, we need to stop retracting all borrowers, and we need to ask
Fed loan to not send retraction letters to those that we approved them to send if they can prevent them
from going out.
Call me for more information.
From: l(bJ(5J I
Sent: Thursday, 25 May, 2017 9:30
To: Foss, Ian
Subject: Re: Employer Retractions_2017.05.15_Email 15
Sure thing. I'll wait.
Thanks,
Taneka
From: Foss, Ian

To: l(b)(5J I
Subject: RE: Employer Retractions_2017.05.15_Email 15
Can we hold off on asking them to retract? I need to read the court filing and look at the borrower
names to assess whether I need to bring OGC into this.
~---~
From: (bJ(5J
Sent: Thursday, 25 May, 2017 9:11
To: Foss, Ian
Subject: Fw: Employer Retractions_2017.05.15_Email 15
The Vietnam Veterans of America is included in this zip file. There are three borrowers that
need to be retracted with ECFs on file from 2012 and 2013.
I'll send the PW separately. I'll send a message to Fed Loan to retract this now. Do you also want
me to ask why these borrowers were not caught when then initial decision went out?

To: l(b)(5J I
Cc: Battle, Cynthia; Foss,Ian; Odom, Christian; FedloanProgramManagement
Subject: Employer Retractions_2017.05.15_Email 15
Thanks!
Kim
and/or attachments.
Code:PHEAA
From: l(b)(5)
Sent: 6 Dec 2016 14:11:30 +ODDO
To: Foss, Ian
Subject: Re: Employer Review - AARP
:) I was planning to ask Fedloan regarding the ECFsthey had on file since the latest escalation
came from the organization and was not included. I'm taking sick leave today (just came on to
put up an away message). My youngest is not feeling well. I'll add you to the email stream.
Thanks,
Taneka
From: Foss. Ian

Sent: Monday, December 5, 2016 3:41 :22 PM
To: !(b)(51 I
Subject: RE: Employer Review - AARP
What EIN was on the ECF?
From: l(b)(5) I
Sent: Monday, December 05, 2016 3:55 P\1
To: Fo~~,Ian
Subject: FW: Employer Reviev.,- AARP
Iii Ian,
Sec below. The American Association of Retired Persons (AARP) is being escalated to fSA for
the third time. The first time they \Nere denied was in 2013, after you found that their Legal
Counsel for the J::lderly was an independent arm of the AARP and that a:, an organization it did
not directly provide a qualifying service. The next escalation we received was in September
2016, with the AARP claiming that they were actually a 50 I (c)(3). Rene and I escalated the case
to OGC. and it \Na:. again determined that the AARP is not an eligible employer and that their
primary purpo:-.e i:-.not to provide services to the "elderly".
Below is the latest email from AARP. It seems like the AARP believes they should be
considered as a disregarded entity of the AARP foundation. I pulled scrccnshots of the Schedule
R's for the AARP Foundation which i:-.a 50l(c)(3) and AARP. lnc which i:-.a 50l(c)(4). !'he fir:-.t
screenshot i:-.the foundation and it lists the AARP, Inc. as a related organization (not a
disrePardcd omanintion) and the foundation doesn't have controllinP nowcr over it. The
(b)(5)
elile GRAPHIC ~,int - DO NOT PROCESS I A~ Filed Doto - I DLN,93493179004015
SCHEDULER Related Organizations and Unrelated Partnerships

(Form 990) ► complete ,r the """'"'"tK>naMwe,ed , ... ""Fom,990,
► Attach fo Fom,
Part IV,""" 33, "'• a>b, 30, o, 37.
'"'°· 2014
• J,to...,., .,,, about """"""" R (Fo"" 990) a"" ,,. '""'""""" "at w"w '"-~•• /to,m090.
"'' ,1•'c,,•,,•,;,•,,,
"'''
llm:D Identification of Dis,ega,ded Entities <:mnplete ,f the m,,m,at,m a·,swece,I "Yes "" Fnm, 'J'Hl, Part TV, l,ne
'"'
,,,,,,,,,.,,.
,,.,,,,,
lmlII ldentit,cation of Related Tax-Exempt o,gan,zation~ C,omplete 1f the o,g,n,zat,on a1swe,ed "Yes on I orm 990 eart lv, line J4 tecause ,t had one
cela1e,J
1,l' e,e n1,I""'""''"'"'"''''"""'the ta, ·,ea,
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Fo, Pa orl< Reduct""' Act"°';"' ..,. the lostn,ct,ons 1..- '""" "90. Cat \o 5 _35, Schedule R '""" ggo 2014
Sottwa,e IO:
Softwar-e ve,sion:
EIN: 95·1985500
Name: AARP
orm 990, Schedule R, Part I· Identification of Disregarded Entitles

,., '" ,., <•>
Pnm•C\'"""''Y
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o,,.,tconrro,1,,,
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comooov
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,0<0,noton. DC 20049
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,o,esr,e,tNW
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comp,ny "' • >l,Ul,lH URP
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•s-,,assoo
, AARP
,ARPHOr•-S'"C
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company "' ll,910,03"
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,01 E St.-.otNW
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comoany "'
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•O!ESt,eo!NW
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R"I <>ta!• holdmo
'""'"'"' "'
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,ARP A M<\,s l nsoraac • fund LLC losmoce caotwe 1.llS,177 5,361,698 AARP
,O!ESt,o,tNW
,ash,noton, DC 20040
"'
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,r. Rol'nao•n•d LLC A<mt oooplo ,n 211,UO 14,171,961 AA~P
,01 E St,eetNW
"""""°"'""'""'""'
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'"'"'""'""·
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oc 10049
oo•I•
From: Kimberly A Myers [mailto:kmvers(dpheaa.orgJ On Behalf Of Fed Loan PSLF

Sent: Mondav. December 05, 2016 8:49 AM
To:j(b)(5) I
Subject: Fw: Employer Review - AARP
Hi Taneka! I know we have had prior hack and forth in regards to AARP. Based on the mo~t recent c~calation and
dctcm1ination that they don't qualify, we rc~pondcd with a pcr~onal letter to the AARP directly. That same staff
pcr~on i~ now escalating again. She emailed one of our internal staff The content~ of her email arc he low.
Plca~c let u~ know how you would like us to proceed. Thanks!
Kimberly A \1yers
Compliance Services
k mve rsfn:pheaa .org
(717) 720-2630
-···· FurwarJ~d by K1mkrly .\ \1yns/f'HE.\t\ on 12/05/2016 08.44 AM .
•,er~· gooo morn,ng ·,, rog,ot·at,or of •;c"Jdo·sNt p,o,•,ao '°""" ,ca or a ""~" for ,rc,r mem,crs ,, oc,o b, MRP s,-...,ces '" ,As,, an ,tt,ale The, are 110, o, P,of,t Mc of MRP "" mere ,c a Pn·,ato
I e,re, l<uh·,; "' ,,.,,,, I, AAF!" m ,sl keep ASI ar "''" s ""'"'
11,epe,s, ..,.,,,,, "'"'"""'''';rl,e '''"""'"""Jdoe, ""' ,eeH ,,, '"''""'"'" l'J> ,·n IL'POtAAld' .,..,,, 'J,S "'"''"""
,1ff1ate 1'c 0100·o,·11,csdo prov de d,roct sc·,,co edueatioo ,1S,•oc,c. cl'. lo· ALLC1· pco, o
ol 11,epa,e,· n,e' ""'"""" A~I; ,, l • ,f-"> '"' ,., ,,,,,el1m I'»' de,, •., A~l ,srt,e" ,, '"' ,,, ,,,.
cl,,,,-,
"."/hoc.n I spc.1k ·1,,th.100,· 1' , d,·oc11·.sc th,11we c.10 "" ,~,\indi,9 ''""'' I m 1', c>,.cg,- ~ould be hclcic Le gor ou, 109,1deo,wncnl '""'"'°"bec,ucc I "" aooarentl, not ""'"''•"9 "" 11-,11
o,ough Also ,,
,,, p,cw,1e "'"' es ,,,,,1'" ''"' """" '"' ""' ,run,r,·s tile·,
,,,,, ( c '"" '"""""' AA'lP ,.,,,. ASI: nH)<)I,ll"' ,,..,,,,,·e.><1,l.S °""'" nt a,,ce I'"" 101,"""'"·"' ,'
Roo, Delaae\ SPHR ACCI H,m.a Re,ou,ce, Gco,p

1,,1,,,,"•'"'>'""'"''AJ•,""' I '"'"' ·,u; ; ,4-Ci,' ·-c ,,,,,, -,,u ,u I
c<·,aol,_cl,,,.... J
001 E S1«·c1ti\".' 32 -2',01 W,shmg•o, CC 2,0'9
attachments.
Code:PHEAA
From: l(b)(5)
Sent: 28 Feb 2014 08:58:14 -0600

To: Fedloan PSLF
Cc: Battle, Cynthia;Johnson, IL.(b-'-l('--51
_______ _,I Ian
Subject: Re: Evergreen Cemetary Association
Attachments: Deductability Codes.docx
Hi Diane,
I agree with your analysis that this organization does not qualify. As to which deductibility codes you
can use, I found the attached, which maps the codes to the organization's status. As you can see,
there's a lot of overlap that leads me to believe that we cannot really rely on the deductibility codes
for much. I would suggest reliance on the BMF, as it provides the definitive subsection code that will
tell you if the organization is a 501{c)(3) or something else.
This may be useful, so I found the mapping of the deductibility codes here:
http://www.irs.gov/i rm/part25/i rm 25-007-006.html.
Ian
On 2/17 /14, 15:32, "Fed loan PSLF"<[email protected]> wrote:
Hi Ian,
The employer checked 501{c)(3). They are listed with a deductibility

status of EO on the Exempt Organizations Select Check List. EO means: An
organization described in section 170(c) of the Internal Revenue Code other
than a public charity or private foundation.
When we checked their Form 990, they are listed as a 501(c)(13) and we
determined that they don't provide a qualifying public service. They are
also listed on the IRS Business Master File list as 501(c){13). Please
confirm that you agree.
(b)(5)
Thanks for your help! Password to follow.
{See attached file: Evergreen Cemetery Association.zip)
Diane Freundel
Compliance Services
{717) 720-3267
fax- (717) 720-3911
only. If you
individual engaging
Deductibility
Code Type of organization and use Programming
Limitation
PC A public charity 50%
Foundation Code is 02 or 03
POF A private operating foundation 50% and the Current EO Status
Code is not 25
Foundation Code is 04 and
PF A private foundation 30% (generally) the Current EO Status Code
is not 25
Generally, a central organization holding a group exemption letter,
GROU whose subordinate units covered by the group exemption are also Depends on various
Affiliation Code 06 or 08
P eligible to receive tax-deductible contributions, even though they are factors
not separately listed.
LODGE A domestic fraternal society, operating under the lodge system, but '¾ Current Subsection Code 08
30 0
only if the contribution is to be used exclusively for charitable purposes. or10
Current Subsection Code is
UNKW A charitable organization whose public charity status has not been Dependson various
03 and the Foundation Code
N determined. factors
is 09
04, 08, 10, 13 or 19 OR
An organization described in section 170(c) of the Internal Revenue Depends on various
EO Current Subsection Code is
Code other than a public charity or private foundation. factors
01 and the Activity Codes
present are other than 925
An organization to which contributions are deductible if made for the
FED 50% 01 and at least one of the
use of a federal governmental unit.
Activity Codes is 925
A foreign-addressed organization. These are generally organizations Universal Location Code is 98
Dependson various
FORGN formed in the United States that conduct activities in foreign countries. and the State is ., indicating a
factors
Certain foreignorganizationsthat receive charitablecontributions foreign address
deductible pursuant to treaty are also included, as are organizations

created in U.S. possessions
A type 1, type 2, or functionally integrated type 3 supporting Foundation Code is 21, 22, or
so organization
50%
23
SONFI A non-functionally integrated type 3 supporting organization 50% Foundation Code is 24
SOUNK A supporting organization, unspecified type 50% Foundation Code is 17
From: l(b)(5)
Sent: 29 Nov 2013 16:11:48 -0600

To: Fedloan PSLF
Cc: l(bl( 5l Ilan;Johnson,
Debbe;Battle, Cynthia
Subject: Re: Excela Health Physicians Practice
Hi Diane,
I can t find any record that thi~ i~ a 50l(c)(3) organization. but the
1
businc~s filing confirm~ that this is a non-profit organization. Schedule

R in Form 990 doc~ not mean that any of the organiLations listed 1~
for-profit.
Given that this is the physician's group, we can easily approve this a~ a
non-profit organization offering public health services.
Ian
On 1I /22/13, 9:07. "FedLoan PSLF" <FedLoanPSLF(iijpheaa.org> wrote:
>
>Hi Ian. We're having difficulties making a decision on this one.
>
>ECr - certified 50 1(c)(3)
>Business filing - same name as organization on ECr(Excela Health
>Physicians
>Practice) lists as non-profit
>Form 990 - for Excela Health (page 1)
>Form 990 Schedule R for Exccla Health - Exccla Health Physician~ Practice
>is li~tcd as a Related Organization Taxable a~ a Corporation or Trust -
>li~tcd a~ a C Corp - we thought this meant that the entity wa~ for profit
>
>Password to follow. Thanb for your a~~i~tancc!
>
>(Sec allachcd file: Exccla Ilealth Phy~1cians Practice.zip)
>
>Diane Freundcl
>(717) 720-3267
>fax- (717) 720-3911
>[email protected]
>
From: l(b)(5)
Sent: 8 May 2013 13:36:40 -0500

To: Fedloan l(bl(5l I
Subject: RE: Explore Knowledge Academy
Hi Diane,
I agree that ti~ one qualifies, even though the ~late corporations database ~ays that the organization'~ status
is "permanently revoked". Clearly, it is still an operating charter ~chool in Nevada and i~ organized as a
not-for-profit under stale law.
I abo pulled a copy of the school's charter, which is valid into 2014.
Ian
Sent: Tuesday, Ar! 30, 2013 4:09 PM
To:l(b)(5)
Subject: Explore Knowledge Academy
Hi Ian, This is a another charter school we're having difficulty with.
They only checked "public education" on the ECF, not box c for private non-profit.
Nevada business filing shows non-profit with a permanently revoked status.
Nevada law for charter ~choob indicates operation for profit is prohibited - page 3 of lcg.~tatc.nv
attachment.
We think we can approve, but would like your input. Password to follow.
Thanh again!
(Sec attached file: Explore Knowledge Academy.Lip)
Diane Freundcl
Compliance Services
(717) 720-3267
fax-(717) 720-391 I
From: l(b)(5)
Sent: 20 Jan 2017 13:41:58 +DODO
To: Foss, Ian
Yeah, let me confirm if they are switching the approved employment to fall under New
Venture Fund?
Thanks,
Taneka
From: Foss. Ian

Sent: Wednesda,. January 18.2017 5:02: 15 PM
To: l(b)(5J -
So are there any borrO\vers left certified as employed by Fair Elections Legal Network?
On Jan 18, 2017, at 14:56, FedLoan PSLF <FedLoanPSLF(d;pheaa.org> wrote:
Hi Taneka! I just wanted to follow-up on your requests regarding this employer.
I confirmed that it was an oversight by the BU for why they did not forward the ECFs
where 'Fair Elections Legal Network' was included in the name, but the EIN of New
Venture Fund was provided.
The BU was able to get in contact with the certifying official for several borrowers.
The certifying official confirmed that the borrowers were employed and paid by New
Venture Fund.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
:::ro1'l Fedloan PSLF/PHEAA

To l{b)(5) U(b)(5)
Cc "Battle. Cynthia" <[email protected]>. Fedloan PSLF <[email protected]>. "'Foss, Ian"
<[email protected]>
n;;:e 0111012017 01:02 PM
SubJect Re. [external]RE: Re. Fair Elections Legal Network
Scwt by Kimberly A Myers
Hi Taneka! After re-reading my message, I realize I was a little unclear.
There were a total of 10 borrowers who were certified under the EIN for New
Venture Fund. Of those 1O borrowers, only 2 of the ECFs included or used the
name 'Fair Elections Legal Network.' The ECFs for the other 8 borrowers only
indicated the name of the organization as 'New Venture Fund' and made no
mention to 'Fair Elections Legal Network'.
The ECF I attached in my last message was one of the two borrowers who included
'Fair Elections Legal Network' in the name in conjunction with the EIN for New
Venture Fund. I specifically included his correspondence as he explained the
relationship between the two organizations.
In regards to the eight borrowers who indicated New Venture Fund on their ECF
along with the New Venture Fund EIN, there wouldn't be anything for the Business
Unit to question, and that is why they were approved.
I am checking to identify why the Business Unit didn't question the two ECFs that
indicated/included 'Fair Elections Legal Network' but certified under the EIN for New
Venture Fund (although I'm assuming it was just an oversight).
Based on my request to the Business Unit, they will also be contacting the certifying
official for those borrowers who were certified under the EIN of the New Venture
Fund to determine who the borrower actually works for.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
~r:w1 publicservice l{b)(5) I

Cc "Battle. Cynthia" <[email protected]>. "Foss. Ian" <[email protected]>, 1{b~)~(5~)
0 -~
l{b)(5)
01/10/2017
I
09:18 AM
SubJect [external]RE: Re: Fair Elections Legal Network
H1Kim,
Thanks for the quick follow-up.
For the borrowers who used the EIN for New Venture -were there any checks to reconcile
the conflicting information between the organization name and the EIN provided? We are
just trying to discern if any research was conducted that would help with the borrower who
used the EIN for Fair Elections Legal Network (FELN} and referenced New Venture.
Since all the borrowers certified under the name Fair Elections Legal Network, we think 1t
might be helpful for the Business Unit to also contact one of the certifying officials who
certified FELN under the EIN for New Venture to help us better understand the relationship
and who the borrowers actually work for.
Thanks,
Taneka

Sent: Monday, January 09, 2017 3:50 PM
To: !(bl(51 I
Cc: Battle, Cynthia; Fedloan PSLF; Foss, Ian
Hi Taneka! You are correct, the borrowers who used the EIN for New Venture Fund
were approved as 501 (c)(3). I will have the Business Unit reach out to the certifying
official to determine who actually employs the borrower. I will let you know what we
find out. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
~r~w1 l/bl/51 U(b)(5) I

T,1 Fedloan PSLF <[email protected]>
Cc "Battle, Cynthia" <Cynthia [email protected]>, "Foss, Ian" <[email protected]>
D:i:e 01/09/2017 02:29 PM
SubJect [external]Re. Fair Elections Legal Network
Hi Kim,
Just to clarify, the borrowers who certified under "Fair Elections Legal
Network" but provided the EIN for New Venture Fund were approved under
the 501(c)(3) category, right?
Can Fed Loan reach out to the Certifying Official to confirm if these
borrowers are employed for New Venture Fund or Fair Elections Legal
Network?
Thanks,
Taneka
From: Kimberly A Myers <[email protected]> on behalf of Fedloan PSLF

Sent: Monday, January 9, 201712:39 PM
To: l(b)(5) I
Cc: Battle, Cynthia; Fedloan PSLF;Foss, Ian
Hi Taneka! From what I could determine, we have not received an ECF certified
under the 'public interest legal services' category for Fair Elections Legal Network.
However, based on your request, I had the Business Unit do a further query on the
system. While they didn't find any other certifications under this EIN for Fair
Elections Legal Network, there were some other borrowers who used 'Fair Elections
Legal Network' in the employer name, but certified under a different EIN that links to
the New Venture Fund, a 501 (c)(3) (there were a total of 1O borrowers). One
borrower also submitted a letter regarding the relationship, which I attached. The
employer, New Venture Fund, had not previously been escalated to Compliance.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
~r~w1 i(b)(5l li(b)(5l I

Cc "Battle. Cynthia" <Cynthia [email protected]>. "Foss. Ian'" <[email protected]>
D:i:e 01/09/201711:43AM
SubJect [external]Re. Re: Re: Fair Elections Legal Network
Hi Kim,
Can you tell me if the authorized official for the Fair Elections Legal Network
ever submitted an ECF as providing Public Interest Law Services. The ECF
that was attached for the borrower in 2015 is certified under Public
Education.
Thanks,
Taneka

Sent: Monday, November 21, 2016 6:44:52 AM
To: l(b)(5) I
Cc: Battle, Cynthia; FedLoan PSLF;Tiongquico, Rene
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
c::ro,'l l/bl/51 lirbl/51 I

Cc "Battle. Cynthia" <Cynthia [email protected]>. "Tiongquico, Rene" <Rene T1ongquico@ed gov>
D:i:e 10/07/2016 03:35 PM
SubJect [external]Re. Re: Fair Elections Legal Network
Thanks Kim.

To: l(b)(5) I
Cc: Battle, Cynthia; FedLoan PSLF;Tiongquico, Rene
Hi Taneka! We only have record of this one borrower being approved under the
Fair Elections Legal Network, and it was approved on 3/5/12. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
~r~w1 l/bl/51 l<[email protected]>

Cc l{b)(5) U(b)(5) l "T1onqqu1co. Rene" <Rene T1onqgu1co@ed gov>, "'Batlle,
Cynthia'" <Cynth1a.Battle@ed gov>
D:i:e 10/07/2016 01:09 PM
Hi Kim,
(b)/5)
Thanks,
Taneka

To: l!b)/5) I
Hi Taneka! This employer was last reviewed in March 2012 (during the beginning
stages of our PSLF reviews). We had escalated this one and Ian approved as
private not-for-profit, and we categorized it under public interest legal services.
(b)(5)
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
This message contains privileged and confidential information intended for

the above addressees only. If you receive this message in error please
delete or destroy this message and/or attachments.
The sender of this message will fully cooperate in the civil and criminal
prosecution of any individual engaging in the unauthorized use of this
message.
Code:PHEAA
From: l(b)(5)
Sent: 2 Mar 2012 11:07:08 -0600

Subject: RE: Fair Elections Legal Network
Diane,
You're right, this one i~ tough.
I would note that FELN cannot he a

501 (c)(3) organiLation, ilsclC because il engage~ in advocacy work,
lobbying for or against legislation. This makes it more compatible with
50l(c)(4) slalu~; however, there is not entry in the IRS Bu~incss Master
File to that effect.
And, merely because another organization that happens

to be a 50l(c)(3) has assumed full financial and legal responsibility for
the organization doesn't make it a 50 1( c )(3). Despite that relationship,
FELN remains separately organized from the Nev., Venture Fund (the EIN in the
letter from the IRS to the New Venture Fund is different from the EIN that
the borrower supplied on the ECF).
What's more. I found rELN in DC's

business filings as an LLC. which is exactly how it was described on the
\vebsite (I'll also note that it had its entity status revoked, but I don't
know why and don't think its relevant). I will also note that the DC
business filings database does distinguish between other corporations and
not-for-profit organization~ and I know that because there is abo an cntty
for the Pair Election~ Foundation, which is listed as a not-for-profit
(though the two organin1tion~ remain separate). All this being ~aid, LLC~
arc not required to i~~uc~tock, and can easily mimic a not-for-profit
corporation by not offering ~tock and operating not-for-profit, which would
make them nol-for-prolit. Nomrnlly I would be wary of relying on entries in
variou~ non-authoritative databases, ~uch as Democratic GAIN, but here I
think it\ okay because the organiLation appears lo have supplied the
description it~clr So, that makes it a not-for-profit.
Because they arc

not a 501 (c)(3) organization. they need to provide a qualifying public
serve. They do provide public interest legal services, through its network
of attorneys that advise on litigation strategy and repeal efforts. I'd
note that they pair with the ACLU on cases before the Supreme Court and the
like and also provide legal training to students and others on election law
issues.
So. this qualifies in the last category of employment.
Ian
>
rmailto:dfrcundctn)acssucccs~.or l On Behalf Of
0
> FcdLoan PSLF
> Sent:
Thursday, March 0L 2012 9:13 P\1
> To: l(b)(5) I
> Subject: Pair
Election~ Legal Network
>
>
> Hello, We have another tough one.
>
> They
certified as 50 I (c )(3) and provided documents showing that the
>New
Venture Fund, a 50l(c)(3), serves as the fi~cal spon~or for the
> Fair
Elections Legal Network (FELN) - .pdfnamed Nev., Venture Fund
> SOl(c)(l)-
sorry the pages are out of order.
>
> I believe FELN is a non-profit itself
- bio.pdf indicates it's
> organization type is non-profit advocacy.
>
>
I'm not sure ifFELN can be considered a 50l(c)(3) or if they are a
>
private non- profit. If they're a private non-profit is the advocacy
>
work they do a public service? I think so became their overall
> mi~~ion
is to remove barriers to registration and voting for traditionally
undcrrcprc~cntcd
> constituencies. Would this be considered public service
law ~ervicc~?
>
> Password lo follow. Thanks!
>
> (Sec attached file:
Fair Elections Legal Network.zip)
>
> Diane Freundel
> Compliance
Services
> (717) 720-3267
> fax- (717) 720-3911
> [email protected]
>
-------------------

information intended
> for the above addrc~scc~ only. If you receive this
message m error
> please delete or dc~troy thi~ message and/or
allachmcnt~.
>

civil and
> criminal pro~ccution of any individual engaging in the
unauthorized
> use of this mc~~agc.
>
--------------------------------
>
From: Foss, Ian

Sent: 7 Mar 2017 21:08:57 +0000
To: !(b)(5) I
Sorry for the delay on this.
Here's the critical paragraph, I think, with a critical highlight:
The FELN Project recruits, hires and supervises employers to fulfill New Venture Fund's
charitable mission. Like many section 501(c){3} and other organizations, the FELN Project
engages a third party to provide payroll services, health insurance and other administrative
support. Under this arrangement, Robert M. Brandon & Assoc. {"RBA") provides administrative
and payroll services to the FELN Project. As employees, of the FELN Project, these employees
were common law employees of the FELN Project, a qualified section 501(c)(3) project of New
Venture Fund.
I don't know what set of employees they're referring to, but I'm confused enough to think we should
write back to say that, typically, when an organization contracts for services of another organization, the
services are rendered by employees of the contracted organization; it is not, in our experience, common
for the employees of the contracted organization to become employees of the contracting organization.
Moreover, the PSLFdefinition of what it means to be an employee mirrors the definition of what it
means to be an employee for IRS purposes, and the outcome of the determination that an individual is
an employee of the organization is the issuance of the W-2. Therefore, the borrowers who have W-2s
associated with the management company are not employees of New Venture Fund for PSLFpurposes,
and therefore do not work in in qualifying employment.
From: l~(b'-')(5-'-I~~-!
Sent: Tuesday, 21 February, 2017 10:46
To: Foss, Ian
Hi Ian,
Attached is a letter that I failed to discuss with you on Friday. During the meeting we discussed having
Fed Loan sent a customized denial letter to all borrowers who are being paid through the management
company; however, after reading the letter from the president I'm not so sure these borrowers should
be denied.
I have reluctance about denying these borrowers because I don't understand why there are employees
being paid through New Venture fund and working for FELN and employees being paid through the
management company and working for FELN. What do you think after reading the letter? Is there
anything else we can request or that I can look up to show the borrowers paid through the management
company should qualify?
Thanks,
Taneka
From: Kimberly A Myers [mailto:[email protected] l On Behalf Of FedLoan PSLF

Sent: Thursday, February 09, 2017 2:14 PM
To: l(bJ(5J I
Cc: Odom, Christian; Battle, Cynthia; Foss, Ian
Hi Taneka! Based on my previous email to you, we had requested W-2s from these borrowers. So far,
we received a W-2 from 6 of the 11 borrowers (attached). One borrower submitted an additional letter
from the organization and I attached that as well.
Of the 6 borrowers, 4 show they are paid directly by New Venture Fund under their EIN. The other 2
show they are paid by Robert M Brandon & Associates Uust to note, one of these two borrowers was the
borrower who prompted this original email). As we stated previously, we were informed by the certifying
official that Robert M Brandon & Associates is a management company and the funds actually come from
Fair Elections Legal Network (not New Venture Fund).
Based on the borrowers who are paid directly by New Venture Fund, we believe they should remain
approved as New Venture Fund is 501(c)(3). Please let us know how you would like to proceed with
those borrowers paid by the management company.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
~r:w1 Fedloan PSLF/PHEAA

To l{b)(5) U(b)(5)
Cc "Odom, Christian" <Christian Odom@ed gov>, "Battle, Cynthia" <Cynth1a.Battle@ed gov>, Fedloan PSLF
<[email protected]>, "Foss, Ian" <Ian [email protected]>
D:i:e 01/20/201710:57 AM
SubJect Re. [external]Re: RE. Re. Fair Elections Legal Network
Sert lly Kimberly A Myers
Hi Taneka! Currently all of the borrowers (10 total) whose ECFs were certified under the New Venture
Fund EIN are showing approved as 501 (c)(3). The one borrower who certified under Fair Elections Legal
Network with Fair Election's EIN is still in an approved status as private not-for-profit, public interest legal
services.
At the time I sent you the below email, the Business Unit was only able to contact the certifying official for
3 of the borrowers certified under the New Venture Fund EIN. Just to note, none of those 3 borrowers
had included the name 'Fair Elections Legal Network' in the title of the organization.
Since I messaged you, I found out that the certifying official of another borrower has since contacted our
office (this borrower's ECF was certified under the name 'New Venture Fund-Fair Elections Legal NW).
The certifying official indicated that New Venture Fund is the fiscal sponsor for the not-for-profit Fair
Elections Legal Network's donations and the reason the ECF listed both organizations. She also
indicated that the borrower was paid by a management company, Brandon & Associates. I had
previously forwarded you a letter regarding the fiscal agent relationship between the two organizations.
At this point, since we have one borrower still under the EIN for Fair Elections Legal Network and 10
under the EIN for New Venture Fund and due to the fact the latest official again indicated the fiscal
sponsor relationship between New Venture Fund and Fair Elections Legal Network, we were going to
request W-2s from all the borrowers to confirm whose EIN appears on their W-2s.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
· r~w1 i(b)(5) li(b)(5) I

iic~,,,.,.~-B~a,Ul,e,Cynthia" <Cynthia [email protected]>, "Foss, Ian" <[email protected]>, "Odom, Christian" <Christian [email protected]>,
0
-='1
!(b~)~(5~) <publicservice@ed gov>
u.n, 011201201708:43 AM
:C;LJtw-ad [external]Re: RE: Re: Fair Elections Legal Network
Hi Kim,
Thanks for confirming with the certifying official. Will FedLoan be switching these borrowers as
approved and employed under New Venture Fund?
Thanks,
Taneka

Sent: Wednesday, January 18, 2017 1:56:26 PM
To: l(b)(5) I
Cc: Battle, Cynthia; Foss, Ian
Subject: Re: RE: Re: Fair Elections Legal Network
Hi Taneka! I just wanted to follow-up on your requests regarding this employer.
I confirmed that it was an oversight by the BU for why they did not forward the ECFs where 'Fair Elections
Legal Network' was included in the name, but the EIN of New Venture Fund was provided.
The BU was able to get in contact with the certifying official for several borrowers. The certifying official
confirmed that the borrowers were employed and paid by New Venture Fund.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
· r:w1 FedLoan PSLF/PHEAA

To !(b)(5) U(b)(5)
Cc "Battle. Cynthia" <[email protected]>. FedLoan PSLF <[email protected]>. "Foss, Ian" <[email protected]>
n;;:e 0111012017 01:02 PM
Subject Re. [external]RE: Re. Fair Elections Legal Network
:=;,w1il)' Kimberly A Myers
Hi Taneka! After re-reading my message, I realize I was a little unclear.
There were a total of 10 borrowers who were certified under the EIN for New Venture Fund. Of those 10
borrowers, only 2 of the ECFs included or used the name 'Fair Elections Legal Network.' The ECFs for
the other 8 borrowers only indicated the name of the organization as 'New Venture Fund' and made no
mention to 'Fair Elections Legal Network'.
The ECF I attached in my last message was one of the two borrowers who included 'Fair Elections Legal
Network' in the name in conjunction with the EIN for New Venture Fund. I specifically included his
correspondence as he explained the relationship between the two organizations.
In regards to the eight borrowers who indicated New Venture Fund on their ECF along with the New
Venture Fund EIN, there wouldn't be anything for the Business Unit to question, and that is why they were
approved.
I am checking to identify why the Business Unit didn't question the two ECFs that indicated/included 'Fair
Elections Legal Network' but certified under the EIN for New Venture Fund (although I'm assuming it was
just an oversight).
Based on my request to the Business Unit, they will also be contacting the certifying official for those
borrowers who were certified under the EIN of the New Venture Fund to determine who the borrower
actually works for.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

Cc "Battle. Cynthia" <Cynthia [email protected]>. "Foss. Ian" <[email protected]>, -~0 0(b~)(~5~)
1{b~)~(5~)
0 ----~
D:i:e 01/10/2017 09:18 AM
Subject [external]RE: Re: Fair Elections Legal Network
H1Kim,
Than ks for the quick follow-up.
For the borrowers who used the EIN for New Venture - were there any checks to reconcile the conflicting
information between the organization name and the EIN provided? We are just trying to discern if any research
was conducted that would help with the borrower who used the EIN for Fair Elections Legal Network (FELN) and
referenced New Venture.
Since all the borrowers certified under the name Fair Elections Legal Network, we think 1t might be helpful for the
Business Unit to also contact one of the certifying officials who certified FELNunder the EIN for New Venture to
help us better understand the relationship and who the borrowers actually work for.
Thanks,
Taneka

Sent: Monda , January 09, 2017 3:50 PM
To: (b)(5)
Hi Taneka! You are correct, the borrowers who used the EIN for New Venture Fund were approved as
501(c)(3). I will have the Business Unit reach out to the certifying official to determine who actually
employs the borrower. I will let you know what we find out. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

Cc "Battle, Cynthia" <Cynthia [email protected]>, "Foss, Ian" <[email protected]>
Da:o 01/09/2017 02:29 PM
Sub1oct [external]Re- Fair Elections Legal Network
Hi Kim,
Just to clarify, the borrowers who certified under "Fair Elections Legal Network" but provided
the EIN for New Venture Fund were approved under the 501(c)(3) category, right?
Can Fed Loan reach out to the Certifying Official to confirm if these borrowers are employed for
New Venture Fund or Fair Elections Legal Network?
Thanks,
Taneka

Sent: Monday, January 9, 201712:39 PM
To: l(b)(5) I
Cc: Battle, Cynthia; Fedloan PSLF;Foss, Ian
Hi Taneka! From what I could determine, we have not received an ECF certified under the 'public interest
legal services' category for Fair Elections Legal Network.
However, based on your request, I had the Business Unit do a further query on the system. While they
didn't find any other certifications under this EIN for Fair Elections Legal Network, there were some other
borrowers who used 'Fair Elections Legal Network' in the employer name, but certified under a different
EIN that links to the New Venture Fund, a 501(c)(3) (there were a total of 10 borrowers). One borrower
also submitted a letter regarding the relationship, which I attached. The employer, New Venture Fund,
had not previously been escalated to Compliance.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
-r,w, i(b)(5) U(bj(5)

Io Fedloan PSLF <[email protected]>
c, "Battle, Cynthia" <Cynthia [email protected]>,"Foss, Ian" <[email protected]>
u.n, 011091201711:43AM
:C;LJtw-ad [external]Re: Re: Re: Fair Elections Legal Network
Hi Kim,
Can you tell me if the authorized official for the Fair Elections Legal Network ever submitted an
ECFas providing Public Interest Law Services. The ECFthat was attached for the borrower in
2015 is certified under Public Education.
Thanks,
Taneka

Sent: Monday, November 21, 2016 6:44:52 AM
To: l(b)(5) I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
-r,w1 i(b)(5) li(b)(5) I

c, "Battle, Cynthia" <Cynthia [email protected]>, "Tiongquico, Rene" <Rene Tiongquico@ed gov>
Da:c 10/07/2016 03:35 PM
SubIcct [external]Re- Re: Fair Elections Legal Network
Thanks Kim.

To: l(b)(5) I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

Cc l{b)(5) U(b)(5) l"T1onqqu1co. Rene" <Rene T1onqgu1co@ed gov>, "'Batlle, Cynthia" <Cynth1a.Battle@ed gov>
D:i:e 10/07/2016 01:09 PM
Hi Kim,
(b)(5)
Thanks,
Taneka

To: l(b)(5) I
Hi Taneka! This employer was last reviewed in March 2012 (during the beginning stages of our PSLF
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: l(b)(5)
Sent: 16 Apr 2014 13:51:00 +DODO
To: 'Fedloan PSLF'
Cc: l(b)(5J I
Subject: RE: Fairview Medical Group
Hi Diane,
lf"Fairvicw \1cdical Group" i~ an assumed name of"Fairvicw Health Services", then "f-airvicw Medical
Group" i~ not its own entity, it'~just a <lib/a name. However, I've been unable to tic the EIN to anything
relating to Fairview. So, I'd follow-up with the employer and ask for more information.
Ian
From: Diane Frcundcl [maiHo:dfrcundc:11.phcaa.orn]On BchalfOfFcdLoan PSLF
Sent: Sunday, March 23, 2014 8:21 PM
To:l(b)(5) I
Subject: Fairview Medical Group
Hi Ian, We're not sure about this one.
Employer certified 501 (c )(3 ).
Business filing shows it's an assumed name. The "name holder" is both Fairview Health Services and
Fairviev,· Clinics, both of which are non-profit
Fairview Health Service~ i~ 50\(c)(] ), but we couldn't locate Fairview Medical Group on ib Form 990.
We can't tell if the Medical Group is a part of the Health Service~, or if

it'~ independent. We abo had an [(T from f-airvicw Physician Associates
Network la~t year - a 50 1(c )(3) that had the ~amc addrc~~ a~ f-airvicw \1cdical Group. We couldn't find
Fairview Medical Group's EIN on this Fom1
990 either.
Can you assist? Pas~word to follow. Thanks
(Sec attached file: Fairview \1cdical Group.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax-(717) 720-391 I
[email protected]
From: l(b)(5)
Sent: 7 Feb 2017 20:17:40 +ODDO

To: Foss,Ian
Subject: Re: Family Adolescent Children and Therapy Services Inc
Thank you for escalating.
- Taneka
From: Foss, Tan

Sent: Tuesday, February 7, 2017 11:40: 16 AM
To: !(b)(51 I
Subject: RE: Family Adolescent Children and Therapy Services Inc
I suppose you're right and that this is closer than an outright denial. I'll go ahead and escalate.
From: IL.(b_l(_51
__ __,
Sent: Tuesday, January 31, 2017 5:39 PM
To: Foss, Ian
I can't locate Form 990 but they include the school-linked partnerships as a one of their
specialities.
FACTS 1s c1group of mentc1I health profess1011;,ls, r:imct1t1oners c1nd hehc,v1oml skills prov1ciers spec1;,l1z111q
1n work vv1th fam1l1es, couples 1nd1v1ciuc,ls c1nd ch1lcire11
We specialize in providing:
•
•
•
•
•
•
•
Instead of escalating I can request additional information regarding their school-based services.
The organization isn't very large and they appear to have a fair number of staff who provide
services in the school. Attached is the lawyer's letter. If you really believe they don't provide
qualifying services I am okay with sending a denial. - Taneka
From: IL.(b-'-l('--51
__ __,
Sent: Friday, January 27, 2017 12:06:48 PM
To: Foss,Ian
Subject: Fw: Family Adolescent Children and Therapy ServicesInc
Hi Ian,
This just came in today and I think we may want to escalate as qualifying under "Other School
Based" Services. The organization employs therapists which wouldn't qualify under public
health as Kim outlined below. On the ECF,the authorizing official checked Public Education and
Other-School based services. Attached is the research that Kim conducted - included is a letter
from the organization's lawyer.
I also went to the organization's website and focused on the School Linked services. There is not
much information (so I can request) but it looks like they have partnerships with a few
Independent School Districts (ISD) in Minnesota and have staff designated that serve the
mental health needs of those particular school districts.
The password is the same format with today's date.
https://www.facts-mn.org/services/school-linked-services
School Linked Services -

facts-mn.org
www.facts-mn.org
FACTS 1sa grnup of mental health

prnfess1onals, practit1orie1·s and behav101·al
skills pi-ovidc1·s spcciali1inq in 1.vork1.vith
families, couples, individuals, and children.
https://www.facts-mn.org/staff/staff-contacts/school-linkd-program/115-khristina-
hinnenkamp-lgsw
FACTS
www.facts-mn.org

skills pi-ovidc1·sspcciali1inq in 1.vork1.vith

Sent: Friday, January 27, 2017 11:11 AM
To: l(b)(5J I
Subject: Family Adolescent Children and Therapy Services Inc
Hi Taneka! I'm hoping this is an easy one for you, but wanted to send for formality sake.
We received this employer back in March 2016. At the time, Compliance denied the organization as they
are not-for-profit but do not perform a qualifying public service. They would fall under the SOC 21-1010,
which would not qualify for PSLF purposes.
In July 2016, the borrower submitted additional documentation, but the reason she was disputing the
denial was because she was told that the employer was denied as being for-profit (rather than not-for-
profit not providing a qualifying public service). Based on this, we asked the Business Unit to clarify with
the borrower that the reason for the denial was that the organization does not provide a qualifying public
service.
We now have an additional borrower who was denied and also submitted the same documentation as the
previous borrower. While we still don't believe they provide a qualifying public service, we wanted to
escalate.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: Foss,Ian
Sent: 30 Jan 2017 21:18:49 +0000
To: !(b)(5) I
Subject: RE:Family Adolescent Children and Therapy ServicesInc
From: l(bJ(5J I
To: Foss,Ian
Subject: Fw: Family AdolescentChildren and Therapy ServicesInc
Hi Ian,
This just came in today and I think we may want to escalate as qualifying under "Other School
Based" Services. The organization employs therapists which wouldn't qualify under public
health as Kim outlined below. On the ECF,the authorizing official checked Public Education and
Other-School based services. Attached is the research that Kim conducted - included is a letter
from the organization's lawyer.
I also went to the organization's website and focused on the School Linked services. There is not
much information (so I can request) but it looks like they have partnerships with a few
Independent School Districts (ISD) in Minnesota and have staff designated that serve the
mental health needs of those particular school districts.
The password is the same format with today's date.
https://www.facts-mn.org/services/school-linked-services
School Linked Services -

facts-mn.org
FACTS1sa grnup of mental health

skills pi-ovidc1·s spcciali1inq in 1.vork 1.vith
https://www.facts-mn.org/staff/staff-contacts/school-linkd-program/115-khristina-
hinnenkamp-lgsw
FACTS

skills pi-ovidc1·sspcciali1inq in 1.vork1.vith

To: l(b)(5J I
We received this employer back in March 2016. At the time, Compliance denied the organization as they
are not-for-profit but do not perform a qualifying public service. They would fall under the SOC 21-1010,
which would not qualify for PSLF purposes.
In July 2016, the borrower submitted additional documentation, but the reason she was disputing the
denial was because she was told that the employer was denied as being for-profit (rather than not-for-
profit not providing a qualifying public service). Based on this, we asked the Business Unit to clarify with
the borrower that the reason for the denial was that the organization does not provide a qualifying public
service.
We now have an additional borrower who was denied and also submitted the same documentation as the
previous borrower. While we still don't believe they provide a qualifying public service, we wanted to
escalate.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: l(b)(5)
Sent: 7 Feb 2017 20:27:42 +DODO

To: Fedloan PSLF
Cc: !(b)(5) I
Hi Kim,
Unfortunately, this one isn't going to be an easy one. We will be escalating this to OGC
for a determination.
Thanks,
Taneka

Sent: Frida , January 27, 2017 11: 11:43 AM
To: (b)(5)
We received this employer back in March 2016. At the time, Compliance denied the organization
as they are not-for-profit but do not perform a qualifying public service. They would fall under the
SOC 21-1010, which would not qualify for PSLF purposes.
In July 2016, the borrower submitted additional documentation, but the reason she was disputing
the denial was because she was told that the employer was denied as being for-profit (rather than
not-for-profit not providing a qualifying public service). Based on this, we asked the Business Unit
to clarify with the borrower that the reason for the denial was that the organization does not
provide a qualifying public service.
We now have an additional borrower who was denied and also submitted the same
documentation as the previous borrower. While we still don't believe they provide a qualifying
public service, we wanted to escalate.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: Foss, Ian

Sent: 13 Jun 2017 20:07:48 +0000
To: !(b)(5) I
Subject: Re: Federal Reserve Bank of New York - Escalated Dispute
Actually, I did more research and the federal reserve banks are for-profit
corporations. I don't know how or why I forgot this!
Take a look at section 4 and section 7 of the Federal Reserve Act. They issue
capital stock and distribute profits to shareholders ...
From: Ll(b_l(
__
51~~-'
Sent: Monday, June 12, 201717:16
To: FedLoan PSLF
51__
Cc: Odom, Christian; Battle, Cynthia: Foss, Tan: FedLoanProgramManagernent; Ll(b_l(_ _,
Subject: RE: Federal Reserve llank of New York - Escalated Dispute
Hi Kim,
That is correct, FSA has not received an official definition for "Emergency Management". As
such, FSAwill need to escalate this employer to OGCfor review since the borrower is disputing
Federal Reserve Bank's eligibility for PSLFand believe that it should qualify under "Emergency
Management". We will keep you posted.
Thanks,
Taneka

Sent: Monday, June 12, 2017 1:34 PM
To: l(bJ(5J I
Cc: Odom, Christian; Battle, Cynthia; Foss, Ian; FedLoanProgramManagement
Subject: Federal Reserve Bank of New York - Escalated Dispute
Hi Taneka! You had previously provided guidance on this employer, most recently responding to
a retraction request on 5/15/17, advising that they are not eligible for PSLF purposes. However,
we now received a highly escalated dispute regarding this employer. Due to the dispute, it is our
procedure to escalate to you.
This borrower originally submitted an ECF in May 2014 and certified under government.
Fedloan denied the ECF because the organization does not qualify. She is now disputing that
the Federal Reserve Bank of New York is not-for-profit and performs "emergency management"
services. I don't believe we ever officially received a definition of "emergency management" that
we could cite in a response letter to this borrower.
As always, your guidance is appreciated. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
This message contains privileged and confidential information intended for the
above addressees only. If you receive this message in error please delete or
destroy this message and/or attachments.
prosecution of any individual engaging in the unauthorized use of this message.
Code:PHEM
From: l(b)(5)
Sent: 14 Jun 2017 20:10:31 +ODDO
To: Fedloan PSLF
Cc: 5'-I___
Odom, Christian;Battle, Cynthia;Foss, Ll(b-'l'-( _,
Subject: RE: Federal Reserve Bank of New York - Escalated Dispute
Attachments: Federal Reserve Bank of New York_FinaI_20170614_Foss.docx
Hi Kim,
Ian quickly reviewed the letter and had the following edits. See attached (PII redacted).
Thanks,
Taneka

To: l(bJ(5J I
Cc: Odom, Christian; Battle, Cynthia; Fedloan PSLF; Foss, Ian
Hi Taneka! Attached is the letter that was drafted for this borrower. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
c::ro,'l l/b)/5) 11/b)/5) I

Cc "Odom Chnsl1an"' <Christian Odom@ed gov>, "Battle, Cynthia'" <Cynth1a.Battle@ed gov>, "Foss, Ian"' <Ian [email protected]>,
l{b)/5) U(b)(5) I
D:i:e 06/14/2017 09:00 AM
SubJect [external]RE: Federal Reserve Bank of New York - Escalated Dispute
H1Kim,
Ian was able to do additional research on the Federal Reserve Bank. The Federal Reserve Bank is a for-profit
corporation since it issues capital stock and distributes profits to shareholders. These details are outlined under
section 4 and section 7 of the Federal Reserve Act.
Based on these findings, Fedloan does not have to hold the denial of this borrower's dispute. In the denial letter
could you please reference the sections of the Federal Reserve Act listed above and forward a draft of the letter to
FSAto review before mailing out?
Thank you!
Taneka
From: 1(b_l(_5_1
0 --~
To: Fedloan PSLF
Cc: Odom, Christian; Battle, Cynthia; Foss, Ian; FedloanProgramManagement; 51
1(b_l(_
0
__ ~
Hi Kim,
(b)(5)
Thanks,
Taneka

To: l(bJ(5J I
Cc: Odom, Christian; Battle, Cynthia; Foss, Ian; FedLoanProgramManagement
Subject: Federal Reserve Bank of New York - Escalated Dispute
(b)(5)
This borrower originally submitted an ECF in May 2014 and certified under government. Fedloan denied
the ECF because the organization does not qualify. She is now disputing that the Federal Reserve Bank
of New York is not-for-profit and performs "emergency management" services. I don't believe we ever
officially received a definition of "emergency management" that we could cite in a response letter to this
borrower.
As always, your guidance is appreciated. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
f SERVICING
www.MyFedLoan.org
Phone: 1-800-699-2908 Fax: 717-720-1628
June 14,2017
[REDACTED]
[REDACTED]
[REDACTED]
RE: Your Student Loan Account
Dear [REDACTED]:
Thank you for your correspondence addressed to our President and Chief Executive Officer, Mr.
James Preston. Your correspondence was forwarded to my attention, and I am pleased for the
opportunity to address your concern about the loans we service for you on behalf of the U.S.
Department of Education (the Department).
Your request regarding your account, as we understand it, is for FedLoan Servicing to approve your
employer, the Federal Reserve Bank of New York, as a qualifying employer for the Public Service
Loan Forgiveness (PSLF) program based on vour understanding that the bank is a not-for-profit
organi;,at1on that provides emergencv management -;ervice-;.
After review of the documentation you provided and consultation with the Department, the
Department has concluded that the Federal Reserve Bank of New York is not a qualifying employer
for purposes of PSLF because. at a mimmum. it i-; not a not-for-profit organi ✓ at1on. Instead, -=l=-He---the
Department -IIBse4---i-1-s
deci~,ion Bfl--l-Re---H:l-€-1:hclicvcs
that the Federal Reserve Bank of New York is a
for-profit corporation tful-t--bccausc it issues capital stock and distributes profits to shareholders, as
outlined under Section 4 and Section 7 orthe Federal Reserve Act.
To be eligible for PSLF, you must be directly employed by a "public service organiLation" as defined
in the PSLF eligibility criteria statement provided with this letter. If you have additional questions
regarding PSLF, please refer to this information. If you have additional questions or wish to provide
additional documentation supporting the Federal Reserve Bank of New York's status as a qualifying
employer for the purposes of PSLF, Fedloan Servicing has assigned you an analyst to serve as a
direct point of contact:
Mary Kate Cowher - Consumer Relationship Analyst

FedLoan Servicing
P.O. Box 69184
Harrisburg, PA 17106-9184
(717) 720-2972
[email protected]
You may also monitor your account onlinc at MyFedLoan.org.
Sincerely,
Stephanie M. Martella

Page2
Senior Vice President, Loan Operations and Client Relations

04 6859 4706

Page2
ELIGIBLITY CRITERIA FOR PARTICIPATIO:"rl l:"rl THE PLBLIC SERVICE LOA:"rl

FORGIYEXF.SS PROGRA\1
You must have made 120 on-time. separate. monthly payments a/fa October I. 2007. on the Direct Loan
Program loans for which forgiveness is requested. Payments made prior to October 2. 2007 do not count
toward meeting this requirement. Each of the 120 monthly payments must be made for the full, scheduled
installment amount within 15 days of the due date.
The 120 n:quin:d paymrnb must be made undL:rone or more of thL:following Direct l.oan Program repayment
plans:
• Income-Based Repayment (IBR) Plan (not available for parent Direct PLUS Loans or Direct
Comolidation Loans that rL:paida parrnt Pl.US Loan)
• Income Contingent Repayment (ICR) Plan (not available rnr parent Direct PLUS Loans or Direct
• Pay As You Earn Repayment Plan (not available for parent Direct PLUS Loans or Direct
• Revised Pay As You Earn Repayment Plan (not available for parent Direct PLUS Loans or Direct
• Standard Repayment Plan with a I 0-year repayment period
• Any other Direct Loan Program rcpaymrnt plan; but only payments that aiT al kast c4ual to the
monthly payment amount that would have been re4uired under the Standard Repayment Plan with a
10-year repayment period may be counted toward the required 120 payments.
You must be employed full-time (in any position) by a public service organi/ation, nr must be serving in a full-
time /\mcriCorps or Peace Corps position at the time you make each qualil'ying payment. Organi/.ations that
med the definition of "public ~crv1cc organi1:ation" for purpo~cs of the PSI .r Program arL:listed bL:low.
• J\ government organi/.ation (including a federal, state. local or tribal organi/ation, agency. nr entity: a
pubhc child or family ~crvicL:agency: or a tribal colkgc or university):
(includes most not-for-profit private schools, colleges, and universities):
• A private. non-profit organization* (that is not a labor union or a pa11isan political organization) that
provides one nr more of the following puhlic services:
o Emergency management
o Military service
o Public safdy
o Law enforcement
o Public interest law services
o Early childhood education (including licensed or regulated health care, Head Start, and state-
o Public sL:rv1ccfor individuals with disabilities and the cldL:rly
o Public hL:alth(including nursL:~,nur~c practitioner~, nur~cs in a clm1cal sdting, and full-time
occupations)
o Public education
o Puhlic library services
o School library or other school-based services
*NOTF. For p111posesof rlwfull-rime requirement (Section 3. !rem 7 & fl o(rhe FCI'), _vourqualifring
emplo_vment does not include rime spent on job duties tlrat are related to religious i11srr11ctio11,
1rorship
service.1,or un.i·.fi;nn of'pro.1e~1·1i::i11g.

From: l(b)(5)
Sent: 14 Feb 2012 19:15:35 -0600
To: 'Fedloan PSLF'
Cc: Sipple-Asher, ~(b~l(~51~--------,Sandra;Foss, Ian
Subject: RE:Fresenius Medical Care
Confirming that this is a for-profit entity.
-----Original
Message-----
From: Sipplc-A~her, Bessie
Sent: Tue~day, February 14, 2012
11:22 A\1
To: l(b)(5) I
Fos~. Ian
Subject: RE: Fresenius Medical Care
agree this is a for-profit entity and does not qualify.
-----Original
Messas;e-----
From:f._bl_(5~1-~,-,
Sent: Tuesday, February 14, 2012 10:57
AM
To: Foss, Ian; Sipple-Asher, Bessie
Subject: FW: Fresenius Medical
Care
How about thi~ one?
From: Diane Frcundcl
rmailto:dfreundctn)aessucecs~.or<'l On Behalf Of FedLoan PSLF
Sent: Wednesday,
February 08, 2012 4: 16 PM
To:l(b)(5) I
Subject: Fre~enius Medical
Care
We believe this is a for profit entity and therefore not a qualifying

organization.
EIN - 00-04-3074770
It is traded on the NYSE under F\1S,

FMS/P and on the Frankfurt Stock Exchange as FME, FME3
We found some
indication that they are 36% owned by the German company Fresenius.
They
did not check box a, b, or c, but did check public health under box
C.
Thanks
Diane Frcundcl
Compliance Service~
(717) 720-3267
fax-(717)
720-3911
org
This message contain~ privileged and

confidential infonnation intended for the above addrc~~ees only. Ir you
attachments.

of this
message.
--------------------------------
From: l(b)(5)
Sent: 16 May 2016 21:12:53 +0000
To: Foss,l(b)(5J I
Subject: RE: Front St. Inc - PSLFdenial
Great. I'll just email Fedloan back to let them know we agree with their decision.
Thank you!
Taneka
From: Foss, Ian
To: l(bJ(5J I
Subject: Re: Front St. Inc - PSLFdenial
Yeah, I agree. I just emailed the borrower to tell her that she was denied because we found that
they \Vere for-profit, but that, if she had information to the contrary, that she could follow-up and
I'd \Valk her through \Vhat to provide and how.
51
On May 16, 2016, at 16:28, .._l(b_l(_
___ _,I<publicservice(d;ed.gov> wrote:
Hi Ian,
I don't think the borrower qualifies unless she can show that she is employed by the
county. I found an expenditure plan for the county of Santa Cruz and it makes reference to
Front St. as a community partner {pg. 26, 76). It seems like the county provides joint
services to individuals needing mental health services so I was trying to determine if the
county has employees who also work at these agencies? Is there anywhere else that you
can suggest I should look?
Taneka
__ ~
51
Cc: Battle, Cynthia; Fedloan PSLF; Foss, Ian; l.._(b_l(_
Subject: Re: Front St. Inc - PSLFdenial
Hi Taneka! It looks like this borrower submitted an ECF on two separate occasions in the
past (7/21/14 & 8/14/15). We originally denied this employer in August 2014.
I attached the information we found. From what we could determine, this organization is for-
profit and the reason we denied her employment.
We had a similar type situation in the past where the employer (Discovery Point Pre-Kand
Kids R Kids) was for-profit, but the borrower was disputing the denial as her job was funded
by the state of Georgia. We escalated this and Ian agreed that the employment wouldn't
qualify because, even though the organization received state funding, the organization itself
was for-profit.
Please let us know whether you agree or disagree. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
lrorn "Chialastri, Taneka" <[email protected]>

To Kimberly A Myers <[email protected]>, FedLoan PSLF <FedloanPSLF@piihea,,a,.oc'9s"~,.,-,------,
0
Cc "Foss, Ian" <[email protected]>, "Battle, Cynthia" <[email protected]>, !(b)(5) l!(b)(5)
IJc<if 05/1612016 12:20 PM
Sub.fct [extemal]Front St. Inc - PSLF denial
Hello Kim,
I'm having email issues today so my apologies if you are receiving this twice. FSA received an inquiry
from a borrower regarding the denial of her employer, Front St. Inc, as a qualifying organization for
the purposes of Public Service Loan Forgiveness. Based on the borrower's description it sounds like
her position may be funded by State/Federal funds and that the agency receives appropriations
from the county to support various business operations.
Can you pul I all relevant details regarding FedLoan's review of this organization? The borrower's
information is below.
Jennifer A. Gosk
[email protected]
Thanks,
Taneka
Taneka Chialastri I Management and Program Analyst, Business Operations I Federal Student Aid
Office: 202-377-4390 I [email protected]
above addressees only. If you receive this message in error please delete or destroy
this message and/or attachments.
The sender of this message will fully cooperate in the civil and criminal prosecution
of any individual engaging in the unauthorized use of this message.
Code:PHEAA
From: l(b)(5)
Sent: 16 May 2016 22:13:55 +0000
To: Fedloan PSLF
Cc: Battle, Cynthia;Foss, Ll(b-'l('-5'-I
___ _,
Subject: RE: Front St. Inc - PSLFdenial
Hi Kim,
FSA agrees with the decision that Fed Loan made regarding this organization. Ian already reached out to
the borrower to provide additional insight into why Front St. Inc. was denied.
Thank you,
Taneka
From: Kimberly A Myers [mailto:[email protected]] On Behalf Of fedloan PSLF
Cc: Battle, Cynthia; Fedloan PSLF; Foss, Ian; Ll(b_l(_51
__ _,
Subject: Re: front St. Inc - PSLF denial
Hi Taneka! It looks like this borrower submitted an ECF on two separate occasions in the past (7/21/14 &
8/14/15). We originally denied this employer in August 2014.
I attached the information we found. from what we could determine. this organization is for-profit and the
reason we denied her employment
We had a similar type situation in the past where the employer (Discovery Point Pre-Kand Kids R Kids)
was for-profit, but the borrower was disputing the denial as her job was funded by the state of Georgia.
We escalated this and Ian agreed that the employment wouldn't qualify because, even though the
organization received state funding, the organization itself was for-profit.
Please let us know whether you agree or disagree. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
~r~w1 "Chialastri. Taneka" <Taneka.Chialastri@ed gov>

T,1 Kimberly A Myers <kmyers@pheaa orq>, Fedloan PSLF <cFe~d~L~oa~c~P~S~LF=~h~e~aa~.o~;~>'-,==-----,
Cc "Foss, Ian" <Ian [email protected]>, "Battle, Cynthia" <Cynthia [email protected]>, b 5 !(b)(5)
Da:o 05/16/201612·20 PM
SubIoct [external]Front St Inc - PSLF denial
Hello Kim,
I'm having email issuestoday so my apologies if you are receiving this twice. FSAreceived an inquiry from a
borrower regarding the denial of her employer, Front St. Inc, as a qualifying organization for the purposes of Public
Service Loan Forgiveness.Based on the borrower's description it sounds like her position may be funded by
State/Federal funds and that the agency receives appropriations from the county to support various business
operations.
Can you pull a II relevant details regarding Fedloan's review of th is organization? The borrower's information is
below.
Jennifer A. Gosk
Jen [email protected]
Thanks,
Taneka
Office: 202-377-4390 I [email protected]
St .. r:,·nt
attachments.
Code:PHEAA

Sent: 22 Jan 2015 16:05:19 -0500
To: Foss, Ian
Cc: Battle, Cynthia;Chialastri, Taneka;[email protected]
Subject: Re: Fwd: University Medical Resident Services, PC
Attachments: pic09785.gif, pic21640.gif
Hi Ian, We asked the Business Unit to query the sy~tcm for this employer.
Two borrowers were sent a letter in December 2014 advising their accounts
were under review - they will be approved today. The others were all
approved. We can find no record of a denial other than the ones we denied
in 2012 and 2013 that prompted the escalation. If Mr. Maloney can provide
a name, we can search on the name. Thanh
Diane Frcundel
Compliance Service~
(717) 720-3267
fax-(717) 720-391 I
From:"Foss, Ian" <[email protected]>

To:"Diane heundel" <[email protected]>
Cc:"Chialastri, Taneka" <Taneka.Chialastri(~ied.gov>, "Battle,
Cynthia" <[email protected]>
Date:01/22/2015 02:35 PM
Subject:Fwd: University Medical Resident Services, PC
Hi Diane,
Can you help me undcr~tand what happened here?
Ian
Begin forwarded mes~age:
From: "Maloney, Christopher" <cmaloney(i1;buffalo.edu>

Date: January 22, 2015 at 13:24:28 EST
To: "Foss, Ian" <lan.Foss(?i)ed.gov>
Subject: RE: University Medical Resident Services, PC
Hello \1r. Foss,
I wanted to thank you again for your help with this process.
One of our resident employees recently submitted a PSLF application

to the DOE. She informed me that her application \vas denied because
UMRS does not appear on the list of approved employers. Are you able
to direct me to the appropriate pm1y to cn~urc we arc added to this
list
Thank you again.
Best,
Chri~
Chri~tophcr \1aloncy
Human Resource~ Assistant
O11iccof Graduate \1cdical Education
University at Buffalo
117 Cary !!all
3435 Main Street
Buffalo, NY 14214
T: (716) 829-5997
F: (716) 829-3999
[email protected]
horn: Foss, Ian [mailto:lan.Fossfli:ed.gov]

Sent: Wednesday, October 01, 2014 10:52 A\1
To: Lawrence M. Ross
Cc: Maloney, Christopher
Subject: RE: University Medical Resident Services, PC
Hello \1r Ross,
We have reviewed the documentation that you provided and agree that
Univcr~ity Medical Resident Service, PC i~ a qualifying employer for
the PSLF program became it i~ a not-for-profit organin1tion that,
while not tax-exempt under Section 50\(c)(]) of the Internal Revenue
Code, provide~ public health services.
The ol1icial proce~s by which the Department acknowledges that an

employer is a qualifying organization for the PSLF program 1~ through
the submission orthe Employment Certification for Public Service
Loan Forgiveness, available here. I recommend that you have employees
of the organization submit this fonn. In Section 3 of the fonn, take
care to select box "c" in Item 3, and to then indicate that U\1RS
provides "public health'. services.
Kind regards.
Ian Foss
horn: Lawrence M. Ross [mailto:l.\1R(d-hun,,;it7fine.com]

Sent: hiday, September 19. 2014 10:09 AM
To: Foss, Ian
Subject: University \1cdical Rc~idcnt Services, PC
Dear Mr. Fos~.

Thank you for taking the time yesterday to ~peak to me. A~ we
discu~~cd. I believe that Univcr~ity Medical Rc~idcnt Services, PC
(UMRS) i~ a qualifying public ~crvicc organization under 34 CPR
685.219 by virtue of the fact that the organiLational document~ for
UMRS demon~trate that it is a pnvate not for profit organization
that provides a public service. Attached to this email is the U\1RS

Certificate of Incorporation. as restated in 1992. To my knowledge,
the document has not been modified since this rc~tatcmcnt and remain~
in full force and effect.
Thi~ document should confirm U\1RS' eligibility a~ a qualifying
employer under the Public Service Loan Forgivcnc~~ Program.
Yesterday, you made reference to the corporate by-law~. Should you
need to ~cc the by-law~ a~ well, I will retrieve the corporate minute
book and forward them to you. llopefully thi~ is not necessary.
Aller your review of the certificate of incorporation, I ask
that you kindly conlim1 in writing UMRS' eligibility a~ a qualifying
employer under the Program. Thanking you in advance, I remain,
Respectfully yours,
Larry Ros~
(Embedded image moved to file: pic09785.gif)Hurwitz & rine,

r.c.
Lawrence M. Ross
\1cmbcr
Hurwitz & Fine, P.C.
1300 Libc11y Building ■
Buffalo, NY 14202
tel (716) 849-8900
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IMPORTANT: llmwitz & Fine, P.C. u~es spam fillers in it~

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BLJFr-ALO ALnANY AlnlON AMIIFRH LONG l~lAND NIAGARA FAllS PALM BF.A.Cl!GARDFNS TORONTO
From: Foss, Ian on behalf of Ll(b-'l('-5'-I

__ _,
Sent: 29 Jan 2014 09:44:16 -0500
To: Fedloan PSLF
Cc: l(bl(5l Ilan;Battle, Cynthia;Johnson, Debbe
Subject: Re: Genesee Education Consultant Services
Hi Diane,
It ~ounds to me like this organization directly employs the teachers, who

works in school~ who ~eek the ~crvicc~of the organization. In that ~cnsc
(and if that 1~ the case; I think we'd want to verify), then the
organiLation is akin to an educational service agency, and we think it
would qualify under the public education category.
Ian
On 1/2/14, 21: I 0, "Fed Loan PSLF" <[email protected]> 1Nrote:
>
>Hi Ian, This one is odd.
>
>On the ECF they checked both 501 (c)(3) and private non-profit.
>
>We could find no evidence of50l(c)(3) status.
>
>They are an employment agency, providing teachers among other types of
>employees. Their business filing and articles of incorporation state they
>are non-profit, but that they are organized on a stock basis and the total
>number of ~hare~ they have the authority to i~~uc i~ 100. How can a
>non-profit i~~uc ~tock?
>
>If they arc a private non-profit, would they qualify since they place
>teachers?
>
>Password to follow. Thanh!
>
>(Sec allachcd file: Genesee Education Consultant Services.Lip)
>
>Diane Freundcl
>(717) 720-3267
>fax- (717) 720-3911
>
From: l(b)(5)
Sent: 7 Jun 2012 11:42:34 -0500

Subject: RE: George Washington University Hospital
Diane,
For the rca~on~ that you have stated, this entity docs not qualify.
The hospital is owned by a limited partncr~hip that was created by GW
University and Univcr~al I lcalth Services, Inc. Parlncr~hips arc for -profit
enterprises by definition. Even ifwc could look past that which we could
maybe consider if all members in the partnership were not-for -profit
entities, UI IS has the ovcn.vhclming stake in the partnership at 80% and 1~ a
Fortune 500 company--it docs not get more for-profit than that.
In short, I
agree that this organization does not qualify.
Ian
> -----Original
Message-----
> From: Diane Freundel [mailto:dfreundefa'.pheaa.orgJ On Behalf Of
Fed Loan
> PSLF
> Sent: Wednesday. June 06, 2012 4:53 PM
>To:
l(b)(5)
> Subject: George Washington University Hospital
>
>
>Hi,
We didn't expect thi~ one lo be dil1icult. They checked private
non-profit
> but we could find no confim1ation of that status. We did find
that they arc
> jointly owned and operated by a partnership between George
Washington
> University and a subsidiary of Universal Health Services,
Inc.
> Under the terms of the partnership, named The District Hospital
Partners, LP,
> UHS holds an 80 percent interest and GWU holds 20 percent
interest.
> Business filings for UHS lead us to believe they are for profit;
therefore.
> we don't think GWU Hospital is a qualif)'ing organization. Do
you agree?
> Passv,rord to follow. Thanks
>
> (Sec attached file: George
Wa~hing Univcr~ity Hospital.zip)
>
> Diane Frcundcl

>
(717) 720-3267
> fax-(717) 720-3911
> This message
contain~ privileged and confidential information intended for
> the above
addre~~ees only. If you receive this message in error please
> delete or
destroy this me~~age and/or allachment~.
>
> The sender of this message
will fully cooperate in the civil and criminal
> prosecution of any
individual engaging in the unauthorized use of this
> message.
From: l(b)(5)
Sent: 24 Jun 2013 15:55:25 -0500

To: Fedloan PSLF
Cc: l(bl( 5l Ilan;Ninemire,
Sandra;Johnson, Debbe
Subject: Re: God is Greater Homeless Outreach Ministry
Hi Diane,
Thi~ one i~ highly ~uspicious. We should reject it for in~ufficicnt

evidence that the organin1tion qualific~. hut he prepared to a~k for and
evaluate additional information about the organiLation.
Ian
On 5/24/l 3, 15:32, "FedLoan PSLF" <FedLoanPSLF(d!pheaa.org> wrote:
, (b)(5)
>They are a private non-profit, but we're not sure if they provide a
>qualit)'ing service. They indicated they provide emergency management,
>public interest law services, public service for the disabled elderly, and
>other school-based services.
>
>According to their facebook page they minister the word of God to the
>homclc~~ and provide food and clothing, di~trihutc survival kit~,
>hackpacb, winter holiday kits, and provide referral ~crvicc~. Also
>indicates they plan to open a 24 hour ~helter.
>
>Articles of incorporation indicate they arc organized to provide ~crviccs
>to the homeless; to open a soup kitchen: to provide 24 hr emergency
>shelter~ and refc1rnl ~ervices, and lo distribute survival kit~.
>
> 1~t amendment to articles removed "to open a soup kitchen and lo provide
>services lo the homeless."
>
>2nd amendment to articles dated 05/07/2013 (a few weeks after the ECF was
>signed) added "emergency management services, public interest law
>services,
>public service for individuals with disabilities and the elderly, and
>school-based services" - sound familiar?'.'
>
>
>(See attached file: God is Greater Homeless Outreach Ministry.zip)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>d frcundc((j)phcaa.org

>
From: l(b)(5)
Sent: 10 Apr 2013 13:54:06 -0500

To: Fedloan PSLF
Cc: l(bl( 5l I
lan;Ninemire, Sandra;Sipple-Asher, Bessie;Johnson,
Debbe
Subject: Re: Greenpeace USA
Hi Diane,
A~ we've discu~~cd, these sorts of'\crvicc~" definitely do not fall

within the ~cope of "public education". I tried to fit them into the
legal services box, but, alter talking with others, the feeling 1~ that
organiLations who do "issuc-ba~cd law~uit~", or, who go find a plaintiff
lo sue to make a policy point arc not qualifying by themselves. Abo,
folks like Greenpeace contract oul such casework to attorneys that they do
not employ. This is unlike the ACLU, which hires and pays allomcys to
lake on indigent clients.
Ian
On 4/1/13 20:30, "FedLoan PSLF" <[email protected]> 1Nrote:
>Hi Ian, I'm not sure about this one. They are a 501 (c)(4) - on ECF they
>checked private non-profit that provides public education. I don't think
>]
>consider what they do as public education. but l"m not sure. Based on
>their \vebsite, they consider themselves to be an independent direct-action
>environmental organization. They "defend the natural world and promote
>peace by invc~tigating, exposing and confronting environmental abuse, and
>championing environmentally rcspon~iblc solutions."
>
>We appreciate your thoughts. Password to follow. Thanh!
>
>(Sec allachcd file: Greenpeace USA.Lip)
>
>Diane Freundcl
>(717) 720-3267
>fax- (717) 720-3911
>
From: l(b)(5)
Sent: 16 Sep 2013 14:47:48 -0500

To: Fedloan PSLF
Cc: l(bl( 5l I
lan;Johnson, Debbe;Ninemire, Sandra
Subject: Re: Greentree Community Learning Center
Hi Diane,
Thi~ organization doesn't qualify. The only catcgmy under which this
organin1tion could qualify is other ~chool-bascd services, and providing
space for early childhood education providers 1~ not ~chool-ba~ed
services. When talking about that tem1, we're thinking of service~
provided within a ~chool selling by third partie~. They primarily seem lo
relate to mental health and counseling services.
Ian
On 7/9/13, 15:41, "FedLoan PSLF" <[email protected]> 1Nrote:
>
>Hi Ian, We're unsure of this one.
>
> 1. They checked private non-profit providing other school-based services
>2. They are a 50 l(c)(4) and based on their Form 990 they provide lower
>income housing
>3. I found a website that indicates they provide Section 8 housing and
>they have a HUD inspection score
>4. They seem to be a part of the Housing Ministries of American Baptists
>in Wisconsin and their mi~~ion is to " ...provide affordable hou~ing and
>services to individuals who qualify for rc~idcncy in our development~."
>5. The only I could find regarding other school-based services is in the
>"info" and "options-" documcnb which indicate that the Greentree &
>Tcutonia Community Learning Center provides space for Head Start, day
>care,
>after-school programs, meal services, and senior activitie~ in a housing
>community.
>
>Another one where Kirn and I di~agree. I think they qualify, but I'm nol
>sure under which category. She doesn't think they qualify. Password to
>fol101N.Thanks!
>
>
>(See attached file: Greentree Community Leaming Center.zip)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>

From: l(b)(5)
Sent: 20 Aug 2015 18:03:27 +0000
To: Fedloan PSLF
Cc: Battle, Cynthia;Johnson, Ll(b-'l('-5'-I
____ __,
Subject: RE: Hammocks Community Association Inc
Hi Diane,
Co-employment relationship aside, we don't believe that Hammocks Community Association provides a
qualifying public service. For "public safety" we are looking at organizations that aid in disaster
prevention and relief.
The only other qualifying service that the community association could provide is "law enforcement". As
you know for the purposes of qualifying for PSLF,"law enforcement" "means service performed by an
employee of a public service organization that is publicly funded and whose principal activities pertain to
crime prevention ...". In Florida, to become a security officer individuals must be licensed by The
Department of Agriculture and Consumer Services; however, since the primary activities of Hammocks
Community Association primarily consist of providing maintenance and facility assistance to outdoor
common areas they would not qualify.
Thanks,
Taneka
From: l(b)(5J I
Sent: Tuesday, July 14, 2015 10:49 AM
To: Fedloan PSLF
Cc: l(b)(5J I Battle, Cynthia; Johnson, Debbe
Subject: RE: Hammocks Community Association Inc
Thanks Diane. We will start the review.
- Taneka
To: l(b)(5J I
Subject: Hammocks Community Association Inc
Hi Taneka, Here is another one we'd like your input on.
This organization is a homeowner's association. The ECFis certified as non-profit providing public safety,
as the borrower works in the security department. We requested W-2s because we wanted to confirm
that the borrower was actually a paid employee and not a volunteer, as their website indicates they
have volunteers. The borrower's 2014 W-2 and a pay stub from December 2014 show he is paid by
CoAdvantage Resources 40, Inc, which appears to be a Professional Employer Organization (PEO) and is
for profit.
The pay stub also reads Hammocks Community Association, Inc. along with CoAdvantage. In a previous
instance, a qualifying organization (a charter
school) that used a for-profit PEOfor payroll or HR purposes was approved because it was a co-
employment relationship.
Hammocks Community Assoc is not-for profit, but we cannot find any evidence of 501(c)(3) status.
Notwithstanding CoAdvantage's status, we cannot determine if this organization provides a qualifying
public service.
According to the association's website, their security department can be contacted for noise complaints,
suspicious behavior in the neighborhood, and parking issues. We think that if they do provide "public
safety", then they can be approved even though CoAdantage is for profit, as we believe it is a co-
employment relationship between the two.
As always, we appreciate your help. Password to follow. Thanks!
(See attached file: Hammocks Community Association Inc.zip)
Diane Freundel
Compliance Services
(717) 720-3267
[email protected]
Code:PHEAA
From: l(b)(5)
Sent: 12 Mar 2012 15:14:52 -0500

To: Fedloan PSLF
Cc: l(bl( 5l lNinemire, Sandra;Sipple-Asher, Bessie;Foss, lan;Johnson,
Debbe
Subject: Re: Healthcare Services Group - Avery Heights Churh Homes
I verified that the bonowcr is actually employed by Healthcare

Services
Group, Inc. by searching the EIN in Wcstlaw and then verified that
it is a
for-profit corporation by seeing that it is in the EDGAR database (I
only
made the connection because one orthe Wesllaw entrie~ associated with
the
employer\ EIN had EDGAR infom1ation).
It filed a 10-K fonn with the

SEC meaning that it is publicly traded.
It's SIK Number is 0000731012, if
you want to search for it.
On 12/3/12 12:41. "FedLoan PSLF"

<[email protected]> wrote:
>Another difficult health care employer.

I believe the borrower is
>actually
>employed by Healthcare Services Group
(for profit in Bensalem, PA), but
>they arc working at Avery Hcighb Church
Home~ (non-profit in CT).
>Although you can't sec the full window~ within
the lleallhcare Services web
>pages that I printed (allached), it shows that
they supply housekeeping
>and
>food ~ervices to health care facilitie~.
>I
think 1,veshould deny because I believe the employer is for profit. Do
>you
agree? Password to follow. Thanks.
>Additional research from Kirn:
Checked box Bon form.

>- Could not locate EIN on pub78 or Healthcare
Services Group or Avery
>Heights Church Home on BMF.
>- At first I couldn 1t
determine who the bonowcr 1s employer wa~. In
>googlc
>searching the EIN.
it does belong to Healthcare Services Group. However,

>the borrower resides
in CT. In reviewing the Healthcare Service~ Group
>the
>only thing I can
determine i~ that they arc a contractor working at Avcty
>Heights Church
Home.
>- I did research on both organizations lo ~cc if they qualify.
>- /\
Bu~incss Filings ~carch for Ilealthcarc Services Group wa~ found under
>both
PA and CT sites. The PA one wasn't beneficial and didn't indicate
>one
>way
or the other. The CT one however, did indicate business type
of
><Estock'.
>- In searching the Avery Heights Church Home's website, they
indicate they
>are a nonprofit corporation and their name is actually Church
Homes Inc.
>- On the HMF I found Church Homes Inc Congregational with the
same address
>but different EIN.
>- A Businc~~ Filing~ search for Church
Home~ Inc Congregational shows a
>name change - they were originally Church
Home~ Inc (in folder)
>
>(Sec attached file: Healthcare Service~ Group
Inc.zip)
>
>Diane Freundcl
>(717) 720-3267
>fax- (717)
720-3911
>=================================
>===
>This message contains privileged and
confidential information intended
>for the above addressees only. If
you
message
>
cngagmg
>in the unauthorized use of this
message.
>-------------------------------
From: l(b)(5)
Sent: 4 May 2017 15:09:58 +DODO

To: Fedloan PSLF
Cc: l(bl( 5l I
Subject: Re: Health Now New York Inc
Hi Kim,
Health Now New York Inc. can be retracted for not providing a PSLF qualifying service as
its primary purpose.
Thanks,
Taneka

Sent: Friday, April 21, 2017 12:00:18 PM
To;!(b)(51 I
Subject: HealthNow New York Inc
Hi Taneka!
We had previously approved this organization as private not-for-profit providing public health
services. They are a health plan, and we determined they employed qualifying individuals.
We recently received an ECF for this employer from another borrower. In light of the recent
guidance regarding health plans, we are escalating for review. We do not believe they would
qualify; therefore, we would need to potentially retract the prior approvals and deny this new ECF.
There are a total of 5 borrowers with employment approved on our system with the earliest
approval date of 10/1/07.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: l(b)(5)
Sent: 24 Feb 2012 12:30:39 -0600
Cc: Sipple-Asher, L(b~l(~51~--------~Sandra
Subject: RE: HeartShare of NY
Thanh for the due diligence on thi~ one, Diane. I agree this i~ affiliated
with the RC Diocese of Brooklyn.
The organization still qualifies, but

let's go ahead and hold il with all the other religiously af1iliated
organiLations until we instruct otherwise.

>
From: Diane Freundcl [rnaiHo:dfn::undc:,rn.:ssucccss.orgl On Behalf Of
> FedLoan
PSLF
> Sent: Friday, February 24, 2012 I: 16 PM
> To: l(b)(5) I
> Cc:
Sipple-Asher, Bessie; 'FedLoan PSLF'; Foss, Ian; .l(_bl_(5_1
__ ~1Ninemire,
Sandra
> Subject: RE: HeartShare of NY
>
> The name on the IRS HMF for the
ElN is Heartshare Human Services of New
> York RC Diocese of Brooklyn.
Also, sec the attached. Pas~word to follow.
> Thanh!
> ( Sec attached

file: Jkartshare-lluman-Servicc~-Of- 02 24 zip)
>
> Diane Freundcl
>
Compliance Service~
> (717) 720-3267
> fax-(717) 720-391 I
>
>
>
> 1------------>
> I From:
>
1------------>
>
>---------------------------------------------------------------------------
>
lrublic~crvicc Ll(~b)~(5~1
______ _,
>I
>
>---------------------------------------------------------------------------
>
1------------>
> I To: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
l"'FcdLoan PSLF'" <FcdLoanPSLF(d!phcaa.org>, .l(_bl_(5_1
__ ~
>
l(b)(5)
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
> I Cc: I
> 1------------>
>
> --------------------------------------------------------------------------
> ------------------------------------------1
>
l"Foss, Ian" <lan.Fo~~t~·cd.gov>, "Nincmirc, Sandra"
>
<Sandra.Nincmirc(a;'Cd.gov>. "Sipple-Asher, Bessie"
>
<BcssicKo.Sipplc/\shcr(d!c<l.gov>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
> I Date: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
102/23/2012 07:26 PM
>I
>
> --------------------------------------------------------------------------
> ------------------------------------------1
>
1--------->
> I Subject:
> 1------------>
>
> --------------------------------------------------------------------------
> ------------------------------------------1
> RE:
HcartSharc of NY
> I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
>
>
>
>
> Could you give me some more infonnation regarding hov., you associated
the
> organization with the Catholic Church'? I couldn't find any evidence
of that
> And, the organization has posted its latest IRS Form 990 on its
\vebsite
> (available here: www.heartshare.org/mediaipdf-990form09 I 0.pdt) on
which
> the legal name of the organization i~ HcartSharc Human Service~ of
New York
> and the [IN matchc~ the one that the borrower provided on the
ECF.
>
[mailto:dfrcundcrdacssL1Cc.:ss.urgl On Behalf Of
> FcdLoan PSLF
> Sent:
Thursdav, Fcbruarv 23, 2012 8:41 A\1
> To: l(b)(5) I
> Subject:
HeartShare of NY
>
>
> Good morning.
>
> This employer is a 501 (c)(3),
but it is associated with the Catholic Church.
> There is no indication of
this on their website. We \vouldn't have known
> except that the EIN i~ for
the Roman Catholic Diocc~c of Brooklyn.
> I thought it hc~t to run this one
by you. Please advi~c.
>
> Pas~word to follow. Thanks!
>
> (Sec attached
file: Foster_HeartShare of NY.zip)

>
> Diane Frcundcl
> Compliance
Services
> (717) 720-3267
> fax-(717) 720-3911
>
>
>
message in etTor please
attachments.
>
civil and criminal
> message.
>
--------------------------------
>
>
>
>
>
>
>

attachments.
>
civil and criminal
> message.
>
--------------------------------
>
From: l(b)(5)
Sent: 5 Sep 2012 09:45:14 -0500

Subject: RE: Henderson Behavioral Health
Diane,
This is another case of a wholly owned subsidiary of a not-for-profit qualifying based on the subsidiary
being a disregarded entity. In essence, a disregarded entity is one that is treated as being part of the
owner for tax purposes. The last time we encountered them, I was able to find the disregarded entity as
being listed in the parent organization's Form 990, Schedule R. This time, I could find no mention of the
LLCin Schedule R. I'll say LLCwhen I'm talking about the employer in question and organization when
I'm talking about the parent not-for-profit organization.
From reading more about disregarded entities, they should be reported in Schedule R if the organization
answers "yes" to question 33 on Form 990, Part IV, which reads: "Did the organization own 100% of an
entity disregarded as separate from the organization under Regulations sections 301.7701-2 and
301.7701-3? If 'Yes,' complete Schedule R, Part I." Here, the organization marked "no". So, there should
not be any disregarded entities listed. However, there is an entity in Schedule R. So, I saw a conflict, and
dug deeper.
Generally, an LLCwill be taxed (1) as a partnership if it has more than one member or (2) be taxed as
sole proprietorship if it has one member (and treated as a disregarded entity), unless it makes a specific
election to be treated as a corporation or association by filing IRS Form 8832. Because this LLChas one
member, it should be a disregarded entity unless it made a specific election under Form 8832, which is
something that we would not have access to.
Based on all of that, I thought that this organization has made an election to be taxed as a corporation
and thus not be a disregarded entity, that can then benefit from the organization's tax-exemption;
however, I did more searching and found an independent auditor's report filed with the State of Florida
for the 2009 tax year (prior to the name change). In the financial statement, the LLCis described as
being a disregarded entity (See Page 21). So, there is an unquestionable conflict between the Form 990
and the financial statement, but in light of the internal conflict in the organization's Form 990
(answering "no" to question 33 and still partially completing Schedule R), I'm inclined to think that the
organization made a mistake, and that the LLC is a disregarded entity--especially because the audited
financial statement is filed under the penalties of perjury.
Even if I'm wrong here, and the LLCshould not be a disregarded entity, I think that it could also qualify
as a not-for-profit LLC providing a public service. The Florida Code, Title XXXVI, Section 608.4261
requires that LLCs:
The profits and losses of the limited liability company shall be allocated among the members in
the manner provided in the articles of organization or the operating agreement. If the articles
of organization do not or the operating agreement does not provide for the a/location of profits
and losses among members, profits and losses shall be allocated on the basis of the agreed
value, as stated in the records of the limited liability company, of the contributions made by each
member to the extent such contributions have been received by the limited liability company and
have not been returned.
Here, the articles of organization provide that:
No part of the income or net earnings of the Company shall inure to the benefit of, or be
distributable to, and Director or officers of the Company or Henderson or any other private
individual.[. ..] No part of the assets of the company shall inure to the benefit of or be
distributable to any organization whose income or net earnings or any part thereof inure to the
benefit of any private shareholder{ ...}
Because this language tracks the language required of Florida not-for-profit corporations in Title XXXVI,
Sections 617.0505, 617.1301, the LLChas effectively made itself a not-for-profit organization by
organizing in a way that prohibits it from taking profits.
In short, I would approve this as a 501(c)(3) organization.
Ian
To: l(b)(5J I
Subject: Henderson Behavioral Health
(b)(5)
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
[email protected]
engaging in the unauthorized use ofthis message.
From: l(b)(5)
Sent: 23 Feb 2012 17:55:40 -0600

To: 'Fedloan l(bl( 5l I
Subject: RE: Highland Hospital and University of Rochester
Became of the [IN conflict, I think we need to deny thi~ one (or at least
rcquc~t more infonnation from the borrower or employer) because we don't
genuinely know who the employer i~.
The employer's address is that of

Strong \1emorial Ilospital, the teaching hospital that is part of the
University of Rochester Medical Center. Given that thi~ 1~ a leaching
hospital that 1~ part of the medical school, I would expect that the Medical
Center is not separately organiLed from the University, itself. I would
expect this to be different from the relationship between the University's
Medical Center and an affiliate hospital, such as Highland Hospital, the
borrower's previous employer.
However, I can't prove a negative, and, like

you, I can only find entries in the Business \faster File for the University
of Rochester. I also could not find any literature on the medical center
(or the university's website) indicating that it operates on a
not-for-profit basis. The annual reports at the medical center's website
\Vere of very little help.
That all being said, in the "giving" section of

the websites, it does not state that the donations are tax deductible, which
casb doubt~ on their being organized under the 501 (c)(3).
Sec abo:
www. unnc. roe hcstcr .cdu/ncw~ipub Iica tions/roc hc~tcr-mcd ic inc iwi ntcr -20 11,..phi1
anthropyiloan-q-a.cfm. While ohviou~ly not determinative they say that
they qualify.
[mailto:d!'reunde(daessltCc.:ss.urgl On BchalfOf FedLoan PSLF
Sent: Wednesday,
Februar, 22, 2012 10:48 P\1
To: (b)(5)
Subject: Highland Hospital and
University of Rochester
I put these together because they are for the same

borrower and I'm a bit confused by them.
There is an ECr from Highland

Hospital of Rochester from 01/01/2000 to
05/02/2006 with box c checked.
It's a 501(c)(3), but the employment i~ not qualifying because it's prior to
Oct 2007.
She also submitted an ECF from University of Rochester from

05/02/2006 to
02/08/2012 al~o with box c checked. It has the ~amc EIN as
Highland Ho~pital and the certifying official is the same. Highland Ho~p is
affiliated with the Univcr~ity of Rochc~tcr Medical Center. The Univcr~ity
of Rochester is on the IRS BMF with a different EIN and address.
I think
Univ of Rochester \1edical Center is qualifying a~ a private non-profit, but
I'm confused on the use of the EIN for llighland I losp of Rochester which is
the 50l(c)(3).
Password lo follow. Thanks!
(See attached file: Sweet Univ

of Rochester.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax-
(717)
720-3911
[email protected]
--------------------------------

receive thi~ mc~~agc in error plca~e delete or dc~troy this message and/or
attachmcnb.

of this
message.
From: l(b)(5)
Sent: 9 Jan 201718:14:54 +0000
To: Fedloan PSLF
Cc: 5'-I_____
Battle, Cynthia;Foss, lan;Odom, Ll(b-'l('- _,
Subject: Re: High mark Inc.
Hi Kim,
FSA reviewed this organization and did not uncover any additional research that would
indicate that the organization qualifies for PSLFunder Public Health Services.
Thanks,
Taneka
From: Kimberly A Myers <kmyers(q:;phcaa.org> on behalf of FedLoan PSLF

<[email protected]>
Sent: Wednesday, January 4, 2017 8:54:25 AM
To: !(b)(51 I
Subject: Highmark Inc.
Hi Taneka! I don't believe we ever escalated Highmark Inc in the past.
For this particular borrower we received an ECF in November 2016. From the organizational
chart we located, the EIN provided ties to the not-for-profit (non-501 (c)(3)), and therefore would
have to provide a qualifying public service. We had made a decision internally based on
guidance we previously received for other health insurance companies. We reviewed the
organization's job categories and determined they did not directly provide public health (e.g.
practicing registered nurses).
This borrower has now provided additional documentation.
Although we don't believe the additional documentation provides any further evidence of the
qualifying status of the organization, we wanted to forward this on in light of the recent inquiries
regarding certain not-for-profit organizations.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: l(b)(5)
Sent: 2 Mar 2012 09:15:28 -0600

Cc: Sipple-Asher, Bessie;Ninemire, Sandra;Foss,
lan;Johnson, Debbe
Subject: RE: Hope Academy Charter School
Diane,
Charter schools are public schools that operate independently of the SEA or
LEA regardless of who charters them. If the borrower is actually employed by
the charter school, then their employment is qualifying under the government
category. If the borrower is employed by the chartering organization (which I
would think is unlikely), then the chartering organization must independently
qualify.
1
1 11give you a lot of excerpts from the New Jersey law, which are very
representative of the various laws across the US.
See New Jersey Charter School Program Act, Section 18A:36A-4 {available
here: http://www.nj.gov/education/chartsch/cspa95.htm) for more no how
charter schools are established in New Jersey.
A charter school may be established by teaching staff members,
parents with children attending the schools of the district, or a
combination of teaching staff members and parents. A charter school
may also be established by an institution of higher education or a
private entity located within the State in conjunction with teaching
staff members and parents of children attending the schools of the
district. If the charter school is established by a private entity,
representatives of the private entity shall not constitute a majority of
the trustees of the school, and the charter shall specify the extent to
which the private entity shall be involved in the operation ofthe
school. The name of the charter school shall not include the name or
identification of the private entity, and the private entity shall not
realize a net profit from its operation of a charter school. A private or
parochial school shall not be eligible for charter school status.
I would note that, while a private, for-profit entity could conceivably petition
that a charter school be created, the charter school itself is required to be not-
for-profit. And, I think most states would be disinclined to approve a charter
school that is operated by a for-profit entity. But, like I said, who charters
them is irrelevant.
See also Section 18A:36A-6:
A charter school established pursuant to the provisions of this act shall
be a body corporate and politic with all powers necessary or desirable
for carrying out its charter program, including, but not limited to [5]
Body corporate, above, means that the entity has its own legal personality,
and may therefore sue or be sued, enter into contracts, etc. Body politic,
above, means that it is part of the state.
And finally, see Section 18A:36A-11:
a. A charter school shall operate in accordance with its charter and the
provisions of law and regulation which govern other public schools:
except that. upon the request of the board of trustees ofa charter
school, the commissioner may exempt the school from State
regulations concerning public schools, except those pertaining to
assessment, testing, civil rights and student health and safety, if the
board of trustees satisfactorily demonstrates to the commissioner that
the exemption will advance the educational goals and objectives of the
school.
b. A charter school shall comply with the provisions of chapter 46 of

Title 18A of the New Jersey Statutes concerning the provision of
services to handicapped students: except that the fiscal responsibility
for any student currently enrolled in or determined to require a private
day or residential school shall remain with the district of residence.
c. A charter school shall comply with applicable State and federal anti-
discrimination statutes.
Depending on the state, the employees of the charter school may be paid by
the State, the LEA, or the charter school (but using a mix of state, local, or
private funds). But regardless, it 7 s all government.
This is a very long way of saying that this qualifies. I rambled for so long to give
you a lot of background on charter schools.
Ian
> Fedloan PSLF
> Sent: Thursday, March 01, 2012 11:42 PM
> To: l(b)(5) I
> Subject: Hope Academy Charter School
>
>
> Hi, I don't have a very good understanding of charter schools. They checked
> private non-profit. There isn't anything definitive on their website. A wiki
> article on charter schools indicates they are part of the public education
> system and can be chartered by a local school district or
> non-profits, universities, or government entities. Would they always be a
> non-profit or could they be government or even for profit?
>
> They also didn't provide an EIN - we'll try to call to obtain. If no success, we'll
> deny for no EIN.
>
> Any pointers on determining the status of charter schools?
>
> password to follow. Thanks!
>
> (See attached file: Hope Academy Charter School.zip)
>
> Diane Freundel

> (717) 720-3267
> fax- (717) 720-3911
> [email protected]
>==========================================================
>====================
>
> message.
>==========================================================
>====================
From: l(b)(5)
Sent: 12 Mar 2012 14:52:12 -0500
To: Fedloan PSLF
Cc: 51'--------'1
Ll(b-'l('- Sandra;Sipple-Asher, Bessie;Johnson,
Debbe;Foss, Ian
Subject: Re: Housing Authority of City of Tampa
Thi~ i~ a hona fide qua~i-govcrnmcntal organization. I found

relevant
~tatutc, creating the various hou~ing authoritic~ at the ~tatc
level as a
"hody coq1oratc and politic." Sec Flmida Code Sec. 421.04.
Sec
here:
http://www.lc!!.stak.11.u~,\lalutcsiindcx.clin?App modc=Displav Statutc&Scar
ch_ String=& URL =0400-0499/0421 /Scction~/0421.04.html
I also searched for

the entity in Westlaw by EIN (I recently learned that
1,vehave a flat fee
structure, so I can search my heart out), 1Nhichis tied
to the Tampa Housing
Development Corporation. Inc., which you found in the
state corporations
database as a not-for-profit organization.
That makes sense, since rlorida

Code Sec. 421.09 require~ them to he
operated on a not-for-profit
basis.
On 12/3, 12 11: 15. "FcdLoan PSLF" <FcdLoanPSLF(j_i;phcaa.org>

wrote:
>
>Iii everyone, We're struggling with this one.
>
>They checked
the government box. I couldn't find anything on the FL
>state
>or Tampa
city website. A search of the FL corporations website brought up
>several
related entities 1,viththe same address (info attached). The Tampa
>Housing
Authority Development Corp is a non-profit. The only EIN I could
>find that
matches the EIN on the ECr is for the Palm Terrace Assisted
>Living Facility
and Adult Daycare Center (fictitiom name filing for Tampa
>Housing
Authority included in attachment). On the fictitious name filing
>document,
there is a note that Tampa Housing Authority is a "quasa

>Government
agency". b this employer quasi-government? Password to
>follow.
Thanh!
>
>(Sec attached file: Tampa Homing Authority.zip)
>
>Diane
Freundcl
>(717) 720-3267
>fax- (717)
720-3911
>=================================
>===
>This message contains privileged and
you
message
>
cngagmg
>in the unauthorized me ofthi~
message.
>================================================
>===
From: Foss, Ian

Sent: 28 Dec 2016 16:48:52 +DODO
To: !(b)(5) I
Subject: Re: Human Rights Campaign
Exactly. The lack of definitions in particular is why we are going to get so many disputes.
51___
On Dec 28, 2016, at 11:47,L!(b_l(_ 5_1
,c!!(_bl_(
______ _,!wrote:
(b)(5)
From: Foss. Ian

Sent: Wednesda,. December 28. 2016 10:40:36 AM
To: l(b)(5J -
No worries. I'm using these as a test case to press people to further define
what various undefined public services mean. I highly doubt this qualifies
too.
(b)(5)
51__
On Dec 28, 2016, at 11:36,L!(b_l(_ 51
~1,.it_bl_(
______ ~lwrote:
LOL. I just emailed you too. Disregard thanks for escalating.
From: Foss, Ian

Sent: Wednesday, December 28, 201610:35:58 AM
To:!(b)(51 I
Escalating to OPE and OGC.
51
On Dec 28, 2016, at 10:06, !(bl(
l(b)(5J lwLro-,e-,--~
Thanks Kim. We will review on this end.
Happy New Year!
Taneka
From: Kimberly A Myers <kmvers((/)pheaa.org> on

behalf of FedLoan PSLF <FedLoanPSLF((i,,pheaa.org>
Sent: Thursday, December 22, 2016 7:45 AM
To: !(b)(51 I
Subject: Human Rights Campaign
Hi Taneka!
We received an ECF for this organization in late 2013. At

that time, we denied the organization. Although they are
not-for-profit (they are a 501(c)(4)), they do not provide a
We now received an ECF from another borrower along

with a letter outlining the functions of his role within the
organization. He is requesting reconsideration of the
organization. Although the letter does not provide further
evidence that the organization is qualifying for PSLF
purposes, we wanted to escalate due to the request for
reconsideration.
As always. your guidance is appreciated. Also. if I don't

talk to you before. I hope you have a wonderful holiday!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
This message contains privileged and confidential

information intended for the above addressees
delete or destroy this message and/or
attachments.
The sender of this message will fully cooperate in

the civil and criminal prosecution of any individual
Code:PHEAA

__ _,
Sent: 29 Jan 2014 10:53:46 -0500
To: Fedloan PSLF
Cc: l(bl(5l Ilan;Battle, Cynthia;Johnson, Debbe
Subject: Re: ldyllwild Fire Protection District
Hi Diane,
I agree that this one i~ quasi-governmental. The di~trict i~ subject to

the California Public Record~ Act, which could only be the case if it were
considered a 'state agency' or 'local agency". They arc also required lo
submit a 'local government compensation report" to the State Comptroller's
of1icc and undergo annual audits a~ a government agency.
Ian
>
>Hi Ian, We're having difficulties with this one.
>
>ECF certified as private non-profit providing public safety.
>
>WikiDirectories indicates they are government.
>
>According to Hizapedia, the ldyllwild rire Protection District Auxiliary
>is
>for profit.
>
>Based on the organizational Chart (Contacts attachment) - the Fire Chief
>reports to the Elected Board of Commissioners, who in tum "report" to the
>public.
>
>There 1~ a cooperative agreement between the ldyllwild Fire Protection
>District, a special di~trict, and the county of Riverside, CA. The County
>will provide the District with fire depai1ment dispatch and communication
>services and the District will provide the County with pern1i~~ionto use
>the Di~trict FCC licensed radio frequency.
>
>I think they may be quasi-government. Can you assist? Password to
>follo,N. thanks!
>
>(See attached file: Idyllwild Fire Protection District.zip)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>

From: l(b)(5)
Sent: 19 Jun 2017 14:55:11 +0000
To: Fedloan PSLF
Cc: 51'------'
Odom, Christian;Battle, Cynthia;Foss, Ll(b-'l('-
Subject: Re: Imagine Schools - Update
Hi Kim,
Thanks for the clarification.
I don't see any documents in the zip file attachment for Hillcrest Academy. Could you
reattach and send it?
For Sullivant Avenue Community - Thanks for pointing the issue with the Form 990. I
reviewed the full Form 990 again and it is sufficient in outlining the management
agreement that the school has with Imagine Schools. We will hold the decision on this
pending the Imagine Schools ruling date.
Thanks,
Taneka

Sent: Monday, June 19, 2017 7:53 AM
To;!(b)(51 I
Cc: Odom, Christian; Battle. Cynthia; Fedloan PSLF; Foss, Ian
Subject: Re: Imagine Schools - Update
Hi Taneka! I just want to clarify on some things you outlined below and confirm the actions you
want us to take. However, I also wanted to let you know I reached out to the BU to request the
additional information on Imagine Schools under Delaware law.
For Hillcrest Academy, it appears the Business Unit pulled the incorrect ECF to be reviewed. This
borrower submitted two ECFs at the same time. One for Destiny Community Schools with
employment until 10/31/11 and one for Imagine Schools under their EIN from 11/21/11 to 7/20/12.
I could go back as far as 2013 in viewing Destiny Community School's Form 990, but it does state
0 employees on the form 990 of the 501 (c)(3) EIN that was certified on the ECF that was
forwarded over for your review. Perhaps Imagine Schools started managing Hillcrest Academy in
2011. I could have the BU reach out for additional information; however, not sure how much they
could get because of the organization now being dissolved. I attached the other ECF and will
send the password separately.
For Sullivant Avenue Community School. The EIN provided on the ECF does tie directly to the
501(c)(3) organization; however, the Form 990 showed zero employees, so we requested W-2s.
The W-2 indicates the borrower is employed by Imagine Schools under their EIN , and not the
501 (c)(3) EIN that was provided on the ECF. I believe I also included the W-2 in the original
documentation I sent you, but if not, please let me know and I will send that over to you. I think
the decision on this school is dependent on what Imagine Schools comes back with regarding the
ruling date of their 501(c)(3) exemption.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From l/bl/51 I
To Fedloan PSLF
Cc l{b)(5) I, "Battle, Cynthia", "Foss, Ian", "Odom, Christian"
IJc<if 06/151201711:11 AM
Sub.fct [external]lmagine Schools - Update
Hi Kim,
We previously requested that the Business Unit request documentation of the date
when Imagine Schools became tax-exempt through the IRS. My apologies for the back
and forth on this but could you to the Business Unit to also request documentation of
when the organization became exempt under Delaware law.
There are a couple of schools that were included in the Imagine Schools review (listed
below) that we would like to provide updates for:
Hillcrest Academy (aka - Destiny Community School). This organization is now dissolved.
Please reinstate any decisions for borrowers who were previously denied up until the
date when the organization was dissolved (12/15/2016). This organization was included
in the zip file sent to FSAon April 10, 2017.
Sullivant Avenue Community School -The EIN reported for this organization links
directly to the school which is organized as a 501(c)(3). We are still holding retractions
for all organizations but wanted to provide an update on this organization since these
borrowers would be eligible for PSLF.The ruling date for the organization's exempt
status is listed as 2010. We could not locate and exact date; therefore, the Business Unit
would need to request documentation from the employer for the month/day of the
ruling date if there are borrowers certifying employment in 2010.
If you have any questions, please let me know.
Thanks,
Taneka
Code:PHEAA
From: l(b)(5)
Sent: 25 Jun 2015 15:18:30 +0000

To: Fedloan PSLF
Cc: l(b)(5J ICynthia;Johnson, Debbe
Subject: RE: Improved Dwellings for Altoona
Hi Diane,
We do not think Improved Dwellings for Altoona qualifies. The rca~on that Ian provided for To~homingo i~
~till relevant. However, I would add that since the primary mission of Improved Dwellings docs not
mention providing low cost hou~ing lo the di~abled and elderly (since they do thi~ on a limited basis) and
the majority of building~ that they manage and/or owe do not serve this purpose they do nol qualify.
Thanh.
Taneka
From: Diane Freundel Lmailto:dfreunde:11-phean.or!!.I
On BehnlfOfFedLoan PSLF
Sent: Tuesday, Mny 26, 2015 3: 17 PM
To: l(b)(5) I
Subject: Improved Dwellings for Altoona
Hi Taneka, We previously denied this employer for not providing a

qualifying public service. The borrower has disputed our decision, so we're sending it to you to ensure that
you agree.
[CF certified a~ private non-profit providing public services to the di~abled and elderly.
Organization is a 501 (c)( 4) that provides administrative ~crviccs to low co~t hou~ing organization~
(according to the Form 990).
We based our initial denial in part on Ian's response on a similar organiLation - Tishomingo Apartments,
Inc (copy of email included in zip file).
In the dispute the employer slates that the building the borrower manage~ 1~ for the di~abled and elderly.
We still believe that the employer docs not provide a qualifying public ~crvicc. Please let us know your
thoughts.
Pnssvmrd to follow. Thnnks!
(See attached file: Improved Dwellings for Altoona.zip)
Diane Freundel
Compliance Services
(717) 720-3267
[email protected]
From: l(b)(5)
Sent: 13 Apr 2017 20:56:13 +DODO

To: Foss, Ian
Subject: Re: In Home Supportive Services
(b)(5)
I'll update Kim and let her know that we are consulting with OGC.
Thanks,
Taneka
From: Foss, Ian

Sent: Thursday, April 13. 2017 3:20:15 PM
To,!(b)(51 I
Subject: Re: In l lomc Supportive Services
(b)(5)
From:_Ll(b_l(
__
51~-,-'
Sent:Thursday,April 13,201715:40
To: Foss, Ian
(b)(5)
From: Foss, Ian

Sent: Thursday, April 13, 2017 2:34:55 PM
To: !(b)(51 I
(b)(5)
From:,Ll(b_l(_51,-....,.~
Sent: Tuesday, April 11, 2017 12:38: 19 PM
To: Foss, Ian
Subject: RE: In l lomc Supportive Services
Hi Ian
(b)(5)
Taneka

Sent: Tuesday, April 11, 2017 9:08 AM
To: !(bl(51 I
Thanks Taneka!
I just wanted to bring one more thing to your attention before we reach out to the IHSS borrowers.
We have received at least one W-2 from a borrower who is providing the IHSS services. On the
W-2 the person receiving the services is actually listed as the employer with no indication they
are employed through IHSS (see the attached W-2 -password will follow). This is probably the
reason the borrowers are going to the person receiving services for the certification.
Based on the structure of this organization. I would assume the IHSS would have record of the
borrower's employment and hours worked. It appears that each county might have its own IHSS
office. Do you think it would be beneficial to direct the borrower to the IHSS office in the county
they work?
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
lrorn i(b)(5) li(b)(5) I

Cc ""Odom, Christian· <Christian Odorn@ed gov> "Battle, Cynthia"' <[email protected]>. "Foss, Ian··
<[email protected]>. !(b)(5)
LJc1lH 04/11/2017 08:39 AM
U(b)(5) I
Suh Hci [external]RE: In Home Supportive Services
Hi Kim,
We were talking internally and agreed that Fedloan should have accurate ECFson file for borrowers who
will now qualify for PSLFas employees of IHSS.Could FedLoan reach out to the borrowers were the
recipient of services signed their ECFform and request that the borrower resubmit an ECFand have an
authorized official sign their form. My apologies for any confusion.
We briefly discussed IRISwhile reviewing IHSSand understood IRIS, which I think is located in Wisconsin,
to be structured differently than IHSS(California}. We'll look more closely at IRISand will let you know.
IRISwas reviewed prior to my joining FSAso I'll need to familiarize myself with the organization. We still
have the files. I'll you know 1fwe need anything additional.
Thanks,
Taneka

__ ~
Cc: Odom, Christian; Battle, Cynthia; Fedloan PSLF; Foss, Ian; l~(b_l(~51
Hi Taneka! Thank you for the follow-up on this one. So, we will go ahead and approve the ones
we have already received under IHSS; however, moving forward, if we would happen to receive
an ECF for IHSS, we will do a soft denial and request that an authorized official from IHSS sign
the ECF form.
I do have a quick question regarding the employer that stemmed the basis for our decisions on
this one. We had previously had an employer (IRIS/Tatyana Zuykaua) that we had escalated. It
was determined that they person providing the services was the employer. They are paid through
a fiscal agent (MCFI). From our research we found that MCFI Fiscal Agent services are available
to county agencies and consumers receiving government funding. Should the employment for
these borrowers also be reconsidered? I'm not sure if you still have the information on this
employer. We had escalated it back on 8/7/14. If you need me to resend any information, please
let me know. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
lrorn "Ch1alastri, Taneka" <[email protected]>

Cc !(b)(5) U(b)(5) !"Battle, Cynthia" <[email protected]>. "Foss, Ian" <[email protected]>,
"Odom. Christian" <[email protected]>
LJc1lH 04/10/2017 04:34 PM
Suh Hci [external]ln Home Supportive Services
Hi Kim,
After researching In Home Supportive Services (IHSS)we discovered that the organization is structured so
that borrowers are employees of the county. As a result these borrowers should be eligible for Public
Service Loan Forgiveness. The majority of the ECFsthat were forwarded to us for review were signed by
the recipient of IHSSservices. In the future, the borrowers should have an authorized official from IHSS
sign their ECFform.
IHSSProvider Information
Fair Labor Standards Act Information Corner
Provider Eligibility and Orientation Information
Please let me know if you have any concerns with this decision.
Thanks,
Taneka
Office: 202-377-4390 I Cell 202-256-7842 I [email protected]
St .. r:,·nt
and/or attachments.
Code:PHEAA
From: l(b)(5)
Sent: 13 Apr 2017 21:04:46 +DODO

To: Fedloan PSLF
Cc: Odom, Christian;Battle, Cynthia;Foss, 51'------'
Ll(b-'l('-
(b)(5)
I'll let you know when we have a final determination.
Thanks,
Taneka
From: Kimberly A Myers on behalfofFedLoan PSLF

Sent: Tuesday, April 11, 2017 8:08: 18 AM
To: !(b)(51 I
Cc: Odom, Christian; Battle, Cynthia: FedLoan PSLF: Foss, Ian
Thanks Taneka!
(b)(5)
I
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
f-rrnn !(b)(5) I
To Fedloan PSLF
Cc "Odom, Christian", "Battle, Cynthia", "Foss, Ian", !(b)/5)
D,itr, 04/11/201708:39AM ""'""---'
Sub,r,ct [extemal]RE· In Home Supportive Services
Hi Kim
(b)(5)
Thanks,
Taneka

5_1__
Cc: Odom, Christian; Battle, Cynthia; Fedloan PSLF; Foss, Ian; IL(b_l(_ _,
Hi Taneka! Thank you for the follow-up on this one. So, we will go ahead and approve the ones
we have already received under IHSS; however, moving foiward, if we would happen to receive
an ECF for IHSS, we will do a soft denial and request that an authorized official from IHSS sign
the ECF form.
I do have a quick question regarding the employer that stemmed the basis for our decisions on
this one. We had previously had an employer (IRIS/Tatyana Zuykaua) that we had escalated. It
was determined that they person providing the services was the employer. They are paid through
a fiscal agent (MCFI). From our research we found that MCFI Fiscal Agent services are available
to county agencies and consumers receiving government funding. Should the employment for
these borrowers also be reconsidered? I'm not sure if you still have the information on this
employer. We had escalated it back on 8/7/14. If you need me to resend any information, please
let me know. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
f-rrnn "Chialastri, Taneka" <Taneka [email protected]>

Cc l{b)(5) U(b)(5) I."Battle, Cynthia" <Cynthia.Battle@ed gov>, "Foss, Ian" <Ian [email protected]>, "Odom,
Christian" <[email protected]>
D,itr, 04/10/2017 04:34 PM
Sub,r,ct [extemal]ln Home Supportive Services
Hi Kim,
After researching In Home Supportive Services (IHSS)we discovered that the organization is structured so
that borrowers are employees of the county. As a result these borrowers should be eligible for Public
Service Loan Forgiveness. The majority of the ECFsthat were forwarded to us for review were signed by
the recipient of IHSSservices. In the future, the borrowers should have an authorized official from IHSS
sign their ECFform.
IHSSProvider Information
Fair Labor Standards Act Information Corner
Provider Eligibility and Orientation Information
Please let me know if you have any concerns with this decision.
Thanks,
Taneka
St .. r:,·nt
and/or attachments.
Code:PHEAA
From: l(b)(5)
Sent: 4 May 2017 14:27:20 +DODO

To: Fedloan PSLF
Cc: l(bl( 5l I Cynthia;Foss, lan;Odom, Christian
Subject: Re: International Alliance for Responsible Drinking
Hi Kim,
FSA will be forwarding this organization to OGC for review as result of some of the work
that International Alliance for Responsible Drinking does internationally to promote
public safety.
Thanks,
Taneka

Sent: Monday, April 10, 2017 9:36 AM
To;!(b)(51 I
Subject: International Alliance for Responsible Drinking
Hi Tankea!
We received an ECF for this employer in February 2017. Although they are not-for-profit (they are
501(c)(4)), we determined that they do not provide a qualifying public service. Therefore, we
denied employment at this organization.
Another borrower has subsequently provided additional documentation requesting the re-review
of the organization. Based on reviewing the additional documentation, we still do not believe
International Alliance for Responsible Drinking provides a qualifying public service. However, we
are forwarding for your review since this is a dispute.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Code:PHEAA
From: l(b)(5)
Sent: 31 Dec 2015 16:19:07 +DODO
To: Fedloan PSLF
Cc: Battle, Ll(b-'-l('-51
_____ _,
Subject: RE: International Code Council
Hi Diane,
We looked at thi~ employer a little closer and now believe that the International Code Council ~hould
qualify as intergovernmental.
For this decision, we revisited an escalation for the National Board of Boiler and Pre~~ure Vessel
In~pectors. In that decision, OGC saw that the board members were government (~late or local) employees.
Additionally, International Code Council negotiates and drafts model law~, to provide building and
ultimately public safety, that members (state governments) can take back and introduce as legislation in
their juri~diction as a way of having standardiLed law~ throughout the country.
Please let me know if you vmuld like to discuss further.
Thanks,
Taneka
From: Diane Freundel [mailto:dfreundefa'.pheaa.orgl On BehalfOfFedLoan PSLF
Sent: Tuesdav, December 08, 2015 10:08 AM
To:l(b)(5) I
Subject: International Code Council
Hi Taneka, We previously denied thi~ employer. but the bonowcr is now

di~puting. The International Code Council (ICC) i~ 501 (c)( 6 ); they certified a~ private non-profit public
safety. This organization is respon~iblc for developing, maintaining, and publishing the statutes and
standards for building code~. but they do not actually construct the buildings.The borrower sent in the ICC\
by-laws and infonnation from their website. Upon review of that documentation, and based on prior
guidance received in April 2014 regarding this type of employer (Downtown Durham Inc), we maintain
that the ICC wa~ correctly denied. Ilowever. since the borrower is di~puting, we'd like your confimrntion.
Thanks for your help! Passvmrd to follow.
(See attached file: International Code Council.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax-(717) 720-3911
[email protected]
--------------------------------
Codc:PHEAA
From: l(b)(5)
Sent: 7 Mar 2016 20:47:11 +0000

To: Fedloan PSLF
Cc: l(b)(5J I
Cynthia
Subject: RE: International Community School
Hi Kim,
We agree that the International Community School of Addis Ababa does not qualify since the school is
international. The documentation that you provided is also sufficient to show that the borrower is not
employed by the foundation.
Thanks,
Taneka
Sent: Thursda , March 03, 2016 10:55 AM
To: (b)(5)
Subject: International Community School
Hi Taneka!
We think this will be an easy one, but just wanted your thoughts.
The official certified the ECF using the EIN for the foundation (International Community School of Addis
Ababa Education Foundation), which is 501(c)(3). Historically, when a foundation is involved, we found
that most borrowers are not paid directly by the foundation. As a result, we requested the borrower's W-2.
In response to our request, the borrower wrote a letter indicating that ICS in Addis Ababa does not issue
W-2s and provided a letter from the employer regarding the borrower's employment.
On the ICS Addis Ababa website, it appears the foundation was established solely for obtaining funding
through donations and grants. We do not believe the employees of the actual school are employed and
paid by the foundation.
Since this is an international school and we could find no evidence that they are 501 (c)(3) or that they
operate in the U.S., we are inclined to deny.
As always, we appreciate your guidance. Password to follow.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: l(b)(5)
Sent: 11 Aug 2014 20:15:33 +0000

To: 'Fedloan PSLF'
Cc: 51'-------'
Foss, lan;Battle, Cynthia;Johnson, Ll(b-'l('-
Subject: RE, IRIS
Hi Diane,
This is all very interesting. From what I can tell, IRISis a Medicaid waiver program for those who are
eligible both for Medicare and Medicaid. You can find the IRIS policy manual here; it lays out a bit more
how the program is structured.
This program essentially allows the beneficiary to become an employer unto themselves to manage
their elder care. The role of the "fiscal agent", played by MCFI here, is to essentially be an escrow agent.
The beneficiary sets a budget and hires people, then directs the bill to the fiscal agent who will pay the
party who provided services to the beneficiary. This is all to prevent the beneficiary from receiving any
of the money associated with the program.
You'll also note that the fiscal agent also processes payroll for the beneficiary, so that each of the service
providers is paid through the fiscal agent, but the employer is the beneficiary, and the ultimate source of
the funds is Medicaid-so, federal/state money.
All of this seems to be reflected in the ECF.The borrower would be the service provider, the employer is
the beneficiary, and the certifying official is the fiscal agent (indeed, a Google search for the phone
number of the certifying official directs me to MCFl's IRIS page). The beneficiary being the employer, I
don't think this employment qualifies.
Ian
To: l(b)(5J I
Subject: IRIS
Hi Ian, This one is very confusing. I'll do my best to give you a high level overview.
L We received multiple ECFsfor this borrower/employer. Employer is listed as IRIS/ a person's name
(ex Tatyana Zuykova). EINs on each one are different.
2. We researched IRISand it is a Wisconsin program where someone self directs their publicly funded
community-based long term care supports and services.
3. We requested a copy of borrower's W-2.
4. The employer on the W-2 is MCFI - Fiscal Agent, Agent for "person's
name". We can't link the EIN to anything, leading us to believe they
probably don't qualify. We found a business filing for MCFI Home Care LLCwhose agent has the same
address as the address on the W-2.
5. MCFI Fiscal Agent manages finances for individuals who are unable to do so. MCFI Fiscal Agent
services are available to county agencies and consumers receiving government funding. They provide
timely and accurate payroll processing for various members of long-term care, enabling the consumers
to maximize their independence.
6. We found a business filing and a Form 990 for MCFI Inc (Milwaukee Center For Independence) which
is 501(c)(3) but has a different EIN than what is on the W-2.
Our inclination is to deny, but we wanted your thoughts. Password to

follow. Thanks!
{See attached file: IRIS.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
[email protected]
From: l(b)(5)
Sent: 10 Apr 2013 07:46:52 -0500

To: Fedloan PSLF
Cc: l(bl( 5l I
Debbe
Subject: Re: Islamic Center of Orange Park, Inc
Attachments: Screen Shot 2013-04-10 at 8.44.45 .png
Hi Diane,
Thi~ one i~ a 50l(c)(3), ~o it qualific~. Sec attached.
Ian
On 3/1 9/l 3 9:37, "FcdLoan PSLF" <FcdLoanPSLF(a;'phcaa.org> wrote:
>
>Hi Ian, This is the other religious organization I mentioned in my email
>on One Accord Global Ministry. On the ECF they checked both boxes band
>c
>and under c they checked public education, school library services, and
>other school based services.
>
>Thanks again. Password to fol!O\v.
>
>(See attached file: Islamic Center of Orange Park, Inc.zip)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>dfrcunde((j)phcaa.org
>This me~sage contain~ privileged and confidential infonnation intended
>for the above addrc~~ees only. lfyou
>
Exempt Organizations Select Check E,ernpt Orgar,zat,ons Select C~eck Home
Organizallons Eligible to Receive Tax-Deducllble Contnbutions (Pub 78 data)- Search Results
The following 11stincludes tax-exempt organizations that are eligible to rece,ve tax-deducllble contributions. Click on the "DeductJb1lIty
Status" column for an explanation ol l1m1tallonson the deducllb1l1tyol oontnbut,ons made to different types oltax-exempt orgamzallons
Results are sorted by EIN. To sort results by another category, ciIck on the icon next to the column heading for that category. Clicking on that
icon a second time will reverse the sort order. Click on a column heading for an explanallon of 1nforma11on,n that column.
1-25 of 28 results Results Per Page o, « Prev 11-251 Ncxl »
EIN .-. Leycll Nmne {Doing Business As).-.

" City.-. St~te .-.Country.-. Deduct1b1l1ty_
St~tus .-.
11-3704052 lslam,c Center of Brandon Inc. Brandon FL United States cc
20-1171908 Islamic Center of Lakeland Inc. Lakeland FL United States cc
20-3167881 Islamic Center of Palm Beach Inc. West Palm Bch FL United States cc
26-3661390 Islamic Center of Broward Inc. Sunnse FL United States cc
26-3676870 Islamic Center of Orange Park Inc. Orange Park FL United States cc
26--4487266 Islamic Center of Deltona Inc. Orange City FL United States cc
27-0358711 Indian River Islamic Center - Irie Jensen Beach FL United States cc
27-3520946 North Miami Islamic Center Inc. Miami FL United States cc
30-0475804 Leesburg Islamic Center Inc. Leesburg FL United States cc
38-2520789 Flint Islamic Center Tallahassee FL United States cc
51-0524014 Bonita Springs Islamic Center Bonita Spgs FL United States cc
59-1882880 Islamic Center of North East Florida Jacksonville FL United States cc
59-2309180 Islamic Center of Southwest Florida Inc. Fort Myers FL United States cc
59-2435588 Islamic Center of Daytona Beach Inc. Daytona Beach FL un,led States cc
59-2443382 St. Petersburg Islamic Center MasI1d AI-MumIn,n Inc. St. Petersburg FL United States cc
From: Foss, Ian

Sent: 11 Apr 2013 12:59:28 +DODO
To: 'Fedloan l(bl(5l I
Cc: Sipple-Asher, Bessie;Johnson, Debbe;Ninemire, Sandra
Subject: RE: Islamic Center of Orange Park, Inc
Actually, the date that the organization became a bone fide 501(c)(3) ~hould be in the Businc~~ Ma~ter
File. So, if there's ever a concern that the employment certification goc~ back prior to the date that the
organin1tion obtained tax-exempt ~tatu~,we can check there,
From: Diane Freundcl [rnaiHo:dfreunde:11.pheaa,or!!]On BehalfOfFedLoan PSLF
Sent: Thursdav, April 11, 2013 8:57 A\1
To: l(b)(5) I
Cc: Sipplc-A~her, Bessie: Johnson, Debbe: FedLoan PSLF; Fo~s, Ian; Ninernire, Sandra
Thanks Ian, An additional question on this one, I can't be positive that

I checked the IRS' Tax Exempt Select Check list on this one -we
(Compliance) assume that the Business Unit has done that first, so we don't ahvays double check; however,
if! spend a lot of time researching an employer, I typically do still review this list I probably didn't review
the list for this one, but guess it's possible that this organization 1,vasnot on the list 1Nhen(it)I reviewed it
Since borrowers can be certifying past employment, we're not able to confirm that the organization had the
appropriate status when the borrower was employed there. I know this is inherent to the process, I just
1,vantedto point it out.
Also, I'll make sure we ahvays check the IRS site before sending to you.
Thanks again!
Diane
From: ,,.l(b_l(~51_~='11.,,(b~)(~5)~~~==~~
To: "FcdLoan PSLF" <FedLoanPSLF(a;phcaa,org>
Cc: l(b)(5) U(bJ(5) l"Foss, Ian"
<lan,Fos~(a;'ed,gov>, "Ninernire, Sandra" <Sandra.Ninemire(a;ed,gov>,
"Sipplc-A~her, Bessie" <Bcs~icKo,SipplcA~her(a;cd,gov>, "Johnson,
Debbe" <DebbcJohn~on(a;ed,gov>
Date: 04/J0/2013 08:47 AM
Hi Diane,
This one is a 501 (c )(3 ), so it qua I ifies. See attached.
Ian
On 3,, 19/13 9:37, "FedLoan PSLF" <FcdLoanPSLF½_~·pheaa.org>wrote:
>
>Hi Ian, This i~ the other religious organin1tion I mentioned in my email
>on One Accord Global Ministry, On the [CF they checked both boxes band
>c
>and under c they checked public education, school library services, and
>other school ba~cd ~crvicc~.
>
>Thank~ again. Pa~~word to follow.
>
>(Sec attached fik: hlamic Center of Orange Park, Inc.zip)
>
>Diane Frcundcl
>(717) 720-3267
>fax- (717) 720-3911
>dfrcundc(d)phcaa .org
>This mc~sagc contains privileged and conlidcnlial information intended
>for the above addressees only. If you receive this message in error
>please delete or destroy this message and/or attachments.
>
>The sender of this message will fully cooperate in the civil and
>criminal prosecution of any individual engaging in the unauthorized use
>of this message.
[attachment "Screen Shot 2013-04-10 at 8.44.45 .png" deleted by Diane heundel/PHEAA]
you receive this message in error pkasc delete or destroy thi~ mc~~agc and/or attachment~.

__ _,
Sent: 29 Jan 2014 10:31:05 -0500
To: Fedloan PSLF
Cc: l(bl(5l I
Subject: Re: Jax Transit Management Corp
Hi Diane,
I agree that this one qualific~ as qua~i-govcrnmcntal. The acquisition of

a mas~ transit sy~tcm i~ squarely within the authority 1s power~. And,
it's also providing a service that is usually provided directly by the
government.
Ian
On 1/5/14, 19:47, "FedLoan PSLF" <FedLoanPSLF(a/pheaa.org> wrote:
>
>Hi Ian, We think this one could be quasi-government, but we're not sure.
>If they're private non-profit, we're not sure they provide a qualifying
>public service.
>
>ECr - employer checked government. but crossed it out and checked private
>non-profit providing public service for individuals with disabilities and
>the elderly. Title of person certifying form (William \1oseley) is "Chief
>of Staff'. The cover letter \Viththe ECF is from the Ethics and
>Compliance Officer of the Jacksonville Transportation Authority.
>
>The bmincss filing indicate~ they arc non-profit. The rcgi~tcrcd agent
>is
>the pcr~on who ~igncd the E(T - William Mo~c!cy.
>
>According to the hi~toty of the Jacbonvillc Transportation Authority,
>they
>arc an independent slate agency. We can't tell iflhe Transit \1anagemcnt
>Cmv 1~ a part orthe Tran~portation Authority.
>
>Any help you can provide is greally appreciated. Password to follow.
>Thanks!
>
>(See attached file: Jax Transit Management Corp.zip)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>
>and/or attachmcnb.
>
From: l(b)(5)
Sent: 17 Feb 2012 19:30:48 -0600

Subject: RE: Kaiser Permanente Orange County Family Med Residency Program
Kai~cr Permanente is generally organi?cd as a not-for-profit; however. it i~

al~o a dccentrali?cd organization. There arc mually three component part~
in each of eight region~ (though it also varies by region). Namely, there
is the health in~uranec company. which i~ not-for-profit the hospital
system, which is not-for-profit, and the medical group, which is
phy~ician-owncd and operates on a for-profit ba~is.
I would assume that it

is the hospital that employs the residents, a~ that is the most typical
arrangement. but the more of these I sec. the !cs~ inclined I am to rely on
,,,,..hatI've regarded as "typical" in the past. To ,Nit: the webpage (see here:
http ://res idenc v .kp .orgi sen[/resi dencv/ fami 1vmed ic ine oci index .html) that
provides information about the residency program is copyrighted by KFHP.
Inc., which is the Southern California iteration of the health insurance
company.
In the end, 1say this qualifies as a non-501 (c )(3 ),

not-for-profit organization that provides public health
services.
rmailto:dfrcundctn)acssucccs~.or<'l On Behalf Of FcdLoan PSLF
Sent: Thursday,
To: l(b)(5) I
Subject: Kaiser Permanente
Orange County Family Med Residency Program
Good evening,
EIN -
00-95-1750445
From what I could find. Kaiser Pennanente is a non-profit H\1O

http://phvsiciancareers.kp.orgiabout-kaiser.htrn1
They also have a Kaiser
Permanente Medical Group with over 4500 partner physicians. I assume this
would be for-profit
The borrower completed a portion of the ECF and said

she \Vasjust checking to see if the employer qualifies, so \Ve don't have any
certification. If she is in the residency program. I think she would
qualify; however, I
don't think that the Medical Group is a qualifying
employer. Do you
agree?
Thanks
Diane Frcundcl
Compliance Service~
(717)
720-3267
fax-(717)
720-3911
<lfrcunde(a;pheaa .org

confidential infonnation intended for the above addressees only. Ifyou
attachments.

of this
message.
--------------------------------

__ _,
Sent: 23 Jan 2014 10:06:21 -0500
To: Fedloan PSLF
Cc: Foss, L(b-')('-51'--------' Debbe;Battle, Cynthia
Subject: Re: Kalispel Tribe of Indians DBA Northern Quest Resort and Casino
Hi Diane,
Thi~ one qualific~. The Kali~pcl Tribc legal code makes cxprc~s that
1
~
organin1tion~ chartered under Title 17 arc government agencies. I think

you've established that this organiLation was chartered under that title.
Sec here: http://www.narf.oru/nill/C'Olks/kal1spclcolkichapkr 17.pdf.
Ian
>
>Hi Ian, We're still not comfortable making the final decision on Tribal
>Casinos. We think this one qualifies as government, but it's not clear.
>Can you please confinn? Passvmrd to follow. Thanks
>(See attached file: Kalispel Tribe of Indians DBA Northern Quest Resort &
>Casino.zip)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>
>The ~ender of this me~~age will fully cooperate in the civil and criminal
From: l(b)(5)
Sent: 26 Feb 2013 09:36:49 -0600
To: Fedloan PSLF
Cc: 51'--------'1
Ll(b-'l('- Sandra;Johnson, Debbe;Foss, lan;Sipple-Asher,
Bessie
Subject: Re: Kansas Association of School Boards
Hi Diane,
We agree that they do not provide a qualifying service, and, a~ such, do

not qualify for PSLf-. Furthcnnorc, we do not think that an organization
whose primary purpo~e is advocacy (even ifnon-parti~an) is likely lo
provide qualifying services al all. We further note that advocacy, in and
ofitsclC will never be a sufficient "qualifying ~crvice" lo qualify for
PSLF.
Ian
On 12/J3/12 13:21, "FedLoan PSLF" <[email protected]> wrote:
>
>Hi Ian. We're having trouble with this one. They are a 50 l(c)(4) and
>therefore \vould need to provide a qualifying public service. They checked
>the boxes for public interest law services and other school-based
>services.
>Based on their website, they provide services for their members, not the
>general public. Because their members are governing boards for unified
>school districts, community colleges, etc., \Ve first thought they would
>qualify. But we don't think they offer a public scr\'icc. I know we
>di~cusscd other hoard~, such a~ a ~chool hoard, hut I don't recall ifwc
>di~cusscd any a~~m:iations.
>
>Password to follow. Thanb!
>
>(Sec allachcd file: Kansas Association of School Boards Inc.zip)
>
>Diane Freundcl
>(717) 720-3267
>fax- (717) 720-3911
>
From: l(b)(5)
Sent: 8 May 2013 13:14:49 -0500
Cc: Foss, lan;Johnson, Debbe;Ninemire, Sandra;Sipple-Asher, Bessie
Subject: RE: Keys Gate Charter High School
Hi Diane,
It's entirely common for charter schools in states requiring them to be organized as not-for-profits to
actually be legally organized that way, have a skeleton staff that runs the school itself, but then turns
over nearly all management to a for-profit.
Under the Florida law that you cite, I think this structure is permissible. The language states that "A
charter school shall organize as, or be operated by, a nonprofit organization". Here, because the
management company (the operator) is a for-profit, the charter school must be technically organized as
a not-for-profit. It seems like there is such a corporation, the "Keys Gate Charter School Holding Inc",
which is organized as a not-for-profit organization under Florida law. See here in their articles of
organization.
Here, because the EIN you entered turned up the for-profit corporation, I am inclined to believe that the
borrower actually works for the for-profit management company, and not the charter school, itself
(which likely only has a board of directors and a chief executive officer). And, the charter school's career
[email protected]_ certainly suggests that the employees of the charter school are actually employees of the for-
profit.
So, I would reject the ECF.
Great job on the research.
Ian
From: Diane Freundel [mailto:[email protected]] On Behalf Of FedLoan PSLF
Sent: Tuesday, April 30, 2013 4:06 PM
To: l(b)(5J I
Subject: Keys Gate Charter High School
Hi Ian, We're having trouble with this charter school. I think bullets
will be easier to go through on this one.
- They checked private non-profit on the ECF.
- The school website indicates they are a member of the Charter Schools USA family of schools, one of
the largest providers of charter school management services in the state of FL
- Prior research of Charter Schools USA indicates they are a for profit management company
- Charter Schools USA operates 48 charter schools in 5 states. We reviewed the laws for several of the
states and they indicate that a charter school must be non-profit. One of the states in which Charter
Schools USA operates charter schools is NC and its law indicates that "a charter school shall be operated
by a private nonprofit corporation ... " An FL law (page 19 of attachment) indicates that charter schools
shall organize as, or be operated by, a nonprofit corporation.
- FL Sec of State corporations website allows you to enter an EIN. When we use the EIN provided on the
ECF,it comes up as Charter Schools USA at Renaissance High School of South Dade and it's an LLC.
Renaissance High School has a different address than the address listed on the ECFfor Keys Gate.
We're inclined to deny because Charter Schools USA seems to be for profit; however, we're unsure how
a for profit management company can manage charter schools in states that require operation by a
nonprofit
corporation. Thoughts?? Password to follow. Thanks!
(See attached file: Keys Gate Charter High School.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
[email protected]
From: l(b)(5)
Sent: 8 Feb 2012 14:43:36 -0600

Cc: Ninemire, Sandra;Foss, lan;Sipple-Asher, Bessie
Subject: RE: Kidspeace Advances
Thi~ one also qualifies. However. there arc some entries in Pub 78 for
Kid~Pcacc, though none under the EIN provided. So. I think this borrower i~
employed in a non-501 (c)(3) component of the broader organi?ation that i~
non-profit and provides a qualifying public service.
I found a number of
entric~ for KidsPcace in the Pennsylvania Business Filings Database that all
indicate not- for-profit organization.

> From:
Diane Freundel Lmailto:dfreunde:11-aessuccess.orgI On Behalf Of
> FedLoan
PSLF
> Sent: Tuesday, February 07. 2012 8:58 PM
> To: l(b)(5) I
Subject: Kidspeace Advances
>
>
> We believe this is a qualifying private
non-profit
> Employer checked box c and "other school based services"

>
> [IN: 00-75-2376421
>
http://www.kidspcace.urg/about.aspx·. 1ekrn.:n~cl=c580fa7b 72 0 3198 I
>
>
Thanh
>
> Diane Freundel
> (717) 720-3267
> fax-
(717) 720-3911
>
>
>
--------------------------------


attachments.
>
civil and criminal
> message.
>
>
From: l(b)(5)
Sent: 10 Jun 2014 17:43:33 +0000

To: 'Fedloan PSLF'
Cc: l(bl(5l I
Subject: RE: King County Bar Association
Sorry for the dclay. I agree.
Sent: Wednesday, May 07, 2014 1:47 PM
To: FedLoan PSLF
Cc: l(b)(5) I
Subject: Re: King County Bar Association
Iii Ian, Ba~ed on our discu~sion today and a re-evaluation ofthi~ employer's website, we don't think they
qualify. It appears to us that the pro bona services that are provided to the public are provided by the Bar
Association's members as volunteer work. We couldn't find any indication that the Association itself
provides the services.
Please let us know if you agree/disagree.
thanks!
Diane
From: FedLoan PSLF/PHEAA

To: l(b)(5) I
Date: 05/06/2014 10:20 AM
Subject: Public: King County Bar Association
Sent by: Diane Frcundcl
Iii Ian, I hale to keep ~ending these to you, but we're just not cornf011ablcwith public interest law
services. W c think this one docs
qualify. We appreciate your thoughts.
ECF certified as private non-prolil, providing public intere~t law services.
They are a 50l(c)(6).
Based on their website (specifically the pdf ending with legalhelp) lists all of the pro bona services they
provide to the community.
Passv,rordto follow. Thanks!
(See attached file: King County Bar Association.zip)
Diane Freundel
Compliance Service~
(717) 720-3267
fax-(717) 720-3911
dfrcundc((_l'.phcaa.org
From: l(b)(5)
Sent: 19 May 2016 19:42:42 +DODO

To: Fedloan PSLF
Cc: l(b)(5J I
Cynthia
Subject: RE: Kia-Mo-Ya Casino
Attachments: KMYC Application Form 01.18.13.pdf
Hi Kim,
We were able to pull up employment information for Kia-Mo-Ya Casino that suggests that it may be
separately organized from the tribe. The certification and agreement section of the employment
application for Kia-Ma-Ya, states that, "it is understood however, that Kia-Mo-Ya Casino as an enterprise
of The Klamath Tribes does adhere to a policy of Indian Preference ..." and "I understand and consent
that if considered for employment and as a condition for that employment, that I must apply for and
obtain a gaming license from the Klamath Tribal Gaming Regulatory Commission KTGRC,a separate
regulatory agency, of the Klamath Tribes."
Based on those clauses we would suggest denying the casino and requesting that they provide
additional information to show that they are in fact governmental.
Thanks,
Taneka
Sent: Frida , A ril 15, 2016 2:04 PM
To: (b)(5)
Subject: Kia-Mo-Ya Casino
Hi Taneka! We have another casino for you.
This casino is part of the Klamath Tribe in Oregon. We found one website that listed it as an enterprise of
the tribe (Enterprise of Tribe document). Another site (ODAIR Draft document) appears to list the casino
as a department. We also located the tribe's Constitution, which states, on page 4, that " ...sovereign
powers, authority and jurisdiction of the Klamath Tribes extends to all the territory which formerly
constituted the Klamath Reservation, and to all property, airspace, natural resources, cultural resources
and such other lands or interests ...". This suggests that the casino would be considered part of the tribe
and therefore would qualify as governmental.
Though we know that Wikipedia isn't the most reliable source of information, it also states that the casino
is a tribally-owned gambling establishment and that the casino disburses payments to the tribal members.
As always we appreciate your guidance! Password to follow.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
Application for Employment

.
• Kla-Mo-Ya Casino. Corp.
34333 llwy'J7 N. Chiloqum OR ')7624
P: 541 7RJ.7529i F: 541.783.3670
Please complete the n:quc,tcd inlorrnation fully and accurately. Make sure lo ll><Cblue or black mk only. pnnt or
,.rite lq:ibly, and date and >1gn 1hc application: othcmi,c it may not be co11>11.kn:dfor the po>1ll0ll. For areas that
For What Position or Department
Are You Applying?
do not i!pply. mdicatc with ''"J/A··. A resume or addnional mformation may be ,ntachcd but not a, a substitute for
rcquc,tcd informmmn. Appl1cmmns rcm,1111on fl le for six month, .. A.pplic;mts ilrc rc,ponsiblc for upd,ning
personal/contact infornrnt1on. tqmil accc,s to KM YC program,, scr, 1cc,, and employment 1sa,aibblc to i!II
person,. Applicants needing: reasonable accmmnodallon lo complete the procc,s shculd notify Human Resource,.
Identification
D Applying for any available po~ilion
Li!sl"Jame:__________________ Cirst:______________ '11..____ _ for which considered qualified.
Addrc,s: --------------------------------------- Type of Employment Desired

City: ____________________ Swtc: _______ Lip Code: ______ _
Primary T dephonc #: _______________ Other#: _______________ _ □ full-Time

□ Pan-Time
□ Temporary Seasonal
1:-'vlailAddre,s: ------------------------------------
Shift \Vork Preference
Native American Preference
In accordancewith 42 U:>C5ec. 2000 c 2 (i). Kla-~1o-YaCa,ino e~erciscs rnbal a11dK,ni,·c,'imencan preference
□ Days D Swing D Graveyard
in employment mnong si1mlarly quahfiet.l applicants. Employment decisions lor all other apphcanl, and employees
,.ill be made without reg art.Ito race. creed. color. religion. gentler, age. natwnal onguL , eteran status, disability or
other legally protcctet.l statu,. If a tribal member. you may be asked to pro\'lde ,-enlicatwn or enrollment. Can You Work'?
Please indicate your Tribal affiliation:

0Yes 0No (h-erlime A~ Needed
D Enrolled Klamath Tribal Member Enrollm,:,nt #:
D Descent.lent of a Klamath Tribal Member 0Ycs 0No V.'cckcnds (Sat/ Sun)
D Member of Another Fet.lerally Recognizet.l Tribe >Jame of Tribe: 0Ycs 0No Holiday's
D l\ot associated with a :,Jatl\'C/\mcrican tribe
Information How did you learn about Kia-Mo-Ya
Casino and/or this position(s)?
0Ycs Arc you a citizen of the Cn1tcd States of 1\mcrica'.'
0Yes li'nol a citizen, are you legally authorized lo work in the USA'! D Employee Referral (t1<,m
Whmnl.
0Yes ]!'authorized, will you be able to provide proper verification of your status'.'
To work at Kia-Mo-Ya Casino (please mdicatc "''hich applies): D Casino or Tribal Postmg
D Enrolled Tribal Members must be at least 18 years of age to apply for any position
D Kia-Mo-Ya Web~ile i Employment
D :,Jon-enrolled Tribal members must be at least 18 years of age to apply for a non-gaming position
D :,Jon-enrolled Members must be at least 21 years of age to apply for a Class 111gaming position D Herald & l\ew~ Job Adverli~ement
D >Jone of the above
D Work Source Klamath Falb
Completion ofa high school level education is required for all positions. Do you ha,-c a --
D High School Diploma (you will be a~ked lo provide a copy ifseleclet.l)
D Radio/TV At.l,ertisemenl
D Recognized GED Ccrtiticat1on (you will be asked to pro,·1dc a copy if selected) D Internet ('ircc1hl
D :,Jcithcr D Other 1~p,c11y1
D Yes D No Do you ha,e a valit.l t.lriver's licen~e'! State of Js~ue: !/-:______ _
For HR Use Only
D Yes D No Have you ever been arre~led. t.letained, charget.l, indicted, or summoned lo an~wer
for any criminal offense or violation for any reason whatsoever. regardless of the
disposition of the e,enl'! (Except minor traffic citations} Application Received:
D Yes D No Have you ever plead "guilty" or "no conle~l" or been comicted or felony or other
cnmmal offense w1thm the last ten ( 10) years'' (Except tnftic offenses) Selected for Interview:
D Yes 0No /\re you presently charged with a v10lation of the law? (Excluding traffic v10lations)
Notification Sent:
D Yes D No Have you ever been employed by Kla-Mo-Ya Casmo?
0Ycs 0No lfycs: DatcofScparation: ID#: Comment:
D Yes D No /\re any rclati,·cs currently employed or associated with Kia-Mo-Ya Casino'?
OBTAINED BY STUDENT BORROWER PROTECTION CENTER AND AMERICAN FEDERATION OF TEACHERS UNDER THE FREEDOM OF
HR f'omr Dat~ INFORMATION
of'""" 10,111;111; ACT
Kia-Mo-Ya Casino, Corp. ◄ ► Application For Employment
Educational information
l ltgh School Cll:, / State Y,·ar, D,1>1011,a
,,,. D,·~re,· R,·c,·,,ed / ftdd of Stud:,
Completed
College or l In,, er,H) Cll:, / State Y,·ar, D,1>1011,a

,,,. D,·~re,· R,·c,·,,ed / ftdd of Stud:,
Completed
College or l In,, er,H) City State \cur, [),plomu OT Degree Rccci,·cd Field of5Hldy
Completed
T rndc or V oc·,monul Sc·hool City State \cur, [),plomu OT Degree Rccci,·ed Field of5Hldy
Completed
Other Ccn,tled Spern,11,ed Tru1n111g City State \cur, CcnitlCutlOn Rccci,·ed Field or·swdy
Completed
If You Eurned u (ieacrnl Educu11on Diploma 1(iH)J Name or·1he cemt\1ng 111,111<111011 City State Yc;,r
Reccl\·cd
U.S. Military Service

D Yes 0No Have you served in the C.S. Armed forces'? If yes. you will be asked to pro\·1dc a copy ofyour 0D214 1fsdcctcd.
Jfye~. which Branch'! __________________ _ Dales Served: from: _______ _ To: _______ _
Please describe any military training received or duties performed that may be relevant to the position for which you arc applymg.
Other information
tr you answered ye~ lo either question regarding criminal offen~es above, was the convictitm for a D \1i~demeanor or a D felony'!
Please indicate the nature of the offense. the date. circumstances. and duration of incarceration, if any.
The existence ofa criminal comiction or pending charge will not nece~sar.ly preclude you from employment with Kia-Mo-Ya. however the nature or
the crime, its relationship to the position responsibilities for which you applied. the degree of rehabilitation that has or 1s occurring. and the elapsed
time since the crime or release from confinement will be considered and subject licensing re~lrictions and/or requirements.
Employment History
llcgm with your most recent employmentexperiencei!ndco,er the pa,t 7 years. l'lca,e print. Be sure to accuratelycompleteall requestedinfornrntion.Feel free to
auach add1twnal document, mclut.ling a resume regarding other employment or expcncnccs rein-ant lo the position for "h1d1 applying. H,mcver. auachrnenls.
including a resume, may not be pro, it.ledas subsl!lules lor the reque,ted inlorrnatwn.
Most Recent Emplovment·

.
l\amc of D Full-Time 0 Self-Employed
Employer: Fi Part-Time Fi other
City Stale: F,orn1\1'Yl To(M/Y)
Telephone I Supeni~or·~ Fmal Wage

Number: l\ame / Title: Or :>alary: Per:
Job Title: I Leaving:
Reason For
Brieily de~cribed the work performed or the skills utiliLed (make ~ure lo li,l any work or ~kills relevant lo the po~ition for which applying):
HR Fomr Date of INFORMATION
l»<1e 10,111;111; ACT
!\ext Most Recent Emplo,;ment·

.
Employer: M Part-Time Mother
City Stale: F,orn1\1'YJ To(M/Y)

Number: l\amc / Title: Or :>alary: Per:
Job Title: I Reason For
Leaving:
Brieily de~cribeJ the work performed or the skills utiliLed (make ~ure lo li,l any work or ~kills relevant lo the po~ition for which applying):
.
Third \lost Rccrnt Emplovmcnt·
Employer: M Part-Time Mother
City Stale: 1-rom(\1,'Y) ToiM Yi

Number: l\amc / Title: Or Salary: Per:

Lca\'lng:
Brieily de~cribeJ the work performed or the skills utiliLed (make ~ure lo li,l any work or ~kills relevant lo the po~ition for which applying):
Fourth Most Recent Employment:

l\ame of D Full-Time D Selt~Employcd
Employer: Fl Part-Time Fl other
City State: 1-rom(\1,'Y) ToiM Yi

Number: l\amc / Title: Or Salary: Per:

Lca\'lng:
Rnetly described the work performed or the skills utilized (make sure to list any work or skills relevant to the position for which applying):
Please identify and explain any gaps in your employment history durmg the past 7-ycars. such as Unemployed. Student, etc. Include dates.
References
l\ame Address/Cit)·/State/Zip Contact# Business/Personal Years Known
of'""" 10,111;111; ACT
Applicant's Certilication and Agreement
I attest and certify that all information I have provided in order to apply for and secure work with Kla-Mo-Ya Casino, Corp. (K:-VIYC)1s true and
complete ant.I made in good faith. I understand that thi~ application form is intended for u~e in evaluating my qualification~ for employment an<l the
position for which being considered and that it is not in any context to be considered an offer of employment. l understand that any false mformation,
misrepre~enlalion~ or omi~sions on this application. other written materials, or as provided during my inlerview(s} may lead lo the rejection of my
application ant.I if employed. be cause for discipline up lo an<l including the termination of my employment at the time any fabe information or
omissions arc discovered and that Kla-Mo-Ya Casino rctams the right to tcrmmatc my employment on these grounds.
I expre~sly authorize, without reservation. KMYC, ib representative~. employees, or agent~ lo nmlact an<l obtain information from all references
(personal and professional), employers. public agencies. liccnsmg authJrit1cs. consumer rcportmg bureaus. and educational institutions and to
olhem·i~e verify the accuracy of all information provided by me in this application, other submille<l documentation, or job inlerview(s}. I hereby
waive any and all rights and claims I may have regarding the employer, its agents. employees. or representatives. for seeking. gathering and using
truthful and non-defamatory mformation in a lawful manner. in the employment process and all other persons. corporations. or orga111zat1011s for
fumi~hing such information about me.
I understand that 1f hired. my employment will be considered "at will" meaning I have no contractual right. expressed or implied. to rcmam in the
employ of KMYC an<l that this application Joe~ not con~litule an agreement or contract for employment for any specified period or definite duration.
I understand that 1f employed. 1 am free to resign at any time. 'Nith or without cause and with or without prior notice. and KMYC reserves the same
right to terminate my employment at any time. with or without cause or with or without prior notice, except as may be required by law. ln
consideration of my employment, I acknowledge that my employment or the lenn~ and condition~ thereof, including compen~alion, can be changed
or terminated with or without cause or notice at any time at the option of KMYC. lt 1s fu11hcr agreed. that this "at will'" relationship may not be
changed by any implied oral or wrillen agreement or by conduct, that no supenisor or representative of KMYC i~ authorized lo make any as~urance~
to the contrary unless such change is appro\·Ccl and acknov.,Jcdgcd 111wnting by the Kia-Mo-Ya Board of Directors.
I un<ler~lan<lthat KMYC maintains a policy of equal opportunity employment with regard to race, color, religion, national origin. sex. age. genetics,
known di~ability or veteran slalu~ and no que~lion on thi~ application i~ used for the purpose of limiting or eliminating any applicant from
consideration for employment on any basis prohibited by applicable local. state or federal law. Reasonable accommodation will be made as
appropriate lo enable any employee or applicant for employment to ~aiely and properly perform the job for which applying as requested. It is
understood however. that Kla-Mo-Ya Casino as an cntcrpnsc of The Klamath Tribes docs adhere to a policy of Indian Preference and will gi\·C
preference in employment, promotion. and training lo qualified members of federally recognized tribe~ who satisfy the minimum thre~lmld
qualiticat1011sfor the position when applicants arc reasonably and s11nilarlyqualified.
I understand that Kla-Mo-Ya Casmo has adopted an i\lcohol & Drug Free Policy applicable to all employees and candidates for employment. /\s
such, I hereby agree an<l con~ent, as a condition of my employment. lo ~ubmilling lo a pre-employment Alcohol & Drug lest a~ established by
K:-VIYCand farther authorize release of any test results to KMYC by the testing agency 1 fu11hcr understand that my failure to appear for said test
within the lime period allotted. lo le~l positive for any nnered ~ub~lance, lo refuse lo sign a consent form or ~ubmit for testing or fail to cooperate in
any manner or to produce an unacceptable specimen withm the designated time pcnod. will be cause for the rescinding of my job offer and disqualify
me from further consideration for any po~ilion for a period of 24-months conditioned upon providing evidence of ha, ing successfully completing an
appropriate treatment program. I further agree and consent that if hired an;! throughout the term of my employment with KMYC to abide by KMYC
alcohol & drug testing pol icics and procedures (includmg random and suspicion) and authorize release of any such test results to KMYC.
I understand and con~ent that if con~it.len:<lfor employment an<las a condition for that employment, that I must apply for and obtain a gaming licen~e
from the Klamath Tribal Gaming Regulatory Commission KTGRC). a separate regulatory agency, of the Klamath Tribes. I understand that the
KTliRC will requin: compldion of their gaming licen~e application ant.I Jisclo~ure document~ for purpo~es of obtaining a gaming license an<l will
conduct a background investigation to include. but not be limited to. cducat1011aland employment history. crimmal records checks, references and as
applicable, a credit hi~lory check. I further understand that KTCiRC'~ findings may be ~hared with KMYC ant.I may affect my eligibility for
employment. I abo under~land that KTCiRC utilizes surveillance equipment as part ofil~ daily operation~ an<l that J may be video an<l/or audio taped
while on propc11y.
I understand that the Immigration Reform ant.IControl Act of l\ovember 6. 1966 require proof of legality ofresi<lency in the Lnited Slates or Lnited
States citizenship and will be asked to complete an 1-9 form 111 this regard. l further understand that such proof must be provided to KMYC at the
lime of hire. The failure lo <loso will result in the withdrawal of the employment offer or termination of my employment. (Acceptable documentation
include~ but i~ nol limited lo a valid driver·~ license, social ~ernrity card. Tribal enrollment card, birth certificate, US Pa~~porl, or certificate of LS
cit1zcnsh1p.)
I agree to conform to all cxistmg and future KMYC policies, procedures. requirements. regulations. rules. and/or management directives, as a
condition of my employment an<l un<ler~land that such policie~. procedure~. requirements, regulations, rules, an<l/or management directives may be
changed. modified. amended. withdrawn. or interpreted at any time as KMYC deems appropriate with or without notice. 1 also acknowledge that
K\1YC re~enes the right lo change the wages, hour~. an<lworking conditions ofmy employment a~ deemed nece~sary with or without notice.
DO !\OT SIG~ U~TIL YOL HAVE CAREFULLY READ THE ABO\"E APPLICANT'S CERTIFICATION
I hereby certify that I have react. fully understand and accept all terms of the forgoing i\ppl1cant"s Certification.
Signature of Applicant: ______________________________________ Date: ___________ _
of'""" ;111; ACT
10,111
From: Foss, Ian

Sent: 10 Jul 2012 13:49:10-0500
Cc: Sipple-Asher, Bessie;Johnson, Debbe;Ninemire, Sandra
Subject: RE: Kool Kidz World, Inc
Wonderful! Thank you. Given that the entity wa~ holding itself out a~ a
not-for-profit organization on it~ wch~itc I found it troubling that I
could find nothing cl~c to confirm that.

>
From: Diane Freundcl [rnaiHo:dfn::unde:11.pheaa.orn]On BehalfOfFedLoan
>
PSLF
> Sent: Tue~da , July I 0, 2012 I :37 P\1
> To: (b)(5)
> Cc:
~---~
Sipple-Asher, Bessie; Johnson, Debbe; FedLoan PSLF; Foss, Ian;
>
l(b)(5) INinemire, Sandra
> Subject: RE: Kool Kidz World, Inc
>
>Hi
Ian, This is just informational. We found a way to access basic
>
information on the NJ Corporations website without paying and this
>
organin1tion i~ non-profit. However. as we discussed, we have no
evidence
> that they arc licensed to provide child care, so our denial
~tand~.
>
> From http: '/www.coordinatedlegal.com/S.:cretarvOfState.htrnl
we access
> the
> NJ link "Search Busines~ Entity, Trade/Service marks".
then in~tead of
> "Busine~s Entity Li~t~"we go to "Busine~s Entity Status
Reports" - in the
> attached file. see the .pdftitled Business filing - NP.
We verified that
> NP stands for non-profit. Passvmrd to follow.
Thanks!
>
> (See attached file: Kool Kidz World Inc.zip)
>
> Diane
Freundel
> (717) 720-3267
> fax-(717) 720-3911
>
d fn:undc(c(phcaa. org
>
>1------------>
>I horn:
1------------>
> --------------------------------------------------------------------------
> ---------------------------------------------1
>
lpublic~crvicc l(b)(5)
>I ~-----~
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
>ITo: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
l"FcdLoan PSLF" <FcdLoanPSLF½_~·phcaa.org>,.l(_bl_(5_1
__ ~
>
l(b)(5)
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1--------->
> I Cc: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
l"Ninernire, Sandra" <[email protected]>, "Sipple-Asher, Bessie"
>
<BessieKo.SippleAsher(~ied.gov>, "Johnson, Debbe"
>
l<[email protected]>, "Foss, Ian" <[email protected]>
>I
>
> --------------------------------------------------------------------------
> ------------------------------------------1
>
1--------->
> I Date: I
> 1------------>
>
> --------------------------------------------------------------------------
>
106/21/2012 02:01 PM
>I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1--------->
> I Subject: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
> RE:
Kool Kidz World, Inc
>I
>
>---------------------------------------------------------------------------
> ------------------------------------------1
>
>
>
>
>
> Diane,
>
> I sec on the organization's website that it is a
non-profit organization:
> however, I'm not sure that's true. To be a
non-profit organization, the
> organization would need to have some sort of
structure, necessitating a
> filing, and I can find no record of the
organization existing (including
> Westlaw)--there is no EIN match or no
name match (either for Kool Kidz or
> the name of the individual running the
center). So, I don't think it's truly not-
> for-profit
>
> Further, even
if it is not-for-profit, it need~ to be liccn~cd or regulated child
> care.
New Jersey law require~ that child care center~ that serve ~ix or more
>
children be licensed (sec here:
>
http://www.11).gOvidclidiv 1~mnsilic.:n~mg/ccntcrs.html). If you cannot
find
> record of this center being licensed. then I don't think the
organin1tion
> qualifies. I'd note that, when looking at the entitie~ 1
>
tuition, they would need to ~erve ~ix or more children to earn enough
money
> to pay employees above the poverty level.
>
> If you like,
follow-up with the employer.
>
> Ian
>
> > -----Original Message-----
>>
From: Diane Freundel Lmailto:dfreunde:11-pheaa.or1tlOn BehalfOfFedLoan
>>
PSLF
>>Sent: Wednesda . June 20, 2012 3:46 P\1
>>To: (b)(5)
>>
~---~
Subject: Kool Kidz World. Inc
>>
>>
>>Hi, We can't find anything on
thi~ organization, other than their
> website that
> > ~ays they arc
non-profit. The NJ Bu~ines~ filing~ doesn't let you sec
> anything
>>
without paying, but it docs show that the ~ystcm retrieved a
> > record for
the name. They arc abo not li~tcd on Pub 78 or the B\1F.
>>
>>lfounda
list of licensed child care providers in the state of NJ. but
>>they
aren't listed there either. We appreciate your assistance.
> > Passvmrd
to follow. Thanks!
>>
>>(See attached file: Kool Kidz World Inc.zip)
>
>
>>Diane Freundel
>>Compliance Services
> > (717) 720-3267
>>fax-
(717) 720-3911
> > dfrcunde(cfphcaa.org
>>This message contain~ privileged
and confidential information intended
> for
> > the above addressees only.
If you receive this message in error

>>please delete or destroy this
>>
>>The sender of this message will fully
cooperate in the civil and
>>criminal pro~ccution of any individual
engaging in the unauthorized
> > u~e of this me~~age.
>
> This message
contain~ privileged and conlidential information intended for
> the above
addre~~ees only. If you receive this message in error please
> delete or
>
> The sender of this message
1,villfully cooperate in the civil and criminal
> prosecution of any
individual engaging in the unauthorized use of this
> message.
From: l(b)(5)
Sent: 13 Jun 2017 13:48:33 +DODO
To: FedLoanPSLF
Cc: 51~---~
Odom, Christian;Battle, Cynthia;Foss,Ll(b~l(~
Subject: Re: Law Office of Brian J Davis- Yuba County
Hi Kim,
FSAagrees with FedLoan's assessment that this employment would not qualify for PSLF.
Below is an excerpt regarding "Independent Contractor[s]" as outlined in the contract
provided in the zip file. It clearly states that independent contractors are not employees
of the County. Therefore, the borrower working under a for-profit organization as a
contractor with the County would not be eligible for PSLF.
In the denial letter that Fed Loan drafts could you reference some the information
provided in the the contract that was supplied. Additionally, correct us if we are wrong
but it also sounds like the borrower misrepresented himself on his initial ECF;in the
denial letter could FedLoan incorporate the language that is currently being used in the
for-profit retractions so that the borrower understands why their initial ECFwas
approved?
FSAwould like to review the letter before it is mailed our. Please let me know if you
have concerns. Thanks, Taneka
1-l (I h'r ..111rur,1,1.<;c-. ,.msmE u1:Jt1 tlu~ ,\)£:een:tn·. :\TTL1rne:, ~!ull he an
tndcpcndc:lt c01~'.rn.cto:-a~ prnv:Jcd b) ]a\\. and ,.\ttl•rn..:y and ..:ach ai:d every cmplPyec.
a~!':11. <;er,.-ant rartrn::-. ~r:::m:holde~. .:L1nt:-c1..:10~

and <;ubcnntr,1ctor of .\tt,1:-m:) ~h,dl no! be.
A[rccm..:nt sha:t r:c•t u:1Cer :my ci:-cu:n'itan..:c, bt· l'ut1,1Lll'Li l•r n 1 :>:J,.::::ll tn '."lea jdtnl
VL·:iturc,)' il __
l(ltnl p,,v.er~ Jgrtement ,is Jescr1hcJ i:i (Jo\t·mr:1cr:t l'u<lc ~ecti,11160UO ct
~t'I.J. L>r(,:htrv.:<,<c .\, ar. inGi:?e;:1.kn1co:nracw:-. t:lc fo:k>\\Jnl:' "h~-il!an'ly un,kr th,
:,1 he rr,,\ iJt:J ~';' AttLYllt'~as de'>..:riht·J1;1th1, Aut.':cmcm

_,-..:r\11;c<;
b: Atkrney ~h.1:I he rc,r\•n,1:J:c rn \01;r.ty t(,r the rcc_u:rcmcnts and rcsu!h
-.rc.:1~icJ tiy this ,\s~ccmi.:nt ;-m<l:.--hall!ll'I ·:--c~~~_1ec1

1,, (_\,t.n•y·s u>ntr0I with re~pt·d \(.'
e:11pl0y:•1emof \\llrker in<.urance nr hcndit cm·er,1gc required by any federal, 5tdte. ,1r
~ci.:urity Ol<l Age Prn~ton Pni~r:m:. Soc:,1: Security Di:--ahil1t~pn,grarr. or any other l;','L'
From: Kimberly A Myers <kmyers([(pheaa.org> on behalf of Fed Loan PSLF

Sent: Frida , June 9, 2017 12:26 PM
To: (b)(5)
Cc: Odom, Christian; l3attlc, Cynthia; Foss, Ian
Subject: Law Office of Brian J Davis - Yuba County
Hi Taneka! We had originally received this employer in late 2014. Based on the documentation
provided, it appeared to be a private, for-profit, law firm that was contracted by Yuba County to
perform public defender services.
We have now received a dispute letter from another borrower. In reviewing his file, it appears
that the Business Unit approved his prior employment (however, his original form was certified
under 'Yuba County Public Defender'). He attached additional documentation for review. In the
documentation it was noted that Yuba County does not have its own public defender office, so
they in turn contract with their specific law office for those services. I wanted to escalate as it
appears this would still be deemed as a government contractor, but your guidance is appreciated.
Password to follow. Also, I have a few more escalations to send over. The password will be the
same for all escalations. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Code:PHEAA
From: l(b)(5)
Sent: 23 Jul 2012 15:45:13 -0500

To: Fedloan PSLF
Cc: 5~1____
Ll(b~l~( _,I1an;Ninemire, Sandra;Sipple-Asher, Bessie;Johnson,
Debbe
Subject: Re: Law Offices of Robert R Bryan
Diane,
I cannot even find anything to confirm that thi~ organization

lS
incorporated/organiLed in any way. Therefore, I am inclined to
suspect
that it is ~omc sort or sole proprietorship or general
partnership,
neither of which can be not-for-profits.
Many attorneys
maintain that there is an inherently not-for-profit aspect
to their services
as to indigent clients, many ofwhom receive services
for free, or through
government-provided subsidies. As \Ve addressed in
the preamble to the final
PSLF regulation, this is insufficient to be
considered not-for-profit under
the PSLF Program. And, though California
!av,·specifically allows
profc~~ional law corporation~ predominately
~crving indigent client~ to
organi?c a~ a public benefit corporation (the
CA version ofa not-for-profit
corporation). I can find no indication that
thi~ i~ the case hcrc«again,
because I cannot find any record of this
of1ice being "organiLed" at
all.
Ian
On 7/20/12 13:32, "FedLoan PSLF" <FedLoanPSLF(iijpheaa.org>

\Vrote:
>
>Hi Ian, I checked all of the usual resources and couldn't
determine
>whether this firm is not for profit. As you can see on his
profile, Mr
>Bryan is a very high profile international attorney
specializing in
>human-rights litigation. He certified the form and
therefore. I think the
>office~ mu~t be not for profit but I can find no
confirmation. As
>always, we appreciate your input. Pa~~wordto follow.
Thanks.
>(Sec attached file: Law Offices of Robert Biyan.zip)
>Diane
Frcundcl
>(717) 720-3267
>fax- (717)
720-3911
>dfreun<le(d)pheaa .org
>This me~sage contains privileged and
confidential infonnation intended
>for the above a<ldres~ees only. If
you
message
>The sender of this message will fully

engagmg
From: l(b)(5)
Sent: 6 Feb 2012 12:22:37 -0600

To: Diane cl(b~)(~5~)
-----~
Cc: [email protected]
Subject: RE: Legal Aid Society of middle TN and the Cumberlands
Diane,
Thi~ qualifies as a 50l(c)(3) organin1tion because I found it as a

public charity in Pub 78. It'~ worry that ~o many borrowers arc just
choosing the last category of employment and ticking a public ~ervice
type.
Ian

Lmai Ito:d fre undefa·aess ucces s.org I
> Sent: Saturday, Februaty 04, 2012 7:18
PM
> To: ,_l(b_)(_51_~~
> Cc: [email protected]
> Subject: Legal Aid Society
of middle TN and the Cumberlands
> I believe this is a qualifying

private non-profit employer. Passv,rordto follow.
> Thanh!
> (Sec
attached file: Evan~_Lcgal Aid.zip)
> Diane Freundcl

> Compliance
Services
> (717) 720-3267
> fax-(717) 720-3911
> dfreunde(a;pheaa.org

attachments.
>
civil and criminal
> message.
--------------------------------
From: l(b)(5)
Sent: 12 Mar 2012 16:01:22 -0500
To: Fedloan PSLF
Cc: 51'--------'1
Ll(b-'l('- Sandra;Sipple-Asher, Bessie;Foss, lan;Johnson,
Debbe
Subject: Re: Leiva's Roll Off
Thi~ i~ indeed a for-profit entity and therefore doc~n't qualify.
A Wc~tlaw
~carch provided a little hit more information than did the
California
corporations ~earch, which indicated that it was a for-profit
entity.
I'll
also note that I found that it 1~ a pem1itted hauler of solid waste
in the
City of Los Angeles. See
here:
http :iird ms.1ac ity .or1tireporticache/Hau [erList. pdf.
This report from

the LA Department of Public Works describes the
regulatory scheme for the
collection of solid waste in the
city:
http://boe.lacity.org/docsidpv.'iagendasi201 I /20 I 105/20 l 10520/bos/20 l 105
20_ag
_ ha_ ho~_ l.pdf. Essentially, the Bureau of Sanitation provides its
own
~crvicc~ and liccn~c~other cntcrpri~cs to provide ~upplcmcntal
~crv1cc
via a permitting ~chcmc.
An application for permit can he found

here:
http://www.lacitv~an.urg/sol1d n:sourcesipdfsi201 li/\13939 Permit /\pp an
d Ter
ms_04-201 l.pdf.
On l2i3/12 13:44, "FedLoan PSLF"

>Hi. They didn't provide an EIN and

checked the government box. but I
>think they're for-profit and would like
to deny it for that reason. rather
>than for a missing EIN. I think they
arc a recycler that ha~ municipal
>contracts. Your thoughts? Pa~~word to
follow. Thanh!
>Additional research by Kim:

>- Checked box A on form.
>-
I googlcd their website and they offer municipaL commercial,
indu~trial
>and rc~idcntial recycling services. I couldn't determine if
they have a
>link to the state of California, etc.
>- /\ ~carch of their
Bu~incss filing~ doesn't indicate anything that is of
>u~c.
>
>(Sec allachcd
file: Lcivas Rollo ff Inc.zip)
>
>Diane Freundel
>(717)
720-3267
>fax- (717)
720-3911
>-------------------------------
>----
>This mc~sagc contain~ privileged and
confidential infomrntion intended
>for the above addrc~~ccs only. If
you
>receive thi~ mcs~agc in error plca~c delete or destroy this
message
>
>The ~ender of this me~~age will fully
engaging
>in the unauthorized use of this
message.
>================================================
>===
From: Sipple-Asher, Bessie

Sent: 24 Feb 2012 08:40:44 -0600
To: Ll(b-'-l('-51
__ _,I.FedLoan PSLF
Cc: Foss, lan;Ninemire, Sandra
Subject: RE: Lockheed Martin Defense contract
I think reaching out to the employer is prudent in thi~ ca~c to confirm that
the borrower i~ not a
contractor.
Thanh,
Bes~ie
From:
l(b)(5)
Sent: Wednesday, February 22, 2012 3:56 P\1
To: FedLoan PSLF;
!(b)(5) I
Cc: Foss, Ian; Ninemire, Sandra; Sipple-Asher, Bessie
Subject:
RE: Lockheed \1artin Defense contract
I'm almost positive that this

individual works for DOD, not Lockheed Martin. What this borrower did is
\vrite in the contract that she manages for the Defense Contract Management
Agency, abbreviated DMCA. and is on the header of the faxed ECF. See also
he re: http :iiwww .dcma. m iIic mo/Orlando/ contact. cfm
In mo~t case~, I think

the [IN i~ going to he the most authoritative information we ha\'c to
determine who the employer actually is.
Bc~~ic,do you think that PHEAA

should reach out to thi~ borrower because of the apparent conflict either hy
denying the ECF or by simply reque~ting more information? Or do you think
that we can approve thi~ one? I'm prelly confident that the DOD 1~ the
employer.

Lmailto:dfreundefa-aessuceess.orgl On Behalf Of
> FedLoan PSLF
> Sent:
Wednesda Februaty 22, 2012 3:26 PM
1
,
> To: L.(b-")(-'5)~~--'

> Subject: Lockheed
Martin Defense contract
>
>
> Hi, We know that Lockheed Martin is for
profit. We want to make ~urc
> there is nothing regarding the defense
contract~ that we're not aware of
> that would qualify thc~c employees.
The certifying official checked
> government and the EIN provided is used

for civilian employees with the
> Defense Dept (~cc No. 25, page 3 of
attached Federal Agency EIN list).
>
> Pas~word to follow. Thanks.
>
>
(Sec attached file: Baker_ Lockheed Martin.zip)
>
> Diane Frcundcl
>
Compliance Service~
> (717) 720-3267
> fax-(717) 720-391 I
>
>
>

attachmcnb.
>
civil and criminal
> message.
>
>

__ _,
Sent: 3 Mar 2014 13:08:08 -0500
To: Fedloan PSLF
Cc: l(b)(5J !;Johnson, Debbe;Battle, Cynthia;Foss, Ian
Subject: Re: Major Health Partners
Hi Diane,
I agree that this qualifies a~ a local government entity. Note that the
organin1tion EIN in Wcstlaw tics to 'Major Hospital".
1
~
Ian
On 3/3/14, 10:16, "FedLoan PSLF" <FedLoanPSLF(a/pheaa.org> wrote:
>
>Hi Ian, We're having trouble with this one.
>
> 1. ECF certifies private non-profit
>
>2. We found the association between Major Health Partners and \1ajor
>Hospital (attachment \1ajor Health Partners)
>
>3. A search on the IN business filings for Major Health gave one result
>(Business filing_Major Health Search)
>
>4. From the \1ajor Hospital website - History - indication that they are
>chartered as a city/county facility (History)
>
>5. Major Ho~pital hu~incss filing indicates they were formed pursuant to
>IC
> 16-22-8-6. "other entity" under 23-15-1-5-. to provide for a~~umcd name
>
>6. Indiana Code references arc included as attachments
>
> 7. Major I Iospitab 50 I ( c )(3) status wa~ revoked a~ of Sil 5/ 11
>
>We think they arc government. Do you agree? Password to follow.
>thanks!
>
>(See attached file: Major Health Partners.zip)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>
From: l(b)(5)
Sent: 31 Dec 2012 08:40:54 -0600
To: Fedloan PSLF
Cc: 5~1____
Ll(b~l~( _,I1an;Ninemire, Sandra;Sipple-Asher, Bessie;Johnson,
Debbe
Subject: Re: Make It Right
Diane,
For thi~ one, it took me a while, hut I di~cm·crcd that Make It Right New
Orleans, LLC (EIN 26-2398097) i~ a wholly owned subsidiary of the \1akc It
Right Foundation (EIN 26-0723027). The foundation is a 50l(c)(3) in its
own right; the LLC 1~ not. Additionally, I could not pull the LLC\
articles of organiLation: however, I pulled the Fom1 990 of the
foundation, and found that the LLC is a disregarded entity orthe
foundation, meaning that the 50l(c)(3) status passed through from the
foundation to the LLC.
See Schedule R of the Foundation's 2010 Fonn 990 here:

http://makeitright.orl!/wp-contentiuploadsi20 12/08/20 I0-990.pdf.
So, this one qualifies as a 50l(c)(3).
Ian
(b)(5)
>Thanks again for your help. Password to follow.

>
>(See attached file: Make it Right.zip)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>
From: l(b)(5)
Sent: 30 Sep 2015 19:47:42 +ODDO

To: Fedloan PSLF
Cc: l(b)(5J ICynthia
Subject: RE: Maple Star Colorado
Hi Diane,
We agree with your finding~ - Unfortunately, Maple Star doc~ not provide a qualifying service. The job
descriptions that arc li~tcd throughout Maple Star do not fall within the Standard Occupational
Classification (SOC) categones that qualify.
Thanh.
Taneka
From: Diane Freundel Lmailto:dfreunde:11-pheaa.or1tJOn BehalfOfFedLoan PSLF
Sent: Wednesda 1 , August 19, 2015 4:13 P\1
To: (b)(5)
Subject: Maple Star Colorado
Hi Taneka, We denied this employer, but the borrower has disputed our
denial, so \ve'd like your confirmation that the employer does not quality.
We had determined that although they are not-for-profit, they do not
provide a qualifying service (they are not 501(c)(3)]. Their website
indicates that they provide foster care & adoption services, and clinical services. We looked at the staff
listing and job openings and we don't sec anything that indicates they have employees that fall under one of
the eligible Standard Occupational Classification (SOC) categories that qualify
for PSLF purpose~. The borrower provided a copy of the organization's
Articles of Incorporation which indicate that they arc organized to provide ~ocial and human ~crvicc~,
con~ultation and training to other provider~ of ~ocial and human ~crvicc~, and conduct rc~carch in the field
of social and human service~.
We can't find anything indicating that they provide a qualifying public service. Plea~e lei u~ know if you
agree. Password to follow. Thanks!
(Sec attached file: For FSA.Lip)
Diane Freundel
Compliance Services
(717) 720-3267
fax-(717) 720-391 I
--------------------------------
Codc:PHEAA
From: l(b)(5)
Sent: 21 Feb 2012 15:39:27 -0600

Subject: RE: Marshalltown Water Works - City of Marshalltown
That the annual audit states that the entity is a component unit of the
city, I am comfortable approving this E(T a~ a governmental employer at the
local level. Based on the city'~ wcb~itc and the wcb~itc of the entity, I
think thi~ i~ quasi-government but qualifying.
> -----Original
Message-----
> From: Diane Freundcl [mailto:dfr.:Lmdc:,rn.:ssucccs~.orgl On
Behalf Of
> FedLoan PSLF
> To:
l(b)(5)
> Subject: Marshalltown Water Works - City of Marshalltown
>
>
> Hi, Similar to the housing authority, we're unsure what to review for
these
> types of employers. They did check box a for government.
> Their
Independent Auditors' Report as of June 30, 2011 and 2010 states they
> are
"a component unit of the City of Mar~halltown". Pa~~word to follow.
>
Thanh.
>
> (Sec attached file: Wilson [CF.7ip)
>
> Diane Freundcl
>
Compliance Service~
> (717) 720-3267
> fax-(717) 720-3911
>
>
>

attachmcnb.
>
civil and criminal

> message.
>
--------------------------------
>
From: l(b)(5)
Sent: 9 Feb 2012 11:13:49 -0600

Subject: RE:Mecklenburg Area Catholic Schools
Out of an abundance of caution. let'~ hold off for now.
> -----Original
Message-----
> From: Diane Freundel [rnailto:dfrcLmdc:g,acssucccs~.org] On
Behalf Of
> FedLoan PSLF
> Sent: Thursday, February 09. 2012 11:51 AM
> To:
l(b)(5) I
> Cc: Sipple-Asher, Bessie; [email protected]; Foss, Ian;
!(b)(5) I
> N inemire, Sandra
> Subject: RE: Mecklenburg Area Catholic
Schools
>
> Thanks Ian. This is very helpful, One thing I'd like to
clarify in light
> of the conversation you had with \tlatt today. Can \Ve
approve this one?
>
> Diane Freundel
>(717)
720-3267
> fax-(717) 720-3911
> dfrcundc(c(phcmuirg
>
>
> 1------------>
>
I From:
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
lpublicservice Ll(~b)~(5~1
______ _,
>I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
> I To: I
> 1------------>
>
>---------------------------------------------------------------------------
>
l"FcdLoanPSLF½_~-phcaa.org"<f-cdLoanPSLF((j)phcaa.org>
>I
>
> --------------------------------------------------------------------------
> ---------------------------------------------1
>
1--------->
> I Cc: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
lpublicservice .l(_bl_(5_1
_______ "Foss. Ian" <[email protected]>. ~1
>
"Ninemire. Sandra" <[email protected]>, "Sipple-Asher, Bessie"I
>
l<Bess ie Ko.Si ppleA sher(~ied. gov>
>I
>
> --------------------------------------------------------------------------
> ------------------------------------------1
>
1------------>
> I Date: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
IU2/08i2012 02:22 PM
>I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
> I Subject:
> 1------------>
>
> --------------------------------------------------------------------------
> ------------------------------------------1
> RE:
Public: Mecklenburg Arca Catholic Schools
>
>
>---------------------------------------------------------------------------
>
>
>
>
>
> Diane,
>
> This ~till shows up a~ private, but I'll reproduce the
content. below.
>
> In short. You're correct, and arc not confu~ing
anything that we talked about
> on the phone yesterday. This organization
does not show up in Pub 78, but
> does show up in the BMF. When I looked in
the BMF and saw an affiliation
> code of "9". it indicated to me that this
is a subordinate of a group exemption
> by the IRS. As such, it might not
appear separately in Pub 78. It's
>unfortunate.but true. However, it is
a 501(c)(3) organization, and, as such.
> qualifies.
>
> The group
exemption number is 928, meaning all other organization covered
> by the
group exemption letter will have the same number. In the relevant
> B\1F,
there arc no less than 43 organiLations with group exemption number
> 928,
and we wouldn't have a full count unless we received a data dump of all
> of
the BMFs. None of the affiliation codes in the relevant BMF were
> anything
other than 9, so I looked at the Georgia B\1F to see if! could find
> the
parent organization (suspecting the parent is the Archdiocese of Atlanta,
>
\vhich has jurisdiction over North Carolina) and came up with nothing, but
>
there is a pattern. All those \vith group exemption number 928 are
Catholic.
>
> Turns out, the Catholic Church is very centrally organized.
The parent
> organin1tion i~ the United State~ Conference of Catholic
Bishop~ here in
> Washington, DC. If you look at the BMF for DC. you can
find it (EIN:
> 530196617: group exemption number 928: affiliation code of
"8"). You can
> also find a copy of a letter from the IRS to the Conference
here:
> http: '/old. usccb.orgiogcigroup-ruli ng-20 I 1.pdf
>
> Of cour~c, you
could have ~topped a~ soon as you found the [IN from the
> ECF in the
relevant BMF. I wa~ just belaboring the point about group
> exemptions.
>
> Ian
>
> The certifying official checked box c and "other school ha~cd
services.
>
> EIN - 00-56-1779865
>
> Just to see what we vmuld come up
1Nith,I checked both Pub 78 and the
> Business Master File. There are no
results in Pub 78, but they are in the BMF
> \vith a subsection code of 3.
Screen shots attached. I apologize for my
> confusion on the IRS information
that we review.
>
> My understanding:
> Pub 78 include~ only 501 (c)(3)
organin1tion~.
> The BMF contain~ all tax-exempt organization~. Within the
BMF. 501(c)(3)
> organinllion~ have a ~ub~cction code of 3.
> Therefore, I
would assume that if an organiLalion has a subsection code of
>3onthe
BMF, it ~hould also he found in Pub 78. \1y results do not ~upporl
>my
a~~umption. Again, my apologie~ for my confu~ion.
>
> An additional
question is in reference to the fact that it is a Catholic School.
> We
checked their staff list and the botTower is a healthiphys ed teacher.
>
>
(See attached file: Pub 78 pg 1.pdf)
>
> (See attached file: Pub 78 pg
2.pdf)
>
> (Sec attached file: from IRS B\1f-.xbx)
>
> Thanh!
>
> Diane
Freundcl
> (717) 720-3267

> fax- (717) 720-3911
>
d fn:unde((_l'.pheaa.org
>
--------------------------------
>

> the above addressees only. Ir you receive this
message in error please delete
> or dc~troy this message and/or
allacbmcnt~.
>
civil and criminal
> message.
>
--------------------------------
>
>
>>-----Original Me~~age-----
> > From: FedLoan
PSLF [mailto:securemail.d-39448220-
>>
2nZk5 FDTX3cwTGW A((_l'.~eeuremai
l.aes~uece~~.orgl On Behalf Of FedLoan
> PSLF
>>
Sent: W ednesdav, February 08, 2012 I :23 P\1
>>To: l(b)(5) I
>>
Subject: Public: \1ecklenburg Arca Catholic Schoob
>>
> > You have a secure
email message waiting for you from FedLoan PSLF at
> > AES/PHEAA with the
subject: Public: Mecklenburg Area Catholic Schools.
>>
>>How to Retrieve
Your Message
>>
>>To retrieve your message from FedLoan PSLF with the
subject: Public:
>>Mecklenburg Area Catholic Schools, go to:
>>
http~:i/sceurcma i I.aessueecs ~-orgimc~~en l!er/msg'?x-d- 39448220-
>>
2nZk5FDTX3cwTGWA
>>
>>This message will be available until 04/08/2012.
>
>
>>Why You Are Receiving this Email

>>
> > A[S/PH[AA ha~ sent you a
message that may include sensitive
>>information
> or
> > personal data,
a~ defined by federal law. To protect the privacy of
> > this information,
the email has been encrypted.
>>
>>
> > Personal data protected by federal
law includes:
>> Social Security numbers
>> Driver's
license numbers
>> credit repotts/scores
>>
>>
>>If you have
questions regarding the authenticity of this message,
>>please
> visit
>>
us onlinc at www.ac~Succcss.oru/sccurcmail, or contact us:
>>
>>Phone:
1-800-233-0557
>>[mail: ccomm(j_i;ac~~
ucccss. org
> > Po~tal mail:
/\ES/PJIEAA
>> 1200 N 7th St
>> Ilarrisburg, PA
17102
>>
>>
>>
>
>>
>>This message contains privileged and confidential

> for
>>the above addressees only. If you receive
this message in error please
> delete
>>or dc~troy thi~ message and/or
attachmcnb.
>>
>>The sender of this message will fully cooperate in the
civil and
>>criminal pro~ccution of any individual engaging in the
unauthorized
> > u~c of this me~~age.
>>
>
--------------------------------
>>
>>
>>
>>
>>
>>
>>
>>
>>
>
>
>
>
>
>
--------------------------------
>

attachmcnb.
>
civil and criminal
> message.
>
>
From: l(b)(5)
Sent: 4 May 2017 18:04:10 +DODO

To: Fedloan PSLF
Subject: Re: Medica Health Plan
Thank you for the prompt reply on the Business Unit's review process. We would still
like to review the letter for this organization.
- Taneka

<[email protected]>
Sent: Thursda , May 4, 2017 12:47:07 PM
To: (b)(5)
Cc: Odom, Christian; Battle, Cynthia; FedLoan PSLF; Foss, Ian
Subject: Re: Mcdica I lcalth Plan
Hi Taneka! There is definitely some inconsistencies in the certifications on these ECFs. Our
thought is that the borrower just completed the form and the official signed without even reviewing
the responses (which we knows goes against what they are actually certifying).
However, while reviewing an ECF for eligibility, the only time the Business Unit will deny the
employer right away is if all three boxes (9, 10, and 11) are checked "no" designating ineligibility.
If the borrower/employer checks "yes" to any box, they will review further or escalate to
Compliance as needed. The Business Unit will review prior decisions and will process based on
the prior decisions, except if it has been more than one year since approved. If it has been more
than one year since approval, the employer will be reviewed based on procedures and the
applicable websites, etc, used to qualify an employer (or escalated to Compliance as needed).
Please let me know if you have any other questions. I will notify the Business Unit to retract this
denial. Would you like to see the retraction letter before going to the borrower?
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
lrorn i(b)(5) li(b)(5) I

Io FedLoan PSLF <[email protected]>
Cc !(b)(5) U(b)(5) !"Battle, Cynthia" <[email protected]>, "Foss, Ian" <[email protected]>,
"Odom, Christian" <[email protected]>
LJc1lH 05/04/2017 09:44 AM
Suh Hci [external]Medica Health Plan
Hi Kim,
Medica Health Plan can be retracted. They do not provide public health as their primary
purpose.
One thing that we noticed while reviewing the ECFsfor Medica is that there are three
forms that were approved by the same person but the forms do not have consistent
reasons listed for how the organization qualifies. For example, the same certifying
official has checked the box that the organization, "does not qualify" on one form, that
the organization is governmental in another form, and finally that the organization
qualifies under Public Health, Public Services for the Elderly, and Public Education. When
the business unit reviews an ECFthat has a check that the "Organization does not
qualify" will do they normally deny the organization or check to see if the organization
has a previous approval and base their decision off of what is on the system? I'm not
sure if we discussed these type of scenarios since they do not happen often.
Thanks,
Taneka
and/or attachments.
Code:PHEAA
From: l(b)(5)
Sent: 27 Apr 2015 08:16:34 -0500

To: Fedloan PSLF
Cc: !(b)(5) I
Subject: RE: Menominee Casino Resort
Hi Diane,
I consulted with Ian on this one and while we could not find where it explicitly states that the
Menominee Casino Resort is "the tribe" we think they do qualify based on the fact that Menominee
Casino Resort is a tribally chartered entity. The court case was an interesting read, it looks like the
federal court ultimately dismissed the case (not on the basis of sovereign immunity), but because the
plaintiff did not follow correct protocol and brought his case to the federal court before first going
through the Tribal Court system. However, the fact that the federal court would defer to the Tribal Court
in hearing the case also leads me to believe that the tribe qualifies.
Please let me know if you have any concerns/questions.
Thanks,
Taneka
Sent: Thursday, April 09, 2015 3:32 PM
To: l(b)(5J I
Subject: Menominee Casino Resort
Hi Taneka, It was nice meeting you last week! We have another tribal
casino we'd like to run by you. Our initial review made us believe they do not qualify. However, we
found a court case from 1995 (Barker v. Menominee Nation Casino) that, if we're interpreting it
correctly, says that the defendants' dismissal motions must be granted. It states they are immune from
suit in federal court because they were issued a corporation charter by the Legislature through a tribal
ordinance and pursuant to the Tribal Constitution and they are a tribal enterprise. Pgs 5-6 of Barker v.
Menominee Nation Casino. Please let us know if you agree. Password to
follow. Thanks!
(See attached file: Menominee Casino Resort-Menominee Indian Tribe of
WI.zip)
Diane Freundel
Compliance Services
(717) 720-3267
[email protected]
From: l(b)(5)
Sent: 29 Nov 2013 14:53:09 -0600

To: Fedloan PSLF
Cc: l(bl( 5l I
lan;Johnson, Debbe;Battle, Cynthia
Subject: Re: Methodist Counseling Center
Hi Diane,
I agree that if they were part of the church that they would qualify under
the 50 I (c)(3) category, but I don 1 think they arc since they have their
1
own articles of organiLation. When I search for the organization on

Wesllaw, I pull up another organiLation with the same name, but with a
dil1Crenl EIN (20-5618020) located al I Ith Street in Boise, Idaho.
I think it's pretty clear that they would not qualify under public health,
a~ they don't ~eem lo employ anyone with a job that corre~ponds to those
listed in the proper SOC Codes.
Given that the articles oforganization reference 501 (c)(3)s several

places, I'm guessing that they're going for 50l(c)(3) status but don't
have it yet, which is not surprising given that they only recently
organized.
So, I think this organization doesn't qualify (for now).
Ian
On 11/25/13, 20:04, "FedLoan PSLF" <[email protected]> wrote:
>
>Hi Ian, This i~ another one we're having trouble with. We can't tell if
>they're actually part of the church, and therefore 501(c)(3).
>
> 1. ECF certified as providing public health services, but neither box a,
>b, nor c wa~ checked.
>
>2. Page 2 of the "wellne~~" attachment de~cribes their mission as faith
>ba~ed counseling.
>
>3. HIPPA Space entry indicates they are an organization that provides
>community/ behavioral health
>
>4. Business filing lists them as non-profit
>
>5. Articles of Organization indicate they provide pastoral care and
>counseling.
>
>If they are a private non-profit, \Ve don't think they provide a qualit)'ing
>public service since they provide counseling. However, if they are a part
>of the church, they would qualify as 501 (c)(3). Your thoughts'?
>Password
>to follow. Thanh!
>
>(Sec attached file: Methodist Counseling Center.zip)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>dfn;undc((j)phcaa.org
>This mc~sagc contain~ privileged and confidential infonnation intended
>
>The ~ender of this me~~age will fully cooperate in the civil and criminal
From: l(b)(5)
Sent: 16 Feb 2016 21:15:58 +0000

To: Fedloan PSLF
Cc: l(b)(5J ICynthia
Subject: RE: Missouri Foundation for Health
Hi Kim,
It looks like the Missouri Foundation of Health employs a nurse; however, her job title is not in
field and does not appear to be health services related. Additionally, as you stated below, the
organization does not seem to provide services directly to the public. Therefore, we agree that
Missouri Foundation of Health does not qualify for the purposes of PSLF.
Thanks,
Taneka
To: !(bl(51 I
Subject: Missouri Foundation for Health
Hi Taneka!
I apologize for all of the emails today, we were working through some of our outstanding employers. This
is the last one, I promise : )
This organization is 501(c)(4) that we had previously denied. They are more of an association and do not
provide any qualifying services--specifically health, as they'd certified.
The business unit denied a second borrower as a result of our original finding, and they submitted
additional information. They submitted the articles of incorporation with part of the purpose highlighted:
" ...with the purpose to ...identify and fill the gaps in the myriad of public and private health services already
available to the uninsured and underinsured in the 84 counties comprising the former service area of Blue
Cross and Blue Shield of Missouri."
We still believe that this organization does not provide a qualifying service, as it does not appear they
provide health services directly to the public. It seems they primarily issue grants to health-focused not-
for-profits.
Your input is appreciated. Same password as others. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: Foss, Ian

Sent: 8 Jun 2017 01:32:38 +0000
To: Odom, Christian
Cc: l(bl(5l I Taneka;Battle, Cynthia;Oldre, Lisa
Subject: Re: Ms. Kaitlyn Rodriguez (ECS00987744)
(b)(5)
On Jun 7, 2017, at 20:26, Odom, Christian <Christian.Odom(d;ed.gov> wrote:
One other question. Isn't the email belO\v asking for a response to the
borrower? I'm not sure Tony knows FSA has already revie\ved and that
likely would be the gist of the response.
Sent from my iPhone

Christian Lee Odom
U.S. Department of Education:: Office of Federal Student Aid
50 United Nations Plaza:: San Francisco CA 94102
(P) 415.486.5683 :: (M) 415.533.7556
Instant Message Mc On Skype for Business
On Jun 7, 2017, at 5:21 PM, Odom, Christian <Christian.Odom(d;ed.gov>

wrote:
Sorry Mike. This mailbox was for handling the employer review
or explanation of past review in this case. If I'm not mistaken,
Jana's area \vould handle congressional responses. Is that still
correct Lisa?
Sent from my iPhone

Christian Lee Odom
U.S. Department of Education:: Office of Federal Student Aid
50 United Nations Plaza:: San Francisco, CA 94102
(P) 415.486.5683 :: (M) 415.533.7556
Instant Message Mc On Skvpc for Business
On Jun 7, 2017, at4:08 PM, ~l(b_l(5_1

__ ~
<publicservice(i'l'.ed.gov> wrote:
Hi Michael,
+ Cindy and Ian
Thank you for forwarding. I read the letter and this

borrower was previously escalated to FSAon
February 12, 2016, as a denial dispute of a
retraction that was internally decided by FedLoan.
FSA reviewed the organization and January 11th
dispute letter and determined that the Association
of Independent Colleges & Universities in
Massachusetts did not qualify for PSLF.Our
decision was sent to the servicer on March 7th who
generated and appeal denial letter to the
borrower.
To provide some background - The Association of

Independent Colleges & Universities in
Massachusetts (AICUM) is a 501(c)6 who primarily
provides advocacy services to its member
university and colleges. While these advocacy
services provide assistance to their member
institutions; currently, FSAdoes not consider
advocacy to be a qualifying public service for the
purposes of PSLF.
Unfortunately, as far as I'm aware, our unit does

not respond to Control Mail disputes. In the past
we have provided research and information but I'm
not sure who will ultimately handle this
request/response.
Thanks,
Taneka
From: 11les,Michael
To: !(b)(51 I
Subject: FW: Ms. Kaitlyn Rodriguez (ECS 00987744)
<image00l.jpg>
FYI..
From: King, Antrole

Sent: Wednesday,June 07, 2017 11:08 AM
To: Illes, Michael
Cc: Ford, Juanita
Subject: Ms. Kaitlyn Rodriguez(ECS00987744)
Good Afternoon,
We received a call from the borrower regarding

their certification for PLSF and her employer. She
has provided documentation that notified her that
the organization in which she was employed, met
the criteria for PLSF and then received notification
that there was a mistake. She would like FSA to
consider the original notification and would like FSA
to respond.
Ms. Ford was initially contacted because there was

a Controlled response sent by Senator Warren on
behalf of the borrower. Can you review the
attached documentation and initiate the appropriate
FSA response to the borrower?
The borrower can be reached at 617-513-1883 if

needed.
Tony King
Senior Loan Analyst

U.S. Department of l::ducation
Busine:-.s Operations
500 \Vest Madison, Suite 1520
Chicago, Illinois 60661
Telephone :--Jumber: 312.730.1(140
Fax :--Jumber: 312.730.145(1
<image002.png>
This transmission may contain information that is
privileged, confidential and/or exempt from disclosure
under applicable law. If you are not the intended recipient,
you are hereby notified that any disclosure, copying,
distribution, or use of the information contained herein
(including reliance thereon) is STRICTLY PROHIBITED. If
you received this transmission in error, please immediately
notify the sender and destroy the material in its entirety,
whether in electronic or hard copy format. Thank you.

__ _,
Sent: 23 Jan 2014 11:59:09 -0500
To: Fedloan PSLF
Cc: 51'-------'1
Foss, Ll(b-'l('- Cynthia;Johnson, Debbe
Subject: Re: MSTAR Academies
Hi Diane,
1 m guess that this is an organization that ha~ fikd for 501(c)(3)

1
~tatu~,hut ha~ not yet received it from the IRS. When the IRS ultimately
grants it, I'm sure it will be rclroaetivc to the dale that the
organiLation formed, hut until then, il would need to qualify on the basis
of providing a qualifying service. As they do nol currently do ~o (lhc
school 1~ not open, as you note), the organization docs not qualify. Ir
and when it is granted 501(e)(3) slalu~, it will be eligible hack to the
el1Cetive date of the IRS's determination.
Ian
>
>Hi Ian, We \vanted your thoughts on this one. Employer is non-profit and
>will provide public education, but based on several Linkeln profiles
>(borrower, owner, presumably owner's husband), we don't think they \viii
>open until 2015. I don't think we can approve since they are not yet
>providing a qualifying public service. Do you agree?
>
>
>(Sec attached fik: mStar Acadcmic~.zip)
>
>Diane Frcundcl
>(717) 720-3267
>fax- (717) 720-3911
>This mc~sagc contains privileged and eonlidenlial information intended
>for the above addres~ces only. If you
>
From: Foss, Ian

Sent: 25 Jan 2017 16:55:03 +0000
To: !(b)(5) I
Subject: RE: National Conference of State Legislatures - Possible Retraction
My quick research didn't turn up much. Can have compliance reach out to the organization to get more
information about its legal structure?
From: l(bJ(5J I
Sent: Wednesday, January 25, 2017 10:12 AM
To: Foss, Ian
Subject: FW: National Conference of State Legislatures - Possible Retraction
0 I wanted to forward this to you since there are 22 borrowers impacted. I'm going to research it later
today. PW to follow.
Thanks,
Taneka
From: Kimberly A Myers [mailto:[email protected]] On Behalf Of FedLoan PSLF

To: !(bl(51 I
Subject: National Conference of State Legislatures - Possible Retraction
Hi Taneka!
This employer was first escalated to Compliance in November 2016. The employer checked the
government box on the form. However, we found that this organization is actually a bi-partisan non-
governmental organization that serves the members and staff of state legislatures. By definition, we
found that a non-governmental organization is a not-for-profit that is independent from states and
international government organizations. Being not-for-profit, in order to qualify for PSLF, they would have
to perform a qualifying public service. Since their objectives are to improve the quality and effectiveness
of state legislatures; promote policy innovation/communication among state legislatures; and ensure the
voices of state legislatures in the federal system, they would not qualify for PSLF purposes. We
ultimately denied the organization.
The Business Unit has indicated that they have internally approved this organization in the past.
Therefore, I am now submitting for a possible retraction.
It appears that overall 22 borrowers were approved under this employer. The oldest date approved was
May 12, 2012.
Attached is the information we found as well as a few of the ECFs. I only attached a few, as they were
mainly all certified by the same individual under the same category (Diane Chaffin certified ECFs for 20 of
the borrowers while another 2 had their ECF certified by Mary Wild). If you would like the remainder of
the ECFs, I can certainly pull them and send them to you.
Your assistance is appreciated. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: Foss, Ian

Sent: 25 Jan 2017 16:05:48 +0000
To: !(b)(5) I
Subject: Re: National Conference of State Legislatures - Possible Retraction
Any chance we could consider them an intergovernmental organization? These types of

organizations usually are created by the state governments, themselves, even if it's a
50l(c)(6)/(4) organization...
I'll poke around on Westlaw.
51___
On Jan 25, 2017, at 10: 12, Ll(b_l(_ ~1
<publicscrvicc({l,,cd.gov> \Vrote:
(0) I
wanted to fonvard this to you since there are 22 borrowers impacted. I'm going to
research it later today. PW to follov.'.
Thanks.
Taneka
From: Kimberly A Myers [mnilto:krnversfa-pheaa.orgl On Behalf Of Fed Loan PSLF
Sent: Wednesda,, January 25, 2017 8: 15 AM
To: l(b)(5) _
Subject: National Conference of State Legislatures - Possible Retraction
Hi Taneka!
Thi~ employer wa~ fir~t escalated to Compliance in November 2016. The employer checked the
government box on the form. However. we found that thi~ organization is actually a bi-partisan non-
governmental organization that ~ervc~ the member~ and ~taff of state legislature~. By definition, we
found that a non-governmental organization is a not-for-profit that is independent from slates and
international government organization~. Being not-for-prolil, in order to qualify for PSLF, they
would have to pcrfonn a qualifying public service. Since their objective~ arc to improve the quality
and effectiveness of stale lcg1~laturcs: promote policy innovation/communication among state
lcg1~laturcs: and ensure the voices of~tate legislature~ in the federal system, they would not qualify
for PSLF puq1oscs. We ultimately denied the organization.
The Business Unit has indicated that they have internally approved this organization in the past.
Therefore. I am now submitting for a possible retraction.
It appears that overall 22 borrowers were approved under this employer. The oldest date approved
wa~ May 12, 2012.
/\llachcd is the information we found as well as a few of the ECFs. I only attached a few, as they
were mainly all certified by the same individual under the same category (Diane Chaffin certified
ECFs for 20 of the borrowers while another 2 had their ECF certified by Mary Wild). If you would
like the remainder of the ECFs, I can certainly pull them and send them to you.
Your a~~1~tancc1~appreciated. Password lo follow. Thanks!
Kimberly A Myers
Compliance Services
kmvers(dpheaa.org
(717) 720-2630
The sender of this message will fully cooperate in the civil and criminal prosecution
Code:PHEAA
From: Foss, Ian

Sent: 15 Jun 2017 17:00:43 +0000
To: !(b)(5) I
(b)(5)
On Jun 15, 201 7, at 11 :45, Ll(b_l(_51

___ 0
! L(b_l(_51
_______ _, wrote:
Hi Ian,
I haven't sent anything out. My understanding is that it is still on hold

pending a decision from OGC.
Thanks,
Taneka
From: Foss, Ian

Sent: Thursda , June 15,2017 10:08 AM
To: (b)(5)
What's the current status of this? Did we make a decision? I can't find
anything after this email.
On Feb 2, 2017, at 11:22, Ll(b_l(

__
51__ _,!L(b __
l(_51
_______
0
wrote:
Hi Kim,
Thank you for providing this additional documentation. FSA will

be escalating the National Conference of State Legislatures to
OGC for a final determination. We will update you when a
decision is made.
Kind regards,
Taneka
From: Kimberly A Myers <kmvcrs(hpheaa.org> on behalf of

FedLoan PSLF <FedLoanPSLF((l;,pheaa.org>
Sent: Thursday, February 2, 2017 9: 13:55 AM
To: !(b)(51 I
Cc: Odom, Christian; Battle, Cynthia: FedLoan PSLF: Foss, Ian
Subject: Re: RE: National Conference of State Legislatures - Possible
Retraction
Hi Taneka! Just wanted to follow-up on this one.
The Business Unit called the Authorized Official, Diane Chaffin, and
she stated the National Conference of State Legislatures is the
instrumentality of all states. She stated they are funded by all 50
states and they also get donations. She stated they are considered a
Government organization with the EIN is 84-0772595.
They also asked for Articles of Corporation and she stated they do not
have that but she provided the attached IRS letter.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From l/bl/51 lirbl/51 I

Cc "Batlle, Cynthia" <C nth1a.Battle ed. ov> "Fossi Ian"' <[email protected]>, '"Odom,
Christian" <[email protected]>. b 5 i(b)(5 I
Date 01/2512017 03.39 PM
SulJ_ect [external]RE. National Conference of State Legislatures - Possible Retraction
Hi Kim,
Could you have the businessoffice reach out this organization for more
information on their legal structure before we proceed with retracting these
borrowers? Ian and I started researchingthe organization but did not
uncover much in our search.
Thanks,
Taneka
From: Kimberly A Myers [mailto:[email protected]] On Behalf Of

Fedloan PSLF
To: !(bl(51 I
Subject: National Conference of State Legislatures - Possible
Retraction
Hi Taneka!
This employer was first escalated to Compliance in November 2016.

The employer checked the government box on the form. However,
we found that this organization is actually a bi-partisan non-
governmental organization that serves the members and staff of state
legislatures. By definition, we found that a non-governmental
organization is a not-for-profit that is independent from states and
international government organizations. Being not-for-profit, in order
to qualify for PSLF, they would have to perform a qualifying public
service. Since their objectives are to improve the quality and
effectiveness of state legislatures; promote policy
innovation/communication among state legislatures; and ensure the
voices of state legislatures in the federal system, they would not
qualify for PSLF purposes. We ultimately denied the organization.
The Business Unit has indicated that they have internally approved
this organization in the past. Therefore, I am now submitting for a
possible retraction.
It appears that overall 22 borrowers were approved under this

employer. The oldest date approved was May 12, 2012.
Attached is the information we found as well as a few of the ECFs.

only attached a few, as they were mainly all certified by the same
individual under the same category (Diane Chaffin certified ECFs for
20 of the borrowers while another 2 had their ECF certified by Mary
Wild). If you would like the remainder of the ECFs, I can certainly pull
them and send them to you.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
This message contains privileged and confidential information

intended for the above addressees only. If you receive this
message in error please delete or destroy this message and/or
attachments.
The sender of this message will fully cooperate in the civil and
criminal prosecution of any individual engaging in the
unauthorized use of this message.
Code:PHEAA
From: l(b)(5)
Sent: 17 Feb 2017 20:43:50 +0000

To: Fedloan PSLF
Cc: l(bl(5l ICynthia;Foss, lan;Odom, Christian
Subject: RE: National Insurance Crime Bureau
Hi Kim,
FSAwill be escalating the National Insurance Crime Bureau to OGCfor review.
Thank you,
Taneka
5~1-~~
From: l~(b_l(
Sent: Wednesday, February 151 2017 11:48 AM
To: Fedloan PSLF;l(bJ(5J I
Subject: RE: National Insurance Crime Bureau
Hi Kim,
Thank you. We'll start reviewing. I plan to send an update on a few of our pending escalations and
retractions on Friday.
Thanks,
Taneka

Sent: Tuesda , February 14, 2017 1:53 PM
To: (b)(5)
Subject: National Insurance Crime Bureau
Hi Taneka! This should hopefully be my last email of the day: ) We were re-evaluating this employer
that was previously approved. We wanted your opinion. as we are torn on whether this should be a
retraction or remain approved.
This employer certified as private not-for-profit providing law enforcement (and were ultimately approved
under this category). They are 501 (c)(4). They partner with insurers and law enforcement agencies to
facilitate the identification, detection and prosecution of insurance criminals. Specifically (according to
their bylaws), they conduct investigations of insurance-related crime and fraud and facilitate, whether
through litigation or otherwise, the recovery of stolen or wrongfully obtained property or funds and return
the property or funds to the victims.
I didn't have the BU query for other impacted borrowers at this point, as I wasn't sure if it would be a
retraction. Please let me know how you would like us to proceed.
Password the same as previous escalations today. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: Foss, Ian

Sent: 16 Feb 2016 15:50:51 +0000
To: !(b)(5) I
Subject: RE: National Railroad Passenger Corp (AMTRAK)
I had to escalate this one to OPE and OGC. They both agreed that Amtrak should now be considered
governmental.
From: l~(b_l(_51~~,.-,-,
To: Foss, Ian
Subject: FW: National Railroad Passenger Corp (AMTRAK)
This one was fun to read. Amtrak should be considered as governmental based on the 2015 Supreme
Court decision.
Sent: Tuesda January 19, 2016 2:47 PM
To: (b)(5)
Subject: National Railroad Passenger Corp (AMTRAK)
Hi Taneka!
(b)(5)
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: l(b)(5)
Sent: 5 Sep 2014 10:11:35 -0500

To: Fedloan PSLF
Cc: l(bl( 5l I
Cynthia;Johnson, Debbe;Foss, Ian
Subject: Re: Naytahwaush Community Charter School
Hi Diane,
(b)(5)
Ian
On 8/22/14, 15:51, "FedLoan PSLF" <FedLoanPSLF(iijpheaa.org> wrote:
>
>Hi Ian, We're struggling with this one because we think another entity
>handles the payroll for the school and we think this entity is for profit,
>even though the school is 50 I(c )(3 ).
>
>1. ECr ce1tified as 50l(c)(3), we verified by Form 990.
>
>2. EIN on E(T isn't the EIN for the school ~owe requested a copy of
>borrower's W-2.
>
>3. W-2 li~b the employer a~ EdVision~ Cooperative
>
>4. Busine~s filing for EdVision~ Cooperative shows shares of stock
>
>5. Co-Op histmy pdfindicatc~ EdVision~ Cooperative has a non-profit
>division, but it appears to be called EdVision Schools. This history also
>indicates EdVisions Cooperative manages approximately 225 payrolls.
>
>6. Borrower is a teacher at Naytahwaush Community School
>
>7. Naytahwaush is not listed on EdVision Schools website as an EdVisions
>School
>
>This seems very similar to the ADP issue. We think \Ve probably have to
>deny this one, but \vanted to check with you.
>
>Password to follow. Thanks
>
>(Sec attached file: Naytahwamh Community Charter School.zip)
>
>Diane Frcundcl
>(717) 720-3267
>fax- (717) 720-3911

>This me~sage contain~ privileged and confidential infonnation intended
>for the above addrc~~ecs only. If you
>
From: l(b)(5)
Sent: 6 Aug 2013 08:34:07 -0500

To: Fedloan PSLF
Cc: l(bl( 5l Ilan;Ninemire, Sandra;Johnson, Debbe;Battle, Cynthia
Subject: Re: Neighborhood Assistance Corp of America
Hi Diane,
I escalated this one and we determined at the organization doesn't qualify. The legal services that it
offers as much more like other (c)(4) organizations, by which I mean that they take on cases, but only
for selective clients, to the extent that the legal services they offer are really a part of their issue
advocacy.
Ian
Hi Ian, I'll be sending you a few more ECFsover the next several days.
We continue to struggle with what constitutes public interest law services.
This employer is a 501(c){4). They checked that they provide public

interest law services and public education. According to their website
they are a community advocacy and homeownership organization. They
provide workshops and counseling on buying a home and provide each member
with a Mortgage Consultant. I searched job openings and didn't see
anything for an attorney.
We don't think they qualify, but wanted your thoughts. Password to

follow. Thanks!
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
only. If you
individual engaging
From: l(b)(5)
Sent: 31 Dec 2015 17:51:06 +0000

To: Fedloan PSLF
Cc: l(b)(5J I
Cynthia
Subject: RE: New York Racing Association
Hi Diane,
The New York Racing Association (NYRA) was an interesting organization to research. While researching,
I came across a 2003 report, written by Eliot Spitzer when he was an Attorney General, on illegal
activities (i.e. money laundering, illegal betting, and tax fraud) by the NYRA. Fascinating read.
Sorry to digress, after reviewing the documents provided and conducting additional research we believe
that the NYRA should be classified as quasi-governmental. After the NYRA filed for bankruptcy and
reorganized in 2006 they passed custody of the racetrack to the state. Additionally, the majority of the
board consists of individuals appointed by government officials.
I also did a little research on if they could qualify as not-for-profit under law enforcement and came
across a board meeting that lists of all the NYRA's peace officers for 2013. On Tab 3 (near the end of the
document) there page that explains that how peace officers for the NYRA are special police who have
the duty to prevent illegal activities related to gambling and arrest individuals, if necessary. Below is also
more information regarding the powers of peace officers for the state of New York. Based on this
information, we believe the NYRA could have qualified under law enforcement if they had not already
been deemed as quasi-governmental.
New York Criminal Procedure Law§ 2.20 Powers of peace officers - See more at:
http:// codes.find law .com/ ny /criminal-procedure-law/ cpl- sect- 2 -
2 0. htm l#s thas h. BHh2 qdQk.d pu
Thanks,
Taneka
Sent: Tuesday, December 08, 2015 10:15 AM
To: l(b)(5J I
Subject: New York Racing Association
The New York Racing Association (NYRA) appears to be organized as a not-for-profit organization, per
the business filing. The official certified the ECFas private not-for-profit, law enforcement. If the NYRA is
truly a private not-for-profit, we are not sure that they provide a qualifying service. The information we
found about the law enforcement force states that this force is composed of "uniformed New York State
certified Peace Officers, Fire Marshals and Investigators." They also have security guards, but they
appear to be outside of the force and do not have enforcement duties.
We also found information that may support the NYRA being a governmental or quasi-governmental
entity. The Financial Statements do specify in the heading that they are a component unit of the state of
New York; however, in part (l)(a) of the Notes to Basic Financial Statements (pg 21 of 74 ofthe audited
financial statements pdf), it is described as a not-for-profit organization.
NYRA had also filed for Chapter 11 bankruptcy in 2006 which we believe may have resulted in a
reorganization of the business structure. On page 28 of the Notes to Financial Statements, part (2)(a)
states that " ...for financial reporting purposes, NYRA is considered a governmental entity engaged only
in business-type activities." We realize it is possible that this organization is similar to PHEAA's structure
in that it could potentially be considered quasi-governmental as well as a not-for-profit.
We appreciate your guidance on this one. Password to follow. Thanks!
(See attached file: New York Racing Association.zip)

Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
[email protected]
Code:PHEAA
From: l(b)(5)
Sent: 28 Jun 2012 11:43:42 -0500

Subject: RE: Nexstep Education Services/Life Skills Centers Akron & Summit Co
Diane,
I agree that this bonowcr is employed by Ncxtstcp, not the charter

~chool. Ncxtstcp, as you've found i~ an LLC and Ohio law generally
provides for profits lo be distributed. /\s such, without something more lo
prove that it is a not-for-profit, I don't think it qualific~. What's more,
Ohio law also provides for formation as a not-for-profit corporation, which
has separate article~ of organiLation/incorporation from LL Cs. So it's
clear that this entity is an LLC. not a not-for-profit corporation.
In
searching around, I found a document prepared by the IRS on whether they
1,villgrant tax-exemption to LL Cs. It makes a lot of great points, and I
think it more or less tracks what we've been doing so far. So, look it
over. I'd note that, to the extent 1,verely on this, we vmuld not care if
the organization's sole purpose is tax-exempt activities, as that's clearly
not a requirement for the non-501 (c )(3) not-for-profits, though it could
certainly come into play ifi,ve have a 501(c)(4) come forward. See here:
http://viV.'V.'.irs.gov/pub.ii
rs-tegeieotopicb0 1.pdf
The borrower's letter

indicates that he provides psychological services to students at a charter
~chool. Therefore, even though Ncxtstcp i~ abo a placement agency, the
entity, though thi~ bonowcr at lea~t, provide~ school-based service~. By
looking at their wcb~itc, though, you wouldn't necessarily assume this to be
the ca~c.
Ian

> From: Diane Freundcl
[mailto:d!'reumle(dphcaa.orn:] On Behalf Of FedLoan
> PSLF
> Sent: Thursday,
June 21, 2012 3:33 PM
> To: l(b)(5) I
> Subject: Nexstep Education
Services/Life Skills Centers Akron & Summit Co
>
>
> Hi, We're pretty
sure this employer does not qualify, but we'd like your
> input The
borrower submitted two ECFs (Nexstep and Life Skills Centers),
> but if you
read hi~ letter (page 3 of the [CF document), he appear~ to actually
> be
employed by Ncx~tcp. According to the main web page of The Ncx~tcp
> Group
(their complete site is down and under construction), they appear to

> be a
placement agency, leading m to conclude that they do not qualify.
> Ncxstcp
certifying official indicated they arc private non-profit providing
> public
education and other ~chool based services.
>
> Password lo follow.
Thanh!
>
> (Sec attached lilc: NcXslcp Education Services.Lip)
>
> Diane
Freundel
> (717) 720-3267
> fax-(717) 720-391 I
>
[email protected]
attachmcnb.
>
civil and criminal
> message.
From: Foss, Ian

Sent: 24 Apr 2012 15:47:47 -0500
Subject: RE: Northwest Counseling & Guidance Clinic, Inc
I agree, we made a mi~takc on thi~ one. I'm really sorry, Diane. Thi~ was
before (I think) the era where I made it a habit of checking Wc~tlaw on the
c~calatcd ca~c~. Having checked the [IN, the legal name i~ "Northwest
Coun~cling and Guidance Clinic, Inc.".
This organization and Northwest

Passage, Lid. arc definitely affiliated in some way, but they arc separate
entities. The EIN for Northwest Passage, Ltd. i~ 39-1311448.
>
Lmailto:dfreundefa-pheaa.org I On Behalf Of FedLoan
> PSLF
> Sent: Tuesday,
April 24, 2012 10:09 AM
> To: l(b)(5) I
> Cc: Sipple-Asher. Bessie;
'FedLoan PSLF'; Foss, lan:,"l(b~)~(5~)--~INinemire,
> Sandra
> Subject: RE:
Northwest Counseling & Guidance Clinic, Inc
>
> I think we may have made a
mi~takc on thi~ one. I wanted to nm it by you
> ~incc you assisted the
first time and we weren't quite as adept with our
> rc~carch skill~.
>
>On
the 1st ECF we received in February, they checked box c and other
>
school-based services. You found them under "Northwe~t Pa~~age, Lid" in
>
the WI corporations filing as a non-stock corporation. Also, they provide
'> public health service.I also confirmed Northwest Passage is listed in

Pub 78.
> It does look like Northwest Counseling is an offshoot of Northwest
Passage.
> and has a different EIN.
>
> On the 2nd ECF \Vejust received for
another borrower (signed by the same
> certifying official). they did not
check box a, b, or c. They did check other
> ~chool-ba~cd services again,
but wrote next to it "for profit".
>
> Further research:

> Notthwest
Coun~c!ing is listed as a "domc~tic hu~incs~" in the WI
> corporation~
filing~.
> Northwest Passage is listed in GuidcStar, Northwest Counseling i~
not.
> Northwest Coun~cling is not listed in Puh 78 and I also did not find
it in the
> B\1F.
>
> I believe Northwc~l Counseling 1~ for profit. PW lo
follow. Thanks.
>
> (See attached file: Northwest Counseling.zip)
>
>
Diane Freundel
> (717) 720-3267
>fax-(717)
720-3911
> [email protected]
>
>
>1------------>
>I horn:
>
1------------>
>
> --------------------------------------------------------------------------
> ---------------------------------------------1
>
lpublic~crvicc l(b)(5)
>I ~-----~
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
>ITo: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
l'"FcdLoan PSLF'" <f-cdLoanPSLf-((j)phcaa.org>, Ll(~b)~(5~1
__ _,
>
l(b)(5)
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
>IC" I
> 1------------>
>
> --------------------------------------------------------------------------
> ---------------------------------------------1
>
l"Foss, Ian" <lan.Fos~(a;'ed.gov>, "Ninemire, Sandra"
>
<Sandra.Ninemire(a;'ed.gov>, "Sipple-Asher, Bessie"
>
<BessieKo. Sipp leAsher(iijed. gov>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
> I Date: I
> 1------------>
>
>---------------------------------------------------------------------------
> ------------------------------------------1
>
102/17/2012 08:05 PM
>I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1--------->
> I Subject: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
> RE:
Northwest Counseling & Guidance Clinic, Inc
>I
>
>---------------------------------------------------------------------------
> ------------------------------------------1
>
>
>
>
>
> I agree both that this is a non-50l(c)(3), not-for-profit organization
that
> provides public health services. I found this organization in the

Wisconsin
> Corporation Filings under the name "Northwest Passage, Ltd." And
organi?cd
> a~ a non-~tock corporation.
>
>
> -----Original Mc~~agc-----
>
From: Diane Freundcl [rnaiHo:dfn::undc:,rn.:ssucccss.orgl On Behalf Of
> FedLoan
PSLF
> Sent: Tuc~day, February 07, 2012 9:50 PM
> To: l(b)(5) I
>
Subject: North,Nest Counseling & Guidance Clinic, Inc
>
>
> We believe this
is a qualif)'ing private non-profit; however, \Ve believe the
> ce1tifying
official checked an incorrect box.
>
> Box c - Other school based services
\Vas checked. \Ve believe it should be
> box c - Public health.
>
>[IN:
00-39-1793993
> 203 United Way Dr, f-rcdcric, WI
>
>
h tlp ://www. n w c gc. corn/ a bout .him
>
>
h tlp ://www. mi 1waukccjo bs. corn/cornpanv/prn fi1c.Thc- North we~t-
>
Systems'.'cid= 3DC5257D3A I F93409752EA5 l 8851 82C8
>
>
> Thanks
>
> Diane
Freundel
> (717) 720-3267
> fax- (717) 720-3911
>
d fn:undc((_l'.phcaa.org
>
>
>
--------------------------------
>
>

attachmcnb.
>
civil and criminal
unauthorized u~e ofthi~
> message.
>
>
>
>
>
>
>
> This message contains privileged and
confidential information intended for
> the above addressees only. If you
receive this message in error please
attachmcnb.
>
civil and criminal
> message.
From: l(b)(5)
Sent: 9 Feb 2012 12:26:55 -0600

Subject: RE:Oak Ridge Associated University
It is clear cut. If the borrower is not an employee of a qualifying

organin1tion, then her employment docs not qualify,
> -----Original
Message-----
> From: Diane Freundcl [mailto:dfr.:Lmdc:,rn.:ssucccs~,orgl On
Behalf Of
> FedLoan PSLF
> Sent: Thursday, February 09, 2012 12:10 P\1
> To:
!(b)(5) I
> Subject: Oak Ridge Associated University
>
>
> I believe
this one is clear cut, but ,,,,..antedto get your input as we!L
>
> No EIN is
included, so \Vecould just deny for that reason, but I don't believe
> the
borrower qualifies anyway, so we want to ensure we provide the correct
>
denial reason, The letter included with the E(T indicates that the borrower
lS
> participating in an intcm~hipirc~carch program with the EPA,
> It then
~tatc~that ~he is cla~~ificd only a~ a participant in the program and i~
>
not an employee of EPA, ORISE, ORAU, or DOL
>
> Password lo follow,
>
>
(See attached file: Werber_Oak Ridge,zip)
>
> Thanks!
>
> Diane Freundel
>
Compliance Services
> (717) 720-3267
> fax- (717) 720-3911
>
[email protected]
>
--------------------------------
>
> This message contain~ pri\'ilcged and confidential

attachmcnb.
>
civil and criminal
> message.
>
>
From: l(b)(5)
Sent: 14 May 2012 12:16:11-0500

Subject: RE: Ochsner Medical Center North Shore
Hi Diane,
I apologize for the delay. This one was tricky. I found an audited financial
statement that I found for the Ochsner Health System that explains how the
organizations are structured (see here, particularly page 3).
In essence, the health system is the parent company for the charitable
foundation and primary clinic. The other medical centers are subsidiary to the
foundation. The health system's financial statements indicate that all of the
subsidiaries are 501{c)(3)s.
The foundation's Form 990 also makes clear that the north shore facility is a
disregarded entity for tax purposes (See Schedule R). A disregarded entity is
one that is separate from its owner (separately organization), but elects to be
treated as one for tax purposes. If an affiliated entity is treated as a
disregarded entity for a tax-exempt organization, the disregarded, affiliate
entity receives the benefit of the tax-exemption (see here).
In the end, then, this organization qualifies as a 501(c)(3).
Ian
> PSLF
> Sent: Thursday, May 10, 2012 11:45 AM
> To: l(b)(5) I
> Subject: Ochsner Medical Center North Shore
>
>
> Hi, We're struggling with this one because ofthe Medical Center's affiliation
> with the Health System.
>
> The employer is listed as Ochsner Medical Center North Shore and the
> certifying official checked box c - public health.
>
> A google search of Ochsner Medical Center North Shore takes you to
> Ochsner Health System's website.
>
> Ochsner Health System's website indicates they are a 501(c)(3).
>
> Ochsner Health System is listed in Pub 78 under a different EIN than the
> one provided on the ECF.It also has a deductibility code of SOUNK - I
> don't recall if we determined whether we need to be concerned about the
> different deductibility codes in Pub 78.
>
> There is a business filing for Ochsner Health System that shows it is a non-
> profit.
>
> There is a separate business filing for Ochsner Medical Center North Shore,
> LLC
>
> I believe the medical center is probably non-profit as well, but can't
>confirm.A google search of the EIN on the EFChas no results. Can you
> please advise? Password to follow. Thanks!
>
> (See attached file: Ochsner Medical Center Northshore.zip)
>
> Diane Freundel
> (717) 720-3267
> fax- {717) 720-3911
> [email protected]
>
> message.
From: l(b)(5)
Sent: 10 Apr 2013 07:35:10 -0500

To: Fedloan PSLF
Cc: l(bl( 5l I
Debbe
Subject: Re: One Accord Global Ministry
Hi Diane,
I agree with your a~scssmcnt that thi~ i~ not a "church", and that it must
therefor apply for a 50\(c)(]) status with the IRS, which we must be able
lo confinn before approving the ECF. I cannot confirm that this
organiLation is a 50l(c)(3) either, so I think we should deny it.
I'd note that there is a ~cparatc organiLation in Indiana called the "One
Accord Ministry", which is a 501 (c)(3). In some of the allachmcnt~ that
arc associated with your email message, this organiLation wa~ rclCrcnccd.
They are separate organizations; so I just wanted to make the distinctions
clear.
Ian
>
>Hi Ian, We have two different religious organizations that \ve're having
>trouble \vith. They are both from December. I apologize for the delay in
>sending them.
>
>This is the fir~t one. The ECF indicate~ they arc a 501(c)(3). but we
>can't confirm. Since they arc not a church, I don't think we can
>automatically a~sumc they arc a 50\(c)(]). Plea~c sec what I highlighted
>one page~ 2 and 3 (page~ 4 and 5 of the entire pdf) of the IRS Tax Guide
>for Churches and Rcligiom Organization~. It looks like rcligiom
>organiLalions that arc nol churches, rnu~l apply for tax-exempt ~talus.
>
>We appreciate your help. Pass word lo follow for the Lip file. Thanks
>
>(Sec allachcd file: One Accord Global Minislry.Lip)(Scc
>attached file: IRS tax guide for churches and religious organizations.pdt)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>
From: Foss, Ian

Sent: 18 Jul 2012 15:52:56 -0500
Cc: Sipple-Asher, Bessie;Johnson, L(b~l(~5~1
_________ _,Sandra
Subject: RE: Opportunities for Learning Public Charter School
Diane,
As to number one, yes, I meant to say that 401(k)s are usually not a feature of not-for-profits. I really
need to give myself a 20-minute breathing window after composing an email before sending it, to catch
errors like this.
As to number two, thanks for the article!
As to number three, California's code is a giant mess, and is in no way user-friendly. What I did to come
to the conclusion that charter schools could be for-profits was similar to you did. First, I went to
legalinfo.ca.gov/calaw.html, then I selected the Education Code box, then I hit search. By not entering a
search term, I was able to retrieve the table of contents for the Education Code.
Now you need to find what's relevant to charter schools. Most states will segregate all sections of the
code relating to charters, and California was (luckily) not an exception in this case. Part 26.8 is all about
charter schools. So, I started sifting through the relevant sections to find what I was looking for. First
was section 47604, which gives charter schools the option to incorporate as a public benefit
corporation. That's a big clue.
If only not-for-profits can establish charter schools in a state, it will say so. Otherwise, for-profits would
likely be eligible. So, if you can't find something that limits charter schools to not-for-profits, you'll have
to search through the entire relevant code sections to be sure. Most states will include the not-for-
profit limitation, if they have one, in the sections relating to "who can create" a charter school or
"operation of" a charter school. So I went looking for that. I couldn't find anything. So I looked through
the rest ofthe relevant code and couldn't find anything there.
Between giving the OPTION, but not requiring, that charters schools organize as a public benefits
corporation, and not finding any other limitation, I concluded that for-profits could likely be chartered or
operate a charter on behalf of the holder of the charter. This was more or less confirmed for me when I
started searching in the charter database for California and found that some had the not-for-profit box
checked and others did not. Unfortunately, if you can't immediately find the non-profit limitation, we're
going to need to prove a negative, which is always difficult.
Because I like certainty as much as the next person, I started searching Google for "for-profit charter
school California" and found an article detailing a bill from 2010 to ban for-profit charters in California.
See here. I looked up the bill to see what its status was (e.g., Had it passed? Is it law?) and found that it
never made it out of the Senate committee on education. I then searched all other with the keyword,
newer legislation for the keywords charter school to see if there was anything more recent. Though
there were many bills about charters, most were about funding, getting people to sign the petition to
form the charter, etc., but not about this issue, and none of the legislation that was even remotely
relevant had passed. Since there wasnt anything relevant, Im operating on the conclusion that there has
not been a banning of for-profit charter schools in California.
Westlaw offers a SO-state survey on this topic, but my subscription does not permit me to access it.
Ian
To: l(b)(5J I
5'-I__
Cc: Sipple-Asher, Bessie; Johnson, Debbe; Fedloan PSLF;Foss, Ian; Ll(b-'l'-1 _,INinemire, Sandra
Subject: RE: Opportunities for Learning Public Charter School
Thanks Ian, A few things.
1. Just for documentation purposes -when you said below " ...and it offers a 401(k) Plan (usually not a
feature of for-profits, though this is not conclusive) ..." - did you mean to say " ...usually not a feature of
not-for-profits ... 11?
2. I found a good article -

http://www. d a ilyce nso red .co m/2 012/0 7/ 15/i rs-exa mining-charter -schools-and-the- far-profit -tax -
consulting-firms-are-rubbing-their-hands-in-delight/
3. I'm trying to enhance my research skills - I'm having trouble finding the CA law that permits charter
schools to be organized/run by for-profits.
I assume you're using Westlaw, which I've never used. I try to use google
but can't seem to get to the right source or the specific law. Please see
attachment for my difficulties with finding the correct CA law. Pdf 1 is
where I started (highlighted what I clicked on), pdf 2 is the next screen (highlighted what I searched), pdf
3 is the result. I'd have to go into
each of the 17 sections. Any pointers on specific search terms I could
use? It will help as I'm going through the ones we've already approved.
Thanks!
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
[email protected]
(------------>
I From: I
(------------>
>-------------------------------------------------------------------------------------------------------------------------
-1
Irn!(b"'l("51---,U'("'bl"(5,-)
------,
>------------------------------------------------------------------------------------------------------------------------
-1
1------------>
I To, I
1------------>
>------------------------------------------------------------------------------------------------------------------------
-I
51
I "Fed loan PSLF"<[email protected]>, Ll(b-'-l('-
__ _,
!(b)(5) I
>------------------------------------------------------------------------------------------------------------------------
-I
1------------>
I cc I
1------------>
>------------------------------------------------------------------------------------------------------------------------
-1
I "Foss, Ian" <[email protected]>, "Ninemire, Sandra" <[email protected]>, "Sipple-Asher,
Bessie" <[email protected]>, I
I "Johnson, Debbe" <[email protected]>
>------------------------------------------------------ -----------------------------------------------------------------
1
1------------>
I Date: I
1------------>
>------------------------------------------------------ -----------------------------------------------------------------
I 07/18/2012 12:29 PM
>------------------------------------------------------ -----------------------------------------------------------------
1
1------------>
I Subject: I
1------------>
>------------------------------------------------------ -----------------------------------------------------------------
I RE: Opportunities for Learning Public Charter School

>------------------------------------------------------ -----------------------------------------------------------------
Diane,
Though LLCsin California can operate on a not-for-profit basis, between the fact that California law
permits charter schools to be organized/run by for-profits, the California Department of Education's
website does not indicate that the corporation that holds the charter is a not-for-profit, and it offers a
401(k) Plan (usually not a feature of for-profits, though this is not conclusive), I think that this is a for-
profit business that does not qualify.
Ian
From: Diane Freundel fmailto:[email protected]] On Behalf Of FedLoan PSLF
Sent: Tuesday, July 17, 2012 10:23 PM
To: l(b)(5J I
Subject: Opportunities for Learning Public Charter School
Hi Ian, This is a new charter school. Employer checked private non-profit. It took some research, but I
reached the conclusion that they are for profit. Please confirm.
1. Not found in standard non-profit searches
2. Noticed at top of website their name includes "EMS" - about.pdf
3. Found contact information on "Locations" page. Address on ECFis the corporate address, not one of
the charter schools - I think the borrower works for the corporation and not at one of the charter
schools. Also
noticed the employer's email address is ....emsofl.com - locations.pdf
4. Googled EIN and found 401(k) info on Brightscope - name listed as

Ems-Wsh, LLC - Brightscope 401(k) info.pdf
5. Looked at list of charter schools on CA Dept of ED website for Los Angeles County (Opportunity for
Learning has schools in LA County) - looked at all "More Details" on each Opportunity for Learning
school in LA County
- all contained the same info - CA Dept of ED.pdf - note that the box
"non-profit" is not checked. Found that corporation name is EMS-BP II, LLC.
6. Checked CA business filings for EMS-BP II, LLC;however, CA site does not list profit vs. non-profit
status - business.pdf
(See attached file: Opportunities for Learning Charter School.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
[email protected]
From: l(b)(5)
Sent: 26 Feb 2013 09:33:22 -0600

To: Fedloan PSLF
Cc: l(bl( 5l I
Sandra;Sipple-Asher, Bessie;Johnson, Debbe
Subject: Re: Order Sons of Italy in America
Hi Diane,
We agree that this doc~ not qualify for PSLF. Thi~ doesn't come close to
"public education."
Thanh,
Ian
On 12/27/1221 17, "FcdLoan PSLF" <FedLoanPSLF(a/pheaa.org> wrote:
>
>Ian, This is another organization that we're unsure as to 1Nhetherthey
>provide a qualifying public service - they are a 501(c)(8). but checked
>the
>50l(c)(3) box. The closest qualifying service I could get to is public
>education, but I think that's a stretch (their mission is to encourage the
>study of the Italian language and culture, preserve Italian American
>traditions, and promote closer cultural relations bet\veen the US and
>Italy). Membership is not limited to those of Italian heritage.
>
>Password to follow. Thanks again!
>
>(Sec attached file: Order Son~ of Italy in America.zip)
>
>
>Diane Frcundcl
>(717) 720-3267
>fax- (717) 720-3911
>This me~sage contains privileged and conlidenlial information intended
>
From: l(b)(5)
Sent: 6 Oct 2015 14:46:30 +0000

To: Fedloan PSLF
Cc: l(b)(5J I
Cynthia
Subject: RE: Oregon Connections Academy
Hi Diane,
We reviewed the documents that you forwarded over and conducted additional research. While
researching we came across the Oregon Public Charter School Handbook. In Part 2, Section Q, 8
Description of Staff Members and Required Qualifications of Teachers it states, "As charter schools are,
by statute, public schools, employees of charter schools are public employees. Charter schools and their
employee's must participate in Oregon's Public Employees' Retirement System (PERS)." Based on this
statement and the letter that was provided, this borrower should qualify for PSLFfor the dates outlined
in her ECF.
Furthermore, we believe you are correct and that moving forward Fedloan will need to review the state
laws, charter agreement, and/or request a letter from the borrower's employer (similar to what was
provided in this escalation) to determine if an employee working for a charter school under the
Connections Education EIN qualifies.
Please let me know if you want to discuss this further.
Thanks,
Taneka
Sent: Friday, September 04, 2015 10:53 AM
To: l(b)(5J I
Subject: Oregon Connections Academy
Hi Taneka, I hate to start the long weekend out with another complicated
employer, but here goes.:-)
We receive ECFsunder the name Connections Education, or a specific Connections Academy, e.g.
Nevada Connections Academy. Sometimes the EIN provided links to Connections Education, a charter
school chain for which we have linked ownership to Pearson, a large, international for-profit company.
Sometimes the EIN links directly to a specific Connections Academy where the borrower is teaching.
These schools are often non-profit or public. If the EIN is Connections Education's, we deny. If the EIN is
the specific Academy's, we review the school for eligibility and approve if the school is eligible. The
Business Unit identified a discrepancy where consecutive ECFsfor a borrower had the same employer
name with different EINs (one EIN for Connections Education and one for the Academy). As a result, we
identified all borrowers (approved or denied) associated with either Connections Education or one of
the specific Connections Academies.
Upon further review of the identified borrowers, we found that some of the Connections Academies'
990s listed O employees, while others have employees. We requested W-2s for all of the borrowers and
most returned them. We found that if a 990 listed O employees, the EIN on the W-2 was Connections
Education's (the for-profit entity). Alternatively, if a 990 listed employees, the EIN on the W-2 was for
the specific Connections Academy.
This brings us to the purpose of our email. For a particular borrower employed at Oregon Connections
Academy, her W-2 provided the EIN of Connections Education. We denied her employment. The
borrower subsequently disputed the denial and included a letter indicating that she's eligible for
participation in the Public Employees Retirement System (PERS)in Oregon. In addition, she attached her
employment offer letter outlining this benefit. Due to the borrower's eligibility for participation in the
PERS,we now question our denial. The EIN on her W-2 is for the for-profit entity, but her inclusion in
PERSsuggests she is a public employee, and therefore works for a qualifying organization. We don't
know how to reconcile the EIN with the fact that she is eligible for public employee
benefits. We understand that in some instances, a school may use an
outside organization for HR and payroll services, typically referred to as a Professional Employer
Organization (PEO). In these situations, we approve, as this differs from a staffing agency, which would
not qualify.
However, we haven't found evidence that Connections Education serves as a PEO. It appears to be a
parent organization that staffs schools which are affiliated with it.
There is also a letter included from the HR Manager from Connections Education, which states " ... [the
school] contracts with Connections Education to provide, amongst other things, its HR services including
payroll." The letter also states that " ...per our charter agreement, [the borrower] is considered an
employee of [the school], not Connections Education." The statement regarding the charter agreement
may suggest we need to review the charter agreement for each school.
We appreciate your assistance. Password to follow. Have a good weekend!
Thanks
{See attached file: Oregon Connections Academy.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
[email protected]
Code:PHEAA
From: l(b)(5)
Sent: 8 Sep 2016 19:14:48 +0000

Cc: Battle, Cynthia;Tiongquico, Rene
Subject: RE: Outpost Casino
Hi Kim,
It looks like the Outpost Casino is now the Bordertown Casino; however, please hold off on denying this
escalation. We will be forwarding this escalation and the escalation for the Cherokee Nation Tribal
Entities to OGC in the hopes of obtaining a more consistent process for evaluating these type of
organizations. We will keep you updated. Thanks, Taneka
http ://www.bordertowncasino.com/fa q
https ://www. face book. com/pages/Bordertown-Outpost-Casi no/2188424114 77114
Sent: Thursda , August 11, 2016 12:09 PM
To: (b)(5)
Subject: Outpost Casino
Hi Taneka!
We have another tribal casino for you. We could not find very much information on this employer,
including a website. When we searched the address, the results predominantly pointed to a pizza place.
Eventually we found that Outpost Casino is listed as an enterprise of the Eastern Shawnee Tribe of
Oklahoma. The only "similar" business filing we found was for Bordertown Outpost Casino, and they are
listed as an LLC.
We reviewed the website of a sister casino, Indigo Sky Casino, which indicates they are owned and
operated by the tribe.
I also reviewed their Gaming Ordinance, and could not find any significant evidence to show that the
Outpost Casino should qualify as a governmental organization.
Your assistance is appreciated. Password to follow.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: l(b)(5)
Sent: 7 Jun 2017 22:37:11 +0000
To: Fedloan PSLF
Cc: 51'------'
Subject: Re: Outstanding employer reviews
Hi Kim,
Thank you for the reminder on these. It looks like we provided determinations but but I
failed them over. Please see below for decisions and updated statuses.
Family Adolescent Children Therapy Services Inc (forwarded 1/27/17, but you noted on 2/7/17
you sent to OGC)
Update - Still on hold with OCG
Chugach Electric Association

This organization does not provide the qualifying services that would allow them to
quJlify for PSLF; however, pleJse hold this retrJction.
American Medical Association -

FSAagrees with the denied. Even though the borrower is stating th;:it the Litigc1tionCenter is
;:in unincorpor;:ited c1ssocic1tion,
we do not believe thc1tthis would qu;:ilify the borrower for
PSLFsince he Jn employee of the AMA and the ;:ictivities of the Litigc1tionCenter ;:ire attributc1ble
to the members of the associ;:ition.
Riverbend Center for Mental Health (forwarded 3/14/17)

This orgJnizJtion should remJin eligible for PSLF.As J mentJI heJlth center they employ
Psychiatrists and nurses to diagnose and treat mental illness
http://www.rcmh.org/programs.htm.
Please let me know if you have questions. Thanks again for the follow-up.
Taneka

<[email protected]>
Sent: Wednesda,. June 7, 2017 8:06 AM
To: l(b)(5J -
Cc: Odom, Christian; l3attlc, Cynthia; Foss, Ian
Subject: Outstanding employer revie,vs
Hi Taneka! I know I have inundated you with employer retractions recently; however, I wanted to
check on the status of some of the outstanding employers we had escalated that are several
months old. I just want to ensure they didn't slip through the cracks. Specifically, I wanted to
inquire on the review of the following:
Family Adolescent Children Therapy Services Inc (forwarded 1/27/17, but you noted on 2/7/17
you sent to OGG)
Chugach Electric Association (forwarded 2/1/17 - this was also a possible retraction)
Riverbend Center for Mental Health (forwarded 3/14/17)
American Medical Association (forwarded 3/21/17 - this was a dispute)
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Code:PHEAA
From: l(b)(5)
Sent: 14 Feb 2012 19:22:03 -0600

To: 'Fedloan l(bl( 5l I
Cc: Sipple-Asher, Bessie;Ninemire, Sandra;Foss, Ian
Subject: RE: outstanding employers
Diane, you arc correct. I wa~ not counting the employers on hold. To be
clear, \1cckknbur, Arca Catholic Schoob ha~ been determined to be an
•liuihlr-cmnlo, •r l(b)(5)
(b)(5)
By now, we ~hould have

gotten you an an~wer to Fresenius Medical and University of TN.
The
others (San Joaquin, Kaiser, Valley Health System, the Temple) are still
pending for me.
Thanks for helping me keep all these

straight.
[mailto:dfreundefli:aessuccess.or 0 ] On Behalf Of FedLoan PSLF
Sent: Friday,
February I0, 2012 9:27 A\1
To:l(b)(5) I
Subject: ouManding
employers
Ian, On our call yesterday, you mentioned that you thought you
had 2
outstanding employers. Our records show the following (some arc
religious
connected, so you might not be counting them). We just want to
make ~ure we haven't mis~ed anything.
Mecklenburg Area Catholic Schools -

religious connection (on hold) Valley Health System (sent 02/07) - religious
connection (on hold'.') Northwest Counseling and Guidance Clinic, Inc (sent
02/07) Temple Emanu-El ofWesfield (sent 02/08)- religious (on hold)
Fresenius Medical Care (sent 02/08) Central San Joaquin Water Conservation
District (sent 02/09) Kaiser Pennanente Orange County Family Med Residency
Program (just sent last night) Univ of TN Genetics Center (just sent last
night)
Thanks!
Diane Frcundcl
Compliance Service~
(717) 720-3267
fax-
(717)
720-3911
[email protected]
--------------------------------

receive thi~ mes~age in eITor please delete or destroy this message and,..or
allachment~.

of this
message.
From: Siegel, Brian

Sent: 25 Jun 2014 12:45:48 -0500
To: Foss, lan;Moran, Pamela
Subject: RE: Outstanding PSLFEmployers
I agree that we should not approve IRA now but wait to see what the IRS does.
In regard to the Federal Reserve Banks, using my language is fine and I agree with the distinction you mentioned in regard to
FINRA.
Brian
From: Foss, Ian

Sent: Wednesday, June 25, 2014 11:31 AM
To: Siegel, Brian; Moran, Pamela
Subject: RE: Outstanding PSLF Employers
(b)(5)
From: Siegel, Brian

To: Foss, Ian; Moran, Pamela
Subject: RE: Outstanding PSLF Employers
(b)(5)
Brian
From: Foss, Ian

Subject: Outstanding PSLF Employers
Hi Brian and Pam,
I wanted to follow-up on the attached PSLFemployer questions.
Pam chimed in on the Federal Reserve Bank (a re-hashing of a prior decision), but I think that
neither of you have responded on International Rights Advocates.
Ian
From: l(b)(5)
Sent: 8 Feb 2012 14:41:17-0600

To: !(b)(5) I
PSLF
Cc: Sipple-Asher, Bessie;Ninemire, Sandra;Foss, Ian
Subject: RE: PA state representative
And once more, the escalation wa~ quick.
There will be no per ~e bar on

elected officiab (aside from members of the US Congrc~~) and political
appointees qualil)'ing.
That being said, they, like everyone else, must be

considered full-time employee~. Therefore, we will have to rely on a
certification from the employer that they arc both (I) an employee and (2)
full-time (unless they arc part-lime and have another qualifying job).
Also
bear in mind that some state legislatures, such as Matyland, are patt-time.
In such cases, the borr01,verwould likely need another qualifying job in
order to meet the full-time definition.
From: ~l(b~)(~5)~~~
> Sent: Wednesday. February 08, 2012 2:44 P\1
>To:
Fed loan PSLF; l,_(b_l(~5)~~.,..
> Cc: Sipplc-A~hcr. Bessie: Nincmirc, Sandra:
Fo~~, Ian
> Subject: RE: PA ~tatc reprc~cntativc
> This one will be

c~calatcd too.
>
> > From: Diane Frcundcl
[mailto:dfrcundcrdacssL1cc.:ss.urgl On Behalf Of
> > FcdLoan PSLF
> > Sent:
Wednesda 1 , Februat 08, 2012 2:05 PM
>>To: L(b-'-)('-'5)=--'
> > Subject: PA
state representative
>>
>>
>>Would an elected official (a state
representative) qualif)' for PLSF?
>>We received a phone call.
>>
>>
Thanh.
>>
>>Diane Freundcl
>>Compliance Service~
>>(717)720-3267
> fax-(717) 720-3911

> > dfn:undc((_l'.phcaa.org
>>
>>
>>
>>

>>for the above addrc~~ees only. If you receive this
message m etTor
>>please delete or destroy this message and/or
attachments.
>>
> > The sender of this message will fully cooperate in the
civil and
>>criminal prosecution of any individual engaging in the
unauthorized
>>use of this message.
>>
>
-------------------
>>
From: l(b)(5)
Sent: 15 Mar 2012 08:10:44 -0500

Subject: RE: Pacific Gas & Electric
Diane,
I agree, this one doc~n't qualify.
Though a subsidiary of a
for -profit corporation can qualify if il is separately organized and
independenlly qualifies, thi~ subsidiary is abo a for-profit corporation.
I found its articles of incorporation, which address the issuance of stock,
meaning it is a ~tock company, and therefore also for-profit. Sec here:
http 1 \\ \\ \\ 1mccurp com 1<1boutusCOl)J guv/pdJsiUtility Art1clesoflncorp.pdf.
Also note that the provision of electricity to the public in California

makes one a public utility under the California Code; however, that does not
make you a governmental organization. Instead, it subjects you to
regulation. You become a regulated entity. See the California Public
Utilities Code Section 216, available here:
http://v.,.-v,,,v,,,_leginfo.ca.gov/cgi-binidisplaycode'?section-puc&group-OOOO
1-0 1000&
file-201-248.
Finally. California also recognizes the framev,·ork \vhereby

there is a local, publicly owned utilities as well. See California Public
Utilitic~ Code Section 385, available here:
http: i/www. lel!info. ca. go\'icl!i-b in/disp lavcodc '?~cctimi-puc&group-0000 1-0 1000&
filc-385-387.8. Though I am not in a position to ~late so conclmi\'cly,
many, if not mo~t. local, publicly owned utilities would be go\'crnmcntal
cntitic~. 1 found a list of local, publicly owned utilities in a report
prepared for the California Energy Commission on whether lo subject such
entities to renewable energy procurement requirements. Sec table 2 of the
document available here:
h tlp :i/www.cncrgv.ca. go\· /2005 p ltb1ica tions/C EC -300-2 005-02 \/C EC-300-200 5-02 3.
PDF. Sec also the definition of a local, publicly owned electric utility, in
Section 224.3 orthc California Public Utilities Code. available here:
http:iiwww .leginfo.cn.govicgi-bin/displaycode'!section=puc&l!roup=0000 1-0 l 000&
file=201-248.
In short. this is a for-profit, privately owned corporation

that provides electricity and natural gas services to regions of California.
It is a public utility. and is therefore subject to regulation. but that
does not make it a governmental organization.
Ian
> -----Original
Message-----
> From: Diane Frcundcl rmailto:dfrcundC:ciacssuccc~~.or"] On
Behalf Of
> FcdLoan PSLF
> Sent: Wcdnc~day. March 14. 2012 11:26 PM
>To:
l(b)(5)
> Subject: Pacific Gas & Electric
>
>
> Hello, I don't
think thi~ employer qualifies, but I want to be ~urc
> ~incc the ECP wa~
signed by their Director of Regulatory Compliance/Support.
> They certified
a~ government. PG&E is a subsidiary or PG&E Corporation.
> PG&E Coq1oration
is clearly for profit and is traded on the NYSE a~ PCG. I'm
> not sure how
subsidiaries work. Could a subsidiary of
> a for profit ever be a
qualifying employer'.' Password to follow. Thanks.
>
> (See attached
file: Pacific Gas and Electric.zip)
>
> Diane Freundel
> Compliance
Services
> (717) 720-3267
> fax-(717) 720-3911
> dfrcundc(cfphcaa.org
>
--------------------------------
>

allachment~.
>
civil and criminal
> message.
>
--------------------------------
>
From: l(b)(5)
Sent: 19 Apr 2012 12:43:39 -0500

Subject: RE: Paramedics Plus - EMSA
Diane,
I don't think thi~ organization qualific~. Paramedic~ Pim i~ a

~cparatc legal entity from Ea~t Tcxa~ Medical Center Regional Healthcare
System, with subsidiary here probably meaning that the system wholly own~ or
has a controlling slake in Paramedic~ Plu~. There\ nothing indicate that
Paramedics Plus is a not-for-profit in its own right, and no organization
can find '\heller" in its parent company.
I'd abo note that Paramedic~

Plus is in "good standing" on its Texas Franchise Tax, which means that it
is a taxable entity, meaning that it is not a not-for-profit corporation
under Texas law. Of course, many more organizations than not-for-profit
organizations are exempt from Texas Franchise Tax, but that an entity is not
exempt means that it is not a not-for-profit corporation.
Ian
>
[mailto:dfreundefn:pheaa.org l On Behalf Of Fed Loan
> PSLF
> Sent: W cdnc~day.
April 18. 2012 9:59 PM
> To: l(b)(5) I
> Subject: Paramedic~ Plu~ -
E\1SA
>
>
> Iii, We're having trouble with this one. The employer checked
public health
> under box c_ but did not check box a, b, or c. They arc an
LLC, and according
> to the video on their "about us" page on their ,,,,..ebsite
(link below), they are
> an indirect subsidiary of East Texas Medical Center
Regional Healthcare
> System. The TX franchise tax cettification for East
Texas Medical Center
> Regional Healthcare System indicates it's an
"exempt
> entity". Also. the HMF shows that East Texas Medical Center
Regional
> Healthcare System has several [lNs and they arc all listed a~
50l(c)(3).
> But we could find nothing for Paramedic~ Plu~.
>
> A~ an
indirect subsidiary of a 50 I(c)(3 ), does Paramedics Plus qualify?

> Pass\vord
to follow. Thanks.
>
> http://parnmcdic~plu~.eomiahout u~.php
>
> Diane
Freundcl
> (717) 720-3267
> fax-(717) 720-3911
>
d freunde(a;phcaa .org
>
>
attachments.
>
civil and criminal
> message.
From: l(b)(5)
Sent: 25 Feb 2015 10:07:29 -0600

To: Diane Freundel;FedLoan PSLF
Cc: l(b)(5J I lan;Battle, Cynthia
Subject: RE: Partnership for Downtown St Louis
Hi Diane,
After reviewing the details of this escalation, I believe that the Partnership for Downtown St. Louis does
not meet the criteria to be a qualifying employer for the basis of PSLF.
The Partnership for Downtown St. Louis, a 501(c){6), and the Downtown St. Louis Community
Improvement District, a 501{c)(3), basically have a mutually beneficial business relationship. On the
Schedule L of the Improvement District's 2012 Form 990, it states that they have a "cooperative
agreement" with the Partnership of Downtown St. Louis. I interpret a "cooperative agreement" to mean
a strategic alliance. In a strategic alliance "an agreement [is established] between two or more parties to
pursue a set of agreed upon objectives needed while remaining independent organizations" (Wikipedia).
In this situation, the Partnership provides staffing and management services to the St. Louis Community
Improvement District in return for services related to revitalizing downtown St. Louis. Even though the
Improvement District reimburses the Partnership for staffing services the individuals are not employed
by the Improvement District.
There is also a place on the Improvement District's 2012 Form 990 where to the Partnership for
Downtown St. Louis is listed as an "unrelated organization". In supplemental information provided on
Schedule J, the Improvement District states that, "the Unrelated Organization, Partnership for
Downtown St. Louis, paid all persons in schedule J, Part 11... and may or may not represent 100% of the
individuals entire compensation paid by the unrelated organization." It's interesting (and somewhat
relevant) but the employee that the Improvement District was referring to on Schedule J was Mike
Sondag, who provided the details for this escalation.
I also did not see that a Schedule R form was completed for either organization so this is not be a
circumstance where the Partnership could potentially qualify based on the Improvement District's status
as a 501(c)(3).
Please let me know if you have questions or need me to provide additional clarification on this one.
Thanks,
Taneka
From: Diane Freundel [mailto:[email protected]] On Behalf Of FedLoan PSLF
To: l(b)(5J I
Subject: Partnership for Downtown St Louis
Hi Ian, We'd like your input on this one. Our inclination is to deny, but
there is one thing that makes us second guess it.
ECFis certified as 501(c)(3) with a note "see attached comment" - attachment is part of the same .pdf.
Attachment states that the entity (Partnership for Downtown St Louis) is a
501(c)(6) which we confirmed by the Form 990, but that 100% of the borrower's time is reimbursed by
the 501(cl(3) - Downtown St Louis Community Improvement District which is managed by the
Partnership for Downtown St Louis. The letter also states that, based on a technicality with the
organizational structure of the Downtown St Louis Community Improvement District, it has no
employees of its own. This was the piece of information that made us question our inclination to deny.
Based on their mission/significant activities on the Form 990, we don't think the 501(c)(6) provides a
As always, thanks for your help. Password to follow.

(See attached file: Partnership for Downtown St Louis.zip)
Diane Freundel
Compliance Services
(717) 720-3267
[email protected]

__ _,
Sent: 14 Feb 2014 06:43:40 -0500
To: Fedloan PSLF
Cc: l(bl(5l I lan;Battle, Cynthia;Johnson, Debbe
Subject: Re: Patient-Centered Outcomes Research Institute
Hi Diane,
After c~calating, we determined that this organin1tion doc~ not provide

public health ~crvicc~ and is not a quasi-govcrnmctnal organization for
PSLF purpo~cs, and, therefore, doc~ not qualify.
Ian
On 1/8/14, 14:24, "FcdLoan PSLF" <FcdLoanPSLF(a;'phcaa.org> wrote:
>
>Hi Ian, We're not sure if this employer provides a qualifying public
>service. I tend to think they qualify based on job postings, but we'd
>like
>your input.
>
>ECr is certified as 501 (c )(3 ).
>
>Page 38 of56 of the annual report states they are 501(c)( I).
>
>They conduct research to provide information about the best available
>evidence to help patients and their health care providers make more
>informed dcci~ions.
>
>I looked at ~omc of their job posting~ Science and Rc~carch and found one
>with the following required experience: Doctorate or Fir~t Profc~~ional
>Degree (e.g .. PhD, ScD, MD, DrPH) or Ma~tcr'~ degree+.
>
>Several of their "\1cthodology Committee \1cmhcr~" arc \1D~, as well as their
>Executive team.
>
>I think we can approve as private non-profit providing public health
>services because they employ phy~icians. Do you agree? Pa~~word to
>fol101N.Thanks!
>
>(See attached file: Patient-Centered Outcomes Research Institute.zip)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>
From: Foss, Ian

Sent: 27 Mar 201717:06:35 +ODDO
To: !(b)(5) I
Subject: RE: Peoples Community Bank- Possible Retraction
Yeah, a state-chartered bank is still a regular bank, not governmental. The primary difference between a
state bank and a national or federal bank relates to where the bank can operate and who regulates the
bank. State-chartered banks can1 t say that theire "national" banks or "federal" banks, for example.
Moreover, while the "national" banks are regulated by a Federal agency-the Office of the Comptroller
of the Currency, state-chartered banks are overseen by the state regulator responsible for banks in the
state that issued the charter.
Moreover, there's nothing "special" about Peoples Community Bank in this regard. When you look at
their "mission statement", one of their missions is to "maximize shareholder return".
This is a particularly egregious error on FedLoan's part.
5_I~~~
From: l._,(b~l(
Sent: Friday, 24 March, 2017 16:31
To: Foss, Ian
Subject: FW: Peoples Community Bank - Possible Retraction
Hi Ian,
I missed reviewing this organization. Do you know anything about state-chartered banks? The People's
Community Bank was chartered by the State of Missouri in the 70's. The organization certified as
government on the borrower's ECF.I tried to do an EIN search and could not locate any information. I
1
also tried to see if they were hiring and if they offered state benefits to their employees but didn t have
success. I found the business filing but it just lists that the bank is regulated by the Dept. of Finance. Any
suggestions on where else I can look?
The PW is in the usual format for Mar. 22 nd .
Thanks,
Taneka

Sent: Wednesday, March 22, 2017 8:30 PM
To: !(bl(51 I
Subject: Fw: Peoples Community Bank - Possible Retraction
Hi Taneka! This is the other one I don't believe we received a response on. Just checking on the status.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
----- Forwarded by Kimberly A Myers/PHEAA on 03122/2017 08 29 PM-
~r:w1 Fedloan PSLFIPHEAA

T,l l{b)(5) I
Da:c 02114/2017 08:16 AM
Sub1cct Peoples Community Bank- Possible Retraction
Sert lly Kimberly A Myers
Hi Taneka! This was previously approved under government. We found that they are a state chartered
bank, which is chartered and regulated by the state and the federal government; however, we don't
believe they are part of the government.
Only one borrower has been impacted. The approval was performed on 8/4/15.
Same password as previous employer. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: l(b)(5)
Sent: 27 Jan 2017 16:55:39 +0000

To: Foss, Ian
Subject: Re: PHCXA Inc
Yay!
Thank you.
From: Foss, Tan

Sent: Friday. January 27, 2017 10:46:42 AM
To: !(b)(51 I
Subject: RE: PHCXA Inc
Yeah, I think we can reverse the denial. They're a not-for-profit whose primary purpose is to provide
1
acupuncture services. And, as you ve noted, acupuncturists are in the appropriate category of SOC
Codes.
From: l~(b~l(~51
__ ~
To: Foss, Ian
Subject: Re: PHCXAInc
It's because of the acronym - I didn't realize it \Vas never spelled out.:) PHCXA stands for
Phoenix Community Acupuncture. www.phocnixcomrnunitvacupuncturc.com.
Kim included the Arizona business filing for them and they are listed as non-profit.
Phoenix Community Acupuncture
www.phoenixcommunityacupuncture.com
PhxCA is CLOSED Satu1·day, Jan l!l While Mayo is a1.vayon maternity leave, Shi1·a\Nill be
substituting & PhxCA will be closed 011Thutsdays. Normal houts Tuesday.
From: Foss, Ian

Sent: Friday, January 27, 2017 9:58:28 AM
To: l(b)(5J I
Subject: RE: PHCXA Inc
Can I get a link to the organization's website? I'm having trouble locating them ..
From: l~(b~l(~51_~~
To: Foss, Ian
Subject: Fw: PHCXAInc
Hi Ian,
Good news. I think we can retract this denial. Acupuncturists are listed in the SOC designation
for Health Diagnosing and Testing practitioners (other). Are you okay with me sending this
approval?
Thanks,
Taneka
From: l~(b_l(_51
__ ~
Sent: Thursday, January 26, 2017 12:27 PM
To: Fedloan PSLF
Thank you for including the SOC designation.
Do you have the name on the other organization that was denied?
Thanks,
Taneka

Sent: Thursday, January 26, 2017 8:08:32 AM
To: l(b)(5J I
Subject: PHCXAInc
Hi Tankea! We would like your input on this one.
This employer certified as 501 (c)(3) and private not-for-profit, providing public health services. While we
could not find evidence of 501 (c)(3) status, we found the organization is not-for-profit. The organization
provides acupuncture services.
In searching the SOC, an Acupuncturist is listed as an illustrative example under the 29-1100 Health
Diagnosing and Treating Practitioners, All Other category. Therefore, I believe they are eligible. I also
was to point out that in my review, I found there was a not-for-profit acupuncture organization in the past
and it was denied as they were deemed ineligible.
Your guidance is appreciated. If you agree they are eligible, we will approve this organization and
additionally reverse the denial on the other organization. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: l(b)(5)
Sent: 27 Jan 2017 17:06:33 +DODO

To: Fedloan PSLF
Cc: 5'-I_____
Battle, Cynthia;Foss, lan;Odom, Ll(b-'l('- _,
Hi Kim,
We agree that PHXCA, Inc. can be approved as eligible for PSLF.In the letter can the
business unit make sure that the organization is approved as a not-for-profit
organization providing public health services.
Thanks,
Taneka

<[email protected]>
Sent: Thursda , January 26, 2017 8:08:32 AM
To: (b)(5)
Subject: PHCXA Inc
Hi Tankea! We would like your input on this one.
This employer certified as 501 (c)(3) and private not-for-profit, providing public health services.
While we could not find evidence of 501 (c)(3) status, we found the organization is not-for-profit.
The organization provides acupuncture services.
In searching the SOC, an Acupuncturist is listed as an illustrative example under the 29-1100
Health Diagnosing and Treating Practitioners, All Other category. Therefore, I believe they are
eligible. I also was to point out that in my review, I found there was a not-for-profit acupuncture
organization in the past and it was denied as they were deemed ineligible.
Your guidance is appreciated. If you agree they are eligible, we will approve this organization
and additionally reverse the denial on the other organization. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: l(b)(5)
Sent: 31 Jul 2012 15:01:21-0500

Subject: RE: Phoebe Physician Group
Diane,
I can't imagine why the organization is no longer in Puh 78 or the BMF unlc~~it i~ ha~ its tax-exempt ~tatu~
revoked, hut it's not in the section of Puh 78 devoted to those having exemption automatically revoked for
failing to lile Form 990 or in the ~ection or the IRS' website that pertain~ to organiLations having their tax-
exempt status ~uspended,
I would approve this under the non-501(c)(3), not-for-profit category because the documentation (articles
of incorporation) support~ that back to 12/18/2008, or course, you can then only look al payments going
back that fac
Ian
From: Diane Freundel Lmailto:dfreunde:11-phea,wr1tlOn BehalfOfFedLoan PSLF
Sent: Wednesda July 25, 2012 I0:57 P\1
1,
To: (b)(5)
Subject: Phoebe Physician Group
Hi Ian, This is a classification question. They certified as private non-profit. Based on my research, they
filed a 990 as a 501(c)(3), but
they arc not li~tcd in Pub 78 or the BMF. Should we cla~~ify them as a
501 (c )(3) or private non-profit providing public health services. Pa~~wordto follow. Thanks!
(Sec attached file: Phoebe Physician Group.zip)
Diane Freundcl
Compliance Service~
(717) 720-3267
fax-(717) 720-3911
From: l(b)(5)
Sent: 7 Jun 2012 12:16:31-0500

Subject: RE: Physicians Reference Laboratory/Blue Springs
Internal Medicine
Diane,
I do not think that this organization qualifies. While it's true that LLCscan
always operate as not-for-profit corporations, I would not assume that to be
true, particularly when they can incorporate as not-for-profit corporations. In
this case, Missouri has provisions for not-for-profit corporations, and this
entity elected to organize as an LLC.
LLCsin Missouri are taxed at the state level in the same way that they are
taxed at the federal level. And, an LLCis usually subject to federal tax in one of
two ways: as a corporation {if elected) or as a partnership (default). Missouri
law also provides that LLCsthat are taxed as corporations may be exempt
from state tax to the extent that they are exempt from federal tax.
I pulled the Articles of Organization for the organization and found that they
are taxed as a partnership. This means that the organization cannot be tax-
exempt at either the federal or state level and that income tax is assessed on
the individuals/entities to whom distributions are made. The Articles of the
Organization state that the members of the LLC include a Professional
Corporation and a not-for-profit corporation. So, the distributions that inure
the not-for-profit are not actually taxed because it's probably a tax-exempt
entity, but the distributions that inure the Professional Corporation will be
taxed.
But in the end, I think that this is more or less not qualifying for the same
reason as GW Hospital did not qualify--it's essentially a partnership that is
subject to tax on its profits.
Ian
> From: Diane Freundel [mailto:[email protected]] On Behalf Of FedLoan
> PSLF
> Sent: Thursday, June 07, 2012 11:22 AM
> To: l(b)(5J I
> Subject: Physicians Reference Laboratory/Blue Springs Internal Medicine
>
>
> Hi, We're having trouble with this one.
>
> ECFindicates they are private non-profit providing public health services.
> Our research found the following:
>
> PRLis a limited liability corp, which in Missouri can be a non-profit.
> PRLMO business filing just indicates LLC Business filing Blue Springs general
> shows 3 entries, only one of which is active Business filing Blue Springs
shows
> it is a "fictitious registration" and the owners are Carondelet Physician
> Services, Inc Business filing Carondelet shows it is a non-profit Carondelet
> Health about us indicates they are a part of Ascension Health, the nation's
> largest Catholic non-profit health system.
>
> A search of the EIN wasn't productive, but we did find that they offer a
> 401(k) plan
> I think this employer qualifies, but I can definitively determine.
> Password to follow. Thanks.
>
> (See attached file: Physicians Reference Laboratory.zip)
>
> Diane Freundel
> (717) 720-3267
> fax- {717) 720-3911
> [email protected]
>
> message.
From: l(b)(5)
Sent: 30 Sep 2014 15:52:54 -0500

To: Fedloan PSLF
Cc: l(b)(5J I
Subject: Re: Piedmont Medical Care Corporation
Hi Diane,
I'm confused. The bmincss filing ~ay~that it is a not-for-profit organization, and it employs doctor~, and
therefore provide~ public health services. The [IN in Brighbcopc doc~n't match the EIN the borrower
provided. llowcvcr, a Wcstlaw search of the EIN that the borrower provided tics back lo the name of the
organiLation on the ECF.
/\ not-for-profit status doc~n't necessarily mean that the organiLation is tax-exempt, but it doesn't have to be
lax-exempt to qualify for PSLF. /\lso._1ust because Schedule R of the related organization's Fonn 990 has
this organization listed as a related organiLation that 1~ "taxable" as a corporation or trust, I don't think
mean that the organization is not tax-exempt (or is not a not-for-profit). Instead, they are talking about how
taxation would proceed, not that it does proceed.
Because it's Piedmont Healthcare that has a "profit-sharing" plan, and the organization on the ECF is
distinct from the organization that has the profit-sharing plan (even if Piedmont Medical is I 00% owned by
Piedmont Healthcare).
In short, I think this organization qualifies.
Ian
On 9/4/14, 14: 12, "FedLoan PSLF" <[email protected]> wrote:
>
>Hi Ian, We have mixed opinions on thi~ one. On the one hand, the
>bus inc~~
>filing ~how~ they arc not-for-profit, hut on the other hand, the
>Brightscopc site shows lheir401k is a "profit sharing plan", and they arc
>\i~ted a~ a "C-coq1" on Piedmont Ilealthcarc's Fom1 990 Schedule R. We
>also
>found evidence that Piedmont Medical Care Corp doc~ business as Piedmont
>Phy~icians Group. I know we've ~ccn Physicians Groups as Disregarded
>Entitic~ and therefore they arc non-profit, but when the group 1~ li~tcd
>as
>a taxable C-corp we question their eligibility since physician practices
>are typically for profit
>
>
>(See attached file: Piedmont Medical Care Corporation.zip)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>
From: l(b)(5)
Sent: 30 Oct 2014 21:03:07 +DODO
To: Fedloan PSLF
Subject: RE: Piedmont Medical Care Corporation
Whoop~ ...I sent thi~ from the wrong mailbox. I have too many to manage clearly!
-----Original Me~~age-----
From: 150Perecnt-Qucstions
To: FedLoan PSLF
Cc: Batlle, Cynthia; Johnson, Dcbbc; .l(_bl_(5_1
__ ~
Subject: RE: Piedmont Medical Care Corporation
Sony, Diane, you're right. I found a ~imilarly named organization doing my own ~earch on Brightscopc and
didn't find the same organization you did. I can't find a lot of good infonnation in my research about
1Nhethera not-for-profit organization could have some sort of "profit-sharing" plan. What I think you
should do is treat it like conflicting infonnation and contact the authorized official to clarify.
From: Diane Freundel Lmailto:dfreunde:11-phean.or!!.I
To:l(b)(5) I
Cc: Hattie, Cynthia; Johnson, Debbe; redLoan PSLF
Subject: Re: Piedmont \tledical Care Corporation
Hi Ian, I'm not sure \vhich EIN you're looking at on the Hrightscope page.
The EIN (highlighted this time) in the upper right column is the same [IN as is on the E(T. There i~
another [IN (the auditor's- E&Y) fm1hcr down
in that column. The profit sharing plan info is what made u~ question
the husinc~~ filing statm of "non-profit", and the fact that we can't
confirm an [IN a~~ociatcd with the hu~incss filing. Abo, although I
still don't fully understand C-CO!l)and S-CO!l)entities, I thought we
di~cusscd that they could be either for profit or not- for-profit. Because
of the conllicl (profit-sharing plan, husinc~~ filing, C-eorp status), we wanted you opinion.
Before we approve it, we want lo make sure you sec the EIN we were
rekrring lo on Brighlscope. Password lo follow. Thanks!
(See attached file: ECF and Brightscope.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax-(717) 720-3911
[email protected]
l(b)(5)
To:"FcdLoan PSLF" <FcdLoanPSLF(,ipheaa.org>
l(b)(5) U(bJ(5) I "Battle, Cynthia"
<Cynthia.Battlc((_l'.cd.gov>,".lohn~on, Dcbbc"
<Dchbc.John~on(c(cd.gov>
Date:09/30/2014 04:53 PM
Subject:Re: Piedmont Medical Care Corporation
Hi Diane,
I'm confused. The bmincss filing ~ay~that it is a not-for-profit organization, and it employs doctor~, and
therefore provides public health services. The EIN in 81ight~copc doesn't match the EIN the borrower
provided. llowcvcr, a Wcstlaw search of the EIN that the borrower provided tics back lo the name of the
organiLation on the ECF.
/\ not-for-profit status doc~n't necessarily mean that the organiLation is tax-exempt, but it doesn't have to be
lax-exempt to qualify for PSLF. /\lso._1ust because Schedule R of the related organization's Fonn 990 has
this organization listed as a related organization that is "taxable" as a corporation or trust, I don't think
mean that the organization is not tax-exempt (or is not a not-for-profit). Instead, they are talking about how
taxation would proceed, not that it does proceed.
Because it's Piedmont Healthcare that has a "profit-sharing" plan, and the organization on the ECF is
distinct from the organization that has the profit-sharing plan (even if Piedmont Medical is 100% owned by
Piedmont Healthcare),
In short, 1 think this organization qualifies.
Ian
On 9/4/14, 14: 12, "FcdLoan PSLF" <FcdLoanPSLF½,~·phcaa.org>wrote:
>
>Hi Ian, We have mixed opinions on thi~ one. On the one hand, the
>husinc~~ filing shows they arc not-for-profit, but on the other hand,
>the Brightscopc ~ilc ~how~their 401k is a "profit ~haring plan", and
>they arc listed as a "C-corp" on Piedmont llcallhcarc's Fom1 990
>Schedule R. We also found evidence that Piedmont Medical Care Corp
>docs business as Piedmont Physician~ Group. I know we've ~ccn
>Phy~icians Group~ as Disregarded Entities and therefore they arc
>non-profit, hut when the group is listed as a taxable C-corp we
>question their eligibility since physician practices are typically for
>profit.
>
>
>(See attached file: Piedmont Medical Care Corporation.zip)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>for the above addrc~~ccs only. If you receive this mc~~agc in error
>please delete or dc~troy this message and/or attachments.
>
>The ~ender of this mc~~agc will fully cooperate in the civil and
>criminal prosecution of any individual engaging in the unauthorized u~c
>ofthi~ message.
From: l(b)(5)
Sent: 14 Nov 2013 09:39:31 -0600

To: Fedloan PSLF
Cc: l(bl( 5l Ilan;Johnson, Debbe;Battle, Cynthia
Subject: Re: Pines at Bristol
Hi Diane,
In Westlaw, I find no business filings for "Pines at Bristol''_ which leads me to believe that this is
nothing more than a OBA name.
When I search for "National HealthCare Associates" on Westlaw, I find filings from Florida and
Colorado, but nothing in the states in which the organization appears to actually operate. Also, the
EIN for the organization I found is 65-0282999, not the EIN on the ECF. This organization
was incorporated in 1991. IT is also a for-profit.
When I search for "National Health Associates" in Westlaw, I find nothing.
I would call the certifying official and ask them for more information that might shed
light on why the EIN is \Vhat it is and how they relate to National HealthCare Associates.
Ian
On 10/18/13, 21:14, "Fed loan PSLF"<[email protected]> wrote:
Hi Ian, We're having trouble with this one.
ECFcertified as private non-profit providing public health.
Pines website indicates they are an affiliate of National HealthCare

Associates.
National HealthCare Associates website indicates they were founded in 1984.
We couldn't find any business filing under the name of National HealthCare
Associates in any of the states they list as having facilities. The
closest we could find is a NY filing for an entity with the name of
National Health Associates - we think it could be them because the initial
filing date is 04/17/1994 and they are non-profit.
A website we use as a last resort/confirmation for skilled nursing

facilities indicates it's for profit.
We appreciate your help. Password to follow. Thanks
(See attached file: Pines at Bristol.zip)
Diane Freundel
Compliance Services
{717) 720-3267
fax- (717) 720-3911
only. If you
individual engaging
From: l(b)(5)
Sent: 7 Mar 2016 17:40:10 +0000

To: Fedloan PSLF
Cc: l(b)(5J I
Cynthia
Subject: RE: Potawatomi Bingo and Casino
Hi Kim,
We agree that the Potawatomi Bingo and Casino should qualify.
Thanks,
Taneka
Sent: Frida , February 12, 2016 3:13 PM
To: (b)(5)
Subject: Potawatomi Bingo and Casino
Hi Taneka!
I'm going to apologize up front because we have several employers to forward along, with two being tribal
entities!
The Potawatomi Bingo and Casino appears to be similar to Upper Sioux Community dba Prairie's Edge
Casino, which we approved in August 2014 based on Ian's guidance. This entity shows no indication of
being an 8(a) firm. In addition, the website indicates that it is owned and operated by the tribe.
We located a couple of court cases regarding this entity. The first case, from 2006. rejects the argument
for sovereign immunity. The second case, from 2013, granted the motion to dismiss based on sovereign
immunity. Through other cases referenced within these, it seems that there has been inconsistency
regarding the tribe's sovereign immunity applying to the Bingo and Casino. In reviewing the financial
statements, the Potawatomi Bingo and Casino is an enterprise fund of the tribe.
Given no other evidence indicating it is separately organized from the tribe, we would lean toward
approving this one.
Password to follow. As always, thank you for your assistance!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: l(b)(5)
Sent: 10 Apr 2013 08:45:44 -0500

To: Fedloan PSLF
Cc: l(bl( 5l I
Debbe
Subject: Re: Power of Three
Diane,
Thi~ one i~ a ~trctch, but I think we can approve it. Though the articles
of organization, which explain that it will only he carried out for
purposes that would qualify il for an exemption under 50l(c)(3) and the
filing of the 990-N, which they wouldn't do unless they actually were
lax-exempt, I am okay making the leap that they actually arc exempt under
50l(c)(3). Of course, the authoriLcd of1icial's (who appears lo be a
corporate ol1iccr) certification also helps.
I did find the organization's website (http: '/www.po3az.org/), but it was

ofno more help than anything else.
Let me know if you disagree.
Ian
>
>Hi Ian, This is another religious organization that we're unsure of.
> They checked box h that they arc a 50 1(c )(3 ). Wc couldn't find a wch~itc
>for them, but according to their Article~ of Incorporation. they say that
>they "Provide community aid to include refugee, humanitarian a~si~tancc,
>religious mini~try, as well a~ youth mentoring." The Articles arc \'Cty
>difficult to read. You can go to the Ari7lma Corporation Commi~~ion's
>website and find it there where you can zoom in and read it better.
> hll p: /i starpas. azcc. gov i sni pl sicgi ip. exe/WServ icc=wsbroker I inames-dctai 1.
>p?name-id= 14320542&type=CORPORA TION
>
>We found evidence on the IRS Select Check website that they filed their
>Form 990 via "c-postcard" ~owe can't actually view it to determine their
>status.
>
>
>(See attached file: P01,verof Three.zip)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>
From: l(b)(5)
Sent: 1 May 2012 08:26:26 -0500

To: Fedloan PSLF
Cc: l(bl(5l Ilan;Ninemire, Sandra;Sipple-Asher, Bessie;Johnson,
Debbe
Subject: Re: PRH Clinic Network, LLC- Palouse Pediatrics, PLLC
Diane,
This is the hardest one that I've seen in a while, and it's one where we're just going to have to make
a call, and I'm going to come down on the side of saying that this doesn't qualifySat least for now.
You're correct in that Public Hospital Districts in the state of Washington are governmental entities.
Public Hospital District# 1-A, which was listed as a member of PRH Clinic Network, LLC,is Pullman
Regional Hospital. The PRH in the name of the clinic network is "Pullman Regional Hospital".
However, there are other members of the clinic network. So, I don't think that this is an entity that is
even wholly owned and operated by the district<and that's only partially relevant.
Remember, this is an entity that is separately organized, so it has to independently qualify. It's not
clear to me that this is organized as a not-for-profit LLC.Other searches in the NPI database for the
network returned other results indicating that the network had another doing business as name,
which is "Palouse Ent., LLC", which I believe is for-profit.
The Pullman Regional Hospital, the d/b/a name for the district, has a list of affiliations, none of which
include the clinic network.
I could not find the EIN in Westlaw, which has tended to mean that the organization is a
governmental entity. The EIN has a prefix of 26, which is currently reserved for internet registrations.
All of the entities associated with the hospital district, including the "foundation" and "auxiliary",
both of which are 501(c){3)s, had EIN prefixes of 91. The hospital district also has an EIN prefix of 91
(found it by pulling the relevant form 990 for the hospital foundation).
I'm happy to reconsider if more evidence comes to light. But right now, I think the answer is "no".
lac
From: Fed loan PSLF<[email protected]>

To: Ian Foss l(b)(5J I
Subject: PRH Clinic Network, LLC- Palouse Pediatrics, PLLC
Hi, We'd like your input on this one. The certifying official checked box
c and public health. I initially thought it was going to be for profit,
but I found a few things that led me to think it is governmental.
1. The WA business filing for Palouse Pediatrics (for profit) is inactive

2. The WA business filing for Pullman Regional Hospital Clinic Network
lists it as an LLC,but at the bottom of page 1 it lists one of the
"governing persons" as "Public Hospital District"

3. A google search of "public hospital district" shows that in Washington
state, public hospital districts are governmental entities and are
organized as municipal corporations.
Do you think this employer is qualifying under government? Password to

follow. Thanks
(See attached file: PRHClinic Newtork, LLC- Palouse Pediatrics.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
[email protected]
only. If you
engaging
From: Foss, Ian

Sent: 23 Feb 2017 20:11:02 +0000
To: Fedloan PSLF
Cc: l(b)(5J I
Cynthia
Subject: RE: Primary Purpose
Hi Kim,
I'm sorry to say that I think you're right. I checked in with OGC about this case quickly before replying,
and our program attorney agrees that a health insurance company is just never likely to qualify unless a
significant part of what they do is employ individuals in the appropriate SOCCodes who provide actual
heath care to people they insure. So, a very centrally managed health insurance company, who doesn't
merely have a "network" of health care providers, but instead directly employs those health care
providers, would qualify, but those who simply have a network are not likely to cut it.
So, I looked at Blue Cross Blue Shield of RI again and I think that we need to do a retraction in this case.
I'm truly sorry about the mess up on my part here.
Can you all comb through those organizations that we've approved under "public health" and provide us
a list, like you've done for public education and public interest legal services?

To: Foss, Ian
Cc: l(bJ(5J I
Battle, Cynthia
Subject: Primary Purpose
Hi Ian! After reading your most recent changes to the letter for Ms. Rudert (Vietnam Veterans of
America), and in conjunction with your recent response to Delta Dental and Ms. Delaney from AARP, we
had some additional concerns.
In response to all three organizations (Vietnam Veterans of America, Delta Dental, and AARP), you
referenced that the organization's "primary purpose" has to be to provide one of the qualifying services.
We are now concerned as to whether or not this guidance is directly conflicting with how we have been
evaluating certain organizations.
As you might recall from several years ago, we had escalated and you had provided guidance on Blue
Cross Blue Shield of RI. They are 501(c)(4), but in order to qualify would have to provide a qualifying
public service. Even though they are a health insurance company, they employ individuals who meet the
Rhode Island definition of what 'nursing' is. Due to this fact, together we determined that we could
approve as not-for-profit that provides public health services. However, the organization's primary
purpose is providing health insurance to its members.
There have been similar organizations that we had internally made a decision on based on the guidance
you provided on Blue Cross Blue Shield of RI. We just want to ensure that we are still ok to approve
organizations such as Blue Cross Blue Shield of RI on the basis that they employ an eligible position. As
always, we appreciate your assistance!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: Foss, Ian

Sent: 20 Jun 2014 13:57:07 -0500
To: Fedloan PSLF
Cc: !(b)(5) I
Subject: Re: Priority Please: NEXUS Institute
I think this is VERYcut and dry because the President said it was a for-profit, but I'll escalate it further
out of an abundance of caution.
Hi Ian, We denied this employer twice already and they are disputing the
denial again; therefore, we're asking for your confirmation of our denial.
If you can make this one a priority, we'd appreciate it.
They certified as private non-profit providing public interest law

services. Our first denial in March 2014 was because we determined that
Nexus Institute was an international organization and we couldn't find any
confirmation of the EIN or of the not-for-profit status.
The Linked In profile for the certifying official listed both the NEXUS
Institute and Warnath Group. We researched the Warnath Group and found
that the NEXUSInstitute is a sister organization. We found a business
filing for Warnath Group which is registered as an LLC(not helpful).
In May 2014 they sent a letter that didn't provide any more information
other than confirmation that they are an international human rights policy
center. We denied it again.
In June 2014 we received an email from University of Michigan where the

borrower attended law school. Univ of Ml Human Trafficking Clinic also
partners with NEXUS.They seem to think that all they need to do is
clarify that they aren't making a profit, as Kathryn Johnson (U of Ml)
states in her 6/2/14 in the email chain (doc name For Profit Memo). The
founder wrote a letter in which he specifically states that NEXUSInstitute
is organized as for a for-profit (for-benefit) entity (doc name Supporting
information for Christina Parello ... ).
If you agree that they don't qualify, I'm not sure if they will accept a
response from us. Would you prefer to respond? Please let us know.
{See attached file: Nexus Institute.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911

only. If you
individual engaging
From: l(b)(5)
Sent: 23 Jun 2014 12:54:13 -0500

To: Fedloan PSLF
Cc: Foss, l(bl( 5l ICynthia;Johnson, Debbe
Hi Diane,
I would go ahead and deny this one again. Be sure to cite the definition of "public service
organization" in the regulations, which specifically says that non-501(c){3) not-for-profits cannot be
"a business organized for-profit".
lac
From: <Foss>, Ian Foss <[email protected]>

Date: Friday, June 20, 2014 at 14:57
To: FedLoan PSLF<[email protected]>
Cc:!lb)(51 Ulb)(51 I
I think this is VERYcut and dry because the President said it was a for-profit, but I'll escalate it further
out of an abundance of caution.
On 6/20/14, 14:40, "Fed loan PSLF"<[email protected]>wrote:
Hi Ian, We denied this employer twice already and they are disputing the
denial again; therefore, we're asking for your confirmation of our denial.
If you can make this one a priority, we'd appreciate it.
They certified as private non-profit providing public interest law

services. Our first denial in March 2014 was because we determined that
Nexus Institute was an international organization and we couldn't find any
confirmation of the EIN or of the not-for-profit status.
The LinkedIn profile for the certifying official listed both the NEXUS
Institute and Warnath Group. We researched the Warnath Group and found
that the NEXUSInstitute is a sister organization. We found a business
filing for Warnath Group which is registered as an LLC(not helpful).
In May 2014 they sent a letter that didn't provide any more information
other than confirmation that they are an international human rights policy
center. We denied it again.
In June 2014 we received an email from University of Michigan where the

borrower attended law school. Univ of Ml Human Trafficking Clinic also
partners with NEXUS. They seem to think that all they need to do is
clarify that they aren't making a profit, as Kathryn Johnson (U of Ml)
states in her 6/2/14 in the email chain (doc name For Profit Memo). The
founder wrote a letter in which he specifically states that NEXUSInstitute
is organized as for a for-profit (for-benefit) entity (doc name Supporting
information for Christina Parello ... ).
If you agree that they don't qualify, I'm not sure if they will accept a
response from us. Would you prefer to respond? Please let us know.
{See attached file: Nexus Institute.zip)
Diane Freundel
Compliance Services
{717) 720-3267
fax- (717) 720-3911
only. lfyou
individual engaging
From: l(b)(5)
Sent: 19 Jul 2012 15:37:58 -0500

To: Fedloan PSLF
Cc: Foss, lan;Ninemire, Sandra;Sipple-Asher, Bessie;Johnson,
l(b)(5)
Subject: RE: PRN Ambulance
Hi Diane,
Thi~ one got lost in the shuffle. Like you, I could find no
evidence to support that it i~ a not-for-profit organin1tion, and most
not-for-profit organization~ hold thcmselvc~ out as such. I would deny
iI.
Ian
Lmailto:dfreundefa-pheaa.org I On Behalf Of FedLoan PSLF
Sent: Wednesday, July
18, 2012 8:43 PM
To:l(b)(5) I
Subject: hv: PRN Ambulance
Just want to
make sure this one wasn't overlooked. I don't think I missed
a response.
Thanh!
Diane
----- Fonvardcd by Diane f-reundcl/PHEAA on 07/18/2012 08:42

PM -----
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I Date: I
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08:56 A\1
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Public:
PRN Ambulance
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Diane
Freundel
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Hi Ian.
We're having difficulty making a determination with thi~
employer. The CA
businc~s filing doc~n't show if an organization is non-profit. We couldn't
come up with anything to point to non-profit ~talus. We were going to deny,
but I thought I would run it by you.
Pas~word to follow.
Thanh!
[attachment "PRN Ambulance.zip" deleted by Diane

Freundel/PHEAA]
Diane Freundcl
Compliance Service~
(717) 720-3267
fax-
(717) 720-3911
<lfreunde(a;pheaa .org

confidential infonnation intended for the above addre~~ees only. Ir you
receive thi~ mes~age in eITor please delete or destroy this message and,..or
attachments.

of this message.
From: l(b)(5)
Sent: 21 Feb 2012 09:18:23 -0600

Subject: RE: Pro-Active Rehab, Inc
Agreed. This i~ for-profit and therefore docs not qualify.
> -----Original
Message-----
> From: Diane Freundcl [rnailto:dfrcLmdc:g,acssucces~.org]On
Behalf Of
> FedLoan PSLF
> To:
!(b)(5) I
> Subject: Pro-Active Rehab, Inc
>
>
> Hello, We believe
this is a for-profit company based on the attached and
> therefore does not
qualify. Please confirm. Password to follow. Thanks!
>
> (See attached
file: Sessions_Pro Active Rehab.zip)
>
--------------------------------
>

allachment~.
>
civil and criminal
> message.
>
>
From: l(b)(5)
Sent: 3 Apr 2012 07:59:48 -0500

Subject: RE: Progressus Therapy LLC
You did a lot of research on this one. So, thanks!

That an entity is a 3 portfolio company 2 of a venture capital firm has no bearing
on whether it qualifies; all the term means is that the firm has invested
(perhaps heavily) in the entity and we don 1t care what the source of revenue
is. And, it 1s not even all that unusual for a not-for-profit organization to have
an investor, be it called a venture capital firm or a philanthropist.
All that matters for our purpose (in this case) is that the organization is {1) not-
for-profit, (2) provides a designated service, and (3) is not a partisan political
organization or labor union.
While it 1s undeniable that the 3 service 2 component is there, it does not appear
to be a not-for-profit organization. When I looked the entity up in the
Maryland business filings, I found that it was formed in Delaware. So, I
searched the Delaware business filings for 3 Progressus Therapy 2 and found the
entity (you appear to have searched for the principal office/registered agent
that was contained in the Maryland business filings) as 3 general LLC2 . As we 1ve
found in the past, the Delaware business filings tell you definitively whether an
organization is a not-for-profit organization or not, and this organization was
not founded as a not-for-profit in Delaware. In addition, there is no other
suggestion (save for the ECF)that it is a not-for-profit organization. Thus, it
doesn 1t qualify.
> PSLF
> Sent: Monday, April 02, 2012 8:47 PM
> To: l(b)(5J I
> Subject: Progressus Therapy LLC
>
>
> Hi, We're having trouble with this employer. They checked box c, but I can't
>confirm.All of our research is in the attachment. I can't find anything that
> specifically says they are non-profit. The reason I question their non-profit
> status is because their website lists them as a Sterling Partners portfolio
> company and Sterling Partners as a private equity firm.
> Sterling is for-profit. I'm not sure if a portfolio company can be
> considered as non-profit. Password to follow.
>
> Thanks again!
>
> (See attached file: Progressus Therapy.zip)
>
> Diane Freundel

> (717) 720-3267
> fax- (717) 720-3911
> [email protected]
>
> message.
From: Siegel, Brian

Sent: 11 Jun 2014 13:13:07 -0500
Cc: Arnold, Nathan
Subject: RE: PSLF- Alabama 811
I think it does.
From: Foss, Ian

Cc: Arnold, Nathan
Exactly. I don't see in the Alabama law that the utilities are required to be a member of this, or
any other organization, but the state law does treat the "one-call notification system" (which is
what Alabama 811 is) as "acting on behalf' of the utility in terms of the public's requirement to
notify the utility of excavation.
If anyone is interested, a copy of the law is available on Alabama 811's website:

http://www.allcall.com/alabama act 94-487.pdf.
Does that mean the we think this organization would qualify?
From: Siegel, Brian

Cc: Arnold, Nathan
Alabama 811 is similar to the group that runs the Miss Utility operation for Maryland, DC and
Delaware. In Maryland at least, state law requires all utilities to be a member of one of these
notification services. While the membership is limited, the service they provide is really to the
public -- they were created so that individuals or companies can contact one place to get utilities
to mark underground lines before any digging occurs. I don't think they really do anything else.
Brian
From: Foss, Ian

Sent: Wednesday, June 11, 20141:55 PM
To: Moran, Pamela; Siegel, Brian
Cc: Arnold, Nathan
Those issue are also frequently present with SOl(c)(_) organizations (that are not 501(c)(3)s),
but I think it's most common in 501(c)(4) organizations. This presented itself recently in an
organization that takes legal cases of clients to make political points. We said that, because their
primary purpose was more political than legal (and, frankly, seemed to be more lobbying that
anything else), that we didn't consider this to be the provision of public interest legal services.
See attached for the organization that I was thinking about.
From: Moran, Pamela

To: Foss, Ian; Siegel, Brian
Cc: Arnold, Nathan
Yes, that's what I'm recalling. I think there also may have been an issue of the membership
organization also being no more than a lobbying arm---representing their narrow interests of
the limited membership---before governmental bodies.
From: Foss, Ian

Cc: Arnold, Nathan
FINRA is a 501{c)(6) organization and we approved them. Though, I think Brian indicated (when
discussing another organization} that there might be a point at which the organization is so
exclusive that it might be deemed to not provide services to the "public".
Also, you could argue that even though the members of the organization are not the public at
large, the organization ultimately serves/benefits the public by helping it comply with the
requirements of state law.
From: Moran, Pamela

Cc: Arnold, Nathan
I thought we had said no to limited membership-based organizations because they were not
broadly serving the general public?
From: Foss, Ian

Cc: Arnold, Nathan
Subject: PSLF- Alabama 811
Pam and Brian,
We have a 501(c){6) organization called "Alabama 811" whose purpose it is to streamline the
compliance with state law requirements to notify the various public utilities before excavating
under any piece of property. They are saying that they provide public safety services.
The state law {Underground Damage Prevention Act) on which the service is predicated has the
following stated purpose:
The purpose of this act is to safeguard against injury and loss of life due to excavation or
demolition and to protect underground facilities from costly damage and the
interruption of utility or other services to the general public.
The "members" of the 501(c)(6) organization, remember, the (c)(6) is a membership-based

organization are the public utilities that are notified by the 501(c)(6).
Though all of the various categories of organizations that are not government or 501(c)(3) are
always hazy for me, I think this would constitute a "public safety" service. Do you?
Ian
From: Foss, Ian

Sent: 16 Feb 2016 19:01:29 +0000
To: Siegel, Brian;Hoblitzell, Barbara;Mclarnon, Gail;Smith, Brian;Weisman,
Annmarie
Subject: RE: PSLF - Alpha Phi Alpha Educational Talent Search
Good point, Brian. We have never approved an organization under the category of other ~chool-ba~cd
~crvicc~. We had one organization try to come in under that category, but they were an educational
management corporation that wa~ organized as a not-for-profit corporation and wa~ not tax-exempt as a
501 (c )(3). Wc ~aid that it didn't qualify because it didn't provide services to studcnts/fami lies; instead, it
provided ~crvice~ to schoob.
From: Siegel, Brian
Sent: Tue~day, February 16, 2016 11:55 AM
To: IloblitLclL Barbara; Foss, Ian; McLamon, Gail; Smith, Brian; Wci~man, Annmarie
Talent Search is one of the Federal TRIO grant programs administered by ED. Alpha Phi Alpha is a
grantee that provides grant funded services. Traditionally TRIO grantees provide at least some oftheir
services at high schools they identify in their application. I don't knov.,whether we have any precedents for
defining "school-based services" broadly or narrowly. Ifwe interpret it broadly they seem to qualify.
Brian
From: Hoblitzell, Barbara
To: Po~~, Ian; Siegel, Brian; McLarnon. Gail; Smith. Brian; Weisman, Annmarie
According to their website," Alpha Phi Alpha Educational Talent Search i~ governed by the Epsilon Beta
Lambda Chapter of Alpha Phi Alpha Fraternity, Incorporated Board of Directors" who~c website dc~cribc~
the Talent Search as" ...a federally funded program through the United State~ Department of Education.
All services arc FREE! ETS provides educational guidance services lo individuals in five Middle Georgia
countie~ to help them graduate from ~ccondary school and enroll in po~t-sccondary schools. ETS provides
services to individuals who arc between the ages of 11 and 27 years old with the potential to succeed in a
post-secondary educational ~citing (college, university, or vocational)".
Not sure this fits well with the "other school-based services" since it's not really 'school-based', but it
should fit into some public service category ..
From: Foss, Ian
Sent: Tuesday, February 16, 20 16 11:34 AM
To: Siegel, Brian; \1cLarnon, Gail; Smith, Brian: Hoblitzell, Barbara; Weisman, Annmarie
Just fo!IO\vingup on this one.
From: Fo~~, Ian
Sent: Friday, Fcbruary05.20161 l·l 1 AM
To: Siegel, Brian; \1cLarnon, Gail: Smith, Brian; Hoblitzcll, Barbara; Weisman, Annmarie
Subject: PSLf- - Alpha Phi Alpha Educational Talent Search
Hi PSLF gang,
We have an escalated employer that I need your input on. The organi?ation i~ a not-for-profit organization
that i~ not a 50\(c)(]), and ~o must provide a public ~crvicc to qualify for PSLF.
Herc is what the organin1tion docs:
> We arc proud to he the longest running Talent Search in Macon, Georgia. Our organization has hccn in
existence since September 1, 1978. Our staff is committed lo working with students from grades 6-12 who
have college potential hut arc nol aware of academic and career opporlunitic~ that arc available to them
beyond high school. Through our cxccllcnl educational guidance service~, we arc able to promote high
school graduation and enrollment into ~omc form ofpost~ccondary in~tilulion. We offer SAT. PSA T, and
/\CT training. We abo offer training with the Georgia Iligh School Graduation Test. And, we pay for our
students to take the SAT and ACT. In addition. our organization 1,villpay up to four college application
fees for high school seniors. We assist students with creating academic resumes and completing financial
aid fonns. Workshops on study skills. time management and applying for college is offered throughout
each academic year. \1iddle grades students have access to our after school tutorial component named
Project Climb. We also sponsor trips to college fairs, college campuses throughout the Southern states, and
Math and Science summer programs offered at various college campuses throughout the Southeast.
Because Alpha PhiAlpha Educational Talent Search is federally funded, all services we provide to the
students are free. The staff at Alpha Phi Alpha Educational Talent Search strive to continue with our
legacy of excellence in the area of preparing our youth for postsecondary education.
I think this would count as "other school-based services". Since there's no definition of the term, however, I
wanted to check with you all.
Thanh,
Ian
From: Siegel, Brian

Sent: 8 Feb 2012 13:52:59 -0600
Cc: Ninemire, Sandra;Utz, Jon;Jenkins, Harold
Subject: RE: PSLF:American Civil Liberties Union of VT
While not clearly defined, from my review the term "partisan political organization" refers to an organization affiliated with a
partidar political party -- Democratic, Republican, Socialist, whatever. The ACLU is not affiliated with a political party. Lobbying
for legislation would not by itself turn an organizaion into a partisan political organization.
Brian
From: Foss, Ian

Sent: Wednesday, February 08, 2012 1:29 PM
Cc: Ninemire, Sandra; Utz, Jon; l~(b~l(~5~1
--~
Subject: PSLF: American Civil Liberties Union of VT
Pam and Brian,
This is the first employer that we are escalating to you for PSLFpurposes as part of the interim
certification process that we instituted.
Our servicer is asking whether 501(c)(4) organizations, such as the ACLU of VT, would be
considered a public service organization, or whether it is disqualified because it is a "partisan
political organization", which is referenced in the definition of a public service organization, but
not further defined.
I'll note that 501(c)(4) organizations may, unlike 501(c)(3) organizations, lobby for legislation
(though not all of them do so). However, 501(c)(4) organizations cannot become involved in
political campaigns. They also must be operated on a not-for-profit basis, with their general
scope being the promotion of social welfare. See here for more:
http://www.irs.gov/i rm/pa rt7 /irm 07-025-004.html#d0e332.
I'd also note that the ACLU does provide a designated public service; namely, public interest
legal services.
I'd assume that, if we do not think that 50l(c)(4)s that lobby for legislation qualify as a public
service organization, that it would not mean that all 50l(c)(4)s are disqualified, especially
because not all of them lobby. In other words, saying one 50l(c)(4) does not qualify would not
mean that none of them qualify.
Any light you could shed on the meaning of "partisan political organization" would be helpful,
particularly with regard to the ACLU of VT.
Thanks,
(an

> Fedloan PSLF
> Sent: Wednesday, February 08, 2012 12:36 PM
>To:l(b)(5J I
> Subject: American Civil Liberties Union of VT
>
>
> Good afternoon,
>
> We're unsure if the ACLU is a qualifying organization since they are a 501
> {c)(4) and engage in political lobbying, although they are non-partisan.
> The certifying official checked box c and both public interest law services and
> public education.
>
> EIN - 00-03-0221930
>
> Thanks!
>
> Diane Freundel
> (717) 720-3267
> fax- (717) 720-3911
> [email protected]
>
>
>==========================================================
>====================
>
> message.
>==========================================================
>====================
From: l(b)(5)
Sent: 9 Mar 2017 21:34:23 +0000
To: Foss, l(b)(5J I
Subject: RE: PSLF-American Public Transportation Association
I found my notes and Rene and I also thought this one didn 1 t qualify. Thanks for looking at this.
I'll forward over and will request a letter to review before we mail out
Thanks,
Taneka
From: Foss, Ian
Sent: Thursday, March 09, 2017 8:46 AM
To: l(bJ(5J I
Subject: PSLF- American Public Transportation Association
Hi Taneka,
Let's go ahead and deny the American Public Transportation Association. It seems nobody made a
decision on the organization while I was on detail.
I looked at their bylaws and here are their objectives:
The objectives of this Association are:
A. To represent the public interest in improving public transit for all persons.
B. To represent the interests, common policies, requirements, and purposes of public transit.
C. To provide a medium for exchange of experiences, discussion, and comparative study of
public transit affairs.
D. To promote research and investigation to the end of improving public transit.
E. To aid members in dealing with special issues.
F. To encourage cooperation among its members, their employees, and the general public.
G. To encourage compliance with the letter and spirit of equal opportunity principles.
H. To collect, compile, and make available to members data and information relative to public
transit.
I. To assist in the training, education, and professional development of all persons involved in
public transit.
J. To engage in any lawful activities which will serve the members and promote public transit.
None of the services indicated on the ECFare part of their primary purpose. Since this was escalated to
compliance, we should have them do a custom denial letter listing the objectives found in the bylaws
and why the organization doesn't qualify.
Ian
From: Foss, Ian

Sent: 16 Feb 2016 15:51:04 +0000
To: Siegel, Brian;Weisman, Annmarie;Smith, Brian;Mclarnon, Gail;Hoblitzell,
Barbara
Subject: RE: PSLF-Amtrak
Thanks, everyone!
From: Siegel, Brian
To: Weisman, Annmarie; Smith, Brian; Foss, Ian; Mclarnon, Gail; Hoblitzell, Barbara
Subject: RE: PSLF- Amtrak
Considering that the Supreme Court decision determined that other factors which indicated that Amtrak
should be treated as a governmental entity outweigh the factors on which we relied to say that it
wasn't, I agree that we should change our decision and treat it as a governmental entity.
Brian
From: Weisman, Annmarie
To: Smith, Brian; Foss, Ian; Siegel, Brian; Mclarnon, Gail; Hoblitzell, Barbara
I'd consider Amtrak to be quasi-governmental. While I understand the 2013 decision, I think the
Supreme Court ruling justifies a change and allows for PSLF.
From: Smith, Brian
To: Foss, Ian; Siegel, Brian; Mclarnon, Gail; Hoblitzell, Barbara; Weisman, Annmarie
I would say, based on the Supreme Court's ruling, that Amtrak qualifies as a government "entity. 11
We've run across similar situations before in connection with mass transit systems, which often
have somewhat unique organizational structures (especially ones that serve areas in several
different governmental jurisdictions). Generally (for purposes of law enforcement cancellations for
transit police) we've treated these systems as government entities.
Brian
From: Foss, Ian
To: Siegel, Brian; Mclarnon, Gail; Smith, Brian; Hoblitzell, Barbara
Subject: PSLF- Amtrak
Hi all,
Back in 2013, we relied on the statute that created Amtrak to say that it is not a governmental entity
and did not otherwise qualify for PSLF.The statue says two things that we relied on to disqualify it for
PSLFpurposes:
•Amtrak "is not a department, agency, or in-strumentality of the United States
Government." 49 USC 24301(a)(3).
•Amtrak "shall be operated and managed as a for profit corporation." 49 USC24301(a)(2).
In 2015, the Supreme Court ruled that, for the purposes of the constitutional separation of powers
analysis, Amtrak is a governmental entity. Though, of course, the Supreme Court case was about a
limited issue, the analysis would seem to support a reading that Amtrak is fundamentally governmental,
whatever the statute says. The opinion, which goes into a fair amount of detail about how Amtrak is
organized and tied to the government, is here.
I'm of two minds about whether this means anything at all for PSLFpurposes. What do you all think?
Also consider whether we couldn't approve Amtrak as a "quasi-governmental" organization in light of

the statute language I cited above.
Ian
From: Siegel, Brian

Sent: 9 Dec 2013 13:01:29 -0600
To: Moran, Pamela;Foss, Ian
Cc: Arnold, Nathan
Subject: RE: PSLF:Another Indian Casino
I agree.
From: Moran, Pamela

Sent: Monday, December 09, 2013 1:45 PM
Cc: Arnold, Nathan
Subject: RE: PSLF: Another Indian Casino
I thought I reluctantly said yes.
From: Foss, Ian

Sent: Monday, December 09, 2013 1 :42 PM
Cc: Arnold, Nathan
Subject: Re: PSLF: Another Indian Casino
Brian and Pam,
Just \Vanted to follow-up on this one. Have you had time to consider?
Ian
On Nov 14, 2013, at 11:28, "Foss, Ian" <lan.Foss({l,,cd.gov>wrote:
Hi Brian and Pam,
I escalated an indian casino to you in the past. We rejected the employer

because there \Vere not sufficient links to the tribal government. Pam \Vas
against having any indian casino qualify, as a matter of policy, if memory
serves.
We now have another indian casino, which is chartered by the tribal

government, and, according to the certifying official of the ECF: '·Valley
View Casino and Hotel is an entity of the San Pasqual Band of Mission
Indians". The employer also certified the borrower's ECF as a "government
organization''.
As with most records associated with indian tribes, I cannot find out much
about it aside from this website (\vhich I'm prohibited from accessing on the
ED network because it is associated with gambling) and this ne\vs article,
which makes mention of the casino's links to tribal government and even
calls it a '·government casino".
What do you think?
Ian
From: Siegel, Brian

Sent: 10 Feb 2014 13:40:26 -0600
Cc: Arnold, Nathan
Subject: RE: PSLF- Bar Association of San Francisco
I agree with Pam.
Brian
From: Moran, Pamela

Sent: Monday, February 10, 2014 9:55 AM
Cc: Arnold, Nathan
Subject: RE: PSLF - Bar Association of San Francisco
I don't think they qualify.
From: Foss, Ian

Cc: Arnold, Nathan
Subject: Re: PSLF - Bar Association of San Francisco
Hi Brian and Pam,
Do you have any thoughts on the below?
Thanks,

Date: Monday, January 27, 2014 at 11:11
To: "Siegel, Brian" <[email protected]>, "Moran, Pamela" <[email protected]>
Cc: "Arnold, Nathan" <[email protected]>
Subject: PSLF- Bar Association of San Francisco
Brian and Pam,
We received a PSLFform with The Bar Association of San Francisco as the employer. The organization is a
S01(c)(6). Like most bar associations, it runs a number of programs that are designed to open up access to
legal services to the indigent. However, as is also typical, those who could be deemed to be providing "legal
services" are volunteer attorneys, not employees of the organization. Would facilitating the provision of
legal services be sufficient?
The only one program where it seems that employees of the organization are prodding legals services is the
Justice and Diversity Center, which is independently organized and separately tax-exempt as a 501(c){3).
Information about the programs that the organization provides is

here: http://www.sfbar.org/a bout/programs.aspx.
We had another organization that provided similar "coordination" /"facilitation" services, but we said that it
qualified as a quasi-governmental organization {even though it was tax-exempt as a 501(c)(4)).
What do you think?
Ian
From: Foss, Ian

Sent: 17 Jul 2012 20:27:00 +0000
To: 'Diane Freundel'
Cc: Sipple-Asher, Bessie;Battle, Cynthia;Johnson, Debbe;Ninemire,
l(b)(5)
Subject: RE: PSLF- Charter Schools
Diane,
Thanh again for going back and checking. After discussing this with others, we would foci more
comfortable ifwc took an approach to charter schools whereby whatever organization that hold~ the
chai1eriemploys the borrower must independently demon~trate that that organization qualify.
Thus, in the case of an organization that 1~ tax-exempt under 501 (c)(3) of the tax code, they would qualify,
but not as government. The same holds true for other non-profits providing public education. Thi~ would
have the effect of ~aying that no charter school would qualify under the government calegmy, and if the
borrower 1~ employed by a for-profit that either hold~ a charier or runs a charier ~chool, it is not a PSLF-
qualifying employer.
Ian
From: Diane Freundel [mailto:dfreundefa'.pheaa.orgl
Sent: Monday, July 16, 2012 9:39 AM
To: Foss, Ian
Cc: Sipple-Asher. Bessie; Battle, Cynthia; Johnson, Debbe; Ninemire, Sandra
Subject: RE: PSLF - Charter Schools
Hi Ian, I reviewed 10 that we approved. I'm confident that they arc all eligible, but I'm not ~urc about the
type of organization under which we approved them.
The attached file contain~ the following:
1. Wikipcdia definition of Charter School - one thing ~urpriscd me - it ~ay~that a public school can be
managed by a for profit - is that correct?
2. Information from Sandpoint Charter School's website - what is a charter school - authorized by Tille 33
of the Idaho Code - a nonprofit publicly funded and nonsectarian entity.
3. Information from North Star Academy's Wikipedia entry - lists the "authority" as Uncommon Schools,
Inc (which I verified is a private
nonprofit) and the NJ Comm. of Education. We approved this one as government - I think it should be
private non-profit.
4. Two items about Desert Sands Charter School - from their website - CA legislature passed the Charter
School's Act in 1992. And from the CA state website - info about the school stating it is "directly funded".
We approved as government - they certified as private non-profit
File is zipped so I could send one folder - no password as I didn't include an borrower data. If you'd like to
see any of the ECFs for EINs let me
know. Thanks.
(Sec attached file: Charter School~.7ip)
Diane Frcundcl
Compliance Services
(717) 720-3267
fax-(717) 720-3911
org
1------------>
I From:
1--------->
>------------------------------------------------------------------------------------------------------------------------------
"Fos~. Ian" <lan.Foss(d)cd.gov>

>------------------------------------------------------------------------------------------------------------------------------
1------------>
I ro, I
1------------>
>------------------------------------------------------------------------------------------------------------------------------
"Diane Freundel" <[email protected]>
>------------------------------------------------------------------------------------------------------------------------------
1------------>
ICc I
1------------>
>------------------------------------------------------------------------------------------------------------------------------
"Sipplc-A~hcr. Bessie" <Bc~~icKo.SipplcA~hcr(c(cd.gov>. "Battle, Cynthia" <Cynthia.Battlc((_l'.cd.gov>.

"Johnson, Dcbbc" I
<Dcbbc.John~on½_~·cd.gov>,"Nincmirc, Sandra"
<[email protected]>
>------------------------------------------------------------------------------------------------------------------------------
1--------->
I Date: I
1--------->
>------------------------------------------------------------------------------------------------------------------------------
07/J3/2012 03:22 PM
>------------------------------------------------------------------------------------------------------------------------------
1------------>
I Subject: I
1------------>
>------------------------------------------------------------------------------------------------------------------------------
RE: PSLF - Charter Schools
>------------------------------------------------------------------------------------------------------------------------------
Thanh, Diane. That worb for me.

> From: Diane Freundel [mailto:dfreundefa'.pheaa.orgl
> Sent: Friday, July 13, 2012 1:08 P\1
>To: Fo~~, Ian
> Cc: Sippk-A~hcr. Bessie: Battle, Cynthia: John~on. Dchbc: Nincmirc,
Sandra
> Subject: Re: PSLf, - Charter Scools
>
> Iii Ian, We've had 83 charier schools and 4 magnet ~chools. 59 were
> approved and 28 were denied - the denials could have heen for any
> rea~on. such a~ no Direct Loans. Mo~t of them were not ~enl lo
> Compliance for review, so I can spot check some of the approvab and
> lei you know. b Monday OK? lhanb
>
> Diane Freundel
> (717) 720-3267
> fax-(717) 720-391 I
>
>
> 1------------>
> I horn:
> 1------------>
>
> ----------------------------------------------------------------------
> -------------------
> ------------------------------------------1
> 'To~~, Ian" <lan.Foss((j)cd.gov>
>I
>
>-----------------------------------------------------------------------
>--------------------
> ---------------------------------------------1
> 1------------>
> I To, I
> 1------------>
>
>-----------------------------------------------------------------------
>--------------------
> ---------------------------------------------1
> "Diane Freundel" <[email protected]>
>I
>
>-----------------------------------------------------------------------
> -------------------
> ------------------------------------------1
> 1------------>
>IC" I
> 1------------>
>
>-----------------------------------------------------------------------
>--------------------
> ------------------------------------------1
> "Battle, Cynthia" <Cynthia.Battk½_~·cd.gov>, "Nincmirc, Sandra"

> <[email protected]>, "Sipple-Asher. Bessie"
I
> <[email protected]>, "Johnson, Dcbbc"
> <Dcbbc.Johnson(j_i;cd.gov>
I
>
>-----------------------------------------------------------------------
>--------------------
> ---------------------------------------------1
> 1------------>
> I Date: I
> 1------------>
>
>-----------------------------------------------------------------------
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> ---------------------------------------------1
> 07/12/2012 06:19 PM
>I
>
> ----------------------------------------------------------------------
> -------------------
> ------------------------------------------1
> 1------------>
> I Subject: I
> 1------------>
>
>-----------------------------------------------------------------------
>--------------------
> ---------------------------------------------1
> PSLF - Charter Scools
>I
>
>-----------------------------------------------------------------------
>--------------------
> ---------------------------------------------1
>
>
>
>
>
> Hi Diane,
>
>Previously.we had provided you guidance to the effect of "charter
~choob
> arc public ~choob" and therefore qualify in the government category
> of eligible PSLF employer. While I still believe that this is, by and
> large,
a true
> statement, I wanted to get a sense from you how many you have seen
> come through.
>
> I worry that, in certain ~tatc~,charter school~ may not be con~idcrcd
public
> ~choob, particularly when they can operate on a for-profit basis or
>when
the
> employees at the chai1cr arc completely exempt from the requirements
> al1Ccting traditional public ~chool teachers.
>
> Thanh,
>
> Ian
>
>
>
foe
> the above addressees only. If you receive this message in error
> please delete or destroy this message and/or attachments.
>
> The sender of this message will fully cooperate in the civil and
> criminal prosecution of any individual engaging in the unauthorized

Sent: 17 Jul 2012 16:30:50-0400
To: Foss, Ian
Cc: Sipple-Asher, Bessie;Battle, Cynthia;Johnson,
75)~---------'-'--,
rn(b~)( Sandra
Subject: RE: PSLF- Charter Schools
Thanh for the infomrntion. I think I need to go hack to some that

I
thought would be con~idcrcd government. Based on a fairly quick review,
I
don't think I could tell irthey were for profit or non-profit and
they
seemed to be governmental. I may need you lo look al ~orne.
Diane
Freundel
Compliance Services
(717) 720-3267
fax-(717)
720-3911
1------------>
I From:
1------------>
> --------------------------------------------------------------------------
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'To~~,
Ian" <lan.Fos~((_l'.cd.gov>
I
>---------------------------------------------------------------------------
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1------------
>
I To, I
1------------>
>---------------------------------------------------------------------------
-------------------------------------------------------------1
"Diane
Freundel" <dfreunde(?i)pheaa.org>
I
>---------------------------------------------------------------------------
-------------------------------------------------------------1
1------------
I c" I
1------------>
> --------------------------------------------------------------------------
-------------------------------------------------------------1
!"Sipple-Asher, Bc~~ic" <Bcs~icKo.SipplcA~hcr(j_i;cd.gov>, "Battk, Cynthia"
<Cynthia.Battlc(j_i;cd.gov>, "Johnson, Dchhc" I
<Dcbhc.Johnson((1)cd.gov>, "Nincmirc, Sandra" <Sandra.Nincmirc(ji;cd.gov>,

(b)(5) l(b)(5) I I -
>---------------------------------------------------------------------------
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1------------
>
I Date: I
1--------->
>---------------------------------------------------------------------------
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07/J7/2012
04:27 PM
I
>---------------------------------------------------------------------------
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1------------
I Subject:
1------------>
> --------------------------------------------------------------------------
-------------------------------------------------------------1
RE: PSLF -
Charter Schools
>---------------------------------------------------------------------------
-------------------------------------------------------------1
Diane,
Thanks again for going back and checking. After discussing this
with
others. we would feel more comfortable ifwe took an approach to
charter
~choob whereby whatever organin1tion that hold~ the charter/employ~
the
borrower mu~t independently dcmon~tratc that that organization
qualify.
Thus, in the case of an organization that i~ tax-exempt under

50l(c)(3) or
the tax code, they would qualify. hut not as government. The
same holds
true for other non-profits providing public education. This
would have the
effect of ~aying that no charter ~chool would qualify under
the government
catcgoty, and if the borrower i~ employed by a for-profit
that either hold~
a charter or runs a charter schooL it i~ not a
PSLF-qualifying employer.
Ian
From: Diane
Freundel Lmailto:dfreunde:11-pheaa.or!!.J
Sent: Monday, July 16, 2012 9:39 AM
To:
Foss, Ian
Cc: Sipple-Asher, Bessie; Battle, Cynthia; Johnson, Debbe;
Ninemire, Sandra
Subject: RE: PSLF - Charter Schools
Hi Ian, I reviev,red 10
that we approved. I'm confident that they are all
eligible, but I'm not
~urc about the type of organization under which we
approved them.
The
attached file contains the following:
I. Wikipcdia definition of Charter

School - one thing suq1riscd me - it
says that a public ~chool can be
managed by a for profit - is that correct?
2. Information from Sandpoint

Charter School's website - what is a charter
school - authorized by Title 33
of the Idaho Code - a nonprofit publicly
funded and nonsectarian
entity.
3. Information from North Star Academy's Wikipedia entry - lists

the
"authority" as Uncommon Schools, Inc (which I verified is a
private
nonprofit) and the NJ Comm. of Education. \Ve approved this one
a~
government - I think it should be private non-profit
4. Two items
about Desert Sands Charter School - from their website - CA
lcgi~lature
passed the Charter School's Act in 1992. And from the CA ~talc
website -
info about the school stating it is "directly funded". \Ve

approved as
government- they certified as private non-profit.
File i~ zipped ~o I
could send one folder - no pa~~word a~ I didn't include
an borrower data.
If you'd like to sec any of the [Cf,\ for [INs let me
know. Thanh.
(Sec
allachcd file: Charter Schools.Lip)
Diane Frcundcl
Compliance
Services
(717) 720-3267
fax-(717)
720-3911
[email protected]
1------------>
I From:
I
1------------>
> --------------------------------------------------------
---1
"Fos~. Ian"
<lan.Foss(d)cd.gov>
I
>------------------------------------------------------
------1
1------------'
I To:
I
1------------>
>---------------------------------------------------------
---1
"Diane Frcundcl"
<dfrcundc((j)phcaa.org>
I
> --------------------------------------------------
1------------>
I Cc:
I
1------------>
> --------------------------------------------------------
---1
"Sipplc-A~hcr, Bessie" <Bc~~1cKo.SipplcA~hcr(a;cd.gov>, "Baltic,
Cynthia"
<Cynthia.Baltlc(t1Jc<l.gov>, "Johnson, Dcbhc"
l<Dcbbc.Johnson(d)cd.gov>, "Nincmirc, San<lra"

<[email protected]>
I
>-----------------------------------------------
-------------1
1------------>
I Date:
I
1------------>
> --------------------------------------------------------
---1
07/13/2012 03:22
PM
I
>---------------------------------------------------------------------
-------------------------------------------------------------------1
1-----
------->
I Subject:
I
1------------'
>---------------------------------------------------------
---1
RE: PSLF - Charter
Schools
> ---------------------------------------------------------------
Thanh, Diane. That worb for me.

> From:
r
Diane Frcundcl mailto:dfrcundc:gphcaa.orgl
> Sent: Friday, July 13, 2012
I :08 P\1
> To: Fos~. Ian
> Cc: Sipplc-A~hcr, Bessie: Battle, Cynthia:
John~on. Dcbbc; Nincmirc,
Sandra
> Subject: Re: PSLF - Charter Scools
>
> Hi
Ian, We've had 83 charter schools and 4 magnet schools. 59 were
>
approved and 28 \vere denied - the denials could have been for any
> reason,
such as no Direct Loans. \1ost of them were not sent to
> Compliance for
review, so I can spot check some of the approvals and
> let you know. Is
Monday OK? thanks
>
> Diane Frcundcl
> (717)
720-3267
> fax-(717) 720-3911
> dfrcundc(a;phcaa.org
>
>
> 1------------>
> I
From:
>
1------------>
>
>----------------------------------------------------------
>--------------------
>
---------------------------------------------1
> "Foss, Ian"
<Ian. Foss((j)cd.gov>
>
>
> ----------------------------------------------------------------------
> -------------------
> ---------------------------------------------1
1------------>
> I To: I
1------------>
> ---------------------------------------------------------
>--------------------
>
---------------------------------------------1
> "Diane Freundel"
<dfreun<le(d)pheaa.org>
>
>
>-----------------------------------------------------------------------
>--------------------
> ---------------------------------------------1
>
1------------>
> I Ce: I
>
1------------>
>
> ---------------------------------------------------------
> -------------------
>
---------------------------------------------1
> "Batlle, Cynthia"
<Cynthia.Baltlc(t1Je<l.gov>, "Ninemire, Sandra"
> <San<lra.Ninemire(a;'ed.gov>,
"Sipple-Asher, Bessie"
I
> <[email protected]>, "Johnson,
Debbe"
>
<Debbe.Johnson(?i)ed.gov>
I
>
>------------------------------------------------
>--------------------
>
---------------------------------------------1
> 1------------>
> I Date:
I
>
>
>----------------------------------------------------------
> -------------------
>
---------------------------------------------1
> 07/12/2012 06:19 PM
>
>
>-----------------------------------------------------------------------
>--------------------
> ---------------------------------------------1
>
1------------>
> I Subject:
>
1------------>
>
>----------------------------------------------------------
>--------------------
>
---------------------------------------------1
> PSLF - Charter Scoob
>
>
> ----------------------------------------------------------------------
>--------------------
>
---------------------------------------------1
>
>
>
>
>
> Hi Diane,
>
>
Previously. we had provided you guidance to the effect of "charter
schools
>
are public schools" and therefore qualif)'" in the government category
>of
eligible PSLF employer. While I still believe that thi~ i~. by and
>
large,
a true
> ~tatement I wanted to get a ~en~e from you how many you
have seen
> come through.
>
> I \VOITY that, in certain states, charter

schools may not be considered
public
> ~choob, particularly when they can
operate on a for-profit ba~i~or
>when
the
> employees at the charter arc
completely exempt from the requirement~
> al1Ccting traditional public
school teachers.
>
> Thanh.
>
> Ian
>
>
>
> This message contains
privileged and confidential information intended
foe
only. If you receive this message in error
> please delete or destroy this
>
> criminal pro~ccution of any individual engaging
in the unauthorized
This message contain~

privileged and conlidcntial infonnation intended for
the above addressees
delete or destroy this
The sender of this message will fully cooperate

in the civil and criminal
prosecution of any individual engaging in the
message.
Thi~ message contain~ pri\'ilegcd and

receive thi~ mc~~agc in error plca~c delete or dc~troy this message and/or
attachmcnb.
and criminal prosecution of any individual engaging

in the unauthorized use
of this mc~~agc.
From: [email protected]
Sent: 17 Feb 2016 09:03:11-0500
To: Siegel, Brian
Cc: Smith, Brian;Mclarnon, Gail;Hoblitzell, Barbara;Weisman, Annmarie
Subject: Re: PSLF- Consumer Federation of California
Thanks, Brian.
On Feb 16, 2016, at 15:55, Siegel, Brian <Rrian.Sicgcl({l,,cd.gov> wrote:
Here is the description of cy pres funding from the Federation's website:

Cy Pres Awards-Vital for Consumer Rights
Cy pres awards from consumer class action cases are a source of funding for Consumer
Federation of California's advocacy work. Courts approve cy pres distributions to CFC in
recognition of the effectiveness of our work for millions of consumers.
Cy pres awards are residual payments from class action lawsuits when a full distribution of
a settlement or court award to members of the class is not achieved or is impractical.
California law instructs courts to distribute cy pres residuals to "nonprofit organizations or
foundations to support projects that will benefit the class or similarly situated persons,
or that promote the law consistent with the objectives and purposes of the underlying
cause of action, most likely to serve and protect the plaintiff class..." California Civil Code
Section 384 (emphasis added). This unambiguous public policy favors the distribution of cy
pres funds to support legislative advocacy on behalf of consumers, which is CFCs core
m1ss1on.
The Consumer Federation of California is an active force at the state capitol and before
administrative agencies. The breadth of our work in California is unrivaled. Recent
legislative work includes safeguarding our financial and medical privacy, eliminating
deceptive marketing scams, cracking down on elder abuse, improving food and drug
safety, derailing homeowners insurance rate hikes, auto insurance steering practices and
health insurance rescission practices, banning toxics from household products, requiring
truth in advertising from for-profit colleges, and safeguarding low-income and limited-
English customers from discrimination by utilities. That's just a short list of the campaigns
we take on.
CFCis virtually unique because we use every penny of a cy pres award to advance the
rights of consumers. CFC is approved by the IRSas a non-profit organization under a
section of the tax code [SOl(c) 4] that permits unlimited advocacy.
If the parties restrict cy pres distributions to tax-deductible charities under IRSsection
SOl(c) 3, the Consumer Federation of California Education Foundation is an eligible
recipient. Our Education Foundation conducts education and research on key consumer
issues.
As Ian notes, the funds come from funds that are not distributed after a resolution of a
class action. In my view, these funds are not government provided funds. They are funds
from (in most cases) private parties that have agreed to or been ordered to pay in
connection with a class action. The government wouldn't have any involvement in
determining who gets the funds if the parties are able to divide it all up. They are not
appropriated funds or otherwise under the control of a government agency.
I note however, that the Federation 1 s Educational Foundation is a (c)(3) and is a qualified
organization for PSLFpurposes.
Brian
From: Foss,Ian
Sent: Tuesday,February 16, 2016 11:48 AM
To: Siegel,Brian; Smith, Brian; Mclarnon, Gail; Hoblitzell, Barbara; Weisman, Annmarie
Subject: PSLF- Consumer Federation of California
Hi all,
Here's another PSLFescalation, and the last one for today. This organization, the
Consumer Federation of California, is a 501{c)(4) that does what you would expect every
other consumer protection organization to do-it lobbies legislators in California to
support more consumer friendly policies and represents people who have consumer
protection claims in California. Given the good documentation we can find of their legal
representation, we know that they provide legal services to the public; however, we've
had some trouble confirming that they receive government funding.
After some sleuthing, I found out that nearly 70% of their funding comes from court-
ordered cy pres awards. Acy press award is something that courts provide to not-for-profit
organizations that provide legal services to the indigent with funds that are left over from,
for example, class action lawsuits. For the purposes of PSLF,would we consider a cy pres
award as "government funding"?
I think we were thinking more about appropriations or grants from executive agencies with
the language in the PSLFregulations about government funding, but this would seem to fit,
too.
Ian
From: Foss, Ian

Sent: 10 May 2013 19:21:05 +0000
To: Siegel, Brian;Moran, Pamela
Subject: RE: PSLF- Council of State & Territorial Epidemiologists
(b)(5)
Thanks, Brian.
From: Siegel, Brian

Sent: Friday, May 10, 2013 3:03 PM
Subject: RE: PSLF- Council of State & Territorial Epidemiologists
It looks to me that this group is a professional association like the American Bar Association, the Federal
Bar Association and all the other groups that have conventions. All of those groups provide important
educational opportunities to their members, may provide opportunities to their members to provide
public services to low income communities, etc .. but they don't seem to meet the definition of a public
service organization since their purpose is to serve their members in various ways not to serve the
public.
Brian
From: Foss, Ian

Subject: PSLF- Council of State & Territorial Epidemiologists
Brian and Pam,
We have had the Council of State & Territorial Epidemiologists come forward as a potentially qualify
organization for PSLF. It is a 501(c)(6) organization. It's "active" members are those who practice in the
field for a government, so we could try and fit the organization in as an intergovernmental organization,
though I'm not quite sure that just because someone who practices in the profession for the
government means that the government, itself, is a member of the organization. That being said, I am
also seeing that some of its "active members" are part of the Canadian and UK government, so I'm
worried that this avenue is closed as a result. You can read more about its members here.
The other option is determining whether the organization provides a qualifying service. The obvious
one would be public health, and I think the organization actually does provide public health services in
some form, though there's also an argument that this is just another 501(cl(6) that provides no bona
fine services, and is just a "talk shop". You can see an overview of the types of work it does by looking
on its website, where it touts its accomplishments, here.
What do you both think? Does this organization qualify for PSLF?
Ian
From: Smith, Brian

Sent: 5 Nov 2015 16:21:50 +ODDO
To: Mclarnon, Gail;Foss, lan;Siegel, Brian;Arnold, Nathan
Cc: Utz, Jon;Chialastri, Taneka
Subject: RE:PSLF- DC37
I am satisfied as well.
Brian
Sent: Thursday, November 05, 2015 11:00 AM
To: Foss, Ian; Siegel, Brian; Arnold, Nathan; Smith, Brian
Cc: Utz, Jon; Chialastri, Taneka
Subject: RE: PSLF- DC 37
If Brian Siegel is satisfied, I'm fine with it.
From: Foss, Ian
To: Siegel, Brian; Mclarnon, Gail; Arnold, Nathan; Smith, Brian
Thanks, Brian. Personally, the letter from the employer's lawyer satisfies me that benefits are not
restricted to union members.
Gail/Brian, do you have thoughts on this?
From: Siegel, Brian
To: Foss, Ian; Mclarnon, Gail; Arnold, Nathan; Smith, Brian
My basic objection was that the organization was providing services solely to members as a membership
benefit. If we are satisfied that is not accurate then I would agree that this would qualify.
Brian
From: Foss, Ian
Hi all,
Just wanted to nudge on this issue. This does seem to be a bit more like a legal aid office than we
originally thought.
Thanks,
'"
From: Foss, Ian
So, it seems this was escalated again-this time directly to me. The organization's lawyer has written to
me further explaining what the organization does. It seems the legal services provided are not just to
union members. Read the below and let me know what you think.
DC 37 provides services nearly identify to those provided by legal aid offices, at no cost to the
individual represented. By case volume, DC 37's legal services department is primarily involved in
representing this population in housing cases (nearly 3,000 over the past year), helping to keep
public servants in their homes. But DC37 also provides representation for bankruptcy or other
debt issues, parental rights cases, consumer protection cases, cases to help individuals secure
entitlements like food stamps and social security, cases assisting with citizenship or immigration
issues, and cases involving securing services for public utilities.
{ * * *J
The population served by DC 37 is made up largely of economic and demographic groups known
to face significant barriers in accessing adequate legal representation and health services.
Economically, the public servants who receive public services from DC 37 are among the lowest
paid of city workers, many of whom struggle just to make ends meet (some actually live in
shelters and are on public assistance) while contending with remarkably high cost of living in the
region.
{ * * *J
Finally, DC 37 does not only provide services to union members. DC37 services are provided to all
NYC public servants (and their families) working in or retired from specific job titles, and union
membership is not a criterion for eligibility for services.
From: Siegel, Brian [mailto:[email protected]]
To: Foss,Ian; Mclarnon, Gail; Arnold, Nathan; Smith, Brian
Subject: Re: PSLF- DC 37
it seems to me that the organization is that the trust is not providing public services but is
providing benefits to union members as part of the benefits of union membership. On the
medical side, it is not providing medical services but is acting as an insurer. on the legal services
side, it is not practicing public interest law but is providing some basic legal services again in
exchange for union membership. Nobody receives benefits unless they are a union member or
relative. Under this circumstances I don't think it qualifies under PSLF.
Brian Siegel
From: Foss, Ian

Subject: RE: PSLF- DC37
And, I forgot to include my colleague from Business Operations in my original message. I'm looping her
in now. Sorry, Taneka!
From: Foss, Ian
Cc: Utz, Jon
Subject: PSLF- DC 37
Hi Brian and OPE,
We've had a PSLFescalation from Fedloan Servicing regarding DC 37 Health & Security Plan Trust, an
insurance plan that is for NYCemployees who are members of the DC 37 labor union. The plan is
separate from the union, itself, but you have to be a member of the union in order to be able to benefit
from the plan.
They are not-for-profit under 501(c)(9) of the IRC(a voluntary employee benefit association), and so
must provide a qualifying public service in order to qualify for PSLF.One would naturally think that
public health services would qualify, but the plan contracts all of the actual provision of health services
to for-profit professional corporations (not uncommon). They also seem to provide "free" legal services
to members. Attorneys of the plan work with members to do things like prepare contracts, real estate
transaction documents, and estate planning documents. It would seem that, because they are funded in
part by New York City, that they may provide public interest legal services; however, it raises two issues
for me:
•Are these services provided to "the public"? We have talked before about whether "membership-
based" organizations are per-se disqualified, and decided that they are not, but that we could
exclude a particular organization from qualifying if they were too restrictive on membership.
• Are these "public interest" legal services? While it's true that these services are "free" at the point
of use, the cost ofthem is baked into the insurance premiums that members ofthe plan pay. As
such, they are not actually "free". There's nothing that says that a public service has to be
offered for "free" to be a "public service" for PSLF,but, as I understand the intent behind "public
interest legal services", it was a category intended to support organizations who provide legal
services to those who are indigent, like "legal aid" organizations.
What are your opinions about this?
Ian
From: Foss, Ian

Sent: 28 Mar 2016 18:20:55 +ODDO
To: Mclarnon, Gail;Siegel, Brian
Cc: Hoblitzell, Barbara;Smith, Brian
Subject: RE: PSLF- Detroit Economic Growth Corporation
Thanks, Gail. If it makes you feel any better, the borrower is free to provide us additional documentation
that he/she think would lead us to conclude that the organization qualifies.
Cc: Hoblitzell, Barbara; Smith, Brian
I am inclined to say that this organization does not qualify but I'm conflicted.
From: Foss, Ian
To: Siegel, Brian; Mclarnon, Gail
We have checked and have not approved an organization as quasi-governmental if it has not exercised
governmental power.
OPE, do you know where you want to go on this?
From: Foss, Ian
Thanks, Brian.
I'll go back and check on whether we have approved any organization that didn't actually exercise
"governmental power", but I don't think we have. Another factor we have looked at is one that you
pointed out: how and whether governmental organizations exercise control over the organization,
though, for example, appointments to the board of directors or other management.
OPE, do you have a preference here?
From: Siegel, Brian
To: Foss, Ian; Mclarnon, Gail
I think this is another borderline situation. Local gov'ts have to approve the creation of the corporation.
The local gov't also appoints the board members and up to 3 members {there must be at least 9
members on the board} can be local officeholders. Moreover, as you note they perform a traditional
gov't function. On the other hand, they are not a gov't entity and it doesn't look like the gov't would be
financially liable for the corporation's debts. The corporation may issue bonds or notes which are tax
exempt but they aren't considered municipal bonds/notes.
I think my inclination would be to say it qualifies but I'm not sure how it fits with other precedents and
defer to FSAand OPE.
Brian
From: Foss, Ian
Sent: Monday, March 07, 2016 4:11 PM

Subject: PSLF - Detroit Economic Growth Corporation
Hi Brian and Gail,
The Detroit Economic Growth Corporation was created by the city of Detroit as an "economic
development corporation". This is a specific term that is tied to Michigan state law that governs these
types of organization. It is clearly not a government agency. They say so on their website. Instead, they
say that they have a strong partnership with the Detroit government.
We were wondering whether the organization could be a quasi-governmental organization. We suspect
that we wouldn't consider them quasi-governmental, but wanted to check, since we don't really have a
firm definition. Generally, when looking to approve an organization as quasi-governmental, we look for
two things.
First, we look to see whether the organization is performing an inherently governmental function. As
economic development is something that municipalities frequently engage in, I think this organization
could easily meet that criterion.
Second, we look to see if the organization is exercising governmental authority. We have learned that
when states create quasi-governmental organizations and want them to exercise government authority,
they create them-in the state or local code-as bodies "corporate and politic". If we can't find that
language, we look to see whether they can issue bonds that are backed by the government, whether
they have tax authority, or whether they have eminent domain powers. This organization is created as a
"body corporate", but not body politic-so, as a regular corporation, and doesn't possess any ofthose
other governmental powers. However, it looks like the Mayor of Detroit has appointment authority to
the board.
What do you think? Do you agree that this organization doesn't qualify?
Ian
From: Siegel, Brian

Sent: 17 Oct 2012 08:33:36 -0500
Subject: RE: PSLF- Early Childhood Education
Ian is correct We have a situation here (which should be rare) in which, as far as we can tell, none of the employees perform a
qualifying service. Volunteers who are members of the organization provide that service not the employees. So we are not
making a distinction between employees but between employees and non-employee members.
From: Foss, Ian

I think the distinction that Brian was trying to make, and that would carry over into 501(c)(3)
territory, is that no employee of the organization provides the qualifying service; rather, unpaid
members of the organization provide the service. It's a new, nuanced twist on the example of
the janitor v. executive director issue.
From: Moran, Pamela

I agree with your conclusion on this one. For the issue that Brian raised, however is there a
problem making this distinction with the non-501(c){3) not-for-profit organizations that we did
not make with the 501{c)(3)s? If I am following this correctly, putting aside that this is not a
school-based service for the larger issue, the tutoring or other leadership support services are
provided by the sorority members in the various chapters who cannot be considered full-time
employees of the organization rather than the full-time employees of the organization. Since
the full-time employees are not directly providing the services on which forgiveness would be
based, they are ineligible. On the 501(c){3} side of the aisle, however, we have said you could
be the janitor or the executive director and as long as you are a full-time employee of the
organization, you 1 re eligible, at least based on qualifying employment and employee status.
From: Foss, Ian

Thanks again, Brian. I agree that this is a different case than what we've seen in the past, and
that it presents an issue that we have not fully addressed. We'll put it on a list and discuss it
when the issue must be resolved.
From: Siegel, Brian

I agree that this is determined by the fact that it is not a school based service.
(b)(5)
From: Foss, Ian

Thanks, Brian.
From what I can discern, the sorority is centrally organized here in DC, and all of the
chapters fall within the scope of the one corporation. All of the chapters also share the EIN
of the organization in DC. So, because the organization provides the service, albeit through
members {who are similar to members in an LLC,i.e., owners, but without private
inurement), I'm not sure that the fact that we are not sure that the employees provide the
service should be determinative. The only time we have looked at an employee's job duties
is when the employee has religious duties.
That being said, if you don't think it fits the bill of "other school-based services", then the
paragraph above is moot. I raised it because it made me question how I'd been thinking
about PSLF.
From: Siegel, Brian

(b)(5)
From: Foss, Ian

Subject: Re: PSLF- Early Childhood Education
(b)(5)
Catching the rJJ"eamso/Tomol"J"OH',Prepal'ing Young fVomen For the 21st

Century lhe Delta Academy[thi::. i::.the name of one of the programs they
run] was created out 1?f'anurgent srnse that hold action H'as needed to sai-'e
our young/emales (ages I l-!4)./iwn the perils c!f'arndemic/ai/ure, low self
esteem, and crippled /i1t11J"es.
Delta Academy provides an opportunity_/(1r
local Delta chapters to enrich and enhance the education that our young
teens receive in puhlic schools across the nation Spec(ficalfv, ii·e augment
their scholarship in math, science, and technology, their opportunities to
provide service in the_/Orm of'{eadership through sen,ice leaminx, and their
sisterhood, defined as the rnltivation service learning, and their sisterhood,
defined as the cultivation and maintenance of relationships. A primw~r goal 1?f'
the program is lo pl'epal'e young girls_f(1r,fit!/pal'/ic1JJation as leadC/'s in the
21st Centwy.
(b)(5)
From: <Siegel>, Brian <Brian,[email protected]>

Date: Thursday, October 11, 2012 14:02
To: Ian Foss <lan,Foss@ed,gov>, "Moran, Pamela" <Pamela.Moran@ed,gov>
(b)(5)
Brian
From: Foss, Ian

Subject: PSLF - Early Childhood Education
Brian and Pam,
We have a borrower who submitted our employment certification form, indicating that she
was employed by a non-501(c)(3), not-for-profit pre-school. Instead of checking the box for
"early childhood education (including licensed or regulated child care, Head Start, and State-
funded pre-kindergardem)", she checked "other school-based services" and wrote-in "early
childhood program" next to it.
Based on this, my research of New York law, and my search of various New York databases
where a license or registration would be recorded, they are not a licensed or regulated
childcare provider, a Head Start program, and they do not receive state-funds for pre-
kindergarden. So, they do not seem to meet the requirements of "providing early childhood
education services" within the scope of PSLFunless the parenthetical associated with that
checkbox (see above) is not intended to be all-inclusive.
And, if the check box's parenthetical is all-inclusive, I don't think the should be able to do and
end-run around that fact by coming in under school-based services-they really are just a pre-
school.
What do you think?
Ian
From: Siegel, Brian

Sent: 24 Jun 2013 10:36:43 -0500
To: L.l(b--1(--'51
_____ _,IPamela
Cc: Ninemire, Sandra;Arnold, Nathan
Subject: RE: PSLF- Emergency Management
I need more info. It seems odd to me that an ambulance :-.crvicc is qualified a:, a (c)(4) they arc
u:-.ually either affiliated with a hospital (w·hcthcr a (c)(3) or profit), or a go\'crnmcnt or arc profit
making. Do we have any more information about them'?
Brian
From: l(5
IL.(b
__ ~1-~_,
Sent: Monday, June 24, 2013 10:39 AM
Cc: Ninemire, Sandra; Arnold, Nathan
Subject: PSLF - Emergency Management
Brian and Pam,
We might finally have a not-for-profit organization that is a 501(c)(4) and that provides an actual public
service. There is an ambulance service that is organized as a 501(c)(4), and we think these are "emergency
management" services. Since this is the first organization that might meet that definition, I wanted to get
your input on whether the organization provides those services.
What do you think?
Thanks,
Ian
From: Siegel, Brian

Sent: 27 Jan 2014 08:30:08 -0600
To: Foss, Ian
Cc: Arnold, Nathan;Moran, Pamela
Subject: RE: PSLF- Federally Chartered Tribal Corporation
Under the definition of "public service organization" in 34 CFR 685.219. a businc~~ organized for profit is
~pccifically excluded from the definition. There i~ no exception for for-profits whose ~tock i~ wholly
owned by a governmental organization. So, the company would not qualify. I abo note that the for profit
holding company it~clfwould not have any employee~ pcrforn1ing public ~crvicc activities since the
holding company's puq1ose 1~ only to hold the stock of the ~ub~idiaries. A for-profit holding company may
have non-profit ~uh~idiaries and employees of that ~uh could potentially qualify but that is not this
situation.
81ian
From: Foss. Ian
Sent: Monday, Januaty 27, 2014 9:04 AM
To: Siegel. Brian
Cc: Arnold. Nathan; \1oran. Pamela
Subject: Re: PSLF - Federally Chartered Tribal Corporation
Brian,
What do you think?
Ian
On 1/22/14, 13:37, "Moran, Pamela" <Pamcla.Moran((j)cd.gov> wrote:
>If it'~ a for-profit corporation, even ifit benefit~ the tribe, how
>can it he an eligible public ~crvicc organization for PSLF purposes.
>can't believe the IRS would view this as a governmental entity.
>
>From: Foss. Ian
>Sent: Wednesday, January 22. 2014 11: 16 AM
>To: Siegel, Brian; Moran. Pamela
>Cc: Arnold, Nathan
>Subject: Re: PSLF - Federally Chartered Tribal Corporation
>
>Hi Brian and Pam,
>
>Anything on this one yet?
>
>Thanks.
>
>Ian
>
>From: <Foss>, Ian Foss <[email protected]<rnai1to:[email protected]>>
>Date: Monday, December 30, 2013 at 13:42
>To: "Siegel, Brian" <Brian.Sicgcl(c(cd.gov<mailto:Brian.Sicgcl½_~·cd.gov>>.
>"Moran, Pamc Ia" <Pamc la. Moran(c(cd. gov<ma i1to: Pamela. M [email protected]> >
>Cc: "Arnold, Nathan"
><[email protected]<mailto:Nathan.Arnold(c(cd.gov>>
>Subject: PSLF - Federally Chattered Tribal Corporation

>
>Brian and Pam,
>
>We have another tribal organin1tion that I need your help with for PSLF
>purpo~cs. The organinllion i~ called 'Chicka~aw Nation lndustric~,
>Inc!, which i~ a federally chartered for-profit tribal corporation
>that acb a~ a holding company for several LLC~. The holding
>corporation is wholly owned by the tribal government, itself, and its
>website say~ that 'a portion 2 of profit~ from the busine~~es arc used lo support the tribe.
>
>The employer certified as 'govemmenlal 2 , but I wanted to be sure that
>you agreed that thi~ wasn't 'tribal govcmment2 for PSLF purpose~.
>Nomrnlly, we've been able to find out more infom1ation about how the
>employees of government corporations are treated, for example, if they
>are eligible for government pensions, if the state be held liable for
>the actions of the corporation, or ifit has governmental p01,vers.
>However, that's not something we'll be able to find here.
>
>What I have found is recognition of the organization in the Chickasaw
>Code; specifically, in Section 2-1007.1 and .2. available
>h ere<https://V,'\VW.chic kasav,·.net/Documents/Long-Term/Chic kasav,·-Code/Title
>-02 .aspx>. What is says is that the corporation is exempt from
>taxation because of its status as an extension of the tribe, also has
>sovereign immunity (even though the tribe authorized the corporation to
>waive that immunity in a limited ~cn~c), and that profits may be
>di~tributcd to the tribal government (presumably for the purpo~c~ of
>economic development).
>
>What do you think about thi~?
>
>Ian
From: Siegel, Brian

Sent: 27 Jan 2014 08:17:33 -0600
Cc: Arnold, Nathan
Subject: RE, PSLF- FINRA
(b)(5)
From: Foss, Ian

Sent: Monday, January 27, 2014 9:03 AM
Cc: Arnold, Nathan
Subject: Re: PSLF- FINRA
Thanks, Brian. This stops short of saying that the organization qualifies as a law enforcement organization. Is
that true, or am I reading too much into what you wrote?
On 1/23/14, 10:34, "Siegel, Brian" <[email protected]> wrote:
(b)(5)
Brian
From: Foss, Ian
Sent: Thursday, January 23, 2014 8:51 AM
Cc: Arnold, Nathan
Thanks, Pam. I'm looping Brian and Nathan back in, particularly as this discussion may help Brian's
thinking.
On 1/23/14, 8:47, "Moran, Pamela" <[email protected]> wrote:
Well, they are saying they are providing law enforcement services. I
would expect an organization that is trying to make the case that they
provide such services to have such powers. As much as I might support
the work that they do, I don't believe that their employees work in
PSLFqualifying employment.
From: Foss, Ian
Sent: Wednesday, January 22, 2014 5:11 PM
To: Moran, Pamela
Almost certainly not! But then again, I wouldn't expect a non-profit

organization to have employees that are "sworn law enforcement officers".
Only those who work for a government in some capacity would be "sworn".
To me, a law enforcement officer is one who is executing a police
power, which only governments have.
Are any of the employees sworn law enforcement officers?
From: Foss, Ian

Sent: Wednesday, January 22, 20141:09 PM
Cc: Arnold, Nathan
No, they 1re claiming to be a not-for-profit organization that provides

law enforcement services. Since licensure by FINRA is a condition of
participating in the securities market, I think this is a little
different than an ordinary 501(c){6). Doesn1t mean they actually
provide a qualifying public service, of course ...
If they are not a governmental entity, and not a 501©(3), and not a
private, non-profit organization working in one of the areas covered
by our definition, I don't see how an employee of the organization
qualifies. They seem to be a private, membership organization that
can fine and sanction its members. Are they claiming to be a
governmental entitySpart of the SEC?
From: Foss, Ian

Cc: Arnold, Nathan
Subject: PSLF- FINRA
Brian and Pam,
We 7ve had {Financial Industry Regulatory Authority) FINRA come

forward for PSLFpurposes. FINRA is organized as a self-regulatory
organization under Section 15A of the Securities Exchange Act (it is
overseen by the SEC). It is organized as a non-profit and is
tax-exempt under section
501(c)(6) of the internal revenue code. I think we would not
considered this a quasi-governmental organization {they say over and
over again that they are not the government), so it 1s only chance of
qualifying is by providing a qualifying public service.
Would we consider them to be providing 3 law enforcement2 services?

Under Section lSA of the Securities Exchange Act, FINRA enforces its
rules by limitation or modification of a respondent 1s business
activities, functions and operations; fine; censure; suspension {of
an individual from functioning in any or all capacities, or of a firm
from engaging in any or all activities or functions, for a defined
period or contingent on the performance of a particular act); bar
{permanent expulsion of an individual from associating with a firm in
any or all capacities); expulsion (of a firm from FINRA membership
and, consequently, from the securities industry); or any other
fitting sanction. Since they are non-governmental, this isn1t some
sort of quasi-judicial power, however; instead, enforcement comes by
way of binding arbitration.
What do you think?
From: Siegel, Brian

Sent: 24 Jan 2014 10:04:01 -0600
Cc: Arnold, Nathan
Subject: RE: PSLF- Genesee Education Consultants Sercices
Ian thi:-.sounds like it might be similar to an educational scr\'icc agency. Tho:-.e agencies
employ teachers \Nho then work in public schools. Congress amended the teacher loan
forgiveness provisions a few years ago to make teachers employed by that type of agency
eligible for teacher loan forgiveness. If they operate the same way but aren't a public
educational :-.ervice agency \NC should probably treat them as eligible fi.ir PSLF.
Brian
From: Foss, Ian

Sent: Thursday, January 23, 2014 10:57 AM
Cc: Arnold, Nathan
Subject: PSLF - Genesee Education Consultants Sercices
Brian and Pam,
We have a non-501(c)(3) not-for-profit that has come forward claiming to provide public education services.
They are an employment agency for teachers and school support staff. The last time we dealt with public
education services, it was an organization that provided administrative support to public schools which we
said didn't qualify; this seems much more directly related to public education.
I'm seeing a lot on the organization's website that indicates that they actually employ the teachers, who then
go work in public schools (which we will verify). This makes me think that the organization could qualify. Do
you agree? Is that outcome-determinative? For example, if they don't actually employ the teachers or
support staff, would the organization not qualify?
Ian
From: Foss, Ian

Sent: 10 Apr 2013 12:15:38 -0400
Subject: Re: PSLF- Greenpeace
Whoops, disregard that! I just found out that the Legal Counsel for the Elderly is independently
organized, though affiliated with the (c)(4). It has its own legal name, EIN, etc. So, I guess this means
that the (c)(4) doesn't qualify at all.

Date: Wednesday, April 10, 2013 12:12
Thanks, Brian. Some follow-up on AARP.
My research indicated that AARP is highly centralized. There is one AARP (the (c)(4)) and the AARP
Foundation (the (c)(3)). Though AARP has offices ("chapters") in each state, then, each office is part
of the centralized organization; indeed, when I look at the Secretary of State databases for several
states, the AARP corporate filings indicate that they're a "foreign business" to that state, and that
their state of organization/incorporation was DC. And, though they have a large list of EINs
associated with them (according to the IRSdatabase), they all point back to the same (c)(4)
organization.
I also attributed the Legal Counsel for the Elderly to the (c)(4), not the (c)(3). So, my conclusion (so
far) had been that the entire (c)(4) qualifies because of services provided out of its headquarter-
offices. It was the (c)(3) (the foundation) that seemed to provide the Greenpeace-like issue-based
legal representation, even though that was counterintuitive to me.
This was rather unlike the ACLU (and many other national organizations), which had separately
organized chapters with their own governing board, articles of organization, programs, etc.
That being said, where does this leave us on the (c)(4) part of the AARP?
From: <Siegel>, Brian <[email protected]>

To: Ian Foss <[email protected]>, "Moran, Pamela" <[email protected]>
Subject: RE: PSLF- Greenpeace
Ian, Thanks. I didn't remember seeing anything on the AARP so I'm actually glad that you hadn't sent it to me and not that I'm
losing my memory (which I may be anywayl)
I think the ACLU 1sthe easiest-- 1t employs lawyers who do provide legal services including representation for 1nd1vidualson
behalf of those individuals. The cases it picks do have to serve its overall policy interests but its lawyers do represent individuals.
The AARP DC affiliate apparently has a program called Legal Counsel for the Elderly which as Ian said provides legal
representation for DC residents 60 and over. Clients do not have to be AARP members. That program employees lawyers
directly to provide the legal services. Those attorneys do clearly seem to be doing qualifying PSLFwork. On the other hand,
AARP itself 1snot a (c)(3) (it is a (c)(4)) and its legal representation involves issue representation and litigation that AARP itself
chooses. This role doesn't seem to qualify as PSLFemployment.
Greenpeace's legal services also seem to be issue based. To the extent it provides legal services at all, it pays for lawyers to
represent members as class or group representatives in litigation that is designed to achieve a certain public policy goal. Its
overall purpose is not to provide legal services. if Greenpeace is considered to be providing public interest legal services than we
need to consider every public services organization which at some time is involved in representing "public" interests in any way as
a qualifying organization for PSLF. I don't think that has been our interpretation of the provision.
Brian
From: Foss, Ian

Sent: Wednesday, April 10, 2013 11:23 AM
AARP is a 501(c)(4), like the ACLU and Greenpeace, which I didn't escalate to you guys (perhaps I should have, in hIndsIght)
because it seemed so similar to the ACLU. I didn't find the fact that the AARP was a membership-based organization (like
Greenpeace) as disqualifying since we had previously discussed that the "public" in "public service" did not need to mean the
public at-large. Brian previously said:
I also dont think the term ''public/I in ''public service/I has to mean everyone -
for example/ Head Start which is specifically identified as eligible is
theoretically open to everyone but has a low income requirement and a
particular Head Start only serves children in certain residential areas. I
assume there could be an extreme situation in which an organization serves
such a limited group that it cant be considered public but I dont think we
have seen that yet.
For AARP, I analogized to Brian's Head Start example. AARP provides public interest legal services to the elderly (or at least that's
the box into which we were trying to fit them), and, "services to the elderly" was a category of public service specifically
recognized. I also found nothing to suggest that such services were only open to AARP "members"; rather, it seemed from what
I read that it was open to all low-income seniors in DC. These legal services were also offered from the centrally organized AARP,
not the separate AARP Foundation, which is a 501(c)(3) and provides different services.
From: <Moran>, Pamela <[email protected]>

To: Ian Foss <[email protected]>, "Siegel, Brian" <[email protected]>
Subject: RE: PSLF- Greenpeace
I don't see that they provide legal services to individuals ...just on behalf of their organization's
membership and what they perceive to be the greater public good. That's different than the
ACLU, but perhaps not different from the AARP. What was our take on the AARP? Or were they
a 501(c)(3) so it wasn't an issue?
From: Foss, Ian

Sent: Wednesday, April 10, 2013 10:24 AM
Subject: PSLF- Greenpeace
Pam and Brian,
We have a PSLFform with the borrower being employed by Greenpeace, which is a 501(c)(4). They
claim to provide public education services, but they're claiming that on the basis that they try to
educate the public through campaigns, and the like, whereas we have interpreted "public education"
more narrowly.
If they qualify at all, it's by providing public interest legal services. They are frequently involved in
lawsuits to enforce various Federal environmental protection laws. Here is an
example: http ://www. green peace .org/ usa /en/ news-and- blogs/ news/green peace-sues- to-protect -
rar/. See paragraphs 19-21 of the complaint associated with the lawsuit, below:
19. Plaintiffs are each membership organizations with individual members who live and work
near and visit the Tongass National Forest, including the Scott Peak, Overlook, Traitors Cove,
and Soda Nick project areas. They use these national forest lands for a variety of purposes,
such as hiking, backpacking, skiing, photography, scientific studies, wildlife observation,
hunting and fishing, and they intend to continue to do so, on an ongoing basis, in the future.
Plaintiffs' members derive recreational, spiritual, professional, aesthetic, educational, and
other benefits and enjoyment from these activities.
20. The Scott Peak, Overlook, Traitors Cove, and Soda Nick projects, if implemented as
currently planned, will adversely affect Plaintiffs' members' use and enjoyment of the
project areas by clear-cutting and partial-cutting of old-growth forest. The cutting and related
activities planned for these projects will harm the values that Plaintiffs associate with these
areas and will adversely affect declining habitat for deer and wolves in the Tongass.
21. Plaintiffs have a long-history of involvement in planning and decision-making for the
Tongass, including specifically for the Scott Peak, Overlook, Traitors Cove, and Soda
Nick project areas. Plaintiffs filed written comments on the proposed Scott Peak, Overlook,
Traitors Cove, and Soda Nick project and filed administrative appeals for each of these
projects. The Forest Service denied the final appeals of these projects. Plaintiffs have been, are
being, and will continue to be adversely affected and irreparably injured by the decisions
challenged in this case. These injuries are actual and concrete and would be redressed by the
relief sought herein. Plaintiffs have no adequate remedy at law.
One final note. We have previously said that the ACLUand AARPprovides public interest legal
services. The ACLUrepresents indigent clients whose civil rights have been violated and the AARP
provides legal services to the elderly for free (relating to SSAbenefits, but also basic civil legal
services).
What do you think about Greenpeace?
Ian
From: l(b)(5)
Sent: 26 Jan 2017 22:42:40 +0000

To: Foss, Ian
Subject: Re: PSLF- Human Rights Campaign
Okay. Thank you ..
From: Foss, Ian

Sent: Thursday. January 26. 2017 2:50:38 PM
To: !(b)(51 I
Subject: F\V: PSLF - Human Rights Campaign
FYI.We need to deny HRC.
From: Siegel, Brian

Sent: Tuesday, January 24, 2017 10:44 AM
To: Foss, Ian; Mclarnon, Gail; Weisman, Annmarie; Smith, Brian; Hoblitzell, Barbara
Subject: RE: PSLF- Human Rights Campaign
I agree with Annmarie 1 s discussion. An internet search shows that there are private organizations that
provide "public safety" services that might qualify for PSLFpurposes (although I didn't identify any that
are non-profits). While I understand lan1 s point that "emergency management", "public safety" and
"law enforcement" are listed separately in the definition of qualifying organization, I have not found
anything in the regulatory or legislative history that provides a basis for distinguishing between the
three categories in a meaningful ways so I can't say how they are different or if the authors of the
legislation had a particular type of organization or job in mind. In any case, I don't think that HRC{the
(c)(4)) qualifies - my review of the HRCFoundation's website {http://www.hrc.org/hrc-story/hrc-
foundation} shows the activities that Ian lists below as activities of the Foundation (a qualifying
organization) and not HRCthe (c)(4) organization.
Brian
From: Foss, Ian

To: Mclarnon, Gail; Weisman, Annmarie; Siegel, Brian; Smith, Brian; Hoblitzell, Barbara
Hi there,
Just following up on this with the group.
Thanks,
Ian

Sent: Wednesday, December 28, 2016 4:35 PM
To: Foss, Ian; Weisman, Annmarie; Siegel, Brian; Smith, Brian; Hoblitzell, Barbara
I would like OGCto weigh in.
From: Foss,Ian
Sent: Wednesday, December28, 2016 2:32 PM
To: Weisman, Annmarie; Siegel, Brian; Mclarnon, Gail; Smith, Brian; Hoblitzell, Barbara
Like you, when I think of public safety, I think of what you mentioned. However, given that law
enforcement and emergency management are independent categories for PSLFpurposes, I'm
wondering whether it mean something broader. We've struggled with the law enforcement and
emergency management categories, as well, I think in part because those are inherently governmental
functions that you don't really expect a not-for-profit organization to provide. The argument for public
safety here is that the purpose of the programs below are to keep LGBTQmembers of the public safe-
from bullying, hate crimes, etc.-through the programs expressed below.
The early childhood education is definitely more tenuous, and now that I think about it, you're right-
none of this is early childhood education. I must have been thinking too quickly. It was the work they do
with child welfare agencies that made me associate it with early childhood education. This program
could also be construed as "public safety", however-depending on what the terms means.
From: Weisman, Annmarie

Sent: Wednesday, December28, 2016 12:19 PM
To: Foss,Ian; Siegel, Brian; Mclarnon, Gail; Smith, Brian; Hoblitzell, Barbara
Subject: Re: PSLF- Human Rights Campaign
I don't see what I'd consider public safety or early childhood education here. I realize we do not
strictly define these terms, but I'd expect public safety to include law enforcement, fire
protection, emergency management, etc. for the general public and early childhood education
to include preschool teachers, child care workers with an educational component, etc. also for
the general public and aimed at children from birth to about age eight. As an example,
graduates of early childhood education programs at universities usually qualify to apply for
certification to teach up through grade three.
I think the group supports those (through various programs) who perform public safety and
early childhood education services, but I do not see where they provide it directly.
We can certainly discuss further and review additional information, but based on what I've
read, I do not see enough here to support including them as a qualified employer.
Annmarie
From: Foss, Ian

Sent: Wednesday, December 28, 2016 11:35
To: Siegel, Brian; Mclarnon, Gail; Smith, Brian; Hoblitzell, Barbara; Weisman, Annmarie
Subject: PSLF- Human Rights Campaign
Hi PSLFfolks,
The Human Rights Campaign (HRC) has come forward seeking recognition as a qualifying
organization for PSLF.There's a separate organization, the HRC "Foundation", which is a (c)(3).
However, the main HRCis a (c)(4) and so must provide a qualifying service to qualify for PSLF.
They, of course, engage in advocacy work at the Federal, state, and local levels. However, they
also carry out the following programs, which do seem significant to me and part of the
organization's primary purpose.
These programs below could be construed as providing public safety and early childhood
education services. However, "public safety" has no definition and "early childhood education"
does not have an all-inclusive definition. Can you all review and let me know whether you think
that HRCis or is not providing a qualifying service?
Time to THRIVE Conference: An annual conference that is open to the public and which
promotes the safety, inclusion, and well-being for LGBTQyouth everywhere.
Project One America: A comprehensive, multi-year campaign to dramatically expand LGBTQ

equality in the South through permanent campaigns in Mississippi, Alabama, and Arkansas.
HRCGlobal: Strengthens the global equality movement through public education, advocacy,
fellowships, partnerships, and research.
HRC's HBCU Program: Empowers LGBTQ HBCU students to be change-agents on their campus
and lead resourcefully through the intersections of race, religion, gender identify, class, and
sexual orientation.
HRC'sAll Children: Promotes LGBTQcultural competence among child welfare agencies through
innovative resources including an on line agency self-assessment tool, comprehensive staff
training, free technical assistance, and more. Child welfare agencies that recruit, license,
support, and place with adoption/foster families and/or provide directing services to youth in
out-of-home care are eligible to participate.
Thanks,
Ian
From: Foss, Ian

Sent: 12 Sep 2013 18:36:23 -0400
Subject: Re: PSLF- Integrity Educational Services
This one is still outstanding on my list. Brian, have you considered further?

Date: Wednesday, August 28, 2013 at 12:08
Anything on this yet, Brian? You and Pam had slightly different understandings of the term "school-based
services" and yours was narrower than hers.

Date: Tuesday, August 6, 2013 at 12:38
(b)(5)

Subject: RE: PSLF- Integrity Educational Services
(b)(5)
From: Foss, Ian

Subject: Re: PSLF - Integrity Educational Services
(b)(5)

(b)(5)
From: Foss, Ian

Sent: Tuesday, August 06, 2013 10:S9 AM
(b)(5)

(b)(5)
From: Foss, Ian

Brian and Pam,
Anything on this one yet? I know we're all very busy, but I don't want us to take too long on these, as
borrowers are waiting for answer from our PSLFservicer.
Ian

Date: Friday, July 19, 2013 at 10:22
Subject: PSLF- Integrity Educational Services
Brian and Pam,
We have a non-501(c)(3), not-for-profit organization that may provide "other school-based services" or
"public education". The organization, Integrity Educational Services, provides the following services to public
charter schools and private elementary and secondary schools in Michigan:
• Financial services;
• Human resources services;
• Medicaid billing and collection;
• Per-pupil and special education accounting systems;
• Behavior management;
• Special education consulting;
• Curriculum development
• Marketing consulting; and
• Food service consulting.
Job postings I found also indicate that the school employs teachers that work in public charter schools. This I
think may qualify them as providing "public education" services.
The original articles of incorporation for the organization explain that it was established to exclusively carry
out activities described in section 501(c)(6) of the IRC. In 2011, the articles were amended to change that to
501(c)(3). So, even though the organization is not yet a 501(c)(3), the language in the articles is a clue that
they are in the midst of applying for that status. But, of course there is more. In 2013 (May), the articles
were amended to explain that the organization is a "supporting organization" under Section 509{a)(9) of the
IRCfor two 501(c){3) organizations (both are public charter schools). This also bolsters my belief that the
organization is applying for 501(c){3) status, as being a "supporting organization" for another 501(c)(3) is a
special type of public charity that can be tax-exempt under the same section of the IRC.
All that being said, since the organization does not yet have that tax-exempt status, it must provide a
qualifying service, and "other school-based services" or "public education" are categories that seems to fit;
particularly the behavior management and curriculum development services the organization provides as
well as employing teachers to work in public charter schools.
Do you agree that the organization qualifies on that basis? This one seemed clearer to me than most others
that I escalate to you two, but given how difficult charter schools are to fit into a box, because of
management organizations like this, I wanted to be extra-clear that this organization qualifies before
proceeding.
From: Siegel, Brian

Sent: 15 Jun 2012 12:13:58 -0500
Subject: RE: PSLF- Local Intergovernmental Organization
Since it is considered a government instrumentality I agree.
Brian
From: Moran, Pamela

Sent: Friday, June 15, 2012 12:27 PM
To: Foss, Ian
Cc: Siegel, Brian; Ninemire, Sandra
Subject: RE: PSLF- Local Intergovernmental Organization
OK...then I would think it would be eligible.
From: Foss, Ian

To: Moran, Pamela
Cc: Siegel, Brian; Ninemire, Sandra
Subject: Re: PSLF- Local Intergovernmental Organization
The thing is, it is an instrumentality of the local governments of Colorado. It is organized as a

domestic not-for-profit corporation under Colorado law, but has no particular "tax-exempt" akin
to 501 (c )(3) or (c )(4) because it is an instrumentality of government, and, as such, is tax-exempt
under the Internal Revenue Code.
On Jun 15, 2012, at 9:19, "Moran, Pamela" <Pamela.Moran(d;ed.gov> wrote:
I would think we would have to determine that they are a non-profit of some sort since they are not an
instrumentality of government. You indicate that they lobby ....so if it's non-partisan advocacy and they
are akin to civic leagues, why wouldn't they have a 501(c) (4) status? What is their tax status?
From: Foss, Ian

Subject: Re: PSLF- Local Intergovernmental Organization
Pam and Brian, I wanted to follow-up on this one, as I had not yet heard from you.

Date: Thursday, June 7, 2012 12:26
Cc: "Ninemire, Sandra" <[email protected]>
Subject: PSLF- Local Intergovernmental Organization
Pam and Brian,
As you'll probably recall, when discussing whether intergovernmental organizations qualify for PSLFas
"government", we decided that international intergovernmental organization, e.g., The United Nations,
do not qualify, but that domestic intergovernmental organizations could qualify. We have a domestic
intergovernmental organization that has presented itself to us, and I wanted your thoughts on whether
the organization qualifies.
The name of the organization is the Colorado Municipal League. The League is an instrumentality of the
cities and localities of the State of Colorado and advocates for its members before various bodies, such
as Congress or the state legislature, but it is also expressly non-partisan. Though other entities or
individuals can be associate members of the league, only municipalities or localities have any voting
authority in the organization. The entity is organized as a not-for-profit corporation under Colorado law,
but is not tax-exempt under Section 501(c)(3) of the Internal Revenue Code, and is indeed not tax-
exempt under any provision of the Internal Revenue Code as near as I can tell.
I would note that my experience working in state government tells me that these organizations
are verycommon across the country-and a decision about this organization would have large
implications for them all.
I would also draw an analogy to S01(c)(4) organization (civic leagues, that perform similar advocacy
functions before elected bodies in a non-partisan fashion). The only difference between the two is that
this organization has it members as cities, which would render it intergovernmental, whereas a 501(c)(4)
organizations have its members as individuals, meaning that they can only qualify if they are a not-for-
profit organization that provides a qualifying public service.
Do you think this organization qualifies as governmental because it is an instrumentality of cities?
Ian
From: Siegel, Brian

Sent: 1 Oct 2014 08:39:24 -0500
Cc: Arnold, Nathan
Subject: RE: PSLF- Medical Residents in New York
I agree.
Brian
From: Moran, Pamela

Sent: Wednesday, October 01, 2014 9:20 AM
To: Foss, Ian
Cc: Siegel, Brian; Arnold, Nathan
OK...then I agree that they are a non-profit doing eligible work.
From: Foss, Ian

To: Moran, Pamela
Cc: Siegel, Brian; Arnold, Nathan
Subject: Re: PSLF- Medical Residents in New York
Correct, there is nothing to contradict their NFP status.
Thanks. And there is nothing about the way they compensate the residents that
would contradict a nonprofit status?
From: Foss, Ian

Cc: Arnold, Nathan
Here's a snipped from the IRSabout the case·
http://www. irs.gov/i rm/part7 /i rm 07-025-003-cont0l.html

7.25.3.11.2 (02-23-1999)
Other Healthcare Organizations-Traditional
[...]
3. In University Medical Resident Services. P. C. and University Dental Resident
Services, P. C. v. Commissioner, T.C. Memo 1996-251 (1996), the Tax Court
upheld the Service's denial of charitable status for the petitioners, UMRS and
UDRS. which were nonprofit professional corporations established to aid certain
medical and dental residency programs in upstate New York. A charitable
organization administered the residency programs, the teaching hospitals handled
the training, and medical schools supervised the quality of the teaching program.
The petitioners. which had no administrative staff, paid the residents' compensation
and had nominal power to hire and fire the residents.
A. The petitioners argued they were charitable because they (1) advanced
education; (2) lessened the burdens of the local government; and (3) were
educational under the integral part theory. The court ruled that the
petitioners' advancement of education was minimal; that the petitioners
had failed to establish that either the medical schools or the teaching
hospitals were governmental entities or that the petitioners reduced the
cost of the training in any event; and that petitioners were merely shell
corporations providing the conduit through which compensation might be
made to the medical and dental residents. Thus, the petitioners could not
be conducting the integral functions of any charitable organizations.
From: Moran, Pamela

Cc: Arnold, Nathan
Why did the IRSdeny them tax-exemption? Just curious.
From: Foss, Ian

Cc: Arnold, Nathan
Subject: PSLF- Medical Residents in New York
Hi Brian and Pam,
There's a borrower seeking employment certification for PSLF.All medical

residents in the state of New York are employed by one professional corporation -
University Medical Residents Services, P.C.The organization is not a 501(c)(3)
organization and therefore must be a not-for-profit providing a qualifying service
{in this case, public health).
Typically, the first thing we do when there is an employer in this category is check
to see how the organization has established itself. Most states have a separate
corporate form for not-for-profit corporations, but not all states do. In states that
do not have a separate corporate form, we look into the articles of organization to
see if the articles prohibit, for example "inhibit inurement to a private person" and
how excess revenue will be distributed if and when the organization winds down.
These are basically the things that the IRSlooks to when determining whether an
LLCcould receive tax-exemption under the IRC.
In New York, corporations can organize as a not-for-profit corporation, but this

organization has organized as a professional corporation (when it incorporated,
there was no separate corporate form for not-for-profits). That being said, the
organization could organize as a not-for-profit, even though it is a medical
corporation. In any case, the organization's articles of organization contain the
same language we look for when the organization is from a state that does not
provide a separate corporate form for not-for-profits. I think this is sufficient

evidence that the organization is a not-for-profit (the IRSagreed that it was a not-
for-profit, too, but declined tax-exemption for another reason), but wanted to
check that you agreed before proceeding, especially because this is an escalated
case, and the organization's attorney reached out to me.
Ian
From: Siegel, Brian

Sent: 30 Oct 2014 09:48:07 -0500
Cc: Arnold, Nathan
Subject: RE: PSLF- National Board of Boiler and Pressure Vessel Inspectors
I agree.
Brian
From: Moran, Pamela
Sent: Thursday, October 30, 2014 10:38 AM
To: Foss, Ian
Cc: Arnold, Nathan; Siegel, Brian
Subject: RE: PSLF- National Board of Boiler and Pressure Vessel Inspectors
I would say yes because, as I read it, the services and resources are not limited to members of an
organization only. Almost all of the National Board's functions that you list below include interaction
with the general public (educating the public) or providing training/accrediting/ resources and services
to ensure public safety to folks who may be in the professional field, but are not necessarily members of
the organization.
From: Foss, Ian
Cc: Arnold, Nathan
Subject: PSLF- National Board of Boiler and Pressure Vessel Inspectors
Hi Pam and Brian,
The National Board of Boiler and Pressure Vessel Inspectors is the employer of a borrower seeking a
PSLFcertification and I am not quite sure whether they qualify. They are a 501{c)(4) organization, and so
are not-for-profit, but because they are not a 501(c)(3) organization, they would need to provide a
designated public service in order to be a qualifying employer.
The only category of public service that I think they could potentially be providing is "public safety".
Here's an excerpt from their "about us" page, which details what they do. It seemed like your typical
trade organization, at first. However, all of the members seem to be government employees, and the
organization seems to fulfill a role similar to that of the National Conference of State Legislatures, which
negotiates and drafts model laws that members (state governments) can take back and introduce as
legislation in their jurisdiction as a way of having standardized laws throughout the country. Such
organizations tend to be intergovernmental, but I cannot find anything that suggests this is the case
here except for the membership list.
The National Board's functions include:
c Promoting safety and educating the public and government officials on the need
for manufacturing, maintenance, and repair standards.
c Offering comprehensive training programs in the form of continuing education for
both inspectors and pressure equipment professionals.
c Enabling a qualified inspection process by commissioning inspectors through a
comprehensive examination administered by the National Board.
c Setting worldwide industry standards for pressure relief devices and other
appurtenances through operation of an international pressure relief testing
laboratory.
c Providing a repository of Manufacturers' Data Reports through a registration
process.
a Accrediting qualified repair and alteration companies, inservice Authorized

Inspection Agencies, and owner-user inspection organizations.
o Investigating pressure equipment accidents and issues involving code compliance.
o Developing installation, inspection, repair, and alteration standards {National
Board Inspection Code).
Resources Available from the National Board
o Statistical reports of violation findings within participating National Board
jurisdictions.
o Synopsized jurisdiction boiler and pressure vessel laws of North America.
oAccess to pressure equipment expertise from knowledgeable industry
professionals.
c An extensive collection of publications and technical articles available on the
National Board Web site.
c Pressure equipment safety videos.
c State-of-the-art training facilities and online seminars.
c Annual General Meeting of pressure equipment professionals.
What do you think? Is this "public safety" services?
Ian
From: Foss, Ian

Sent: 18 Jul 2012 13:41:48 +ODDO
To: Moran, Pamela
Cc: Siegel, Brian
Subject: RE: PSLF- Native American Casino
It was a described to us an unincorporated subdivision of tribal government. To me, this would suggest
that profits inure the tribal government, much the way the proceeds on our student loans go to the
Treasury.
From: Moran, Pamela

To: Foss, Ian
Cc: Siegel, Brian
We will need to know the status of the subdivision. Brian, haven't we seen structures with for-profit
divisions that also contain not-for-profit divisions?
From: Foss, Ian

To: Moran, Pamela
Cc: Siegel, Brian
Our servicer has reached out to the employer for more information and was told by the CFOthat the
casino is a subdivision of tribal government. Of course, we'll get documentation to back this up, but
assuming this is true, will this employer ultimately qualify?
From: Moran, Pamela

To: Foss, Ian
Cc: Siegel, Brian
That of course is my gut reaction. The borrower would have to demonstrate or ED document that
this kind of operation is part of tribal government or is a not-for-profit instrumentality of
government. I am not sure how these tribal casino operations are legally organized.
From: Foss, Ian

To: Moran, Pamela
Subject: Re: PSLF- Native American Casino
I agree, but want to be sensitive to modern tribal norms. To them, this is regarded as a means of
economic development.
It's also not too far off from states like Washington having a monopoly on the sale of alcohol.
Depending on how such structures are organized in the state, we might find ourself in a place where
we say "selling alcohol is public service".
On Jun 14, 2012, at 17:18, "Moran, Pamela" <[email protected]> wrote:
My view is thumbs down and we should find a way to say that it is not part of tribal
government. A job at a casino is not public service ..I don't care who owns it.
From: Foss, Ian

Subject: PSLF- Native American Casino
Pam and Brian,
I have an interesting PSLFcase for you. We have had an employee of a tribal-run

casino come forward for PSLFand assert that it is a "tribal government organization".
wanted your thoughts on what that term means in the context of PSLF.
There are two great white papers on the organizations of tribal businesses. One is by
the IRS(here) and one is by the State of Michigan (here). Both make plain that there
are five common structures: unincorporated, tribal subdivisions, Section 17
Corporations (federally chartered corporations), corporations chartered under tribal
law, and corporations organized under state law. If we were willing to really explore
this, I think that only organizations that fall into the first two categories, above, would
be considered "tribal governmental organizations" for PSLFpurposes.
The documentation received from the employer thus far only goes so far as to state
that the State of North Dakota and the Federal government were vesting the tribal
government with the authority to license and regulate "Class Ill gaming". That
certainly does not mean that the casino that we are dealing with is part of the tribal
government. However, Article IX, Section 11 gives the Tribal Council the power to
engage in any business that will benefit the tribe. So it's conceivable that the
corporation is a division ofthe tribal government. Unfortunately, the Tribe's code is
not available online at the moment-I was going to see how their law deals with
government corporations and the like.
But I wonder whether you two could tell me what you think of all of this, and whether
there are circumstances in which we would recognize a tribal casino as being a tribal
governmental organization (i.e., because the business is indivisible from the tribe itself
or it is a division of tribal government).
Ian
From: Siegel, Brian

Sent: 12 Sep 2012 09:29:35 -0500
To: Foss, Ian
Cc: Moran, Pamela
Assuming we have documentation that the casino is a subdivision of trillal gov't and the employees of the casino are employees
of the tribal gov't they would seem to qualify for lo:an forgiveness.
From: Foss, Ian

Sent: Wednesday, September 12, 2012 9:56 AM
To: Siegel, Brian
Cc: Moran, Pamela
Hi Brian,
This is still outstanding. Can you provide any further guidance?
Thanks,
Ian
From: Foss, Ian

To: Moran, Pamela
Cc: Siegel, Brian
Our servicer has reached out to the employer for more information and was told by the CFO
that the casino is a subdivision of tribal government. Of course, we'll get documentation to
back this up, but assuming this is true, will this employer ultimately qualify?
From: Moran, Pamela

To: Foss, Ian
Cc: Siegel, Brian
That of course is my gut reaction. The borrower would have to demonstrate or ED

document that this kind of operation is part of tribal government or is a not-for-profit
instrumentality of government. I am not sure how these tribal casino operations are legally
organized.
From: Foss, Ian

To: Moran, Pamela
Subject: Re: PSLF- Native American Casino
I agree, but want to be sensitive to modern tribal norms. To them, this is regarded as a
means of economic development.
It's also not too far off from states like Washington having a monopoly on the sale of
alcohol. Depending on how such structures are organized in the state, we might find ourself
in a place where we say "selling alcohol is public service".
On Jun 14, 2012, at 17:18, "Moran, Pamela" <[email protected]> wrote:
My view is thumbs down and we should find a way to say that it is not part of
tribal government. A job at a casino is not public service ...! don't care who
owns it.
From: Foss, Ian

Subject: PSLF- Native American Casino
Pam and Brian,
I have an interesting PSLFcase for you. We have had an employee of a tribal-

run casino come forward for PSLFand assert that it is a "tribal government
organization". I wanted your thoughts on what that term means in the context
of PSLF.
There are two great white papers on the organizations of tribal businesses.
One is by the IRS (here) and one is by the State of Michigan (here). Both make
plain that there are five common structures: unincorporated, tribal
subdivisions, Section 17 Corporations (federally chartered corporations),
corporations chartered under tribal law, and corporations organized under
state law. If we were willing to really explore this, I think that only
organizations that fall into the first two categories, above, would be considered
"tribal governmental organizations" for PSLFpurposes.
The documentation received from the employer thus far only goes so far as to
state that the State of North Dakota and the Federal government were vesting
the tribal government with the authority to license and regulate "Class Ill
gaming". That certainly does not mean that the casino that we are dealing
with is part of the tribal government. However, Article IX, Section 11 gives the
Tribal Council the power to engage in any business that will benefit the tribe.
So it's conceivable that the corporation is a division of the tribal government.
Unfortunately, the Tribe's code is not available online at the moment-I was
going to see how their law deals with government corporations and the like.
But I wonder whether you two could tell me what you think of all of this, and
whether there are circumstances in which we would recognize a tribal casino
as being a tribal governmental organization (i.e., because the business is
indivisible from the tribe itself or it is a division of tribal government).
From: Siegel, Brian

Sent: 30 Jul 2013 10:11:12 -0500
Subject: RE: PSLF- Neighborhood Assistance Corporation of America
I don't think they qualify. Upon re\·ie\','ing their website it appear:, to me that their primary
ser\'ice:-. relate to helping low income borrowers get mortgages and other housing assi:-.tance.
They also arc heavily involved in advocacy work. \Vhilc they may have some attorneys or non-
attorneys who provide legal services to individuals. that isn't the organintions primary (or even
secondary) purpose. In those cases. providing legal :-.ervices is ju:-.t a method of al.h'ocacy work.
From: Foss, Ian

Subject: Re: PSLF- Neighborhood Assistance Corporation of America
Brian, have you had the opportunity to consider this yet?

Date: Tuesday, July 23, 2013 at 8:48
Subject: RE: PSLF- Neighborhood Assistance Corporation of America
After viewing their website, I would agree that employees might be able to qualify under the public
interest legal services category. I question, however whether these services must always be provided by
an attorney if other full-time staff are trained to provide such services to the public. An organization can
be dedicated to providing such services, but is it necessary for all of these services to be provided by an
attorney? I'll defer to you and Brian if you believe we should be conservative in our interpretation of
who can be covered under this category.
From: Foss, Ian

Subject: PSLF- Neighborhood Assistance Corporation of America
Brian and Pam,
We have yet another 501{c)(4) that is seeking recognition as a PSLF-qualifyingemployer. This organization
works on housing issues. When completing the PSLFform, they indicated that they provide public interest
legal services and public education. While we know they don't fit the bill for "public education", there's a
chance that they might qualify as providing "public interest legal services" because they:
• Take on low-income to moderate-income clients (regardless of whether they are

"members" of the organization to "pursue remedies where there has been a pattern of
abuse including fraudulent modification companies and others."
• They provide delinquency and foreclosure counseling to borrowers and work \Vith the
borrowers to resolve their delinquency with the lender.
While for the former is obviously provided by an attorney, the latter I think is provided by non-
attorneys. Must "public interest legal services" be provided by attorneys? My thinking is yes.
Do the services that the organization's attorneys provide qualify them for PSLF purposes?
The organization's \Vebsite is here: https://www.naca.com. I found this information posted in job
descriptions on their website.
Ian
From: Siegel, Brian

Sent: 26 Jun 2014 13:24:56 -0500
Cc: Arnold, Nathan
Subject: RE: PSLF- NEXUSInstitution
I abo agree.
From: Moran, Pamela

Cc: Arnold, Nathan
Subject: RE: PSLF - NEXUS Institution
I agree with you.
From: Foss, Ian

Cc: Arnold, Nathan
Subject: PSLF - NEXUS Institution
Brian and Pam,
We've had a PSLFemployer escalate themselves twice over now. The organization is, according to the
president of the organization, organized on a for-profit basis as an LLC,but thinks that the organization
should qualify because it's not actively generating and does not intended to generate a profit. Specifically,
the president says (by way of a letter to Fedloan Servicing):
The NEXUS Institute is organized as/Or-pro.fit (/Or-benefitj entity but there is nothing
'fOr-pro.fit" about it operational~v. All ofNEXfJS'.fUnding comes.from grants. The
NEXUS Institute has no income-producing activities. There are no profit-making activities
and the NEXUS Institute has never made a profit.
Because the organization is not a 501(c)(3), it must qualify under paragraph (5) of the definition
of a public service organization in 34 CFR 685.2 l 9(b ). Doesn't (ii) make it clear that the
organization doesn't qualify?
(ii) Is not a business organizedfor profit, a labor union, a partisan political organization,
or an organization engaged in religious activities [. . .]
The only reason I'm prompted to ask is because it's become rather contentious between FedLoan
Servicing and the employer.
Ian
From: l(b)(5)
Sent: 22 Nov 2016 21:59:18 +DODO

To: Foss, Ian
Cc: Chialastri, Taneka
Subject: Re: PSLF- NYC Economic Development Corporation
Great memory! I'll start looking.
From: Foss, Ian

Sent: Tuesday, November 22, 2016 3:48 PM
To: !(b)(51 I
Subject: FW: PSLF - NYC Economic Development Corporation
This is relevant to the St. Louis Development Corporation.
I can't believe that I remembered this employer-from over 3 years ago. It was another case of
quasi-governmental organizations providing economic development services. We should do
research similar to what we did below to find out whether there are sufficient ties to the
government for them to quality. I don't think that merely being listed on a website is going to
cut it, not based on what we know about it.
Interestingly enough, if they had said that they were governmental in the first place, FedLoan
Servicing would have checked the city's website and approved it as governmental without
question.
From: Moran, Pamela
Sent: Thursday, March 14, 2013 1:05 PM
To: Foss,Ian; Siegel,Brian
Subject: RE:PSLF- NYCEconomic Development Corporation
Thanks.
Since the component unit Apple will remain a 501(c){3}, the NYCEDCis described as a unit of
NYC, and a significant portion of its operating revenues are grants from NYC and revenue from
rental or sales from NYC-owned properties, I am convinced we should consider them a
governmental entity and employees of the organization PSLFeligible.
From: Foss,Ian
To: Moran, Pamela;Siegel, Brian
Right, but they had another merger in 2012 (with the NYC Economic Growth Corporation), which
(according to their general counsel} caused them to lose their 501(c)(3) status with the IRS.They
continue to be exempt from federal taxation, but under Section 115 of the IRC.
This is reflected in their FY 2012 financial statement:

"Currently, NYCEDCis seeking a legal restructuring that is expected to be completed during fall
2012. EDCwill remain a not-for-profit corporation organized under Non-Profit Corporate Law
and its revenues will be exempt from federal income tax under Section 115 of the Internal
Revenue Code {"IRC Code"). Apple will remain a component unit of the restructured entity and
will continue to operate under Section 501(c){3) of the IRC Code." See here.
The link containing the articles of organization also contain all the documents necessary to
substantiate that the merger occurred in November 2012. See here.
From: Moran, Pamela
To: Foss,Ian; Siegel,Brian
I just reviewed the Financial Statement issued by E&Y for 2011 and it states that NYCEDCand its
merged unit Apple are both S0l(c) (3) organizations.
From: Foss,Ian
Subject: Re: PSLF- NYCEconomicDevelopment Corporation
They are very similar to other groups that we have determined do not qualify based on what they
do; however, such organizations had no links whatsoever to a governmental entity, as is the case
here. That's the only reason I escalate this. The other organizations could only as a not-for-profit
organization providing an enumerated public service (they had no links to the government), and we
determined that "economic development" activities did not fall within one of the enumerate public
services. Here, however, the organization has significant links to the government; links I believe go
beyond merely that of a government contractor.
From:, Pamela <[email protected]>
Date: Wednesday, March 13, 2013 17:33
Subject: RE: PSLF- NYC Economic Development Corporation
Although it may be politically unpopular, I don't believe they cut it. I believe they serve the
greater public interest of the citizens of NYC, but think they are too similar to a couple of groups
that we already determined were not eligible.
From: Foss,Ian
Subject: PSLF- NYCEconomic Development Corporation
Brian and Pam,
We have the New York City Economic Development Corporation that has asked whether it
qualifies for PSLF.It is not a 501(c)(3). It is a not-for-profit; however, they and we do not believe
that they provide any public services that would allow them to qualify under the residual not-
for-profit category. Their purpose is to, according to their articles of organization:
• Relieving and reducing unemployment in NYC;
• Promoting and providing for additional and maximum employment and bettering and
maintaining job opportunities;
• Attracting new industry and business to, and encouraging the development and retention
of industry and business in, NYC;
• Promoting, alone, or in concert with federal, state, and local officials and interested
national, state, and local groups, the economic grown and business prosperity of NYC;
• Promoting and improving the economic growth and business prosperity of NYC;
• Promoting and improving NYC's maritime, water front, freight rail, and aviation assets;
• Creating and coordinating financial incentives available in NYC
• Increasing private investment in NYC;
• Preserving and augmenting the tax base of NYC; and
• Undertaking projects to retain and increase economic development in NYC, including

through contracts with NYC.
Therefore, the only way for them to qualify is in the government category. Since they have told
me that they are not an official city agency, constituted under the City's charter, its only option
is as a quasi-governmental organization. Here are factors that support their being able to qualify
in this manner:
• Based on the activities above, they perform an inherently governmental function;
• Their articles of organization state that their purpose is to alleviate the burden on the
government of NYC (see here);
• Their financial statement holds them out as a "component unit of the City of New York"
(see here)
• The board of directors is (in whole or in part, depending on your point of view), appointed
by the Mayor of NYC (see here);
• They are treated as a local instrumentality for the purposes of federal taxation (exempt
under Section 115 of the IRCand here;
• They are obligated to report their financial information to the State of New York using the
Public Authorities Reporting Information System, which is used by local governments
(see here and here);
• The NYCgovernment website pulls the website of the organization into its website. For
example, the organization's website is www.nycedc.com; however, you can reach the
same site by going to www.nyc.gov/html/edc; and
• The NYCgovernment homepage lists the organization as a city agency (see here; go to the
sidebar that says "jump to city agency websites" and click on "economic development")
The thing that I think bears negatively on their qualifying is that:
• They were not established pursuant to the NY State Laws governing "public authorities"
(see here); and
• They were not established pursuant to the NYC Charter or Administrative Code (see here
and here).
What do you both think?
Ian
From: Siegel, Brian

Sent: 14 Mar 2013 09:07:35 -0500
(b)(5)
Brian
From: Foss, Ian

They are very similar to other groups that we have determined do not qualify based on what they do;
however, such organizations had no links whatsoever to a governmental entity, as is the case here. That's
the only reason I escalate this. The other organizations could only as a not-for-profit organization providing
an enumerated public service (they had no links to the government), and we determined that "economic
development" activities did not fall within one of the enumerate public services. Here, however, the
organization has significant links to the government; links I believe go beyond merely that of a government
contractor.

Although it may be politically unpopular, I don't believe they cut it. I believe they serve the greater
public interest of the citizens of NYC, but think they are too similar to a couple of groups that we already
determined were not eligible.
From: Foss, Ian

Subject: PSLF- NYC Economic Development Corporation
Brian and Pam,
We have the New York City Economic Development Corporation that has asked whether it qualifies for
PSLF. It is not a 501(c)(3). It is a not-for-profit; however, they and we do not believe that they provide
any public services that would allow them to qualify under the residual not-for-profit category. Their
purpose is to, according to their articles of organization:

• Promoting and providing for additional and maximum employment and bettering and
maintaining job opportunities;
• Attracting new industry and business to, and encouraging the development and retention of
industry and business in, NYC;
• Promoting, alone, or in concert with federal, state, and local officials and interested national,
state, and local groups, the economic grown and business prosperity of NYC;
• Undertaking projects to retain and increase economic development in NYC, including through
contracts with NYC.
Therefore, the only way for them to qualify is in the government category. Since they have told me that
they are not an official city agency, constituted under the City's charter, its only option is as a quasi-
governmental organization. Here are factors that support their being able to qualify in this manner:

• Their articles of organization state that their purpose is to alleviate the burden on the
government of NYC (see here);
• Their financial statement holds them out as a "component unit of the City of New York" (see
here)
• The board of directors is (in whole or in part, depending on your point of view), appointed by
the Mayor of NYC (see here);
• They are treated as a local instrumentality for the purposes of federal taxation (exempt under
Section 115 of the IRC and here;
• They are obligated to report their financial information to the State of New York using the
Public Authorities Reporting Information System, which is used by local governments (see here
and here);
• The NYCgovernment website pulls the website of the organization into its website. For
example, the organization's website is www.nycedc.com; however, you can reach the same site
by going to www.nyc.gov/html/edc; and
• The NYCgovernment homepage lists the organization as a city agency (see here; go to the
sidebar that says "jump to city agency websites" and click on "economic development")
• They were not established pursuant to the NY State Laws governing "public authorities" (see
here); and
• They were not established pursuant to the NYCCharter or Administrative Code (see here and
here).
Ian
From: l(b)(5)
Sent: 13 Dec 2016 18:03:29 +0000

To: Foss, l(b)(5J I
Thanks. 0·
From: Foss, Ian
Sent: Tuesday, December 13, 2016 12:35 PM
To: l(bJ(5J I
So you have something confirming our conversation, we can approve this. Given that the corporation
was established by the Mayor of the city and the director of the corporation is a cabinet-level position,
we can treat this as a qualifying quasi-governmental organization.
From: l(bl(5l I
Sent: Tuesday, December 13, 2016 12:29 PM
To: Foss, Ian
Cc: l(bJ(5J
https://en.wikipedia.org/wiki/Vincent C. Schoemehl
https://www.stlouis-mo.gov/government/departments/mayor/cabinet.cfm
From: Foss, Ian
Sent: Tuesday, November 22, 2016 4:48 PM
To: !(bl(51 I
Subject: FW: PSLF- NYC Economic Development Corporation
This is relevant to the St. Louis Development Corporation.
I can't believe that I remembered this employer-from over 3 years ago. It was another case of quasi-
governmental organizations providing economic development services. We should do research similar
to what we did below to find out whether there are sufficient ties to the government for them to
quality. I don't think that merely being listed on a website is going to cut it, not based on what we know
about it.
(b)(5)
From: Moran, Pamela

Thanks.
Since the component unit Apple will remain a 501{c)(3), the NYCEDC is described as a unit of NYC, and a
significant portion of its operating revenues are grants from NYCand revenue from rental or sales from
NYC-owned properties, I am convinced we should consider them a governmental entity and employees
of the organization PSLFeligible.
From: Foss, Ian
(b)(5)
This is reflected in their FY 2012 financial statement,

"Currently, NYCEDCis seeking a legal restructuring that is expected to be completed during fall
2012. EDCwill remain a not-for-profit corporation organized under Non-Profit Corporate Law
and its revenues will be exempt from federal income tax under Section 115 of the Internal
Revenue Code ("I RCCode"). Apple will remain a component unit of the restructured entity and
will continue to operate under Section 501{c)(3) of the IRCCode." See here.
The link containing the articles of organization also contain all the documents necessary to substantiate
that the merger occurred in November 2012. See here.
From: Moran, Pamela
I just reviewed the Financial Statement issued by E&Y for 2011 and it states that NYCEDC and its merged
unit Apple are both 501{c} (3) organizations.
From: Foss, Ian
(b)(5)
From:, Pamela <[email protected]>

<:11 hi<>rt• BE PSIE - NYC Ecooomic Develo □ me □ t Cornoratio □
From: Foss, Ian

Subject: PSLF- NYC Economic Development Corporation
Brian and Pam,
We have the New York City Economic Development Corporation that has asked whether it qualifies for
PSLF.It is not a 501(c)(3). It is a not-for-profit; however, they and we do not believe that they provide
any public services that would allow them to qualify under the residual not-for-profit category. Their
purpose is to, according to their articles of organization:
• Promoting and providing for additional and maximum employment and bettering and maintaining
job opportunities;
• Attracting new industry and business to, and encouraging the development and retention of
industry and business in, NYC;
• Promoting, alone, or in concert with federal, state, and local officials and interested national, state,
and local groups, the economic grown and business prosperity of NYC;
• Undertaking projects to retain and increase economic development in NYC, including through
contracts with NYC.
Therefore, the only way for them to qualify is in the government category. Since they have told me that
they are not an official city agency, constituted under the City's charter, its only option is as a quasi-
governmental organization. Here are factors that support their being able to qualify in this manner:
• Their articles of organization state that their purpose is to alleviate the burden on the government
of NYC (see here);
•Their financial statement holds them out as a "component unit of the City of New York" (see here)
• The board of directors is (in whole or in part, depending on your point of view), appointed by the
Mayor of NYC (see here);
• They are treated as a local instrumentality for the purposes of federal taxation (exempt under
Section 115 of the IRC and here;
• They are obligated to report their financial information to the State of New York using the Public
Authorities Reporting Information System, which is used by local governments (see here and
here);
• The NYCgovernment website pulls the website of the organization into its website. For example,
the organization's website is www.nycedc.com; however, you can reach the same site by going
to www.nyc.gov/html/edc; and
• The NYCgovernment homepage lists the organization as a city agency (see here; go to the sidebar
that says "jump to city agency websites" and click on "economic development")
• They were not established pursuant to the NY State Laws governing "public authorities" (see here);
and
• They were not established pursuant to the NYC Charter or Administrative Code (see here and
here).
Ian
From: Siegel, Brian

Sent: 30 Jun 2015 20:08:39 +0000
To: Foss, lan;Arnold, Nathan;Mclarnon, Gail;Smith, Brian
Cc: Utz, Jon;Chialastri, Taneka
Subject: RE: PSLF- Osler Institute
From my quick research on the term "public education 11 it did seem limited to K-12 rather than including
higher ed. I guess that comes out of the US view that higher ed is not a "right" as is elementary and
secondary ed. On the other hand, I don't think there is a legally binding definition.
I think that the only private non-profit {non-public) higher ed institutions that aren't 501(c)(3)s are
religious institutions that can't meet the non-discrimination requirements of the IRS{Grove City College
of Penn. is one; Bob Jones Univ used to be).
Brian
From: Foss, Ian
To: Siegel, Brian; Arnold, Nathan; Mclarnon, Gail; Smith, Brian
This is definitely the first professional continuing education provider that I'm aware of. However,
wouldn't we also interpret "public education" to include higher education to the extent that such an
organization would have chosen not to pursue a 501(c){3) tax exemption? I think it would be rare, of
course, that a higher education institution wouldn't be a 501(c)(3), but even so?
Indeed, the whole category of not-for-profit that's not a 501(c)(3) but that provides a qualifying public
service is rare, overall. Out of the 319,841 certification forms that have been approved, only 1,331 have
been for a not-for-profit organization providing a designated "public service".
From: Siegel, Brian
To: Foss, Ian; Arnold, Nathan; Mclarnon, Gail; Smith, Brian
From what I can tell "public education" generally refers to K-12 education paid for by the state or local
gov't. For example, some state constitutions refer to the state providing a free and equal public
education. I don't think that language is ever interpreted to include continuing education for
professionals. I also note that this approach is consistent with the references to early childhood
education, public library services, school library services and other school-based services. Have we had
questions on other professional continuing education providers like this?
Brian
From: Foss, Ian
Sent: Tuesday, June 30, 2015 10:46 AM
Hi all,
I wanted to follow-up on this employer.
Thanks,
la,
From: Foss, Ian

Subject: PSLF- Osler Institute
Hi all,
We have a PSLFescalation from Fedloan Servicing about an organization called "The Osler Institute".
They are organized as a 501(c)(6) organization, and so are not-for-profit, but must provide a designated
public service because they are not a 501(c)(3) organization. Though their website leaves a lot to be
desired, they are a continuing medial education organization. They are certified by the Accreditation
Council for Continuing Medical Education (ACCME) and provide courses that offer the American Medical
Association Physician's Recognition Award- AMA PRA Category 1 Credit. Although Osler allows the
on line purchase of educational materials, they only grant continuing medical education credit to
participants who physically attend courses, taught by physicians (who serve as faculty for Osler
Institute).
The only thing that this cou/dfit in by way of category of public service is public education, but we've not
yet granted that designation to anything beyond higher education. By way of reference, we decided that
our definition of public education was: "services that provide educational enrichment or support directly
to students or their families in a school or a school-like setting". While this is definitely not taking place
in a "school", it is taking place in a school-like setting in that faculty deliver lectures to those who attend
in a structured way.
If it's relevant, like teachers and lawyers, I think that most physicians are also required to receive a
certain number of continuing medical education credits each year in order to retain their medical
license.
Do we think this is "public education"?
Thanks,
Ian
From: Siegel, Brian

Sent: 8 Feb 2012 13:53:57 -0600
Cc: Ninemire, Sandra;Utz, Jon
Subject: RE: PSLF:PA state representative
I agree with Pam. The lcgi~lator would need to demonstrate that he/she i~ a full time employee of the ~tatc.
Brian
From: Moran, Pamela

Sent: Wednesday, February 08, 2012 2:48 P\1
To: Fo~~-Ian; Siegel, Brian
Cc: Ninemire, Sandra; Utz, Jon
Subject: RE: PSLF: PA state representative
It seems to me that the burden of proof in on them to show that they are full-time employees of state
government and that may vary from state to state. \1any legislatures meet for only selected months out of
the year and folks hold other full-time jobs.
From: Foss, Ian
Sent: Wednesday. February 08, 2012 2:44 P\1
Cc: Ninemire, Sandra; Utz. Jon
Subject: rSLF: PA state representative
Pam and Brian,

(b)(5)
Thanks.
Ian

> From: Diane Freundel [mailto:dfreundefa'.aessuecess.orgl On Behalf Of
> FedLoan PSLF
> Sent: Wednesda . February 08, 2012 2:05 P\1
> To: L.(b-'-)(--'5)~---'
> Subject: PA ~tatc representative
>
>
> Would an elected official (a state representative) qualify for PLSP?
> We received a phone call.

>
> Thanh.
>
> Diane Freundcl
> (717) 720-3267
> fax-(717) 720-3911
> <lfrcundc(a;phcaa.org
>
>
> ==========================================
> ===============
> for the above addressees only. If you receive this message in etTor
> please delete or destroy this message and/or attachments.
>
> criminal prosecution of any individual engaging in the unauthorized
> use of this message.
>------ ----------------------
>------
From: Foss, Ian

Sent: 12 Feb 2014 10:45:22 -0500
Cc: Arnold, Nathan
Subject: Re: PSLF- Patient-Centered Outcomes Research Institute
That's correct, Brian. We already rejected a federal credit union as being quasi-governmental.

Date: Wednesday, February 12, 2014 at 10:42
Subject: RE: PSLF- Patient-Centered Outcomes Research Institute
Apl)clrently the most common form of SOl(c)(l) organizations are Federal Credit Unions. I assume we have not treated them as
quasi-governmental for PSLF purposes. That would be a precedent for this entity.
From: Foss, Ian

Cc: Arnold, Nathan
Subject: Re: PSLF- Patient-Centered Outcomes Research Institute
(b)(5)
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(b)(5)

Date: Wednesday, February 12, 2014 at 10:21
Subject: RE: PSLF- Patient-Centered Outcomes Research Institute
(b)(5)
From: Foss, Ian

Cc: Arnold, Nathan
Subject: PSLF- Patient-Centered Outcomes Research Institute
Brian and Pam,
We've had the Patient-Centered Outcomes Research Institute come forward for PSLF. The
organization was established as a not-for-profit organization under the Affordable Care Act.
According to the law, the organization's purpose is to:
The purpose of the Institute is to assist patients, clinicians, purchasers. and policJ·-makers in
making informed health decisions by advancing the quality and relevance of evidence
concerning the manner in which diseases. disorders. and other health conditions can
effi:ctiFely and appropriately be prevented. diagnosed, treated. monitored, and managed
1hro11ghresearch and evidence sy111hesistlwl considers varia1ions in patient s11hpopu!utio11s,
and the dissemination of research findings with respect to the relatii:e health outcomes, clinical
e.ff"ectii:eness, and appropriateness r!f the medical treatments, services, and items descrihed in
subsection (a)(2)(8).
From its website, the organization doesn't seem to conduct the research, itself; rather, like many
agencies, it selects what research will be conducted, who will do it, and provides the money to do it.
It must also give priority to the NIH and the Agency for Healthcare Research and Quality in any bid
for research.
The organization is also called out for tax-exemption specifically under Section SOl(c)(l) of the IRC
(by way of cross-reference to 501(1)), meaning that it's not a 501(c)(3) organization. It therefore
must either be considered government, or be a not-for-profit providing (presumably) public health
services.
On the not-for-profit score. We know it is organized that way, but I think public health services is a
bit tricker. To provide public health services, the organization must, according to our regulations,
employ nurses, nurse practitioners, nurses in a clinical setting, or full-time professionals engaged in
health care practitioner occupations or health care support occupations, as defined by the Bureau of
Labor Statistics. While the organization does employ doctors, who are "health care practitioners",
the organization does so in a manner that does not actually have them practicing medicine. So, the
organization does not, I think, qualify as a not-for-profit providing public health services.
This would mean the organization's only avenue to qualify would be governmental, probably quasi-
governmental. Given that it is established by Congress, funded by Congress, is carrying out what
could be seen as a governmental function, and the members of the board include Federal
governmental officials and others appointed by Federal government officials, I think this could be a
quasi-governmental organization. Furthermore, certain government agencies are required to assist
the organization in publicizing its research, and CMS is permitted to use the organization's research
when determining whether to cover a particular procedure under Medicare.
What do you think? I've attached the pertinent part of the ACA.
lac
From: Siegel, Brian

Sent: 19 Aug 2014 10:24:22 -0500
Cc: Utz, Jon;Arnold, Nathan
Subject: RE: PSLF- Public Education and Public Health
I can :-.upport the distinction made in regard to #I and Ian's generalized :-.tatemcnt i:-.OK.
On #2 I can support the distinction in Ian's original email - the organintion in this case seems to
be an advocacy or support organintion for nurses in Texas and it is not engaged in public
... ,, h 11b115
(b)(5) I
Brian
From: Foss, Ian

Cc: Utz, Jon; Arnold, Nathan
Thanks, Pam. That is helpful. One note about "curriculum development". I think that sprang to mind
because I had seen it before. Indeed, I saw it in the description of the employer "Integrity Education
Services" that I attached to my last message-an employer that we rejected.
To generalize all of this, though, would it be something like, "public education services are those that
provide educational enrichment or support directly to students or their families in a school or a school-
like setting"?
(b)(5)
From: Moran, Pamela

Sent: Monday, August 11, 2014 11:28 AM
(b)(5)
staff or guidance or health professionals in the schools (nurses and mental health practitioners) ...you
get the idea. I agree it could also provide support the kind of support services you describe below.
From: Foss,Ian
Subject: RE: PSLF- Public Educationand Public Health
(b)(5)

To: Foss,Ian; Siegel, Brian
Subject: RE: PSLF- Public Educationand Public Health
(b)(5)
From: Foss,Ian
Sent: Friday, August 08, 2014 9:51 AM
Subject: PSLF- Public Educationand Public Health
Pam and Brian,
We denied two employers as being qualifying employers for PSLFpurposes, and the borrowers are asking for
more written information about why we made that decision.
One organization, Society of Digital Agencies, is a 501(c)(6) organization and claimed to provide public
education services. Their mission, according to their Form 990, is to provide infrastructure, processes, and
products to enable collaboration between members around education, best practices, and advocacy. In
dealing with "public education" services in the past, we have more or less been looking for an organization
that provides actual educational services in a school or school setting-something structured, pedagogical. A
charter school is an example. We have rejected as qualifying organizations those that provide administrative
services to schools, and this organization seems to be more in the category of administration. We have also
rejected advocacy organizations that seek to "educate the public" about their chosen issue. Because "public
education" is not a term that is defined in the context of PSLF,I wondered whether both of you agreed with
my explanation that "public education", for PSLF,means services that include the actual provision of
education to students in a structured, pedagogical environment. When you look at their website, they in no
way appear to actually be an organization that is about "public education". Contrary to their "mission", they
seem to be about marketing.
The other organization, the Texas Nurses Association, is another 501(c)(6) organization that, just like you
would expect, advocates for nurses in the state ofTexas. Among other things, the organization develops best
practices for nurses, and advocates for various legislation. It is, essentially, the NASFAAof nurses {but limited
in geography). They are claiming to provide public health services. Of course, "public health" includes
"nurses, nurse practitioners, and nurses in a clinical setting", but we have been looking to see whether the
organization employs individuals who are working in that capacity. This organization hires nurses, but they do
not practice nursing. Among other administrative things, the nurses that work for the organization "provide
support and oversight to association activities relating to nursing practice and monitor, evaluate, and
respond to evolving issues affective nursing practice and policy in Texas". Do you agree that this limitation is
appropriate? If so, do you have any problem with us explaining that in written correspondence?
Thanks,
Ian
From: Moran, Pamela

Sent: 31 Oct 2014 10:10:06 -0500
To: Siegel, Brian;Foss, Ian
Cc: Arnold, Nathan
Subject: RE: PSLF- Section 8 Housing Provider
I'm fine with that.

From: Siegel, Brian
Cc: Arnold, Nathan
Subject: RE: PSLF - Section 8 Housing Provider
I've re\'iev.'ed the HUD info on the Housing Choice Voucher program, the actual name fi.ir the
Section 8 program. First as you all note, public housing is not specifically mentioned as a
qualifying service- the I !EA and the regs refer to ..public service for individuals with disabilities
and the elderly". I'm not :.ure what '"public service" in thi:. :.entence means but I :.uppo:,e it could
include pro\'iding hou:.ing. Also, I don't think that the fact that the housing complex takes
Section 8 vouchers is necessarily determinative; as Ian notes, those vouchers can be used
anywhere the landlord accepts them and goes through the process to qualify. In addition, the
hou:.ing complex ha:, a broader focu:, than the regulatory language since it pro\'ides housing
ba:.ed on low-income as well to the elderly and di:.ablcd. So, while thi:. i:. a clo:.e calL my
inclination is to say that it doesn't qualify.
From: Foss, Ian
Cc: Arnold, Nathan
Hi Pam and Brian,
I wanted to follow-up on this. I think the below is the last message I have about this employer.
Thanks,
Ian
From: Foss, Ian
Cc: Arnold, Nathan
Q "
(b)(5)
From: Moran, Pamela

Cc: Arnold, Nathan
(b)(5)
From: Foss, Ian

Cc: Arnold, Nathan
Subject: PSLF - Section 8 Housing Provider
Brian and Pam,
We have an employment certification form for a borrower who works at an apartment complex in
Oklahoma. The complex is organized as a not-for-profit, and an tax-exempt as a 501(c)(4) organization.
It's mission is to provide Section 8 housing to low-income families, the disabled, and the elderly. If it
qualifies, it would be an not-for-profit organization providing housing services to the elderly and the
disabled.
Technically, I think that anybody can accept Section 8 housing vouchers if the landlord were to do a
minimum number of things-submit to an inspection, charge "fair market rent", fill out a form with the
local public housing authority, and advertise that you accept Section 8 vouchers.
I'm torn. While it's true that this is providing a service to the elderly and the disabled, it's not much of
one. The only thing that bears positively on this organization for me is that it's purpose is to provide
housing to those eligible for Section 8. But there's also the fact that Section 8 isn't targeted at just the
elderly and disabled.
What do you think?
Ian
From: Siegel, Brian

Sent: 16 Sep 2013 11:57:29 -0500
Subject: RE: PSLF- Tate Monroe Water Association
I agree as well.
From: Moran, Pamela

Sent: Monday, September 16, 2013 12:19 PM
Subject: RE: PSLF - Tate Monroe Water Association
I agree. I don't see how this one qualifies. I don't interpret "public safety" so broadly that it covers this
form of membership association that provides a particular benefit or service to its members.
From: Foss, Ian

Sent: Monday, September 16, 2013 11:51 AM
Subject: PSLF - Tate Monroe Water Association
Brian and Pam,
We got another new type of ECFfrom a borrower, and I wanted to run it by you. This organization is called
the "Tate Monroe Water Association", which is organized as a not-for-profit under state law and is tax-
exempt under Section 501(c)(12) of the IRC.
In sum, this organization is a co-operative association that treats and provides water to residences and
businesses. The only people who receive water from the association are members, but membership is open
to anyone that resides or conducts business in the geographic region served by the organization.
Though this sounds quite a bit like a public utility, I do not think that they can be considered quasi-
governmental, because there was no act of government that in any way lead to the association's organization
(they appear to have no connection to government at all and appear to actually "compete" with the county-
provided water utility).
So, if this organization is to qualify, it's on the basis of it being a not-for-profit organization providing specific
public services. The only public service that comes close to aligning with what this organization does is
"public safety", because, along with merely providing water, they do so in a manner that ensures that it is
safe for its members. Since many categories have not been clearly defined, I don't really know what "public
safety" was intended to mean. If I'm reading it strictly, which is what we have been doing with PSLF
employers, I don't think it qualifies because it really only ensures that drinking water is safe for members
based on mandates via Federal and State law.
The most information that I could provide about the organization is located in its "new customer packet",
available here. In addition to being exempt from income tax under state law, it also appears to be exempt
from property tax under state law (under Ohio Revised Code Section 5709.111, available here).
What do you think?
From: Siegel, Brian

Sent: 27 May 2015 18:33:58 +ODDO
To: Foss,lan;Mclarnon, Gail;Smith, Brian;Arnold, Nathan
Cc: Utz, Jon;Chialastri,Taneka
Subject: Re: PSLF- Vietnam Veterans of America
5
Ian, I don't think we can consider the VVA to be providing the public services. (bl( l
(b)(5)
Brian Siegel
From: Foss, Ian

To: Siegel, Brian; McLamon, Gail; Smith, Brian; Arnold, Nathan
Cc: Utz, Jon; Chialastri. Taneka
Subject: PSLF - Vietnam Veterans of America
Hi Brian and OPE,
Here's my second PSLFescalation of the day - the Vietnam Veterans of America.
This organization is tax-exempt as a 501(c)(19) organization (a veterans' organization).
Therefore, it must provide a designated public service to qualify for PSLF.The only
public service we could identify is services for the disabled. While a bit tenuous, the
organization does facilitate the provision of disability-related services to Vietnam
veterans who are disabled, but does not provide any services to them outright. Instead,
the organization has partner organizations with whom it puts Vietnam veterans in
contact should they require such services. This usually comes by way of creating
brochures, etc., to the veterans.
Could this be providing services (information) to the disabled? Or, is it too tenuous?
Thanks,
Ian
From: Siegel, Brian

Sent: 29 Aug 2013 10:57:41-0500
Subject: RE: PSLF- Wayne County Mediation Tribunal Association
I agree.
From: Moran, Pamela

Subject: RE: PSLF - Wayne County Mediation Tribunal Association
I just reviewed the material related to the program and it appears to me that it is a public service
organization for PSLFpurposes. They are a quasi-governmental organization and any fees assessed are
simply used to support the continued operation of the non-profit mediation service.
From: Foss, Ian

Subject: Re: PSLF - Wayne County Mediation Tribunal Association
Brian and Pam,
Have you had the opportunity to consider this one yet?
Ian

Subject: PSLF- Wayne County Mediation Tribunal Association
Brian and Pam,
We have another 501(c)(4) organization coming forward for PSLFclaiming to provide public interest legal
services. This organization was created by the Wayne County Circuit Court in Michigan to coordinate cases
that the court refers to mediation to the area and is now also relied upon by the Federal District Court for the
Eastern District of Michigan for the same purpose.
Because the organization coordinates the mediation, none of their employees actually perform mediation;
rather, they establish and nurture a network of attorneys in the area who do perform the mediation. My gut
reaction is that the organization qualifies, if for no other reason that it was established by a component of
government to carry out functions that are normally conducted by government, but understand that you may
approach this from a more nuanced perspective.
You can find out more about the organization in this

re port: http://www. fj c.gov/pub Iic/pdf. nsf/lookup/med edm ich .pdf /$file/med edm ich .pdf.
What do you think? Does the organization qualify?
Ian
From: Foss, Ian

Sent: 31 May 201719:39:33 +0000
To: !(b)(5) I
Subject: Re: PSLF& ACLU
I'm with you; I don't think they need to request W-2s as a matter of course.
5_1__
On May 31, 2017, at 15:38, ..._l(b_l( _,I<publicscrvicc(ZDcd.gov> wrote:
I'm okay with them not continuing to validate these borrowers. Would you prefer that they
continue requesting W2s from these borrowers?

To: l(bJ(5J I
Cc: Odom, Christian; Battle, Cynthia; FedLoan PSLF; Foss, Ian;
FedLoanProgramManagement
Subject: Re: RE: RE: PSLF& ACLU
Hi Taneka! For the attached borrower, we did confirm the employer (via a W-2), and he is
employed by the eligible 501(c)(3) foundation.
Just for some clarity, when we originally discussed the ACLU, we had requested W-2s for all
borrowers who had submitted ECFs for a branch of the ACLU or ACLU Foundation. Based
on what we received, I believe all borrowers were employed under the EIN they stated they
were employed by (with most being a branch of the 501(c)(3) foundation). As a result, going
forward we were not requesting W-2s for all subsequent borrowers who submitted ECFs.
We have been processing based on the EIN provided by the borrower/employer.
Would you like us to continue to request W-2s for all borrowers who submit ECFs for any
branch of the ACLU?
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
f-rrnn i(b)(5) l<publicservice@ed gov>

Io FedLoan PSLF <FedloanPSLF@pheaa org>
Cc "Battle, Cynthia" <Cynthia.Battle@ed gov>, "Foss, Ian" <Ian Foss@ed gov>, l°"(b"")("5)'--'
<publicservice@ed gov>, "Odom, Christian" <Christian [email protected]>
LJc1lH 05/31/2017 01:02 PM
Suh Hci [external]RE: RE: PSLF & ACLU
Hi Kim,
As you know, Christian and I are in the process of validating borrowers to receive their 6 month pre-
forgiveness letters. During my review, I came across a borrower with 113 QP whose ECFcertifies
that he works for the ACLU Foundation. Would you be able to confirm if Fedloan requested
additional documentation from the attached borrower (he is also a lawyer) per the message below
and if you confirmed if he in fact did work full-time for the 501(c)(3) and not as a volunteer or for
the 501(c)(4)?
The borrower information is attached. I'll send the PW separately.
Thanks,
Taneka

Sent: Monday, March 14, 2016 10:38 AM
__ ~
Cc: Battle, Cynthia; Fedloan PSLF; Foss, Ian; l~(b_l(_51
Subject: Re: RE: PSLF & ACLU
Hi Taneka! Thanks for the quick response. We will go ahead and retract any appropriate
approvals and request appropriate documentation on the other borrowers.
I will also work with the area responsible for updating the web content to include some
additional clarifying language.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From '"Ch1alastri.Taneka"' <Taneka Ch1alastr1@edgov>

To Fedloan PSLF <FedloanPSLF@pheaa org>
Cc l{b)(5) U(b)(5) l"Foss, Ian" <[email protected]>, ""Battle, Cynthia""
<Cynth [email protected]>
IJc<if 03/1112016 02.54 PM
Sub_fct [external]RE. PSLF & ACLU
Hi Kim,
Ian and I spoke offline. FedLoan will need to retract the approvals we gave to the ACLUfor the
501(c)(4) entities where it was determined that the borrowers were volunteers or did not provide a
qualifying service. We also need to be sure that the borrowers at the 501(c)(3} entities were
volunteers, and, if they were, retract those approvals, too.
We think 1twould be a good idea to add more language to the StudentAid.gov and MyFedLoan.org
websites to make it clear that non AmeriCorps and Peace Corps volunteers do not qualify. We will
work on updating StudentAid.gov. Would Fedloan be able to add a brief statement to MyFedloan
stating, "unless you are an AmeriCorps or Peace Corps volunteer, volunteering for an organization is
not qualifying employment for the purposes of Public Service Loan Forgiveness"?
Thanks,
Taneka

Sent: Friday, March 11, 2016 7:48 AM
To: Foss, Ian
Cc: l(bl(5l I
Chialastri, Taneka
Hi Ian! We just wanted to follow-up on this employer to see if you had any more information
and/or made a decision on the direction you would like us to go. The Business Unit recently
escalated another borrower employed at the ACLU and we currently have it on hold.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
f-rrnn Fedloan PSLF/PHEAA

Io "Foss, Ian" <Ian [email protected]>
Cc Fedloan PSLF <FedloanPSLF@pheaa org>, !(b~)~(5~)
0 _ _,I<publicservice@ed gov>, "Chialastri, Taneka"
<Taneka.Chialastri@ed gov>
LJc1lH 11/03/201511:01 AM
Suh Hci Re: [external]PSLF & ACLU
S,-.r,IIJy Diane Freundel
Hi Ian, We asked the business unit to perform a query to identify numbers. The numbers
they provided indicate 5 borrowers were approved for employment at various ACLUs that
were 501 (c)(4) entities. The numbers also indicate 56 borrowers were approved for
employment based on an EIN that linked to a 501(c)(3) Foundation or Union Fund.
One of my newer employees who works on the escalated ECFs, reviewed 2 ACLU 501 (c)(4)
entities and based on our normal review process determined they did not provide a
qualifying service. One entity had 9 employees and one had 11. She looked at the staff
listing and determined the employees didn't provide a qualifying service - all of the attorneys
were listed as volunteers. She hadn't located your previous guidance.
Let us know. If the decision is that they should be approved, we'll want to be more careful
of the number of employees at a specific entity, whether the borrower is an employee, and
whether the employees, rather than volunteers, perform the qualifying service. We'll hold
any new ones until we hear from you.
Thanks!
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
[email protected]
From "Foss, Ian" <Ian [email protected]>

To Fedloan PSLF <FedloanPSLF@pheaa orq>
Cc l{b)(5) U(b)(5) l"Chialastri, Taneka" <Taneka.Chialastri@ed gov>, Diane Freundel
<dfreunde@pheaa orq>
Date 11102/201501.51 PM
Sull.ect [external]PSLF & ACLU
Hi FedLoan folks,
It seems that we might have approved the ACLU and affiliates as a qualifying organization when we
should not have done. I know we approved the ACLU of Vermont, but have we approved any other
ACLU organizations?
The issue is that the forms we've gotten in associated with the ACLU are usually completed as a
non-501(c)(3) non-profit providing public interest legal services, but that requires the organization
to be funded at least in part by the government, and the ACLU receives no government funding ...
I don't want to retract any approvals just yet, but I wanted to get a sense of how many ACLU
organizations we have approved, and how many borrowers this affects.
Thanks,
lac
The sender of this message \Vill fully cooperate in the civil and criminal prosecution
Code:PHEAA
From: Foss, Ian

Sent: 26 Jul 2012 16:44:45 +ODDO
Subject: RE: PSLF& Charter Schools
Thanks, both. While what I have laid out below is correct in most states, it seems that some states (so
far, MA) actually treat charter schools as part of the government. So, these will absolutely need to be
decided on a case-by-case, or sometimes state-by-state basis.
From: Siegel, Brian

To: Moran, Pamela; Foss, Ian
I agree with Pam.
From: Moran, Pamela

Sent: Monday, July 16, 2012 2:10 PM
My two cents would be that what matters is what the status is of the borrower's direct employer.
would think that teachers who are considered employees of a for-profit entity hired to run a charter
school are not PSLFeligible. Based on what you indicate below, all other charter school teachers
would appear to be employed by some form of non-profit entity. Maybe that takes you inevitably to
case-by-case examination unless we can identify the for-profit entities that employ teachers in the
world of charter schools.
From: Foss, Ian

Subject: PSLF& Charter Schools
Pam and Brian,
First, I'm sorry to have sent you so many emails over the past days-I know you're really busy with
other things.
We've been trying to grapple with whether and how charter schools are qualifying employers for
PSLF. The standard refrain is "charter schools are public schools" -a matter that is confirmed in each
state's charter school law. On that basis, one would think that they qualify like any public school
would, under the government category. However, the more I read about them, the less confident I
am that we can take such an easy approach.
• Some states let charters be run by for-profit entities, but require that the entity holding the
charter to be non-profit. Other states require that a non-profit not only hold the charter, but
also be the entity that runs the school from day-to-day. Some states are even more extreme,
and appear to be moving toward chartering organizations that are for-profit.
• Some charters are financed entirely through tax dollars and receive state funds like any other
public school, other charters have mixed funding streams or are entirely privately funded.
• Some states exempt charter school teachers from certification requirements, others require
state-based certification.
• Some states wholly exempt charter school teachers from being considered public school
teachers in the traditional sense of the word, some are opted into public school teacher
pensions and benefits schemes, but not are strictly "government employees".
• Some states explicitly make charters independent, legally, of the local education agency,
meaning that one cannot sue the public school system for damages for acts committed by the
charter school, whereas other states do not do this.
Based on these differences, should we be looking at these on a case-by-case basis, and determine, in a
very strict sense, whether the employer, be it the entity that holds the charter, or in some cases
manages the school (really, whomever the employer is), independently qualifies as a not-for-profit
organization?
Or, should we be looking at this in a different way, by analogizing to state-chartered universities,

which we would consider public and therefore governmental?
Thanks,
Ian
From: Moran, Pamela

Sent: 9 May 2012 08:28:50 -0500
To: Foss, lan;Siegel, Brian
Subject: RE: PSLF& Federal Credit Unions
I don't believe they are a governmental entity.
From: Foss, Ian

Subject: RE: PSLF& Federal Credit Unions
Pam and Brian,
Though, the more I think about it, the less I think that a Federal Credit Union could qualify as an
employer in the "government" category, I'd still like you two to weigh in before we take action on the
borrower's Employment Certification Form.
Thanks,
Ian
From: Foss, Ian

Subject: PSLF& Federal Credit Unions
Pam and Brian,
We've received an Employment Certification Form from a Federal Credit Union and I wanted your
opinion on whether such organizations qualify as a federal governmental entity or qualifying quasi-
governmental entity for PSLFpurposes.
All credit unions are not-for-profit by definition, but there are two types: State-Chartered Federal
Credit Unions and Federal Credit Unions. The one that we're dealing with is a Federal Credit Union; to
be specific, it is the Transit Employees Federal Credit Union (TEFCU) here in DC.
To be a "Federal Credit Union", the entity must receive a designation that can only be granted by an
independent federal governmental agency, called the National Credit Union Administration, pursuant
to 12 USC 1752 et seq.
All credit unions that received a designation are tax-exempt under a group exemption granted by the
IRSto the NCUA under Section S0l(c)(l) of the Internal Revenue Code.
Section S0l{c)(l) of the IRC is for instrumentalities of the United States. Therefore, I think there's an
argument that Federal Credit Unions, if you can verify that they are designated as such by the NCUA
(there's a database at NCUA.gov; for this one, search for charter number 3764), qualify as federal
governmental organizations.
Though we're not examining one right now, state-chartered credit unions are exempt from taxation
under IRSSection 501(c)(14).
I'd note that this situation is a bit different from the Federal Reserve Banks that we considered a while
back.
• First, the credit unions are all not-for-profit whereas the Federal Reserve banks are for-profit
(though the profits inure the federal government)
• Secondly, while the Federal Reserve Banks are tax-exempt, they are exempt by a specific
provision of Congress in the Federal Reserve Act, not the Internal Revenue Code.
I don't think there's any basis, aside from governmental, for a Federal Credit Union to be a qualifying
PSLFemployer.
Thanks,
Ian
From: Siegel, Brian

Sent: 12 Sep 2012 09:31:35 -0500
Subject: RE: PSLFEmployer - Business District.
I agree that these are not qualified jobs for PSLF.
From: Foss, Ian

Subject: PSLF Employer - Business District.
Pam and Brian,
I want your opinion on whether either of the two would qualify as a qualify public servicer for
the category of employer that is a not-for-profit organization, but not a 50l(c)(3):
• Providing financing to renovate dilapidated buildings (public safety); and

• Being a "resource" and providing "seminars" to businesses on the local building code
(public education.
I think the answer should be no, but wanted to run it by you.
This is a "business district" in Iowa, that is trying to redevelop a downtown. I confirmed that it is
a not-for-profit organization.
Ian
From: Foss, Ian

Sent: 3 Feb 2017 18:47:32 +ODDO
To: Fedloan PSLF;Chialastri, Taneka
Cc: 5'-I____
Odom, Christian;Battle, Cynthia;Diane Freundel;'Lauren M. Ll(b-'l'-( __,
Subject: RE: PSLFEmployer Escalation Meeting Minutes_01302017
;:i lr.t- Ki....,I

(b)(5)

Cc: Odom, Christian; Battle, Cynthia; Diane Freundel; 'Fedloan PSLF'; Foss, Ian; 'Lauren M. Swett';
!(b)(5) I
Subject: Re: PSLFEmployer Escalation Meeting Minutes_0l302017
Hi Taneka! Realized I forgot the attachment.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

To "Ch1alastn, Taneka" <[email protected]>
Cc "Odom, Chnsl1an" <[email protected]>, "Battle, Cynthia" <[email protected]>, Diane Freundel <dfreundempheaa.org>,
"'Fedloan PSLF'" <[email protected]>. "Foss, Ian" <[email protected]>, "'Lauren M. Swett'" <[email protected]>, l{b_5) I
l{b)/5) I
D:i:e 02/03/201712:34 PM
SubJect Re. [external][external]PSLF Employer Escalation Meeting M1nutes_01302017
Sert by Kimberly A Myers
Hi Taneka!
We recall both the discussion with Ian and receiving the ECF Processing Protocol in December 2011, that
was shared with the Business Unit to be used when processing ECFs.
(b)(5)
In regards to your other requests:
---1 hope to be able to provide you, by COB today, the information on the 501(c)(4) organizations that you
requested.
--- We currently have 2 staff who devote approximately 25 hours total a week on ECF escalations. On
average, we receive about 340 escalations per month.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
· r:w1 "Ch1alastn, Taneka" <[email protected]>
To "'KimberlyA Myers'" <[email protected]>,Diane Freundel <[email protected]>,"'Lauren M. Swett"' <[email protected]>,

"'Fedloan PSLF'" <[email protected]>
c, "Battle Cynthia" <[email protected]>,"Foss, Ian" <[email protected]>,"Odom, Christian" <[email protected]>,
!(b)(5) U(b)(5) l"Chialastri, Taneka" <[email protected]>
u.n, 0210112017 04:28 PM
[external][external]PSLFEmployer EscalationMeeting Minutes_01302017
Hi Kim,
Thanks again to you and the rest of the team at Fedloan for meeting with FSA to discuss the Employer Escalation
process.1(b)(5)
(b)(5)
Please let me know if there are any questions regarding this email or edits to the meeting minutes.
Thanks,
Taneka
Taneka ChialastriI Management and Program Analyst, Business Operations I Federal Student Aid
Office 202-377-4390 I Cell: 202-256-7842 I [email protected]
----- 0000+ Feb 2017 19:34:57 on Wed, 1 L.l(b.cl(-'51

______ _,IMessage from "-l(b-')(5-'l
__ _,l-----
"Chialastri, Taneka" T
0
<Taneka.Chialastri(ij;ed.gov>:
Fw: Columbia Physical Therapy PS ~ubject
5 1__
Ll(b~)(~ ~1
:From
Tuesday, February 28, 2012 7:45 AM :Sent
Fedloan PSLF:To
) (51___
Johnson, Debbe Ll(b
000
~1 Foss, Ian; Ninemire, Sandra; Sipple-Asher, Bessie :Cc
RE: Columbia Physical Therapy PS :Subject
and therefore does not qualify. You I agree that this is a for-profit entity
it's If .may stop escalating cases where the employer is clearly for-profit
and a close case, or you're not sure that it's a clear case, then go ahead
.continue escalating it
-----Original Message-----<
From: Diane Freundel <
On Behalf Of [ ma ilto :[email protected]]
Fedloan PSLF<
,Sent: Monday<
To:l(b)(5) I<
Subject: Columbia Physical<
Therapy PS
<
<
Please see the attached ECFand information from the ,Hi<
WA Corporations
Please let us know .This entity is for profit .Division <
if you want to
continue to see entities that checked box c that are for<
Password .profit
!Thanks .to follow<
<
See attached file: Columbia)<
(Physical Therapy_Hodgson.zip
<
Diane Freundel <
Compliance Services<
<
720-3267(717)
fax- (717) 720-3911 <
[email protected] <
<
<
This message contains privileged and confidential<

If you receive this .the above addressees only<
delete or destroy this message and/or<
.attachments
<
The sender of this message will fully cooperate in the<
civil and criminal
prosecution of any individual engaging in the <

.message<
<
<
attachments.
Code:PHEAA
From: l(b)(5)
Sent: 31 Mar 201714:53:44 +0000

To: Fedloan PSLF
Cc: l(bl( 5l I
Subject: RE: PSLFEmployer Reetractions - NJSNA
Hi Kim,
Please see the edits (below) for the NJSNA retraction letter. Thanks, Taneka
(b)(5)

Sent: Thursday, 30 March, 2017 14:44
To: l(b)(5) I
Cc: Odom, Christian; Battle, Cynthia; Fedloan PSLF;Foss, Ian
Subject: RE: PSLFEmployer Retractions
Hi Taneka! Attached is the letter for NJSNA (New Jersey State Nurses Association) for your review. I will
also be forwarding over in a separate email some of the for-profit retractions letters (just for your records
since you advised we could use the template and send on our own). Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Fromcl{b)(5) H/b)/5)
To· Fed Loan PSLF<[email protected]>
Cc. l{bj/5) U/b)/5) I "Battle, Cynthia"' <Cynth1a.Battle(oJed gov>. '"Foss, Ian'" <Ian Foss@)edgov>, "'Odom, Christian"'
<Christian Odom(oJed gov>
Date. 03/14/2017 03:22 PM
Subject. [external]RE: PSLFEmployer Retractions
Hi Kim,
FSA responses to the potentia I employer retractions are listed below:
FSA Approved Retractions

Alphabet Arts (please send the draft letter for review)
AmeriHealth Caritas
Common Cause (please send the draft letter for review)

Corrections Corporation
New Jersey State Nurses Association (please send the draft letter for review)
WREG LLC
- The organization is listed as a subsidiary of Tribune Media. The organization is for-profit.
PSLFApproved
ASU Alumni Law Group
- FSAverified that this organization is a 501{c)(3) and should qualify for PSLF.We validated the
organization's eligibility through GuideStar and the IRSExempt Organization BMF.
Please let me know if you have concerns/questions.
Thanks,
Taneka

Sent: Tuesday, March 07, 2017 11:41 AM
To: l(b)(5) I
Subject: PSLFEmployer Retractions
Hi Tankea!
Here are a few more employers identified that we believe had ECFsapproved in error.
Again,I consolidated the information on the employers into a spreadsheet, and created separate folders
for the employer that house the ECFsand additional information we found or have on file.
Please let me know if you have any questions. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Code:PHEAA
From: Foss, Ian

Sent: 5 Nov 2015 17:20:21 +ODDO
To: Heather Jarvis
Bee: l(b)(5)
Subject: RE: PSLFemployment certification
Hi Heather,
Good news. After considering the fact that the organization does not only provide legal assistance as a
benefit of union membership, we are satisfied that the organization qualifies.
Fed Loan Servicing will be sending a letter to the borrower retracting the prior denial.
Note that our determination that this organization is a qualifying organization does not mean that we
necessarily agree with the rationale or statutory/regulatory interpretation that was provided by the
organization's counsel.
Also, understand that, while I am happy to serve as a recipient of inquiries like these if you think that
Fed Loan Servicing is not being responsive or is reaching incorrect conclusions about employers (I think
it's good to have an independent check), I am confident that, if the organization had provided either of
its letters to Fed Loan Servicing instead of me, that Fed Loan Servicing would have escalated the
employer again, and we would have reached the same decision.
'"
From: Heather Jarvis [mailto:[email protected]]
Sent: Wednesday, November 04, 2015 5:58 PM
To: Foss, Ian
Subject: PSLF employment certification
Ian,
Thanks again for your careful attention to these important issues. Please find attached a letter
including infomiation relevant to the Department's analysis of H&S as a public interest
organization.
We will look forward to hearing back as your schedule pennits. Don't hesitate to be in touch if
questions arise or any additional information is needed.
All my best,
Heather
From: Foss, Ian

Sent: 5 Nov 2015 21:50:51 +ODDO
To: !(b)(5) I
Please, do! They should have a full record of what came in on this employer. Be sure they also get my
response back to Heather so that they don't think that they should rely on the reasoning in the letter.
From: l(bJ(5J I
Sent: Thursday, November 05, 2015 4:50 PM
To: Foss, Ian
Hi Ian,
Can I send Fed Loan a copy of the letter you received from DC 37?
Thanks,
Taneka
From: Siegel, Brian

Sent: 21 Feb 2013 12:21:46 -0600
Subject: RE: PSLFEmployment Determinations
Ian - since you are so persistent, here are my views:
(b)(5)
Let me know if you have any questions or disagree with what I've said above.
Brian
From: Foss, Ian

Sent: Thursday, February 21, 2013 11:16 AM
Subject: RE: PSLF Employment Determinations
Brian, Pam, have you had a chance to review these yet?
From: Foss, Ian

Subject: Re: PSLF Employment Determinations
Hi Pam and Brian,
These have been outstanding for a bit, and I don't like to let them linger. Brian, I know you are busy trying to
finalize OGC's informal review of the 150% regulation, but when you're done with that-tomorrow or
Monday, I forget-can you take a look at this?
Pam, I'd appreciate your thoughts as well as soon as you have a moment.
Ian

Date: Monday, December 31, 2012 11:53
To: "Moran, Pamela" <[email protected]>, "Siegel, Brian" <[email protected]>
Cc: "Ninemire, Sandra" <[email protected]>
Subject: PSLFEmployment Determinations
Pam and Brian,
We have received the below employers as escalated, and I need your help to make a decision. All of the
below organizations are 501(c)(4), (c)(6), or (c)(8) organizations, so they are not-for-profit, but must provide a
qualifying public service in order to qualify.
• Order of Sons of Italy in America

The Order of Sons of Italy in America is a 501(c)(8) organization that generally promotes the study of Italian
culture and language in the US. Because it is a 501(c)(8) organization, it is a fraternal organization, and as
such, only provides its "services" to members of the organization (though membership is held out to the
public). Affiliated but separate from the (c)(8) organization is a foundation, which is a (c)(3) organization, and
a social justice arm, which seeks to counter negative stereotypes about Italian people and is a (c)(4)
organization. The borrower works for the (c)(8) organization.
(b)(5)
(b)(5)
• Conference on Jewish Materials Claims Against Germany

The Conference on Jewish Material Claims Against Germany is a 501{c)(4) organization (public interest group)
that negotiates settlements for those who had property confiscated by the German and Austrian government
during the Holocaust and distributes it either to (1) affected individuals or (2) organizations who then provide
the benefit of the settlement directly to affected individuals. This is the organization that negotiated with the
German government to enact laws that would compensate those affected by the Holocaust following the end
of the war. It would be easy to say that this falls into the category of public interest legal services (and think
that it does) or providing services to the elderly (since it does, in a sense, focus on the elderly), but our PSLF
servicer wanted to again raise the issue of whether providing services to a small segment of the population
was sufficient to qualify, or whether they needed to be provided to the public at-large. My thinking is that
this is no different than a not-for-profit that specifically focuses its efforts on low-income individuals.
This organization also has a foundation, which is a 50l{c)(3), but the borrower works for the 50l{c)(4).
• WateReuse Association
This organization is a 501(c)(6) organization (trade association). It seeks to increase the use of sustainable
water sources and high-efficiency conservation techniques to protect the water supply. It is a membership-
based organization, like the Order; however, its members are not just individuals, rather, they are local
utilities, the membership includes federal and state agencies, health officials, consultants, and prominent
researchers from the academic community. I cannot put my finger on specific "services" that they provide,
which is a common theme for 501(c){4), (6), and (8) organizations; however, they say that they provide
"education" to members.
Like the other organizations, they have an affiliated 501(c)(3) organization (a foundation), but the borrower
works for the (c)(6).
• Kansas Association of School Boards

This is another 501(c)(4) organization, which is again only open to members. Members include governing
boards for unified school districts, community colleges, and those who provide services to the other
members. Generally, the organization advocates for certain public policies {like all of the others) and
provides outreach and training to members.
So, the common theme for all of this is (1) do services actually need to be provided to the public, or can it be
provided to members, and (2) do services such as policy advocacy count, or will organizations need to rely on
the direct provision of services to the public (or members)?
Thanks,
Ian
From: Foss, Ian

Sent: 17 Apr 201418:13:15 +0000
Cc: Utz, Jon;Arnold, Nathan
Subject: RE: PSLFIssue
Thanks, Brian.
From: Siegel, Brian

Subject: RE: PSLF Issue
I agree that \NC should consider the borrower to meet the qualifications for PSLF. !'he
"employment" for ADP is only for reporting pay and benefit purposes; the non-profit actually
provides the funds to pay the employee and controls the work and whether the employee
continues to \\'ork.
Brian
From: Foss, Ian

Subject: FW: PSLF Issue
Hi Brian,
See the attached for a pretty peculiar PSLFissue. The borrower is "co-employed". One entity qualifies,
the other does not. The entity that does not qualify-ADP, is little more than the human resources
department for the entity that does qualify, but both entities consider the borrower to be an employee
of the organization.
I initially thought that the borrower couldn't be working full-time for both organizations, and so couldn't
be working full-time for the qualifying organization, but that doesn't seem to be how the employment is
structured. After reading the documentation more thoroughly, it looks like all of the borrower's work
occurs for the organization that qualifies.
What do you think about this? I tend to think that this should qualify, but is new and peculiar and so
wanted to run it by you.
Ian
From: Bartkowiak, Thaddeus

To: Foss, Ian
Cc: Utz, Jon
Subject: PSLF Issue
Please review the attached. Fedloan has denied the borrower's employer certification. Apparently, this
new arrangement between ADPand CaliforniaCenter for Sustainable Energynow considers individuals
to be co-employed by both entities. Fedloan asserts that ADP,as a for-profit enterprise, disqualifiesthe
borrower.
Thanks.
Thad Bartkowiak
Team Lead
{202) 377-3805
Direct inquiries to: OmbudsmanGroup; U.S. Department of Education; 4th Floor,

UCP-3/MS 5144; 830 First Street, NE; Washington, D.C. 20202-5144; Phone: (877)
557-2575/Fax: (202) 275-0549; Email: <mailto:[email protected];> [review
our website at studentaid.ed.gov]
CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, is for

the sole use of the intended recipient and may contain confidential and
privileged information. Any unauthorized review, use, disclosure or distribution
is prohibited. If you are not the intended recipient, please contact the sender
by reply e-mail and destroy all copies of the original message.
From: Foss, Ian

Sent: 26 Jan 2015 21:12:56 +0000
To: Siegel, Brian
Cc: Moran, Pamela
Thanks, Brian. I completely agree with you; I just wanted your concurrence and something else to say to
them in response.
From: Siegel, Brian

To: Foss,Ian
Cc: Moran, Pamela
(b)(5)
1:man
From: Foss,Ian
Sent: Monday, January 26, 2015 11:38 AM
To: Siegel, Brian
Cc: Moran, Pamela
Hi Brian,
Just following up on this. Have you had a chance to read the attachments and consider?
Thanks,
From: Foss, Ian

To: Siegel, Brian
Cc: Moran, Pamela
Does this change your opinion on the matter of the Federal Reserve Banks? I don't think so, as they're
citing nothing that I didn't already know, but I'm unsure of how to explain why we do not think this is a
governmental organization. Can you help me build up a rationale?
From: Udell, Tracy [mailto:[email protected] l

To: Foss, Ian
Ian,
Last month I spoke with your colleague, Taylor Stanek regarding the Public Service Loan Forgiveness
program. As you may know, Bank employees have been consistently denied the opportunity to
participate. Unfortunately, Jerrold Nadler's office did not forward the attached August 17, 2014 letter
from Ms. Randolph. Therefore, on December 10, I wrote Lloyd Horwich, advocating that as an
instrumentality of the federal government and an intimate part of the government's fiscal structure,
FRBNYis an independent government entity and PSLFqualifying employer. I ask that you please review
my attached letter and reconsider the Department's position.
Best wishes,
Tracy Udell I Cuur,~el
Corpor;itc Atbrs
Lr,g;il Group
I 2127281402
F 212 u:, 8!09
E lracy uJell:.(j]11yfrb orsi
33 I ,hwty Street. \Je··NYcrk. NY · OrJ45 I ne•.,vycrkfw1 erg
From: Stanek, Taylor [mailto:[email protected]]

Sent: Friday, December 12, 2014 4:12 PM
To: Udell, Tracy
Cc: Foss, Ian
Subject: PSLF Issue
Tracy-
Thank you very much for taking the time to discuss the FRBNY inquiry with Federal Student Aid
regarding the Public Service Loan Forgiveness program. As I mentioned, back in August we sent Rep.
Nadler a letter responding to this inquiry, ,vhich you will find attached.
I am copying my colleague Ian Foss in Federal Student Aid who, as the letter notes, should be able to
help answer any remaining questions you may have about this program.
Please do not hesitate to let me know if you need anything else. Have a good ,veekend!
-Taylor
W. Taylor Stanek
Office of Legislation and Congressional Affairs
202-453-636]
This e-mail message, including attachments, is for the sole use of the intended recipient(s) and may
contain confidential or proprietary information. If you are not the intended recipient, immediately
contact the sender by reply e-mail and destroy all copies of the original message.
From: l(b)(5)
Sent: 2 Feb 2012 12:01:38 -0600

To: (b)(5)
Cc: Ninemire, Sandra;Sipple-Asher, Bessie;Foss, Ian

Subject: RE: Public: Chesterfield Services
Hi Diane,
I agree, this appears to be a for-profit entity based on the

Wa~hington Secretary of State's databa~e of corporation~ and that the Pub 78
search return no hit~ for "Chesterfield" in the slate of
Washington.
Ian
PS - I'm pa~ting the text ofyourori inal email below so

~---~
that we have a record in the (b)(5) mailbox.
Hi Ian, We believe
this is a for profit entity based on the Washington
State Corporations
list. Please verify. Thanks!
Chesterfield Services
300 West Millplain
Blvd.
Vancouver, Washington
98660
http:i/www.chc~tcrficldhealth.com/index.html
(Sec attached file:

Chesterfield Srvc~.pdf)

> From: FedLoan PSLF
[maiHo:securemail.d- 393 89262-
> B BZxB gpKcmmRo TJU (a;'SCCurcmai l .ae~success.org]
On BchalfOfFedLoan
> PSLF
> Sent: Thursday, February 02- 2012 12:09 P\1
>
To: l(b)(5)
> Subject: Public: Chesterfield Services
>
> You have a
secure email message waiting for you from Fedloan PSLF at
> AES/PHEAA with
the subject: Public: Chesterfield Services.
>
> How to Retrieve Your
Message
>
> To retrieve your mes~agc from Fedloan PSLF with the subject:
Public:
> Chesterfield Services, go to:

>
htips: i/seeurema i I.aessueees ~.orgime~~enl!er.msg'?x-d- J 9J 89262-
>
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>
> This message will be available until 04/02/2012.
>
>
Why You Arc Receiving this Email
>
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lav.,. To protect the privacy of this
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>
>
> Personal data protected by federal law includes:
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thi~ message, plca~c visit
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>
>

message in error please delete
> or dc~troy thi~ message and/or
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>
civil and criminal
unauthorized u~e oJ'thi~
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--------------------------------
From: l(b)(5)
Sent: 8 Feb 2012 13:22:02 -0600

To: Fed Loan [email protected]
Cc: l(bl( 5l I
lan;Ninemire, Sandra;Sipple-Asher, Bessie
Subject: RE: Public: Mecklenburg Area Catholic Schools
Diane,
Thi~ ~till shows up a~ private, but I'll reproduce the content, hclow.
In short. You're correct, and arc not confming anything that we talked about on the phone yc~tcrday. This
organin1tion doc~ not show up in Pub 78, but docs ~how up in the BMF. When I looked in the BMF and
~aw an affiliation code of "9", it indicated to me that this is a subordinate of a group exemption by the IRS.
/\s ~uch, it might not appear separately in Pub 78. It\ unfortunate, but true. However, it 1~ a 50l(c)(3)
organiLation, and, a~ such, qualifies.
The group exemption number i~ 928, meaning all other organiLation covered by the group exemption lcllcr
will have the same number. In the relevant BMF, there arc no le~~than 43 organiLations with group
exemption number 928, and we wouldn't have a full count unlcs~ we received a data dump of all of the
BMFs. None of the affiliation codes in the relevant BMF were anything other than 9, so I looked at the
Georgia BMF to see if I could find the parent organization (suspecting the parent is the Archdiocese of
Atlanta, which has jurisdiction over North Carolina) and came up with nothing, but there is a pattern. All
those with group exemption number 928 are Catholic.
Tums out, the Catholic Church is Ft'IJ' centrally organized. The parent organization is the United States
Conference of Catholic Bishops here in Washington, DC. If you look at the BMF for DC, you can find it
(ElN: 530196617; group exemption number 928; affiliation code of"8"). You can also find a copy ofa
letter from the IRS to the Conference here: http://old. usccb.orgiogcigroup-rul ing-20 I 1.pdf.
Of course, you could have stopped as soon as you found the ElN from the ECF in the relevant BMF. I was
just belaboring the point about group exemptions.
Ian
The certifying official checked box c and "other school based services.
EIN-00-56-1779865
.lust to ~cc what we would come up with, I checked both Pub 78 and the
Bu~incs~ Ma~tcr Pile. There arc no results in Pub 78, but they arc in the
BMF with a subsection code of 3. Screen shob attached. I apologize for
my confu~ion on the IRS information that we review.
My understanding:
Pub 78 includes only 501(c)(3) organizations.
The BMF contains all tax-exempt organization~. Within the BMF, 501 (c)(3)
organiLations have a sub~cclion code of 3.
Therefore, I would a~~umc that if an organization has a subsection code of
3 on the BMF, it should abo be found in Pub 78. My re~ults do not support
my assumption. Again, my apologies for my confusion.
An additional question is in reference to the fact that it is a Catholic
School. We checked their staff list and the borr01,veris a health/phys ed
teacher.
(See attached file: Pub 78 pg l.pdt)
(See attached file: Pub 78 pg 2.pdt)
(See attached file: from IRS B\1F.xlsx)
Thanks!
Diane Freundel
Compliance Services
(717) 720-3267
fax-(717) 720-3911
dfrcundc(cfphcaa.org
addressees only. If you
receive thi~ rnc~~agc in error plca~c delete or dc~troy this message and/or attachments.
The sender of this message will fully cooperate in the civil and criminal pro~ccution of
any individual engaging
in the unauthorized u~c of this mc~~agc.

> From: FedLoan PSLF [mailto:securemail.d 39448220
> 2nZk5FDTX3cwTGWA(d!,securemail.aessucces~.org] On Behalf Of FedLoan
> PSLF
> Sent: Wednesdav, February 08, 2012 I :23 P\1
> To: l(b)(5) I
> Subject: Public: Mecklenburg Area Catholic Schools
>
> You have a secure email message waiting for you from FedLoan PSLF at
> AES/PHEAA with the subject: Public: Mecklenburg Area Catholic Schools.
>
> How to Retrieve Your \1essage
>
> To retrieve your message from FedLoan PSLF with the subject: Public:
> Mecklenburg Area Catholic Schools, go to:
> https :iisecurema i1.aessuccess.o rgimesse nge rims g'.1x -d- 3 9448 220-
> 2nZk5FDTX3cwTGWA
>
> This message will be available until 04/08/2012.
>
> Why You Arc Receiving this [mail
>
> A[SiPHEAA has sent you a message that may include ~cn~itivc information or
> personal data, as defined by federal law. To protect the privacy of this
> information, the email ha~ been encrypted.
>
>
> Personal data protected by federal law includes:
> Social Security numbers
> Driver's license numbers
> credit reports/scores
>
>
> If you have questions regarding the authenticity of this message, please visit
> us online at www.aesSuccess.or 0 isecuremail, or contact us:
>
> Phone: 1-800-233-0557
> Email: ecommfli:aessuccess.or 0
> Postal mail: AES/PHEAA
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> Harri ~burg, PA 17102
>
>
>------ ----------------------
>------
> This message contain~ privileged and confidential information intended for
> the above addressees only. Ir you receive this message in error please delete
> or dc~troy this message and/or attachments.
> prosecution of any individual engaging in the unauthori?cd use ofthi~
> message.
>------ ----------------------
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>
>
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>
From: l(b)(5)
Sent: 16 Feb 2016 21:30:51 +0000

To: Fedloan PSLF
Cc: l(b)(5J I
Cynthia
Subject: RE: Public Service for the Elderly NFP
Hi Kim,
We believe that Public Service for the Elderly should be denied unless the borrower is able to show that
his income is full-time and nrovide evidence that the on,anization nrovide a nualifvim, service lex.
(b)(5)
Thanks,
Taneka
Sent: Tuesda , January 19, 2016 2:46 PM
To: (b)(5)
Subject: Public Service for the Elderly NFP
Hi Taneka!
This is one we would like your input on. We originally received this employer as an escalation from the
Business Unit in August of 2015. The address and EIN match a travel agency, which the borrower and his
spouse operated previously (this was explained in a phone call with the certifying official--the borrower's
wife). The official stated that the EIN was now being used for Public Service for the Elderly NFP and that
their main purpose is to provide food, clothing, and other household items to individuals who needed
assistance both in the United States and internationally.
The business filing lists the organization as not-for-profit, but we were unable to confirm the services they
actually provide, so we requested evidence of qualifying services and the articles of incorporation. In
addition, since it appeared the organization was run by the borrower and his wife, we also requested pay
stubs (this organization just incorporated in 2015, so we were not able to request a W-2 at the time).
On November 12, 2015, we received an earnings statement for October 2015, as well as a 2015 W-2,
both in the amount of $174. The borrower also included a letter indicating that the organization did not
truly start providing services until October 2015, despite the organization opening in June of 2015.
On January 14, 2016, we received additional documentation from the borrower--earnings statements for
November and December of 2015, as well as two more W-2s, each showing $174. It appears that the
borrower may be supplying a W-2 for each month as opposed to it being for the entire year of
employment. They have not yet sent in the articles of incorporation.
The income earned by the borrower for the 3 months of work ($522), does not equate to full-time
employment; however, we're not sure that the organization could even be approved as providing a
Any guidance you can provide would be appreciated. The password is the same as the previous
employer. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: Foss, Ian

Sent: 2 Feb 2012 11:41:56 -0600
To: Fedloan PSLF;Ninemire, Sandra
Cc: Sipple-Asher, Ll(b~l(~51~----~
Subject: RE: public version: Oklahoma Board of Nursing
Diane,
We plan on ~citing up a meeting with OPE on the broader i~~ucs to

get to a consen~us.
With regard to whether a bmrnwer is an employee, I

think we have very little choice but to rely upon the employer's
certification, in all aspect~.
With regard to political appointees and

elected officials, I think it would be easier to determine whether a
borrower in question falls into either of those classes because there is
likely to be information about them on the organization's website. So, if
1,vetake the stance that they are not "employees", then they vmuld be easy to
identify 1Nithlittle effort.
For the doctoral and post-doctoral

researchers, however, I brought them up as a policy decision that we 1,vould
need to make and issue guidance upon: you 1,vouldrely on the certification of
the employer, just like you would for the religiously affi Iiated
organization.
The authorized official's job title i~ going to be very

tricky. My authori?cd official is a "Program Support As~istant", and
looking at it, I don't think you'd have any way of knowing that the per~on
is really "authorized". Be~~ic, Sandy, and Diane, I'd be interested in
hearing your take on thi~.
/\s a general matter, not-for-profit

organiLations cannot issue stock, ~o they cannot be publically traded. So,
I think it's a fair assumption to make that if there is a publicly traded
corporation, it is not a not-for-profit organization. They two arc
c~~entially legally incompatible- - stock is a form or ownership in a
corporation through which profits are distributed. That being said,
publicly traded corporation might have charity arms, and boffowers might
inadvertently list the name of the broader corporation as opposed to the
charity ann or the names might be so similar that it's difficult to
differentiate between the two. This is where the EIN 1,villbe essential to
differentiate. And, I think the charity arm of a corporation would have
it's O\VTI EIN.
Ian

> From: Diane Frcundel
rmailto:dfrcundctn)acssucccs~.or 0 l On Behalf Of
> FcdLoan PSLF
> Sent:
Thursday, February 02, 2012 12:20 P\1
> To: Ninemire, Sandra

>Cc:
__ ~
Sippk-A~hcr, Bessie; 'f-cdLoanPSU\ij)phcaa.org'; Po~~, Ian; .l(_bl_(5_1
>
Subject: Re: public vcr~ion: Oklahoma Board ofNur~ing
>
> I agree that a
broader di~cussion is needed. I also agree that elected
> of1icials and
political employee~ would not qualify. Post-doctoral fellows and
> doctoral
candidates raise another interesting category, especially concerning
> their
funding.
>
> Our biggest concern is hov., we will know things such as sources
of funding,
> job responsibilities (such as at a Catholic hospital). etc. At
some point, unless
> there is an obvious issue, \ve'll need to rely on the
certifying official.
>
> We're trying to be cognizant of the title of the
certifier. For example, we
> have one form with the certifier's title as
"Team Leader". We're calling the
> employer to get more detail on the
rc~ponsibilitic~ of the Team Leader.
>
> .lust a general question - if a
company i~ publicly traded. can we assume it'~ a
> for profit
organiLation?
>
> Thanh for your on-going assistance while we hone our
expertise on thi~
> matter!
>
> Diane Freundel
>
(717) 720-3267
> fax- (717) 720-3911
> [email protected]
>
>
>
1------------>
>lhom:
> 1------------>
>
> --------------------------------------------------------------------------
>
l"Nincmirc, Sandra" <Sandra.Ninemire(t1Jed.gov>
> --------------------------------------------------------------------------
1------------>
> I To: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
lpublicservice <publicservice(i1;ed.gov>, "'FedLoanPSLF(i1;pheaa.org"'
>
<[email protected]>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
> I Cc: I
> 1------------>
>
> --------------------------------------------------------------------------
> ------------------------------------------1
>
l"Sipplc-Ashcr, Bc~~ic" <Bcs~icKo.SipplcA~hcr(j_i;cd.gov>, "Foss, Ian"
>
<lan.Foss(d)cd.gov>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
> I Date: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
102/01/2012 09:16 AM
>I
>
> --------------------------------------------------------------------------
> ------------------------------------------1
>
1------------>
> I Subject:
> 1------------>
>
>---------------------------------------------------------------------------
> ------------------------------------------1
> Re:
public version: Oklahoma Board of Nursing
>I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
>
>
>
>
> I think this does warrant a broader discussion 1NithOPE. Mostly
because 1,ve
> have not had this conversation and I think it needs to be fully
vetted, but also
> because elected or appointed officials are in a separate
category.
>
> I'd also like to have a broader conversation on the
post-doctoral fellows and
> doctoral candidate~. That i~ an interesting
catcgoty a~ well.
>
> Sandy
>
>-----Original Mc~~agc -----
> From:
l(b)(5)
> To: FcdLoan PSLF <FcdLoanPSLF(a:'phcaa.org>
> Cc:
.l(_b)
(5_1_=~"1Sipple-Asher, Bc~sie; Ninemire, Sandra; Fo~s, Ian
0
> Sent: Wed
Feb0l 07:43:132012
> Subject: RE: public version: Oklahoma Board of
Nursing
>
> Diane,
>
> Yes, the Oklahoma Board of Nursing qualifies as a
governmental organization.
>Asa general matter. most boards of this sort
\viii quality as governmental,
> though I think it's going to need to be
looked at on a ca~c-by-casc basis.
>
> And, I think it's ~afc to rely on
the top-level domain of things like *.gov, *.mil,
> and *.cdu, ~incc they
ha\'c a limited purpose and arc controlled by
> authoritative ~ources. The
same could not be ~aid for the *.u~ domain. For
> instance, the *.gov

top-level domain is controlled by the Government
> Service~ Admini~tration
(~cc here:
> http~: '/www.dotgov.gov/portaliwchidotgov/wclcomc).
>
(b)(5)
> And Diane, thank you for re-sending

this outside of your secure messaging
> software.
>
> Ian
>
>>
>> From: Diane Freundel
[mailto:dfreundefli:aessuccess.or On Behalf Of
0 ]
> > FcdLoan PSLF

>>Sent:
Tuc~dax, .lanuarv 31, 2012 4:36 P\1
>>To: l(b)(5) I
>>Subject: public
version: Oklahoma Board ofNur~ing
>>
>>
>>meant to send public - my

apologies. Diane
>>
>>-----Forwarded by Diane f-reundcl/PHEAA on
01/31/2012 04:35 PM-----
> > 1------------>
>>lhom:
>>
>>
>
>-----------------------------------------------------------------------
>
>--------------------
>
>>
---------------------------------------------1
> > IFedLoan PSLF/PHEAA
>>
>>
>
>-----------------------------------------------------------------------
>
>--------------------
>
>>
---------------------------------------------1
> > 1------------>
>> I To:
I
>> 1-----------
>
>>
>
>-----------------------------------------------------------------------
>
>--------------------
>
>>
---------------------------------------------1
> > lpublicservice(?i)ed.gov
>
>I
>>
>
>-----------------------------------------------------------------------
>
>--------------------
>
>>
---------------------------------------------1
> > 1------------>
>>I
Date:
>> 1-----------
>
>>
>
>-----------------------------------------------------------------------
>
> -------------------
>
>>
---------------------------------------------1
>> 101/31/2012 12:18 P\1

>
>
>>
>
>-----------------------------------------------------------------------
>
>--------------------
>
>>
---------------------------------------------1
> > 1------------>
>>I
Subject:
> > 1-----------·
>
>>
>
>-----------------------------------------------------------------------
>
> -------------------
>
>>
---------------------------------------------1
> > !Oklahoma Board of

Nursing
>>I
>>
>
>-----------------------------------------------------------------------
>
>--------------------
>
>>
---------------------------------------------1
> > 1------------>
>>I Sent
by: I
>> 1-----------·
>
>>
>
>-----------------------------------------------------------------------
>
> -------------------
>
>>
---------------------------------------------1
> > IDiane Frcundcl

>>I
>
> ----------------------------------------------------------------------
> -------------------
>>
---------------------------------------------1
>>
>>
>>
>>
>>Oklahoma
Board of Nursing
> > 2915 N. Classen Blvd., Suite 524 Oklahoma City, OK
73106
>>
> > http://www.ok.gov/nursingiabout.html
>>
>>We believe this
entity qualifies because it is a part of the state.
>>
>>Our question is
\vhether there is anything unique to Boards in general.
>>Would a Board
member be con~idcrcd an employee? Typically we won't
>>know if a borrower
is a member of the board or an employee. In
> rc~carching
> > thi~
pm1icular case, we did sec that the borrower is not a member of
>>the
board, rather she 1~ one or the employees listed in the staff directory.
>
>
>>Thank you!
>>
> > Diane Freundel
>>(717)
720-3267
> > fax-(717) 720-3911
> > [email protected]
>>
>>
>>
>
--------------------------------
>>
>>This message contain~ pri\'ilcgcd and confidential

> for
>>the abo\'c addressees only. If you receive
this message in error
>>please delete or dc~troy this message and/or
attachments.
>>
civil and
>>criminal pro~ccution of any individual engaging in the
unauthorized
> > u~c of this mc~~agc.
>>
>
>>
>
>
>
>
>
>
>

attachmcnb.
>
civil and criminal
> mc~sagc.
>
>
From: Foss, Ian

Sent: 2 Feb 2012 12:16:37 -0600
To: Fedloan PSLF;Ninemire, Sandra
Cc: Sipple-Asher, Ll(b~l(~51~----~
Subject: RE: public version: Oklahoma Board of Nursing
On non-profit organization i~suing stock, I should clarify. I think ~omc

~tatc~do allow non-profit corporations to i~~uc ~tock, they allow it only
inasmuch a~ it would he a proxy for quantifying control, e.g., each member
of the hoard of director~ in a hoard of four holds 25%:,of the ~tock, so each
has an equal vole. I lowcvcr, no propc11yrights, such as dividends, etc.,
allach to the issuance of that stock.
I think ~uch non-profits, dc~pite

issuing ~tock, could nol be publicly traded. So, my underlying response,
that publicly traded companies arc for-profit, remains the same.
>
> From: Foss, Ian
> Sent: Thursday, February 02,
2012 12:42 PM
> To: 'FedLoan PSLF'; Ninemire, Sandra
> Cc: Si le-Asher.
~~~~.,,.
Bessie; (b)(5)
> Subject: RE: public version: Oklahoma Board of
Nursing
>
> Diane,
>
> We plan on ~citing up a meeting with OPE on the
broader issues to get to a
> con~cnsu~.
>
> With regard to whether a
borrower 1~an employee, I think we have very little
> choice hut to rely
upon the employer's certification, in all aspects.
>
> With regard to
political appointees and elected officials, I think it would be
> easier to
detem1ine whether a borrower in question falls into either of those
>
classes because there is likely to be infonnation about them on the
>
organization's \vebsite. So, ifwe take the stance that they are not
>
"employees". then they would be easy to identify with little effort
>
>
For the doctoral and post-doctoral researcher~, howc\'cr, 1brought them up
>
a~ a policy decision that we would need to make and i~~ucguidance upon;
>
you would rely on the cettification of the employer, just like you would
foe
> the rcligiou~ly affiliated organization.
>
> The authorized
official's job title i~ going to be \'Cty tricky. My authori?cd
> official
is a "Program Support A~~i~tant''_and looking at it, I don't think you'd
>
have any way ofknowing that the person is really "authoriLed". Bessie,
>
Sandy, and Diane, I'd be interested in hearing your take on this.
>
> /\s a
general matter, not-for-profit organizations cannot issue stock, so they
>
cannot be publically traded. So, I think it's a fair assumption to make
that if
> there is a publicly traded corporation, it is not a not-for-profit
organization.
> They two are essentially legally incompatible · - stock is a
form of ownership
> in a corporation through \vhich profits are distributed.
That being said,
> publicly traded corporation might have charity arms, and
borrower~ might
> inadvertently list the name of the broader corporation as
opposed to the
> charity am1 or the names might he ~o similar that it'~
difficult to differentiate
> between the two. Thi~ i~ where the EIN will he
e~~ential to differentiate.
> And, I think the chaiity am1 of a corporation
would have it's own EIN.
>
> Ian
>
>>
From: Diane Freundel Lmailto:dfreunde:11-aessueeess.orgl On Behalf Of
>>
FedLoan PSLF
>>Sent: Thursday, February 02, 2012 12:20 P\1
>>To:
Ninemire. Sandra
>>Cc: Sipple-Asher, Bessie; '[email protected]';
Foss, Ian; ~b)(5) I
>>Subject: Re: public version: Oklahoma Hoard of
Nursing
>>
>>I agree that a broader di~cm~ion is needed. I al~o agree
that elected
>>official~ and political employee~ would not qualify.
Po~t-doctoral fellows
> and
> > doctoral candidates rai~c another
interesting category, especially

> concerning
>>their funding.
>>
>>Our
biggc~t concern i~ how we will know thing~ such a~ ~ourccs of funding,
>>
job rc~pon~ibilitics (~uch as at a Catholic hospital), etc. At some point,
>
unless
> > there is an obvious issue, we'll need to rely on the certifying
of1icial.
>>
>>We're trying to be cogniLanl of the tille of the
certifier. For example, we
>>have one fonn with the certifier's title as
'Team Leader". We're calling the
>>employer to get more detail on the
responsibilities of the Team Leader.
>>
>>Just a general question - if a
company is publicly traded. can we assume it's
>a
>>for profit
organization?
>>
>>Thank~ for your on-going a~~i~tanccwhile we hone our
expertise on thi~
>>matter!
>>
>>Diane Frcundcl
>>Compliance
Services
> > (717) 720-3267
> > fax-(717) 720-3911
> > dfreunde(a;pheaa.org
>
>
>>
> > 1------------>
>>I From:
> > 1------------>
>>
>---------------------------------------------------------------------------
> --
> > ---------------------------------------------1
>>
l"Nincmirc, Sandra" <Sandra.Nincmirc(j_i;cd.gov>
>>I
>>
> --------------------------------------------------------------------------
> --
> > ---------------------------------------------1
>>
1------------>
>> I To:
> > 1------------>
>>
> --------------------------------------------------------------------------
> --
>> ---------------------------------------------1
>>
lpublic~crvicc .l(_bl_(5_1
_______ ~1"'FcdLoanPSLF(a;phcaa.org"'
>>
<FcdLoanPSLF(a/phcaa.org>
>
>
>---------------------------------------------------------------------------
> --
> > ---------------------------------------------1
>>
1------------>
>> I Cc:
> > 1-----------·>
>>
>---------------------------------------------------------------------------
> --
>> ---------------------------------------------1
>>
l"Sipplc-Ashcr, Bc~~ic" <Bcs~icKo.SipplcA~hcr(j_i;cd.gov>, "Foss, Ian"
>>
<Ian. Foss((j)cd.gov>
>>
>---------------------------------------------------------------------------
> --
> > ---------------------------------------------1
>>
1------------>
>>I Date:
> > 1------------>
>>
>---------------------------------------------------------------------------
> --
> > ---------------------------------------------1
>>
102/01/2012 09:16 AM
>>I
>>
> --------------------------------------------------------------------------
> --
>> ---------------------------------------------1
>>
1--------->
> > I Subject:
>> 1-----------·
>
>>
> --------------------------------------------------------------------------
> --
>> ---------------------------------------------1
>>
IRc: public vcr~ion: Oklahoma Board of Nursing
>>I
>>
>---------------------------------------------------------------------------
> --
> > ---------------------------------------------1
>>
>
>
>>
>>
>>
> > I think this does warrant a broader discussion with OPE.
Mostly because
> \Ve
>>have not had this conversation and I think it needs
to be fully vetted, but
> al~o
>>because elected or appointed official~
arc in a separate category.
>>
>>I'd abo like to have a broader
conversation on the po~t-doctoral fellows
> and
> > doctoral candidates.
That is an interesting category as well.
>>
>>Sandy
>>
> > -----
Original Messa e -----
> > From: (b)(5)
000 00
> > To: Fe~dLo nn~PSL°F,-'
<FedLoanPSLF(U;pheaa.org>
>>Cc: l(b)(5) Sipple-Asher, Bessie:I
Ninemire. Sandra; Foss, Ian
>>Sent: Wed Feb 01 07:43: 13 2012
>>Subject:
RE: public version: Oklahoma Hoard of Nursing
>>
>>Diane,
>>
>>Ye~,
the Oklahoma Board ofNursing qualific~ as a governmental
> organinllion.
>
> /\s a general matter, most hoards of this ~or! will qualify as
governmental,
>>though I think it's going to need to be looked at on a

case-by-case basis.
>>
>>And, I think it's ~afc to rely on the top-level
domain of thing~ like *.gov,
> *.mil,
>>and *.cdu, ~inec they have a
limited purpose and arc controlled hy
>>authoritative ~ourccs. The same
could not be ~aid for the* .u~ domain. For
> > instance, the * .gov
lop-level domain is controlled hy the Government
> > Service~ Admini~tration
(sec here:
> > https: ..\\'WW.dotgov.gov. portaliweb/dotgoviwelcome).
>>
>>
Although I am only opining at this point and we are not in a place where
\Ve
>>need to make a decision just yet, given the definition of "employee"
and
>>"government employee" in 685.219 of"one who is hired and paid" by
the
>>organization. I would think that elected officials and political
appointees at
>>any level of government do not qualify. Though, I am
curiou~ what you
>>(Diane), and other~ (Sandy and Bc~~ic) think, and
whether you think this
>>warrants further consideration (with OPE and
OGC).
>>
> > I would abo add that we really arc relying on employer~ to
know what the
>>definition of employee is and certify only those who meet
the definition.
>>I spoke lo a number of post-doctoral fellow~ and
doctoral candidates who
> > vmrk at the institutions where they are seeking
their degree and it raised a
> > lot of questions in my mind as to whether a
lot of those doing scientific
>>research qualify, especially because they
either in-whole or in-part are
>>funding by sources that are not the
institutions, e.g .. the National Institutes
>>of Health.
>>
>> And
Diane, thank you for re-sending this outside of your secure mc~~aging
>>
~oftware.
>>
>> Ian
>>
> > > -----Original Message-----
>>>From: Diane
Freundel [mailto:dfreundefa'.aessueeess.org l On Behalf Of
> > > FedLoan PSLF
>
>>Sent: Tuc~da , .lanuaiy 31, 2012 4:36 PM
>>>To: (b)(5)
>>>
~---~
Subject: public \'Cr~ion: Oklahoma Board ofNur~ing
>>>
>>>
>>>meant
lo send public - my apologies. Diane
>>>
> > > ----- Forwarded by Diane
Freundel/PHEAA on 01/31/2012 04:35 PM-----
>>> 1------------>
>>>I
From:
>>> 1------------>
>>>
>>
>-----------------------------------------------------------------------
>>
>--------------------
>>
>>>
---------------------------------------------1
> > > IFcdLoan PSLF/PHEAA

>
>>I
>>>
>>
>-----------------------------------------------------------------------
>>
>--------------------
>>
>>>
---------------------------------------------1
> > > 1------------>
>>>I
To:
>>> 1------------>
>>>
>>
>-----------------------------------------------------------------------
>>
>--------------------
>>
>>>
---------------------------------------------1
>>>
Ipub Iic~ervicc(c(ed.gov
>>>I
>>>
>>
>-----------------------------------------------------------------------
>>
>--------------------
>>
>>>
---------------------------------------------1
> > > 1------------>
>>>I
Date:
> > > 1------------>
>>>
>>
>-----------------------------------------------------------------------
>>
>--------------------
>>
>>>
---------------------------------------------1
>>> 101/31/201212:18
PM
>>>I
>>>
>>
>-----------------------------------------------------------------------
>>
>--------------------
>>
>>>
---------------------------------------------1
> > > 1------------>
>>>I
Subject:
> > > 1------------>
>>>
>>
>-----------------------------------------------------------------------
>>
>--------------------
>>
>>>
---------------------------------------------1
> > > !Oklahoma Board of
Nursing
>>>I
>>>
>>
>-----------------------------------------------------------------------
>>
>--------------------
>>
>>>
---------------------------------------------1
> > > 1------------>
>>>I
Sent by:
> > > 1------------>
>>>
>>
>-----------------------------------------------------------------------
>>
> -------------------
>>
>>>
---------------------------------------------1
> > > IDiane hcundcl

>>>
>>>
>>
>-----------------------------------------------------------------------
>>
>--------------------
>>
>>>
---------------------------------------------1
>>>
>>>
>>>
>>>
>>>
Oklahoma Board of Nursing
> > > 2915 N. Classen Blvd., Suite 524 Oklahoma
City, OK 73106
>>>
>>>http:/ www.ok.l!o\·inursinl!iabout.html
>>>
>>>
We believe thi~ entity qualifies because it i~ a part of the state.
>>>
>
>>Our question is whcther there 1~ anything unique to Boards in general.
>
>>Would a Board member be considered an employee? Typically we won't
>>
> know ifa borro,Ner is a member of the board or an employee. In
>>
researching
>>>this particular case, we did see that the borrower is not
a member of
>>>the board. rather she is one of the employees listed in
the staff directory.
>>>
>>>Thank you!
>>>
>>>Diane Freundel
>>>
Compliance Service~
> > > (717) 720-3267
>>>fax- (717) 720-3911
>>>
org
>>>
>>>
>>>
>>
>
--------------------------------
>>>
>>>This message contain~ privileged and confidential

infonnation intended
>>for
>>>the above addressee~ only. If you
receive thi~ mes~agc in e1Tor
>>>please delete or destroy this message
and/or attachments.
>>>
>>>The sender of this message will fully
> > > criminal prosecution of any individual
engaging in the unauthorized
>>>use ofthis message.
>>>
>>
>
--------------------------------
>>>
>>
>>
>>
>>
>>
>>
>
>>

>>the above addressees only. If you receive this
>>delete or destroy this message and/or
attachments.
>>
civil and criminal
>>prosecution of any individual engaging in the
>>message.
>>
>
-------------------
>>
From: Foss, Ian

Sent: 19 May 201716:52:35 +DODO
To: !(b)(5) I
Subject: RE: Pure Milk Mom
Attachments: PSLF- Pure Mom Milk
(b)(5)
From: l(b)(5) I
Sent: Fnday, 17 February, 2017 18:38
To: Fedloan PSLF
Cc: l(bl(5l I
Battle, Cynthia; Foss, Ian; Odom, Christian
Hi Kim,
After researching the requirements that are needed to obtain licensure as a Lactation Consultant,
FSA determined that \Ve\Vill need to escalate Pure Milk Morn to OGC to determine if Lactation
Consultants qualify under any SOC codes that would make it a PSLF qualifying organization
providing public health services.
Thanks,
Taneka
From: Kimberly A Myers [rnailto:[email protected] l On Behalf Of Fedloan PSLF
Sent: Tuesda , February 14, 2017 10:46 AM
To: (b)(5)
Subject: Pure Milk Mom
Hi Taneka!
This employer certified as private not-for-profit, public health. The borrower founded the organization and
she specializes in lactation consultation. She is an International Board Certified Lactation Consultant
(IBCLC), but an IBCLC isn't necessarily a nurse. I found that the organization is not-for-profit; however,
l'rn not sure if you would classify an IBCLC as qualifying under the SOC.
Your guidance is appreciated. Same password as used previously today. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: Foss, Ian

Sent: 24 Feb 2017 21:21:11 +0000
To: Siegel, Brian;McLarnon, Gail;Weisman, Annmarie;Smith, Brian;Hoblitzell,
Barbara
Subject: PSLF- Pure Mom Milk
Hi there PSLFfolks,
We have another employer on which we are being asked to make a decision as it relates to qualifying
employment for PSLF.The organization is a not-for-profit that is not a 501(c)(4), and must therefore
provide a qualifying public service as a primary purpose to be eligible for PSLF.
This organization's purpose is to provide lactation consultant services to mothers who have recently
given birth. The organization employs those who are International Board Certified Lactation Consultants
{IBCLC).This sounds like "public health" to me, but I'm not 100% sure it fits into our definition. Public
health incudes:
• Nurses, nurse practitioners, nurses in a clinical settings; and

• Health care practitioner occupations (like doctors) and health care support occupations, as
defined by the Bureau of Labor Statistics (read: based on the SOCCodes).
Lactation consultants fall into SOCCode 31-9099, or, "healthcare support workers, all others" per the
CIP to SOCcrosswalk (CIP Code 51.0815 is specifically tied to "lactation consultants"). So, this would
seem to fit into the "health care support occupation" family of SOCCode necessary to constitute public
health. But it also seems that a lot of licensed practical nurses hold the IBCLCcertification and provide
lactation consultancy services, and LPNs fall under SOCCode 29-2061, which is in the 29-2000 family.
The 29-2000 family is about "health technologists and technicians" -a SOC Code that doesn't tie to
health care practitioner occupations.
My question becomes, do we want to approve this on the basis of the CIP-SOCcrosswalk categorizing
lactation consultants into health care support occupations, or grapple with whether to include LPNs our
definition of "nurse" or "nurse in a clinical setting" before making a decision-to either approve or deny
this organization. We at FSA have spoken to BLSbefore about their SOCCodes, and they were very clear
that they do not have a standardized definition of what it means to be a "nurse" from an occupational
sense. Indeed, you'll see, when searching through the SOC Codes, that various nurse-like occupations
are scattered throughout the various health-related SOCfamilies.
Let me know what you think.
Thanks,
Ian
PS-while we've had some discussions about some employers recently, I've not communicated any of
those discussions to other staff or FedLoan Servicing, given the hold we're operating under.
From: Foss,Ian
Sent: 22 May 201717:03:22 +0000
To: !(b)(5) I
Subject: RE:Pure Milk Mom
Goodness,yes. Pleasesend over the denial.

From: l~(b_l(_51~~-
Sent: Monday, 22 May, 2017 12:54
To: Foss,Ian
Subject: Re: Pure Milk Mom
Hi Ian,
I researched this organization again and I think we should deny the organization as I not believe
it is for-profit and no longer active. The business filing that Fedloan included in the borrower's
zip file is incorrect. Apparently, there are two Pure Milk Mom's in the world. The organization
that was incorrectly included is listed at a non-profit in North Dakota but this organization is in
Arizona and it was organized as an L.L.C. I found the correct business filing in Arizona (the
borrower is the owner) - the organization is listed as inactive.
http://ecorp.azcc.gov/Details/Corp?corpld=L19850758
The organization's website is no longer available. There is a FB page for the organization but the
borrower/owner doesn't seem to be very active in providing any services.
Are you okay with me sending this over as a denial?
Taneka
From: Foss,Ian
Sent: Friday, May 19, 2017 11:52:35 AM
To: l(b)(5J I
Subject: RE:Pure Milk Mom
__ ~
From: l~(b_l(-51
Sent: Friday, 17 February, 2017 18:38
To: Fedloan PSLF
Cc: l(bl(5l I
Battle, Cynthia; Foss,Ian; Odom, Christian
Hi Kirn,
FSA determined that we will need to escalate Pure Milk Mom to OGC to determine if Lactation
Consultants qualify under any SOC codes that \vould make it a PSLF qualifying organization
Thanks,
Taneka
From: KimberlyA Myers [mailto:[email protected] On Behalf Of Fedloan PSLF
To: !(bl(51 I
Hi Taneka!
I'm not sure if you would classify an IBCLC as qualifying under the SOC.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: Foss, Ian

Sent: 8 Jan 2016 14:51:54 +DODO
To: !(b)(5) I
Subject: RE: PW American Society for Radiation Oncology
Yeah, I doubt this will qualify. Also, when rescinding an employer determination, we have never
provided credit for "time served".
From: l(bJ(5J I
To: Foss, Ian
Subject: FW: PW American Society for Radiation Oncology
FYI- I'll also print the materials.
Sent: Frida , January 08, 2016 8:09 AM
To: (b)(5)
Subject: PW American Society for Radiation Oncology
PLSF_Jan_0S
Thanks!
Kim
attachments.
Code:PHEAA
From: l(b)(5)
Sent: 27 Aug 2012 11:25:58 -0500

Subject: RE: Quality Care Network
Diane,
It's clear that this organin1tion i~ a not-for-profit, but not a 50\(c)(]) organization. It must therefore
provide a qualifying ~crvicc.
As near as I can tell, there arc two primary actors here. The first is the Mancopa County Regional
Behavioral I lcalth Authority, which I take to be a quasi-governmental organization created by the State of
Arizona. The ~econd is the Arizona Department of Ilea Ith Service~.
ll appears as though the Department ofllcalth Services has a contract with \1agcllan Health Services of
Arizona, and there is a requirement that they contract with Provider Netvmrk Organizations to service
children and their families. Quality Care Network was created to fulfill that contractual requirement, and,
as such, its mission is to contract with health care providers, who themselves provide "public service".
However, I can find nothing to support the conclusion that Quality Care Network provides any "public
service" directly, even when looking at how the Bureau of Labor Statistics defines "health support
occupations".
In short, like you, I don't think they qualify.
Ian
Sent: Frida , Au rmt 24, 2012 10:44 AM
To: (b)(5)
Subject: Quality Care Network
Iii Ian, Thi~ 1~ another one we're having difficulties with.
The employer checked 50l(c)(3). We can't conlinn their 50\(c)(J) status.

We can conlinn they arc non-profit, but if they arc not a 50\(c)(J) we
don't think they provide a qualifying ~ervicc. Folder contains AZ
Business filing, articles of incorporation, and some other info we found, such as they offer a 403(8)
retirement plan.
Can you assist? Password to follow. Thanks!
(See attached file: Quality Care Network.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax-(717) 720-3911
d fn:undc((_l'.phcaa.org
From: l(b)(5)
Sent: 20 Mar 2017 15:40:34 +0000
To: Foss,l(b)(5J I
Subject: RE:Question - ASUAlumni Law Group
Makes sense.Thank you(;)

From: Foss,Ian
To: l(bJ(5J I
Subject: RE: Question - ASUAlumni Law Group
I can't think of where else to get it besidesthe BMF. It seemsthat they started taking this information
out of the BMF. Given the confusion here, we should simply ask the organization for documentation
supporting their IRSdetermination and when it became effective. I'm thinking of it like conflicting
information.
From: l~(b~)(5_1-,----,-,-'
Sent: Thursday, 16 March, 2017 13:20
To: Foss,Ian
Subject: Question - ASU Alumni Law Group
Hi Ian,
I'm getting conflicting information on line that is causing me to question the ruling date for the
ASU Alumni Law Group. I initially wasn't worried about the ruling date listed on GuideStar for
the ASU Alumni Law Group because the date fell within the approval date that FedLoan
provided to us as "Earliest Approved". I am looking deeper into this organization's ruling date
now that we've learned that the date FedLoan provides as the "Earliest Approved Date" does
not necessarily reflect how far back a borrower's retraction may cover- this borrower's
employment goes back to 2014.
Attached are the Articles of Organization for the ASU Alumni Law Group that I pulled from
Arizona's Business Entity search. The document states that they were established in 2013 as a
501(c)(3). This conflicts with GuideStar's and ProPublica's ruling date of 2016. Even though
ProPublica lists that they have been tax exempt since Feb. 2016 they also have a copy of the
organization's 2013 Form 990 where they are listed as a 501(c)(3)
(https://projects.propublica.org/nonprofits/organizations/464635819).
I was unable to pull the Ruling Date of the organization out of the IRS Exempt Organization
BMF; however I think that we could qualify the organization as PSLFeligible since 2013 based
on the attached documents and the Form 990. What do you think? Is there somewhere else I
can look to verify the organization's status?
Thanks,
Taneka
From: 1~(b~)(5~1--,
Sent: Tuesday, March 14, 2017 5:40 PM
To: FedLoanPSLF;l(bJ(5J I
Cc: Odom, Christian; Battle, Cynthia; Foss,Ian
Subject: RE: RE: RE: PSLFEmployer Retractions
Thanksfor explaining. Moving forward - could the spreadsheet or information provided list the oldest
employer approved date. Allowing us to see how far back a retraction could extend will help us better
assessborrower impact.
We will do some more research on this organization to determine their status prior to 2016. Everything
that we have viewed indicates that this organization was granted their exempt status in 2016; however,
I located a 2013 Form 990 for this organization that lists the employer as a 501(c){3}.
To: l(bJ(5J I
Subject: Re: RE: RE: PSLFEmployer Retractions
Hi Taneka! I apologize, I was under the impression that the date you were requesting was the date that
the Business Unit performed the approval. I can attach the ECF again, but in the file, the one ECF was for
the employment period of 10/10/14 to 2/22/16, which was approved on March 23, 2016.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
~,~,,.,!(b)(5) U(b)(5) I
To FedLoan PSLF <[email protected]>. !(b)(5) li(b)(5)
COy~c/1/h~iaT'~<Ctviccilllh~,a~,B~aillll;;;le@@ie~d.~go"'v•>.
Cc ""Odom, Christian" <[email protected]>.~"B[a~ttt1e~, "'Foss, Ian" <[email protected]>
u.n, 03/1412017 04:29 PM
:C;LJtw-ad
[external]RE: RE: PSLF Employer Retractions
Hi Kim,
The spreadsheet you provided listed that the oldest approval for this organization was on March 23, 2016 and that
there were two borrowers impacted. We show that ASUAlumni Law Group's status changed to 501(c)(3) as of
February 2016 so believed this would cover the borrowers listed.
What is the oldest approval that you have on file?
Thanks,
Taneka

Sent: Tuesda , March 14, 2017 4:13 PM
To: (b)(5)
Subject: Re: RE: PSLF Employer Retractions
Hi Taneka! Thanks for the prior email and this email. I will notify the Business Unit and get the letters to
you as soon as possible.
I do have one question in regards to the ASU Alumni Law Group below. When we originally reviewed, we
did not find on GuideStar. I do see that they are listed now on GuideStar as you had found; however, the
Ruling Year indicates 2016. Most of the employment that was submitted was prior to 2016. I wasn't sure
how you wanted us to proceed with those employment dates, as prior to 2016 they would have been not-
for-profit, but we still don't believe they provide a qualifying public service.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

Cc l{b)(5) U(b)(5) !"Batlle, Cynthia" <Cynthia [email protected]>, "Foss, Ian" <lan.Foss@ed gov>, "Odom, Christian"
<C [email protected]>
n'":e 03/14/2017 03.22 PM
SubJect [external]RE: PSLF Employer Retractions
Hi Kim,
FSA responses to the potential employer retractions are listed below:
FSA Approved Retractions

Alphabet Arts (please send the draft letter for review)
AmeriHealth Caritas
Common Cause (please send the draft letter for review)
Corrections Corporation
New Jersey State Nurses Association (please send the draft letter for review)
WREG LLC
- The organization is listed as a subsidiary of Tribune Media. The organization is for-profit.
PSLFApproved
ASU Alumni Law Group
- FSAverified that this organization is a 501(c){3) and should qualify for PSLF.We validated the organization's
eligibility through GuideStar and the I RSExempt Organization BMF.
Please let me know if you have concerns/questions.
Thanks,
Taneka
From: KimberlyA Myers [mailto:[email protected] On Behalf Of Fedloan PSLF
Sent: Tuesda , March 07, 2017 11:41 AM

To: (b)(5)
Subject: PSLF Employer Retractions
Hi Tankea!
Here are a few more employers identified that we believe had ECFs approved in error.
Again,I consolidated the information on the employers into a spreadsheet, and created separate folders
for the employer that house the ECFs and additional information we found or have on file.
Please let me know if you have any questions. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: l(b)(5)
Sent: 25 May 2017 14:34:33 +0000

To: Foss, Ian
Subject: Re: Question Regarding Approvals
Sounds good and thanks. I only have one more email to send you from here today. It's
for Imagine Schools. I just need to package it up to send it out.
From: Foss, Ian

To,!(b)(51 I
We could also contact the authorized official before retracting, and would recommend
that Fed loan Servicing do so before retracting. However, if we find that the conflicting
information cannot be resolved, then we should retract to give the borrower an
incentive to comply with our requests for additional information.
5
On May 25, 2017, at 10:30, ..._!(b_l(
_1__ 51______
_,!..._!(b_l(_ _,!wrote:
I would think that Fed loan would need to retract these borrowers until they
are able to reconcile the conflicting information. What do you think?
Taneka
From: Kimberly A Myers <kmvers((/)pheaa.org> on behalf of FedLoan PSLF

<F cdl .oanPS I ,F (luphcaa.org>
Sent: Tuesday, March 28, 2017 7: 10 AM
To,!(b)(51 I
Subject: Question Regarding Approvals
Hi Taneka! I wanted to get your input on how you would like us to handle a few
borrower's ECFs.
We have a few borrower's whose employers were previously approved; however,

after further review, the borrowers provided the EIN of another federal agency.
Four borrowers provided the EIN of the Department of Education, but listed their
employer as an otherwise eligible agency (IRS, Searcy Public Schools,
Albuquerque Public Schools, Community Guidance Center). One borrower
provided the EIN of the University of Central Missouri but listed their employer as
Children's Mercy Hospital.
The Business Unit attempted to reach out to the borrower's to obtain a copy of their
W-2; however, they have yet to return this documentation.
I would hate to retract the employment as their employer is otherwise eligible;

however, wanted to get your opinion. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
This message contains privileged and confidential information intended for

the above addressees only. If you receive this message in error please
delete or destroy this message and/or attachments.
prosecution of any individual engaging in the unauthorized use of this
message.
Code:PHEAA
From: l(b)(5)
Sent: 25 May 2017 14:40:16 +0000

To: Fedloan PSLF
Cc: l(bl( 5l I
Hi Kim,
Fed Loan should contact the authorized officials before retracting the borrowers.
However, if the conflicting information cannot be resolved after contacting the
authorized officials, Fed Loan should send a retraction to give the borrower an incentive
to comply with the request for additional information.
Thanks,
Taneka

Sent: Tuesday, March 28, 2017 7:10 AM
To: !(b)(51 I
Subject: Question Regarding Approvals
Hi Taneka! I wanted to get your input on how you would like us to handle a few borrower's ECFs.
We have a few borrower's whose employers were previously approved; however, after further
review, the borrowers provided the EIN of another federal agency. Four borrowers provided the
EIN of the Department of Education, but listed their employer as an otherwise eligible agency
(IRS, Searcy Public Schools, Albuquerque Public Schools, Community Guidance Center). One
borrower provided the EIN of the University of Central Missouri but listed their employer as
Children's Mercy Hospital.
The Business Unit attempted to reach out to the borrower's to obtain a copy of their W-2;
however, they have yet to return this documentation.
I would hate to retract the employment as their employer is otherwise eligible; however, wanted to
get your opinion. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Code:PHEAA
From: Foss, Ian

Sent: 7 Mar 201719:52:09 +0000
To: !(b)(5) I
Cc: Battle, Cynthia
...,._ ...,._
(b)(5)
From: l~(b_l(_51~~=-'
Sent: Tuesday, 07 March, 2017 14:51
To: Foss, Ian
Cc: Battle, Cynthia
(b)(5)

To: !(bl(51 I
Subject: Re: RE: Baltimore Symphony Orchestra OrchKids
Hi Taneka! Thank you so much for providing feedback so quickly.
To your additional question, the ECF date on the letter is correct. Diane and I were working on compiling
and cleaning up our internal spreadsheets to send over to you (obviously -~,;~~ •~ m~irn •
h ~m f,
for you to use), based on our conference call we had several weeks ago. (bl( 5l I
' ,.,~ . +h;~ · +h~+ o:.--~~~h~,.j
(b)(5)
Please let me know if you have any additional questions. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

Cc "Odom, Christian" <Christian Odom@ed gov>, "Battle, Cynthia" <Cynthia.Battle@ed gov>, "Foss, Ian" <Ian [email protected]>,
!(b)(5) U(b)(5)
u.n, 0310712017 01:49 PM
:C;LJIJl'-ad [external][external]RE: Baltimore Symphony Orchestra OrchKids
Hi Kim,
Ian had the opportunity to review the borrower's letter. Attached are edits to the denial letter, with PII removed.
As you will notice, additional language was added to the text to help ensure that the borrower understands what
documentation needs to be supplied to help FedLoan and FSA properly review Baltimore Symphony Orchestra
OrchKids for PSLFeligibility.
While reviewing the letter, we also noticed that the borrower's ECFreceived date was listed as May 2015? Would
you be able to confirm if the ECFdate received is correct and if so, why FSA is just receiving this employer
escalation for review?
Thanks,
Taneka
From: Kimberly A Myers [mailto:[email protected] l On Behalf Of fedloan PSLF

To: l(bJ(5J I
Subject: RE: Baltimore Symphony Orchestra OrchKids
Hi Taneka! Sorry for the delay on this one. Attached is the borrower letter for your review. Password to
follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

Cc l{b)(5) U(b)(5) I
"Battle, Cynthia" <Cynth1a.Battle@ed gov>, "Foss, Ian" <Ian [email protected]>. "Odom,
Christian" <Christian Odom@ed gov>
D:i:e 02/17/2017 03:52 PM
[external]RE: Baltimore Symphony Orchestra OrchK1ds
Hi Kim,
The EIN for this organization links to the "Baltimore S11mnhon11

Orchestra Pla11ersCommittee Inc." There is no
revenue associated with this organization. j(b)(5l
(b)(5)
I
Thanks,
Taneka

To: !(bl(51 I
Subject: Baltimore Symphony Orchestra OrchKids
Hi Taneka!
This organization certified as private not-for-profit, public education. They are 501(c)(S). It is a kids
program within the symphony. They have staff/instructors, including the borrower. The program (which is
set up to be in a school-like environment) runs during the school year both during and after school. We
found that the students are divided by grade level and have classes/homework.
We think they could possibly be approved under public education, or possibly 'other school based
services', but wanted your opinion.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: l(b)(5)
Sent: 25 Oct 2016 20:44:09 +ODDO

Cc: Battle, Cynthia;Tiongquico, Rene
Subject: RE: Re: Cherokee Nation Tribal Entites
Hi Kim,
You can retract the denial of this organization. Can you also send us a copy of the retraction.
Thanks,
Taneka
Sent: Tuesda , October 11, 2016 9:03 AM
To: (b)(5)
Subject: Re: Re: Cherokee Nation Tribal Entites
Hi Taneka! Thanks for your review and follow-up. I will take care of the below organizations.
However, I want to seek further clarification another organization within this particular tribe. Previously. we
had escalated Cherokee Nation Technology Solutions and you had agreed it should be denied. as they
are for-profit Should this decision be reversed? I attached a pdf of the original email so you won't have to
go track it down. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
c::ro,'l l/bl/51 U(b)(5)

Cc l{b)(5) l<[email protected]>, "T1ongqu1co.Rene" <[email protected]>. "Battle, Cynthia" <Cynthia [email protected]>
D:i:e 1010712016 02.10 PM
Suty,ct [external]Re: Cherokee Nation Tribal Entites
Hi Kim,
Rene met with a larger policy group to discuss the Cherokee Nation Tribal Entities and few of
the other tribal casinos we have pending. We believe the that the Cherokee Nation Tribal
entities: Cherokee Nation Technologies, CN Management & Consulting, and Cherokee Nation
Business are qualifying employers for the purpose of PSLF.The policy group determined that
these entities are governmental so whether the government entity is profit making or not
doesn't negate their governmental status.
Thanks,
Taneka

To: l(b)(5) I
From: 51_~_,
l(~
._,l(b
__
To: 'Fedloan PSLF'
H1Kim,
Let us do research on both Cherokee Nation Technology Solutions and Cherokee Nation Business before you deny
or send out a retraction of the approval. We were aware that the Cherokee Nation Business was an S(a) firm based
on the initial documentation that PHEAA provided and recommendation for approval in the initial escalation
received for this organization. I need to go back through all the documents received and that we researched for
Cherokee Nation Business.
Thanks,
Taneka

Sent: Tuesda , August 16, 2016 9:23 AM
To: (b)(5)
Hi Taneka! We recently received two more entities that fall under the Cherokee Nation, Cherokee Nation
Technologies and CN Management & Consulting. I'm including them together below for ease in review
since they are within the same tribe.
Previously, we had escalated Cherokee Nation Businesses and Cherokee Nation Technology Solutions.
Cherokee Nation Businesses was approved (4/7/15) and Cherokee Nation Technology Solutions was
denied (9/25/15).
I first searched to determine whether the two new employers are S(a) firms under the SBA. I found
Cherokee Nation Management & Consulting, LLC as an S(a) firm, but not Cherokee Nation Technologies.
However, while searching, I also saw Cherokee Nation Businesses on the list of S(a) firms (which was
previously approved).
Based on the verification as an S(a) firm, I would deny CN Management & Consulting.
I couldn't find any conclusive evidence that Cherokee Nation Technologies is part of the tribe. Their
website indicates they are wholly owned by the Cherokee Nation and is part of Cherokee Nation
Businesses family of companies. I'm not sure how to proceed with this one.
Also, should we retract the previous approval of Cherokee Nation Businesses since they are indeed an
8(a) firm. Also, since Cherokee Nation Technologies is part of Cherokee Nation Businesses, I would be
inclined to deny. As always, your guidance is appreciated. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA

Sent: 10 Mar 2016 19:23:31 +0000
To: Fedloan PSLF
Cc: Battle, L.l(b-'-1(--'51
_____ _,
Subject: RE: RE: Detroit Economic Growth Corporation follow-up
Thank you for checking. The only escalation that I came across that was similar is the Big Horn Health
Network. They were wholly owned by the Memorial Hospital of Sheridan County-which is established
under the state laws for Wyoming. The hospital was treated at a "body corporate" but not a "body
politic". We ultimately denied the Big Horn Health network and stated that the hospital was most likely
not governmental.
I'll let you know what OGC comes back with.
Thanks again,
Taneka
Cc: Battle, Cynthia; Fedloan PSLF;.l(b_l_(5_1
__ ...,
Subject: Re: RE: Detroit Economic Growth Corporation follow-up
Hi Taneka! I went through the employers we had approved in-house as quasi-governmental. I didn't find
any that we approved that did not exercise "governmental power." They were all pretty straight-forward
where we were able to find proof of their quasi-governmental status. As you mentioned, I didn't see any
that we had forwarded that should be questioned either. Let me know if you need any additional
information.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
~r~w1 "Chialastri, Taneka" <Taneka.Chialastri@ed gov>

T,1 Kimberly A Myers <kmyers@pheaa org>, Fedloan PSLF <[email protected]>
Cc "Battle, Cynthia" <Cynthia.Battle@ed gov>, l{b)(5) l<[email protected]>
Da:o 03/09/2016 06'05 PM
SubIoct [external]RE: Detroit Economic Growth Corporation follow-up
Hi Kim,
OGC is researching the Detroit Economic Growth Corporation and a question has come up whether we have
approved any organization for PSLFas quasi-governmental when the organization didn't actually exercise
"governmental power". As you know when states create quasi-governmental organizations and want them to
exercise government authority, they create them, in the state or local code, as bodies "corporate and politic".
When that language is absent, we look to see whether the organization can issue bonds that are backed by the
government, whether they have tax authority, or whether they have eminent domain powers. The Detroit
Economic Growth Corporation is created as a "body corporate", but not body politic-so, as a regular corporation,
it doesn't possessany of those other governmental powers. However, the DEGCwas created by the city of Detroit
and is performing an inherently government function (i.e. economic development).
I'm going through all of our escalationsto see if we ever had a precedent of approving a quasi-government who
did not have "governmental power". I do not believe we have approved any. Does Fedloan have any records of
approving an organization as quasi-governmental who doesn't have actual governmental powers?
Thanks,
Taneka
From: L.l(b-"1(~51_~_,
To: 'Fedloan PSLF'
Cc: Battle, Cynthia
Subject: RE: Detroit Economic Growth Corporation
Hi Kim,
We found additional information to indicate that the Detroit EconomicGrowth Corporation may be quasi-
governmental. As a result, we are forwarding this escalation to the Office of General Counselfor review.
Thanks,
Taneka

Sent: Frida , February 12, 2016 3:58 PM
To: (b)(5)
Subject: Detroit Economic Growth Corporation
Hi Taneka!
This should be the last one for now!
The borrower is disputing a previous denial. The ECF was certified as private not-for-profit. They attached
a supplemental document attempting to outline the services they provide (they did not select a service on
the form). The supplemental document doesn't give great detail, but mainly focuses on the fact that they
are 501(c)(4). We denied the employer in December 2015. Their mission is to promote economic growth
in the City of Detroit, which does not fall under any of the eligible public service categories.
The borrower sent in a letter in January requesting re-evaluation of the employer's eligibility. They
indicate that this organization is under the auspice of the city of Detroit. Although the DEGC isn't
specifically found in the financial statements for the city, the statements mention Economic Development
Corporation (EDC). This is indicated to be a legally separate entity. In addition, the website for DEGC
states that they are a "private, non-profit organization" and they are "not part of the city of Detroit's
government."
We still do not believe that this organization qualifies.
Same password as other employer. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: Foss, Ian

Sent: 15 May 201719:44:58 +0000
To: Fedloan PSLF;Odom,Christian
Cc: Battle, Cynthia; FedLoanProgramMa nagementrl( 5l
Subject: RE: RE: Employer Retractions_2015.05.15 ~----~
b)(5)
1
Thanks, Kim. Since you re checking on one thing, ,ir I
(b)(5)

Sent: Monday, 15 May, 2017 15:38
To: Odom, Christian
5_1--~
Cc: Battle, Cynthia; FedLoanProgramManagement; Fedloan PSLF; Foss, Ian; 1(b_l_(
0
Subject: Re: RE: Employer Retractions_2015.0S.15
Hi Christian! I will check with the Business Unit on the exact root case of these recent retractions. but my
assumption is they came across possibly one employer who may have been approved in error. Due to
this finding, they will query the system against the internal PSLF employer database to determine where
discrepant information exists (approved on the system, but denied in the database).
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
-r,w, ~"~'=~-,o=~----~
"Odom, Christian" <,C~"~,s~tia~o~O~d~o~m=e~d~.
Io Fedloan PSLF <[email protected]>, b 5 i(b)(5) I
c, "Battle, Cynthia" <Cynthia [email protected]>, "Foss, Ian" <[email protected]>, FedloanProgramManagement
<[email protected]>
Da:o 05/15/2017 03:19 PM
SubIoct [external]RE: Employer Retractions_2015 05 15
Kim,
This was probably stated in an earlier email and I am not making the connection. What led to the discovery of this
batch of retractions?
Christian Lee Odom

U.S. Department of Education : Office of Federal Student Aid
50 United Nations Plaza:: San Francisco. CA 94102
(P) 415.486.5683 : (M) 415.533.7556
Instant Message Me On Skype for Business
FederaIStudent
' ' '•'••
,,,n1,1, c· ~~;(IS_;.'
•-, AVi'il::A'I \I~ J"

To: l(bJ(5J I
Cc: Battle, Cynthia; Foss, Ian; Odom, Christian; FedLoanProgramManagement
Subject: Employer Retractions_2015.05.15
Hi Taneka! Again, I'm going to apologize in advance. I am going to be sending over quite a few emails
with employer retractions (15 emails to be exact). I did confirm that the BU is performing a clean-up,
which would explain the numerous retraction requests in the short time-frame.
In this email I included the spreadsheet. I will send the password in a separate email, and the password
will be the same for all files.
Please let me know if you have any questions. Also, if you have any suggestions on how to make this
easier for you, I am open! Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: l(b)(5)
Sent: 18 May 2016 19:45:12 +DODO
To: FedLoan PSLF
Cc: l(b)(5J I Cynthia
Subject: RE: RE: Film LA Inc
Hi Kim,
My apologies for the delay. We agree with your denial of this organization. Film LA Inc is only ensuring
public safety as a result of their contractual obligation with the city of Los Angeles. It is not their primary
mission, as you listed below.
Thanks,
Taneka
Sent: Tuesda , May 17, 2016 12:09 PM
To: (b)(5)
Cc: Fedloan PSLF
Subject: Re: RE: film LA Inc
Hi Taneka! I wasn't sure if you had a chance to review this specific employer yet? I just wanted to follow-
up on this one as it is a dispute as a result of Control Mail that MOH ELA received. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
-,,,., l/bl/51 U(b)(5)

Cc !(b)(5) U(b)(5) I
n'":e 04/15/2016 03.42 PM
SubJect [external]RE: Film LA Inc
Thanks Kim. Our unit is not aware of this escalation but we'll start researching the request.
Thanks,
Taneka

Sent: Frida , A ril 15, 2016 1:54 PM
To: (b)(5)
Subject: Film LA Inc
Hi Taneka!
MOHELA (the borrower's current servicer) notified us that the borrower submitted Control Mail directly to
them regarding the denial of his employer (Film LA Inc). The email also states that FSA had requested
the second review (see "Dispute request" document), so we are not sure if you are aware of this
escalation already.
The original ECF was certified as private not-for-profit performing public safety. The borrower included a
letter explaining why he believes this employer qualifies because of the work they do involving film permit
coordination, as this task ensures public safety while they are filming. Their contract with the city of Los
Angeles was also included, as the borrower felt this outlines the organization's fulfillment of public
services.
We denied the employer in early December 2015, as they are a not-for-profit organization [501 (c)(4)], but
we determined that they do not provide a qualifying public service. Per their Form 990, the organization's
mission is to "enhance film and media production, and attract and retain jobs in southern California."
We feel that this should remain as a denial, Password to follow.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: Kimberly A Myers

Sent: 25 Jan 2017 11:45:37 -0500
Cc: 51'--------'
Freundel;Joyce Zaleski;Robert G Cameron;Corey Detar
Subject: Re: RE: Follow-up regarding PSLFEmployer disputes
Hi Taneka! I ran a quick query on the escalations that have come through Compliance since the
beginning of November 2016.
In total, the Business Unit has escalated a total of 1009 employers to Compliance since
November 1, 2016. Of those, the breakdown is as follows:
143 Compliance needed more information about the organization or borrower's actual
employment (e.g. W-2 to confirm the EIN or that the borrower was actually an employee of the
organization)
239 were denied as being ineligible (e.g. for-profit or not-for-profit not providing a qualifying public
service) - of the 236 that were denied, 51 of those did not provide a qualifying public service, the
rest were for-profit.
577 were approved
1 was a split decision (they lost their 501(c)(3) status, so they were approved up until the
revocation and denied after as they do not provide a qualifying public service)
49 are still under review
If you need any further clarifications, just let me know. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
lrorn "Ch1alastri,Taneka" <[email protected]>

Cc "Battle. Cynthia" <C]:[email protected]> "Foss Ian" <[email protected]>, "Odom. Christian"
<[email protected]>, (b)(5) ]f(b)(5) I
LJc1lH 01/25/201710:32 AM
Suh Hci [external]RE: Follow-up regarding PSLF Employer disputes
Hi Kim,
Thank you for replying so quickly. I just sent the invite out. I don't have Joyce or Bob's email so please feel
free to forward the invite.
To help facilitate discussion, could you also provide the group with a snapshot of the volume and type of
employer escalations that the Compliance office has received over the past three or four months.
Thanks,
Taneka

__ ~
5_1
Cc: Odom, Christian; Battle, Cynthia; Foss, Ian; .l(b_l~(
Subject: Re: Follow-up regarding PSLFEmployer disputes
Hi Taneka! There would be a few others that would like to be involved with the call, Diane
included. I'm not sure if you ever worked with Joyce Zaleski or Bob Cameron, but they would
also like to be included. You may not have their contact information, but I can let them know
when we have the call scheduled, as we will likely get a conference room here.
It looks like the rest of this week is pretty booked as far as schedules for us here, but we are all
available Monday 1/30 from 9 - 12 and 3 - 4. We are also available on Tuesday 1/31 from 9 - 1O
and 1 - 2. If none of those times work for all of you, please let me know, I can look out further into
next week.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From '"Ch1alastri.Taneka"' <Taneka Ch1alastr1@edgov>

To Kimberly A Myers <kmyers@pheaa org>
Cc ""Foss, Ian·· <[email protected]>, '"Battle. Cynthia" <Cynth1a.Battle@ed.~ov> '"Odom, Christian··
<[email protected]>, ""Chialastn. Taneka" <[email protected]>.(b)(5) l!(b)(5)
IJc<if 01/24/2017 0110 PM
Sub_fct [external]Follow-up regarding PSLF Employer disputes
Hi Kim,
Thank you again for chatting with me today regarding the PSLFEmployer Escalation process.
(b)(5)
If you could let me know your availability to meet for this or next week and any other individuals from
Fedloan that should be included, it would be greatly appreciated.
Thanks,
Taneka
and/or attachments.
Code:PHEAA
From: l(b)(5)
Sent: 2 Feb 2017 16:19:26 +0000
To: Foss, Ian
Subject: Re: RE: National Conference of State Legislatures - Possible Retraction
Sounds good. I'll inform FedLoan that this will be escalated.
Thank you,
Taneka
From: Foss, Ian

Sent: Thursday, February 2, 2017 9:58: 18 AM
To: !(b)(51 I
Subject: RI::::RE: National Conference of State Legislatures - Possible Retraction
Since being an instrumentality of a government/governments is not conclusive proof of an organization
being "governmental" for PSLF purposes, I want to escalate to OPE/OGC. That being said, I think this
qualifies.
From: rnl(b~)(~5)--~
Sent: Thursday, f-ebruary 02, 2017 10:54 AM
To: Po~~, Ian
Subject: Fw: RE: National Conference of State Lcgi~laturcs - Po~~iblc Retraction
After reading the letter I believe National Conference of State Legislatures should qualify. What
do you think?
Taneka
From: Kimberly A Myers <kmvers(a:'Pheaa.org> on behalf of FedLoan PSLF

<F cdl .oanPS I ,F(i:1~phcaa.org>
Sent: Thursday, February 2, 20 I 7 9: 13 AM
To: !(b)(51 I
Cc: Odom, Christian; Battle, Cynthia; FedLoan PSLF; Foss, Ian
Subject: Re: RE: National Conference of State Legislatures - Possible Retraction
Hi Taneka! .lust wanted to follow-up on this one.
The Bu~incss Unit called the AuthoriLcd Official, Diane Chaffin, and she stated the National Conference of State
Legislatures 1~ the in~trurncntalily of all stales. She ~lated they arc funded by all 50 stales and they also gel
donation~. She ~lated they arc considered a Government organiLation with the EIN is 84-0772595.
They also asked for Articles of Corporation and she stated they do not have that but she provided the attached IRS
letter.
Thanks!
Kimberly A \tlyers
Compliance Services
(717) 720-2630
horn i(b)(5) l•crubl1csc·n·1cet,1cd cm,,

Io f-edLoan l'SLf- < f-cJLoanl'SLf-,li phcaa m~---
l ·c "Hattie. ( 'ynthia", ( \'ntlua.Hattlet,, cd cm< 'f-oss. Ian" •clan f-o"~" cJ.~,"·>_ "Odom. Christian", ( lm,tian.()Jorn·u cJ.go,·>. !(b)(5)
<publtc,c•r, ,cc~g cJ.go, ·, ==-~
Date 0125201703 39!'\1
Subject: [extemal]IU.: National Conference of State Legislatures - l'ossihle Retraction
Hi Kim,
Could you have the business office reach out this organization for more information on their legal structure before
we proceed \Vith retracting these borrowers? Ian and I started researching the organization but did not uncover much
in our ~carch.
Thanks,
Taneka
From: Kimberly A Myers [mailto:kmvers(dpheaa.orgJ On Behalf Of Fed Loan PSLF

Sent: Wednesda . January 25, 2017 8: 15 AM
To: (b)(5)
Subject: National Conference of State Legislature~ - Possible Retraction
Iii Taneka!
This employer was first escalated to Compliance in November 2016. The employer checked the government box on
the form. However. we found that this organization is actually a bi-partisan non-governmental organization that
serves the members and staff of state legislatures. By definition. we found that a non-governmental organization is a
not-for-profit that is independent from states and international government organizations. Being not-for-profit, in
order to qualify for PSLF, they would have to perform a qualit)'ing public service. Since their objectives are to
improve the qua Iity and effectiveness of state legislatures; promote policy innovation/communication among state
legislatures; and ensure the voices of state legislatures in the federal system, they would not qualify for PSLF
purposes. We ultimately denied the organization.
The Bu~inc~~ Unit ha~ indicated that they have internally approved this organization in the pa~t. Therefore, I am
now submitting for a possible retraction.
It appears that overall 22 borrowers were approved under this employer. The oldest date approved 1,vasMay 12,
2012.
Attached is the information \Ve found as well as a fev,· of the ECFs. I only attached a fev,·, as they were mainly all
certified by the same individual under the same category (Diane Chaffin certified ECFs for 20 of the borrowers
while another 2 had their [CF certified by Mmy Wild). If you would like the remainder of the [Cf\, I can cc11ainly
pull them and ~end them to you.
Kimberly A \-lycrs
Compliance Services
(717) 720-2630
attachments.
Code:PHEAA
From: Kimberly A Myers

Sent: 13 Apr 2016 09:34:28 -0400
To: Foss, Ian
Cc: Diane Freundel;Chialastri, Taneka
Subject: Re: Re: PSLF-American Bar Association
Attachments: ECF_Redacted.pdf, Denial Letter_redacted.docx
Hi Ian! Attached is a redacted copy of the ECF and corresponding retraction letter to the
borrower. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
f-rrnn "Foss, Ian"

1o Kimberly A Myers
Cc Diane Freundel, "Chialastri, Taneka"
LJc1lH041131201608:42 AM
Sub,r,ct [external]Re- PSLF - American Bar Association
One last request (for no\v).
Can we get a copy of one of the retraction letters (redacted) and also confirm that the
organization claimed to be a non-50l(c)(3) not-for-profit that was claiming to provide
public interest legal services. I realize that some may have come in as being from the
501 (c )(3), even if it \Vere ultimately determined that the borrO\ver didn't work there. So
I'm asking about the ones that came in directly from the ABA.
On Apr 11, 2016, at 15:45, Kimberly A Myers <knwcrs({lmhcaa.org> \\Tote:
Hi Ian!
Based on the query the Business Unit periormed, there were 9 borrowers who were denied
outright and a total of 19 that received retraction letters. Of the 19 who received retractions letter,
14 were picked up in this most recent query the Business Unit ran.
The longest timeframe from the date the borrower was originally approved to the date retracted
was 45 months. However, one thing to note for that particular borrower, the Business Unit only
retracted about 10 months of employment (from 8/2011 to 5/2012).
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
lrorn "Foss, Ian" <[email protected]>

To '"Kimberly A Myers'" <[email protected]>
Cc Diane Freundel <[email protected]>. "Ch1alastr1,Taneka" <[email protected]>
IJc<if 04/08/2016 02:56 PM
Sub.fct [external]RE. RE: PSLF - American Bar Association
This is super helpful. Thanks, Kim.
Can you give me a sense of how many borrowers received a retraction regarding the ABA and how many
received outright denials? Also, for those retracted, how long after the approval did the retraction go out
(for the borrower for whom it was the longest)?

To: Foss, Ian
Hi Ian! Outside of the employers Taneka listed below I don't believe we had forwarded any other
"Bar" or "Bar Associations" for review. Although we didn't escalate the employer, I know you also
initially made a determination on the American Immigration Lawyers Association (which Jeff
Baker also drafted a letter to the borrower that Taneka shared with us).
I know in the beginning we were struggling with associations in general and specifically
organizations that would qualify under the "public interest legal services" category. At one point, I
know we had talked through it over the phone, which gave us a clearer understanding of this
category. Once we grasped what organization would/would not qualify under this category, we
internally made the decisions and only escalated to you the ones we were on the fence about.
In regards to the American Bar Association, we made the decision internally that they do not
qualify and provided this guidance to the Business Unit. As we received ECFs from borrowers
employed by the American Bar Association, we were denying.
I know in some instances there were borrowers who were certified as working in a qualifying arm
of the American Bar Association (e.g. American Bar Association Fund for Justice and Education
under the EIN 36-6110299). If we had a reason to question it, we would request the borrower's
W-2 to confirm who actually paid the borrower. In most instances, the borrower turned out to be
employed by the American Bar Association directly under the EIN 36-0723150. In light of your
decision on ACLU, we now have reason to question this further.
We were recently escalated an account for the American Bar Association where the previous
approval had not been retracted. As a result, the Business Unit ran a query to identify and clean
up those borrowers who may have been approved under the American Bar Association in the
past who should not have been. This is most likely where the retraction of the previous approval
came from.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
f-rrnn "Chialastri, Taneka" <Taneka [email protected]>

To "Foss. Ian" <lan.Foss@ed gov>, Diane Freundel <[email protected]>, "'Kimberly A Myers"' <kmyers@pheaa org>
D,itr, 04/08/201612:02 PM
Sub_r,ct [extemal]RE· PSLF -American Bar Association
Hi Ian,
I don't show anything on record for the American Bar Association. I only have documentation of decisions
made regarding the King County Bar Association, Bar Association of San Francisco, State Bar of Wisconsin,
and the District of Columbia Bar.
Thanks,
Taneka
From: Foss, Ian

Sent: Friday, April 08, 2016 11:55 AM
Subject: PSLF- American Bar Association
Hello all,
Can you summarize for me what we've done regarding PSLFand the American Bar Association? We just
got a letter saying we approved them and then retracted it several years later. I'm not finding record that
I worked on it personally, but that doesn't mean its so.
Thanks,
lac
and/or attachments.
Code:PHEAA
(Page 3 of ~)
SEcnoN, ..CERnFtCATIONOF EMPLOYMENT ho authcrizad officllll c- Section 6) Ill a. public 10MC9

S.. s-,lb> 3 at 1h11a.:.:cmpanyr,Q
lnsllld(m forC~ EmplD}'IMl!t CmA:afii:111 Pubk
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lnatnJctJon1tor .1wo11:111Z1d0f'lldllf:
Cclmj:Cllettils form only llyo,, are an ...-u,or1z«1 Dfficllll O:UM p,!llir: .. l'\llcaeotganltlltion 1J1Yfflli:hIlle bort.-tlclenml9d In ~n 1 IIIWl1 am~ed 111.~ i:,,
botR,-, lwH I IYll-(ime A.ffleliCorp1DI Peal:.e Co,ps \lduMaef, M ~e,:I Offldelof Nner1Cofpa Cl 1M Peace Ccwp1.
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11v,,u malu, •tll' """"""' tr>llll lrll'ormdon youprowle in 1h11uc.liol\ you mur1 lftllal Heh th■n;o.
PIIJn ratum tlle compftOd fOffll lotllt boffOWII'. The u.s Dl!l"'tllllll1 ol EOucatlonot the PSLF .........,m■ ymnlac:t you!Or ldd.tliollll ~ or
docl.irnenla1i<ln.
when Ill:
• 0 Chllti lhia bruc f yo11 •• ""•hie io obtftln (:eJ!lflcatlon from 11111l!lh<>nledatrlQIII.1or uampla. bDClluH 1119«11111lut1011no long1r v:lltt. Provkl• ,1 '«IUN-llld
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2. Boff_,.I Employmam stat1n.
(1) Da!Holempk,yment Start:
(MM-OD-YMY)
A~ of hows per week: _BS"

,,...,,be,
~ lUllbur ol hi;io.n per'li"tlek: __ _
FD< purposn oleliglbillty fOr PSLF, full-tlm1 am!IIOyment is dalined n:

" qua one or more s. g,
{A) An ,11nu11 eWl'l!IJ8 of el la.as!30 houri pe,,week or. for a aintrac:tual or empk)y1!181lt pe,looofat least 8 mo111h1. an ;r,,erageo1'30l'loull per
week; or
(B) u11111,e the qual1fyln1,1employment is wllh twc 0( more employen;. lhe nurrber of houra the emplover eo11$i<:!•re full-tlme.
orlell.-& timaPl"OvldBeby the ompfoyeror loiwe taiu,11for• Q;mdilionlllilt ii• qu,Ufying ,_..,,, ro,teave undef lhe Family and Medal!
(2) Ve1;11Hoo
lu..., Ac1 of 1993, 29 li.S.C. 2612(•){1) and (3) ID equi\'alent Lo hour,;, wort<ed in qualifying emiiloynlenL.
NOTE: A fl.II-limeAm I ar Peace C ~1.enlalf os conside,od II fu~--timee I lot" e it. lot PSLF.
3. T~PI' of Pub& Servie• OrganlQIUon, In ueordancewllhtfle dtlfinlllon In Socllon 6 (ChKk one!:

(11) 0 A ggyarnm■ nl or111nl:mtlon [indudlng a FadMal. Stale. local or Tribe! organlzaUoo,~ency or entity:• J)Ubllr::child or famil1 wrvlce ege,ncy,or
• Trtl)eol<:OIIIIQ•
... ""Mlrs~v);
(bJ D A non-profit, ta•-.-aml)I organlz.ellon undar S.etlon S01(e)(J) ol lhe Internal Revenue Code:
A private, non•proflt organization (that ID nol a labor un1011or1 partiS11n polFUC&Iorganlza~on) !hat p!QV!clesat ieasl one ol lhe roUQ'Mng publle
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l..sw anfciroemanl.
i P1.ebliclnmMt law HMCff,

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prac\itiofler occu;iut1an. and ~nt, support QCCUpmiorts, n such fff1"'5 are-d~ t,v the a..reauo! lilhor St11tslic:o-).
li
Putlllc llllucation.
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0 ()(her ~VIII $111'\bs.
OOTE e, 1ocate,gori11s (b) and (c:), Fo, purpoaaa of 1he/\dl•UmereQl.lfromenl (Sedan 3, lt11m2.(b) above). 11bonower"11 QUalifying t1m1>loymen1does not
I certify lhll th1 botrowar ldlln~lillct in Section 1 .11bo.-&ii/Wal employed 111a pu!Jr,o ,er,,ce o,ganluition. 89 Indicated above, or ialwes ser-.ing •nan
AlllarlGo~or Poace Corps.~ilion (in eo::ordence wllh 1h11d&llnilions of I/Iese te.rm1 In Se,;'tJo,,51 during tho~ •denbfieiJ In Item ~(a) of this &eoction.
£J.na · ·
f 0c,lf, Jc,r-, Authoriz9d
AJ..m,n
nue
Offldll.l •
/ISS-r;
(b)(6)
Toda c Dale MM•DD•YYYY
f SERVICING
www.MyFedLoan.org
Phone: 1-800-699-2908 Fax: 717-720-1628
March 8, 2016
RorrO\vcr Name
Address
(b)(6)
Dear l~------~
Thank you for your correspondence regarding your student loan account serviced by FedLoan
Servicing, on behalf of the U.S. Department of Education, detailed below.
Loan Disbursement Loan II Original Principal Current Principal

Seauence (b)(6) I Type Balance I Balance
I Direct lJn~uh~idin:d Con~olidation II S9,745.43 II S6,618.47
2 Direct Subsidi?ed Consolidation II S2.:\637.05 II S24.l40.16
3 I Direct Unsubsidi?ed Consolidation II S38.341.78 I S36.338.52
/li!!wm
'/" ..
D. Fo1d Adc1al D//ctl .. lmm P1og1am (D11n1)
On May 2, 2014, we received your Employment Certification Form (ECF) for American Bar
Association. which you \Vere informed \Vas a qualifying employer for the Public Service Loan
Forgiveness (PSLF) program. After additional review. we could find no evidence of this being a
non-profit organization that also provides a qualifying service for the PSLF program. To be
eligible for PSLF, you must be directly employed by an eligible public service organization as
defined in the PSLF eligibility criteria statement on the back of this letter. Based upon our
further research. \Ve have reversed your previously approved employment period under the PSLF
program. Please accept our apology for any inconvenience this may cause.
If you have any additional questions regarding PSLF. please refer to the information on the back
of this letter or call 1-855-265-4038.
Sincerely,
FedLoan Servicing

F:LIGIBLITY CRITERIA FOR PARTICIPATIO~ I~ THE Pt.:BLIC SERVICE LOA~

FORGIYEXF:SS PROGRA\1
You must have made 120 on-time. separate. monthly payments aficr October I. 2007. on the Direct Loan
Program loans for which forgiveness is requested. Payments made prior to October 2. 2007 do not count
toward meeting this requirement. Each of the 120 monthly payments must he made for the l'ulL scheduled
installment amount within 15 days of the due date.
The 120 required payments must be made under one or more of the following Direct Loan Program repayment
plans:
• lncomL: Contingent RL:paymcnt (!CR) Plan (nut available l'or parent Direct Pl.US Loans or Direct
• Pay As You Earn RL:paymcnt Plan (not available fur parent Direct PI.US Loam or Direct
Cumolidation l.uans that rL:paida parrnt Pl.US Loan)
• Revised Pay As You Earn Repayment Plan (not available for parent Direct PLUS Loans nr Direct
Cumolidation l.uans that rL:paida parrnt Pl.US Loan)
• Standard Repayment Plan with a 10-year repayment period
• Any other Direct Loan Program repayment plan; but only payments that are at least equal to the
You must be employed full-timL:(in any position) by a public service urgani;,ation, or mu~t be scn-ing in a l'ull-
time AmeriCorps or Peace Corps position at the time you make each qualif)-'ing payment. Organizations that
meet the definition of"public service organization" for purposes of the PSLF Program are listed belmv.
• A government organization (including a federal. state. local or tribal organization. agency. or entity; a
• A nun-prof'it, tax-exempt organuatiun* under Section 50l(c)(3) ur the Internal Revenue Cude
(includes most not-for-profit private schools. colleges, and universities);
• A privatL:. non-profit urgani;,ation* (that is not a labor union or a partisan political organi1:ation) that
• Public safety
• Law enforcement
• Early childhood education (including licensed or regulated health care, ! lead Start, and state-
• Public health (including nurses, nurse practitioners, nurses in a clinical setting. and full-time
occupations)
• School library or other school-based services
*NOTF. For p111posesof rlwfull-rime requirement (Section 3. !rem 7 & fl o(rhe FCI'), _vourqualifring
emplo_vment does not include rime spent on job duties tlrat are related to religious i11srr11ctio11,
1rorship
services, or a11J·j(mn of'prose!J·tizing

From: l(b)(5)
Sent: 24 May 201715:35:02 +0000

Subject: RE: Re: Pure Milk Mom
Thanks Kim. I missed the Arizona address on the business filing. The registered agent on the North
Dakota business filing is the same person who filled out the borrower 1 s ECFas a Secretary; however, to
be on the safe side- Can you have the Business Unit reach out to the borrower/owner to get a sense if
the organization is still active and whether their employees have attained state licensure to be a heath
care workers or whether they rely on the certification from a third-party to perform their duties as
Lactation Consultants?
Thanks,
Taneka
Sent: Tuesda , May 23, 2017 11:59 AM
To: (b)(5)
Subject: Re: Re: Pure Milk Mom
Hi Taneka! I just wanted to follow up on this one, specifically regarding the business filing. Even though
the business filing I located was in North Dakota, the principal office address listed on the business filing
matches the address that was provided on the ECF. That is the reason I linked the business filing to the
employer.
I believe I found the business filing you linked to for Arizona, but hadn't saved it. The reason for that is the
business filing in Arizona was purged in June 2015. Coupling that with the borrower indicating
employment beginning November 2015 and the business filing for North Dakota being effective 11/4/15, I
think they are related.
Also, the website I found appeared to be active and they indicated locations in Arizona and North Dakota.
In addition, the borrower was noted as the "President, founder, & IBCLC."
Please let me know if I confused you enough!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
-, ., , i(b)(5) li(b)(5) I
c, "Battle Cynthia" <Cynthia.Battle@ed gov>, "Foss, Ian" <Ian [email protected]>, "Odom, Christian" <Christian Odom@ed gov>,
!(b)(5) l<publicservice@ed gov>
u.n, 05/22/2017 02:02 PM
:C;LJtw-,d[external]Re: Pure Milk Mom
Hi Kim,
Fedloan can go ahead and sent a denial to Pure Milk Mom as we believe it is for-profit and no
longer active an active business. I conducted additional researched on this organization. The
business filing that Fedloan included in the borrower's zip file is for a different Pure Milk Mom.
The organization that was included is listed at a non-profit in North Dakota but this organization
is in Arizona and it was organized as an L.L.C. I found the correct business filing in Arizona (the
borrower is the owner) - the organization is listed as inactive.
http://ecorp.azcc.gov/Detai1s/Corp?corpld=L19850758
The organization's website is no longer available and while there is a Facebook page the
borrower/owner doesn't seem to be very active in promoting their business.
Thanks,
Taneka
From: ~l(b~)(~51
__ ~
To: Fedloan PSLF
Cc: l(b)(5) IBattle, Cynthia; Foss, Ian; Odom, Christian
Hi Kirn,
FSA determined that we will need to escalate Pure Milk Mom to OGC to determine if Lactation
Consultants qualify under any SOC codes that \vould make it a PSLF qualifying organization
Thanks,
Taneka

To: !(bl(51 I
Hi Taneka!
I'm not sure if you would classify an IBCLC as qualifying under the SOC.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: Foss, Ian

Sent: 21 Apr 2017 19:55:14 +DODO
To: FedLoan PSLF
Cc: Odom, Christian;Battle, L.(b-'-l('--51
_________ _, Taneka
Subject: Re: Re: Re: American Legion - document request
Attachments: PSLFPacket.pdf
Thanks, Kim. The document is attached.

Sent: Tuesday, April 18.2017 3:52: 13 PM
To: Foss, Ian
Cc: Odom, Christian; l3attlc, Cynthia; Fedloan PSLF; l(bl(5l IChialastri, Taneka
Subject: Re: Re: Re: American Legion - document request
Hi Ian! Sorry for the delayed response. I wanted to follow-up today, but time got the best of me
(thank-you for prompting me).
The Business Unit was not able to find record of a 62-page document received in February of this
year. The only thing comparable, and I did include it when I sent the files over, was a 109-page
document received in October of last year (but that did not come directly from the Legion).
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From "Foss, Ian"

To Fedloan PSLF
_ _,I,
Cc "Odom, Christian" "Battle, Cynthia", .lfb~)~(5~) "Ch1alastn, Taneka"
Date 04/18/2017 02:26 PM
Sull.ect [extemal]Re. Re. American Legion - document request
Hi Kim,
I just wanted to follow up on this one. I don't think we heard back.
Ian

Sent: Thursday, April 6, 201716:51
To: Foss, Ian
Cc: Odom, Christian; Battle, Cynthia; Fedloan PSLF;"l(b-'-)-'-(5-'-1
__ _,IChialastri, Taneka
Subject: Re: Re: American Legion - document request
(b)(5)
I will let you know when I hear back from the Business Unit.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
lrorn "Foss, Ian"

To Fedloan PSLF
Cc "Ch1alastr1,Taneka", "Odom. Christian", "Battle, Cynthia" l~lb~J(~5)~~
IJc<if 04/06/2017 04:08 PM
Sub.fct [extemal]Re. American Legion - document request
Hi Kim,
Thanks so much for sending this along. Taneka and I are reviewing and will let
vou know.
(b)(5)
Thanks!
Ian
On Apr 6, 2017, at 11 :06, FedLoan PSLF <[email protected]> wrote:
Hi Taneka! I reached out to the Business Unit to request a query and then I will pull the
information together. I will get it to you as soon as possible. However, while I'm waiting for the
query to pull the information together, I just wanted to provide you with some background
information on this particular employer and private not-for-profits in general.
The Business Unit's procedure is to escalate all private not-for-profit organizations to Compliance
for review (unless it was previously approved within the past year). The American Legion was first
escalated to Compliance in February 2014, and we have received numerous ECFs since that
time (it appears we have received ECFs from a total of 10 borrowers). The original ECF was
certified as 501(c)(3). Subsequent ones were certified under numerous categories (501(c)(3) or
private not-for-profit providing military services and other school based services, etc). We
identified that this organization is 501(c)(19), which would mean they have to provide a qualifying
public service. Since they do not directly provide military service or any other qualifying public
service within the realms of the PSLF Program, we had denied.
As you may recall from some of the previous discussions we had regarding the employers we
escalate, if we determine an employer does not provide a qualifying public service, Compliance
will make the decision internally and will not escalate to FSA. Only those employers whom we
can not conclusively determine perform a qualifying public service (or are unsure of) do we
escalate for your review.
Please let us know if we should make a change to our process. If you would like us to escalate
these types of employers to you for review going forward, we certainly can.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
lrorn ""Chialastri, Taneka'" <[email protected]>

Cc !(b)(5) l<publicservice@ed gov>, "Battle, Cynthia" <Cynthia.Batlle@ed gov>, "Foss, Ian" <Ian [email protected]>, "Odom,
Christian" <[email protected]>
LJc1lH041061201709:54 AM
Suh Hci [external]American Legion - document request
Hi Kim,
FSAreceived an inquiry from the American Legion regarding a denial of their eligibility for PSLF.Could you
please provide us with details on the number of borrowers who have applied for PSLFwith the American
Legion listed as their qualifying employer (with ECFs),when the decisionsto deny were rendered,
research conducted by the BU or compliance, as well as and any letters of appeal received by FedLoan
from the organization or denied borrowers.
Also, did the Compliance Office review this employer and is there a reason why this employer, as a
501(c)(19),was not escalatedto FSAfor review?
Thanks,
Taneka
Office: 202-377-4390 I Cell 202-256-7842 I [email protected]
Code:PHEM
THE AMERICAN LEG ION

NATIONAL HEADQUARTERS
OFFICE OF THE
NATIONAL JUDGE ADVOCATE
P.O. BOX I 055 •
INDIANAPOLIS, IN 46206
February 10, 2017
Public Service Loan Forgiveness Supervisor

fi'edLoanServicing
PO Box 69184
Harrisburg, PA 17106-9184
Dear Sir or Madam:
The attached letter, with brochures, sels f01ih,in detail, the request to pa11icipate
in the Public Service Loan Forgiveness Program.
Since the formal request is so long and detailed, I have enclosed this shmt letter in
an effort to make communication easier.
If there are any-questions,please don't hesitate to contact me. My telephone

number is (317) 630-1225.
(b)(6)
THE AMERICAN LEGION

NATIONAL HEADQUARTERS
. OFFICE OF THE
NATIONAL JUDGE ADVOCATE
P.O. BOX I 055
INPIANAPOLIS, IN 46206
Februaiy 10, 2017
Public Servi<:eLoan Forgiveness Supervisor·

Fed.LoanServicing
PO !lox 69184
HmTisburg,PA 17106-9184
Dear Sir or Madam:
an Legion, a United
I am the National Judge Advocate (General Counsel) of The Americ
Code (36 U.S.C.
States Co~poration whose corporate chaJ.ter is part oft.he United States
§21701, et seq.).
file to use your

A number of employees of The American Legion have atlempted to
an Lcglon i.s a
services, but have been told they do not qualify because The Americ
"social club" and not a §50l(c)(J) charity under the IRS code.
ndent post<,(local
The American Legion j;; organized pltrsuant to its charter into indepe
ation. Under 36
chapters), departments (state organizations) and the national organiz
U.S.C. §21704 subse.ctions (4) and (5):
The corporation may-
I (4) establish State and territorialorganizationsand local chapter or post
organizations;
(5) provide guidance and leadership to organizationsand local chapte
rs
establishedunderparagraph (4), but may not control or otherw ise influen cethe
specific activities and conduct of such organizationsand local chapters;
entities. Without
As you can see, national, posts ai1d siale organizations arc independent
Legion have to
extra words such as "post" or "department," pie words The American
while some
refer to ihe national organization if used correctly as in this letter. Hence,
ations that run a
posts arc social clubs, the great majority arc patriotic service organiz
ents and the
· great number of charities and charitable programs along with the departm
rn Delaware and one·
national organization For example, I know two posts, one in southe
e centers for
in California that nm the local ambulance corps. Other posts run daycar
rofit hospital for
those who can't afford such commercial services. One post nw.s a nori~p
ations) give out a
its community. National, departments and posts (and subsidiary organiz
list of The American
large number of scholarships each year. Attached is the most recent
ly. Only 8,786 posts
Legion programs gathered from the Consolidated Post Report annuaJ
thus 1 cannot be
out of 13,043 posts actually report because they are independent and,
forced to do so. The numbers are impressive especially when you consider thai money
dedicated to a charitable purpose goes 100% to the charity.
Tnaddition, you should be aware that less than half of the Legion posts have post homes
(buildings they own or rent). The others are allsiwcd meeting space by the c_ounty, city,
town or village where located and are supported by other charitable entities. In addition,
the salaries paid by The American Legion to einployees are less than the going rate for
profit making corporations and government because of what we do. In addition, as noted
above, 100% of all donated funds go to the charity chosen by the donor.
TI1efour pillars of The American Legion are Children and Youth, Americanism, Veterans
Affairs and Rehabilitation and Veteran Employment and Education, Set forth below are
short descriptions of each pillar:
AMERlCANISM
As an organization dedicated to God and country v..'lth a membership of military vetcnms
that takes deep pride in the U.S. flag and all it represents, The American Legion has
always been a stalwart champjon of patriotism, morality and citizenship. Found within
The J\merican Legion's pillar of Americanism is devotion to law aI).dorder; raising,
educating and developing wholesome youth; respectful observance of American ideals
and traditions; law-abiding citizenship; and.fostering an aware and active citizenry.
Youth programs ofThc American Legion help our nation's youth reach their potential by
building physical, mental and moral alertness, cultivating strong character, and nurturing
civic responsibility and patriotism. American Legion Boys State is a practical hands-on
education program where high school students operate a mock government minored after
their ovrn actual local, county and state governments, while American Legion Boys
)ration is basecl upon the study U.S. federal government. Tue American Legion
Oratorical program allows high school youth opportunity to hone their public speaking
skills while at the same time learning about the Constitution of the United States, the
topic upon which they must speak. The American Legion Junior Shooting Sports
program allows individual youth and air-rifle teams to compete from throughout the
nation to develop physical and mental discipline to accurately hit a distant target. The
American Legion Youth Law Enforcement Cadet program provides practical hm1ds-on
insight into the operations oflaw enforcement by allowing high school youth opportunity
to "live the life" at their state police training academy for a week. The American Legion
is also extremely proud of its enc.luringrelationship with the Boy Scouts of America,
whom our organization has supported since our founding in 1919, rncognizing the mutual
values of God and country.
The American Legion encourages academic education by sponsoring scholarships and

school awards. Scholarships arc associated with youth programs of the organization and
The American Legion Legacy Scholarship aids children of fallen service members and
disabled veterans. Veterans volunteering in classrooms embody patriotism and American
values, with flag education being the most prominent classroom activity. Flag advocacy
has been a cornerstone of the organization since its founding, giving it a renowned
reputation as the foremost leading authority on the U.S. Flag.
2
CHILDREN AND YOUTH
The American Legion sponsors dril<lrenand youth programs that concentrate upon the
welfru:cof children, and troop and family support, by offering a hand-up where it may be
needed, imchas the Temporary financial Assistance program, in which non-repayable
cash grants help eligible service members and veterans bridge temporary financial
challenges they may be encountering in maintaining shelter or other basic needs for their
children. The Family Support Netv:ork rallies American Legion posts in local
communities to provide assistance and support to local families of service members who
are deployed on extended absences away from home by helping them with tasks such as
mowing the grass, car maintenance, home repairs, or child care. And while the care at
military hospitals and wanior transition units is exh·aordinary,The American Legion's
Operation Comfort Warriors program was created to provide "nonessentials" - those
comfort items that may help wounded warriors in their recovery but don't usually show
up as a budget hne on government spreadsheets.
Information providing greater overview and detail about programs found Withinthe·
Americanism m1dChildren & Youth pillars of 111cAmerican Legion may be acces.-:ed
on.lineat www.lcgion.org/publications.
VETERAN AFFAIRS AND llliHABILITATION VISION
"To care for him who shall have borne the battle mid/or his widow, and his orphan,"
March 41h,1865, PreSident Abraham Lincoln inhis inaugural address,
To ensme that all veterans have access to the complete range of services they have earned
through their honorable service, and to guarantee that the services they receive is of the
highest possible quality, delivered by public servants who honor and respect the veterans
who have guaranteed their right to live in a free and secure society.
VETERAN AFFAIRS AND REHABILITATION MISSION
To assist all veterans ll1need either personally, or through our nelwork of service officers,
departments, posts, stakeholders, federal partners, or any other available service that is
empowered to assist, and to support our Commission by follovt:ingour guiding
resolutions, our outline of authorizations, our bylaws, and our charter.
To maintain our level of expertise and professionalism through constant fef:dback, open
and honest commllnication, and ongoing professional training.
WHO WE SERVE
Legionnaires, all veterans and their families
3
OUR SERVICES
''v./eassist any veteran who wishes us to help with:
111 Access to high quality and timely healthcare through the VA
• Service connected disability claims and appeals

"' Coordination and organization of about a million volunteer hours per year at the
Departmeil.tof Veterans Affairs
I& Certification, training, and credential tracking of over 3,000 service officers per
year
® Access to combat veteran pensions for indigent veterans
«> Access to debt management services when resulting from VA overpayments
" Assistance with benefits decisions at discharge for transitioning service members
® Assistance with representation before Veteran Law Judges, Vetenm Law Courts,
Decision Review Officers located at Regional Offices
(I) As~istance and represenlalion before military Discharge Review Boards
e Assistance and Representation before Military Evaluation Boards and Physical
Evaluation Boards that determine military fitness and recommended levels of
benefits based on service connected it~uries
lil Assis~ance with the large variety of insurance and pension programs available to
veterans through the VA based on periods of.service
., Onsite representation and site visits at VA medical Centers and Regional Offices
around the country and abroad
• Assist veterans and their families viith mmtuary affairs provided by VA which
include burials, grave markers, plaques, certificates, and flags and final services
ADDITIONAL DUTIES
To assist and educate our members and Commission on the latest and most relevant
information regarding the large portfolio of services we offer. To ensure our members are
well informed and ptofessionally represented at the highest levels of government, in the
media/press, and just as vigorously at the lowest levels human interaction, and
everywhere in-between.
Members of this division interact with veterans and the public at all levels daily. It is
expected that they arc well informed, well mannered, well groomed, and well
spoken. Each word that falls froin the lips of a Veterans Affairn & Rehabilitation
employee reih:cts directly the voice ~d intent of the 2.2 million members ofT.he
American Legion, which is why each Veternns Affairs & Rehabilitation employee is
required to read every resolution that applies to this division during their initial
orientalion.
In addition to oversight of the 3,000 service officer certifications, we host two resident
training courses per year that teach and refresh expertise in a range of advanced skills for
claims processers. The director also oversees and manages a contractual relationship with
the National Veterans Legal Services Program, the foremost authority in veteran's law in
the nation. This is a multifaceted half-mnlion dollar per year relationship and the
4
services range from training to legal representation of our veteran claimants, to amicus
and Supreme Court briefs written and submitted on behalf of The American Legion.
\Vhile our duties include direct veteran representation, we also conduct first person
surveys, evaluate policy as it relates to veteran law, participate in congtessional research
and professional testimony, attend professional briefings, seminars, workgroups, and
similar types of sessions at both the national as well as the local level as needed. We
conduct VA medical center visits and analyze the center's strengths and weaknesses, and
do the same for the VA regional offices 1.hatprocess claims and healthcare access
applications. ·
We operate a 20 person appellate unit that reviews denied claims and writes legal briefs
on behalf of veteran claimants seeking to increase their service connected disability
rating, and when necessary, argues their case before a Veteran Law Judge. Our unit
processes an average of250 claims per week.
Finally, the staff of the V A&R division supports the.Commission m1<lcommittees of the
division administratively at all meetings and gatherings of The Amcricm1 J,egion, which
incllldes National Executive Committee meetings, Washington Conference, anrl National
Convention.
The Veterans Employment and Education Division provides the following services:
EDUCATION
The American Legion conducts multiple national veterans' education symposiums, and
comm1micates with student veterans, campus coordinators, VA leadership and school
officials on a continuous basis to ensure that colleges and universities are providing
adequale educational support for those who served.
CAREERS
The American Legion actively helps 20,000 to 25,000.military personnel and veterans
find rewmding jobs and business opportunities per year iJ1civilian life. At least 100 plus
Job Fairs per year, 3 plus per year resumc-\vriting workshops and online tools for
veterans are just some of the ways in which The American Legion Employment and
Education Commission helps those who s~rvcd to malce_career transitions. The American
Legion has been cited as one of the top resources for veterans looking for work by
Veterm1 Talent Index.
BUSINESS
The American Legion's Business Task Force is a group of highly successful veteran
entrepreneurs and corporate executive who offer their expertise to help other veterans
succeed in business. The task force mentors veterans and conciuctcd 7 training
workshops around the country in 2016. It has also held licensiug and certification round
tables with over 60 for profit, not for profit and governmental entities participating.
5
HOVIELESS
The American Legion has worked shoulder-to-shoulder with state and federal agencies
and other nonprofit organizations· to reduce veteran homelesfmess across the United
States. American Legion posts, districts and departments support or provide activities
aTJdservices to homeless veterans such as health care, housing mid employment
opportunities.
In addition, The American Legion must have Finance, Membership, Internal Affairs,
Human Resources, and IT Divisions to be able to operate. it also has the usual Public
Relations, Magazine, Meeting and Planning sections to per.fmm these functions as well as
a legislative Division to handle The American Legion's relations \Viththe United States
Congress and support legislation for veterans where needed. The American Legion does
NOT support candidates for office. See the Charter of The American Legion, National
Constitution and By-laws attached hereto _including 36 "C.S.C.§21706 and National
Constitution Article II, Section 2.
The American Legion is a section 501(c)(19) organization because that is the section
provided in the United States Code for veterans organizations. In addition, because The
American Legion qualifies as a war time veterar,s organization under 26 U.S,C.
§l 70(c)(3) of the Internal Revenue Code, it has the same slatus as a charity in that donors
may deduct their donations to The American Legion from the donor's United States
income-taxes on their tax return. This means The American Legion, in addition, has the
~m~oo~m '
The American Legion also has a §501(e)(3) charity as a subsidiary, American Legion
Charities, Inc., because it is much easier to convince some la\\'Yers to donate to it rather
than a §501 (c)(l9) corporation which qualifies under 26 U.S.C. §I 70(c)(J). The funds,
thanks to 26 U.S.C. §170(c)(3), can be freely transferred to The American Legion
National Headquarters and its departments and posts. Hence, it is crystal clear that The
American Legion has all the rights of a charity.
Attached are pamphlets and other documents that provide more detail about American.
Legion programs. They are:
• A booklet containing the Charter of The American Legion and the National
Constitution and By-laws
• Unifonn Code of Procedure for the Organization of National Conventions of The
American Legion
• Rules of the National Executive Committee of The American Legion
• The American Legion Assists Families of Active Duty Troops·
• A pamphlet on The American Legion Action Programs of Americanism
• l\. pamphlet on The American Legion Children & Youth Programs
• A pamphlet on the National Emergency Fund
• A pamphlet on Disaster Preparedness and Response
• The Consolidated Post Report-
• IRS Pom1 990 for 2015
• Did You Know? Sheet
6
(iii American Legion cited as a top resource for job seekers

111 A pamphlet on Po.st-Traumatic Stress Disorder
• Post Service Officer Guide
Ql A pamphlet on ·what to Do Before a Veteran Dies
s A pamphlet on Agent Orange Benefits & Programs
e Veterans Affairs Voluntary Service Handbook
Since:.rel:lP."",
,.
(b)(6)
National Judge Advocate
Cc: Daniel S. Wheeler, National Adjutant

Jeffrey 0., Brown, Executive Director
Verna Jones, Executive :pirector
7
7/?8/16 8.08.05 AJ\'.EF:.121>1~::.,EGI:J'" NA'LONJ\_L HEJI..DQTJA?-.TE?i.S
CPR022R2 Ps1ye l
Cunsolidated ?ost Report Sur:ur.a.u:-y
Fo~: ALL DEPARTMEKTS
National ~otals
::.,ine Tt.e:n/Desc Cc11-.t.s/Amcu::Ls L:ne 1 t.err./Jcc;<.:
( 4; F:.na::_ 20E Membership Cuunts/Amounts
l,225,63S (63) O;,:-a~orical Con::ests . -- _,l~O
( 7) CaSRC HanClcd by P88 149,216 (64) # Oratcr.'ca:-.. Youl.:hs
( 8) Emergency Aid 7,239
3,031,567 (6S) Ordtc.,rical Costs 31:,056
( 9) Volunteer Huu:cs 80"/, 786 (66) Schoo::_ Awc1rd Proo:::ol.rr.
(10) ::"ontributions tn VA H 2,523
:., 779,043 (67) School ~edals Awa:::ded 25,650
(11) VAVS Coorc.inator 1,260 (68) Ed:.:.cation Week.
(12) No. o:: VAVS Vo'..unteers 808
3S,250 (69) Jc/ Schools Assisted 4,909
(13) Blood Dcnor Pi~ts Donated 75, 39'.' {70J AsA:is"'.:ance Costs 915,556
(14) Number cf Donors from Post 45, t,r;R ('Ill No. uf Scholarships 8,259
(15) ROTC Medals Presented B,3Be (72) scrolarshiu Costs 11,?74,643
(16) Energy Cha.irrerson 461 (731 Ed.1c ...::ion irours 156,717
(17) Crime Prevention/Law and Ordec Prog 78E (74) Additional Ed. Ami.: 358,031
( 18) Fi re Preventior. Program 906 (75) Vets in ;::he c:.assroc:n 93S
(19) Homeland Security/Disaster Relie= 57:_ (76) Local Flag I'Lesentations 2 9, 960
(20) POW/ML>; c:iai:cperson 1, 9'>4 (77) Local Flag Presentation Costs 283,)53
(21) Fo:::-eign Relations Com:nittee Chairpe 332 (78) FL.i.g Day 4,313
(22) Post PR C'1.airman/Cfficer 3,162 (79) Get out the Vote ·1, ':-131
(23) Pnst Pi.:blications 2,593 (80) v,.,terans Day 6, 926
(24) Post l~ebsi te 2,613 (81) Memorial Day 7' ?~",
(2'i) # Annual com11.w1ity Events 38,677 (82) July 4th 4,390
(26) 9/11 Com:nunity Event 1,548 (83) Legion Birthday 3, ~17
(27) f<adio Ccverag'-' 46,227 (84) 4 Chaplains Sunday 1,455
(28) TV coverage 10,02.:: (85) Hou:::s Corom,mity Service 4,046,f,8/.
(~9) Cable Access TV 28,22S (86) Cost of Comrr.UI'.ity Servicl"l 3,399,C77
(30) Newspaper:star:es) 45,019 (87) # Yrn,':".hs in Jr. Shooting Club 6, ~91
(31) Newspay<cr:ltr to edi:::or) 8,68~ (88) Jr. Shooting Club Cos::s 284,:.SO
(32) Color Guard 4, 79:._ (89) # ;J:::. Shooting Clu;.ls 7., 4 '/8
(33) Firing Squad 4,116 (90) -:';,rticipates in OCW 628
(34) No. o= ;.'nneral Honors 122,068 (91) -::>articipatcs ;n Jr. Law Cadets 3S1
(3':i) Uniformed Crou1,> Cost 2,691,883 (92) Jr. Law Cadet FYouths 9,103
(3G) Employment Cha:rman 60'.._ (93) No. C & Y ActiviLi~s l 7, /.0 3
(37) Homeless Vets Chairperson 968 (94) Cash Aid to C & Y 2,421,816
(38) Post part:cipates in C.;i.rra,er Fairs l, 059 (95) Value of Goods C & Y ~,589,916
(39) LVER/DVOP reference 5,358 (9G) # C & Y Aided 183,867
( r, 0 l Placed .in E:nployment 3,295 (97) # Vul. Hours for C & Y 442,495
(41) .::-ob Train:ncr Plact"lment l, 218 (98) Halloween Safety l, lS',
( r, /.) Pro:noLe Programs (99) Fam.ily Support Network
(,;,)) Homeless
(.r,_,J) ~:mploy'c'r
Vets Outrear.h
of D.isabl'-'J
'"
73
16S
9 (100)
(1 07)
# of Families
H.eal::h &. Chi_d
Ass.uited
Safety
814
25,855
800
(45) Er:iployer of Older Workf>rs
(46) Er:ipl_ SuLvice LVER '"
20S
(102)
(103)
April
N,:iLiuual
is C&Y Monte
Fam:'_ly Week
651
(47)
(48)
EDpl.
Enpl_
Service
Service
DV:JP
Local Office
383
lH
(104)
(105)
Temporary
Adminis:::::-a:::ive
Fi~ancial
Costs
Asst '°'
55'i
641,212
(49; Enployers cf Veterans (large) se (106) Par~-Y and Gifl Costs 1,328,? ✓.6
(so; EDployers cf ve::erans (rr.e6..} ·11 (107) A:l Othe::: ~=enses 2,682,628
(51; Enrloyers of Veterans (smell) 2'4 (108) F'c1mi ly Suppo1'.·t Ketwork 1 9·1, ':: 34
(5~) Boys Slate# Sponsored 1·1, 029 (109) Tumporary Fic,ancial Ass':: 529,560
(53: Koy:c; State Cosls 3,768,807 ·17 o; Legion ':,ndowment Fund 106,854
(54) Legion Legacy Scholarship Amount :._,;;M3,1·1:, 111; Children's Hospital 133,929
(55} Ci'::izenship/l'<atu-::-alization A<.:tiviti 30C 112; Total Other Choi.rities -l,",El,~61
(56} Legion 3aseball l,96E 113; Anerican Legion Riden; Grou:., l, '334
(c,·1 J,e.gion 3ascbiJ.ll Cu:at 5,571,530 ·114; /I Lcg.iorc Family Merrbe:::s 38,139
(58 Non-Leg:on Baseball l, 468 l15) Nationa~ Emerge:-.cy F·Jnd 489,696
(S9 Teams Coc.t :._,424,529 116; Si:pport OuL Troops - cost to post 1,011~,517
(60 Scout Q:'.'_its 2,012 117} Si.:pport Our Troops - vo1ur,teer Ju,; 512,114
( 61 ;! YoU:hs in Scouting 44,482 118} St:.ppnrt. Our Troops ;i volunteers 39,591
(62 Scoutins Costs l,738,831 J_l9} All Other Fund Raisi:-.g no:: on form 7,262,429
ToL.:i.l Numb<c:c cf: Report:ng Posts 8,786
"'' 8879-E0 IRS e-file Signature Authorization OMfl Nn. 1545-1673

for an Exempt Organization
Forcalenc'aryear2015,or 1Iscalyearbegioolrlg , 2015,ander.ding , 20
Departmentol 1h&T~asu,y ► Oo not sond lo tho IR6. Keep for your reGords.
lnle;n.olRoeanueSe:vlc~ ► lnfonniltlon about Form 8879-EO and Its lm~tructlons Is at www.Jrs.gov/form887fJeo.
NameoJexemptor9anlua\loo Employorldontilication number
THE AMERICANLEG,ON 35--0144250
NamDand tlUeof officer
GEORGI: 1'.. BUSKIRK. JR., NATIONAL T~EASURER
IRfflilT}/p€-ofReturn and Return lnformatlon (WholeDollarsOnly)
Check !ha box for the return 1or which you are using lhls Form B879-EO and enter the applicable amount, if any, frorn the rnlurn. Ii yoJ
check 1he box en line 1a, 2a, la, 4a, or 5a, below, and the amount on that line for the return being fifed with this form was blank, then
ieave line 1 b, 2b, 3b, 41,, or 5b, whichever is ,1pplicable, blank (do not enter -0-). But, if you entered -0- or the retum, then enter -0- on
the applicable line below, Do not complete more than 1 llna In Part I.
1 a Form 990 clwck,here ► 0 b Total revenue, if any (Form 990, Part VIII, column (A), llne 12) 1b 72,257,030
2a -=orm930-EZ er.eek here ► D
b Total revenue, if any (Form 990-EZ, line 9). 2b
3a fo:m 1120-P0L check here ► D
4a form 990-f'F check here ► 0
b Total tax (Form 1120-POL, line 22)
b Tex based on investment income (Form 990-PF, PartVf, line 5) "------
4b
Sa form 88GB check here ► D b Balance Duo [Form 8868, Part I, line 3c or Part II, llns 8c) Ob
jifjljl Declaration and Signature Authorization of Officer

Under penalties of perjury, I declare that 1 am an officsr cf-the above organiiatfon and Urnt J hoM;1examined a co~y of the
L>ri;aniz<1tion's2015 electronic return and accompanying schedules and statements and to the best of my knowledge and belief, they
a-e true, correct, and complete. I further declare tli1:t the an,ount in Part I above is the amount shown on the copy of the
organization's electr::inlc return. I consent to allow my intermediate service provider, transmitter, or electronic reltjm originator (ERO)
to send the organization's reti..lrn to the IRS and to receive from the IRS {a) an aclmow!edgernent of receipt or reason for rejection of
:he transmission, (b) the reason for any delay in processing !he return or refund, and (c) the date of any refund. Jf applicable, I
authorize :he U.S. Treasury-and Its designated Financial Agent to initiate an electronic funds withdrawal {direot dobi'.) cr-.tryto the
ftnancial insUution account indicated in the tax preparation software for payment of the organization's federal taxes owed on this
rnit.:rn, anc' the financial institution to debit the entry to tllis account. To revoke a payment, 1 must contact the U.S. Treasury Financial
Agent at 1-688-353-4537 no later than 2 business days prior to the payment (settlement) date. I also authorize the financial Institutions
involved in the processing of the electronic payment of taxes ta receive confidential Information necessary to answer inquiries and
resolve isst.:es n,lated to the payment. I have selected a personal identification number (PIN) as my signature for thu organization's
e/ectrunic return and, if applicable, the organization's consent to electronic funds withdrawal,
Officer's PIN: check one box only
Er authorize CROWE HORWATH LLP to enter my PIN I4 j 4 j 2 [ 6 I O I mi my signature
!'.RO firm name Enter fiv~ numbers, bl/I
do not~nler all zeros
on the organizatio.1's tax year 2015 electronically filed re1urn.If t have indicated within this return that a copy of lhe return is
being liled w.'th a state agency(les) regulating charities as part of the IRS Fed/State program, I also authorize ths afonlmentioned
ERO lo ~nter my PIN on \he return's disclosure consent screen.
OAsanofficeroftheo anlza I will enter m PIN as r.i signature on the organization's tax year 2015 electronically filed return.
It I have irJdlcat (b)(6) is ?elng filed with a state agency(les) requlatlng charities as part of _',,"t',;1j'::,c·i<_r"':s-!:';
ihe IRS Fed/Sta 's c1scbsur1.>con:.erit semen. •ii,:·M:m :5/"i.
Dal~ ► / :Z •
..:_$""', -?k,'. ,;;:;~
Certifio
EHO's EFIN/PIN. Enter your six-digit electr
number (EFIN)followed by yourfive-digit
filing identificalion
sell-selected PIN. 1,1,1,1,1,1,1,1,1,1,1°1
do 110!enter all zeros
I certify that the abov!;l numerio entry i:; my PIN, whioh i~ my signature on lhe 2015 electrcnlcally flied retur1 for the organization
indicated above. I confirm that I am submitting this return in accordance with the requirements al Pub. 4163, Modernizea e-Hle (MeF)
lnform<ltion /or Aiithorized IRS a-file Providers for Business Returns,
EAO's s;gnalure ► Pate ► ______________ _
ERO Mus1 Retain This Form-See Instructions

Do Not Submit This Form To the IRS Unless Req\Jasted To Do So
For P~perwork Reduction Act Notice, see hack of form. Cat. No. ~7169W Form 8879-EO 12015)
5/12/2016 2:11:01 PM 2015 Return The Arieriun Legiori

35-0144250
PUBLIC DISCLOSURE COPY

coo 990 Return of Organization Exempt From Income Tax
0MB No. 104~•0()47
Und11rsection 601(c), 527, or 4947(a)(1) l)f the Internal Revenue Code (except privatQ foundalione)
► Do m,t enter social security numbers on this form as It may be made public.
Oepartrn,ntof the TreaSUI'/
lntoroalFlever.usSsrv,oe ► Information about form 990 and its Instructions Is at www./r&. av/form'990,
A for the 2016 calendar ear or tax ear be )nnln 2016 and ondin
8 Check II applicable: C Name of organization THE AMERICAN LEGION o Emplo~r lderi11rftat;onnumbw
0 Address chor1ge Doing busiMasae THE AMERICANLEGION NATIONAL HEADQUARTERS 35-014425C
0 Name oan~e Number and alreol (0< P.O. ~ox i' mail is ml delisered lo alree\ address) Room/suite E Telephone numbsr
0 lnillalr~turn PO BOX 1055 (317) 630-1229
loc==='===--=======,-----~--------'1---===~--
[_j fl,al reium.'l<lrniin,ted City or town, stalP- or prc,v"1ne. 0<1<1ntry,
and 71P 01 fore ·on poallll coll>
LJ Amondod rotu'll INDIANAPOLIS, IN 46206 G Gross n,coipls $ 131,465,620
D Applicali<ln p9ndlng F Name and address of prinrnpal office,; HAROLD D. BA~NETT H(a)lslh ,agroupielum lorsuboidlna'e>lO'la5 @ No
-c-----~"SA"'iMCEcAcS~CCACBCOCVCE~=~~-~---~-=----~~--"tllb)Ntall•UbOldin1teslncluoed?OYn □ No
I Tax-mc<>mptstatus: 0 501(c)[J] 0 50i fc)( 19 ) ◄ fln•~ri no,) D 4~a)jl 0, D 527 If "No.' altach a list. [Ha lnslructions)
J Wabslt~: ► WWL/11.U:GION.ORG H(c)Groupexampticnnumbar II>
K Form of 01Janizaticn; " Oori)oralionO Trust D AHociatlo,1 0 0lhar ► L Yaarof formation: 1919 M Slate of legal dumicile, IN
Summary
1 Briefly describe the organization's mission or most slgnlf:ce.nt activltlas: AS THE NATION'S LARGEST WAR-IME
•
0 VETERANS SERVICE ORGANIZATION, THE FFDf'RAl.l.Y CHARTERED /\MERIC/\N LEGION IS COMMllTt'l>TO LIFELONG
"1 {CONTINUED ON SCHEDULE 0)
i0 2 Check thie box ► D if the organization discontinued Its operations or disposed of more than 2b% of its net as:;c!\s.
0 3 Number of voling members otthe governing body (Part VI, Hna 1a) . 3 61
•" 4 Number of independent voting members of the governing body (Part VI, line 1b)
Total numbor of individuals employed in calendar year 2015 (Part V, line 2a)
4 ,a
~, 5 5 327
•
0
<
6
7a
fotal number of volunteers (estimate If necessary)
To:aJunrelated businsss revenue from Part VIII, column (C),line 12
6 <ill
10.156,036 ,,
- -·--b Net unrelated business taXl:lble income from Form 990-T, line 34 7b 0
Prior Yo~r CurrontYoa,
8 Conlr'ibutlons and grants (Part VIII, line 1h}. 7,802,967 11,947,990
I
" 9 Program service revenus (Part VIII, line 2g) 36,905,609·'
-- -----------
~ 10 lnvestT1ent Ir.come (Part VIII, column (A), lines 3, 4, and 7d)
e-------~1?6-2"4731-----c'"·'c"c'"-'c'c'
C 11 Other revenui, (Part VIII, column (A), lines 5, 6d, Sc, 9c, 10c.:,o1nd11 ej 21.411,653 21,772,393
12 Total revenue-add Hnes8 lhrough 11 (must equal Part VIII, □ oliimn (Al, line 12) 68,462.702 72,2!i7,030
13 Grants and similar amounts paid (Part IX, column {A), lines 1-3) . 1,366.792 1,535,975
14 9enefits paid to or for members (Part IX, columi:t (A),line 4)
" 15 Salaries, other compensation, employee benefits (Part JX,column (A), lines !i-10) 19,323,425 19,790,93D
i Professional fundraising fees (Parl IX, column {A), line 11e)
l ,."'
7,036,638 193,444
b Total fundraising expenses (Part IX, c:;lumn (D), lirie25} ► 0
17 Other expenses (Part IX, column (A), lines 11a-11d, 11f-24e) 38,199,031 52,113.276
Total expenses. Add ,lines 13-17 {must equal Part IX, column (A), line 25) 65,925,886 73,633,625
19 Revenue less expenses. Subtract line 18 from line 12 (1,376.5!!5)
15 8 Boslnn"19 of Curra~1 Y~ar End or Year
~·
{!Jj 20
.;'S 21
z~ 22
Total assets (Part X, l!ne 1S)
Tot.:;1liabllltie:. (P.irt X. line 26)
Net assets or fund balances. Subtract !lne 21 from line 20
[il.DI(-c-=S~lg~n=•t=u~r•~B=lo=c=k--,----~~--~-----------------
112,764,8ti4
88,320.225
24,444,82\l
114,410,454
93,542,005
20,368,449
under penlllt1ea of parJ<.rf, I dedave that I l,uve examined this roturn, Including axompanym9 sc~ed~les and stalarneots, Bnd to the bM1 of my mowieclge aoo bel al, 1tm
tn.,e, carrect, a~d completa. Declarallonofp:eparer (Dlhor th,anolllccr) ls boscd on all lnf9rmatlon o1 which preparer hu any know:edge.
Sign
Here ►► Ei<:i~~tureor officer
GEORGE A. BUSKIRK, JR., NATIONAL TREASURER
TypH ur prii\l rmm~@d tllle
Data
Print/Type propumr's noma Data PTIN

Paid ? (b)(6) Che~k O if
RACHEL SPU~LOCK S/l)/n16 self-arrployed P00520729
Preparer
!
Firm'snama ► CROWE HORWA'fH LLP Ffrm'sFIN "" 35-0921660
Use Only
Finn's ~ddraei ► 3615 RIVER CROSSJNG PAm<WA", SUITI:
0,"? 0,0300, INDIANAPOLIS, IN 46240-0977 Phona 1c,
0o0s')==~,==cc=""~'----=~0Yos (317) 569-8989
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For P~perwork Reduction Act Not!ce, sa,;1the separate lm;;ln.1cti<;1ns, Ca1.No.11282Y Furrn990 (2015) i
5112/2016 2;03:50 PM 2015 Raturn The American L~glon

35-0·144250
I
Page 2
CEii1llJStatement of Program Service Accomplishments
Check if Schedule O contains a response or note to any li_ne)_nthis Part Ill------
Briefly descrlbo the organization's mission:
AS THE NATION'S LARGEST WARTIME VETERANS SERVICE ORGANIZATION, THE fEDERALLY CHARTERED AMERICAN
LEGION IS COMMITTED TO LIFELONG ASSISTANCE AND SUPPORT FOR MEN AND WOMEN WHO HAVE SERVEC IN THE U.S.
ARMED FORCES, SIGNIFICANT ACTIVITIES OF WHICH INCLUDE FREE BENEFITS COUNSELING, EDUCATION Al\'D CAREER
(SEE STATEMENT)
2 Did the organlzatlnn undertake any significant program services during the year which wera not listed on the
prior Form 990 or 990-EZ? O Yes 0 No
If "Yes," describe these new services on Schedule 0.
3 Did the organization cease conducting, or make significant changes in how II conducts, any program
serv'css? □ Yes [!:]No
If "Yes," describe these changes on Schedule 0.
4 Describe the organization's program service accomplishments for each of its three largest program services, as measured by
expenses. Section 501(1,;)(3)u111J
0:01(c)(4)org.-nl,;aliorn, <>rernqulred to report Hl6 amount or gran!s and allol'~tions to 0H1sirs,
the total expenses, and revenue, if any, for each program ioervice reported.
4a (Cede: ) {Expenses$ Including grants of$ ) (RevenLe $

MEMBER MAGAZINES AND NEWSLETTERS: THE AMERICAN LEGION MAGAZINE EXISTS TO PUBLISH PROFESSIONALLY
'i'/RITTEN, ACC'JRATG AND RELEVANTARTICLES THAT PROMOTE THE GROWTH or AMERICAN LEGION PROGRAMS, THE
ATTAINMENT ANO UNDERSTANDING 01' AMEHICAN LEGION POLICY OBJECTIVES ANDA 8ENSE 01' t,;SPRIT DE CORPS AND
PRIDE IN BEING A VETERAN AND MEMBER OF THE AMERICAN LEGION.
4b (Code; ) (Expenaes $ including grants of$ ) (Revenue $

ONE PUR?OtiE OF THI: AMEKICAN LEGION NATIONAL HEADQUARTERS IS TO CONTRIBUTE TO AMERICANISM, VETERAN'S
AF=AIRS, CHILD:1EN. AND YOUTH PROGRAMS. VARIOUS COMMITTEES AND COMMISSIONS ARE ORGANIZED TO PROVIDE
PROGRAMS IN lHESE AREAS. YOUTH PROGRAMS /\Vl\lLABLE TO THE PUBLIC INCLUDE A NATIONWIDE BASEBALL
PROGRAM; THE EDUCATIONAL PROGRAM CALLED BOYS NATION WHERE PARTICIPANTS LEARN ABOUT THE FEDERAL
GOVERNMENT THROUGH INTENSE WORKSHOPS; SUPPORT FOR THE BOY SCOUTS OF AMERICA TO BUILD CHARACTER AN'.'.l
POSITIV!: ·1MITS AMONG THE YOUTH OF AMERICA; ANO THE JUNIOR SHOOTING SPORTS PROGRAM THAT TEACHES
MARKSMANSHIP AND HOSTS COMPETITIONS.
--- ---- ------------· ---~ -·--- ----- -------- --·

<le (Code: ) (Expanses $ including grants of$ ) (Revenue$
TIIE AMl:RICAN LEGION NATIONAL HEADQUARTERS PROVIDES SCHOLARSHIPS AND OTI-IER FINANCIAL ASSISTANCE TO
VETERANS, !Jicl-'ENl.:ENTS OF VETERANS, ANDPARTICIPANTS IN VARIOUS YOUTH PROGRAMS. IHE OHGANILArlON IS
RAISING fUNDS TO ENSURI: THAT HIGl-,rn rnucATJON WILL BEA RE:ALITY FOR THESE FAMILIES. PROVIDING FOR
THF. CMILDREN OUR MILITARY PERSONNEL LEFT BEHIND IS OUR CIVIC DUTY. AN EDUCATION IS/>. POWERFUL WAY TO
SHOW OUR THANI\S,
4d Other program services (Describe In Schedule O.)

(Expenses$ Including grants of$ ) (Revem.:e$
4a Total program service expenses ► · 0
Fof'r1 990 (2015)
5/12120162:03:SO PM 2 2015 Return The American Le!)lon
35-0144250
Fmm 990 j2015) Page3
/! "Ye.s,"
1 Is the organization described
complete Schcdu!o I\ .
in section OO!(c)(3) or 4947(a)(1) (other than a private tound.ilion)?
.,
2 Is the orgarilzatlon required to complete Schedule 8, Schadu/a of Contributors {see instructions)? 2 v'
3 Did the organization engage in direct or Indirect political campaign activities on behalf of or In opposition to
cnndidates for puLilio office? If "Yes," complete Schedr.i/e C, /'art I 3 v'
4 Sectkm 501(o)l3) org1;mi.::ation:., Did U1eorg1:rnl.:atlon engage in lobbying activities, or have a stJctio11001(h)
election in effect during the tax year'l ff "Yes," complete Sohedufo C, Part JI . 4
t----t---t--
5 Is the organization a section 501(c)(4), 501(c)(5), or 501(c)(6) organization that receives r.,embershlp dues,
assessments, or slmllar amounts as defined in Revenue Procedure 98-19? ff "Yes," complete Sohedufe C,
Part II! 5 v'
6 Did the organization maintain any donor adv:sed lunds or any similar funds or accoLJnts for which donors
have the right to provide advice on the distribution ur investment ct amounts in such funds or accounts? If
"Yes," complete Schedule D, Part I 6
7 Did the organization recoivo or hold a conservation eaOOfl;ent, lnoluding easements to preserve open space,
f--"-+-+--
the environment, nistoric land areas, or historic structures? If "Yos," complete Schedule D, Part II 7
.,
8 Did tho organization maintain collections of works of art, historical treasures, or other similar assets?
campf&re Schedule D, Part Ill
If "Yes,"
8
.,
9 Did the organization report an amount in Part X, line 21, for escrow or custodial account liability, serve as a
custodian for amounts not listed in Part X; or provide credit counsellng, debt manegement, credit repair, or
debt negotiation services? If "Yes," complete Schedu/o D, Part JV ,
:
9
.,
10 Did the organization, directly or through a rolatod organiz.1tion, hold o1ssots fn ti,mp<;irarily restricti,d
endowments, permanent endowments, or c_uasi-endowrnents? If "Yes,~complete Sc,~edule D, Part V 10
.,
11 If the organization's answer to any of the following questions Is "Yes," then complete Schedule D, Parts YI.
VII, VIII, IX, or X as applicable.
a Did the organization report an amount for land, buildings, and equipment In Part X, line 10? If ·'Yes,"
complete Schedule D, Part VI 11, .,
b Die the organi.a.ation report an amount for investments-other securities in Part X, line 12 H:at is 5% or more
of its total ai,sets reported in Part X, line 16? If "Yes," complete Schedule D, Part VII 11b
.,
c Did the organization roport o1namount for investments-program r·elated 111
Part X, line 13 that is 5% or more
of Its total assets reported in Part X, line 16? If "Yee," complete Schedule D, Part VIII 11', ,,
---
.,--
d Did the organization report an amount for other assets in Part X, line 15 that is 5% or more of [ts total assets
v
reported in Part X, line 16? If "Yes," complete Schedule D, PartiX
e Did tho organization report an amount for other liabilities in Part X, lino 25? If "Yes,"completeScnedule0, PartX
11d
11, .,
f Did the organization's separate or consolidated flnanoial statements for the tax year include a footnote that addrcssl!S
the organization's liability for .uncertain tax positions under FIN48 (ASC740)?If "Yes," complete Schedule 0, PartX 111
., -~
12 a Did :he organization obtain separate, Independent audited financial s\atemen\:; for \h~ tax ye;,(! If "Ye.s," comp/eta
Schedule D, Parts XI and XII 12, .,
b Was the organization Included In consolldated, fndependent audited iinancial statements for the lax year? If
llYes," and If the organizationanswered"No" to /!ne 12a, then comp/,;;tingSchadu/s D, Paris XI E1ndXII Is optional 12b
.,
v
i3 If "Yes," complete Schedule E
Is tho orgom[zation a school doscribod in section 170{b)[1)(A}(ii)?
14 a Did the organization n1aintaln an office, employees, or agents outside of Iha United States? 14'
13
.,
b Did tile organization have aggregate revenues or expenses of more than $10,000 from grantmalli11g,
fundraising, business, in11ostment, and program sorvico activities outside \he Uni!ed States, or aggregate
foreign investments valued at $100,000 or more? fr "Yes," compJete Schedule F, Parts I and JV. 14b
~· ,
.,
15 Ilk: the organization report on Part IX, column (A), line 3, more than $5,000 of grants or other asslstanco 1n or
for eny fa reign organizat!on? If DYes," complete Schedule F, Parts II and {V
-
15 v
16 Did the organization report on Part IX, column (A), line 3, more than $5,0CO of aggregate grants or o1her
assistanco to or for foreign individuals? If "Yc1s,"complete Schedule F, Parts Ill end IV. 16
.,
17 Did the organizatian report a total of more than $15,000 of expenses for prof=ional fundralslng services on
Part IX, column (A),lines 6 and 11 e? If "Yes," complete Schedule G, Part I (sea Instructions) 17
.,
18 Did the organization report more than $15,000 total of fundraislng event gross inc;orne and conlrlbutions
Par: VIII, lines 1 o and 8a? If MYes,~ complete Schedi.J/e G, Pert II •
on
16
.,
Did the organi.:ation report more than $15,000 of gfoss income from gaming activities on Part VIII, line 9a'?
19
If "Vos," complete Schedule G, Part Ill . 19
.,
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35.0144250
- Page4
- Checklist of Reql.lired Schedules rcontinuedJ
,.,
20, Did the organizationoperate one or more hospital facll!tles?If ''Yes,"complt!le Schedule H . 20, .,"'
b If "Yes" to line 20a, did the organization attach a copy of !Is audited financial statements to this return? 20b
21 Did the organization report more than $5,000 of grants or other assistance to any domestic organl7alion or
domestic govsrnment on Part IX, colL-mn {A), line 1? If "Yes," complete Schedule I, Parts I and II 21 .,
22 Did lhe organization report more lhan SS,000 of grants or other assistance to or for domestic individuals on
Part IX, column (A), line 2? If "Yes," complete Schedule 1, Perts I and Ill 22 .,
2J Did !he organization answer "Yes" to Part VII. Section A. line 3, 4, or 5 about compensation of tho
crgcmlzation's current and former officers, directcrs, trustees, key employees, and highest compensated
employaes? If "Yes,~compioto Schvdu/o J. 23
.,
"' Did the organization have a tax-exempt bond Issue with an outstanding principal amount of more than
$1 0U,000as of the last day of the year, ·that was Issued after December 31, 2002? If "Yes," answer .linesJ4b
.,
through 24d and complete Schedule K. If "No," go to fine 25a 24,
b Did the organil'.atlon invest any proceeds of tax-exempt bonds beyond a temporary period exception? 24b
Did the organization maintain an escrow account othsr than a rsfunding escrow a: any ti.11e during the year
' to defease any tax-exempt bonds? 24,
d Did the orgar,i;.ation act as an "on behalf of' Issuer for bone's outstanding a1 any t,me during the year? 24d
25a Section 501(c)(3), 501(c){4), and 501(c){29) organizations. Did the organization engage in an excess benefit
transaction with a disqualified person dL..rlngthe year? If "Yes," complete Schedule L, Part.I 25a
b Is the organization awa,e that It engaged In an excess benefit transaction with a disqualiiied person in a prior
year, and Hi.it the lr11ns.iction has not been reported on any of the organization's prior rorrr.s 990 or 990-F.7?
If"Yes," complete Schedule L, Pan r 25b
26 Did the organization report any amount on Part X, line 5, 6, or :,;:, for receivables irom or payables to t1ny
current ur former officers, directors, trustees, key employees, highest compensated employees, or
disqualified persons? If "Ye:.," complete Schsdu/e L, Ptirt II
27 Did \he organization provide a grant or other assistance to an officer, director, trustee, key employee,
26
"
substantial contributor or employee therl3of, a grant selection committee member, or to a 35% controlled
entity or family member of any of these persons? If "Yes,'' complete Schedule L, Part If/ 27
.,
28 Was the organization a party to a business transaction with one of the followlng pa11ies {see Schedule L,
Part IV instructions for applicable filing thresholds, conditions, .ind exceptions):
a A u~m;nt er former officer, director, trustee, or ke\remployee? If "Yes," complete Schedule L, Part IV- 28i:I .,
b A family member of a cL<rrent or former officer, director, trustee, or key employee? If "Yes," complete
Schedt1/e L, Part IV 26b .,
An entity of which a current or fumwr offi::er, diractor, trustee, or key employee (or a famlly member tharnof)
' was an officer, director, trustee, or direct or lnolrect owner? If "Yes," complete Schedule L, Part IV .,
29 receive more than $25,000 In non-cash contributions? If "Yes," complete Schedule M
Did the urg<mi~1otio11
28,
29 .,
--
30 Did the crganizatio.i receive contributions of art, historical treasures, or other similar assets, or qu:;,lified
conservation contributions? If "Yes," complete Schedule M 30
.,
--
31 Did the org.1ni"ation liquidate, terminate, or dissolve and cease operations? If "Yes," complete Schedule N,
P;,rt! 31
.,
32 Did tho organiailion ·i.etl, exdiange,
complete Schedule N, Part II
dispose of, ix transfer more than 25% of Its net assets? If "Yes,"
32 .,
33 Did !he organization own 100% of an entity disregarded as separate from the organization under Ragulations
sections 301.7701-2 and 301.7701-3? If "Yes," complete Schedule R. Pert I ,
., "
33
34 Was :he organization related to any tax-exempt or tax.al.illl entity? If "Yes," comp/ere Schedule R, Part II, Iii,
or IV, and Part V. line 1
30a Jid the organization have a controlled entity withi1 the meaning of section 512(b)(13)'?
34
35a .,
b If "Yes" to lino 35a, did tho organization receive any payr)umt frorn or engage In any transaction with a
controlled entity within the meaning of section 512(bX13)? ff "Yes," complete Schedule R, Part V, /irr"!2 ,
36 Section 501{c)(3) orgenlzailons. Did the organi;,:ation make any transfers to an exompt ~on-charitable
35b
"
related organization? If ~Yes,"complete Schedule11,Part V, 1/ne2 , 36
37 Did the organization conduct more than 5% of ile.activities through an entity that Is not a related organization
and that Is treated as a partnership for federal income tax purposes? ff "Yes,n comp/f;lteSchedule A,
Part VI . 37
.,
" Did the organization complete Schedule O and provic'e explanations in Schedule O for Part VI, lines 11b .ind
197 Note. All Form 990 filers are required to complete Schedule Q. 38 .,
form99012015)
5/1212016 2:03:50 PM 4 2015 Return Tho American Logion

S5·0144250
Form 990 (2015) Pu,io5

Hfflti Statements Regarding Other IRS Filings and Tax Compliance
,ock ·1SCh
Ct
' ' d uIe O contains a response or note to anv I'ine in this Part V
,,□
1a Enter the number reported in Box 3 of Form 1096, Enter •O· if not applicable I 1a I 118
"'
b Enter the number of Forms W-2G included in line 1a. Enter -0· if r,ot applicable . . . . I 1b L 0
C Did the organization comply with backup withholding rule!! for reportable payments lo vendors and
..,
2,
reportc.Ole gaming (gambling) winnings to prize winners? .
Enter the number of o1mployees reported on Form W-3, Transmittal of Wage and Tax
.
S1atcmcnts, filed for 1he calendar year ending with or within the year covered by this return
.
2a
I I~27
.
1c
b It at least one is reported on line 2a, did the organization file all required federal employment tax returns? 2b v
"
Note. If the sum of lines 1a and 2a is greater than 260, you may be roquirod toe-/ilo (see instructions)
Did the organi;rution have unrelated busim:1ssgroi.s income of $1,000 or more during the year? ,, ..,
b If "Yes," has it filed a Form 990-T for this year? If "No" to line 3b, provide oinexplanationin ScheduleO . 3b ✓
4a At any lirne during the calendar year, did the organization have an interest in, or a signature or allier authority
over, a financial account in a foreign country (suc/7 as a bank 1;1ccuun\,securities o1ccount.or other ll1)anclal
account)? . 4a
..,
b If "Yes," enter the name ot the foreign country; ► • C
See instnactions for lillng requlremenl'3 for FlnCEN Form '.14, Repor1 of Foreign Bank and Fir,ancial Accounts
,, (F8AR).
Was the orga11izationa party to a prohibited tax shelter transaction at any time during the tax year? Sa ..,
,,
b
C
Did any taxable party notlly the organization that It was or Is a party to a prohibited tax she.:ter transaction?
H "Ye~·· to line Sa or 5b, did the organization file Form 8886-T? ,,
Sb v
Does the organization have annual gross receipts that are normally greater than $100,000, and did the
organization solicit a.1ycontributions thal were 11oll<!x deductible as charitable contributions? • ,, ..,
b If "Yes," did the orga11ita!lon Include with every solicitation an express statemsnt that such contributions or
gifts wero not tax deductible? 6b
7 Organizations that may receive deductible contr!bullons under sec11on 170(c).
a Did the organization receive a payment in excess of $75 mace partly as a contribution and partly for goods
and services provided to tho payor? 7a
..,
b If "Yes," did the organization notify the donor of \he value cf the goods or ser,,ices provided? 7b
0 Did the organization sell, exchange, or otherwise dispose of tangible personal property for which it was
req1.;iredto file Form 8282? ,, ..,
I I
d
'
If "Yes," indicate the numb8r of Forms 8282 filed durir,g the year 7d
Did the organization receive any funds, directly or indirecily, to pay premiums on a p0tsonai benefit contrl'.ct? ,, -----
..,
···-
f Did the orgomi.:.ition, during t:le year, pay premiums, directly or indirectly, on a personal beneiit conlract?
9 If the organl~atlonr~ived a contribution otqualified Intellectualproperty,didtha organization!ile Fmm 8899 as requirGd?
7f
_I.~----· "
--·-·
" 11tliu urg.iniialion receiveda contributionof cars, boats,airplanes,or other vehicles,did the organizationf~ea Fann 1098,C?
'"
'
9
Sponsorlns urg.inizations maintaining donor ad~leed funds. Did a donor advised 1und maintai1ed by the
sponsoring organization have exoess b1..11:1ine:.:,;holdings at any time during the year'/
Sponsoring organizations maintaining donor advised funds. '
a Did the sponsoring crganization make any lax.ible Uislributiun:. under :.ection 4966? 9a
b Did the sponsoring organization make a distribution to a donor, donor advisor,or related person? 9b
10 Section 6D1(o){7) organizations. Enter:
b ' !nillation feai. and capital contrlb_utlons Included on Part VIII, line 12 10,
110b I
I I .
Gross recalpts, Included o:i Form 990, Part VIII, line 12, for public use of club Facllllies
- .
...
11 Section 501(c)f12) organizations. Enter:
a Gross Income from members or shareholders . 11a •_
b Gro:;8 Income 1mm olher sour(;l:!S {Do not net amounts due or paid to other sources
-
against amounts due or received from them.) 11b .
12,
b
Sectron 49471a)(1) non-exempt charitable trusts. Is the orga111iat1onfiling Form 990 in lieu
If "Yes," enter the amount of tax-exempt interest received or accrued during the year. .
f1
F~lm 10417
12b
12,
· ..
.
13 Section 501 [c)(29} qualified nonprofit health insurance issuers.
Is the org1onization llcensea to issue qualified health plans In more than one state? 13a
' Note. See the Instructions for additional lnformallon the organization must rep:)rt on Schedule O.
b Enter tho amount of reserves the organiz~tion is required to mi.iintaln by the states In which
the organization is licensed to Issue qualified health plans I 13bl
0 Enter the amount of reserves 011hand 130
14a Did the organization receive any payments for indoor tanning services during the tax year? 14a ..,
b If ''Yes," has it filed a Form 720 to report these pavments? If "No," Qrovldean explanationIn ScheduleO 14b
rorm990 [2015)
5112/2016 2:03:IW PM
' 2015 Return The American Legicm
35-0144250
Form 990 (2016) Pag~6

l®JfJI Governance, Management, throughlb below,and tor a "No"
and Disclosure For each "Yes" responseto Jines 2
responseto lineBa,8b, or 10bbelow,describethe circumst11nces,
processes,or changesin Schedule0. See instructions.
Check ii Schedule O contains a response or note ta any line In this Part VI . . . . 0
Section A Governing Body and Management
y.,
1a Enter the number of voting members of the governing body at the end of the tax year 1a "1
"'
_'::·,:·
If there are matcriril difforences in voting rights among members of tho govorning body, or
it the governing body ctelega:ed broad authority ta an executive committee or similar
comr1ittee, explain in Schedule 0,
. '
b Enter the number of voting members included in fine 1a, above, who om independent 1b 60
2 Did any oflio□ r, director. trustoo, or ke~•employee ha~e a fomily relationship or a business relationship with •
any o!her officer, director, trustee, or key employee? 2 v
3 Did the organization delegate control ever management duties custome.rlly performed by or undsr the cirect
supervision of officers, directors, or trustees, or key employees to a management company or o'.her pernon? 3 v
4 Did !he organization make any significant changes !o Its governing documents since the prior Form 990 was filed? 4 v
v
'
6
7a
Did the organization become aware during the year of a significant diveraion of the organ!.:atlon's asi,ets?
Did the organization have members or stockholders?
Did the organization have members, stockholders, or other persons who had :he power to elect or appoint
'
6 v
one or more members of the governing body? 7a
.,,
b Are any governance decisions of the organization reserved to (or subject '.o approval by) :nembers,
:itockholders, or persons other thar the governing body? 7b v
8 Dir.I the or1,;anization contsmporaneously document the meetings held or wrlllen acliorii, undertaken during
'b
the year by the following:
The governing body? ,, v
Each commiltee with authority lo act on behalf of the governing body? Sb v
9 ls there any officer, director, trustee, or key employee listed lo Part VII, Section A, who cannot be reachRd at
the organization's mailing address? If "Yes," prov/de the names and addresses In Schedule O . 9 v
Section B Policies (This Section B requests information about po/JCJasnot required by the Internal Revenue Code.)
y,.
10a Did tho organization have local chapters, branches, or affiliates? 10a v "
b If "Yes," did the organl;a:ationhave wrllten policies and proceC:ures governing the activities of such chapters,
affiliates, and branches to ensure their operations are consistent with the organization's exempt purpo~e:,? 10b v
11a Hu,.,the orgmizationprovided a completecopy or this Form~SIJI() all membersol its go•Iernlngl;lodybefore Wingthe form? 11a v
b De:;crib1; in Schedule O the proces:,, If any, used by the organization to review this Form 990.
12• Did the organii:atlon have a written ccnflJct of interest pol!cy? if "No," go to line 73 12a v
b Wernofficers,directors,or trustees,and key employeesrequiredto discloseannuallyintere:i\sthat could giv6 1i~ lo cvr1n:ct~r 12b v ·--
C Did the organization regularly and consistently monitor and enforce compliance with the policy? If "Yes,~
describe in Schedule O how this WBBdone . 12c v
13 Did the organizat:on have a written whistleblower policy? 13 v
14 Did the organlzat!on have a written dooument retention and destruction policy? 14 v
15 Did the process for determining companeation of the following persons include a review and approval by :_ '.·
independent persons, comparability data, and contemporaneous substantiation of the deliberation and decision? ..·...
a The organization's CEO, Ei<;eculiveDirector, or top manage1neril official 15a v
b other officers or key employees of the organization 15b v
If ''Yes" to line 15a or 15b, describe the process in Schedule O (see instructions).
16a Did the organization inv~st i.1, contribute assets to, or participate in a joint venture or similar arrangement
with a taxable entity d11ringthe year? . 16a v
bIf "Yes," did the orga:iizalion follow a written policy or procedure requiring the organization lo evaluate its .
part'cipation in joint venture arrangements under 11pplioablelederal tax. law, and l<lke sl6ps-to safeguard Urn
organization's exempt status with respect ta such arrangements? 16b
. .
Section C. Disclosure
~=c;.,.~===..,.,-=~---~~-~=-==~~~~-~===~=======c··--
17 Ll:;t the sla\t!S wl\11whiwh <1 copy of this Form 990 Is required to be filed ► AL, AK, AZ, AR, (CONTINUED ON SCHEDUC.E0)
1a Section 6104 requires an organization to make its Forms 1023 (or 1024 if applicable), 990, and 99U·T {Section 501(c):3)~ only)
available for public inspection. Indicate how you made theso available, Check all that epply.
0 Own website D Another's website 0 Upon request D Oiher (explain in Schedule 0)
19 Describe In Schedule O whether (and If so, how) the organization made its governing documents, conflict of interest policy, and
financial statements tivailable to \hi;! µul.ilic during the tax year.
20 State the Mme, address, tind telephone number of the peraon who possesses the organization's bocks and records: ►
GEORGE A. BUSl<IRK, JR., 700 N PENNSYLVANIA STREET, INDIANAPOLIS, IN 46204, (317)630-1229
l'orm99O{2015)
5/12/.20t6 2:03:50 PM
• 2015 Return The Am~rlean Legion
35-0144250
form 9S0 (2o·.5J Pa~a 7

l@l'.411
Compensation of Officers, Directors, Trustees, Key Employees, Highest Compensated Employees, and
Independent Contractors
Check if Schedule O contains a reseonse or note to any line in this Part Vil . . . . D
Section A. Officers, Directors, Trustees, Key Employees, end Highest Compensated Employees
fa Complete this table for ell persons required to be listed. Report compensation for the calendar year ending wi1h or within the
or!]an zation·s ta><year.
• List all of the organization's current officers, directors, trustees \whether Individuals or organizations), regardless of amount o1
compensation. Enter -o-·in columns (D},(E), and (F) if no compensation wm,paid.
• :.1stall of the organizaticin's current key employees, if any. See instrJctions for definition of "key employee."
• list the organlzatlon"s five current hlgfiet;t compensated employees \ot!ier than an officer, director, trustee, or key employee)
who rec?.ived ro1portable compensation (Box 5 of Form W-2 and/or Box 7 of Form 1099-MISC) of more than $Hio,oou !!om the
organization and an1•related organizaUons.
• List all of the organization's 1ormer officers, key employees, and highest compensated employees who recei•:ed more '.har'
$100,JOO uf nipurt<11Jler.:ompensatlon from the organization and any related organizations.
• List all of Lhe organi~ation's former directors or trustees that received, in the capacity as a former director or trustee of tl",e
organization, more th.sn $10,000 of reportable compe11salion from the organization and any related organizations.
List persons in the following order: individual trustees or directors; Institutional trustees; otticers; key employees; highest
compensated employees; and former such persons.
0 Check this box if neitl1er the ornanization nor anv related organization comnensaled anv current officer, director. or trustBe,
(Cl
Poai1ion
!Al IOI o,1
NamearidTllla Al'arage
ooun:POI
(do not check more than ona
ho~, unloee poruon is bolh"" Raportab/o '"
Ropor!~IJfo
officerand a dlreclor/lrus1ee) compensalim1 ccmpensation lrom
l'I
fstimrnod
amountor
iwMk Olstooy
~OU/8 for
relaWd
"=
'"
related
orga1izatior;s
o1her
comp811sation
organizalic~ (','M'l1099·MISC) frt,m1110
organi<ations (W,2/1099"MISC) or9"ni2alicn
li,slow dotted and reinled
line) organi<illlons
(1) HAROLD D. BARNETT 40.0

NATIONAL COMMANDER 1.0 :34,000 0 0
{2)GERALDl. JACO!JS 1.0
OAO,Oto
,N ONOAOcOvO1O
ecO·O
cOoONOMO
,,ONOoO
,Os O1OeO
AcRoTt
AO
O tO
Y.,EAcoR)L.j_ao
O.o'-+C"--1--e"--l--l---1--l----'ol-----'o". __ _ 0
{3) MICHAELD, HELM 1,0
N~lJ()!'/A~ COMMANDER (PART!ALYEAR) 1.0 60,677 0 1,759
(4)GEORGEE. CUSHING 1.0
NATIONALVICE COMMANDER 0.0 0 0 0
f5) P/\ULO. SAN!'OKD 1.0
,N,A,T,tOcN,'ActcVclaCE=CaOcMcMcAcNcDcEcR_lcPcAcRclclAcLcYcEcARc)L(_COC.o~-1
., 0 0, 0
(6) RICHARDW. NEVILLE 1.0
_N,A,lclOcN,A,LcVclcCE=CaOcMcMcAcNcDcEcRclcPcAcRcTicAct,YcEcARc)L(_cOc,O~--l--C'-+-1c'--4--1---4--1----"'l-----"01-------~
(7)WILLIAM R. ORYANT 1.0
NATIONALVICF-'.COMMANIJFR(PARTIALYEAR) 0.0 0 0 0
(8) DOUGLASC. HAGGAN 1.0
NATIONALVICE COMMANDER (PARTIALYEAR) 1.0 0 0 0
(9) JOHN W. HARGREAVES 1.0
NATIONAi.VICE COMMANDER 0.0 0 0 0
{1 O)ALAN A DAVIS, SR. 1.0
NATIONAL VlCE COMMANDER 0.0 0 0 0
(i1) DA.YIDL GOUGH 1.0
----
(12] JIMMY F. LANE 1.0
[13) JOHN H. MILLER 1.0
,"cAcTclOeNeAotcEsXcEoCcUcTctVcEcCeOeMcM,::clTcToEoE
____ 4-_,0c,O'-+""-l-l--+-+-+--+----- ~ .. _ 0 0
(14)ALVIN R, BROWN 1.0
NA rlONI\L EXECUTIVF COMMITTEE (PARTIAL YEAR) 0.0 0 0 0
511212016 2:0J:50 PM 7 2015 Return The Arnerlca'l Legion

35--0144250
Form 960{2015) Pa.ge8

Section A. Officers, Directors, Tru~tees, Key E lovees, and Hl,.hest Comnensated Emnloyees (continued)
IBI
A\falage
Posmnn"'
(do nol check more lhan one
box,unle•s person is bothan Reportable
,.
napcrtabl• '"
Estimated
ho1.1r~par officer and a dire~lot/1.,u~ie_a)_compmsation compensalion lrom ~mount ol
lll'ilek II~! any ,--- trom related Olh~t
~5. tir; ~ .f _§.if3'
*
hours for !he 0111ani>al1ons cm1,pot16alion
ml~1od ~-~ !l <> 6'[ ~ mgooi,alion (W-2/1099-MISG) from tho
organizationsQ~
below dotted
g· ""' '1g!l (W-211099-MISG) organl.zaUcn
and related
1,oe]
2 ill. ~ ,:i
orgarnn1/ons
lr [ ' i
(15)R08:cRT C, MILLER JR.
NATIONAL EXECUTIVE COMMITTEE
1.0
0.0 V
"' l
•
11
0 0 0
- ------- -
(16) ROBERT J. l~IMBALL 1.0
NATIONAL EXECUTIVE COMMITTEE o.c V 0 0 0
I'
(17) BRUCE C. f'EUERBACH 1.0 !\
NA"7"I0l~ALEXFCUTIVF COMMITTEF U,U V 0 0 0
(18)CHARLES 0. AUCOIN 1.0
r>JATIONALEXECUTIVE COMMITTEE o.o V 0 0 ,)
{19)CHAl-lLES E. SCHMIDT 10
NATIONAL EXECUTIVE COMMITTEE o.o ✓ 0 0 0
(20)CHARL!::S F. WESSINGER 1.0
.'IATIOl~AL EXECUTIVE COMMITTEE 0.0 ✓ 0 0 0
-----
(21) CHARLES W. GOODIN 1.0
NATIONAL EXECUTIVE COMMITTEE 0.0 V 0 0 0
(22) DANIELE. MCCOLE 1.0
NATIONAL !::XECIJTIVE COMMITTEE 0.0 V 0 0 0
(23) DAVID A. GOLDE 1.0
NATIONALE:~ECUTIVECOMMITTEE (PARTIAL YEAR) 0,0 ✓ 0 0 0
{24)DI\VIO 0. WARNKEN 1.0
NATIONAL EXECUTIVE COMMITTEE o.o V 0 0 0
(25) (SEE STATEMENT)
1b Sub-tot.ii .
► 94,677 0 1,759
c Total from contlnu.tlion sheets to Part VII, Section A ► 1,294J54 0 390,622
d Total (add lines 1b and 1c} . ► 1,386,831 0 392,381
2 Total number of lndlvlduals (Including but not limited to those Usted above) who rar,eived more than $'100,000 of
reportablo compen;;citioI1 from th!:! ory,mizittion ► 14
,,
3 Did the organization list any former officer, director, or tmstee, key omployoe, or highest comr::ensated '".
employee on line 1a? /I "Yes," complete Schedule J for such indi'lidua/ 3 ✓
4 For any individual listed Ofl line 1&, is the sum of reportable compensation and other compensation from the .
organization and related organizations greater than $150,COO? If "Yes," complete Schedule J for such
individ1..1a/. 4 V
5 Did any person :Isled on line 1a receive or accrue compensation from any unrolatcd organization or individual
for services rendered lo the organization? If ''Yes," comp.'ete Schedule J for such person 5 ✓
Contractcni
So~~r_o_!!~_".._lndependent
1 Complete this table for your live highest compensated lndopondont contractors that received more tt1an $100,000 of
compensation from the organization. Report compensation fort he calendar year ending with or within the organization's tax
yeo1r.
,,,
RESOURCE ONE, PO BOX 839
"
Nam~ and bu,;lneasaddreO$
TULSA OK "/4101-083!:I
Descrip11on or service:
DIRECT MAR·<ETING
"'
Compensation
6,65fl,e65
EDGE DIRC'CT, 6201 E 43RD STREET, TULSA, OK 7413?__ DIRECf MAIL 5,763,W,5
.. ---
_13RDONNELLEY &_~_O_NS,CO, PO BOX 93514, CHICAGO, IL 60673-3514 PRINTING SERVICES 3,517,483
JAMES G. ELLIOTCOMPANYINC» 134 N LASALLE STREET.SUITE 1700. CHICAGO.IL 60602 PUBLISHING 1,393,255
\JATIONAI_VETERANSlEGAl SERVICESrRooRAM,
1608KSTREET NW.SUITEoi~.WAWINGTON. DC wooe LEGAL SERVICES 917,231
2 Total number oJ independent contractors (including but not Hmlted lo those listed above) who .
received more than $100,000 of compensation from the organizatiori ► 19
Form 990 (~015)
5/12/2016 2:03:50 l>M 8 2015 Ret1.1r11 The American Legion

3~·0144250
Form 990 (2015)

UZtil!WI
Statement of Revenua
Check if Schedule O contains a response or no e to anv line in this Part VIII . □
'',
,. · .. ',.·_.·,:.
,', :·.' ,'
11,947,990 ,.
,
.... ·-: '., . -,_-
2a MEMBl:RSHIPDUES 813410 32,737,722 32,737,722
b MfMflEH SEKVICESINCOME 813410 703,326 703,326
c SONSOF THEAMERICANLEGION 813410 750,_13~____-~7 0C0
0,013
08+-----+-------
d BASEBALL INCOME 711320 475.393 475.393
e CONVENTIONINCOME 561920 340,024 340,024
f All other progmm service revenue . 900099 645,322 645,322 o o
~~~~-►-f---35-, 65°1°,9°2°5+--~==~----~~------"
0
9 Total. Acd lines 2a-21
3 Investment Income Oncludlng dividends, interest,
a1d other similar amoun1s) ► 2,599,276 2,599,276
4 !ncome from inveslment ol lax-axempt bo11dproceeds ►
5 Royalties ►
,, Gross r9flts
l•JRe~I ~lfPar30llal
·.
'
b Less:rental expenses
0 Rentalinccmeor Ooss) 0 0 ..
,,d Net rental income or loss)

Gross ~mount framsalescf ~) Seourilltl~ Q~Olhar
►
.. ·.,.
.., .. --. '
~:.rels
otlierlimnl11ve~\ory 52,309.600
b Less:costor otheroasis
a!ld s~les(ll(f)eflS!ls 52,024,220 ". -: -
Gai11or (loss) 285,446 :' 0
'
d Ncl gaill U( (I~:;) ► 2-05.446 265,446
Ba Gross income from fundralslng

events(no: includ:ng$ 70,354
of colllribution:. reported on line 1c).
SeePart IV,.'ine18
b Less: direct expenses '1---=cc"I'
b 77,758 :
c N<:itincomo or (loss) from fundraising events ► (77,758,),: m,758)
9a Gross incoma from gaming activities. r~~~~-f-."·,,"·"··""·.·"··"··"·•.•..+~~---+---,-.- ..-+-".-•-.-===
see PartIV, line HJ
b Less: direct expenses
·f------,
b
i
Net income or (loss) from gaming actiLei"ti"~~---►c-1
10, ' Gro ss sales of inventory, less ~----~-----!------1-----+------
---- --
b
c
n,tums and allowances
Less: cos! of goods sold
'f---- 7,128,612
b
1c3c·14c2·c6llc
Net income or (loss) from sales of invsntory .

MiscellaoeousRave~ue
0
7-,
BuslnN~ C~cie
►
.
6,016,085
'
'.',,·,
' .
. ..
.
6,016.0S5
!
;,
ii
,.
,,'
11 a ADVERTISING 541800 10,132,570 10,132.570
"t
b LABEi. ANUPRINTINGINCOME 900004 2,321.428 2,297,962 23,466
c AFFINITVPROGRAM 813410 2,830,783 2,830,783
d All other reven~e 900099 649,28D 649,2% 0 0
,•_,-,,-,,_,_,
.. , ----
'. . _.__:
e Total.Addlines11a-11d ► 15,834,066 -,
12 Total revenue. See instructions, ► 72,257,030 40,626,629 10,156,036

Form99O{~015)
5/12120162:03:50 PM 9 2015 R~tum The Ama1·ic1rn

L11gi11n
35-0144250
founS00(2<'15) Page 10
l:1ttJl&I
Statement of Functional Expenses
Secfion 501(c)(3)and 501(c)(4)organiLationsmus, completo all columns.All other organizationsm11stcomplete
. - ·-
column 1A).
Check If Schedule O contains a resoonse or note to anv line in this Part IX
Do not include am<'.luntsreported on /Ines 6b, 7b, (Al ,,, ft
□
Sb, 9b, anr:J10b of Part VIII.
1 Grantsandotherassist:inceto domesticorganizations
Total expenses Pmgrum sornca
experises
Managementand
'"
ganeralex~ansee
.
Fun raising
expenses
..
anddorne21ic
2 Grants
governments,
"'
S11e PartIV,line21
othe.-- assistance to domestic
Individuals. See Part IV, line 22
23,145
1,512,830
. .
..
_, ,
.-
. ..
-·-•--,,..,·i._·,;
",•,'
,'
...
·-:,' '_'
..
..·•·
. ··: .... -. .
' Grnnrn
'"' other mrnistance to foreign
organizations,foreign governments, and foreign
Individuals.See Part IV, lines 15 and 16 . ·.
4 Benems pnld to or for men1bo1s ·. '.· -·
5 Compensc11ionoi current officers, directors,
--
trustees, and key employees 1,051,610
--
•
·····-··-
Compensa1ionnot included above,to disqualified
persun~ (1111 "ndsr section 495!!(Q(1))
d11fin11d and
personsdescribedin section 4958(c)(3)(B)
7 Other salaries and wages 15.006,726
8 Pensionplan accruals and contributions (Include
section401(k)and 403(b) employercontributions) 266,707
9 other employee benefits . 2,239,163
. . ---- ..
10 Payroll taxes .. 1,226,724
11 fees for services {nan-employees):
•b M,magement
ltJgul 119,690
- ---- -·----·
Accounting 113,599
'd Lobbying
Professional fundralsingservices.SooPartIV,line17 193,444 •
f' investment management lees 289,060 .
g Other.{Ifline1lg amountexceeds 10%of lirie25,column
(A)amount, listline11~expen51lsonSchedukl 0.) 4,861,946 0 0 0 f,
I
12 Advertising and promotion 1,255,084
13
14
15
Office expenses
Information technology
Royullles
.. --
17,238,758
307,418 !
16 Occupancy 679,364
17 Travel ?,362,557
18 Payments of travel or entertainment expenses
for anyfederal, state, or local public ofiicials
19 Conferences, conventions, and meetings 4,847,754
20 !merest :H,495
21 Payments lo affiliates
22 Depreciation, depletion, and amortization 82!1,447
>----··
23 Insurance. l88,/9b
24 Other expenses. ltemlw expenses not covered
. .
above (List mIsocllanoousoxpcnsesin line 24e. If I
I .. ·.
line Ne arrount exceeds 10% of line 25, column
(A}arrount, list line 24eexpenseson Schedule0.) .
MAGAZINEPRODUCl'ION 11,140,298
'
b D:KECTMEMBERSHIPSERVrc,;s
-
6,895,762
DIRECTPROGRAMEXPENSES 1,222,829
'd DUES& Sl-'DSCRIPTIONS 126,430
·- ·---
0 All other expense$ 0 0 0 0

25 Total furiclional e~penses.Addfo~s1 lhrougf-i240 73,633,625 0 0 0
26 Joint costs, Comploto this line only ii the
organizationreported in column \B) joint costs
from a combined . educational cami;iin and
fundralslnl sollcltetlon. Check here II
fo:lowing OP 98-2 (ASC95B-720) . . . .
Form 990 (21J10}
5/12120162:03:50 PM 10 2015 Return The Amariean Legion
35-0144250
Form9.0{201~) Pngo 11 'I

ldtl 6alance Sheet !
Chock ifSchedUIEI O contains a response or note to any line In this Part X 11
(A)
Boglrmlng of year
)B)
End a/year I
1 Cash- non-Interest-bearing L853,594 __c1+---~
88,941,054 2
090'50,406~5
92,758,395
l
' Savings and ~mporary cash Investments
3
'
4
Pledges and grants receiwlile, m;1t
Accounts recel\lable, net
' -
4,386,669 4 3,195,201
ti Loans 1;1ndother receivables from current and former officers, directors,
trustees, key Bmployees, and highest compensated smployees.
Complete Part II of Sohedule L 5 0
5 Loansand other recaivahlesfrom otherdisqu~llfiedpersons(asdefinedunderseclioo
4958(~{1)),
persons describedin section4958(c)(3)(8),and contributingemµloyersand
I
spon:;orir:gorganizationsof ssctiun j1J1(c)(9) voluntary employees' bonsficlary
organizations(sooimtruclions). Complete PartII of ScheduleL 6 0
7 Notes and loans receivable, net 7 401,188
8 ln~entories for sale or use 2,704,'.l57 8 2,818,625
9 Prepaid expenses and deferred charges 7,023,417
-- -
10a Land, buildings, and equipment: ~osl or
other basis. Complete Part VI of Schedule 0 10, 1/,!40.t1ll
b less; accumulated depreciation ,1000b~------'1 0 ,05055+----'c•s"c'c·~"'c''l-'1"0"o+------''"''"'c'c·
020,4068 'c"c.'
11 lnvest11ents-publicly traded securities 11
- ---------cl-c'-c-+----~
12 Investments-other securities. See Part IV, :lne 11 f-----~~c"'f-'1c2+---- _ ·-·-·- o
13 Investments-program-related. See Part IV, line 11 18,275 13 15,91\l
14 Intangible assets 14
15 Other assets. See Part IV, line 11 2,000,oco 15 2,000,000
16 Total assets.Add lines 1 throuoh 15 (mus1 enual line 34) . 112,764,854 16 114.410.454
,.
17
18
20
Accou1ts payable and accrued expenses
Granls payable .
Deferred revenue
Tax-e~empt bond liabilities
1____
14,459,198
1,029.216
0,,808,174 19
4~7
16
20
--,~.,~,~,.~36~3
17_ _______ 16,<17S,249
48,420,979
Escrow er custodial account liability. Comple;e Part IV of Schedule D . 21

:ll "
22 Loans and other payables to current and fo1mer officers, directors,
higtw:.L co111pensatcd employees, and
~
trustees, key employees,
disq1.mlified persons. Complete Part II of Schedule L 22
~ 23 Secured mortgages and notes payable to unrelated third parties 1,211,949 23 1,025, 1/49
24 Unsecured notes and loans payable lo unrelated third parties 24
25 Other Habilitles (Including federal income tax, p<lyables to related third
parties, and other liabilities not included on lines 17-24)_ Complclc Part X 23,831,628 26,620,265
of Scl1edule D 25
26 Total liabilltles. Add lines 17 through ?5 88,320,225 26 93,t42,005
OrganizationsthatfollowSFAS117(ASC958),checkhere ► 0 and _,_- -,•, :, : ·- ··-
complete lines 27 through 29, and IInes 33 and 34.
Unrestricted net assets '--- __'1
?.443,298 27 11,691,899
Temporarily restricted net assets 4.001,331 28 4,176,55·)
Permanently restrlc!eC net assots , 5,000,COO 29 5,COO,OO·J
Organizations that do not lollow SFAS117 {ASC958),check hero ► D and
c;omplete lines 30 through 34,
Capital stock or trust principal, er current funds 30
Paid-in or capital surplus, or land, building, or oquipmcnl fund 31
Retained earnings, endowment, accumulated income, or other lunch, C---------+~3~2--1---- _----- _
Total not assets or fund balances, 24,444,629 33 20,868,449
Total liabilities and net assets/fund balances 112,764,054 34 114,410,454
Ferm990 (?075;
5/1212016 2:03:50 PM 11 2015 Return Tile American Legion

3~-0144250
forrn900 [2015) Pago 12

l@f31 Reconcilia1ion of Net Assets
Check if Sc1edule O contains a response or note to any line in this Part x·
1 Total -avenue (must equal Part VIII, column {A), line 12) , ' 1 72,267,030
'
3
Totoil expenses (must equal Part IX, column (A),line 25)
Revenue less expenses. Subtract line 2 from line 1 '
3
73,633,625
__(_1,37Q,_5J5)
4 Net assets or fund bodences .it beginning of year (must equal Part X, line 33, column (A)) 4 24.444,62~
5 Net unrealized gains ~ossss) on Investments 5 (1,248,C27)
'
7
Dcna!f!d services and use of facilities
lnvostment expenses '
7
8 Prior period adjustments . 8
9 Other chan1,es in net assets or fund balances (exp!ain in Schedule O) 9 [951,550)
10 Net assets or fund balances at end ol ye.1r. Combine lines 3 through 9 (must oqual Part X, lino
33, culumn (B)) .
. Financial Statements and Reporting
10 20,868,449
Check if Schedule O contains a rm,ponse or note lo anv line in this Part XU . □

y,. No
1 Accountir.~ method used to prepare the form 990: 0 Cash [!:!Accrual □ Other
I' tho organi:.:o1liunchw1yed lt:i method ot accounting from a prior year or checked "Other," explain In
2,
Schedule 0.
Were '.he orga'lizatlon's financial statements complied orravlawed by an independent accountant? . ,, ,
If "Yes," check a box below to Indicate whether the financial statements for the year were compiled or
naviewed on a separate basis, consolidated basis, or bo1h:
D Separate basis D Consolldated t>::isis D Both consolidated and separate ::iasis
b Woro the organization's financial statements audited by an independent accountant? 2b ,
If "Yell," chock a box bolow to indicate whether the financial statements for the year were audited on a
separate basis, consolidated basis, or both:
D Separate basis 0 Consolidated basts D Both consolidated and separate basis
C If "Yes" to line 2a or 2b, does the organization have a committee that assumes responsibi:ity for oversigh,:
of the audit, review, orcompilation of its financial stateme1ts and selection of an independent acco·Jntant? ,, V
If the organiiation changed either Its oversight process or selection process during 1he tax year, explain in
Schedule 0.
3a As a result ot a federal award, was 1he organization reqlJired to undergo an audit or ai;dits as set lor1h in
the Single Audit Act and DMB Circular A-133?. 3a ,
If "Yes," did Iha organization undergo the required audit or audits? If the organization did not undergo the
b
required audit or audits, explain why in Schedule O anC:describe any steps taken to undergo such audits, 3b ,
l'arm990(20l5)
5/1212016 2;03;50 PM 12 W15 Return Th~Amerlcan J..e9lo11

35-0144250
Soction A, Offlcors, Dlroctors, Trustees, Key Employaona, and Highest CompensateLI Employees (continued}
----
(A) Namo and TH!e (B) M,m,g.. houts (C(Pv5ilkm (D) Reµutlalile {t,j He)Ju11a1Jlo {F) Estimated
per week Clw< a'lll1•1oP
, uo1r.ponsallon compensation amountof other
(llo!"'l)'OOU'Bfrurclalod 0 frnm th~ from relaled compensation
~
''"
i ! I l
OIB•n·zaliOn• bO,,W a
dc~e<I lin•} orianizalion o,W:anizalions from lhe
! a '
1W· 1(19{1-MISCJ ( ·l/1~~~•MISq organllation and
related
'g'' t org<1nilal1ons
0 I
0
!'
•
'
(251DENNISR. BOLAND 1.00
······-··-······-··-· ✓ 0 0 0
NATIONAL EXECUTIVE COMMITTEE 1.00
'
125!EARLON L. SEALE
NATIONAL EXECUTIVE COMMnTEE
1.00
✓ 0 0
. 0
'
0.00
PART~L YEAR)__ __
·-·-__ ______ ·----··· ....
127)FELIX M. TRU.ILLO
--····-~::'? .' ✓
.._..__ 0 0 0
NAT_;pNAL EXECUTIVE COMMITTEE 0.00
126)c'R,O,,t,'CIS
W. MCCURDY 1.00
✓ 0 0 0
NATIONAL EXECUTIVE COMMITTEE 0.00 __ !
------ ---·- -
(291 HERElERT J, SCHOL TEN 1.00
······---·····-···-··-·-··--······-·····-····· ,----··-·· ✓ 0 0 0
NA l lONAL EXECUTIVE COMMIT fEE o.ou
(311 ILDl:FONSO COLON, JR. 1.00
✓ 0 0 0
..
(SJ) JAMES E. PISA 1.00
✓ 0 0 0
-
la/) JAMES E. PRENDERGAST 1.00
-··-·--··············-·----··-·····-·····- -·····---·· ✓ 0 0 0
NATIONAL EXEC'JTIVE COMMITTFF. 0.00
IJ:lJ JAMES V. aYNUM
0 0 0
l\ATIONAL EXf~,C?UTIVECOMMITTEE
I/PARTIAL YEARi
P4J JERRY LANOMMER
0 0 0
NA l lONAL lc:XEGUTIVE COMMITTEE 0.00
(351JOHN H. SKINNER
0 0 0
NATIONAL EXE_'~UTIVE COMMITTEE
PARTIAL YEAR1
u.uo
IJ61 D. JOSEPH JACKSON
0 0 0
NATIONA' EXECUTIVE COMMITTEE
1~1) LAc;:RY W. MOORE
l~/1TICN/\L EXECUTIVE COMMITTEE

0 0 0
PARTIAL YEAR\
IJUJ MARVIN R. SIEGFRIED 1.00
····-- ······--· ✓ 0 0 0
NAT ONAL EXECUTIVE COMMITTEE 0.00
(39) MERVIN G. GUNDERSON __ ,_.o_o
__ .._ ✓
0 0 0
NATIONAL EXECUTIVE COMMITTEE 0,00
(~O) MICH1\El D.,WOOD
········-·-···-· ---- 0,00
0 0 0
(411 MICl<EY C, TAYLOR
···························==·-··-··- 0 0 0
(PARTIAL Y!!AR1____ -, - -- . __o_.o_o
__ +--+-l-+-+-l-+-----1-----
(42) PAUL A. EVENSON 1.00
!·················--····--·-··-············· ✓
·········-·-···-······ 0 0 0
:NATlmJAL EXECUTIVE COMMITTEE 1.00 . ·-·-
il-,1 PAUL I. STl:'WAR\J 1,00
l---o-.o-□---·
INATiONAL.~XE:cur1vE
coMMiffiii ✓ 0 0 0
2015 Return The American Legiotl

5l12/2011l 2!03:50 PM
" 35•0144250
(A) N.ime and Tille (B) Average homs (C~ Posklon (D) Ro;:iortablc {E) Reportable (F) Eslimated
per week /Chee oll lhal npply) compensation compensation 3mount of oth~r
ony hourokir re'ale~
11<>1 g from tho from related
a 'l •'
' " compernm!ion
~•nlza!on• below
Oonodli"")
t'
<
"
~
'
I" orljnnizetion
(W- 110~9-I.IIS~)
or~ni~alions
/W- 1C9~-lll,13C)
from lhe
org.:mizntion □ nd
'
'I ;! f l!
related
organiza11ons
'
• ''
I
[<l) RANDALL COFFMAN LOO
,,.______
'•
-------------------·---·---
---------------------
----.. .......
,
0.00
✓ 0 0 0
(411 RAYMOl,'DA. DEZURIK

1.00
---------------------- ------·-·······---·-·--~ --·-·--·-·-···-··-- ✓ 0 0 0
NATIOl\'AL EXECUTIVE COMMITTEE
-'PARTIAL YE,\R1 0.00
____
, (l() ROBERT
_____ E. GOSA 1.00
-------------
.....------------
,.,_
- ------ ✓ 0 0 0
NATIONAL EXECUTIVE COMMITTEE 0.00 ---- ---------- -----
(41) ROYAL E. SHEELEY
1.00
·-·--· ·--·--···-·--------
------ ---------····· ✓ 0 0 C
NATIONALEXECUTIVE COMMIT:"EE
(PARTIAL YEAR)_
0.00
1•l8) STANLEY H. CLARK
---- . 1.00
NATIONAL EX~\UTIVE COMMITTEE
--·-·-------··-----·
✓ 0 0 0
o.co
,~,
PART'AL YEAR
STEV~N M. JIMMO
---------------······--
·- ------------- 1.00
NATIONAL EXECUTIVE COMMITTEE ✓
·--------·····-·-··- 0 0 0
□ .00
PARTIAL YEARI
(6~) TERRY D. SC-IOW 1.00
·---------------------
----------·-···---------------·-····-······--- ✓
N/\TION/1L EXECUllVE
16",) THOMAS E. MATTICE
COMMITTEE 0.00
1:J0
---- -- - ---- --
0
-----
0
---- ----- ---- '
---------··-····-··------------------------·--- ✓
---------·----·-······ 0 0 0
NAT:ONAL EX_E_,;;_l,IIIVE
COMMITT!:E ._..._Q,9□
(52) T,--!OMASE. SAUNDERS 1-00
----·-···--·--·---·--------- . ---···---------·-·--
✓ 0 0 0
1,11WILLIAM R. WRIGHT, 11!
0.00
1.00
' ~
I ... - -· -· . -·--·---------·--·--·
✓ 0 0 0
NATIONAL EXECUTIVE COMMITTE:t 0.00
l(~I WILLIAM R. BOB WALL/ICE 1.00
I·NATIONAL
···············------······-····
EXECUTIVE COMMITTEE
..
0.00
.... ----✓ 0 0 0
i(oo1WILLIAMW. KIL[ 1.00

-----··----·--·· ✓
I
·-
0.00
0 0 0
i<t!)WILLIS FRAZIER 1.00

······-------------- --------------- --···✓ 0 0 0
1(17)KICHAHU W. PERRY 1.00
-······---------·-----------·---·---·······"··
NA l"!ONAL EXECUTIVE COMMITTEE
...... ------·--·------------
✓ 0 0 0
0.00
(~ij) HUCH :C.CROOKS JR 1.00
------··----·------------------·----------
--------------------
✓ 0 0 0
,.,
NATIONAL EXECUTIVE COMM_!_TT:C~
KENNETH G. WHITMAN
---·-······--------·-····-·-------------------------
----------------------·-
0.00
1.0.'.l
✓ 0
--- -- - ---
0
... ------
0
NA-IONAL EXECUTIVE COMMITTEE 0.00
,oo,WARREN N. CUFFEE 1.00
.. -------
--------·-··----------·------·---
- ----- -------- ··- ✓ 0 0 0
18') :::LBERT D. WHITE 1.00
········--····-·-··---·-···- ------------------- ------- ✓ 0 0 0
:-.tATIONAI. f:XECUTIVE C(>MMITTEE 0.00
(Bi) RONALD L MICHALSi<I 1.00
···--·---------------------
----·-·--···--··· -----------------------
✓ 0 0 0
NAl IONAL EXECUTIVE COMMITTEE 0,00
ioSI BILL G. RICHARD 1.00
- ---·-··--------------------------··-··---··
-----------------· ...... ✓ 0 0 0
NATIONAL 1':XF:CUTIVE COMMITTEE 0.00
5/1212016 2:03:50 PM 14 2015 Return The Amorican Legiori

35-0144250
- -- (F) Es~mated
(A} Name and Tit!e (Bl Average ho1.m1 {C~Po5ilion (D) Reportable (E) Reportable
per week (Cleo, ~n lhs1eppl~I compensation compensaUon amount or other
jliol"',yt..,,. kt" <•la\oc
i, from '.hs fromrelatec· compansalk.m
o,.,,n~•lian• l>!olow
dotlod .1no; f:
~
i f f ' ' orianlzatlon organizations from lhe
l', l '
◄ W• 1089-MISC) (W.inu~w-MISC) org<ml.:alion an~
I rt1lat~d
i 'I organin,1ions
'
I-
l
------ j
----+-----+--+--+--+-+-"+-+----+--------,--------,
'
•
164)RORERT L. KRAUSE 1.00 '
✓ 0 0 0
(il5l STEVE l<RUEGER 1.00
✓
-------------------- 0 0 0
Nf\TiONAl. FXF.CUTIW: COMMITTF.1-: O.OU
166) CECIL F. HENNIS _____ 1.00
------------------------------- -----------1 ✓ 0 0 0
1871c-RANCIS J. KILLAY
0 0 C
\IATIONAL EXECUTIVE COMMITTEE
(6sl FRANCIS J. MACDONALD 1.00 ✓
----------------------
0.00
0 C C
10;1 GARY R. DRENNON 1.00 ✓

------------------------ 0 0
~A TIONAL EXEC'JTIVE COMMITTEE o.oo
1101JERRY A. □ALL 1.00
------------------✓ 0 0 C
N,cA,Tl,ON=A,L,EeX,ec,u,Tcll,'E~c,o.McM,1TT=E,E+-~'c-Oo0~-+---1-+---1-+---t-+-·-····--
__
111) MARLAND A. Ro.'-lNING 1.00
✓
----------------------- 0 0 0
(721MARY V. EROMAN
0 0 0
I\ATIONAL EXECUTIVE COMMITTEE
(Ill RAMO~A A. NARAGON 1.00
✓ 0 0 0
NATIONAL EXECUTIVE COMMITTEE 0,00
U◄ l ROBERT D. WINSTON 1.00
------·····-----···········-· ✓ 0 0 0
(75)ROOER H. wi:m;-cR 1.00
✓ 0 0 0
NAilOt>IAL EXECUT:VE COMMITTEE 0.00
-·-- -- - -
(NI WAYNE WAGNER 1.00
1----·-····-·····----- ----····· ✓ 0 0 0
NATIONAL .'-:XECUTIVF-GOMMl"flf'f'" 0.00
1711WILLIAM H. BURNETT 1.00
······-·----···-·····--- ✓ 0 0 0
NATIONA 1• EXECUTIVE COMMITTEE 0.00
11a1WILLIAM R. ROY 1.00
✓ 0 0 0
:79) GEORGE A. BUSKIRK JR. 20.00
✓ 110,007 0 51,695
NATIONAL TREASURER 3.00
(60) c>HILIPG. ONDERDONK JR. 40.00
✓ 211,855 0 46.5~6
N6._TIONALJUDGE_~yo,c,·,AoTc,e~-+-~Oc,Oo0~-+--1-+--1--1---1--1-------i-------i------,
(611DANIELS. WHEELER 40.00
✓ 312,974 0 79.1305
NATIONAL ADJ UTA!\ T 1.00
I15::_:~.:.~~~!..~:.~~~~~~·-------------
1::xi:::cuTJVEDIRECTOR
✓
40.00
0.00
145 338 0 43.712
✓ 143,882 u 35.8\11
✓ 0 47,201
5/12/2016 2:03:50 PM 2015 Rel\.lm Tho A111orioanLogion

36·0144250
(A) Name ar,d TIiie (B) Aveiage ho_.-s (Cl Posilior1 (D) Reportablti [E) Ktipo1Milo (1-)t'stlmatf.d
perw~ek Ir.ho, all1hsle .,.,1 compurrnH~O!L c~mpen~~tion amlllml of olhar
(bl 111>1
hours for rolalod a
~ s •' ! fromlh9 from related compsnEalion
i t•'
or~onizalions b~uw organilat,ons from 1he
or_lJ~nlzalion
'l
dou,o lino) i 0
t! '
(W 11099--MISG) {l/l-2110fls-l.llSC) organlzatlcn and
related
I !' organizations
'•
I l
•
,,
IB~JSHAWN LONG
····--···--··-·············
40,00
....... ·········-······--...... ✓
' 113,159 0 58,171
DIRECTOR OF F,NANCE
(86) JOSEPH C. SHARPE
40.00
·····--··················-·••-'••·---··········· ✓ 27,421
DIRECTOR or
VETERANS
- ------------ 127,9971 0
~,..
EMPLOYMENT AND
_________. EDUCATION
---- - - ------- -- ---------- ·---- --
5112/2016 2;{)3;50 PM 2015 Return Ttle American Legion

" 35·0144250
Schedule B
(Form 990, 990-EZ,
Schedule of Contributors
or990-PFf
► Attac11to Form 990, Form 990-EZ, or Form 990-PF.
Oeparlment ol the Trea,;ury
InternalHeven"aSaNma ► l11formatlo11 or 990-PF)and its lnslructionsIs at www.lrs.~<wlform990.
about ScheduleB(Form990,9SO•!:Z,
Name of the organl:ta\lun
Tl--'EAMERICAN LEGION
I
Employor idontification number
35-0M4250
Organization type (check one):
Fliers of: Section:
Form 99Q or 990-EZ 0 50i(c)( 19 ) (enter number) organization
0 4947(a)(1) nonexempt charitable trust not treated as a private foundatiun
I I 527 polltlcal ocgaoimtloo
Form 990-PF D 501(c){3) exempt private foundation
D 4947(a){1) nonexempt charitable trust treated as a private foundation
D 501(c)(3) taxable private foundat'on
Check ii your organization Is covered by the General Rule or a Special Rule.

Note. Only a section 501 (c)(l), (8), or (10) organilation can check boxes for both the General Rulo .i,r.d a Special Rule. See
instructions.
Generut Aul@
0 For an organilalion filing Form 990, 990-EZ, or 990-PF that r0Ceived, during the year, contributions totaling $5,000
or Inore (in money or properly) !rom any one contributor. Complete Parts I and II. Sea instructio:is for determining a
contributor's total contributions.
Speclal Rules
0 For an organiw.tion doscribod in :ieciion 501{c)(3) filing Form 990 or 000-EZ that met the 33 1/a o/osupport test oi the
regulations under sections 509(a)(1) and 170(b)(1)(A)(vi),that checked Schedule A {Form 990 or 990-F.Z), Part 11,line
13, 16a, or 16b, and that received from any cne contributor, during the year, total contrioutions of the greater of {1)
$5,000 or (2) 2% of the amount on (I) Form 990, Part VIII, line 1h, or (iij Form 990-EZ, line 1. Complete Parts I and IL
0 For an orpanlzetlon described In section 501(0)(7), (8), or (10) filing Form 990 or 990-EZ that received from any one
contributor, during the year, total contributions of more than $1,000 exc!us/v~y for religious, chmit<1ble,scientific,
liternry, or educali.:itikll purFcsea, or for the prevention of cruelty to children O' animals. Complete Parts I, 11,and Ill.
[] For an organilatlon desc•lbed In section 501(c)(7), (8),or (10)filing folTTl 990 or 990-EZ that received from any one
contributor, during the year, contributions exclusivelyfor rallgious, charitable, e7c., purposes, out no sJch
contributions totaled moro than $1,000. If tr.is box is checked, enter hare the total contributions that were received
during the yem for an exclusively:eligious, charitable, !!IC., purpose. Do not complete any of the par:s unloss the
Gim,;iral Rule app:iss to this organization because it received nonexclusive!yreligious, charitable, etc., contributions
totaling $5,000 or more during tho your ► $
Caulion. An organization that is not covered by !he General Rule and/or the Special Rules does not file Schedula B (Form 990,
990-EZ, or 990-PF], but it must answer "No" on Part IV, li.1.i 2, of Its Form 980; or check the box on line Hof its Form 990-EZ or on its
Funn 990-PF, Part I, li11e2, to certify that it does not meet the filing requirements of Schedule A (Form 990, 990-EZ, or990-PF).
For Paperwork Rdll~!lon Act Notice, sn Ule fn,t,1,1ctlonofor Form SSO,S90·EZ, orS90-PF. Cat No, 30~13X S~had1,1le
B (Form 990, 990-EZ, or 90C-PF)I2o·n)
5112/20162:03:50 PM 2015 Retwrn The Ainerlcan Legion

" 35·0144250
Sch,xMo 8 (Fmm 990 990-[Z or 990-PF) (2016) Page2

Name of or9anl:cation I Employer ldentilication number
THE AMERICANLEGION 35-0144✓ ~0
l
l:t'.tlll Contributors (see ir.slructions). Use duplicate copies of Part I it additional space is needed.
i
[
1,1 lb) 1,1 {d) '
No. Name, address, and ZIP + 4 Total contributions Type of conMbution
1 Persun 0
Payrull □
$ 33,Bl>5 Nuncash [J
ICocrplalaPart II for
noncashcontributions.)
~
{a) lb) 1,1 {d)

No. Namo, address, and ZIP+ 4 Total contributions Type of contribution
2 Person 0
Payroll □
$ 31,689 Nonc.ish □
(CompletePart II !or
noncashcontributions.)
-·- . - .....
{a) {b) {o) {d)
No. Name, address, and ZIP+ 4 Total contributions Type of contribution
' Person
Payroll
0
□
$ 26,761 Noncash □
(CompletePart II 'or
noncashcontribs.11io1s.)
-
{ci) 1,1 ldl
I
lb)
'
No.
4
Name, i:lddress, 1md ZIP+ 4 Total contributions Type of contribution
Person 0
i
I
Payroll □ i
$ 25,958 Noncash □ I
(CompletePart 11lor
'
noncashconlributions.:,
1,1 {b) {o) {d)

No. Name, acldreiss, and ZIP +4 Total contributions Type of contribution
-·
5 Person 0
Payroll □
$ 20,243 Noncash [J
(CompletePart II for
noncashoontrlbutlon~.)
--···
{o)
No.
-
{bl
Namr:, address, and ZIP+ 4
1,1
Total contributions
ldl
Typo of contribution
-- ·-·
Ii
I
6 Person 0 '
$ 16,500
Payroll
Noncash
(Comp:etePart II tor
□
□ l
l
n □noash conlrlbullonG)
, ....
Schorlule 6 jForm 990, MIO-EZ, or 990-PF) (201S1
5112/2010 2:0~:5'0 PM 2015 Return The American Legion

36-0144260
0 . .
Name of org:rnizatlon I Employer ldenllflcatlon number
THE AMERICANLEGIO,\J 35-01442(;0
1:/rtil ■ Contributors (see Instructions). Use duplicate copies of Part I if additional space is needed.
(a)
No.
7
(b)
Name, address, and ZIP + 4
(cl
Total contributions
(d)
.
Typa of contribution
Person I"]
!
Payroll D
$ 15,tl35 Noncash D
{Complo1oPart 11for
oofl(:as:1 contributions.)
-----
(al (b) (cl (d)
No. Name, address, and ZIP+ 4 Total contrlbulions Type of contribution
8 Person I"]
Payroll D
$ 15,000 Nonces!,
□
{Complete Part II tor
noncash c~nlril>ull<J11~.)
(a) (bl (c) (di

No. Name, address, and ZIP + 4 Total contributions Type ol contrlbutlon
a Person I"]
Payroll D
$ 13,254 Noncash D
(Ccmpl~te Pait II for
n~ncashcontributions.)
(al (bl (c) (di

" Person
Payroll
I"]
□
$ 10,123 Noncash
□
(Complete Part II for
noncash contrillu1ions.)
1,1 (bl (c) (d)

Ne. Name, address, and ZIP+ 4 Total contributions Type of contribution
11 Perscn I"]
Payroll D
$ 10.106 Nonoa:;,h D
{Cor:-ipletsf>ar1II for
ncmcashconlrihutirins.)
- - --- --
[a) (b) lei (d)
No. Name, address, and ZIP + 4 Total contrltlutions Typo of contribution
-,
12 Person I"]
Payroll D
$ 10,000 Noncash
□
{Complolo Part 11101
noncash cont,lbutlons.)
Sctwdulc B (Form 990, 990.EZ, or 991)..PF)(2015)
5/1212016 2:03:50 PM 19 2015 Return The American Legion

35-0144250
Schcdul~
B (form990,ij90-EZ,or 980-rF){2015) Paga2
l
Nanleof organization Employer idenllllcalion number
lH!'" i\Ml-,RICAN LEGION 35-0144250
1:.fflHContributors {see instructions). Use duplicate copies of Part J if additional space is needed.
--------- --------
{a{ {bj {ol (di
No. Name, address, and ZIP+ 4 Total contributions Type of contribulion
------------·
0
" Person
Payroll
□
$ 10 000 Noncash □
(CompletePart 11lor
noncash con1rlbutlons-}
-· {a) - - - ---
(dj
(bl (oj
----------- ------
0
" Person
Payroll n
$ 10,000 Noncash
□
{CompletePart II 101
nm1oashcontributions.)
{al lb) (oj (di

15 Person 0
Payroll
□
$ 10,000 Noncash
□
(C.:omph:1te
Part ll for
noncashcontriou11orm.)
-13) ___---
(bl 1,1 (dj
No. Name, address, and ZIP+ 4 Total conlributions Type of contribution
----- - ·--- - - --
16 Person 8
Payroll LJ
$ 7,500 Noncash C
(CompleteP.artII lor
noncashconlrilrulior.s.)
-- -----
(a) {bl {oj (di
No. Name, address, and ZIP+ 4 Total contributions Type of co11tribution
17 Person 0
Payroll
□
$ 7,200 Noncash D
(ComplotePart II tor
r.oncashconlributir.nR.)
---- ~ --{bl-·
{•I (ol (dj
No. Name, address, and ZIP + 4 Total contributions Type of contribution
-
'" Person
Payroll
0
D
$ 7,000 Noncash
□
(Comple1aP11rtII for
noncashcon!ribu1ions.)
I
5/12/20162:03:50 PM 28 2015 Relum The American Legion
35-0144250
S~h&du:e
B (Form990 990-EZor990-PF) (201~) Pago 2
Name of organi~ation IEmployer identification number
THE Al.(ERICANLEGION 35-0144250
■ ®JI Contributors (sse instructions). Use duplicate copies of Part I lf additional space is needsd.
. ..
1,1 (b) (c) (di
·-·--·
'9 Person 0
Payroll □
$ 6.328 Noncash [J
(Complc>le Parl II tor
noncashconlrlb~tlons.)
M lb) lei Id)

No. Name, acldress, and ZIP+ 4 Total contribulions Type of contribution
20 Person 0
Payroll □
□
I!
$ 6,00:J Noncash
(CompletePart II101
noneash con!ribJtions.)
- -
1,1 lb) (c) Id) ;
No. Name, address, ,md ZIP + 4 Total contributions Type of contribution
21 Person 0
Payroll □
$ 6,000 Noncash □
(Comple!ePart 11lor
noncashcon1ribull~ns.)
1,1 lb) lei ldl

No. Name, addre:.s, and ZIP+ 4 Total contributions Type of contribution
,, Person 0
Payroll n
$ 5,994 Noncash □
{Compleie Part IItor
noncashcontributions,)
1,1 (bl 1,1 Id}

No. Name, addres:., and ZIP i- 4 Total contributions Type of contribution
23 Person 0
Payroll u
$ S.014 Noncesh
□
(CompletePart II for
noncashcontrlb~lkin~.)
1,1 lb) 1,1 Id)

'4 Person 0
Payroll □
$ 183,383 Noncash □
{Complelt1Part II for
noncMh ccntrlt111tlons.)
Sche<fut&B (Form990, 9B0-EZ, or 890-PF) (2015)
5/12/2016 2:03:50 PM 21 2015 Return The American Legion

35-0144250
Scnedula B iFur,,,J~O, 890·EZ, or 930-Pf) (7015) Page 2

I
Nsime of or9,mlzation Employer !denlllica11011 number
Tl I[ NY1ERICANLEGION ~5-0144250
iiJ:MII Contr'butors (see Instructions) Use duplicate copies of Pait I If addltlonal space rs needed
'
fI
(a) lb) (e) {d)
No. Name, address, and ZJP + 4 Total contribulions Type of contribution
-
25 Pernon Id
Payroll D
$ 250,1S5 Noncash D
(CompletePart ·1ior
noncash contr1b1.1tion~.)
---------
{al {b) 1,1 ldJ
Person D
Payroll D
$ Noncash D
(ComplateP~rt JI for
noncach con1ribulions.)
{al (b) 1,1 [d)

No. Name, address, tmd ZIP + 4 Total contributions Type of contrlbutlon
---- -- ---
Person D
Payroll D
$ Noncash D
(Complel!>Part II for
~oneash contributio.1s,)
[a) [bl 1,1 {d)

No. Name, address, and ZJP + 4 Total contributions Type of conlribullun
- -----
Parson D
Payroll n
$ Noncash D
{ComptatePart II for
noncach contribuHons.)
-
l•I [b) 1,1 [d)
No. Name, .iddress, and ZIP + 4 Total contributions Type of contribution
Person D
Payroll D
$ Noncash D
(GomplelePart 11!~r
normashcontribulions.)
{a) {bl {o) [dJ

Person D
Payroll D
$ Noncash D
(Comple1ePart II for
nrmoashoonlr1buUoris.)
Schedule B (F'onn 990, 990-EZ, or 9~-Pf) !201~)
5/12,2016 2:03:50 PM 22 2015 Return The AmE>rleanLegion

35-0144250
~cl.cdulo B (Fo,r, g90 MIOEZ " rMO PF) (2015)

0
Pnge 3
C
"
Nanw of oreanl:;i:ation I Employer identi!Jcalion number
THF AMFRl:":AN !.FGION 35-0144250
l:ttlll Noncash Property (see instructions), Use duplicate copies of Part II if additionl:11space is needed,
(a) No. lo) {d)

(bl FMV(or estimate)
from Description of noncash property g!ven Date received
Partl (see Instructions)
$
- - -------- -----
(a) No. {c)

{bl FMV {or estimate)
(di
from Description of noncash property giveI1 □ ah, received
Part I (sea Instructions}
"
(a) No.
lb)
1,1 (d)
from FMV(or estimate) D.:1ttireceived
Description af noncash pi'operly given (:1eeInstructions)
Part I
(a) No, (c)

lbl (d)
from FMV \or estimate)
Description of noncash property given (see Instructions)
Date received
Pmtl
--
(a) No. (c)

(bl {d)
from FMV(or estimate) Date received
Description of noncash property given {see Instructions]
Part I
(a) Ne. (c)

{b) (d)
from FMV (or estimate) Data received
Descriplio11 of noncash property given {sea Jn5trucllone)
Part I
- ---- ,
$clmlule S (Form990, ~00-EZ, or 900,PF) (2015)
2015 Return naAmeric~n Legion

~,'12/20162:D3:~0 PM
" 35-0144250
Soh<ac!ule!o ~orm 990, 9\lO·EZ, or 99D-f'I-) (2015) rage 4

Name of org,miz.ilion Employer identiflcat1on numbe1'
TH[ AMCRICANLEGION 35-0144250
.' Exclusively religious, charitable, etc., contributions to organizations described in section 501fc)(7), (8), or
{10) that total more than $1,000 for the year from any one contributor. Complete columns (a) through (e) and
the following line entry. For organizations completing Part Ill, enter the total of exclusively relig:ous, charitable, etc.,
contributions of $1,000 or less for the year. (Enter this information once. See instructions.) ► S
Use dun!icate conies of Part Ill if additional s□ace is needed.
1:.!I,.o.
(mm (b) Purpose of gift (c) Use of gift {d) Description of how gift is held
Part I
{e) Transfer of gift
Trnnsferee's mime, address, ~nd ZIP+ 4 Relationship of transferor to transferee
l~,,.o.
rrom (bl Purpose of gift (c) Use of gift (d) Description of how gift Is he!cl
Part I
(e) Transfer of gift
Transferee's name, address, and ZIP+ 4 Relationshlp of transferor to transferee

·-·-
l<II~o.
from (b) Purpose of gift (c) Use of glft (d) Descrlp1lon of how gift Is held
Pan I
(e) Transfer of gift
Transferee's name, address, and ZIP+ 4 Relationship of transferor to tran.sror1;10

-----·---
··--
\~) No.
lrom (b) Purpose of gift (c} Use of gift (d) Description of how gift is held
Part I
(e) Tramifor of gift
Transferee's name, address, and ZIP+ 4 Relationship of transferor to transferee
Sched~I~ B (Form 990, 990-EZ,or 990-PF){20151
5/1?/2016 2:03:50 PM 24 2015 Return The Arr.erican Lflgion

35-0144250
SCHEDULED 0MB No. 1515,0'HI

(Form 990) Supplemental Rnanclal Statements
► Complete If the organl~tlon answered ''Yes" on Form 990,
l
Par1 IV, llne 6, 7, B, 9 1 10, Ha, 11 b, 11c, 11d, 11e, 1H, 12a, or 12b.
0ope1m•nl ol thaTnaaswy ► Attach to Fctm 990. Open to Publ/c
lntorr•I ~Gv,invoS<il'li~e ► Information aboul Sot1eduleD {Form 990) and its instructions is al www,in.,govlformD90. Inspection
Namg of the organization Emplorar ldentlticatlon 11~mber
THE AMERICAN LEGION 35"01442~0
i®ill Organizations Maintaining Donor Advised Funds or Other Similar Funds or Accounts.
Comoel t e 1'f th e oraanizat"10nanswersd "Y es on Forrn990 Part IV I',ne6
'
(a) Oooor advised kN1da
' [b) funds ,mclolheraccov~t•
1 Total number at end of year .

2 Aggregate value of contributions tc [during year)
3
4
Aggregate value :>Igrants from (during year)
Aggregate value at end of year ,
-- l
5 Did the organization Inform all donors and donor advisors In writing that the assets neld In donor advised
funds are the organization's property, suoject to the organization's exclusive legal control? D Yes D No
6 Did the u1g1miiation inform all grantees, donors, a1d donor advisors in writing that grant funds can be usad
only for charitable purposes and not for the benefil of the donor or donor advisor, or for any □their purpose
conferring impermissibl0 private b0neflt? D Yes D No
1:/MIII Conservation Easements,
Complete if the orga~!zaf_!_~n_a!}~_°'."'~.r~£~'.Y_!!_~~~-9_Q_
____ Fo0rrn=9
09
0 00 , 0P0a0rt0 l0V0, 0lin
0 e~?
0, ____________ _
1 Purpose(s) of conservation easements held by Hie org1.1nization(check t1ll lhat 1,pply),
D Preservation of land for public use {e.g., re,-:reattonor education) 0 PreseNation of a historically important land area
[__JProtection of natural habilialt LJ Preservation ot a certified historic structure
D Preservation of open space
2 Comp le le lines 2a t11rougt12d i1the organization held a c;ualitied conservalion contribution in the form of a conscr vat1on
a
easomont 011 :he last dayol the tax year.
Total number of conservation easements
- ,,
Holdall~• End ot !11&Ta~ Year
b Tot21I~craaga restricted by conservation easemants. 2b

c Number of conservation easerrents on a certified historic struciure included In (a) 2c
d Number of conservation casements Included in {c) acquired after 8/17/06, and not on a
historic structure listed In the National Regls1er 2d
3 Number of conserv<ttlon easements modified, transferred, released, extinguished, orterminated by the organi2at1on during the
tax year ►
4 Number of states where property subject to conservation easement Is located ►
6 Does the organization have a written policy regarding the periodic monitoring, lnspectlo,1, handling of
violations, and enforcement of the conservation easements It holds? O Yes D No
6 Staff and volunteer hours devoted to monitoring, Inspecting,liandling of ;'iOIPlions,w1denlurcing clJnservuti011
eolsumcntsduring Ille year
►
7 Amwu11tof expen~es incurred in monitoring, inspecting, handling of violations, and enforcing conservation easements during the year
►$
8 Does each conservation easement reported on line 2(d) above satisfy the requirermmtl:Iof section 170{h}l4){B)(i)
and section 170(h)(4HB)(ii)? , . D y 66 O No
9 In Pa11XIII, describe 110wthe organization reports conservation oascmonts in its revenue and expanse stateme.1t, and
balance sheet, and include, if applicable, the text of the footnote to the organization's flmrnclal statements that describes the
organization's accounting for conservation easements.
1@111 ■ Organizations Maintaining Collections of Art, Historical Treasures, or Otller Similar Assets.
Complete if the organization answered "Yes" on Form 990, Par. N, 'ine e.
1a If the organization elected, as permitted under SFAS 116 (ASC 958), not to report In Its revenuo statemen'. and balance sheet
works of art, historical treasures, or other similar assets held tor public exhibit;on, education, or research in furthc1rance of
public service, provide, in Part XIII, the text of the footnote to Its financial sta1ements.the.I describes these Items.
b If the organization elected, as permitted under SFAS 116 (ASC 958), to report in its rever:ue statement and balance sheet
works of art, historical treasures, or other similar assets held for public exhibition, education, or research in furtherance of
public service, provide :he following amounts relating to these Items:
(i) Revenue included on Form 990, Part Vl!I, line 1 ► $
{ii)Assets Included In Form 990, Part X , . ► $
2 If U1e urgani.:alion rec~ived or held works of <lrl, hisloriolll treasures, or other similar assets for financial gain, provide tile
following amounts required to be reported under SFAS 116 {ASC 958) relating to these Items:
a Revenue included on Form 990, Part VIII, line 1 ► $
b Assets included In Form 990, Part X ► $
F\lr Paperwork Fleduotion Act Notioe, ~ee th11ln~tructione for Form 880. Ca1.No.s~2a~u Sehadule o jform 990) 201~
2015 Return Thi, Arnerioan 1-.eglon

5/12120162:03:50 PM
" 35-0144250
Scl,edula I) (Fo,m 900) 2015 Poge 2

l:fflHIII
Organizations Historical Treasures, or 6iher Similar Assets (continued)
Maintaining Collectio!J:I of Art, __
3 Using the urganimtion's acquisition, accession, and other records, check any of the following !hat are a s,'gnfflcan( ~'se of it~
collection items (cheok all that apply):
a 0 Public exhibition d 0 Loan orexchange programs
b 12] Scholarly research
c 12] PreservatiOfl for future generations
• □ Other
4 Provide a description of the organization's collectlol'l.S and explain how they furt~,er the organization's exempt purpose in Part
XIII.
5 During the year, cid the organization solicit or receive donations of ar:, historical treasures, or other similar
assets to ba sold to raise funds rather than to be maintained as part of the organization's collection? □ Yes 0 No
1:tfll\!I Escrow and Custodial Arrangements.
Complete If the organization answered "Yes" on Form 990, Part IV, line 9, or reported an amount 011 Form
990, Part X, line 21.
0,~,c
--,,-.,,~11°,,-0-,-ganl?8tioi-i-a- 0c,c,.,,,,c.,,,c.,c,c,-,c,,,c,oc~s-c,c,coc,c,c,,h•e",
"lo"t'ec°'mc::,,c;c,c,y;.,fo",•o•o","trlbutlor1s"
ci( otherassets not
included en rorm 990, Part X? D Yes D No
b If "Yes," explain tho arrang~ment i.1 Part XIII and complete the following table:
Amoud
c □ eglnning balance •
'
1o
d Additions durir;g the year 1d
e Distributions during the year 1,
2.i
Ending balance • 1f
Did the o.'ganization include an amount on Form 990, Part X, line 21, for escrow otcustodlal 1:1ccoun,Jiabll/ty? . D Yes □ No
b If "Yes," ex lain tho arrangement In Part XIII. Check here If the ax 1anaticn has been rovlded on Part XIII
EndolNlllent Funds.
□
Complete if the ori:1anization answered "Yes" on Form 990 Part IV line 10
(at C~rrentyear (bl Prmr year ' '
(al TWPyears back (d) Th"'• years bick {~IfQ~r y~an: b.ack
1a Beginning of yoar balance 15,090,143 14,278,098 15,176,074 14.765,211 11,230,'106
b Contributions 137,774 319,639 156,188 55,529 84,538
C Net investment earnings, gains, and
r---
losses • 278,087 9551,594 :s26,09oJ 852,319 964,188
d Gra11tsor scholarships 400,287 454.141 '-85,510
Other expenditures for facilities and
' programs 468,952 468.188 46,767 4:J,844 28,411
f Administrative expensos
g End of irear balam;e 15,037,052 15,090,143 14,279,098 15,176,07'1 14,755.21'.
~
2 Provide the est/mated percentago of tne current year end balance (line 1g, column (a)) held as.
a Board designated or qua:,1-endowment ► o.oo%
b Permanent endowment ► 86.85 %
c Temoorarily restricted endowment ► 13.15 %
The percentages on lines 2a, 2b, and 2c should equal 100%.
3a Ale thoro endowment funds not In the possession of the organization that are held and administered for the
organization by:
Yes I No
(i) unrelated organizations 3a(i) v
(ii) related organlta1iur1s . a(iil v
b If "Yes" on line 3a(II), an; the related organizations listed <1srequired on Schedule A? 3b v
4 Dcso:ibo in Part XJIIthe intanded uses of the organizat10.1's endowment funds.
1@191 Land, Buildings, and Equipment.
Complete if the oraanIzatIon answorod "Yes on Form 990, Part IV, line 11a. see Ferm 990, Part x, ine 10.
Description of prop,.,rty (a) Costcrotherbasis {b) Cmtorollierbao;a {o) Accumulated (d) Book valuo
Qnves1m.,,,IJ (~lhlll) depreciaUon
1a Land 469.21;4 . - 469,264
b Buildings 9,399,060 ll.115.147 3,283,913
C Leasehold imprOVt,Jrfl0fltS
f-----t----;-;~;:;-t----,-,~"1------304,BQ6 67,993
--216,613
d
e
Equlpment
Other
7,567,789 6,265,41S 1,302.374 I
1!
I
Total. Add lines 1a throuqh 1e. /Column mus/ aqua/ Form 890, Par! X, column IB! line 10c.) . ,► '
I
I
S~he~~I&D (Form 990! 2015 t
'"'
I
5/1212016 2:03:50 PM 26 2015 Return The American Legion
35-0144250
"!
Schec!ula D [Fon11
990)2015 Page 3
1$1?11 Investments Other Securities.
Comr lete it tile organization answered "Yes" on Form 990, Part IV, line 11b. See Form 990, Part X, l_i!"!~
(a} Dascription of oecu,ily ar ualeyory (b) Book value (~) Meihod o1 valualion:
~neluding name of oomrrity) Goat or ernJ•o'·\'ear mrrket value
{1) financial derivatives

-- --
t
\2) Closely-held equity interests I ---------- -
(3) Other
!Al
(DI
(C)
------
(DI
IEI - -
l>I ------
(G)
..
IHI
Total.(Co/1mm Pa~X,col.IBIUoo12,1►
(b)mi!Sleq11aJF01m
99/J,
Investments-Program Related •
. ...
Complete if the oraanlzation answered "Yes~ on Form 990, Part IV, line 11c. See Form 990, Part x,_line 13.
[Q) Description of Investment (b) Boal<.va!Ue (o) Method of valual1on:
Gcsl o, end-~f-1·ear rnarKel value
111
/21
131 '
141
ISi - .. --
ISi
,.
171
191
.
... --
-
----- --- -- ------

Total.(Coiumn ParlX.eel.'B)/IM13.)►
(b/mus/equalFcrm990,
. Other Assets .
Complete II the organization answered "Yes" on-------
Form 990 Part IV line 11d See Form 990 Part X line 15
-
\!I)::i~scrlpllon ' ' ' lbl Boo~'value
--
/11
,,,
121 -
··--
141
,,,
/SI ....
m
1,1
ffi/
Total, (Coiumn(b) musr equal Form 990, Parl X, col. (B) line 15.) -►
. Other Liabilities •
Comploto 1fthe orgarnzatIon answered ''Yes" on Form 990, Part IV, line 11e or 11f. See Form 990, Part X,
line 25.
1. M Llescriptionol l1atil1ty (bi Hoof: value
(1) FcCoral Income taKes
(2) LIFE MEMBERSHII' ou~s. JU~ ro $TAYE AND LOCAL POST 24,962,632
-(3) OTHER LIABII.ITIES 1,262,971
(4)" DEPOSITS ON EMBLEM MERcHANorsE
SALE :394,662
ISi
161
171
181
ISi
Total.((,U!um~
l{))mus/equo! Form990,P/111X,w/./8)!ilie25.)► 26,620,265
2. l.iabil;tyTo"f
·uncertain tax poslllons. In Part XIII, provide th<1text of the loolnoli1 to ll1eurganluition's !irmncial statements that reports the
organization's liability for uncerh1int.ix positions under FJN48 {ASC 740). Check hereIf the text of the footnole has b<:ienprovided in Part XIII E]
Sch5dule D (Fo•m 990) 2015
5/1212016 2:03:5() PM 27 2015 Return The American Legion

35-0144250
Schedule D [Form 990) 2015 Page 4

1@131 Reconciliation of Revenue per Audited Financial Statements With Revenue per Return,
Complete 1f · the oroanization answer ed "Yes " on Form 990 P rt IV I'1ne~2 ,.
1 Tota! revenue, gains, and other support per audited financial statements
' ' '
1 ----
2
'
Amoun:s included on line 1 but not on Form 990, Part VIII, line 12;
Net unrealized gc1lns(losses) on lnve<>tmenls
b Donated services and use of facilities
,.
2b
Recovorics of prior your grants . 2,
'
d Other (Describe in Part XIIL) .
• Add lines 2a through 2d
2d
,,
3 Subtract line 2e from line 1 3
4 Amounts Included on Form 990, Part VIII, line_12, but not on line 1.
• Investment expenses not Included on Form 990, Part VIII, line 7b
b Othe~ (Describe in Part XIII,) .
••
4b
.
' Add lines 4a and 4b
5 Tola revenue. Add lines J and 4c. (Thi1;; mus( equal Funn 990, Part f, fine 12.) "5
Reconciliation of Expenses per AUdited Financial Statements With Expenses per Return •
Complete if the orqardzation answered "Yes" on Form 990, Part IV, line 12a.
1 Total oxpem;es and losses perai;dited financial statements 1
-·-- ----
2
•
Amounts included on line 1 but riot on Form 990, 1--'artIX, line 25:
Donated services and use of facilities ,.
b 1--'rioryear adjustments
C Other losses . ,,
2b
d Other {Describe in Part XIII.) . 2d
3
• Add llnes 2a through 2d
Subtract line 2e from llne 1
2,
3
4 Amounts included on Form 990, Part IX, line 25, but not on line 1:
• Investment expenses not Included on Form 990, Part VIII, line 7b
••
b Other (Describe in Part XIII.) .
Add lines 4Q and 4b
4b
4c II
.'5
'
Total expense:.. Add lines 3 1arir.J4o, (This mwt equal Form 990, Part/, h'ne 18.) . 5
Supplemental lnformatio_n_ • I
I
----
Provide the descnpt1ons required for Part 11,lines 3, 5, and 9, Part Ill, lines 1a and 4, Part IV, lines 1b and 2b, Part V, lrne 4, Pat1 X, line
2; Part XI, lines 2d and 4b; and Part XII, lines 2d and 4b. Also complete th.ls part to provide any additional information.
SEE NEXT PAGE
'
Scl1ed~lo D (Form 090) 2015
5/12l2016 2;03:50 PM 28 2015 Re1um The Ameri.:Pn J,~glon

35-0144251}
Part Xlll 8upplemenlal Information. Providelhe de$Crlptlonsrequired [or Port 11.liffils 3, !i, and 9; Part Ill,
IInes 1a and 4; Part IV, lines 1b and 2b; Par1V, llne 4; Part X, lino 2; Part XI, lines 2d and 4b; and Part
XII, lines 2d and 4b. Also eomplelethis part lo provide any addiliunal lnformo1t:on.
Ratum Roforo11~0 hfontifiar ,C)(nlanalion

SCI IEDULE D, PART 111, 1HE LEGION OWNS MANY COLLECTIBLE MILITARY RELATED ITEMS AND HISTORICAL UOClJMENTS WHICH
LINE 1A- COLLECTIONS WERE NOT RECORDED AS THEY WERE ACQUIRED. !TIS OFTEN IMPRACTICAl:ILE TO DETERMINE A VALUE
OF ART - FINANCIAL FOR COLLECTIONS AND ACCORDINGLY, Tl-IE LEGION HAS CONCLUDED "IHAT THEY NEED NOT 0[
STATEMENT FOOTNOTE CAPITALIZED. SOME OF THESE ITEMS HAVE BEEN APPRAISED FOR INSURANCE PURPOSES. -
SCIIEDULE D, PART Ill, THE COLLECTION OF 10,000 BOOKS AND MAGAZINES CAN BE A STARTING POINT FOR RESEARCH IN
LINE 4 - COLLECTIONS OF MILITARY HISTORY. THE ROLE OF THF VF:TERAN IN AMERICAN SOCl[TY, AND, OF COURSE, l"HI::
ART - D[SCRIPTION OF DEVELOPMENT OF THE AMERICAN LEGION ITSELF. THE LIBRARY CONTAINS A SMALL BUT IMPORTANT
COLLECTIOt\S COLLECTION OF POST AND DEPARTMENT HISTORIES. THE MUSEUM AREA HAS RE:LICS ANO ITEMS FROM
WORLD WAR I. THE FINE ARTS ROOM ISAN AREA THAT ALLOWS rn~E TO REFLECT ON SYMBOLS OF OUR
HISTORY.
SctlEOULE D, PART V, WORLDWIDE ELECTRONICS LEADER SAMSUNG ENDOWED A SCHOLARSHIP FUND OF $5 MILLION Bl,c ro
LINE 4 - INTENDED USES ADMINJSTERED BY THE AMERICAN LEGION IN 1996. MEANT TO SHOW APPRECIATION fO~ U.S. VETERANS
OF ENDOWMENT FUNDS WHO CAMe' TO l<OREA'S AID DURING ITS STRUGGLE AGAINST COMMUNIST FORCES IN THE KOREAN WAR,
rHt:: SAMSUNG AMERICAN LEGION SCHOLARSHIP PROGRAM ESTABLISHED A.SERIES OF SCHOLARSHIPS
UERIVFDFROM INTEREST AND OTHER INCOME FROM THE PRINCIPAL AMOUNT, SCHOLARSHIPS ARE
RF.STRlCTED TO HIGH SCHOOL JUNIORS WHO COMPLETE EITH"-K/1 BOYS STATE OR GIRLS STATE
PROGRAM AND ARE A DIRECT DESCENDANT- I.E. CHILD, GRN'lr)CHII.P, GREAT GRANDCHILD, ETC. -OR A
LEGALLYADOP1Ecl CHILD OF AV/AR.TIME VETERAN WHO SERVED ON ACTIVE DUTY DURING AT LEAST ONE
OF THE PtR!ODS OF WAROFFICIALL YOESIGNATEDAS ELIGIBILITY DATES FORAMEmCAN LEGION
MEMBERSHIP. SAMSUNG SCHOLARSHIPS ARE FOR UNDERGRADUATE STUDY ONLY AND MAY BE USED I-OK
TU ITJON, SOOKS, FEES, AND ROOM ANO BOA.RD. WINNERS ARE SELECTED ACCORDING TO ACADEMIC
RECORD, INVOLVEMENT IN SCHOOL AND COMMUNITY ACTIVITIES, COMMUNITY $CR.VICE AND FJ~ANCI/\L
NEED. APPLICANTS WHO ARE DIRECT DESCENDANTS OF KOREAN WAR VCTCRANS WILL RECEIVE SPECIAL
CONSIDERATION.
AMC::RICAN LEGION ENDOWMENT FUND CORPORATION, A RELAIED ORGANIZATION, HOLDS ASSETS IN A
Pl:RMANl:NfL Y RESTRICTED FUND FOR THC SOLE PURPOSE OF SUPPORTING THE PkOGHAMS OF
AMERICAN LEGION NATIONAL HEADOUARTCR_S,
SCHEDULED, PARTX, THE LECION IS EXEMPT FROM FEDERAi- iNCOME TAXES UNDER SECTION 501(Cl(1g)OF THE U.S. INTERN,\l
LIN[ 2- FIN 46 (ASC 740) REVENUE CODE. ALC.ALEF AND NEF ARE EXEMPT FROM FEDERAL INCGME TAXES UNDER SECrlON
FOOTNOT[ 501(0)(3) OF THC U.S. INTERNAL REVENUE CODE. NONE OF THE ENTITIES ARE CONSIDERED BF.A ro
PRIVATE 1-0UNDATION. THE LEGION IS SUBJECT TO INCOME TAX ON UNRELATED BUSINESS INCOME. IN
2015AND 2014, THF. LEGION INCURRED NO TAX EXPENSE.
CUKRCNT ACCOUNTING STANDARDS REQUIRE THE LEGION TO DISCLO.SE THEAM:JUNT OF POTENTIAL

BENEFIT OR OE3LIGATION TO BE REALIZED AS A RE SUL r OF AN EXAMINAI ION PERFORMED DY A TAXING
AUTHORITY, FOR THE YEARS ENDED DECEMBER 31, 2015 AND 2014, MANAGEMENTi IAS DETE~MINED THAT
THE LEGION DOES NOT HAVE ANY TAX POSITIONS THAT RESULT JN ANY UNCERTAINTIES REGARDING THE
POSSIBLE IMPACT ON THE LEGION"S FINANCIAL STATEMENTS. THE LEGION DOCS NOT EXPECT THE TOTAL
AMOUNT OF UNRECOGNIZE\J TAX 1:1"-NEFITSTO SIGNIFICANTLY CHANGE IN THE NEXT 12 MONTHS. THE
LEGION RECOGNIZES INll:;Ht;ST AND/OR PENALTIES RELATED TO INCOME TAX MATTERS IN INC0,,1E TAX
EXPENSE. THE LEGION DID NOT HAVEANYAMOUNTSACCRU~ f'OR INTEREST AND PENAL TIES AT
~
DECEMBER 31, 2015 AND 2014
511212016 2:03:50 PM 29 2015 R11tum Th11American Legion

35•0144250
Supplemental Information Regarding Fundralslng or Gaming Activities 0MB No. 1546-C047

SCHEDULEG Complole if lho organlz&llc>nanswered 'Yao" on Form lHIO,Part IV, lines 17, 111,or 10, or If Iha
(Form 990 or 990-EZ} organi.>ntlon entered moro than $15 1000 on Form 990-EZ, lin~ Sa.
► At1ach to FormOSOor Formll90-EZ.
Oapar.mentof \hoT1ea,~,y
ln1ernalHov""'"s.,,,,rce ► !nfarmatkm aboot S~hodulo Q (Form990or 990-EZ)and ii, instructions ls at www.lrs. ov/form900.
Name of the organization Employer ldentlfloaUon number
THE AMERICANLEGION 35-0144250
Fundraising Activities. Complete if the organization answered "Yes" on Form 990, Part IV, line 17.
1:/MI ■ Form 990-EZ tilers are not required to complete this part.
1 Indicate whether the organf,:atlon raised funds through any of the Joilowing activities. Check all that apply.
a Fi] Mailsolicilations e 0 Solicltatior1 of non-g:ivornment grants
b 0 lnterriet ai1d email solicitations D Solicitation of government gran1s
c D Phone solicitations g 0 Special fundraising events
d 0 ln·p!:lrson solicitalions
2a Did the organization have a written or oral agreement with any Individual (including officers, directors, trustees
or key employees listed in Form 990, Part VII) or entity in connection with professional fundraislng services? El Yes D No
b If "Yes," list the ten highest paid individuals or enllties (fundraisers) pursuant to agreements under which the fundralser Is to be
compensated at least $5,000 by the organization,
- ·-···
(vj Amount p,ild lo (v~ Amount paid lo
(Ill) Did fundralscrllovc
11)Na,r,e ond add,ess of lndlvlduol
:11)
Activity custody 01 conlrol ol
llv) GrosHocelprs 1o, retained by) or rel~ined Dy)
01a.1llly(f'Jndralser) from aohvify 1...-idraiserlisled I~ o,gani.elion
oowl~utlons1 col.(IJ
Yes No
CONSULTSON
1 EDGE DIRECT, LLC PO BOX
840, TULSA, OK 74135
DIRECT MAIL
PROGRAM
v 1C,219,577 4,960,935 b,~68.542
-
2 RESOURCE ONE PO BOX 839,
TULSA.0K74110
v 502,115 3.977.006 (3,474,891)
·-·· ~
3 ~IRS f 01,.t.l<Tolc.LLC4;JOOTULLAWORE 1uu,~uuLTiNG

ESTATES flr1AM, <'lA!NFSVILLE,VA 201~6 v 634,851
4
·----
10
--
10,721,692 9,562.,792 1,7~3.751

Total . . ►
3 List all slates 1n which the orgamzal1on IS registered or licensed to sol1c1tcontnbut1ons or has been nolil1cd 1tIS exempt from
regi~trat!on or llconsing.
AL, AK,AZ, AR, CA, CO, CT, PE, OC. FL, GA, HI, ID, IL, IA, IN, KS, KY, LA, ME, MD, MA, Ml, MS, MO, MT, NE, NV, NH,
~•W~~~m~M~mmno~~~•~m~~
For Paperwork Reduction Ao! Notlce, see lhe ln~tructlon• lor Fo111r
900 or 900-EZ, Cat. No, 5QOl!~H Schedl.lle G (Form 980 or 990-!CZj Z015
5112120162:03:50 PM 30 2015 Retlm1 Tho American Legion

35-0144260
Schadula G {Form 9~0 or ~ao-EZ) 2015 Page 2

l:.ETHII
Fundraising Events, Complete if the organization answered "YBs" on Form 990, Part IV, :ine 18, or reported more
than $15,000 of fund raising event contributions and gross income on Form 990-EZ, lines 1 and 6b. List events with
gross receipts greater than $5 000
' (a) E~ar,I Nl {b) Event U2 (c) Otl'\er ev,mla
(di lotalesems
LEGACY RUN (.idd col. \al t~rouJh
co. (c))
(evem type) (asenl ty~o} (!<>!al
numba·I
•,
C
70,354
!0, 1 Gross receipts 70,354 ~
2 Less: Contributions 70,354 70,354

Gross income (lfne 1 minus
' line 2} . 0 0 0 C
4 Cash prizes 0
5 Noncash pri.:es ---

0
8
0,
C
•
~
,lj
ti
a
'
7
8
Aent/laclllly costs
Food and beverages
Entert~lnment
------
0
0
I
n
9 Other direct expenses 77,758 77,758
10 lJireot expense summary, Add lines 4 through 9 in column (d) ► 77,758

11 Not income summary. Subtract line 10 from line 3, co!umn (d) ► (F,/ti8)
.. Gaming, Complete if the organization answered "Yes" on Form 990, Part IV, line 19, or reported more
than $15 000 on Form Cl90-EZ line 6a
C
' (d) Tctal garr.lng (ad~
ID {OI Pu:I labs/instant
(a) Bingo (cj Otl!er gaming
0 blni;nJ/prograss!vabingo cul. la] t~rou!Jllcol. ,:c))
C
ID
>
ID
oc 1 Gross revenue
Casi', prizes
fil
~
ID
'
~ Noncash pri;.;~s
X
w ' •e••
1 4
5
AenVfacilily cosls
Other direct expenses_

1---------,---- ..
. -
D Yes % D Yes % D y., %
6 Volunteer labor . D No D No D No
7 Direct expense summaiy. Add lines 2 through 5 L1column {d) ►
Net gaming Income summary. Subtract line 7 from line 1, column (d) ►
9
' Enter t1e state(s) In which the organization conducts gaming acllvlties:
a Is !he organization licensed to conduct gouningactivities in each of these slatee.? OYesONo
b lf"No,' e~plaln:
10a Were nny o' the organization's gaming licenses revoked, suspended or termlmded during-tho tax yoat1 D Yes D No
b If "Yes," explain:
Sghed11la G (Form 900 o, 99O-EZ)~Ul~
5/12120162:03:50 PM 2015 Return The American Legion

35-D144250
Sc1&d"I" G \Form 990 or990-EZ) 2D15 Pago3

11 Dass ths organization conduct gaming activities with nonmembers? D Yes O No
12 Is the organization a granlor, beneficiary or trustee of a trust or a member of a partnernhlp or other entity
fum:ed to administer charitable gaming? D Yes D No
13 Indicate the percentage of gaming actlvlt)I conducted in:
a The organization's facility
b An outside facility
0" 0 'c+-tf
_____
c.0130 b . __
%~
%
7
14 Enterthe name and address of the person who preplalresths organization's gaming/special ovcnts books and
records:
Name ►
Address ►
15a Doos the orga;iization h:;we a contract with a third party from whom the organization receives gaming
revenue? D Yes '.] No
b If "Yt;1:,,"en\t;1rthe arnount of gsming revenue received by the organization ► $ and the
amount of gaming revenue retained by the lh!rd party ► $
c If "Yes," enter name and address of tht'l tlilrd party:
Narne ►
Acdrcss ►
16 Gaming manager information:
l\'ame ►
Gaming rr,anager compensation ► $
Description ot services provided ►
I J Director/officer □ Employee D Independent contractor

17 Mandatory distributions:
a Is the organlzMlor, requlrt'ld under state law to make charitable distributions from the gaming proceeds to
retain the state gaming license? D Yes D No
b L:nter the amount of distributions required under state law lo be distributed to olner exempt organizations or
:,pent in the organization':, own exempt a1=tivitfesduring the tax year ► $
l®Hl'J Supplemental Information. Provide the explanations required by Part I, line 2b, columns (Ill) and (v); and
Part Ill, lines 9, 9b, 10b, 15b, 15c, 16, and 17b, as applicable. Also provide any additional information (S€9
instructions).
Schod~lo G jForrn 990 or 990-EZ)2D15
5/12/2016 2:03:50 PM 32 2D15 Return Tha American Legion

35-0144250
SCHEDULE I Grants and Other Assistance to Organizations, 0MB No_ 1545-0047
(Form 990) Governments, and Individuals in the United States
Complete if the organization answered "Yes" on Form 990, Pm1 II/, line 21 or 22. ~@15
Oep,,.'1mo'11 of the Tr~asury ► Attach to Form 900. Open to Public
Jrrtomal Re""nue Servic:e ► Information about Schedule 1 (Form 990} and its instn.1ctions is at www.irs.gov/formS9D. Inspection
la -ne of the organ,u,Von iamployeriden\ifi.,.-.rtiOfl numbe,
THE AMERICAN LEGION 35-0144250
General Information on Grants and Assistance
1 Does the organization maintain records to substantiate the am6unt 6f th€ grants or assistance, the grantees' eligibility for the grants or asslsUmce, and
the selection criteria used to award the grants or assistance? ~ Yes D No
2 0f0oc
Describe in Part IV the organization's procedures for monitorfng the use of granC-'t 0d='cc''cth=•cUcccict•
0dc.cScf•
0f0es=.'--------------------------
IUttill
I Grants and Other Assistance to Domestic Organizations and Domestic Governments. Complete if the organization answereC: "Yes" on Form
990, Part IV, line 21, for any__r_~~ipi~r:i_t
that received ~ore than $5,000. Part II can be duplicated if additlonal space is needed.
1 {al Namearo:J
adclressof organiza:tlon (b)BN (c) IRC section i (di Amount of=~ (e) Nnour<: c! non- (!) Method nf V.iitJa'.ior (g) Dl!.Scription
of (h) Purposeof grant
Tlapplicable ' grant (book. i'MV, appraisal.
cash ,:is:aisl:om,e
or government ot~al)
rioo-<:ash as$l$tance or ass'stance
(1)
'
(2) ''
(3) .
(4)
(5)
(6)
(7)
(8)
(9) I
----
'I
{10)
; -
111)
-
(1~
2 Enter total number of section 501 (c)(3) and government organizations listed 1'7the line 1 table .►
3 ~nter total number of othe• or_Rani:z:ationslisted in the line 1 table .►
For Paperwork Reduction Act Notice, see the lnslructiollS for Fonn 990. cat. 'fo. :;oos5? Sot,edulel (FOl"l""C
990) (2015]
5112120162:03:50 PM 201 5 Return The Am.,rlcan Legion

" 35-0144250
""-·•-• ••=•~-~~'=••=,==~-=•"' =•=• •~•~,,-,,,=m,~.,~~,.,=,~~•."M»~=~--=~•~•~--=•,••-'.""'~~~--"""""""''W"~•'"'"""="'•-••~o=<~=o~.-~-•,·•~•~•=•==•*'-'•" .,_,,____ .,_, ~.-,-~.,rn~-•·-•·•-~~--"--·a-,_ 0_ .·=-~-~~ ="'==~ •-,~"•w---~,~--•-- --
S<:heck;le! (Form 9£0) (201'1)
Page2
bEfijjjl Grants and Other Assistance to-Domestic Individuals. Complete if the organi7alion answered "Yes" on Form 990, Part IV, line 22_
Part Ill can be duolicated if additional s_eaceis needed
ta! Typa of g,o, t o, assi,;•.cince !bl Numlmof {e) Amoont o, (d) A""rnHll of (e:, Method ofvalua\Of\ [t:ock, (fl Description of r,on-cash assi5brce
rcc•oients cashg,.,nt non-casti Msifila/lce FMV, appmisa, ciher)
1 GRANTS TO FAMlL.lES FOR TEMPORARY ASSISTANCE 632 873,319
!
2 SCHOLARSHIPS FOR DECEDEITTS OF VETERANS 151 317,417
'
3ANNUAL MEMBERShlP AWARDS 37,436 I 125,845
I
'
4 SCKOlARSHIPS AWARDED TO CONlEST WINNERS 62 138,0()0
5 SCHOLARSHIP-YOUTH
BASEBALi. LfAGU~ .~ARTICIPANTS '6 34,5(}0
6 SCHOLARSHIPS TO PARTICIPANTS IN SOY SCOUTS 4 14,750
.7 SCHOLARSl,IP FOR PARTICIPANTS IN BOYS NATION

Supplemental Information.
7 7,000
Provide the information required in Part I, line 2, Part Ill, column (bl, and anv other additional irrformation .
SEENEXT PAGE
Sched~le I {Form S90J{2015)
5/12/2016 2:03:50 PM 34 2015 Return The American Legion

35-0144250
s=""'"~'="••="·•-~"-• -~":"~~="•-~---~,.,..-,,.,,,,_,~ •=·=• ~.-~,,_~,-~""''"'--- ---~• •~•• = # --=,~-, ,•=--=·=,_...,._.,~,-c~ •·.~.,--"~~~----, --·····--~.--,=-~,, ._,,,.._____ =---•=·-·--~·-·-------
Part IV Supplem~ntal Information. Pro~ide the lnformatloil required in Part I, line 2, Part Iii, columri (b). anrl
any other additlonal lnfo1mation.
Return ii.eference - lden1111er Explanation

SCHEDULE I, PART I, UNE FOR ALL SCHOLARSHIPS AND TEMPORARY FINANCIAL ASSISTANCE AWARDED BY A.I/IERICAN LEG'ON
2- PROCED'.JRES FOR NATIONAL HEADQUARTERS, CHECKS ARE MADE PAYABLE TO Tl-IE GRANT RECIPIENT ANDA THIRD PARTY.
\10NlTORING USE OF THE THIRD PARTY WOULD BE TIIE EDUCATIONAL INSTITUTION (FOR SCIIOLARSHIPS), LANDLORD (FOR
:'.3RANT
FUNDS. TEMPORARY FINANCIAL ASSISTANCE CHECKSd, MORTGAGE COMPANY {FOR TEMPORARY FINANCIAL
ASSISTANCE CHECK~. ETC, THIS PROCEDUR · ENSUl1CS THAT THE CHECI< !S CASHED BY THE THIRD
rARTY AND FUNDS A E USED FOR THEIR INTENDED PURPOSE.
2015 Return The American Lagion

5112/2016 2:03:50 PM
" 35-0144250
SCHEDULE J OMR No. 154/i.(11147

CompensationInformation
(Fonn 990) For c11rt~i11
Officers, Directors, Trustees, Key Employees,a11d1-iighest
Compensated Employees
► Complete If the organization answered "Yee" on Form 990, Part IV, line 23.
► Attach to Form 990.
Open to Public
Departmentof theTreasury
1.,1ei~al
Reve~u&~e,vk:e ► Information about Schedule J (Form990) and Its instructions Is al www.lrs.gov/formSfJO. Inspection
'Jam~o/ lhec,ganlzation Employerldenll11~allonnum~er
THCAMCRICANLCGION 35-014425 □
Questions Regarding Compensation -- ·--·~

Yes Na
1a Chack lhe appropria1e box{e~) if tile organization provided any of the lo!lowing to or for a psrson listsd on Form
990, Part VII, Section A, line 1a. Complete Part Ill to provide any relevant information regarding these Items.
12]Flrst--class or charter travel D Housing allowance or residence for persoral use
0 I·ravel tor compardons n Payments for business use of personal residence
D Tax indemnification and gross~up payments orinitiation fees
[!:I Health er social club dues
D Ciscretionary spending account D Personal services (e.g,, maid, chauffeur, chef}
b If any of tho boxos on lino 1a are checked, did the organization follow a written policy ragarding payment
or reimbursement or provision of all of the expenses described above? !f ·'No," complete Part Ill to
explaln. 1b v
2 Did the organization require substantiation prior to reimbursing or allowing sxµe:1ses illL'Urred by all
direclcrs, trustees, and officers, including the CEO/Executive Dirnctur, wgmdlng tho items chocked in line
1a? 2 .,,
3 lm.li\;o1ltcJ
which, il c1ny,of the lollowi11gthe flllng organization used iO es'.ablish the compensation of the
org.inization's CEO/Executive Director. Check all that apply. Do not check any bcxes for methods used by a
related organization to estctblish compensation of the CEO/Executive Director, but explain ir. Part Ill.
0 Compensation committee D Written employment contrncl )'.:1 ., ,,,''
0 Independent compensation consultant 0 Compensation survey or study
D Form 990 of other organizations 0 Approval by the board or compensation ccmmittee
4 During the year, did any person listed on Form 990, Pan VII, Section A, line 1a, with respect to the 'iling
org::miz.ationo r a related organi7ation:
i1eceive a severance payment or change··Of··GOntrolpayment? 4" v
'b v
Participate 11,or receive payment from, a supplemental nonqualltled retirement plan?
Participate i.1, or rocelvc payment from, an equity-biised compensation arrangement? ,,
4b
v
' If "Yes" to any of lines 4a--c, list the persons and pro~ide the applicable amounts for each item in Part Ill.
.
Only section 501 (c)(3), 501 (c)(4), and 501(c}(29) organization~ must complete lines 5-9.
5 For persons listed on Form 990, Part VII, Section A, line 1a, did the organization pay or accrue any
compensation contingent on the revenues of:
a The organization? 5,
b Any rtilaled organi:.:atI011? 5b
If "Yes" to line Sa or Sb, describe in f'art Ill.
6 For persons listed o:-i Form 990, Part VII, Ssctlon A, line 1a, did the organization pay or accrue any
compensatron contingent on the net earnings of:
a
b
The organization?
Any related org.;riizat!or,'/
••
6b
If "Yes" on line Oa or6b, describe in Fart Ill.
7 ror persons listed on Form 990, Part VII, Section A, line 1a, did the organization provide any non-fixed
payments not described on lines 5 and 6? If "'Yes," describe In Part Ill 7
f-'--1--+-~
a Were any amounls reported on Form 99C, Part VII, paid or accrued pursuant to a contract that was subject
to the initial contract rxception described in Aeguletlons section 53.4958-4(11)(3)? If "Yes," describe
•-m ~•~-+~
9 II "Yes" to lino B, did the organization also follow the rebuttable presump1Ion procedure described in
Regulations section 53,'1958-6(c)? 9
For Paperwork Reduction Act Notice, see the Instructions for Form 990, cat.No. 50053T Schedule J (Form !JSO)
2015
5,'1212016
2:03;50 PM 36 2015Reti.irri The Amijr)can L.c,glon
35·0144250
S::h~u:e J ,:Form990)2015 Page 2
1$111 Officers, Directors, Trustees, Key Employees, and Highest Compensated Employees. Use d~plicate copies if additional space is r.eeded. ·
For eacl7 indrY:dual whose oompensatlon must be reported on Schedule J, report compEnsation from the organization on row (Qand from related organizations, described ln the
instructions, on row Qi). Do not fist any individuals that arc not listed on Form 990, Part VII.
"v'"· '' '" ~~''' '" "'"'"'' ..,~ \'-'J\•rw•J IVI ""'-'' ""''-'-' ' '""''--U"'-' ''''-'"' ""'' """'""'",,,,,vu,,, v, ru,,,, ""u, r,,,, v11, ~=uu,, /-\, """' ,a, "flfl""""''"'
cu1,.mm \UJ ano \C/ amoums 1orma1 lrlOIVKJUal.
{B) Breakdown ol W-2 and/or 1099-MISC compensation
----- (Cl Retlremem ;snd
o,i.er deferred
(OJNontaxabJe (E) Total of colurn~s lFl Comperisation
{A) r-lame and T;tle (i) Base (ii} Bonus&. ,ric:orrtiv• (iii) 0th~• l>eneficS (B)(,)-iO) ic coJumn(BJ "eport<>d
c,,mpensation compensaticn reportable compenSl.llion as dele•redt>r pnor
com_oensation F,:,m,'i)SQ
---·
1 GEORGE A. BUSKIRK JR.
NATIONAL TREASURER
2 PHILIP B. ONDERDONK JR.
"
{ii)
68,544
0
7.000
0
34.463
0
25,256
0
26,639
0
161.902
0
34,463
0
NATIONAL JUDGE ADVOCATE "

{ii)
13S,900
0
6,000
0
66.875
0
19,612
0
26,914
0
258.381
0
€6,875
0
3 DANIELS. WHEELER
NATIONAL ADJUTANT •
(ii)
191,255
0
27,000
0
94.719
0
53,062
0
26,743
0
392,779
0
S-4,719
0
4 JEFFREY 0. BROWN
EXECUTIVE DIRECTOR "
(ii}
139,3:.8
0
6,000
0
0
0
43,487
0
225
0
189,050
0
0
0
5VERNAL,, NJONES (0 133,882 10,000 0 25,10, 10,786 179,773 0
EXECUTIVE DIRECTOR (ii) 0 0 0 0 0 0 0
6 R. J. STOFFER '116,942
OIR.ECTOROf MEOIACOtul!,tUNlCATIO~ " 10,000 0 26.584 20,617 176.143 0
7SHAWNLONG
DIRECTOR OF FINANCE
"m
{ii)
112,409
0
0
0
750
0
0
0
0
0
24,137
0
34,034
0
0
0
171,330
D
0
0
0
8 JOSEPH C. SHARPE m 127,997 0 0 27.421 0 155.418 0
~=ro• 01' , •.,,....,.,
<OCJe~TIClt,
"""·""""'"" '"" {ii) 0 0 0 0 0 0 0
(ii
' {ii)
'° "
(ii)
" "
Qi)
'2
"
(HJ •
'3
•
(Ii}
(0
" {ii}
'5 (i)
{li)
[i)
" ~i)
SC~edUle J (Form 9:S0)2015
5112/2016 2c03'50 PM
" 2015 R<>turn The Am,a,ric.anL,a,gion
35.014250
•=••~'-•~--",_"_~'"-•-••OM--.•=·"-••-• ""'~•~--=~--~=-,e"=•-==,,-= =• ~••~•=-.,=«~•-•---•=~=,m.,=---•-••-•,.--- -•~~-~-=,.,--,,-,,.,;,=,_,,. __ ,,_ -"~ <, ~•••"""""--•~-~,•••• .,,._.~,,,,_,_ """s7e"a'"=''<'",a-,.,,.• -•~-• -•~••~•-•~--~~••"'"
Part Ill SuppleI11entel Information. Provide \ha information, explarmtion, or descriptions required for Part I,
liruis 1e, 1 b, 3, 4e, 4b, 4o, 5a, 5b, Ila, 0b, 7, and 8, and for Parl II. Also comple:e this part for any
addillonal Information. __ ---------------------~
Return Reference - Identifier Exr lenetlon

SCHEDULEJ, f'ARI I, UNI:: t'IHSf-CLASS TRAVEL IS PROVIDEDTO THE NATIONALCOMMANDERSAND NATIONALADJUTANTWHEN
1A - FIRST-CLASSOR FLIGHT EXCEEDSTVVOHOURS,TI-JEIBAVEL IS NOT INCLUDEDAS TAXABLE COMPENSATION.
CHARTER TRAVEL
SCHEDULEJ, PART I, LINE TO PROVIDE AN APPROPRIATEATMOSPHERETO ENTERTAINDISTINGUISHEDGUESTS, CLUB FEES ARE
1A- HEALTH OR SOCIAL PAID FOR OFFICERS.PERSONALCHARGES INCURREDAT COLUMBIA CLUB, ARMY/NAVY CLUBAND
CLU6 DUES OR NATIONAL PRESS CLUBARE PAID BY THE OFFICERS.THIS BENEFIT IS PROVIDEDAS NONTAXAl3LC
INITIATIONFEES COMPENSATIONTO AI.L OFFICFRS !'JIRECTORS AN[)TRUSTEES.
SCHEDULEJ. PART I. LINE THE SPOUSESOF THE NATIONALCOMMANDERS(DANIEL M. DELLINGERAND MICHAEL 0, HELM)
1A - TRAVEL FOR ACCOMPANIEDTHE COMMANDERSTO SIX BUSINt,:SSTt-!IPSFOR BUSINESS PURPOSES.THE TRAVEL
COMPANIONS ~3~Epi~'lEiA~iRNTHOSE SIX TRIPS ARE PAID SY THE ORGANIZATIONAND ARE NOT TRl=ATEDAS TAXABLE
SCHrnuu:; J, PART], LINE DANIC:LS. WHEELER,NATIONALAOJUTANT,PHILIP '3. ONDERDON/'. NATIONAL JUDGE ADVOCATCAND
48 - SUPPLCM!aNTAL GEORGE A, BUSKIRK,JR,. NATIONALTREASURER,PARTICIPATEDII\ A SUPPLEMENTALNONOUALIFIED
NONQUALIFIED RETIREMENT PLAN, DANIELS. WHEELERRECEIVEDA PAYOUTOF $94,719 rROM THIS PLAN DURINGTHE
RETIREMENTPLAN YEAR. PHJLIP8. ONDERDONKRECEIVEDA PAYOUT OF $66,875 FROM THIS PLAN '.JURINGTHE YEAR.
GEORGE A. BUSKIRK,JR. RECEIVECA PAYOUT OF $34.463 FROM THIS PLAN DURING THE YEAR.
5/12,12016 2:03;50 PM 38 2015 R11t~m Tho Amerloan Legion

35-014425'0
SCHEDULE L Transactions With Interested Persons

(Form 990 or990-EZ) ► Completa ii the organization anoiwered "Vas" on Form 9110, Part IV, lin1125a, 25b, 26, 27, 28a,
28b, or 28c-, or Form 990-EZ, Part V, IJne36a or 40b,
Je,mrlrnent of tl,e Tnaasl'ry ► Attach to Form 990 or Form 990-EZ.
nleT'lalHavem~Senlica ► lnlorma11on about Schadula L Form 900 or 990-E and its lmrtructlons Is al www./ni, ovlform990,
Ernplo~er ldenlltlcatlon number
THE AMERICAN LEGION 35-0144250

EKcess Benefit Transactions (section 501(c)(3),soction 501(c)(4), and 501(c)(29) organi7.atlons on!y).
Complete !I the organization answered "Yes" on Forrn 9go, Par\ IV, lfna 2!:ia or 25b, or Form 990-EZ, Part V, line 4Cb.
... ----
{b) Ralal'onshi,i botw""'' droqu~liff~dpcrsu11w!d 101
Co~«l.01
1 (al Nllmeof dl<KJUalllltdperson (cj Description of tr~ris~ct:on
orgam<allor, Yes
f1I
""
(2)
(31 --
(41 -----· .---------
(51 -
(61
2 persons di; -1.1gthe yoar
Enter the amount of tax incurred by the organ1za\1onmanagers or d1squa1Jt1ed
under section 4958. ►
3 Enter the amount of tax, If any, on line 2, above, reimbursed by the organization .. ►
l@lli Loans to and/or From Interested Persons.

Completa if the organization answered ''Yes" on Form 990-EZ, Part V, line 38a or Form 990, Part IV, line 25: or ii the
organization reported an amount on Form 99,'.J,Part X, line 5, 6, or 22.
------
[a) Nam~ of inlore•ted parson (b) na1ation•hlp (cJ Purpose of (d)Loentoor (o) Original (I) Bal,.wo duo Ilg]In dofau!l? [h) Approved i~Wrll1en
with organl.:a11on loan from \ho pr:nclpal mntHml by board or agrnemenl?
organ;7~llon? , comml:lee?
1
N, v.. N, N,
111
------ ... - Tc from
-------
Vos
'"
(21
l3l
(41 ------ ---- ·--· .
(5)
___M__
______ ---- -- .... -
(7) ' '
(8) -
{9)
--
(10)
Total -►
-----
$
·--- -
Complete 11the organization answered " Yss .on Form 990

hlfflilliGrants or Assistance Benefiting Interested Persons.
Part IV line 27
-· ------ '
(a) Name of ictereg!ed person (b) R&l~1Ionshlp Mtween Interested (c) Arncunt ot ass!stw,c~! (d) Type ol ass1Stance IQ) t'~mosc o1oasiatoncc
person and the crgan!zatloo
111
(21 ·-·-
(31
(41
-- ----
~-
(6)
(71
!8L
(91
(10)
For P~perwork Reducl1QnAct Notlclil, sa" lhf:I ln,tructlons for FQrm990 or 990·EZ, '
Cal. No. MOb~A Scha~ule L (F,mn 990 or 51!10-EZ)2015
2015 Ret1,rn The American Legion

5/12l2016 2:03:50 PM
" 35-01442~0
Sd1edul~ L IFo.'fl1900 ~rS90-EZ) 2015

j:ffijj(TJ Businei,s Transactions Involving Interested Persons.
. . . .
Complete if the organizatlon answered "Yes" on Form 990 Part IV line 28a ;;>8b or ?6c
'--------- - - ------ --- - --
i
(a) Nil.ml>of lnt~r""t~d par5all (bl Relation~hip between {o]Amount of (d) Description ot lraisaction i•)Sharngol
lntarastad p~rson Md lh$ lransactlan organi,a!l~r·,
organlU1~0n rnvencoo?
~- ,o
(1) (SEE STATEMENT)
- -~------
"' I
{2) I
[3i
II
'4)
(5)
{6)
I
17)
I~
,,,
.
110)
Supplemental Information
f'rovlda addl71onallnformallon for responses to questions on Schedule L (see instrnclions).
I
ti/1212016 2:03:~0 PM 40 2015 Relurn The Am$rii:ijn Legion

35•0144250
Business Transactions Involving Interested Persons (continued)
(a} Name of i~terested person (b) Relationship between interested (c} Amount of {d] Description of transaction (e) Sha~ng of
person and the organizslion transaction organization's
revenues?
Yes _N~
GEORGE A. BUSl<IRK,JR !S THE
~ATIONAL TREASURER AND IS A !-,COSIER TRUST COMPANY
o: HOOSIER TRUST COMPA,NY
TRUSTEE0~ HOOSIER TRUST $280,945 MANAGES THE INVESTMENTS OF ✓
COMPA~'Y THE ORGANIZATION.
5Ji2/2ll1 I! 2:03:50 PM '1 2015 Return The American Legion

35-0144250
_,,.., -••~-•~ -•=c-.-~••••«==•-,-~•ec•===-=~-s-,..,.,.,,--;--,~-••~•~••-="'""""'='""""''W""'"''"'"'•'-'"'''"=-•=••~,=-----••o,.,d,_,, ___ =•~-~.--.,•~••-•-•-••==>~~•--.•-•••'"•"•C=~~-•==--~~=•=•-"-•~-.,..,,.__,,,,___ ,_.,,_. ____ ,,_

0MB 0/o, 1515-0Y,7

Supplemental Information to Form 990 or 990~EZ
Complete lo prO'<ido
:r,formal'on/or ,e,poo,e, lo "l>O<irlc
qao,tion, on
Fnrm 09Uor 990-EZor«>p,ovldo Art'/oCdlllMolin!o1m,1lon
2015
Open to Public
lnspRctlon
Nomo<>IU>eO.gaei,allon 1:mi,1oy•r1ionllnca1looNumber
THE AMERICAN LEGION 35,0144250
Return Refllrence - Identifier El(OJtm!lllon

FORM 990, PART I, LINE 1 - THE ORIGINALLYFILEO 2014 RETURN FOR AMERICAN LEGION NATIONALHEADQUARTERS
AMENDED RETURN INCLUPEOTHE ACTIVITY OF A RELATEDORGANIZATION,THE AMERl:::ANLEGION Sf::PrEMl:lER11
MEMORIALSCHOLARSHIPTRJST FUND fi1N 42-1553035), \'111,ICH FILESA SEPAAATE FORM 998. THF.
RETURN IS BEING AMEl\'DF.DTO REFJ.EC ONLY THE ACTIVITY OF-:-HEAMERICAN LEGION
NATIONALHEADQUARTERS.IN ADDITION,CERTAIN LINE ITEMSA"ID LINE GROUPINGSON THE
FORM 990, PART IX, HAVEBi::E:NRl::CLASSIHf:DON rHi, AMENDED RETURN TO PROV.'DE
CONSISTENCYAND ACCURATECOMPARATIVESFOR REPORTINGPURPOSES.
.
FORM 990, PART I, l.lNF.1 • ASSISTANCEAND SUPPORTFOR MEN AND WOMENWHO HAVE SERVED IN THE U.S. ARMCO
BRIEF MISSION FORCES, SIGNIFICANTACTIVITIESOF WHICH INCLUDEFREE BENEFITSCOUNSELING,EDUCATION
AND CAREER GUIDANCE,AND HEALTH-CAREADVOCACY.THE AMERICANLEGION ALSO PROVIDES
VOLUNTEER OPPORTUNITIESFOR VETERANSTO MENTORYOUTHAND SPONSORWHOLESOME
PROGRAMSIN COMMUNITIES:LEADSACTIVITIESTHATCELEllRAT[ PATRIOTISMAND HONOR;
PROMOTCSSTRONG NATIONALSECURITY:AND PRDVIO[S MEANINGFULFELLOWSHIPAMONG
SERVICEMCMBE;RS,Vt;T[RANS AND THEIR FAMILIES.
rDRM 990. PART 11:,LINE 1 - GUIDANCE,AND HEALTH-CAREADVOCACY,TlIE AMERICAN LEGION ALSO PROVIOESVOLUNTEER
ORGANIZATION'SMISSl8N OPPORTUNITIESFOR VETERANSTO M[NTOR YOUTH AND SPONSORWHOLESOMEPROGRAMSIN
COMMUNITIES:LEADSACTIVITIESTHAT CELEBRATE PATRIOTISMAND HO'\/OR;PROMOTES
STRONGNATIONALSECURITY:AND PROVIDESMEANINGFULFELLOWS.-!IPAMONC SERVICE
MEMBERS,VETERANSAND THEIR FAMILIES.
FORM 990, PART VI, LINE 1A- BYLAWS, ARTICLE VII, NATIONALEXECUTIVECOMMITTEE
DELEGATE BROAD AUTHORITY
TOA COMMITTEE SECTION 1. BETWEENNATIONALCONVENTIONS,THE ADMINISTRATIVEPOWERSH/\LL BE VESTED
IN THE J'\ATIONALEXECUrlVE COMMITTEE.WHICH SHALL BE COMPOS!,D OF THE NATIONAL
COMMANDER,THENATIONALV!CE COMM/\NDERS,AND ONE I\ATIONAL EXECUTIVE
COMMITTEEMANANO ONE ALTEKNI\TE FROM EACH OF.PARTMENTTO BE ELECTED/\S SUCH
DEPARTMENTSHALL DETFRMINF,THF Al.TERNATE TO ACT ONLY IN THF AASFNCE OF THE
NA":IONAL EXECUTIVE COMMITTEEMAN.
-
1-'0kM9<JO,1-'ARI VI, LINE 8B - THE ORGANIZATIONDOES NOT HAVE ANY COMMITTEESWITH AUTHORITYTO ACT 01\ ITS BEHALF.
OOGUMl::NTA""IONor
MEC:TINGSHELD BY
COMI\UTTEESOF GOVERNING
DODY
FORM 990, PART VJ, LINE 10B - THE ORGANIZATIONDOCS HAVE LOCAL CHAPTERS,HOWEVER,THE ORGANIZATIONDOES NOT
MONITORINGCOMPLIANCEOF HAVEWRITTEN POLICIESAND PROCE:DURESGOVERNINGTHE ACTIVITIESOF SUCH CHAPTERS.
LOCAL UNIT'S ACTIVITIES THE DEPARTMENTSAND POSTS ARE INDEPENDENTCORPORATIONS,AMCRICANLEGIONNATIONAL
HEADQUARTERSPROVIDESSUPPORTOF PROGRAMSBUT THOSE PROGRAMSARE NOT
MANDATED.
FORM 990, PART VI, LINE 118- THE AMERICAN L2GION NATIONALHEADQUARTERSBOARDOF DIRECTORSHAS DELEGATEDITS
R[Vl[W OF FORM 990 BY AUTHORITYFOR OVCRSIGHTAND REVIEWOF THE F0,1.M990 TO A BODYOF A MORE APPROPRIAT[
GOVERNINGBODY SIZE ANO EXPE~TISE. THISBODY IS CALLEOTl-IEflt-iANCIAl GOVCRNANC[ COMMITTEE.ANY
ACTION TAKEN BY THE FINANCIALGOVERNANCECOMMITT[[ IS Rl::PORTEOTO THE FULL BOARD
AND THE BOARD IS-AFFORDEDTHE OPPORTUNITYTO CO\IIMEN";ON THOSEACTIONS.THE FORM
990 WAS REVJEWEDBY THE FINANCIALGOVERNANCECOMMITTEEBEFORE IT WAS FILED.
FORM 990, PART VI, LINE 12C · THE ORGANIZATIONHASA W."<ITTEN

CONFLICT OF INTEREST POLICY.EVERY EMPLOYEEWHO IS
CONfL.CT OF INTEREST ABOVE DEPUTY DIRECTORIS REQUIREDTO COMPLETETHE CONFLJCTOFINTERESTDISCLOSURE.
POLICY
i~~-~~~t~:rrt~g~~EJ?N~0itT~~~-\iiu~xi~~~EJ8~hiE~~~~~%Ef~~i~~
MEMBERS COMPLYWITH THE [)]$CLOSURE POLICY,THE OFFICERSAND DIRECTORSARE
~t~:~Tl~
REQUIREDTO DISCLOSEANf-.:UALL
Y INTERESTSTHAT COULD GIVE RISE TO CONFLICTS.
TOGETHERTHE HUMAN RESOURCESDEPARTMENTAND THE NATIONALJUOGF.ADVOCATE
MONITORAND ENFORCECOMPLIANCEWITH THE POLICY.
FORM 990, PART VI, LINE 15A- THE COMPENSATICNOF THE ORGANIZATION'SNA.flON/\L ADJUTANTfHE TOP MANAGEMENT
PROCESSTO ESTABLISH OFFICIAL) IS REVlf:WED ANNUALLYBY THE COMPF.NSATIONCOMMIT EE. GATl-iF.f<l:llf-D~ lHE
COMPENSATIONOF TOP SOLE PURPOSEOF RESEARCHfNGANDOVERSEEINGTHECOMP2NSATIONOF THF.
MANAGEMENTOFFICIAL ORGANIZATION'STOP OFFICIALS.THE COMMITTEE IS A GROUP OF INDEPENDENTPERSONSWHO
USE COMPENSATIONSURVEYSGATHEREDBY THE HUMAN RESOURCESDEPARTMENTTO HELP
DETERMINEAN APPROPRIATELEVEL OF COMPENSATION.THE CONTENTO,=THE M[lcTINGS IS
DOCUMENTEDIN MINIJTES.THIS PROCESSWAS LAST UNDERTAKENIN 2015.
FORM 990, PARTVL LINE 155- IN ADDITION, THE COMPENSATIONCOMMITTEEANNUALLY REVIEWSTHE SALARIES/1-iONORARIUMS
PROCESSTO ESTABLISH OF All OTHER OFFICERSAND KEY EMPLOYEESOF THE ORGANIZATION.THIS REVIEWINCLUDES
GOMPENSATIONOF U-fHEH THE FOLLOWINGPOSITIONS:NATIONALCOMMANDER,NATIO,\/ALJUDGEADVOCATE,NATIONAL
t:Ml-'LOYl::1::8 TREASURER,AND THE 3 FXFCUTIVEDIRECTORS,THE COMMIHf-'r' LSES COMPENSATIONSJRVEYB
GATHEREDBY THE HUMAN RESOURCESDEPARTMENTTO HELP DETERMINEAN APPROPRIATE
LEVEL OF COMPENSATION.THE CONTENTOF THE MEETINGS IS DOCUMF:NTF.DIN MINUTES,THIS
PROCESSWAS LAST UNDERTAKENIN 2015,
------- --- --
5/12120182:03:50 PM 42 2016 Return The American Legion

3fi.0144250
Roturn Roforonoe • Identifier Exnlan~tlo~

FORM 990, PART VI. LINE 17 - M~~~~M~.L-~.•m~-~~~~MM~m•~~
STATESWITH WHICH A COPY WA.WV.WI
OF THIS FORM 990 IS
Rl:'QLIR.E:P TO 6E FILED
FORM 990. P/\RTVI, LINE 19- J'H:,_ORGANI/ATION'S FINANCIALSTATEMENTSARE FILEDWITH CONGRESSANNUALLYAND ARE
REQUIREDDOCUMENTS AVAII.A6LF.TO THE GENERALPUBLIC,THE GOVERNINGDOCUMENTSAND CONFLICT OF INTEREST
AV/IIL/1.BLETO THE PUBLIC POL.ICYARE AVAILABLE UPON REQUEST.
FOR.M990, PART XI, LINE 9 -

UfHi:R. CHAt,Gl::S IN NET
CHANGE IN PUFL
'•'
De,;crHlon lb\ Arnauri(
565,506
ASSETS OR FUND BALANCES --------
/\MORTIZATOINOf PENSION LOSS - 2,470,872
PENSION RELATED CHANGES OTHERTHAN Nl::r Pl::RIODICPENSION COST 956 164
CHANGE IN VALUE OF CFA .. ._ .. .... - 2,356
. ------ . - ---
51121201$2:03:5(1PM 43 2!116Return Tho American LegiQn

36-0144250
0MB \Jo. 15t.5-U047
SCHEDULER
Related Organizations and Unrelated Partnerships
(Form 990)
► Complete itttie organi:>ation "n;;w,,red "Y"s' on Form 9SO, Part IV,Ji,,.. 3~, 34, '.l.:ib, 36', or 37. ~@15
► Attach to Fo,m 9SO. penou1c
Def,,,rtm<,n,of '.he Trea"'-'ry
InternalReveiiueService ► lnformati0<1 about Sch~uleR (Form 000) and its instructions isat wwwJr.,.gov/fom,~!la. Inspection
Nameof theorganiza~or Em;,loySr identification nUinber
THEAMERICAN LEGION 35--0144250
1@11 Identification of Disregarded Entities Complete if the orga:,ization answered "Yes" on Form 990, Part IV, line 33.
"
Na-ne. address., and EIN fttapcillcable:, of disregard£d entity
.,
Primaryacumy
,.,
lega' dom;cile (state "'
Tota. 1ncofT€
1°1
End-ol--year as5'?t5
w
Diree-: controlling
(1)
or foreign C0'-"1try;,
~'"
(2)
(3)
(4)
(5)
,~
,.
Identification of Related Tax-Exempt Organizations Complete if the organization answered "Yesn on Form 990, Part IV, line 34 because it had
IAAl!Ione or more related tax-exempt organizations during the tax year.
Name, addra=, and Ell\ ofrelat<adorgant:aticn

.,
P~mary activity
,.,
L~al domicile (m.e "'
E><emptCodti section
,.,
r'OOlic charity ciatus
w
Dircc: controlling s~
.,
~121bli1J)
or foreign country) Lrtsection501{c)(3)) enlity ccntrcl<>d
enlityl
Yes No
(35-7041737) GRANThiAKJNG
(1}AMERICAN LEGION CH!LOWl::Ll-'ARE
700 N PENNSYLVANIA STREET, lND!ANAPOllS, IN 46204
FOUNDATION
'" 501(C)(3) 7
NiA
{2l AMERICAN LEGION ENOOWMENTFUND CORF'ORATION [35-6039680) MANAGE FUND IN

501(CJ(3JI 11 TYPEI
~.,_:_RICNIlfGIO~
NA71:)NAJ.
"
700?\J PENNSYLVJ\NIA STREET, !NDIANAPOLIS, IN 46204 HEN>01JM1'aRs
(3) THE AMERICAN LEGION NATIONAL EMERGENCY FUND (35-6€79628) ASSIST MEMBERS A•IEJ!•CA l "
PO BOX 1055, INDIANAPOLIS, IN 46206 '" 501(C)(3)
NATIC""L
"[ HEAOOUAA>,RS
14) THE AMERICA.N LEGIOM SEPTEMBER 11 ME~ I.0RIAL (42-'.553035) SCHOLARSHIPS iN ».!ERIC.AN l£{HDN
NAT,or-w_
7 HEAOQU~RTI'R3
".,,
PO BOX 1055. INOIANAPOLIS, lN 46206 501 (C)(3)
PRESERVE FLAG
(5) CITIZENS FL.AG ALLIANCE. INC. (35-1924749)
700 N PENNSYLVANIA STREET. INCIA.'-JAPOLIS, IN 46204 1'" 501(C}(41
N<A
' .,,
--
(6)THE AMERICAN LEGION CHARiTIES (38-6902131) GRANmAKING AMERICA!', lFCIOt<
7C-ON PENNSYLVANIA STREET, INDIANAPOLIS, IN 46204

1'N 501(C)(3)
NA~IOt<A'_
7 ~"1\0CUAATERS
AMER.ICM l£GION
.,,
(7JAMERICAN LEGION CHARITIES, IN'.::. (90-1017997) GRANTMAKING
700 N PENNSYLVANIA STREET, INDIANAPOLIS, IN 4S204 1'" sc· (C)(3l 7
t<ATION"-
~eADQ'JARTERS
For Paperwork Fleduciion Act Notice, see the Instructions for Fam, 990. Cat. l\a. 5013SY Schcdulo R (Fan-n 990) 2015 "
51121:20~62:03:50 PM 44 2015 Return The American Legion
35-0144250
• .,,_."~~••o-•-•~'""'"~~>"s-~,-.-,.•-•••-"•-~-~--,==-~-=•,-,,.,~~-=~-•--•>,u~-,,;=.~•-~•-='7·=•~•<·•,,.a,.~-"'""'=•-~=-•=,.,,~-----"~•=-"""""~•~•~•---~•=,~-""""'•••--.•- ....,-~,..,=••-•-~•-•;,.~~••--~-
Schedele R{Form 990) 20- ~
P~ge2
1@101 !dentifi~_ti,on
- .,
_of Related Org'.'lnizatians _Ta~ablc as a Partnership Camp~ete if the organization answered "Yes" on Form 990, Part IV, line 34
..,.,,,._,,_u,,.,,
a ''"-'-' rn '"' ur 1,iurt: rt11<C1lt:lU l/,;.:;,iv~oa:,; a pan:r,ersrnp aunng met~
ur~<C1r11.::a.u1.111:,; year.
,., ,.,
Name. adelress. anCI EIN of
rel;;te<icrganlza.tior
'"
Pnma,y ac1rv,ty
Jtj
lef;al
d0"1ioile
{<
Dir~-ct comroler,g
ertir;
Predomir.,nl
in"<lrre [related.
"
Shareoftotal
,noome
(h)
Share o' encl--ol,: O,sp,i;i~·onate
ycnr~s,;cts
Ccde'J-U81 '"
a0o::ali>os1 amount:~ b-ox20
"'
G'"n""'-1 or
man.iging
'"
Percenta.g<>
owrer.ship
(stale or unrelat,.d,
ot-ScMedule K-1 Pl' --mar?
exclcded from
foreign i tax under
; (Farm 1(165)
~OJn,ry)
seclions512-514)
~.-
]_Yes No
-- Yes No
{1)
i
{2}
-
'"
~)
{~
{~
m
h®IW Identification
,.
of Related Organizations Taxable as a Corporation or Trust Complete ITthe organization answered "Yes" on Form 990, Part IV,
Name. address. and ElN ~lated organization

.,
line 34 because it had one or more related organizations treated as a co..-.v-,rationor trust during the tax vear.
,.,ot
Prima,-yaclM":y "
Legaldil'?'licle Oir<>ci:cootroll'ig
" ,,-
Typeof entity "
Share of total ~=m
., .,
Per.:entage •
_.,
Sectioo 512(bl(13)
(state arfaroign::o.ml)(,
~"" :cCO'Jl,S corp,trust) income end--<:f,ycgc assels ownershir,,
enuty'1
Yes No
(1)
{2)
(3)
i
{4)
~)
' -
(6) i
m
Schedule R (Form 990] 2015
5/1212016 2:03:SO PM
" 2015 Return Th,. American
35-0144250
Legion
,~.~=·- ·- •,o•-•-••••--~_,~,...,,-,,=~,-~~;----a-a,,....,,.=-.,,==,~.-.,,,.'-c;
,_,_ ~-.-.R.,~ -•~"-.-----~,~~,•->~=-~.r-,e•,,~_..,---•~•~-•=w•~-~"••==•-~=-•~---• -- ..~•--,.,,..~.a... ~~-~------~,~~--••-=•-•--
Sched.-e R {Fo..-r 990) 20' 5
Page3
lilmD Transactions Wrth Related Organizatlons Complete if the organization answered "Yes" on Form 990, Part IV, line 34, 35b, o~ 36.
Note. Ccmp!ete line 1 if any entity is listed in Parts 11,111, or IV of this schedule. Yes No
1 During the tax year, cid the;iorganization engage in any of the fonowing tran.sact'ons with one or more, related organizations listed !n Parts lHV'l
Receipt of~) interest, {ii) annuities, (iii) royalties, or (iv) rent from a contro!led ei"liiy
' 1, .,
b Gitt, grant, or capital contribution to related organlzation(s) 1b .,
Gift, grant, or capital contriblt.ion from related organization(s)
' 1c .,
d Loans or loan guarw,tees to or for related organizfilion(s) 1d .,
e Loans or loan guarar.tees by related organization(s) 1e .,
:·,l:,.,
f Dividends from related organization(s) 1f .,
g Sale of assets to related organization(s) . .,
h Purchase of assets from related organlZation(s)
fg
1h .,
i Exchange of asse~ with related organization(s) . 1i .,
J Lease offacifities, equipment, or other assets to related organimtion(s) 1j .,
k Lease of facilities, equipment, or other assets from related organization(s) 1k ' .,
I Pertormanoe of services or membership or fundraising solicitations for relatsd organization(s} • .,
m Performance of services or n1embership or fundraising solicitations by related organizatlon(s) . .
11
1m .,
" Sharing of facilities. equipment, mailing lists, OI" other assets with related organization(s) _ . .,
0 Sharing of paid employees with related organization(s) '"
1o .,
p Reimbursement paid to related organization(s) for expenses . 1p .,
q Reimbursement paid by related organization{s) for expenses • . 1q .,
other transfer of eash or property to related organization(s)
•l,'' ,.=>
.,
'
s Other transfer of cash or property fror., related organization(s)
.
.
1, '
.,
.,
1s !
2
<a)
N.!me of related or;,a.n,zation
.,
If tile answer to an" of the above is "Yes," see the instructions for information on who must complete this line, including covered relationships and transaction thresholds.
Transactior
lo)
Amourit inV<llved JJlet;od of diatemiiriing arnoun~ involved
ty.,,.ja-s)
AM .NI t UNU ...,,._RP~,~11uN
11)
' ' N t::1'.>DUWM
C 183,383 FMV
AMER1CANLEGION ENDOWM[NT FUND C
'2'
""' D
''
I 2,000,000 FMV
AMF°R
'3'
'"" J'"'' 1,. ....,, "'-·
C 257,985 OMV
eM· . H W-L A UNLJA11uN
'4'
' s 75,000 OMV
'5'
I
,,,
Schedule R {Form 990) 2015
5/1212016 2:03:50 PM 4' 2015 Return The Arnei-icanLeglon

35-0144250
~•-~-••==,-,~-"--• "'"'"'-'··•'••<-"-" '~"- ,~,~~,'"•-•-•••~~---~~~•-=-r~,~~=~-,-"~"",~---•-•-,--~"._,__,,,_,_, ___,~ .~---•••"~,~~~-"""--'"~~"~•~•--~·~--•·a~,~-----.-~,,~---

SchedW, R [Fo-,r, 990) 2015 Page4
l#tfil!JIUnrelated Organizations Taxable as a Partnership Complete if the organization answered "Yes" on Form 990, Part IV, line 37.
Provide the following lnformffiion for each entity taxed as a partnership through which the organizruio'l conducted more than five percent of its activities (measured by to!c1Iassets
,.
Name, address, a~ci EIN of er,thy
.,
or gross revenue} that was not a related organization. See instructions regarding exclusion for certain investment partnershi.E_s
PMmaryact\•~y
,.,
Legal dorr.iclle
"'
rrecom1r>ant
,.,
/J./eallpartner,; "
$he.re of
JgJ
Sha•e of
.,
l:l,;:,rnport'cr:at "'
CodeV-UBI "
GC!ncralor
,.,
?eroe'ltage
(state orfot'l!ign inco,na (ra:a1ad. S&;:!LJa total iricome end--of-year all:ic,rtioosO ;,rn~unt in box 20 manaslng ownershi~
countf)'.I ucrelated. excluded 5l'l'(c)l31 =cts of Schedule K- • ~artnlif?
fl'<lmtax under "'!i3rJ:i;atimllS? IF<irm 1 065)
scclioc~ 512--514)
y~ No y~ No Yes No
111
(2)
13)
~,
15}
(5)
m
(8)
~,
{10)
(11)
(1~
(13)
(1~
(15}
(16J
-Schedule R {Form 990) 201S
S/1212016 2:03:50 PM
" 2015 Return The American
35-0144250
Legion
•·--=·cas=••••·=•~•=•a•=-=,•~">>'•~•.- '"'-""•~=•""""•"'•=••= =•=•--•==• =•=·~•-~••-~•-•-=•=•=•""~=~•=="•••s•=~•••,>s,s,~'""~•-•.,~-~-~'~"~ •~~-••• -,- -~"•"~~.,

=><~-=-•-----••=•---•~=-r,=~.-----
s~ -=---••-••-
PUBLIC DISCLOSURE COPY

0MBNo, 1~45-0087
Exempt Organization Business Income Tax Return
>om990-T (and proxy tax under section 6033(e))
For calendaryear2015or othertax year be0inning , 20m, and en(lin~ , 20
► lnformatlOfl about Form 990•T and Its instructions !s 1ivallableat www.irs.gov/form990C,
!
Depanmenl
ortM Tr~asury Oret1!0 Publm lnspe~t[onfor
lllte1r1aAE>venJuSaivica ► Do nol ent11tSSNnumbors Qllthis form~" it may be made publioif your organi<allonis a 501(c)[:3]. 601lo)[SJO,gcu,,zatmns Only
N~m~ of organization { 12] Chaok box Hnwrn Gh~ngad and saa lroslructiom;.I O l:m~loyer id~nliflcalion numbor
A.0 a~ir!lss~~n ed (Em~loyoes' lr,,at, sec irs:r,,ctiari,c)
B hempl under seolion ,TeHeEoAeMcEsReiCeAcN"-"LEsCcloO"N
___________ _
Print r 35-01442.G0
I
Elso1( c Jl HI) or NlJfllbor, slreol, and room"' suit<>no_If a P.O. box. see lnslr~·clM:>ns.
E Unrelated bu•inass ocU,•ltycodes
0 408{e) D 220(0) Type PO BOX 1055 (Se~ inmuctlons.)
□ 408A O 5~0(;,j City or Iown, slate Qrprovince, counlr,·, and ZIP or foreign pt>Slalcocie
Ds29• INDIANA.POLIS,IN 46?.06 541600 900004
!
C Sook •,alu• u1 all a8sels F Group exemption number ·see instructions.) ►
al etld of year
114.410.4ti4 G Check organization type ► 0 60l{c) corporation D 56f(C) fruSt [J 401{a}trust D Othertrust
H Describe the organization's primary unrelated business activity. ► ADVERTISING
During the tax yeu, was 1hecorporation a subsidiary In an affiliated group or a parent-subsidiary controlled group? ► . D Yes El \!o
It "Yes." enterthtt 07
mune and 1Cen1ifying""""m"be:'o''''f~th;•cPe•a•,•s">'>'°S'"Po'e"e'eloans.,►:___~ --,-.,---~-~----c=~==~--
J The books are In can, of ► GEORGEA. ~USKlR.K JR Telephorie number ► (317) 630 " 1229
" Unrelated Trade or ausiness Income (Al l~come [B) Expenses IC) Ne!
1a Gross receipts or sales

b Lossroturns11t1dallowances
ol
ol
I
C Balance ►l 1c 0 .
7
i
I
.,
2 Cost of goods sold (Schedule A. line 7)
3 Gross profit Subtrac1 line 2 from line 1c .
Capital galri ntit Income (attach Schedule D)
b Net gain (loss) (Form 4797, Part II, line 1'/) (attaohForm 4797)
2
3
4b
., 0
0
0
0
..
..
I
!
'
_,....: ,' .• ..
.
. 0
0
0
C Capital loss deduction for trusts 4c 0 0
"
5 Income(105s)frompa11nersl1ips andS ~orporations(attachstatement) 5 0 0

Rent income (Schedule C) 0 0 0
6 c-'- '------ '
0 0
7 Unrotated debt-financed income (Schedule E) . 7 0
8 ~terest,aMJllies,roya:ties,
aridrentslromcontrolled (Schoduto
organizatioos F) 8 0 0 0
9 twestrnsnlincJmoof a section501(c)(7),(9),or(17)organization
(ScMdulEG) 9 0 0 0
10 Exploited exempt activity income (Schedule I) . 10 23,468 ',986 21,482
11 Advertising Income (Scheduls J) 11 10,132,570 9,892..421 240,149
12 Other inccine (Seeinstructions; attach schedule) , 12 0 0
t3
. Total. Combine lines 3 throunh 12 t3 10,156,038
Deductions Not Taken Elsewhere (See instructions for limitations on deductions.)
9,894,407
(Except for contributions,
261,631
deductions must be dlrectlv connected with the unrelated business income,\ ·---- ··--·-
14 Compensation of officers, directors, and trustees (Schedule I() 14 0
15 Stilarles and wages 11• "
0
16 Repairs and maintenance . 16 0
17 Bad debts 17 0
'
18 Interest (,;ttach schedule) 18 0
i9 Taxes and licenses, 19 0
0
20
21
Charitable con:ributlons (See Instructions for limitation rules)
Deprecialio,1 (attach Form 4562)
• I ·,, • 1 . ·oi- - 20
22 less depreciation claimed on Schedule A and elsewhere on return 122al 01 22b ··- "
0
23 Depletion 23 0
24 Confriburons to deferred compensation plans 24 0

25 Employee benefit programs , 25 0
26 Excess exempt expenses {Schedule II 26 0

27 Excess readership costs (Schedule J) 27 240,149
28 Other deductions (attach schedule) 28 0
20 Total deduc1iom;, Add lines 14 through 28 29 2.40.149
30 Unrelaied business taxable income before net operating loss deduction. Subtract line 29 from line 13 30 21.482
3i Net operating loas deduction Ulmited to the amount on line 30) 3i 21.482
32 Unrelated business taxable income before speclflc deduction. Subtract line 31 from linti 30 , 32 0
33 Specific deduction (Generally $1,000, but see line 33 Instructions for exceptions) 33 0
34 Unrela1ed business taxable·income. Subtract line 33 from line 32. If line 33 ls greater than llne 32,
enter the smaller of Lero or line 32 , 34 0
For Paperwork R9du<:tlon Act Not10~,11..elnstruot1ons. C~t.No.11291J Form990-T(~015J
5112/2016 2:04:46 PM 2015 Return The American Legion

J.5•01442SO
form HSO-T
(2015) Paya 2
Tax Comutation
35 Orgunizations Ta,:able as Coiporations. See instrucUons for tax computation. Controlled group
members (sections 1561 and "1563}check here ► D See instructiom, and:
a
b
Enter your share of the $50,0DD, $25,DOC, and $9,925,DOO taxable income brackets (in th.it order):
(111L_
Er-ter organization's
-~~ 1211 <,111
sti.iro1 or: (1) Additional 5% tax (not more than $11,750)
I I
1$;-------+
0
I
(2) Additional 3% tax (not more than $100,000) 0$~----'-c----(
c Income tax on the amount on lino 34 . ► ,'c'c'c+-----'+-
36 Trusts Taxable at Trust Ratr;,8. See Instructions for ta>: computation. Income ta>: on
the amount cm line 34 from; D Tax rate schedule or O Schedule D (Form 1041) ► 36
f--'-'--t----+--
37 Proxy lax. See instructions ► 37
38 Alternative minimum tax . 3B 0
39 Total, Add lines 37 and 38 to line 35c or 36, whichever a plies 39 0
Tax and Payments
40a Foreign lax credit (corporations attach Form 1118; trusts attach Form 1116) 4□•
b Other credits {see instructions) . 40b
Genernl businoos credit. Attach Fcmn 3800 (see lnstructlr.ms) • 40, I .
'd Credit for prior year minimum tax (attach Form 8801 or 8827) . 40d
• Total credits. Add lines 40a thrcu;ih 40d 40• 0
41 Subtract line 400 from line 39 41 0
42 Other1axes.Check If from: D Form4255 l ..i Form66: 1 0 Form6697 D Form8866 l .l Other(attachschedule) • 42 0
43 Total tax. Add lines 41 and 42 43 0
44a Payments: A 2014 overpayment credited to 201G 44a
b 2015 estimated tax payments 44b 0
.
44,
'
d
Tax deposited with Form 8868
Foreign organizatioM: Tax paid or withheld at source (see instructions) 44d
0 Backup withholding (see instructions) 44•
.
f Credit for small employer health insurance premiums {Attach Form 8941) 44f
9 Other :;redits and payments: D Form 2439
D Form4136 0 Ottl01" 0 Total ► 44• 0
45 Total payments. Add lines 44a 1hrough 44g 45 0
-
46 Estimated taX penalty (see instructions), Check If Form 2220 is attached .► rJ 46
47 Tax due. II line 45 is less than the total of lines 43 and 46, enter amount owed ► 47 C
.,.
48 Overpayment. If line 45 Is larger than Iha total of lines 43 and 46, enter amount irerpald
want: Cred!led to 2.016eetlm11tedlax ►
Enterthe ammmt ol llne 48 yaL.1 O
. .
Refunded ►
► 48
49
.E
C
~
Statements Regarding Certain Activities and Other Information (see instructions\

1 At any time during ttia 2015 calendar year, did the organization have an Interest In or a signature or other authority Yes No
over a financial account {bank, s601Jltias, or other) In a foreign country? If YES, the organization may have to lile
rlnCEN Form 114, Report of Foreign Bank and Financial Accounts. If YES, enter the name of the foreign country
here ►
2 Cunng Iha tax year, did the organization receive a distribution from, or was It the grantor of, or transferor to, a foreign trust? '
It YES, soo instructions tor o!her lorms tho organization ml'.y have lo file, '
C::nterthe amount of tax-exempt interest received or accrued during the tax vear ► $
'
Schedule A Cost of Goods Sold. Enter method of lnvento valua11on ►
0
1 0 6 Inventory at end of year

2
lnvantory at beginning of year
Purchase5
1
2 0 7 Cost of goods sold. Subtract
6
'
line 6 from lino 5, Enter here and
' '
Cost of labor . 0
4• Additional section 263A costs In Part I, line :-i 7 0
(attach schedule) 4a 0 6 Do lhe rules of section 263A (with resp~cl to y., No
b Olhf.lr co~tc; (attach schedule) 4b 0 property produced or acquired for resale) apply
5 Total. Add lines 1 throuah 4b 5 0 to the organization? .,
I declae that I haveexamriod1,11re um, nclud'ingaccompaiwng soh•aulosand sta aman1s,and lo thebesl of my koowlaOgo
, Un:it.-pen.1esor per1'1<l', and a,1,a1,11,.
Sign true,corr1>et, '" '
and ~ornplete.Oeclara1ion
of preparer(o!h61' " ' ' '
than 1a,payer)II;ba,ed on alliniormotmn '
IllWhichpre~are,
has an)·.<nowled9e.
May lho IRSdlsc~,s ll1lsmlera
►
► I
Here NATIONALTREASURER wi:hlho p1•?•re1show~below
"lllle
(seolnslr"cl1on,)1
~Yes □ No
Signature al officer Dale
Paid
Preparer
1-'rOltfrype
preparer"s
RACHEL SPURLOCK
name
IP,~,~( J 1-1, ID"to
5/12/?016
Chack D If
self-employed
IPTlfJ
P0052(}729
£.ir,n'.sname ► CROWE HORWATH LLP . ~ ... Firm's EIN► 36-0921680
Use Only 3816 RIVER CROS8ING PARKWAY, SUITE 300, INDIANAPOLIS,IN 46240-0977
Firm'sQ<.l<Jresa
► Phor.ono. (~171569-6989
farm 99O-T {~015)
5112/20162:04:46 PM 2 2015 Return The Amcrloan Leglm1
35-0144250
Form ~oo-T (2{)1Sf Paga3

Schedule C Rent Income (From Real Property and Personal Property Leased With Real Property)
{see instruction:i)
1. Dasmipt1onoJ propertv
2, Rant r<>eaiwdor ~c=d
{al From personal propert1·~I the percenlegao! rent (b) From ,eal and personal propertv (If th<l 3(a) Dadu-Otlonsc,racHy connootcd with \1><1 ,ncome
for porsonal pro port~ I~ more than 10% b~t 00! percentage a( renl hlr p&rsoMI prop;,,rty ;,,xceeds. in columns 2{a) and 2(b) (al1•eh aciiadulof
more lhan ~0%) 50% m (f the r~ntrs bas~d an profit or ir.coma)
,,, -----
,,,
@_
,,,
:rota I 0 Total 0
jb) Total ded!.lotlons.
(o) Total income, Add total~ of tx1lurnns 2ia} and 2(b). Enter Enter here and on page 1,
t,ere and on r:,aqe 1 Part I, Una 6, column r.o.,
► 0 Part I, line 6, column (Bl ► 0
Schedule E Unrelated Debt~Fmanced Income {seernstri..ctions)
3, Daducl ons ._.11001yconnaotad wth er a lo,;ablo to
2. 8rossiocom., frum ur
1, Des-,1iptlonol dabt-llnanced pmperty debt-finaooed property
alloeab!e to debt-fim1ncod
propart~ I 1a1~1raigntune oepreclallori- (bf OtherdadL!Ctioos
(attach schadule) (allach schadule)
-
!!L__ --
,,,
~~)
- --
,,,
4. l\moun1 ot average ~- Average adJI/Siadbasis
acqu1smo~debt on or 6, Cclumn B. Allocable dedllCl1ona
of or allccablo lo 7. Gross Income reportable
u looablo to debt-financed 4 divided (column 6 ~ total ol colooins
d<tbMlnanesd propert1· (column 2 x colu'lln 6)
property (altach schedule) by column 5 3(a) ar.d Sib))
(atlacli schaduM
,,, %
"'
ISi
%
%
----- ----
'" %
l::nter here and on page 1,
Part I, line 7, column jA).
Enter here ar.d on page 1,
PHr\ (, li11e7, r.olum~ (BJ.
Totals
► 0 0
Total dividends-received dE>ductions ir,cluded In column 8
►
Schedule F-lnterest, Annuities, Royaltles, and Rents From Controlled Organizatrons (seeInstructions)
ExemptConlro11ed
o_~anlzatlons
1. N;mo ot c~ntrolled 2. l:mployer
~. Net unrala1ed1noorna 4, To!alof apecifled 6, Pwtd ool~mn 4 that i3 6, DeducHons dlraclly
organization ldentilfcation number
Uossl (sea Instructions) pav,nenta mad a lnuludeo in Iha coritr{;lling conneoled wllh Income
organization's 9ro8'8 income in column 5
,,,
,,, - -
"'
,,, ,,
No~e mpI Con ,oiled OrganI atlons
" ' 10. Part ol column 9 11,atIs
8, Nat U11ralatedincoma I,, Total ol specl!iad 11. DedLtcllors d,ract:y
7. Ta)<~Ll~l!:L".lfllD included in the ccntrollln11 connecl;,d with lriccmo in
jloas) (Ha 1natn1Gl1oi,~) payments made
org.,,ir.atiO!l's gro.. Income column 10
'"
Cl
'"
,,, ----
Add coll;mns 5 and 1C. Add columns 8anrl 11,

Enter her~ and on page 1, Enter heTHIOd on p-OgoI,
Pin I, llr,e 8, column (A), Port I, l~1e6, uulurn1 (Bf.
Total~
► 0 0
Forni -
990 T !2015)
5/12/201 ~ 2:()4:46 PM 2015 Return The American Legion

35-0144250
AmountGenerated Amo~nt Used In Prior AmountUoedin Cum,m /\muLClitRt>rm,inlng NOL [xplres

Years Ye~r
2010 258,207 0 21,482 236,725 2030
2011 530,235 L_ ------"-----+---------+'s'a'e,2esasc__ ____ --l-'2,o,,_31.___,
-------~
2012 470,011 0 470,011 2032
2013 5,997 D 5,997 2033
21,482 1,250,958
I
II
5112/2016 2:0.;:46 PM 2015 Return Th& Am11rlo~nLegion

35-0144250
ELECTIONTO FORGO THE TWO•YEM NET OPERATING LOSS CARRYBACK PERIOD
The laxpal'(lr incurred a nel operating loss in 1h11

eurrent ta:,::year and is entitled to a two-)'{lar carryback of tho loss under IRC Sec. 172(b)(1)(A:,(I).
Pursuant to IRC Sec. 172(b)(3), the taxpayer hereby elects to relinquish lhe entlre carryback par1odwilh ms pact to 11nyregular (a:,::and AMI n~t
o ernlin lassos.
5112120162:04:46 PM 6 2015 Re1um The Amoric~n L(lglon

35-0144250
From: l(b)(5)
Sent: 26 Oct 201617:38:18 +0000
To: Fedloan PSLF
Cc: Odom, Christian;Battle, IL.(b-'-l('--51
_____ _,
Subject: Re: Re: Re:Angel of the Winds
I think just an email and ECFin a zip file (so we have the EIN) would be sufficient.
If you could provide a list of the entities that you retract that would be helpful. I'm sure
they are all in this mailbox but I don't want to miss any.
Thank you!
Taneka

Sent: Wednesda,, October 26, 2016 11 :57:43 AM
To: l(b)(5J -
Cc: Odom, Christian; Battle. Cynthia; Fedloan PSLF
Subject: Re: Re: Re: Angel of the Winds
Thanks for the clarification. We will begin to internally make the decision on tribal entities, but will
also send the information for your tracking purposes. Would you prefer we send only the name of
the tribal organization without a zip file, or would you also want the ECF and other information we
found?
I know we have denied some tribal casinos as being for-profit, and we will definitely retract those
denials. All should have been escalated to this mailbox for review, but would you like to have a
list of the tribal entities we update from denied to approve?
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From l/bl/51 I
To Fedloan PSLF
Cc "Odom, Christian" "Battle, Cynthia"'
Date 10/26/201612:39 PM
SulJ_ect [extemal]Re. Re. Angel of the Winds
Hi Kim,
Thank you for the reminder on Outpost Casino. You can internally make decisions; but
please continue to send the tribal escalations you receive to this mailbox so we can
track them. Additionally, will PHEAAbe reviewing previous denials to determine if
retractions need to be made?
Thanks,
Taneka

Sent: Wednesday, October 26, 2016 10:44:46 AM
To: l(b)(5) I
Cc: Odom, Christian; Battle, Cynthia; Fedloan PSLF
Subject: Re: Re: Angel of the Winds
Thanks Taneka! Based on the guidance provided by PU, I am additionally going to approve
Outpost Casino that I had escalated in early August, and you can remove this from your list.
Also, just want to confirm our understanding is the same as yours, that starting immediately, we
can internally make decisions on the tribal hotels/casinos without escalation (as long as we can
conclusively determine they are part of the tribe),
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From l/bl/51 I
To Fedloan PSLF
Cc "Battle. Cynthia"', ,lfb~)~(5~1-~I-"Odom. Christian"
Date 10/26/201611:21 AM
SulJ_ect [extemal]Re. Angel of the Winds
Hi Kim,
We reviewed this organization and they qualify based on the guidance provided by PU.
Thanks,
Taneka
From: Ll(b~)(~5)~-,-~
Sent: Wednesday, October 12, 2016 8:32:59 AM
To: Fedloan PSLF
Subject: Re: Angel of the Winds
I'm not sure what is going on with the email but I think we had this issue before so will
follow up with the FSAhelpdesk. Thanks for providing the summary. We'll conduct
research on this and will get back to you with a decision.
Thanks,
Taneka

Sent: Tuesday, October 11, 2016 1:20:01 PM
To: l(b)(5) I
Subject: Angel of the Winds
Hi Taneka! I tried to send this two more times; however, I keep receiving a mail delivery failure
citing the reason: "the message was rejected by organization policy". It doesn't seem to want to
go through, and I'm not sure if it is the zip file. I don't know if it would be possible for you to review
without the zip file?
Basically, we couldn't not find any indication that the casino is an B(a) firm and that they are
tribally owned and operated. There is no evidence indicating it is separately organized from the
tribe, therefore, we would lean toward approving this one.
Let me know if this is sufficient, or if you want me to try and send again. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: l(b)(5)
Sent: 7 Mar 2017 20:52:22 +0000
To: Foss, l(b)(5J I
Subject: RE: RE: RE: Baltimore Symphony Orchestra OrchKids
Me too. I hope the borrower can pull the documents that will actually him to qualify.
From: Foss, Ian

To: l(bJ(5J I
Subject: RE: RE: RE: Baltimore Symphony Orchestra OrchKids
I'm okay with their changes.

Sent: Tuesday, 07 March, 2017 15:35
To: !(bl(51 I
Subject: Re: RE: RE: Baltimore Symphony Orchestra OrchKids
Hi Taneka! Please see the redacted letter with the requested changes. As you know, the system denial
letter is lacking in detail, so the borrower was previously informed that his "Organization Does Not
Qualify". Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
!(b)(5) l<[email protected]>
Fedloan PSLF <[email protected]>, !(b)(5) I <[email protected]>
c, "Odom, Christian" <Christian Odom@ed gov>, "Battle, Cynthia" <Cynthia.Battle@ed gov>, "Foss, Ian" <Ian [email protected]>
u.n, 031071201703:09 PM
Sub]Cct [external]RE: RE· Baltimore Symphony Orchestra OrchKids
Than ks for providing context regarding the date. In light of th is additiona I information, can you modify the
introduction paragraph so that the borrower understands this IS a re-review and an attempt to provide more
information on the denial previously received should the borrower want to appeal the decision.
Once the letter is revised could you send it back over to us to review again.
Thanks,
Taneka

To: !(bl(51 I
Subject: Re: RE: Baltimore Symphony Orchestra OrchKids
Hi Taneka! Thank you so much for providing feedback so quickly.
To your additional question, the ECF date on the letter is correct Diane and I were working on compiling
and cleaning up our internal spreadsheets to send over to you (obviously trying to make them functional
for you to use), based on our conference call we had several weeks ago. While combing through our
internal spreadsheet, we identified this employer that Sara had previously reviewed and approved. As it
turns out, the Business Unit, rather than approving, denied the organization. However, we wanted to
forward along for your input since Diane and myself weren't quite sure if it should be approved and
wanted to be proactive. We wanted to ensure if the organization was indeed approved, we notify the
borrower accordingly. If denied, no action would have been necessary as the borrower was previously
informed it was not eligible.
Please let me know if you have any additional questions. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
~r:w1 l/b)/5) U(b)(5) I

T,, Fedloan PSLF <[email protected]>
Cc "Odom Christian" <Christian Odom@ed gov>, "Battle, Cynthia" <Cynthia.Battle@ed gov>, "Foss, Ian" <Ian [email protected]>,
l{b)/5) U{b)/5) I
D:i:e 03/07/2017 01:49 PM
SubJect [external][external]RE. Baltimore Symphony Orchestra OrchK1ds
HI Kim,
Ian had the opportunity to review the borrower's letter. Attached are edits to the denial letter, with PII removed.
As you will notice, additional language was added to the text to help ensure that the borrower understands what
documentation needs to be supplied to help FedLoan and FSA properly review Baltimore Symphony Orchestra
OrchKids for PSLFeligibility.
While reviewing the letter, we also noticed that the borrower's ECFreceived date was listed as May 2015? Would
you be able to confirm 1fthe ECFdate received is correct and if so, why FSAis just receiving this employer
escalation for review?
Thanks,
Taneka

Sent: Monda , March 06, 2017 11:21 AM
To: (b)(5)
Subject: RE: Baltimore Symphony Orchestra OrchKids
Hi Taneka! Sorry for the delay on this one. Attached is the borrower letter for your review. Password to
follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
· r~w1 l/b)/5) U(b)(5)

Cc !(b)(5) U(b)(5) I
"Battle, Cynthia" <[email protected]>, "Foss, Ian" <[email protected]>. "Odom,
Christian" <Christian. [email protected]>
n;;:e 0211712017 03:52 PM
[external]RE: Baltimore Symphony Orchestra OrchK1ds
Hi Kim,
The EIN forth is organization links to the "Baltimore Symphony Orchestra Players Committee, Inc." There is no
revenue associated with this organ1zat1on. Could you draft a customized "soft denial" letter to explain that the
borrower is being denied because the organization that is listed on the ECF does not have any revenue associated
with it and Fedloan would need to verify how the borrower is paid. Could you provide us with a copy of the
drafted letter before sending it out to the borrower so that FSA may review it first?
Thanks,
Taneka

Sent: Tuesda , February 14, 2017 8:16 AM
To: (b)(5)
Subject: Baltimore Symphony Orchestra OrchKids
Hi Taneka!
This organization certified as private not-for-profit, public education. They are 501(c)(5). It is a kids
program within the symphony. They have staff/instructors, including the borrower. The program (which is
set up to be in a school-like environment) runs during the school year both during and after school. We
found that the students are divided by grade level and have classes/homework.
We think they could possibly be approved under public education, or possibly 'other school based
services', but wanted your opinion.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: l(b)(5)
Sent: 9 Jan 201716:43:11 +0000

To: FedLoan PSLF
Cc: Battle, Cynthia;Foss,Ian
Hi Kim,
Can you tell me if the authorized official for the Fair Elections Legal Network ever
submitted an ECFas providing Public Interest Law Services. The ECFthat was attached
for the borrower in 2015 is certified under Public Education.
Thanks,
Taneka

Sent: Monday, November 2L 2016 6:44:52 AM
To;!(b)(51 I
Cc: Battle, Cynthia; FcdLoan PSLF; Tiongquico, Rene
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From l/bl/51 U(b)(5) I

Cc "Battle, Cynthia" <Cynthia.Battle@ed gov>, 'Tiongquico, Rene" <[email protected]>
D,itr, 1010712016 03·35 PM
Sull.ect [external]Re: Re. Fair Elections Legal Network
Thanks Kim.

To: l(b)(5) I
Subject: Re:Re:Fair ElectionsLegalNetwork
Hi Taneka! We only have record of this one borrower being approved under the Fair Elections
Legal Network, and it was approved on 3/5/12. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
f-rrnn i(b)(5) li(b)(5) I

Cc !(b)(5) l!(b)(5) l"Tiongquico, Rene" <[email protected]>, "Battle, Cynthia"
<[email protected]>
LJc1lH 10/07/2016 01:09 PM
Suh Hci [external]Re: Fair Elections Legal Network
Hi Kim,
We will need to escalate this for an additional review since this will likely PHEAA will
need to issue a retraction. I will keep you posted on a decision.
While we wait, would you be able to tell us how many borrowers have been approved
under the Fair Elections Legal Network and how long the oldest approval is for?
Thanks,
Taneka
From: KimberlyA Myers <[email protected]>on behalf of FedLoanPSLF<[email protected]>

Sent: Friday,September 16, 2016 12:42:34PM
To: l(b)(5) I
Subject: Fair ElectionsLegalNetwork
Hi Taneka! This employer was last reviewed in March 2012 (during the beginning stages of our
PSLF reviews). We had escalated this one and Ian approved as private not-for-profit, and we
categorized it under public interest legal services.
We now received a recent escalation of this employer. Now knowing more on the public interest
legal services category, we don't believe this employer should qualify. We wanted to escalate to
you for a decision. I included our original research as well as our email exchange with Ian.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: l(b)(5)
Sent: 31 May 201719:45:27 +0000

Cc: Odom, Christian;Battle, Cynthia;Foss, lan;FedloanProgramManagement
Subject: RE, RE, RE, PSLF& ACLU
Hi Kim,
Thank you for confirming this information so quickly. I'm glad that we do not need to do additional
validation on this borrower's employment.
Moving forward -we are fine with Fedloan validating the ECFsof borrowers employed by ACLU based
on the EIN and other information that is being certified by the authorized official.
Thanks,
Taneka
From: Kimberly A Myers [mailto:[email protected]] On Behalf Of fedLoan PSLF

To: l(bJ(5J I
Cc: Odom, Christian; Battle, Cynthia; FedLoan PSLF; Foss, Ian; FedLoanProgramManagement
Subject: Re: RE: RE: PSLF& ACLU
Hi Taneka! For the attached borrower, we did confirm the employer (via a W-2), and he is employed by
the eligible 501 (c)(3) foundation.
Just for some clarity, when we originally discussed the ACLU, we had requested W-2s for all borrowers
who had submitted ECFs for a branch of the ACLU or ACLU Foundation. Based on what we received, I
believe all borrowers were employed under the EIN they stated they were employed by (with most being
a branch of the 501(c)(3) foundation). As a result, going forward we were not requesting W-2s for all
subsequent borrowers who submitted ECFs. We have been processing based on the EIN provided by
the borrower/employer.
Would you like us to continue to request W-2s for all borrowers who submit ECFs for any branch of the
ACLU?
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

Cc "Battle, Cynthia" <Cynthia [email protected]>, "Foss, Ian" <[email protected]>. 1{b~)~(5~1-~l<[email protected]>,
0 "Odom,
Da:o 05/31/2017 01:02 PM
SubJect [external]RE: RE. PSLF & ACLU
Hi Kim,
As you know, Christian and I are in the process of validating borrowers to receive their 6 month pre-forgiveness
letters. During my review, I came across a borrower with 113 QP whose ECFcert1f1esthat he works for the ACLU
Foundation. Would you be able to confirm if FedLoan requested additional documentation from the attached
borrower (he Is also a lawyer) per the message below and if you confirmed if he In fact did work full-time for the
501(c}(3) and not as a volunteer or for the 501(c)(4}?
The borrower information is attached. I'll send the PW separately.
Thanks,
Taneka

5_1
Cc: Battle, Cynthia; Fedloan PSLF; Foss, Ian; "l(b_l_(
--~
Subject: Re: RE: PSLF& ACLU
Hi Taneka! Thanks for the quick response. We will go ahead and retract any appropriate approvals and
request appropriate documentation on the other borrowers.
I will also work with the area responsible for updating the web content to include some additional
clarifying language.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
~r~w1 "Chialastri, Taneka" <[email protected]>

Cc l{b)(5) ll{b)(5) I "Foss, Ian" <Ian [email protected]>, "Battle, Cynthia" <Cynthia [email protected]>
Da:c 03/11/2016 02:54 PM
SubJect [external]RE: PSLF & ACLU
HI Kim,
Ian and I spoke offline. Fedloan will need to retract the approvals we gave to the ACLU for the 501(c)(4) entities
where it was determined that the borrowers were volunteers or did not provide a qualifying service. We also need
to be sure that the borrowers at the 501(c)(3) entities were volunteers, and, if they were, retract those approvals,
too.
We think it would be a good idea to add more language to the StudentA1d.gov and MyFedLoan.org websites to
make it clear that non AmeriCorps and Peace Corps volunteers do not qualify. We will work on updating
StudentAid.gov. Would Fed Loan be able to add a brief statement to MyFedLoan stating, "unless you are an
AmeriCorps or Peace Corps volunteer, volunteering for an organization is not qualifying employment for the
purposes of Public Service Loan Forgiveness"?
Thanks,
Taneka

Sent: Friday, March 11, 2016 7:48 AM
To: Foss, Ian
Cc: l(bl(5l I
Chialastri, Taneka
Hi Ian! We just wanted to follow-up on this employer to see if you had any more information and/or made
a decision on the direction you would like us to go. The Business Unit recently escalated another
borrower employed at the ACLU and we currently have it on hold.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
-r,w1 FedLoan PSLFIPHEAA

Io "Foss, Ian" <lan.Foss@ed gov>
c, _,I<[email protected]>, "Chialastri, Taneka"
Fedloan PSLF <[email protected]>, !(~b)~(5~)
0 _
<Taneka [email protected]>
u.n, 111031201511:01 AM
:C;LJtw-ad Re: [external]PSLF & ACLU
:=;,w1hi Diane Freundel
Hi Ian, We asked the business unit to perform a query to identify numbers. The numbers they provided
indicate 5 borrowers were approved for employment at various ACLUs that were 501 (c)(4) entities. The
numbers also indicate 56 borrowers were approved for employment based on an EIN that linked to a
501(c)(3) Foundation or Union Fund.
One of my newer employees who works on the escalated ECFs, reviewed 2 ACLU 501 (c)(4) entities and
based on our normal review process determined they did not provide a qualifying service. One entity had
9 employees and one had 11. She looked at the staff listing and determined the employees didn't provide
a qualifying service - all of the attorneys were listed as volunteers. She hadn't located your previous
guidance.
Let us know. If the decision is that they should be approved, we'll want to be more careful of the number
of employees at a specific entity, whether the borrower is an employee, and whether the employees,
rather than volunteers, perform the qualifying service. We'll hold any new ones until we hear from you.
Thanks!
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
[email protected]
~r~w1 "Foss, Ian" <lan.Foss@ed gov>

Cc l{b)(5) U(b)(5) l
"Chialastri, Taneka" <Taneka [email protected]>, Diane Freundel <[email protected]>
Da:o 11/02/201501:51 PM
SubIoct [external]PSLF & ACLU
Hi Fedloan folks,
It seems that we might have approved the ACLU and affiliates as a qualifying organization when we should not
have done. I know we approved the ACLU of Vermont, but have we approved any other ACLU organizations?
The issue is that the forms we've gotten in associated with the ACLU are usually completed as a non-501(c)(3) non-
profit providing public interest legal services, but that requires the organization to be funded at least in part by the
government, and the ACLU receives no government funding ..
I don't want to retract any approvals just yet, but I wanted to get a sense of how many ACLU organizations we
have approved, and how many borrowers this affects.
Thanks,
attachments.
Code:PHEAA
From: l(b)(5)
Sent: 10 Feb 2017 19:03:49 +0000
To: Fedloan PSLF
Cc: Battle, Cynthia;Foss,IL.(b-'-l('--51
____ _,
Subject: Re: RE:Re: RE:Re: Employer Review - AARP
Hi Kim,
OGC responded. AARP does not qualify for PSLF.Although we determined that on a
limited basis AARP provides direct services to the elderly through training etc. - those
services are minor and not the primary purpose of the organization.
PLI (Ian) will be sending an email response to Ms. Delaney as a follow-up. We'll forward
the email to FedLoan for your records.
Thanks,
Taneka
From:.Ll(b~l(_51~~-'
Sent: Friday, February 10, 2017 9:44:09 AM
To: FcdLoan PSLF
51,----,,,.-'
Cc: Battle, Cynthia; Foss, Ian; !,-l(b_l(_
Subject: Re: RE: Re: RE: Re: Employer Review - AARP
Hi Kim,
Thank you for the reminder. Cindy, Ian and I conducted a meeting with AARP on January
4th. During the meeting we allowed Ms. Delaney and her colleagues to discuss the ways
that AARP directly provide public services to the elderly through their state
organizations. We have since forwarded this information to OGCfor a review and are
awaiting a decision.
I will update you as soon as a decision is rendered.
Thanks,
Taneka

Sent: Wednesda,, February 8, 2017 1:24 PM
To: l(b)(5J -
Cc: Battle. Cynthia; FedLoan PSLF; Foss. Ian
Subject: Re: RE: Re: RE: Re: Employer Review - AARP
Hi Taneka! I'm following up on a lot of things today, if you haven't noticed!
I wasn't sure if this discussion with AARP had occurred? We still have not taken action on Ms.
Delaney's account or the other affected borrowers. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From l/bl/51 I
To Fedloan PSLF
1{b~)~(5~)
Cc "Battle, Cynthia", "Foss. Ian··, 0 _ _,
IJc<if 12/09/2016 03:27 PM
Sub_fct [external]RE. Re: RE. Re: Employer Review AARP
Cindy, Ian, and I are going to try to set something up for next week. We'll keep you updated on the
outcome.
Thanks,
Taneka

Sent: Friday, December 09, 2016 10:28 AM
To: l!bJ/51 I
Subject: Re: Re: RE: Re: Employer Review - AARP
Thanks Taneka! We will reach out to Ms. Delaney and let her know that someone from FSA will
be in contact with her. Would you please let me know once the discussion has occurred so that
we can draft a formal response to Ms. Delaney and also take action on the other borrowers.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From l/bl/51 U(b)(5)

Cc "Foss, Ian" <lan.Foss@ed gov>, "Batlle, Cynthia" <Cynth1a.Battle@ed gov>, i(b)(5) U(b)(5)
IJc<if 12/09/201610:18 AM ==-~,==----~
Sub_fct [external]Re. RE: Re. Employer Review -AARP
Hi Kim,
Thank you for the information. We reviewed the ECFsthat were forwarded and agree
that only the EINs for the Foundation and the AARP Experience Corps should be
approved for PSLF.Before sending out any official documentation regarding FSA's
decision, can you inform Ms. Delaney that her escalation has been referred to the
Department of Education and that the FSA will be reaching out to her directly to set- up
a call to discuss the AARP and their organization's eligibility for PSLF?
Thank you,
Taneka
From: Kimberly A Myers <[email protected]> on behalf of Fed loan PSLF<[email protected]>

Sent: Wednesday, December 7, 2016 3:36:18 PM
To: l(b)(5) I
Cc: Fedloan PSLF
Subject: Re: RE: Re: Employer Review - AARP
Hi Taneka! Currently all of those borrowers employed by an AARP entity that is 501(c)(3) (the
Foundation and AARP Experience Corps), where the borrower wasn't missing something, or
denied for another reason (e.g. no eligible loans), are showing approved. Only those borrowers
employed by the ineligible AARP (the 501(c)(4)), are showing denied. Just one thing to note, in
asking the Business Unit to run a query, it appears that not all borrowers who were/are employed
by the 501(c)(4) were denied. If the ultimate decision is to deny, these approvals would need
retracted. It appears 3 borrowers fall in this bucket
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From l{b)(5) U(b)(5) I

To Fedloan PSLF <[email protected]>, 0 1{b~)~(5~)
-~1<[email protected]>
Date 12/07/2016 03:53 PM
Sull.ect [extemal]RE. Re: Employer Review -AARP
Thanks Kim.
Currently, are all of these borrowers in a PSLF-deniedstatus because of the decision from FSAto deny the
AARPas an PSLFeligible employer? We are still reviewing these ECFs,but I see that a few of the
borrowers have the Foundation, which is a 501(c}(3), listed as their employer?
Thanks,
Taneka

Sent: Wednesday, December 07, 2016 12:36 PM
To: l(bJ(5J I
Cc: Fedloan PSLF
Subject: Re: Re: Employer Review - AARP
Hi Taneka! I had the Business Unit run a query, and it appears we have a total of 31 unique
borrowers who submitted 42 ECFs for various 'branches' of the AARP. We received 7 different
EINs for this employer.
I separated the ECFs in the attached file based on the EIN that was received. For one EIN
received, it appears it may have been a typo, as it is one digit off from an actual EIN associated
with AARP.
Please let me know if you need anything further or have additional questions. Password to follow.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
From l/bl/51 U(b)(5) I

D,itr, 12/06/2016 09:18 AM
Sub_r,ct [extemal]Re· Employer Review -AARP
Hi Kim,
Can you forward all ECFsthat you have on file for the AARP? If the number is
significantly high please let us know. We are interested in seeing if any borrowers listed
the Foundation EIN instead of the corporation EIN.
Thanks,
Taneka

Sent: Monday, December 5, 2016 7:49:21 AM
To: l(b)(5) I
Subject: Fw: Employer Review - AARP
Hi Taneka! I know we have had prior back and forth in regards to MRP. Based on the most
recent escalation and determination that they don't qualify, we responded with a personal letter to
the MRP directly. That same staff person is now escalating again. She emailed one of our
internal staff. The contents of her email are below.
Please let us know how you would like us to proceed. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
----- Forwarded by Kimberly A MyerslPHEAA on 12/05/2016 08.44 AM -
Jrn, y ,cd "'c""',, l' e "'"" .,.,,,,. ,. ·-~'~v'"'"'"

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1 •,,-,-,r,c, ,., ""l'.",•,,,,1,-,,,,,1, '""'"
and/or attachments.
Code:PHEAA

Sent: 7 Sep 2016 17:56:02 +0000
Cc: Battle, Cynthia
Subject: RE: RE: RE: RE: RE: United Nations Office of Project Service
Thanks, in that case, the employment as a contractor is not qualifying employment unless that contract
employment otherwise meets our requirements. Thank you!
-Rene Tiongquico
To: l(bJ(5J I
Cc: Fedloan PSLF; Battle, Cynthia; Tiongquico, Rene
Rene,
The business unit has finally been able to reach the certifying official for this borrower. She confirmed that
the borrower is indeed employed by the United Nations Office of Project Service as a contractor.
Thank you,
Sara Preston
Compliance Services
(717).720.2808
[email protected]

T,1 "Tiongquico, Rene" <Rene Tionqguico@ed gov>
Cc "Battle, Cynthia" <Cynthia.Battle@ed gov>, Fedloan PSLF <FedloanPSLF@pheaa org>, l{b)(5) U(b)(5)
D:i:e 08/31/2016 02.47 PM ==-~==----~
Subject Re: [external]RE. RE: RE. RE. United Nations Office of Project Service
Sert lly Sara M Preston
Rene,
The business unit has attempted to contact the certifying official again today and has only received a
busy signal at the number provided by the borrower. They left a voicemail with the borrower, but have not
yet heard back.
In the event that the business unit is unable to get in touch with the certifying official, how would you like
us to proceed with this borrower? Ultimately, based on our research, we believe this employer should
remain denied as we have not yet received any evidence that the employer (or the borrower, based on
his contracted employment) would qualify for PSLF purposes.
Thank you,
Sara Preston
Compliance Services
(717).720.2808
[email protected]
c::ro,'l "Tiongqu1co, Rene" <Rene Tiongquico@ed fo~>e;>;.,..-~==-----~

To FedLoan PSLF <[email protected]>. 0(balo(5"1 __ ,.llaibaJ(c5cl
-----~
Cc ""Battle, Cynthia'" <[email protected]>
n'":e 08/30/2016 05.04 PM
Subject [external]RE: RE. RE. RE: United Nations Office of Project Service
Sara:
Any update on whether the individual was a contractor?
-Rene Tiongquico

To: l(bJ(SJ I
Cc: Battle, Cynthia; Fedloan PSLF; Tiongquico, Rene
Hi Taneka,
vacation for two weeks (until 8/18/16). So it seems this one will be on hold for a little longer. We will keep
you updated.
Thank you,
Sara Preston
Compliance Services
(717).720.2808
[email protected]
-,,,., l/bl/51 U(b)(S)

To FedLoan PSLF <[email protected],,;>,,,,,--,
Cc ""Battle, Cynthia'" <[email protected]>, !(b)(S) l<[email protected]>, "'T1ongqu1co.Rene"'<[email protected]>
n'":e 08/03/2016 01.26 PM
Subject [external]RE: RE. RE. United Nations Office of Project Service
Hi Sara,
I tried to do a reverse look-up on the phone number that was provided and I think that the employer provided a
fax number (see below}. If the Business Unite is unsuccessful with emailing the certifying official, I believe you may
be able to reach the Ms. Siles by calling 212-457-4000 or the number listed on ldealist.org. Thanks, Taneka
https ://www. j mu .ed u/ cisr/ pages/ research/gm ar /search/unite d-n atio ns-office- for -project-services- un ops.sh t m I
http://www.idealist.org/view/nonprofit/32FnZjh3PCJ74/

51~~~
Cc: Battle, Cynthia; Fedloan PSLF; ~l(b~l(~
Rene,
Thank you,
Sara Preston
Compliance Services
(717).720.2808
[email protected]
c::ro,'l "Tiongqu1co, Rene" <Rene Tiongquico@ed f"f'\i,,.,---,m,m-------,

6~;.~~;l~~~~:i~~,~~~~~~~~~~~:e~:de~~vo:g>. •'b")"(5"1
__ ,.ll"(b")("5")
-----~
n'":e 07/26/2016 02.15 PM
SubJect [external]RE: RE. United Nations Office of ProJect Service
Sara: Did you all contact the certifying official to confirm that the borrower was employed as a contractor?
-Rene Tiongquico
Federal Student Aid

To: l(bJ(5J I
Hi Taneka!
Thank you,
Sara Preston
Compliance Services
(717).720.2808
[email protected]
c::ro,'l l/bl/51 U(b)(5)

Cc 'T1ongqu1co, Rene" <[email protected]>, ulf~b)~(5~1-~lulfb~)~(5~)
_____ 0 1"Battle, Cynthia" <[email protected]>
n'":e 07/18/2016 01.35 PM
Subject [external]RE: United Nations Office of Project Service
H1Kim,
I have copied ReneTiongquico to this email. He is in the process of being added to the public service mailbox and
will be serve in the same capacity as Ian did with assisting Program Management in reviewing employer
escalations.
In regards to the United Nations Office for Public Service - Could you have someone in the businessoffice contact
the certifying official, Ms. Monica Siles,to confirm that the borrower works for the United Nations Office of Project
Serviceas a contractor? The employer's dispute letter is focused on why they believe the organization qualifies
rather than if the borrower is a contracted employee. I believe having the certifying official confirm the borrower's
status will go a long way in helping the borrower understanding why he does not qualify for PSLF.Rene and I will
continue to research the organization, however, at first glance your logic makes sense.
Thanks,
Taneka

Sent: Thursda , July 14, 2016 11:30 AM
To: (b)(5)
Hi Taneka!
We received an ECF for this organization in September 2015 and had denied as, from what we could
determine, the borrower was not working for the U.S. mission to the United Nations.
The borrower disputed the denial in February 2016, but still did not provide any conclusive evidence he
works for the U.S. mission.
Again in June 2016, the borrower sent in additional information. He sent in copies of his tax return, as he
indicated he does not receive W-2s. His tax return shows he is a contractor. Based on no additional
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: l(b)(5)
Sent: 12 Sep 2012 11:06:32 -0500

Subject: RE: Re: RE: Skydancer Hotel and Casino (Tribal)
Diane,
lfwc can get ~omc sort of documentation from the employer that proves that the casino i~ part of the tribal
government, then we will deem it qualifying employment.
Sony for the delay.
Ian
Sent: Friday, Aurst 31, 2012 10:27 AM
To: l(b)(5)
Subject: FiN:Re: RE: Skydancer Hotel and Casino (Tribal)
Hi Ian, I think this one is still outstanding. Thanks.
Diane
----- Fon.vardcd by Diane f-rcundcl/PHEAA on 08/31/2012 10:26 A\1 -----
From: FcdLoan PSLF/PHEAA
To: f-cdLoan PSLFiPHEAA½_WHEAA
Cc: "Sipple-Asher, Bc~~IC"<BcssicKo.Sipplc/\sher(d!cd.gov>, "Johnson, Dcbbc"

<Dcbbc.Johnson(t1Jcd.gov>, "FcdLoan PSLF"
<FedLoanPSLF(a;phcaa.org>, "Foss, Ian" <Ian.Foss(a;ed.gov>, l(b)(5)
l(b)(5) I
"Nincmirc, Sandra" ~---~
<Sandra.Nincmirc(a;'ed.gov>
Date: 07/17/2012 10:29 PM
Subject: Public: Re: RE: Skydancer Hotel and Casino (Tribal)
Sent by: Diane Freundel
Ian, We obtained additional information from thi~ employer. 1al~o

copied one of the key items from your 5/21 email in thi~ chain.
From your email:

> There arc two great white paper~ on the organization~ of tribal
businesses.
> One is by the IRS (here) and one is by the State of\tlichigan (here).
Both
> make plain that there arc five common structures: unincorporated,
> tribal ~ubdivision~, Section 17 Corporation~ (federally chartered
> corporation~). corporations chartered under tribal law. and
> corporation~ organized under ~tate law. Only organization~ that fall
> into the first two categories,
above,
> would be con~idered "tribal governmental organizations" for PSLF
purposes, I
> would think.
Info from employer:

BotTower states he asked the CFO for this information and CFO states Skydancer is sole proprietorship
under tribal subdivision.
Would they not qualify because they are a sole proprietorship even though
they are under a tribal subdivision? Thanks.
Diane Freundel
Compliance Services
(717) 720-3267
fax-(717) 720-3911
[email protected]
From: FedLoan PSLF/PHEAA
To: l(b)(5)
Cc: "Sipple-Asher, Bc~~IC"<BessicKo.Sipplc/\sher(d!cd.gov>, "Johnson, Debbe"

<Debbe.Johnson(t1Jed.gov>, "FcdLoan PSLF"
<FedLoanPSLF(a;phcaa.org>, "Foss, Ian" <Ian.Foss(a;ed.gov>, l(b)(5)
l(b)(5) I
"Ninemire, Sandra" ~---~
<Sandra.Ninemire(a;'ed.gov>
Date: 06/14/2012 10:52 PM
Subject: Public: RE: Skydancer Hotel and Casino (Tribal)
Sent by: Diane Freundel
Thanks Ian. I thought I was missing something. I didn't get much out of
it other than:
1. There is a Gaming Compact between the Tribe and the ~tatc of ND. and 2. The Compact provides the
Tribe with the opportunity to license and regulate Cla~s Ill gaming to benefit the tribe economically
Nothing dc~cribcs the type of structure of Skydanccr. However, if the

purpose of allowing the Tribe to license and regulate gaming i~ to benefit the Tribe economically, I guc~~
you could infer that the gaming corporation/entity's owner(s) couldn't be receiving profits, unlc~s the
owner(s) is the Tribe. That\ probably a ~trctch.
I can ask the Business Unit to go back and ask a more pointed question:
What i~ the ~tructurc of Skydanccr? I~ it unincorporated, a tribal ~ubdivision, a Section 17 Corporation
(federally chartered corporation), a corporation chartered under tribal law, or a corporation organi?cd under
~tatc law.
Diane Frcundcl
Compliance Service~
(717) 720-3267
fax-(717) 720-3911
From: l(b)(5) U(b)(5)
To: "FedLoan PSLF" <[email protected]>, "'(b_l(_5_)

--"'"'(b_l(_51______ ~
Cc: "Sipple-Asher, Bessie" <BessieKo.SippleAsher(~ied.gov>, "Johnson. Debbe"

<[email protected]>, "Foss, Ian"
<[email protected]>, "Ninemire, Sandra" <[email protected]>
Date: 06/14/201203:14PM
Subject: RE: Skydanccr Hotel and Ca~ino (Tribal)
Diane,
I'm e~calating this one further. In the meantime, what was this documentation intended to ~how? All I can
di~cem from it is that the tribe 1~ authorize "licen~e and regulate", i.e.. pem1it to occur gambling within the
tribe. If that's all you got out ofit too. then that's fine. but I wondered ,,,,..hatyour thoughts were on ,,,,..hat
this documentation sh01,vs.
As for their code, it seems as though their website is being moved to another place and is not yet available.
This is probably why the links I sent you were not available.
Ian

> From: Diane Freundel [mailto:dfreundefa'.pheaa.orgl On Behalf Of FedLoan
> PSLF
> Sent: Thursday, .lune 14, 2012 9:30 AM
> To: l(b)(5) I
> Cc: Sipplc-A~hcr. Bessie: John~on. Dchbc: FcdLoan PSLF; Foss, Ian;
>l(b)(5) INincmirc, Sandra
> Subject: RE: Skydanccr Hotel and Ca~ino (Tribal)
>
> Iii Ian, We received additional infonnation from Skydanccr, but I ~till
> can't make a dctcnnination. Can you please review? Also, the third
link
> in your email belO\v (Tuttle Mountain Band's legal code) goes to a "web
page
> not found" message.
>
> A~ alway~. we greatly appreciate your a~si~tancc. Thanb!
>
> (Sec attached file: Skydanccr _additional documcntation.?ip)
>
> Diane Frcundcl
> (717) 720-3267
> fax-(717) 720-3911
> dfreundc(a;phcaa.org
>
>
> 1------------>
> I From:
> 1------------>
>
>-----------------------------------------------------------------------
>--------------------
>---------------------------------------------1
> pub Iicservice l(b)(5)
>I ~-----~
>
> ----------------------------------------------------------------------
> -------------------
> ------------------------------------------1
> 1------------>
> I To, I
> 1------------>
>
>-----------------------------------------------------------------------
>--------------------
> ---------------------------------------------1
> "FedLoan PSLF" <FedLoanPSLF(iijpheaa.org>, Ll(~b)~(5~1
__ _,
> !(b)(5) !
I
>
>-----------------------------------------------------------------------
>--------------------
> ---------------------------------------------1
> 1------------>
>IC" I
> 1------------>
>
> ----------------------------------------------------------------------
> -------------------
> ---------------------------------------------1
> "Fos~. Ian" <lan.Foss(d)cd.gov>, "Nincmirc. Sandra"
> <[email protected]>, "Sipple-Asher. Bessie"

> <[email protected]>, I
> "Johnson, Dcbbc" <Dcbbc..lohnson½_~·cd.gov>
>I
>
> ----------------------------------------------------------------------
> -------------------
> ---------------------------------------------1
> 1------------>
> I Date: I
> 1------------>
>
>-----------------------------------------------------------------------
>--------------------
> ---------------------------------------------1
> 05/21/2012 10:05 AM
>I
>
>-----------------------------------------------------------------------
>--------------------
> ---------------------------------------------1
> 1------------>
> I Subject: I
> 1------------>
>
> ----------------------------------------------------------------------
> -------------------
> ---------------------------------------------1
> RE: Skydanccr Ilotcl and Ca~ino (Tribal)
> I
>
>-----------------------------------------------------------------------
>--------------------
> ---------------------------------------------1
>
>
>
>
>
> Hi Diane,
>
> I don't think this organization qualifies, but I cannot give a very
reasoned
> answer a~ to why; ~pccifically, because I cannot find any information
about
> the organization beyond what you have already found. We probably need
> to follow-up with the employer.
>
>
> There arc two great white paper~ on the organization~ of l1ibal
businc~ses.
> One is by the IRS (here) and one is by the State of\tlichigan (here).
Both
> make plain that there arc five common structures: unincorporated,
> tribal ~ubdivision~, Section 17 Corporation~ (federally chartered
> corporation~). corporations chartered under tribal law, and
> corporation~ organized under ~late law. Only organization~ that fall
> into the first two categories,
above,
> would be con~idcrcd "tribal governmental organizations" for PSLF
purposes, I
> would think.
>
> The only thing that I could confirm about this organiLation is that it
> is
not
> organized under state law.
>
> From what I can discern, the Turtle Mountain Band of Chippewa Indians
> is
'> legally sophisticated tribe. 1say legally sophisticated because they

have their
> own legal code. including a business/corporations code (see here).
> Therefore. I think it is unlikely that the casino would be
"unincorporated". I
> ~uspcct that the ca~ino is a businc~~ that is organized for-profit
> under
the
> tribal code, but again cannot be sure.
>
> If the employer claims that it i~ a political ~ubdivision, it will
> likely
have a lcllcr
> lo that effect from the IRS or the BIA-DOI (Bureau oJ'Indian
> Affairs/Department of the Interior). The ~amc is true oJ'a Section 17
> Corporation, except that it would only have documentation from the
> BIADOL
>
> Ian
>
>> From: Diane Freundel Lmnilto:dfreunde(a,phean.orgl On Behalf Of
> > Fedloan PSLF
>> Sent: Fridav, \tlav 18. 2012 9:33 AM
>>To: l(b)(5) )
>>Subject: Skydancer Hotel and Casino (Tribal)
>>
>>
>>Hi, Arc Tribal casino~ a part of the Tribal government? My research
>>indicates that the gambling income of the tribe~ and their federally
> chartered
>>corporation~ (form u~ually taken by the casino~) arc not ~ubjcct to
> federal
>>income tax (~cc page 3 ofnagaming.pdf). However, the ma~tcr ~eek
>>document indicates they arc a private company, in which case they
>>would nol qualify ~incc they don't provide a qualil)ling service.
>>Their website
> is
> > rc~trictcd here at work because it'~ gambling, but I checked it on
>>my
> phone
>>and couldn't find anything definitive.
>>
>>We'll be ~ccking additional certification since thi~ [Cf, is
> self-certified
>>if the organization qualilic~. Password lo follow. Thanks!
>>
>>(Sec allachcd file: Sky Dancer I lolel and Ca~ino.Lip)
>>
> > Diane Frcundel
> > (717) 720-3267
> > fax-(717) 720-3911
> > dfreunde(i1;pheaa.org
>>This message contains privileged and confidential information
>>intended
> for
>>the above addressees only. If you receive this message in error
>>please delete or destroy this message and/or attachments.
>>
>>The sender of this message will fully cooperate in the civil and
>>criminal pro~ecution of any individual engaging in the unauthorized
> > u~c of this mc~~agc.
>
> This message contain~ privileged and confidential information intended
for
> the above addressees only. If you receive thi~ mc~~agc in cnor
> please delete or de~troy this message and/or attachments.
>
> criminal pro~ccution of any individual engaging in the unauthoriLcd
> u~c or this me~~age.
you receive this message in enor please delete or destroy this message and/or attachments.
From: l(b)(5)
Sent: 5 Jun 2017 12:56:12 +DODO
To: Fedloan PSLF
Cc: 5'-I___
Subject: RE: Re: Re:Dan River Neurotherapy Center
Attachments: Denial_Dan River Neurotherapy Center_20170601_Foss.docx
Hi Kim,
Thanks for providing the letter for review. See attached from Ian.
Have a good day,
Taneka

Sent: Thursda , June 01, 2017 7:40 AM
To: (b)(5)
Subject: Re: Re: Re:Dan River Neurotherapy Center
Hi Taneka! Attached is the draft denial letter for this borrower. I redacted all information so I could just
attach it to this email. Please let me know if you have any changes/questions. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
c::ro,'l l/bl/51 U(b)(5)

Cc "Odom Chnsl1an"' <Christian Odom@ed gov>, "Battle, Cynthia'" <Cynth1a.Battle@ed gov>, "Foss, Ian"' <Ian [email protected]>,
l{b)/5) U(b)(5) I
n;;:e 05/1812017 05:08 PM
SubJect [external]Re. Re:Dan River Neurotherapy Center
Hi Kim,
Thank you for providing the documentation so quickly. After reviewing the additional
information, we still do not believe that this organization qualifies under tribal government.
The attached document is just stating that the Dan Neurotherapy Center has a license to
practice medicine under a tribal provider network but not not that the organization is
governmental.
Please let us review the letter before mail-out.
Thanks,
Taneka

Sent: Wednesday, May 17, 2017 12:01:41 PM
To: l(b)(5) I
Cc: Odom, Christian; Battle, Cynthia; Fedloan PSLF;Foss, Ian
Subject: Re:Dan River Neurotherapy Center
Hi Taneka! In response to the request, the borrower sent the following documentation. Please let me
know if you deem this acceptable.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
· r~w1 i(b)(5) li(b)(5) I

Cc !(b)(5) U(b)(5) I
"Battle, Cynthia" <[email protected]>, "Foss, Ian" <[email protected]>. "Odom,
Christian" <Christian. [email protected]>
n;;:e 051041201710:17 AM
[external]Re: Dan River Neurotherapy Center
Hi Kim,
We agree with FedLoan's assessment that this organization does not provide a qualifying
service. When FedLoan sends out correspondence to the borrower can you explain that if the
borrower is able obtain a signed letter from the tribe (on letterhead) stating that his
organization is part of tribal government we can reconsider the organization for PSLF.
Thanks,
Taneka

To: l(b)(5) I
Subject: Dan River Neurotherapy Center
Hi Taneka! Although not directly a dispute, I wanted to forward this to you for review as the borrower did
ask for a re-review of their employer.
This borrower appears to be the owner of the organization. In January 2016, he submitted his ECF using
the EIN 27-0086296, and certified under government. Oddly enough, the Facebook page links up to
Whole Counsel Associates, which is a for-profit organization. The borrower did provide documentation
showing he is authorized by the Tribal Health Programs & Clinics as a "Student Tribal Healer", although
this does not automatically make his organization tribal/governmental. We found information indicating
this organization is a not-for-profit (including the website). However, we determined they do not provide a
qualifying public service. We subsequently denied this organization.
The borrower sent in another ECF along with an IRS EIN assignment letter in October 2016, but this was
just forwarded to us for review. The borrower again certified as government, but under the EIN 81-
4188291. The IRS EIN assignment letter verifies this EIN links to Dan River Neurotherapy Center, but is
dated 10/20/16.
While, the borrower didn't provide any further evidence of qualifying status, we still don't think this
organization qualifies for PSLF purposes. As always, your assistance is appreciated.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
f SERVICING
www.MyFedLoan.org
Phone: 1-800-699-2908 Fax: 717-720-1628
May 31. 2017
Redacted
Redacted
Redacted
Dear Redacted:
Thank you for your correspondence regarding your student loan account serviced by us, on
behalf of the U.S. Department of Education (the Department), detailed bclO\v.
Loan Disbursement Loan Original Principal Current Principal

Seouence Date Tune Balance Balance
Redacted Redacted Redacted Redacted Redacted
I Redacted II Redacted II Redacted II Redacted I Redacted
lb!!w111 n. Ford Federal Direct I nw1 Program (Direct)
*Increase in prinujwl ha/mice is the remit of'interesl capilafi::atio11.
On May 11, 2017, we received your correspondence regarding the Public Service Loan
Forgiveness (PSLF) program for the employer, Dan River Neurotherapy Center. After reviewing
the documentation and after consulting with the Department, the Department determined that
Dan River Ncurothcrapy Center ooes-----HB-t
qualify L-t-Atlefis
not a tribal governmental organization.
The documentation you provide _indicates that Dan River Neurotherapy Center has a license to
practice medicine under a tribal provider net\vork but not indicate that the organization
is governmental.
To be eligible for PSLF, you must be directly employed by a ''public service organization" as
defined in the PSLF eligibility criteria statement on the back of this letter. If you have any
additional questions regarding PSLF, please refer to the infonnation on the back of this letter. If
the information does not ans\ver your questions or you ,.vish to provide additional documentation
supporting Dan River Neurotherapy Center's status as a qualifying employer for the purposes of
PSLF. call 855-265-4038.
Sincerely,
FcdLoan Servicing
Rcducr,0
F:LIGIBLITY CRITERIA FOR PARTICIPATIO:"J l:"J THE Pt..:BLIC SERVICE LOA:"J
FORGIVEl\'ESS PROGRA'.\-1
You must have made 120 on-time, separate. monthly payments i!ficr October 1. 2007. on the Direct Loan
Program loans for which l'nrgivencss is requested. Payments made prior to October 2. 2007 do not count
toward meeting this requirement Each or the 120 monthly payments must he made for the Cull_scheduled
installment amount within 15 days of the due dale.
The 120 required payments must be made under one or more of the following Direct Loan Program repayment
plans:
• Income Contingent Repayment (!CR) Plan (not available for parent Direct PLUS Loans or Direct
• Pay As You Earn Rcpaymcnt Plan (not available for parent Direct PI.US Loan~ or Direct
• Rcviscd Pay As You Earn Repayment Plan (nut availablc fur parcnt Direct PLUS Loans or Direct
Con~olidation Loans that rcpaid a parcnt PLUS Loan)
• Standard Repayment Plan with a 10-ycar repayment period
• Any other Direct Loan Program repayment plan; but only payments that are at least equal to the
You must be employed full-time (in any position) by a public service organization, or must be serving in a full-
time AmeriCorps or Peace Corps position at the time you make each qualif)'ing payment. Organizations that
meet the definition of"public service organization" for purposes of the !'SL!- Program are listed below.
• A government organization (including a federaL state, local or tribal organization, agency, or entity; a
(includes most not-for-profit private schools, colleges, and universities):
• A privalc. non-profit organi;,ation* (that is not a labor union ur a partisan political organi1:ation) that
• Public safety
• Law enforcement
• Early childhood education (including licensed or regulated health care, I lead Start, and state-
occupations)
• School library or other school-based services

*NOTF.: For p111poses of the_/11l!-timerequirement (Section 3. Item 7 & fl of the F:CF), _vour qua/Jjring
employment does not include time .1pent on_joh duties that are related to religious in1·truction. irorship
servll·cs, or a11yj(mn of'pmsc/ytizing.


Sent: 8 Feb 2017 16:49:18 +0000
To: Fedloan PSLF
Cc: 5'-I___
Subject: RE:Re: URSEnergy and Construction Inc - Retraction
Sorry- that was a typo on my part It should be for-profit.

Thanks for catching that!
Taneka
Cc: Odom, Christian; Battle, Cynthia; Fedloan PSLF;Foss, Ian; .l(_bl_(5_1 __ ~
Subject: Re: Re: URS Energy and Construction Inc - Retraction
Hi Taneka! I will reach out to the Business Unit for clarification and a root cause analysis on how and why
the error occurred, but in the interim, I just want to clarify the information you found and outlined below.
I had previously found this organization was for-profit, but below you indicated the organization is private
not-for-profit but does not provide a qualifying public service. I had not found indication of not-for-profit
status. I just want to ensure the denial letter reflects accurate information (denied for being not-for-profit
not providing a qualifying public service vs for-profit). Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
-r,w,"Chialastri, Taneka" <Taneka.Chialastri@ed gov>

c, "Foss Ian" <Ian [email protected]> "Battle, Cynthia" <Cynthia [email protected]>, "Odom, Christian" <Christian Odom@ed gov>,
l{b)/5) U{b)/5) I
Da:c 02/08/2017 09·14 AM
Subwct [external]Re: URS Energy and Construction Inc - Retraction
Hi Kim,
My apologies - I missed sending a response for this. URS Energy and Construction, Inc. should
be retracted. The organization is private not-for-profit and does not provide a qualifying
servicer. We also did a search of the certifying official and although the individual has a
government email one of the sites we came across has him listed as a contractor. Would
Fed loan be able to conduct a root cause analysis on how and why the error occurred. This
borrower most likely thinks they are a year or so out from forgiveness so it would be good to
have that information just in case the borrower escalates after learning they no longer qualify.
Can you also send the retraction letter for our records.
Thanks,
Taneka

Sent: Friday, January 6, 201712:S4:00 PM
To: l(b)(5) I
Subject: URS Energy and Construction Inc - Retraction
Hi Taneka! The employer, URS Energy and Construction, Inc, was recently escalated to us for review. On
the ECF, the employer certified as governmental, 501 (c)(3) and private not-for-profit performing multiple
public services (Emergency management, public safety and public health). One thing to note is that the
certifying official appears to be from the CDC, as the form was certified with an email of [email protected].
In performing a search of the borrower, we found that the borrower is directly employed by URS and not
the CDC. While this organization has changed names over the years through mergers, etc, they
organization itself is for-profit.
This particular borrower has submitted ECFs previously, and these were approved in error by the
Business Unit. Currently he is showing approved from 1/1/08 to 11/19/15. This is the only impacted
borrower.
I have attached all ECFs we have received and the research we have performed. Please advise on the
retraction. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
attachments.
Code:PHEAA
From: Foss, Ian

Sent: 30 Jun 2017 19:10:45 +0000
To: !(b)(5) I
Subject: RE: Re: Young Achievers Academy Inc
I don't know if you sent this out already, but no edits from me.

Sent: Sunday, June 25, 2017 11:35 AM
To: l(bJ(5J I
Subject: Re: Re: Young Achievers Academy Inc
Hi Tankea! Please see the letter drafted for this organization. I redacted all personal information.
Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630

Cc l{b)(5) U(b)(5) I "Foss, Ian" <Ian [email protected]>. "Battle. Cynthia" <Cynthia [email protected]>. "Odom,
D:i:e 06/13/201711:42AM
SubJect [extemal]Re. Young Achievers Academy Inc
Hi Kim,
Thanks for sending our previous decision. We agree that this employer does not qualify for PSLFsince it is for-
profit As a contractor, Young Achievers Academy and its employees are not employed by the state or county.
Can you send over the denial letter for review before mailing.
Thanks,
Taneka

To: l(b)(5) I
Subject: Young Achievers Academy Inc
Hi Taneka! This borrower completed her ECF by checking "no" to all three of the qualifying boxes (9, 1O
and 11), thus certifying ineligibility. As a result, the Business Unit denied her ECF. The borrower sent in
supporting documentation acknowledging that the employer is for-profit, but was requesting
reconsideration due to to the contracts they have with the Illinois State Board of Education and other
entities. We had a similar organization such as this in the past and ultimately denied (I attached that
guidance as well). However, since the borrower is requesting a re-review, I am escalating for your
review.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: l(b)(5)
Sent: 18 May 201717:50:44 +0000
To: Foss, Ian
Subject: Re: Re:Dan River Neurotherapy Center
(b)(5)
Yeah. I a rree that the
(b)(5)
From: Foss, Tan

Sent: Thursday, May 18, 2017 12:19:54 PM
To: !(b)(51 I
Subject: RE: Re:Dan River Neurotherapy Center
I don't think this proves that the organization is the Tribal government. Do you?

Sent: Wednesday, 17 May, 2017 13:02
To: l(bJ(5J I
Subject: Re:Dan River Neurotherapy Center
Hi Taneka! In response to the request, the borrower sent the following documentation. Please let me
know if you deem this acceptable.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
c::ro,'l l/bl/51 11/bl/5) I

Cc l{b)(5) U(b)(5) I "Battle, Cynthia" <Cynth1a.Battle@ed gov>, "Foss, Ian" <Ian [email protected]>. "Odom,
D:i:e 05/04/201710:17 AM
[external]Re. Dan River Neurotherapy Center
Hi Kim,
We agree with Fed Loan's assessment that this organization does not provide a qualifying
service. When Fed Loan sends out correspondence to the borrower can you explain that if the
borrower is able obtain a signed letter from the tribe (on letterhead) stating that his
organization is part of tribal government we can reconsider the organization for PSLF.
Thanks,
Taneka

To: l(b)(5) I
Subject: Dan River Neurotherapy Center
Hi Taneka! Although not directly a dispute, I wanted to forward this to you for review as the borrower did
ask for a re-review of their employer.
This borrower appears to be the owner of the organization. In January 2016, he submitted his ECF using
the EIN 27-0086296, and certified under government. Oddly enough, the Facebook page links up to
Whole Counsel Associates, which is a for-profit organization. The borrower did provide documentation
showing he is authorized by the Tribal Health Programs & Clinics as a "Student Tribal Healer", although
this does not automatically make his organization tribal/governmental. We found information indicating
this organization is a not-for-profit (including the website). However, we determined they do not provide a
qualifying public service. We subsequently denied this organization.
The borrower sent in another ECF along with an IRS EIN assignment letter in October 2016, but this was
just forwarded to us for review. The borrower again certified as government, but under the EIN 81-
4188291. The IRS EIN assignment letter verifies this EIN links to Dan River Neurotherapy Center, but is
dated 10/20/16.
While, the borrower didn't provide any further evidence of qualifying status, we still don't think this
organization qualifies for PSLF purposes. As always, your assistance is appreciated.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: Foss, Ian

Sent: 14 Jul 2014 13:08:11-0500
To: Fedloan PSLF;publicservice
Subject: Re: Region 8 Mental Health
Hi Diane,
Thi~ i~ more like it! Based on this new documentation, the employer
qualifies a~ governmental.
Thanh.
Ian
On 7il4il4. 14:0L "FedLoan PSLF" <FedLoanPSLF(d!pheaa.org> wrote:
>Hi Ian. I missed something that came with the 1st W-9 we received for the
>Region IO entity. This W-9 was signed on 6/20/13, but the W-9 itself was
>outdated - it had a revision date of January 2002. We therefore requested
>that they use the current W-9. Attached to the 1st W-9 was other
>documentation that indicates it's a state agency - the cover letter to the
>attachment and Form 637 from November 1973 (last page of attachment). We
>also looked at the Mississippi statute referenced in the cover letter
>(also
>attached). I think this is enough evidence that Region 10 is a state
>agency. Would we need something similar for the other entities (see below
>for decision on Region 8)? I apologize for missing this information
>before. Attachment~ do not contain borrower level data, ~o I didn't zip
>it. Plca~c give m your thoughb. Thanh
>
>
>( Sec attached file: Employer proof of Government Status.pdf)
>(Sec allachcd file: Section 27-65-105(a) \1i~~is~ippi Code of 1972.pdl)
>
>Diane Frcundel
>(717) 720-3267
>fax- (717) 720-3911
>
>
>
>
>
l(b)(5) U(b)(5)
>To:"Fedloan rSLF" <FedLoanPSLF(~ipheaa.org>
>Cc:"Battle, Cynthia" <[email protected]>, "Johnson, Debbe"
> <Debbe.Johnson(~!ed.gov>, "Foss. Ian" <[email protected]>
>Date:07/11/2014 09:32 AM
>Subjcct:Rc: Region 8 Mental Health
>
>
>
>I don't think that writing 'governmental' in the 'other' field is enough.
>on its O\vn,to substantiate that an organization is governmental. There's

>no control over what organizations write in that field. More conclusive
>evidence would be the 1cxcmpt payee code', which contains ~pccific code~
>for ~tatc and local governments. 11d note that with Region 8. thi~ field
>wa~ left blank.
>
>http://www. irs.gov/pub.iirs-pd fi fw9.pdf
>
>Sorry if you got thi~ tw1cedt's showing up in my dralls foldcrSso I'm
>assuming I've not sent il already.
>
>On 7/8/14, 14:57, "FedLoan PSLF" <FedLoanPSLF(a;pheaa.org> wrote:
>
> Iii Ian, I should have asked this before. Is a W-9 sufficient for
> validation of government status? Thanks!
>
> (See attached file: Form W-9.pdt)
>
> Diane Freundel
> (717) 720-3267
> fax- (717) 720-3911
> [email protected]
>
>
>
>
> From: l(b)(5) U(bJ(5)
> To: "FedLoan PSLF" <FedLoanPSLF½_~·pheaa.org>
> Cc: "Foss, Ian" <[email protected]>, "Battle, Cynthia"
> <Cynthia.Battlc(c(cd.go\'>. "John~on, Debbc"
> <Debbc.Johnson(a;ed.gov>, "l(~b)~(5~)-~~ll'rn(b~)(~5~)
------~
> Date: 04/28/2014 11:24 AM
> Subject: RE: Region 8 Mental Ilealth
>
>
>
> Hi Diane,
>
> I'm not sure that any of these centers are "government". While it's true
> that they operate under the supervision of local governments, it doesn't
> make the organization a governmental entity.
>
> When I go to region 8's website. the title of the site is "Region 8
>\tlental
> Health Commission", \vhich is something that I can also find in the NPI
> database, and certainly suggests that it is governmental. but I can't
>find
> out ofthi~ is genuinely a government organization or whether it i~ ~till
>a
> not-for-profit organization.
>
> I cannot even find the law that cited on Department of Mental Health's
1
~
> website. So. we can approve Region 8 for the period that you found it was
> lax exempt under !RC 50l(c)(3). Bui the others should not be approved
> without following up with the organiLations to determine if they really
> are
> governmental.
>
> Ian
>
r
> From: Diane Frcundcl mailto:dfrcundC:ciphcaa.orgl On Behalf Of FcdLoan
>PSLF
> Sent: Wcdncsdav, April 23, 2014 10:29 AM
> To: l(b)(5) I
> Subject: Region 8 Mental I lcallh
>
>
> Iii Ian, We'd like your input on thi~ particular one and ~ome other~ in
> the
> state of \1S that we already processed and may have processed one
> incorrectly. I'm only attaching documents for Region 8, but ifyou need
> the others, let me know. Password to follow. Thanks!
>
> Region 8:
>
>- ECF certified as 50l(c)(3)- employment beginning in Sept 2013. Their
> 501 (c )(3) status was revoked on 5/ I3/ 13. effective 2/ 15/ 13.
>
> - We could find no business filing for Region 8
>
> - According to the MS Dept of \1cntal Health wcb~itc, thc~c regional
> community mental health/mental retardation centers operate under the
> ~upcrvi~ion of regional commi~~ioncr~appointed by county board~ of
> ~upcrvi~ors. Addrc~s on [Cf, matchc~ addrcs~ on MSDMH wcb~itc.
>
> - Decision pending, but we think it's government
>
> Region 10:
>
> - ECF certified a~ 50 I (c )(3 ). We could find no evidence of 50 I (c)(3)
> statu~.
>
> - We could find no business filing for Region I0
>
> - According to the MS Dept of \1ental Health website, these regional
> community mental health/mental retardation centers operate under the
> supervision of regional commissioners appointed by county boards of
> supervisors. Phone number of certifying official on ECF matches phone
> number for Region IO on \1SD\1H wesite.
>
> - We previously approved as government.
>
> Region 4:
>
> - [(T certified a~ private non-profit providing public service for
> di~ablcd/cldcrly and public health.
>
> - We could find no bu~incs~ filing for Region 4
>
> - We initially denied bccau~c we couldn't tic the address/phone number on
> the ECr \vith information on the MSD\1H website. HO\vever,we found an
> article
> that ~how~ Region 4 opened an office at the addrc~~on the [CF.
>
> - We prc\'iously denied, but think we should appro\'c as government.
>
> (Sec attached file: Region 8 Mental Hcaltluip)
>
> Diane Freundcl
> (717) 720-3267
> fax-(717) 720-3911
> dfreunde(a;pheaa.org
>for
>
> message.
>for
> the above addressees only. If you
> receive this message in error please delete or destroy this message
>and/or
> attachmcnb.
>
> in the unauthorized u~c of this mc~~agc.
>
>receive this message in error please delete or destroy this me~~age
>and/or allachment~.
>

__ _,
Sent: 18 Jul 2014 14:34:55 -0400
To: Fedloan PSLF;Foss,Ian
Subject: Re: Region 8 Mental Health
Since I wa~ not able to find anything explaining how the commissions arc
~tmcturcd (except for a passing reference on Region 8's ~itc), I think it
only app lie~ to Region 10 (for now),
On 7il4il4, 14:15, "FedLoan PSLF" <FedLoanPSLF(d!pheaa,org> wrote:
>Thanks! Would this only apply to Region 10 or can we a~~ume that all
>or
>the 15 Regional \1cntal Ilealth Centers in \1S arc government?
>
>Diane
>
>
>
>From: "Foss, Ian" <IanSoss@ed,gov>
>To: "FedLoan PSLF" <FedLoanPSLF(?1)pheaa,org>,l(b)(5)
> l(b)(5) I ~--~
>Cc: "Battle, Cynthia" <Cynthia.Battle@ed,gov>, "Johnson, Debbe"
> <Debbe.Johnson(~ied.gov>
>Date: 07/14/2014 02:08 PM
>Subject: Re: Region 8 \1ental Health
>
>
>
>Hi Diane,
>
>This is more like it! Ba~cd on thi~ new documentation, the employer
>qualilie~ as govcrnmcntaL
>
>Thanks,
>
>Ian
>
>On 7/14/J4, 14:01, "FedLoan PSLF" <FedLoanPSLF@pheaa,org> 1Nrote:
>
>>Hi Ian, I missed something that came with the 1st W-9 we received for
>>the
>>Region 10 entity, This W-9 was signed on 6/20/13, but the W-9 itselfi,vas
>>outdated - it had a revision date of Januaty 2002. We therefore requested
>>that they use the current W-9. Attached to the 1st \V-9 was other
>>documentation that indicates it's a state agency - the cover letter to
>>the
>>attachment and rorrn 637 from November 1973 (last page of attachment), \Ve
>>also looked at the Mississippi statute referenced in the cover letter
>>(also
>>attached), I think this is enough evidence that Region 10 i~ a ~tatc
>>agency, Would we need ~omcthing similar for the other entities (~cc
>>below
>>for decision on Region 8)? I apologize for mi~sing thi~ information
>>before. Attachments do not contain borrower level data, so I didn't

>>zip
>>it. Please give us your thoughb. Thanb
»
»
>>(Sec attached file: Employer proof of Government Status.pdf)
>>(Sec attached file: Section 27-65- lOS(a) Mis~is~ippi Code of 1972.pdf)
»
>>Diane Freundcl
»(717) 720-3267
»fax- (717) 720-3911
>>dfreunde(t1Jpheaa.org
>>
>>From: l(b)(5) U(b)(5)

>>To: "redLoan PSLF" <FedLoanPSLr~pheaa.org>
>>Cc: "Battle. Cynthia" <Cynthia.Battle(,}ied.gov>, "Johnson. Debbe"
>> <[email protected]>, "Foss, Ian" <[email protected]>
>>Date: 07111/2014 09:32 AM
>>Subject: Re: Region 8 \tlental Health
>>
»
»
>>I don 1t think that writing 'governmental" in the 'othcr 2 field is enough,
>>on it~ own, to ~ub~tantiatc that an organin1tion i~ governmental. There 1
~
>>no control over what organizations write in that field. More conclu~ivc
>>evidence would be the 'exempt payee code\ which contains specific code~
>>for slate and local governments. I'd note that with Region 8, thi~ field
>>was left blank.
>>
> > hl tp: // www. ir~.gov ipubiir~-pdli fw9. pdf
>>
>>Sorry if you got this twice,it'~ showing up in my drafts folderSso I'm
>>assuming I've not sent it already.
>>On 7i8/14. 14:57. "FedLoan PSLF" <FedLoanPSLF(iijpheaa.org> wrote:
>> Hi Ian. I should have asked this before. Is a W-9 sufficient for
>> validation of government status? Thanks!
>>
>> (See attached file: Form W-9.pdf)
>>
>> Diane Freundel
>> Compliance Services
» (717) 720-3267
» fax-(717) 720-3911
>> dfrcundc((j)phcaa.org
»
»
»
>>
>> From: Ll(b-'-)('-51
___ ,.U('-b)-'-(5'-)
_____ _,
>> To: "redLoan PSLr" <FedLoanPSLr(~!pheaa.org>

>> Cc: "ross, Ian" <[email protected]>. "Battle, Cynthia"
>> <Cynthia.Battlc((j)cd.gov>, "John~on, Dchbc"
>> <[email protected]>, 'l("b)"(5,i)==~,ll'i,;(b"l("5")-------,
>> Date: 04/28/2014 11:24 A\1
>> Subject: RE: Region 8 Mental Health
»
»
>>
>> Iii Diane,
>>
>> I'm not sure that any of these centers arc "government". While it's true
>> that they operate under the superv1~ionof local governments, it doesn't
>> make the organiLation a governmental entity.
>> When I go to region 8's website, the title of the site is "Region 8
>>Mental
>> Health Commission". which is something that I can also find in the NP!
>>database.and certainly suggests that it is governmental, but I can't
>>find
>> out of this is genuinely a government organization or whether it is
>>still
>> a
>> not-for-profit organization.
>>
>> I cannot even find the law that cited on Department of Mental Health'~
1
~
>> wch~itc. So, we can approve Region 8 for the period that you found it
>>was
>> tax exempt under IRC 501(c)(3). But the other~ should not he approved
>> without following up with the organizations to dctcnninc if they really
>> arc
>> governmental.
>>
>> Ian
>>
>> -----Original Message-----
>> From: Diane Freundcl [maillo:dfreundc(dphcaa.Or!!] On BehalfOfFedLoan
>>PSLF
>> Sent: Wednesday, April 23. 2014 10:29 AM
>> To: l(b)(5) I
>> Subject: Region 8 Mental Health
>>
>> Hi Ian, We'd like your input on this particular one and some others in
>> the
>> state of MS that we already processed and may have processed one
>> incorrectly. I'm only attaching documents for Region 8, but if you need
>> the others, let me know. Password to follow. Thanks!
»
>> Region 8:
»
>> - [(T certified a~ 50\(c)(]) - employment beginning in Sept 2013.
>>Their
>> 50 I (c)(3) status was revoked on 5/13/ 13, effective 2/15/ 13.
>>
>> - We could find no business filing for Region 8
>>
>> - According to the MS Dept of \tlental Health website. these regional
>> community mental health/mental retardation center~ operate under the
>> supcrvi~ion of regional commissioners appointed by county boards of
>> supcrvi~ors. Addrc~~ on ECP matchc~ address on MSDMH website.
»
>> - Dcci~ion pending. but we think it'~ government
»
>> Region I 0:
>>
» - ECF certified as 50 I (c)(3 ). We could find no evidence of 501 (c)(3)
>> status.
>>
>> - We could find no business filing for Region 10
>> - According to the MS Dept of \tlental Health website, these regional

>> community mental health/mental retardation centers operate under the
>> supervision of regional commissioners appointed by county boards of
>> supervisors. Phone number of certifying official on ECF matches phone
>> number for Region 10 on MSDMH wesite.
>>
>> - We previously approved as government.
>>
>> Region 4:
>>
>> - ECF certified a~ private non-profit providing public service for
>> disabled/elderly and public health.
»
>> - We could find no bmincss filing for Region 4
»
>> - We initially denied became we couldn't tic the address/phone number
>>on
>> the ECF with infom1ation on the MSDMII website. Ilowever, we found an
>> ai1icle
>> that shows Region 4 opened an office at the addre~s on the ECF.
>>
>> - We previously denied, but think we ~hould approve as government.
>> (See attached file: Region 8 Mental Health.zip)
>> Diane Freundel

>> Compliance Services
» (717) 720-3267
» fax- (717) 720-3911
>> dfreunde(~!pheaa.org
>> This message contains privileged and confidential information intended
>>for
>> the above addressees only. If you receive this message in error please
>> delete or destroy this message and/or attachments.
»
>> The ~ender of this mc~~agc will fully cooperate in the civil and
>>criminal
>> prosecution of any individual engaging in the unauthorized use of this
>> mc~~agc.
>> This me~sage contains privileged and confidential infonnation intended
>>for
>> the above addressees only. If you

>> receive this message in error please delete or destroy this message
>>and/or
>> attachment~.
»
>> The ~ender of this mc~~agc will fully cooperate in the civil and
>>criminal
>> prosecution of any individual engaging
>> in the unauthorized use of this message.
>>
>> Thi~ mes~age contains privileged and confidential infom1ation intended
>>for the above addressees only. If you
>>receive this message in error please delete or destroy thi~ message
>>and/or attachments.
>>The sender of this message will fully cooperate in the civil and criminal
>>prosecution of any individual engaging
>>in the unauthorized use of this message.
>
>
>
>
From: Johnson, Debbe

Sent: 15 Oct 2014 06:51:53 -0500
Cc: Battle, Cynthia
Subject: RE: Requesting response by 11/3: RE: GFJC Project of Israeli NGO Shurat
Hadin
Wow -- more infonnation than I ever wanted to know about Amutas.
dj
Debhe "dj" Johnson I Management and Program Analy~t, Busine~s Operation~ I Federal Student Aid
P: (727) 940-5083 IC: (202) 440-0937 dehbe._johnson(d)ed.gov
From: Diane Freundel Lmailto:dfreunde:11-phean.or1tJOn BehalfOfFedLoan PSLF
To: l(b)(5) I
Cc: Battle, Cynthia; Johnson, Debbe; FedLoan PSLF
Subject: RE: Requesting response by 11/3: RE: GFJC Project of Israeli NGO Shurat Hadin
I guess we can call this fun!? :-) The borrO\ver will be pleased.
Thanks!!
l(b)(5) U(b)(5)
To:"FcdLoan PSLF" <FcdLoanPSLf-((_l'.phcaa.org>
Cc:"Battlc Cynthia" <Cynthia.Battle((1)cd.gov>, ".lohn~on, Dcbbc"
<Dehbe.John~on((_l'.ed.gov>,l(b)(5) U(bJ(5)
Datc:10/14/2014 04:13 PM ~---~•~-------~
Subjcct:RE: Requesting response hy 11/J: RE: OF.JC Project of hraeli
NGO Shurat I ladin
Hi Diane,
I think this qualifies. Notwithstanding that the borrO\ver says that GFJC is an American organization, it is
Shurat HaDin. Attached to the borrO\ver's latest letter is a certificate of incorporation from Israel stating that
Shurat HaDin is a Amuta. According to the Israeli code, an Amutah is "a body corporate for a lawful
purpose not aimed at the distribution of profits to its members may establish an amuta (non-profit society).
An amuta shall be constitued by registration in the Register ofAmutot." In other words, an Amuta is a not-
for-profit organization.
Now that the organization is established as a not-for-profit. between the information on Surtat Ha Din's
\vebsite and the other information we've found relating to the organization's activities, it provides legal
services.
Arc you having fun yet?
Ian
Sent: Tuc~da , October 14, 2014 3:35 PM
To: (b)(5)
Cc: Battle, Cynthia; Johnson, Dcbbc; f-cdLoan PSLF; Fo~~, Ian
Subject: Requesting response by 11/3: RE: Gf-JC Project of Israeli NGO Shurat Hadin
(b)(5)
The borrower is asking for a response by November 3. We appreciate your

help! Password to fo!IO\v, Thanks
(Sec attached file: New Information.zip)
Diane Frcundcl
Compliance Service~
(717) 720-3267
fax-(717) 720-3911
From: !(b)(5) ll(b)(5) I

To: "FedLoan PSLF" <FedLoanPSLF(U;pheaa.org>
Cc: l(b)(5) U(bJ(5) I
"Foss, Ian"
<[email protected]>, "Johnson, Debbe" <DebbeJohnson(?i)ed.gov>,
"Battle, Cynthia" <[email protected]>
Date: 08/26/2014 04:35 PM
Subject: RE: GFJC Project of Israeli NGO Shurat Had in
Hi Diane,
Thi~ one was the toughest yet. Herc's where we arc.
What we can do is to say we will accept foreign non-profits a~ qualifying employers only if the non-profit
directly or the borrower provide~ documentation (in English or in a form that can be translated into
Engli~h) documenting that the employer is a non-profit under that nation's law~.
They could submit ~omcthing comparable to our articles of incorporation or a governmental form
acknowledging the organiLation as a non-proliL ED docs have resources available to translate documents
into English if necessary but we should fir~t request a translated version from the entity or borrower.
On the qualifying service front, my recommendation would be to go back to the borrower and tell him that
while the Global Frontier Justice Center would appear to qualify as an entity, it still need~ to be providing
one of the identified service~. While he has provided a general ~tatcment about what the organization did
and referred us to their mis~ion statement we have not been able to find any publicly available information
that support~ those general ~tatcments. lfhc or the organization can provide documentation (which could
include citations to generally available public material which could include com1 dcci~ion~, etc.,) that
~how that they were providing legal ~ervicc~ to individual~ (a~ he claims in his letter) we will consider it
Lei me know if you'd like to discuss.
Ian
Sent: Wednesda 1 , August 06, 2014 12:00 PM
To: (b)(5)
Subject: GFJC Project of Israeli NGO Shurat Hadin
Hi Ian, If you can please expedite this one. we'd appreciate it. The
borrower requested a response within 60 days \vhich \viii be 8/13. I meant
to send it to you sooner. but I overlooked it I apologize. I did ask
the Business Unit to contact the borrower and let him know it's under review.
We previously denied this one. Our rationale wa~ as follow~:
Ba~ed on the letter provided with the [Cf,, the EIN provided belong~ to The Berkman Law Office. The
Global Frontier Justice Center (GF JC) was a project of an hraeli public service legal services organization
and GFJC doc~ not have an [IN. Berkman Law Office allowed Gf-JC to u~e spare office space and
equipment and processed GFJC'~ payroll through their office. They indicated the borrower'~ salary was
paid by GFJC, We denied because we could find no evidence of non-profit status and we believed that
GFJC was a foreign entity since the letter states they a project of an Israeli public service organization.
After our denial we received another leller ~tating that the GFJC is a project of its parent hraeli
organiLation, Shural IlaDin, a nonprofit organization registered a~ such in hracl.
We received a new letter appealing our decision. It states that the organization is not foreign - it operates
out of Brooklyn by US employees to litigate in US courts.
Please let us know if our denial was correct If correct, do you have any
suggestions on how to respond'? Passvmrd to follow. Thanks
(See attached file: GFJC Project of Israeli NGO Shurat Hadin.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax-(717) 720-3911
d freundc((_l'.phcaa.
org
engaging in the unauthorized use of this message,
From: l(b)(5)
Sent: 12 Sep 2012 11:19:49 -0500

Subject: RE: Riverfront Business District
Attachments: RE: Public Service Loan Forgiveness
Diane,
I don't think this qualifies.
It's not yet a 501(c)(3), and though a non-profit, it does not appear to provide any qualifying service. The
organization is not unlike the one discussed in the attached email. To the organization's point that it
provides public safety services--it does not do so directly. It does not actually renovate the buildings; it
provides funding to others to renovate the buildings. Even if it did directly renovate buildings, the
argument that this equates to public safety is tenuous as best. As to public education, being a "resource"
or providing "seminars" is not "public education"-we're looking for something more formal, in a
pedagogical setting.
Though this organization may ultimately become a 501(c)(3), I would note that business districts are
usually more like chambers of commerce, which are 501(c)(4) or 501(c){6)s.
What's more, though I would note that the Main Street Fort Madison site says that their predecessor
was the Riverfront Business District, the business filings support the opposite conclusion (Main Street
organized in 1988, was administrative dissolved in 1998, and never reformed; Riverfront organized in
2006). In addition, I don't know what being under the "auspices" means, but I don't think that's availing.
This is not one organization that is wholly owned by another. Riverfront is separately organized, and the
officers of one are not the officers of the other organization. And, in the articles of organization for each,
there is no mention of other organization. So, this couldn't even be a "disregarded entity" situation.
I can find Main Street Fort Madison, Inc. in Westlaw under EIN 42-1310798, which is different than the
"Fort Madison Main Street" on their website, I cannot find it in the IRSdatabase of tax-exempt entities,
either Pub 78 or the BMF.
Ian
To: l(b)(5J I
Subject: Riverfront Business District
Hi Ian, Another difficult one. She is one of the "QP" borrowers. ECF
indicates the organization is a 501(c)(3). We could find no indication of that status, but verified they are
a not-for-profit - their business filing still shows them as active. A google search associates them with
Fort Madison Main Street - website indicates it was founded in 2009, following its predecessor the
Riverfront Business District -website also indicates they are not-for-profit.
We asked the Business Unit to contact the employer for additional information. Employer indicated they
are working on their application for 501(c)(3). They are related to Main Street Fort Madison and are a
private non-profit. Borrower spends a lot of time working on securing grants and funding.
Representative went over the list of qualifying public services to determine if the Riverfront Business
District provides any of them.
Employer stated they work to get decaying 170 year old downtown buildings renovated and as such
would touch on public safety. Employer also said they touch on public education because they are a "go
to" organization and also do some seminars for building owners regarding available tools to get help
renovating and complying with building codes. Employer indicated they are under the "auspices" of
Main Street which he believes is a 501(c)(3).
'O<
(b)(5)
(See attached file: Riverfront Business District.zip)

Diane Freundel
Compliance Services
{717) 720-3267
fax- {717) 720-3911
[email protected]
From: Foss, Ian

Sent: 17 Feb 201219:57:52 +0000
To: rla [email protected]
Subject: RE: Public Service Loan Forgiveness
Dear Ms. Larson,
For employment to qualify for the Public Service Loan Forgiveness Program, you must be a full-time
employee of (1) a governmental organization, (2) a not-for-profit organization that is tax-exempt under
section 501{c)(3) of the Internal Revenue Code, or (3) a not-for-profit organization that provides a
From what I can discern, you work at the National Equity Fund, Inc. (EIN: 36-3490231), which, as you
stated {and I confirmed), is a 501{c)(4) organization. Although it is wholly owned by a 501{c)(3)
organization, that relationship, in and of itself, is insufficient for your employment to qualify as working
for a 501(c)(3) organization.
If you work for a 501(c)(4) organization, your employment will qualify if you work for (1) a not-for-profit
organization, (2) the organization provides a qualifying public service (see list below), (3) the
organization is not a labor union, and (4) the organization is not a partisan political organization. As a
general matter, 501(c)(4) organizations are not-for-profit and non-partisan (though they can lobby for or
against legislation). This would mean that your employer at least meets criteria (1) and (4), above.
Qualifying public services include:
• Emergency management,
• Military service,
• Public safety,
• Law enforcement,
• Public interest law services,
• Early childhood education (including licensed or regulated child care, Head Start, and State-
funded pre-kindergarten),
• Public service for individuals with disabilities and the elderly,
professionals engaged in health care practitioner occupations and health support
occupations, as such terms are defined by the Bureau of Labor Statistics),
• Public education,
• Public library services,
• School library services, or
• Other school-based services.
Assuming the National Equity Fund, Inc. (NEF) is your employer, I cannot determine what qualifying
service the organization might provide. Though I cannot be sure at this point, it might provide public
interest law services. However, from NEF's website, it appears as though NEF plays the role of the
syndicator in the Low-Income Housing Tax Credit (LIHTC) Program. My understanding of the role of the
syndicator (in the context of the LIHTC market) is that it is one who passes investor equity to a real
estate developer and returns tax credits to back to those investors. I'm honestly not sure whether this
includes the provision of public interest legal services. Certainly, the services NEF provides are
ultimately in the public interest, but I don't know whether they are legal in nature and exactly what legal
services NEF might provide and to whom.
I realize that this still leaves your broader question unanswered (in a definitive sense). Please feel free
to give me a call and explain more what NEFdoes, or, if you think your employment qualifies based on
this email, please complete and submit the Employment Certificationfor PublicService Loan Forgiveness
form, available here.
Regards,
fan Foss
Federal Student Aid
Policy Liaison & Implementation
202-377-3681
From: Rene Larson [mailto:[email protected]]

To: IC DocketMgr
Subject: Public Service Loan Forgiveness
I work for a 501(c)(4) organization that is wholly owned by a 501{c)(3) organization.

Does this still qualify me for the loan forgiveness program? Thank you.
Sincerely,
Rene Larson
Compliance Attorney
(312) 697-6148
120 S Riverside Plaza Fl 15
Chicago, IL
60606
From: l(b)(5)
Sent: 27 Jan 2012 08:19:49 -0600

To: Fedloan PSLF
Cc: Ninemire, Sandra;Sipple-Asher, Bessie;Foss,
l(b)(5)
Subject: RE: Rosecrance Berry Center
Diane,
Yes, I'm inclined to agree that Rosecrance, Inc. qualifies as a public service
organization for PSLFbecause it is a not-for-profit, 501(c)(3) organization. That
the stated employer name is "Rosecrance Berry Center", which is not how the
organization is incorporated is of no consequence; the link that you provided
made clear that this was merely a location of the broader organization. If we
had the ECF,I think the EIN would have borne this out. And it would be a good
idea to confirm this when the ECFeventually comes in.
The searchable Pub 78 database that the IRS provides (which now allows for
EIN searches, by the way, even though we didn 1t have one here), is what
makes clear that the organization qualifies as a 501(c)(3) organization instead
as a not-for-profit organization that provides a qualifying public service (see
here). It is listed as a public charity, which is a 5Dl(c)(3) organization according
to the IRS (see here). Similar information could be found in the IRS1s Business
Master File (available here, with instructions). Rosecrance, Inc. has a
subsection code of 03, which means that it is a 5Dl(c)(3); it also has a
classification code of 1, which means that it is a charitable organization.
Though it took me a bit of extra research to come to that determination it was
a 5Dl(c)(3) instead of the private, not-for-profit organization that provides a
qualifying public service, I think it 1s best to check Pub 78 before doing anything
else; that is, when we 1re looking at a not-for-profit organization, and not a
governmental organization. I think the state databases will be more useful
when we 1re looking at that last category of eligible employers, and need to
confirm that it actually is a not-for-profit organization.
Ian
> Fedloan PSLF
> Sent: Thursday, January 26, 2012 2:43 PM
> To: l(b)(5J I
> Subject: Rosecrance Berry Center
>
>
> We're currently not getting EIN's because right now we're getting borrower
> phone inquiries and they don't know the EIN. We plan to give the borrower
> a call back and give a preliminary answer by phone, but advise that a final
> determination will be made if/when they submit the ECF.
>
> Rosecrance Berry Center-8616 Northern Ave, Rockford, IL,61108
>
> Based on our research, we believe this organization qualifies for PSLF.
>
> http://www.rosecrance.org/whoweare/
> http://www.rosecrance.org/?s=rosecrance+berry
>
> (See attached file: Rosecrance_CorporatellcController_a.pdf)
> (See attached file: Rosecrance_CorporatellcController_b.pdf)
>
> Thanks
>==========================================================
> ====================
>
> message.
>==========================================================
> ====================
From: Foss, Ian

Sent: 4 Apr 2012 20:35:38 -0500
To: !(b)(5) IPSLF
Cc: Sandra Ninemire;Sipple-Asher, Bessie;Johnson, Debbe;Foss, Ian
Subject: Re: RTI International
I've just realized that the 56 EIN prefix is also assigned out of Brookhaven. So, perhaps
the 03 prefix might simply indicate that it's an "old" EIN.
One more thing: \Vhen I have not been able to find an employer by EIN in Westlmv, it's
because it a governmental employer.
51
On Apr 4, 2012, at 21 :28, Ll(b_l(_
___ ~1<publicscrvicc({l,,cd.gov> \\Tote:
First, thanks for reminding me about this one. You're rightd had just lost
track of it.
RTI International is a 50l(c)(3) organization; however, the EIN provided

doesn't match the name of the employer. Given that RTI International has a
board of governors that is composed of representatives of the universities
that comprise the University System of North Carolina and Duke University,
I thought that perhaps the borrower was actually employed by one of the
organizations that is represented on the board of governors. However, a
cursory search revealed EINs with the 56 prefix, which obviously doesn't
match the EIN provided.
I confinned that it was a 50l(c)(3) by looking it up by name in the relevant

BMF. This at least alleviated any concern that we may have had about the
listed deductibility code in Pub 78.
Before we get into whether it could qualify as a not-for-profit providing a

qualifying public service (though I think this is an easier case to make for
RTI than it was for Brookhaven), we need to determine who the employer
really is.
I did an EIN search for the one provided on the ECF in Westlaw and it
returned nothing. The 03 EIN prefix comes out of Brookhaven, CT, which
means that the employer, whoever it is, and only if they came into existence
prior to 2002, applied to the IRS for its EIN out of Brookhaven, which means
it has ties further up the east coast. In 2001, the IRS centralized EIN
assignment. So, EINs assigned post-2001 don't necessarily have ties to the
geographic region for the office that assigned the EIN. See
here: http://www. irs. gov/businesses.ismall.iarticle./0,,id= 169067 ,00. html.
From: Fedloan PSLF<[email protected]>

Date: Sat, 31 Mar 2012 20:27:14 -0500
To: Ian Foss <[email protected]>

Subject: RTI International
Hi, We're struggling with this one. They checked box b on the ECF. We
could not find them in Pub 78 or the BMF under the EIN on the ECF. RTI
International was started as the Research Triangle Institute and we found
that entity in Pub 78 under a different (EIN), with a deductibility status
of SOUNK and type of organization as "a supporting organization,
unspecified type."
RTI International is a non-profit, and I think they provide qualifying

public services under several categories, include public health, public
education, and perhaps public safety, but I'm not sure. When we discussed
another research employer (Brookhaven Science Associates), you advised
that
you weren't sure that scientific research, in and of itself, would qualify
as public education. In looking at some of the things that RTI has worked
on, I would consider them public health and education - see some of the
things in the annual report: Reforming Health Care - in 2012 they will
work closely with the Centers for Medicare & Medicaid Services (CMS) to
implement the ne\v Medicare accountable care organizations (ACO)
program;
Drug Discovery and Development; and Education and Training.
We appreciate your thoughts! Pasrn-'ord to follow. Thanks.
(See attached file: RTI International.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
dfrcundc(Zi phcaa.org
This message contains privileged and confidential infonnation intended for
the above addressees only. If you
attachments.
prosecution of any individual engaging
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) I
Battle Cynthia
Subject: RE: San Manuel Indian Bingo Casino
Date: Monday, March 07. 2016 3:17:15 PM
H1Kim,
Unfortunately, we did not come up with add1t1onal 1nformat1on to add to what you already
uncovered in your research I would suggest Fed Loan reach out to the organization to find out if the
Lribe ha:, defir11L1veevidence Lhal Lhe casino is in facl governrnenlal.
Th;rnks,
Taneka
To: !(b)(51 I
Subject: San Manuel Indian Bingo Casino
Hi Tanekal
Here is another tribal entity for you. The website for the casino specifies that it is owned and operated by
the tribe, but it seems that they list the casino as separate from the governmental employment with the
tribe. We located a court case (Harris v San Manuel) in which the plaintiff alleged that the tribe had
waived its sovereign immunity due to the gaming compact the tribe has with the state. however. the court
granted the tribe's motion to dismiss. Another court document (Opposition to Request for Review) from a
different case details that the tribal government employees and casino employees are separate.
The tribe does have a Gaming Commission within their governmental structure. The language in the
website's excerpt includes mention of "tribal government gaming".
Otherwise, we couldn't find much solid information going one way or the other. We're hoping you may be
able to find something a little more specific that will help with the decision in this one.
Same password as other employers. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) I~; Ninemire Sandra: Sipple-Asher Bessie: ,Johnson Debbe
Subject: Re: SeacoastCharter School
Date: Monday, July 23, 2012 5:00:25 PM
Diane,
I agree that thi~ should be approved under the not-for-profit

organization
providing public education. not a 501(c)(3). Usually. the IRS
requires
that entitie~ ~tate that they will carry them~elve~ out exclu~ively
for
charitable purposes that would entitle them to a tax-exemption. The
be~t
way to convey thi~ is to include it in the article~ of organization or
the
by-laws. This gives entities the flexibility to "file now" and
"decide
later" on whether to go for the federal tax-exemption. Given that
this
entity has been a not-for-profit corporation ~ince 2005 and we can find
"o
record in the IRS databased, I don't think it'~ a 501(c)(3). but I
~till
think it qualifie~.
Jan
On 7/21/12 19:38, "FedLoan PSLF"

>
>Hi Jan. I'm starting to go through the
charter ~choob we previously
>approved as government. I'd like your input
on this one. They certified
>a~ private non-profit. they're listed in NH
business filing as non-profit,
>and their by-law~ indicate they were
organiLed to be a 50l(c)(3). I can't
>find them in Pub 79 or the BMF. If
we can't confirm 50l(c)(3) ~talus. I
>a~~ume we should just approve as
private non-profit. conect'' Password to
>follow. Thanks!
>
>(See al!ached
file: Seacoast Charter.Lip)
>
>Diane Freundel
>(717)
720-3267
>fax-(717) 720-3911
>[email protected]
>This message contains
privileged and confidential information intended
>for the ahove addressees
only. If you
message
>
>The ,ender of this message will fully
en gag mg
>in the unauthorized use of thi, message.
From: Foss Ian

To; FedLoanPSLF;.lf~bl~l5~)-~
Cc: Battle Cynthia:,JohnsonDebbe:NinemireSandra
Subject: Re: SEIU - UHW West and Joint Employer Education Fund
Date: Tuesday, August 06, 201312:45:59 PM
I think that 1~ a fair asses~ment of where we are. Jfyou get any that
just feel like they should quality but don 1t under this criteria. don 1t
he~itate to e~calate it.
On 8/6/13, 12:4L "FedLoan PSLF" <[email protected]> wrote:
>Ian, We agree with you. I wanted to make sure I wasn't missing anything.
>
>After reading your email below, I think I may have a better handle on
>member~ v~. the general public - let me know if my thoughts provide a good
>basic approach to evaluation~.
>
>If a private non-profit entity i~ open to member~ only. but anyone can be
>a member (~uch a~ a peVion needing to be a member of a health care
>benefits
>provider in order to receive the public service - Aloha Care was an
>example). and the entity provide~ a qualitYing service. then the entity i~
>considered to be providing a public service.
>
>If a private non-profit entity i~ open to member~ only. and that
>member~hip
>i~ restrictive to certain profession~. ~uch as SEIU - UHW a~ an example.
>then the entity doe~ not provide a public ~ervice (with an empha~is on
>public).
>
>Doe~ this make sense? Thanks!
>
>
>
l(b)(5) U(bJ(5)
>To:"Fe<lLoan PSLF" <[email protected]>
l(b)(5) U(bJ(5) I
"Fu~~,Ian"
> <[email protected]>, "Kinemire. Sandra"
><[email protected]>,
> "Johnson.Debbe"<[email protected]>. "Battle. Cynthia"
> <[email protected]>
>Date:08/06/2013 11:47 AM
>Subject:Re: SEIU - t.:HW West and Joint Employer Education Fund
>
>
>
>Diane,
>
>Given how similar this urganiLation i~ in structure to (c)(6)
>organinitions,providing services. but only tu members<! don 1t think it
>qualifie~, e~pecially considering that the membership requirements are
>more
>pre~cribed here than they are in most (c)(6) organization~.
>
>Can you find anything distingui,hing here'!

>
>Ian
>
>On 8/5113, 12:30, "FedLoan PSLF" <[email protected]> wrote:
>
>
> Hi Ian, We still struggle with private non-profit entities that
> provide a
> qualifying service to its memhers and not the general puhlic.
> Because of
> the limited population to whom they provide service,, I don't think
> this
> employer qualifies. Your thought, please?
>
> They are a 50l(c)(9J. They checked private non-profit that provides
> puhlic
> education and other school-hased services.
>
> They provide career coun,eling, training, and financial assi,tance
>to
> healthcare employees in certain state,. Per,on must work in a
> participating
> SEil; hargaining unit pmition for a contrihuting employer.
>
> Their NTEE category description i, "separately organi7ed trade high
> ,clmol,
> or vocational centers that provide formal preparation for
> ,emi,killed ...occupations for high-school-aged children and in some
> ca,e,
> adults .." - ,ee Google search document
>
> Pa'i'i\VOrclto follmv. Thank,
>
> (See attached file: SEIU - UHW West and Joint Employer Ed Fund.zip)
>
> Diane Freundel
> Compliance Service,
> (717) 720-3267
> fax-(7l7J 720-391 I
> [email protected]
> Thi, me,sage contains privileged and confidential information
> intended for the above addre'i'iee, only. If you
> receive thi'i me,sage in error plea,e delete or de,troy thi'i me,sage
> and/or attachment,.
>
> The sender of thi'i me,sage will fully cooperate in the civil and
> criminal prosecution of any individual engaging
> in the unauthorized me of this me'i'iage.
>
>This mes,age contain, privileged and confidential information intended
>receive this mes,age in error please delete or destroy this message
>
>The ,ender of this mes,age will fully cooperate in the civil and criminal
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) I: Eo..s..w.a..o.;
Battle Cynthia: .Johnson Debbe
Subject: RE: Seneca Gaming Corporation
Attachments: RE Chickasaw Nation Industries Inc.ms□
Hi Diane,
Thi~ organization doe~n't qualify. When the organization i~ clearly regarded as being distinct from the tribe itself. it
cannot claim to be a "tribal government organization" for PSLF purposes. This i~ quite a bit like Chicksaw l\"ation
lndu~trie~-
Jan
From: Diane Freundel [mailto·dfreunde@lpl1eaa or~I On Behalf Of FedLoan PSLF
To: l(b)(5) I
Subject: Seneca Gaming Corporation
Hi Jan. We like you to look at thi~ one.
I. Certified as government - EIN i~n't on ECF - we obtained via phone call

- adding leading zero~ - 0037-1441361
2. Their charter (pg~ 2-3) indicate~ they are a governmental instrumentality of the Nation. having autonomou~
existence separate and distinct from the Nation.
3. We found information regarding SEC tiling~ (EDGAR) and an SEC Form T-1
by Welh Fargo listing Seneca Gaming Corporation as an obligor. I tried
to do ~ome re~earch on the Form T-1 and found reference to the Trust Indenture Act of 1939. I also researched thi~ -
I didn't read the full document I included in the zip tile, but I found references to profit sharing plans of obligor~ -
pg~ 8-9 of Trust Indenture Act pelf
We were going to approve as government, but the SEC information troubled

u~. We'd appreciate your thoughts. Pa~~word to follow. Thanks!
(See attached file: Seneca Gaming Corporation.zip)
Diane Freundel
Compliance Service~
(717)720-3267
fax-(717) 720-3911
[email protected]
Thi~ me~~age contaim privileged and confidential information intended for the above addre~~ee~ only. If you
receive thi~ me~~age in error plea~e delete or de~troy thi~ me~~age andlor attachment~-
The sender of thi~ me~~age will fully cooperate in the civil and criminal prosecution of any individual engaging in
the unauthorized u~e of this mes~age.
From: !(b)(5)
To; FedLoan PSLF; .lf~bl~l5~)-~
Cc: Bl&...!.a!:l.;
Ninemire Sandra: Sipple-Asher Bessie: .Johnson Debbe
Subject: RE: Serenity Hospice
Date: Tuesday, June 26, 20121 :31:55 PM
Diane,
After a ~earch for SAR Ho~pice. LLC in the NP! Directory. I agree
that it is the same a~ Serenity Hospice. However_ a name (either) or EIN
~earch in We~tlaw returns nothing. I'm okay with that here. became \Ve can
match the address and phone number from the NP! index to the web~ite and
ECF
However, I would note that LLC~ in Nevada. like North Carolina do not
appear to ~upport a not-for-profit structure: rather, not-for-profit~ have
their own ~tructure.
So, I think this i~ a for-profit.
Jan
>
[rnailto:dfreunde(alpheaa nrv l On Behalf Of FedLoan
> PSLF
> Sent: Thursday.
June 21, 2012 12:05 PM
> To: l(b)(5) I
> Subject: Serenity Hospice
>
>
> Hi, Another difficult one. They checked private non-profit. but we
can't
> confirm. A google ~earch of the addre~~ a~~ociate~them with SAR
Hospice,
> LLC - we were able to find the Bu~ine~~filing for SAR. but it
only indicates
> they are an LLC. We couldn't find much on thi~
organization.
> Password to follow. Thanks!
>
> (See attached file:
Serenity Hospice.zip)
>
> Diane Freundel
> (717)
720-3267
> fax- (717) 720-3911
> [email protected]
> This me~~age contain~
privilege<l and confidential information intended for
> the above ad<lressees

message andlor attachment,.
>
in the unauthorized me of this
> message.
From: !(b)(5)
To; FedLoanPSLF
Cc: l(b)(5) I
Eo..s..w.a..o.;
,JohnsonDebbe;Battle Cynthia
Subject: Re: Shambhala Meditation Center of Los Angeles
Date: Monday, December 30. 2013 11 :12:18 AM
Hi Diane.
Between the fact that other Shambhala Mediditation Centers flve found have
~pecifically said that they fall under the church exemption to file for
501(c)(3J statu~ and the fact that thi~ center specifically holds
themselve~ out as tax-exempt under 501(c)(3J (see here:
l1trp //la ~hamhhala or~-\lonate/), I agree that this organization qualifie~-
Jan
On 12/24/13. 14:59, "Fed Loan PSLF" <[email protected]> wrote:
>
>Hi Jan, I think thi~ organization may quality under a group religious 501
>(c)(3J filing
>
>Employer certified 50 I(c )(3)
>IRS Select Check identified 4 entities with the name Shambhala
>The employer's web~ite indicate~ they are part of a global community of
>meditation center~-
>The Shambhala web~ite indicate~ they are rooted in the teachings of
>Buddhi~m-
>
>We appreciate your input. Pa~sword to follow. Thanks
>
>(See attached file: Shambhala Meditation Center of Los Angele~.zipJ
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>[email protected]
>This message contain~ privileged and confidential information intended
>fur the abuve addressees only. If you
>receive this me~sage in en-or please delete ur de~troy this me~~age
>and/or attachmenb.
>
>The sender uf this me~sage will fully cooperate in the civil and criminal
>pro~ecution uf any individual engaging
>in the unauthoriLed u~e of this message.
From: !(b)(5)
To; "FedLoanPSLF"
Cc: l(b)(5) I~; Battle Cynthia:,JohnsonDebbe:ChloeTamara
Subject: RE: Shared Charter Services
Date: Tuesday, June 24, 2014 4:28:00 PM
H1Diane,
So, here's what I've found.
• Charter schools in Michigan are governmental entities.

• They are required to be organized as not for profits.
• They are free to contract for services with any organization.
• This school's charter was~ by Central Michigan University.
• .t:iff.e. is a copy of the charter.
• The charter describes two third-parties (in the section relating to position descriptions,
toward the middle of the document).
• Many of the academic positions, such as Special Education teacher, which is how Ms Brewer
is employed are to be filled by MMl, Inc.
• Some administrative positions, such as Personnel Director, which corresponds to the title of
the Authorizing Official, are filled by Special Charter Services.
• As you noted, Special Charter Services is a not-for-profit.
• According to Michigan business filings, MM1 is a for profit corporation.
Given that it looks like the ECFwas completed in its entirety by the personnel director, I think that
she didn't realize that the teacher was actually employed by someone else (which is a terrifying
prospect). Either way, assuming that the information that I found is accurate, the borrower doesn't
qualify, because she 1semployed by a for-profit organization. Of course, she is free to provide
documentation providing otherwise.
Ian
From Diane Freundel [mailto:[email protected]] On Behalf Of FedLoan PSLF
To: l(b)(5) I
Subject· Shared Charter Services
Hi Ian, We wanted to run this one by you. We thought we had a similar situation that we asked you
about before, but we couldn't find it.
Apologies if we did send you a similar one.
The ECFlists Shared Charter Services as the employer and is certified as private non-profit providing
public education and other school based services.
Based on the business filing, they are not-for-profit, but the Articles of Incorporation state that they
provide educational management services to Michigan public school academies.
Based on the staff directory we found on the school's website, we determined that the borrower is a
teacher at Michigan Technical Academy and the certifying official is the HR Director at the school.
We're unsure if the employer (Shared Charter Services) qualifies, since the
employer itself doesn't provide public education. In addition, now that
we've determined that the certifying official is at the school, and not with Shared Charter Services,
we don't think we should accept the ECF.
Before we request that the borrower have someone at Shared Charter Services certify her
employment, we want to make sure that the employer qualifies.
(See attached file Shared Charter Services.zip)
Diane Freundel
Compliance Services
(717} 720-3267
fax-(717} 720-3911
dfreunde@pheaa org
only. If you receive this message in error please delete or destroy this message and/or attachments.
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) I~; Ninemire Sandra: ,Johnson Debbe
Subject: Re: Sharp Career and Development and Consultation at Grace M1ss1onary
Date: Monday, June 03, 2013 4:59:43 PM
Diane,
I think thi~ one i~ ~impler than trying to figure out if thi~ i~ really a
501 (c)(3J. We jmt can't find any record of the organization existing
out~ide of the church, itself So, we need to contact the certifying
official and find out more about the relatiomhip between "Sharp Career
and Development and Con~ultation" and "Grace Missionary".
That begin said_ I am concerned that I could not even find an

incorporation record for the church in Montgomery. Though, a Google
~earch of the addre~s turned up far many more result~ for another church
"African Methodi~t Epi~copal Church" than for "Grace Missionary". I found
an incorporation record for "African Methodist" in Montgomery.
If "Grace Mi~~ionary" really exist~, I worry that we're going to be

dealing with an unincorporated nonprofit a~~ociatiorL which won't really
have any records in a state databa~e. Even ~o. I think follow-up with the
organization i~ required.
Jan
>
>Hi Jan, We're having trouble with thi~ one.
>
>Employer checked private non-profit that provides public service for
>in<lividuals with disabilities an<lthe elderly. an<l other schuol-base<l
>~ervices.
>
>We couldn't find anything fur the entity.
>
>i\ guogle ~earch of the addre~~ on the ECF indicates it's Grace Baptist
>Missionary Church.
>
>Linked In record for certifying official ~how~ he's the pastor of Grace
>Missionary Baptist Church.
>
>Of concern is that a gougle search uf the certifying official's phone
>number indicates it's the borrower's phone number.
>
>We're nut sure if the "employer" would fall un<ler the 501(c)(3) status uf
>the church.
>
>We appreciate your thoughts. Password tu follow. Thanks!
>
>(See al!ache<l file: Sharp Career and Development & Cun~uHatiun at Grace
>Missionary.Lip)
>
>Diane Freundel
>(717) 720-3267
>fax-(717) 720-3911
>[email protected]
>for the ahove addressees only. If you
>
>The ,ender of this message will fully cooperate in the civil and criminal
From: !(b)(5)
To; FedLoan PSLF; .l(~b)~(5~)-~
Cc: Sipple-Asher Bessie: .Johnson Debbe: ~; Ninemire Sandra
Subject: RE: Skydancer Hotel and Casino (Tribal}
Diane,
I'm e~calating thi~ one further. In the meantime. what wa~ this documentation intended to show? All I can discern
from it is that the tribe i~ authorize "license and regulate", i.e., permit to occur gambling within the tribe. If that's all
you got out of it too. then that\ tine, but I \vondered \vhat your thought~ \Vere on \vhat thi~ documentation shO\vs.
As for their code. it seem~ a~ though their web~ite i~ being moved to another place and i~ not yet available. Thi~ is
probably why the links I sent you were not available.
Jan
> -----Original Me~~age-----

> From: Diane Freundel [mailtn:dfretmde@pheaa nq;l On Behalf Of FedLoan
> PSLF
> Sent: Thursday. June 14. 2012 9:30 AM
> To: l(b)(5) I
> Cc: Sipple-A~her. Bessie; John~on, Debbe: FedLoan PSLF; Fo~~.Ian;
> l(b)(5) I
l\"inemire. Sandra
> Subject: RE: Skydancer Hotel and Ca~ino (Tribal)
>
> Hi Jan, We received additional information from Skydancer. but I ~till
> can't make a determination. Can you please review? Also, the third link
> in your email below (Turtle Mountain Band's legal code) goes to a "web page
> not found" me~~age.
>
> A~ always, we greatly appreciate your assi~tance. Thank~!
>
> (See attached file: Skydancer_additional documentation.zip)
>
> Diane Freundel
> (717) 720-3267
> fax- (717) 720-3911
> [email protected]
>
>
> 1------------>
> I From: I
> 1------------>
> >---------------------------------
> ------ ---------------------------------------1
> lpublic~ervice .l("b) (5)_______
0 0 0
>I
> >---------------------------------
> ------ ---------------------------------------1
> 1------------>
> I To: I
> 1------------>
> >---------------------------------
> ---------------------------------------------1
> l"FedLoan PSLF" <[email protected]>,l(b)(5) I
>~ I
---~I
> >-------------------------------------------------------------------------------------------
> ---------------------------------------------1
> 1------------>
> I Cc: I
> 1------------>
> >-------------------------------------------------------------------------------------------
> ---------------------------------------------1
> l"Foss, Ian" <[email protected]>, "Ninemire, Sandra"
> <Sandra.l\"[email protected]>, "Sipple-Asher, Bessie"
> <[email protected]>, I
> !"Johnson, Dehhe" <Dehhe.John<[email protected]>
>I
> >-------------------------------------------------------------------------------------------
> ---------------------------------------------1
> 1------------>
> I Date: I
> 1------------>
> >-------------------------------------------------------------------------------------------
> ---------------------------------------------1
> 105/2112012 10:05 AM
>I
> >-------------------------------------------------------------------------------------------
> ---------------------------------------------1
> 1------------>
> I Subject: I
> 1------------>
> >-------------------------------------------------------------------------------------------
> ---------------------------------------------1
> IRE: Skydancer Hotel and Casino (Tribal)
>I
> >-------------------------------------------------------------------------------------------
> ---------------------------------------------1
>
>
>
>
>
> Hi Diane,
l(b)(5)
,-------------------------~
>
> There are two great \Vhite papers on the organization~ of tribal busine~~e~.
> One i~ by the IRS (here) and one i~ by the State of Michigan (here). Both
> make plain that there are five common ~tructure~: unincorporated. tribal
> subdivi~ion~. Section 17 Corporations (federally chartered corporation~),
> corporation~ chartered under tribal law, and corporations organized under
> state law. Only organizations that fall into the fir~t two categories, above,
> would be comidered ''tribal governmental organizatiom'' for PSLF purposes,
> would think.
>
> The only thing that I could confirm ahout thi, organization is that it is not
> organi7ed under ,tate law.
>
> From what I can di,cern, the Turtle Mountain Band of Chippewa Indian, is a
> legally ,ophi,ticated trihe. I say legally ,ophi,ticated because they have their
> own legal code. including a hminess/corporations code (,ee here).
>Therefore.I think it is unlikely that the casino would he "unincorporated··.
> suspect that the ca,ino is a business that is organi7ed for-profit under the
> trihal code, hut again cannot he sure.
>
> If the employer claim, that it is a political suhdivi,ion, it will likely have a letter
> to that effect from the IRS or the BIA/DOI (Bureau of Indian
> Affairs/Department of the Interior). The same is true of a Section 17
> Corporation, except that it would only have documentation from the
> BIA/DOI.
>
> Ian
>
>>-----Original Message-----
>> From: Diane Freundel lma!lto:dfreunde(d)pl1eaa.orl) I On Behalf Of FedLoan
> > PSLF
>>Sent: Friday, May IX, 2012 9:33 AM
>>To: l(b)(5) I
>>Subject: Skydancer Hotel and Casino (Trihal)
>>
>>
>>Hi. Are Trihal ca,inos a part of the Trihal government'! My research
>>indicates that the gambling income of the trihes and their federally
> chartered
>>corporations (form usually taken hy the casinm) are not subject to
> federal
>>income tax (see page 3 of nagaming.pdt). However, the ma,ter seek
>>document indicates they are a private company. in which case they
>>would not qualify since they don't provide a qualifying service.
>>Their weh,ite
> is
>>restricted here at work because it's gambling. hut I checked it on my
> phone
>>and couldn't find anything definitive.
>>
>>We'll he seeking additional certification since this ECF is
> self-certified
>>if the organization qualifies. Password to follow. Thanks!
>>
>>(See attached file: Sky Dancer Hotel and Casino.zip)
>>
>>Diane Freundel
> > Compliance Service,
> > (717) 720-3267
>>fax- (717) 720-3911
>>Thi, me,,age contaim privileged and confidential information intended
> for
> > the a hove addressees only. If you receive thi'i me,sage in error
> > plea,e delete or destroy this message and/or attachments.
>>
>>The sender of this me'i'iage will fully cooperate in the civil and
>>criminal pro,ecution of any individual engaging in the unauthorized

>
> the ahove addres,ee, only. If you receive this message in error please
>
> prosecution of any individual engaging in the unauthori7ed me of this
> message.
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5)
Subject: Re: Soboba Band of Lu1senoIndians Casino
Date: Thursday, November 14, 2013 11:31:34 AM
Hi Diane.
On Soboba, I cannot find out anything more than you did, but Jld wait to
call the employer for more until I hear back on Valley View If Valley
View qualifie~. I think then 3government 2 will be the only way for indian
ca~ino~ to quality for PSLF, and you 1d need to contact the employer to
find out if this is a 'government casino 2 or not.
Jan
>
>Hi Jan, Thi~ is the other tribal casino I mentioned. I couldn't find
>anything about it~ ~tructure. I thought you might be able to find
>something. If not. I can have someone call the employer
>
>
>(See attached file: Soboba Band Luiseno Indian Ca~ino.zipJ
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>[email protected]
>This mes~age contain~ privileged and confidential information intended
>receive this me~sage in effor please delete or de~troy this me~~age
>and/or attachmenb.
>
>The sender of this me~sage will fully cooperate in the civil and criminal
>pro~ecution of any individual engaging
From: !(b)(5)
To; FedLoan PSLF
Cc: Bl&...!.a!:l.;
Battle Cynthia: ,JohnsonDebbe:l(b
0 0)0(50)_~
Subject: Re: Soboba Band of Lu1seno Indians Casino
Date: Monday, December 09. 2013 3:33:31 PM
Hi Diane.
Now that \ve·ve determined that ·'government" indian casinos qualify. you
~hould go ahead and try and confirm that thi~ is government before
approving.
Jan
On I Iii 4/13. 11:31, l~(b_l(_51

___ .ll,~(b_l(_51
_____ ~1 wrote:
>Hi Diane.
>
>On Soboba. I cannot find out anything more than you did. but Jld wait to
>call the employer for more until I hear back on Valley View. If Valley
>View qualities, I think then 3government 2 will be the only way for indian
>casino~ to qualify for PSLF. and you 1d need to contact the employer to
>find out if thi~ is a 3government ca~ino2 or not.
>
>Jan
>
>
>
>
>On 10/18/13, 20:32. "FedLoan PSLF' <[email protected]> wrote:
>
»
>>Hi Ian. This i~ the other tribal ca~ino I mentioned. I couldn't find
>>anything abuut ib ~tructure. I thought you might be able to find
>>something. Ir not. I can have someone call the empluyer.
»
>>Password to follow. Thanks!
»
>>(See a\lached file: Sobuba Band Luiseno Indian Casino.zip)
»
>>Diane Freundel
»(717) 720-3267
»fax- (717) 720-3911
>>[email protected]
>>This message contains privileged and confidential inforrnatiun intended
>>for the above addressees only. If yuu
>>receive this message in error please delete or destroy this message
»
>>The ~ender of this message will fully cuuperate in the civil and criminal
>>prosecution of any individual engaging
>>in the unauthorized use ofthi~ message.
>
From: !(b)(5)
To; "FedLoanPSLF"
Cc: l(b)(5) I:~; Battle Cynthia:.JohnsonDebbe
Subject: RE: Society of Digital Agencies - escalated
Hi Diane.
Sorry for the delay on this one. We wanted to run it by our attorney, but he wa~ on leave for a while. We've settled,
however. on a definition of pub Iic education! For PSLF. public education ~ervices are tho~e that provide educational
enrichment or support directly to student~ or their familie~ in a ~chool or a ~chool-like setting. The Society of Digital
Agencies i~ a 50l(c)(6) organization whose mi~~ion is, according to their Form 990, is to provide infrastructure.
proce~~e~,and products to enable collaboration between member~ around education, best practices, and advocacy.
When you look at their web~ite, they in no way appear to actually be an organization that is about ·'public
education'· Contrary to their ·'mi~~ion··.they ~eem to be about marketing.
In ~hort, we agree that this organization doesn't quality.
Jan
From: Diane Freundel [mailto·dfreunde@lpl1eaaor~l On Behalf Of FedLoan PSLF
Sent: Monday, July 14. 2014 I :28 PM
To: l(b)(5) I
Subject: Society of Digital Agencies - escalated
Hi Jan. We're comfortable with our decision on this one, but our denial prompted the borrower to e~calate it.
Employer certified a~ private non-profit providing public education, and indicated they are a 501 (c)(6).
We confirmed 501 (cJ(6) statm from their Form 990. Their mi~~ion. a~
~tated on the 990 i~ to provide infra~tructure, processes. and product~ to enable collaboration bet\veen members
around education, best practices and
advocacy. We don't believe this meet~ the requirement~ of public
education.
The borrower is reque~ting a letter explaining why the employer isn't considered to be a provider of public
education. I know we've discussed that public education mu~t be ~tructured and pedagogical in nature: however.
can't find anything definitive that indicate~ ~uch. I reviewed the ~tatute. the regulations, the preamble to both the
NPRM and the final
rules, and can't find anything that define~ public education. Can you
please assi~t'!
Pa~~word to follow. thank~!
(See attached file: Society of Digital Agencieuip)
Diane Freundel
Compliance Service~
(717)720-3267
fax-(717) 720-3911
[email protected]
This message contains privileged and confidential information intended for the above addressees only. If you
receive this message in error please delete or destroy this message and/or a\lachments.
The sender of thi~ rne~~age will fully cooperate in the civil and criminal prosecution of any individual engaging in
From: !(b)(5)
To; FedLoanPSLF
Cc: l(b)(5) I
Eo..s..w.a..o.;
Subject: Re: Somerset Academy
Date: Friday, November 29, 2013 5:00:44 PM
Hi Diane.
Yeah, charter schools are really confming.
Because of what you 1re seeing in the l\"evada bminess search, and the fact
that l\"evada1s charter ~chool lav>'declare~ that employees are 3public
employee~2 and charter ~chooh are 3public bodie~2 • Jim okay approving
this as government. I searched for other charter schools in l\"evada, and
they1re all ~eeming to come up as government in the busines~ ~earch (\vhen
I can find them).
It makes me feel better that, in Nevada, charter schools cannot be

for-profit, and I can link this name and to an actual charter ~chool (and
not a for-profit charter ~chool ~ervice provider).
Jan
>
>Hi Jan, this one is a confming charter ~chool.
>
>I. Certified a~ SomeViet Academy - private non-profit on ECF
>2. SomeViet Academy of Las Vegas website shmvs 4 campu~e~. one of which
>i~
>Sky Pointe - addre~~ matches ECF. We as~ume the Ell\" on the ECF is for
>Somerset Academy of Las Vega~
>3. Sky Pointe Campus' website - "About lls" - show~ that they are a part
>of
>Somer~et Academy in Miramar, FL
>4. Somerset Academy Inc's (FL) Form 990 lists them a~ a 501(c)(3)
>5. Nevada Secretary of State - bu~iness filing search for Somerset
>Academy
>gave 4 results - 3 for PTO~ for 3 of the campu~e~ and one for Somerset
> Academy of Las Vegas
>6. Bu~iness filing for Somerset Academy of Las Vegas lists an
>organinition
>type of "other" with an exemption code of0l
>7. Exemption code of 01 i~ governmental entity
>
>We think they should be government. but wanted your input on this one.
>
>(See al!ached file: Somerset Academy.zip)
>
>Diane Freundel
>(717) 720-3267
>fax-(717) 720-3911
>[email protected]
>
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) I: Battle Cynthia
Subject: RE: Southern Ute Indian Tribe Growth Fund
Date: Friday, January 22. 2016 10:36:00 AM
Hi Kim,
I think mi~~ed ~ending thi~ to you. Jan and I reviewed this one a~ I was unfamiliar with the how to read the SEC
filing~. You're correct in your a~~e~~mentand the Southern Ute Indian Tribe Growth Fund looks to be for profit and
doe~ not qualify for the purpo~e~ of PSLF
Thank~,
Taneka
Sent: Tuesday, December 08, 2015 10:56 AM
To: l(b)(5) I
Subject: Southern Ute Indian Tribe Growth Fund
(b)(5)
We appreciate your guidance. Pa~~word to follow. Thanks!
(See attached file: Southern Ute Indian Tribe Growth Fund.zip)
Diane Freundel
Compliance Service~
(717)720-3267
fax-(717) 720-3911
[email protected]
Thi~ me~~agecontaim privileged and confidential information intended for the above addre~~ee~only. Jfyou
receive thi~ me~~age in error plea~e delete or de~troy thi~ me~~ageandlor attachment~-
The sender of thi~ me~~agewill fully cooperate in the civil and criminal prosecution of any individual engaging in
Code:PHEAA
From: ~
To; !(b)(5) I:FedLoanPSLF@pheaa
ora
Cc: EQ&J.a.n:NinemireSandra:Sipple-Asher
Bessie
Subject: Re: Spec1al1zed
Services of CA
Date: Wednesday, February 22, 2012 5:45:55 PM
Diane,
I agree that this is a for-profit entity and therefore does not qualify. Good job on the thorough
research. It appears as though SESI does two things:
(1) acts as a sort-of private, for-profit entity that provides educational services to public
and private schools for students with intellectual or other social or behavioral
disabilities; and
(2) owns and operates private schools. Some of the private schools, at least based on the
profiles of the schools on SESI's website, appear to be operated on a not-for-profit basis.
If the borrower is employed by SESI, as are those employed by Specialized Educational

Services of CA (on the ECF), then the employment does not qualify. If the borrower is
employed at a not-for-profit private school that SESI happens to control and operate, then that
should qualify, because, to be not-for-profit, the school would need to be separately organized.
Given that the borrower's employer is SESI's CA affiliate, and the Sierra School, at which the
borrower works, is not independently organized, then I think that the borrower is working for
the for-profit entity.
I also want to make it known that this organization was fonnally known as Kids 1, Inc., which
ran into some fraud trouble in the State of New Jersey (it was reported that it settled a suit
regarding the fraudulent over-billing of New Jersey LEAs for services provided), but that it
was rebranded and recapitalized by private investors. See here for more on the
recapitalization, which supports the notion that SESI is a for-profit entity:
http:// c gp. com/ 11ews/ c gp-1eads-growth- recap ita 1i7 ati on-o f-speci a 1i 7 ed-ed uc ati on-sen· ices- i11c/
Ian
51__ --'!"!(_bl_(
On Feb 22, 2012. at 4:38 PM, ..,!(b_l(_ 51
______ __,!wrote:
From: Diane Freundel [mailto:[email protected]] On Behalf Of FedLoan
PSLF
Sent: Wednesday, February 22, 2012 2:46 PM
To: !(b1(51 I
Subject: Specialized Services of CA
Good afternoon!
This was a tough one!
I couldn't find anything on the name or EIN. I googled the address and came up
with a private school that is a part of Specialized Education Services. Inc (SESI).
The Director (Janine Hughes) on the website is the Director who signed the ECF.
I found a Yardley, PA address for SESI so I checked the PA corporations website.
It showed that SESI's state of business is DE. I checked the DE corporations
website and I believe it is for-profit. I also looked at a sample non-profit
(American Cancer Society) to see how a non-profit is listed on the DE corp
website and it clearly shows as a non-profit.
Copies of all documents attached - password to follow. Thanks!
(See attached file: Torrence_Specialized Services of CA.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fox- (717) 720-3911
[email protected]
----------------------------------------------------------
--------------------
----------------------------------------------------------
--------------------
<Torrence_Specialized Services of CA.zip>
From: !(b)(5)
Cc: Bl&...!.a!:l.;
Subject: RE: Specialized Youth Services of Virginia, Inc
Date: Thursday, May 24, 2012 4:36:12 PM
Diane,
I smpect that this i~ a for-profit corporation that as a re~ult of

being for-profit, doe~ not qualify. Thi~ i~ a ~tock corporation, the
hallmark of a for-profit entity; ~pecifically, the entity ha~ i~sued 5JJOO
~hares of common ~tock. What's more, to incorporate a~ a not-for-profit
corporation in VA. the entity rnu~t incorporate as a non-stock corporation or
an LLC. See here: l1trp·.//www dba.virvinia ~ov/non profit ~html.
Jan
>
[ rnailto:dfreunde(alpheaa nrv l On Behalf Of FedLoan
> PSLF
> Sent: Monday. May
2L201210:06PM
> To: l(b)(5) I
> Subject: Specialized Youth Services
of Virginia, Inc
>
>
> Hi, We're having difficultie~ with this one. The
certifying official
> indicates they are a private non-profit/public
education. According to
> the VA Dept of Education website. the VA school
~y~tems contracted \vith a
> private company, Specialized Youth Service~ of
VA. to establish a regional
> alternative education program. According to
SYSVJ\ web~ite, they provide
> educational and treatment service~ to ED/LD
and other at-ri~k children.
>
> I could find no indication that they are a
non-profit. The VA Board of
> Education's criteria for providers of
~upplernental service~ for eligible
> student~ in Title I ~chools. indicates
the provider can be nonprofit, for-profit.
> or a local school division.
>
> Your a~sistance is appreciated. Pa~~word to follow. thanb.
>
> (See
a\lached file: SpecialiLed Youth Services of VA.zip)
>
> Diane Freundel

>
Compliance Services
> (717) 720-3267
> fax-(717) 720-3911
>
[email protected]
> the ahove addres,ee, only. If you receive this
attachments.
>
civil and criminal
> message.
From: Foss Ian

To; FedLoan PSLF; (b)(5)
0
Cc: ;"(b"l'(5'1~--,Ninemire Sandra
Sipple-Asher se"s"s"ie
Subject: RE: St Anthony Hospital, Oklahoma City
Date: Wednesday, February 01, 2012 9:36:03 AM
Oh, intere~ting. Thank you.
Of course, St Anthony's i~ also a religiou~ly

affiliated hospital. And. while it'~ unlikely that most employee~ would
engage in overt religious activitie~, ~ome u~ually do. e.g., reading a
prayer over the loud~peaker. I know you know this, but it bear~
repeating.
Speaking of, we (the Department) received a (non-FOIA) written

reque~t for information regarding "the religious is~ue" already. So. we are
developing a statement regarding the issue, and our decisioniba~is for
implementing a prohibition in the 50 I(c)(3 J category de~pite the regulatory
con~truction that would ~ugge~t otherwi~e. When it is finalized, I will be
~ure that PHEAA get~ a copy for your information, though I would doubt that
you would need to use it with individual bo1TOWeVi.
> -----Original
Me~~age-----
> From: Diane Freundel [mailtn:dfretmde@ae~~ucce~~or~] On
Behalf Of
> FedLoan PSLF
> Sent: Wedne~day. February 01. 2012 9:31 AM
>To:
l(b)(5)
> Cc: Sipple-A~her. Bessie; FedLoan PSLF: Foss, Ian:
l(b)(5) I
Ninemire,
> Sandra
> Subject: RE: St Anthony Ho~pital.
Oklahoma City
>
> Thanks Ian. The St Anthony'~ bo1TOwerwa~ a phone call.
She wa~ the ~ame
> borrower who a~ked about The OK Board of l\"ur~ing.
>
>
Diane Freundel
> (717) 720-3267
> fax- (717)
720-3911
> [email protected]
>
>
> 1------------>
> I From: I
>
1------------>
>
>------------------------------
> ---------------------------------------------1
>
lpuhlicservice Ll(~b)~(5~)------~
>I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
> I To: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
l"FedLoan PSLF" <[email protected]>
>I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
> I Cc: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
lpuhlicservice .l(_bl_(5_1
_______ "Kinernire. Sandra" ~1
>
<[email protected]>, "Sipple-A~her. Be~sie"
>
<Be~~ieKo. S ippleA ~ [email protected]>, I
> l"Foss. Ian" <[email protected]>
>I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
> I Date: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
102/01/2012 08:50 AM
>I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
> I Suhject:
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
> IRE:
St Anthony Ho,pital, Oklahoma City
>I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
>
>
>
>
> Diane,
>
> Yes, I think we would like to ,ee all non-SOl(c)O),
not-for-profit organization,
> at the heginning.
>
> I think this qualities
becau,e St. Anthony', Ho,pital is an active tradename of
> SSM Health Care,
which i'i regi,tered in Oklahoma a, a dome,tic (to OK), not-
> for-profit
corporation. And, given that it is a ho,pitaL it provides health care
>
,erv1ces.
>
> I wonder. i'i that based on an ECF corning in? If so, who was
li,ted a, the
> employer'.' St Anthony', or SSM Health Care? I'm gue'i'iing St
Anthony's,
> since that's the organization you're a,king about, but I wonder
whether the
> EIN on the form ties to St Anthony', or SSM Health Care?
>
>
Jan
>
>>-----Original Message-----
[mailto:dfreunde@aewJCce~~-or~ I On Behalf Of
> > FedLoan PSLF
>>Sent:
Tuesday, January 11, 2012 4:15 PM
>>To: l(b)(5) I
>>Subject: St
Anthony Ho,pital, Oklahoma City
>>
>>
>>We believe this is a qualifying
private non-profit organization. Al,o,
>>it', our understanding that you
want to see all private non-profits,
>>at
> least at
>>the heginning.
ls that correct'! Thank you!
>>
>>St Anthony's History, Mission, and
Values page: indicates they hecame
>>a member of SSM Health Care:
>>
>
littp: '/W\\'\V .~aint,ok.comiinternet/homel~aintsok.nsf/_11060 I 68df9497Jf86
>>
256a0e0058c993/Jdh05e82a9eeh I e5862573f4008 I e8 l d'!OpenDocument
>>
>>OK
Secretary of State Busine,s Services - searched for St Anthony -
>
resulting
>>page:
>>
littp~: 'lw\vw .~o~.ok.!lov/corpicorpl nformation.a,px'.'1d 21 ()() I 37798
>>
>>
Selected St Anthony Ho,pital, file# 2100117798 (fir,t one listed on
>
ahove
> > ,ite) - resulting page:
>>
littp~:i/w\vw .~o~.ok.!lov/corpicorpl nformation.a,px'.'1d 21 ()()I 37798
> which
>>
indicates SSM Health Care is a domestic not for profit
>>
>>Diane
Freundel
>>(717)720-3267
>>fax-(717)
720-3911
>>
>>
>>
>
>>
>>This me'i'iage contaim privileged and confidential

> for
> > the a hove addressees only. If you receive
this message in error

> > plea,e delete or destroy this message and/or
attachments.
>>
>>The sender of this me'i'iage will fully cooperate in the
civil and
>>criminal pro,ecution of any individual engaging in the
unauthorized
>>
>
>>
>
>
>
>
>
>
>
>

> delete or de,troy this me'i'iage and/or
attachment,.
>
> The ,ender of this message will fully cooperate in the
civil and criminal
unauthorized u,e of this
> me'i'iage.
>
>
From: Foss Ian

To; S1oole Asher Bessie
Cc: l(b)(5) I FedLoan PSLF; Ninernire Sandra
Subject: Re: St Joseph Notre Dame High School
Date: Friday, February 24, 2012 10:45:03 AM
Attachments: Guide to Inclusion In USCCB Group Exemption.pd1
ATT00001. txt
Yes, the "religiom issue" is borrower-, not employer-specific;

however, this question i, ahout whether we can peg the employer a, a
50 I (c)(3) organization or not. It's not li,ted as such anywhere, and I find
that odd considering that the Catholic hierarchy has a large group
exemption, even though it didn't need to.
See the attached PDF of a very

useful guide that the l;nited States Conference of Catholic Bishops put
together for organizatiom that wish to he covered hy the group tax
exemption. See al,o, here:
11ttp: //old. uscc h. mg /hi ~hops/d f1/ exe mptmnrul ing .lit m.
So, thi, might just

he an organintion that is not included in the directory, and is therefore
not in the Business Master File. Though, I don't know how we're going to
know that.
Either way, I think you're righMhe website's ,tatement that

all donations are tax-deductible shows that it', a 501(c)(3), even if it's
hy way of relying on the exception of the requirement to file with the IRS
for that status.
Jan
From: !(b)(5)
To; FedLoanPSLF
Cc: l(b)(5) I
Battle Cynthia:Eo.ll...J.a.o.;
Odom Christian
Subject: RE: St Louis Development Corp
Date: Tuesday, December 13, 2016 1:25:15 PM
Iii Kim.
My apologie~ for the delay in getting a re~pon~e hack regarding thi~ employer.
Upon closer revievv of the Article of Incorporation for the St. Loui:-. Development Corporation
(SLDC). Ian and I determined that the SLDC ,vas e:-.Lahli:-.hed by the Mayor of St. Louis.
Hon. Vincent C. Schoemehl. Additionally, the current director of the SLDC is a cabinet-level
position. Ba:-.ed on thi:-.information, 1-'edLoan can treat the SLDC as a qualifying qua:-.i-
governmental organinttion for the purpose of PSLF.
Plea~e let me know if you have que~tions regarding thi~ decision.
Thank you.
Taneka
Sent: Monday, November 21, 2016 8;10 AM
To: !(b)(51 I
Subject: St Louis Development Corp
Hi Taneka! We had escalated this employer to you back in September and in October you had made a
decision that they do not qualify as they do not provide a qualifying public service. Based on this, we
notified the Business Unit to deny accordingly.
We have now received another borrower who is requesting re-review of the employer. In addition, we also
identified (based on the letter from the new borrower), that there were several other borrowers (lour total)
whose employment had previously been approved for this organization and we believe now needs to be
retracted. So, this is a two-fold email.
Based on the information provided by the new borrower, we don't see any additional evidence from what
we found before to warrant that this organization provides a qualifying public service. We would conclude
the decision should remain that this employer is denied.
As for the four other borrowers who were approved in error. I am forwarding on the information as
discussed. But, also wanted to confirm you would indeed want to also see cases in this particular
scenario (based on the fact that you had previously reviewed/denied, and they just weren't retracted at
the appropriate time, in error).
Thanks! Password to follow.
Kimberly A Myers
Compliance Services
kmyers@pbeaa
oro
(717) 720-2630
and/or attachments.
Code:PHEAA
From: ~
To; !(b)(5)
Subject: RE: St Louis Development Corporation
Date: Tuesday, November 22, 2016 4:32:00 PM
What's the password?

From: l(b)(5J I
Sent: Monday, November 21, 2016 1 :46 PM
To: Foss, Ian
Subject: FW: St Louis Development Corporation
(b)(5)
Hi Tanekal We had escalated this employer to you back in September and in October you had made a
decision that they do not qualify as they do not provide a qualifying public service. Based on this, we
notified the Business Unit to deny accordingly.
We have now received another borrower who is requesting re-review of the employer. In addition. we also
identified (based on the letter from the new borrower), that there were several other borrowers (lour total)
whose employment had previously been approved for this organization and we believe now needs to be
retracted. So. this is a two-fold email.
Based on the information provided by the new borrower, we don't see any additional evidence from what
we found before to warrant that this organization provides a qualifying public service. We would conclude
the decision should remain that this employer is denied.
As for the four other borrowers who were approved in error, I am forwarding on the information as
discussed. But, also wanted to confirm you would indeed want to also see cases in this particular
scenario (based on the fact that you had previously reviewed/denied, and they just weren't retracted at
the appropriate time, in error).
From: Kimberly A Myers (mailto:[email protected]] On Behalf Of FedLoan PSLF
Sent: Friday, Serember 16, 2016 2:19 PM
To: l(bJ(5J
We originally denied this organization in September 2014. The organization is 501 (c}(4), but they do not
They now submitted a letter appealing the denial. They indicated that although they are 501 (c}(4), in
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; FedLoan PSLF
Cc: ~: l(b)(5) IBattle Cynthia: .Johnson Debbe
Subject: Re: STAR Communities
Date: Monday, December 30. 2013 10:00:49 AM
Hi Diane.
I could find no record of the organization 1s existing in any of the

databa~e~ that we rely upon, including Westlaw. I wa~ able to confirm
that the organization does hold a service mark in the therm 3 ST AR
Communities 2 and that it is regi~tered to a 3Star Communitie~
Corporation 2 • but that 1~ the extent of it. I could find nothing to
~ub~tantiate that the organization is a not-for-profit of any kind.
I find it intere~ting, however, that the organization 1~ addre~~ is 3care

ot2 the DC Department of the Environment.
Either way, I think we need proof from the organization that it i~ a

501(c)(3J ifit 1s going to quality. I ahothink that, ifit 1s a
non-50 I ( c)(3) not-for-profit. that the organization doesn 1t provide a
qualifying service.
Jan
>
>Hi Jan, Can you plea~e take a look at this one'J They certified 501
>(c)(3J. I can find no evidence of it. I also haven't been able to
>access
>the DC bminess search web~ite for about a week, but if they are private
>non-profit, I don't think they provide a qualitYing public ~ervice. Let
>me know what you can find. Password to follow. Thanks!
>
>(See al!ached file: Star Communitie~.zip)
>
>Diane Freundel
>(717) 720-3267
>fax-(717) 720-3911
>[email protected]
>receive this me~sage in en-or please delete or de~troy this me~~age
>and/or attachmenb.
>
From: !(b)(5)
Cc: Bl&...!.a!:l.;
Subject: RE: Stepping Stone Child Care
Hi Diane.
I can find nothing to ~upport the a~sertion that they are a not-for-profit organization. A search for the Ell\" in
We~tlaw returns no result~- In addition. I can find no public record~ for "Garcia Gomez Family Child Care Center"
in We~tlaw's California databa~e.
While l could find records for "Stepping Stone Child Care", they were nothing more than a fictitiou~ busine~~ name
registered to "Ava Garcia". One thing to note i~ that the "bu~ine~~type" for the fictitiou~ entry was "individual".
So, l suspect that thi~ i~ a ~ole proprietor~hip. which cannot be a not-for-profit organization. and thus cannot be a
qualifying employer. And, that would also explain why you could not find an entry for the employer in the
California business ~earch databa~e.
Jan
Sent: Friday. Augu~t 24. 2012 ](J:21 AM
To: l(b)(5) I
Subject: Stepping Stone Child Care
Hi Jan. We're having difficulty with thi~ one.
The employer on the borrower's fir~t ECF was Gomez-Garcia Family Child Care. They checked private non-profit
providing early childhood education.
We denied for no EIN, no addre~~-
The employer on the borrower's second ECF Stepping Stone Child Care. They checked private non-profit providing
early childhood education. It had an Ell\" and address and was signed by the ~ame certifying official as the previous
ECF (the bo1TOwer·~mother).
Their web~ite is under the Stepping Stone name and is a .org - I know this i~n't definitive
They are licen~ed in CA under Gomez-Garcia Family Child Care.
We couldn't find anything in the CA Busines~ tiling~. although even ifwe could CA doe~n't specify non-profit
~tatus.
Can you find anything to determine if they are non-profit'.' Pa~~word to

follow. Thank~!
(See attached file: Stepping Stone Child Care.zip)
Diane Freundel
Compliance Service~
(717)720-3267
fax-(717) 720-3911
[email protected]
This message cuntains privileged and confidential information intended for the above addressees only. If yuu
receive this me,sage in error please delete or de,troy this me<;<;ageand/or attachments.
The sender of this me<;<;agewill fully cooperate in the civil and criminal prosecution of any individual engaging in
the unauthorized use of this message.
From: Foss Ian

To; FedLoan PSLF
Cc: l(b)(5) I~; Ninemire Sandra: Sipple-Asher Bessie: ,Johnson Debbe
Subject: RE: Sterling Medical Corporation
Date: Tuesday, February 28. 2012 9:05:32 AM
Kirn did the ~arne research I would have and came to the ~ame conclmion re
Sterling Medical Corporation. It is a for-profit entity (specifically. a
professional corporation) and therefore doe~ not qualify.
> -----Original
Me~~age-----
> From: Diane Freundel [mailtn:dfretmde@ae~~ucce~~ or~] On
Behalf Of
> FedLoan PSLF
> Sent: Monday. February 27. 2012 9:09 PM
>To:
l(b)(5)
> Subject: Sterling Medical Corporation
>
>
> Hi, Kim did
a lot of good re~earch on thi~ one. The conclu~ion we
> reached is that it
is a for profit. The borrower also didn't obtain certification.
> but we
also want to let her know it's not a qualitYing
> employer when we deny thi~
reque~t. Included in the attachment is
> another
> ECF from her. This one
is a qualifying employer - Commonwealth of VA Dept
> of Rehabilitative
Service~ - but she did not obtain certification for thi~
> one either. She
did provide certification for her current qualitYing
> employer (Troy
University). I assume she didn't try to obtain
> certification from her
prior empluyers. We'll deny this one for nu certification
> - just wanted
to let you know.
>
> Passwur<l to follow. Thanb.
>
> Kim's research:
>
"So this une tuok me a bit (well at lea~t the 2nd one). but I think I got
it.
>
> As far as the Cumrnonwealth of Virginia Dept of Rehabilitative
Services go.
> they are qualifying since they fall under box A. However.
since the borrower
> checked the bux that they cuul<ln'( obtain
certification, we need to
> determine how these are to he handled.
>
>The
Sterling Medical Corporation wa, a different ,tory. Again the borrower
>
checked the hox that they couldn't obtain certification, hut I wanted to
check
> if that organintion was even qualifying. This is what I
found ..
>
> First I tried to identify if Sterling Medical Corporation
was a S0l(c)OJ
> organintion, hut I couldn't find it on either the puh 78
or BMF. I then tried
> searching the business filings for Ohio. Several
organizations came up when I
> typed in Sterling Medical Corporation, ,ee
>
> http://www2.sos.state.oh.us/pls/hsqryit'!p= I 00:2:12729889904074 7 .N():RP:
>
>
> I selected the third listing (755500) became it most closely
resembled the
> company. When I brought it up, the address didn't match,
hut I delved into
> the documents/filing, at the bottom.
>
> r identified
that the company Sterling Emergency Medicine, Inc was formed
> as a
for-profit organization effective August 25, 1989.
>
> I then located two
document, advi,ing of a merger of Sterling Medical
> Corporation and that
Sterling Medical Corporation wa, formerly Sterling
> Emergency Medicine,
Inc.
>
> Therefore, Sterling Medical Corporation would not quality.
>
>
(See attached file: Sterling Medical Corporation.zip)
>
> Diane Freundel
>
Compliance Service,
> (717) 720-3267
> fax- (717) 720-3911
>
[email protected]
>
>

attachments.
>
civil and criminal
> message.
>
>
From: !(b)(5)
To; FedLoanPSLF
Cc: Battle Cynthia: Tiongquico Rene:~l(b~)(~5)~~
Subject: Re: Students First
Hi Kim,
I think this should be the last email for today.
Thank you for running this list. We reviewed it but I failed to respond to your question
regarding the W2s. If you have not already, we agree that you should request W2 from the
borrowers who submitted and ECF under a different EIN.
I had sent a previous email today about the retraction letter to the borrower for this
organization. We thought the retraction letter for Student First was especially vague since it
Just listed that Students First was no longer eligible for PSLF.Since these retractions are ad hoc
letters, in the future the letters should provide the definition we have for public education
(since we have one now) and that the employer does not qualify as a result of not meeting the
definition (ex. employer is an advocacy group).
Thanks again!
Taneka

Sent: Tuesday, August 16, 2016 1:42:24 PM
To: l(b)(5J I
Cc: Battle, Cynthia; FedLoan PSLF,Tiongquico, Rene
Hi Taneka! Sorry for the delay. Attached is the spreadsheet with the counts you requested. I included
both requests in the same spreadsheet, under separate tabs.
1) The first tab contains the borrowers who submitted ECFs for Students First. We included the SSN (but
wasn't sure if you needed them), EIN, processed date, status of the ECF (approved or denied) and some
additional notes.
There were a total of 6 borrowers who submitted ECFs for "Students First". One ECF was never
approved as the original ECF was missing information and the borrower never responded with a complete
ECF. What I found interesting is that 5 of the borrowers submitted their ECFs under the EIN we found for
the 501 (c)(4) entity, but one borrower submitted his ECF under a different EIN which ties to Students First
Institute, a 501(c)(3) entity. Both organizations have the same address. I'm going to suggest we reach out
to all borrowers and request a W-2 just to confirm under which EIN they are actually paid. Do you agree?
2) The second tab contains the listing of employers we approved to date as private not-for-profit (not
501 (c)(3)), providing public education. We included the EIN, name, and the date approved.
There were a total 87 employers approved as private not-for-profit providing public education. I did not go
through each one, but I believe most of the decisions we made internally, with only a handful escalating to
you.
Please let us know if you have any questions. Password to follow. Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Frrn~, b5
IC·
c~ b 5 , '"Battle. Cynthia'". "'T1ongquico. Rene"'
Dc1l~ 0810812016 04:08 PM
SL,,;_ecl [external]RE: Students First
11l(1rn,
We ,1grec with P-1E1\A', del.51(Jll tu dc·,v ull',CIT!µuvc L,1,cd Oil tile delcrrn111c1l"uc•,l"Ell dT cl"",JdVUlcllV grouo Jnd
do not :irov de public education as dethed tor the :iu':ioses at .>':,L-
i\tte' revie1.~'in1:,this escalation we would Ike to 'equest add t anal hto"nation tram f-'H=1\I\.
• A copy of tlw retr,,ct1on lettn that was spnrJ to \1<. KorkPs

• Please ::irov1clea counl of the ol·1er borrowers v11horeceived 0
etracllons and the elate of t·1e1r approval fo 0
Sludcnl, F1r,l.
• Would =>H:CAA
Uc Joie tu pul ,1 ww,t of lhc ·,u1T1!Jcrc1opcovcd nu
0 0
·, µruf"t nun 5O1(c)(3,I U"gc1°·,1z,1t1O11,
who lic1ve
been :i:iproved as :iu:ilic educat a~,to d:ite? t so, could .>H=1\I\be a:ile to vovide us ·,vith the name ot the qualitvinr,
employer and t~,e vear :i:ivoved7 I believe ·nost at these mav ~,;ive been escalated to f-S1\but ·,v;i~,tto make sure
we h,1vc ,1 cornµrelic 0
·,51vcbl.
I hanks,

To: l(bJ(5J I
Back in March 2012, we received an ECF for this employer (I didn't attach this one). We determined this
organization was 501 (c)(4), which was not-for-profit, but had to perform a qualifying public service. Since
this was at the beginning stages of the PSLF reviews, we approved this organization under the public
education category. This was before our more detailed conversations with Ian regarding public education
and that of an association.
It wasn't until April 2016 that we received another ECF for this employer. Based on our increased
knowledge at this point, we determined that this employer that, although not-for-profit, they actually do not
perform a qualifying public service. They don't actually provide the public education, but defend the
interest of children in public education.
Based on our re-review and ultimate denial of this employer, we requested the Business Unit to retract all
prior approvals. One borrower, who was approved based on the decision we made back in 2012 (they
submitted their form in July 2012), has now disputed the denial.
purposes.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; FedLoanPSLF
Cc: l(b)(5) I
NinemireSandra;fu&...!.a!:J_;,JohnsonDebbe
Subject: Re: Success Academy Charter School
Date: Monday, June 03, 2013 10:25:49 AM
Hi Diane.
I cannot a~~ociate the Ell\" with the organization in any way. Searching in
We~tLaw by Ell\" returned no re~ults, and. I ~earched the E!Ns of all the
charter schools within the network in the New York City-area and couldn't
find a match.
So, l would try and follow-up and ~ee what the Ell\" i~ all about.
Jan
> l(b)(5)
>Hi Jan, •·----------------~but
I we'd like
>your
>opinion.
>
>Employer indicated 50 I(c)(3) on the ECF. We previou~ly approved a
>Succe~s Academy Charter School under a different EIN (Harlem Succe~s
>Charter School 3). ~ame addre~s. While researching the current ECE we
>found a Form 990 for the Success Academy Charter School Network -
>different
>ElN. same addres~. The Network'~ Form 990 doe~n't include a ~chedule R
>showing related entities. We can't find anything under the EIN provided
>on the ECF ~o we're not sure if they quality.
>
>Passwur<l tu follow. Thanb!
>
>(See al!ache<l file: Succes~ i\ca<lemy Charter School.Lip)
>
>
>Diane Freundel
>(717) 720-3267
>fax-(717) 720-3911
>[email protected]
>This me~sage contains privileged and cunfidential information intended
>receive this me~sage in error please delete ur <le~troythis me~~age
>and/or attachmenb.
>
>The sen<leruf this me~sage will fully cooperate in the civil and criminal
>pro~ecution uf any indivi<lual engaging
>in the unauthoriLe<lu~e of this message.
From: !(b)(5)
To; FedLoanPSLF
Cc: l(b)(5) I~; NinemireSandra:,JohnsonDebbe;Battle Cynthia
Subject: Re: Suit Up for Business, Inc
Date: Tuesday, August 06, 201310:03:23 AM
Diane,
I agree that thi~ organization qualifies as you 1ve laid out. While I wi~h
there wa~ more evidence. between the certification on the ECF and the
articles of organization. I think \Ve have enough to approve it.
Jan
On 7/10/13. 21 :39, "FedLoan PSLF" <[email protected]> wrote:
>
>Hi Jan, Thi~ is another public intere~t law ~ervices employer that we're
>not sure of. The Bminess Cnit (BU) had to go back to the employer who
>i~
>aho the borrower a few times until we got some more information on what
>the organization doe~.
>
>I. ECF was completed as a private non-profit providing public interest
>lav>'
>service~. We could find no information on the organization except for the
>CA bu~iness filing which doesn't provide any detail. We asked the BU to
>contact the employer for proof of non-profit ~tatus as well as more
>information on what they do.
>2. BC talked to borrower who ~aid ~he couldn't provide anything because
>they had just formed in Jan 2013 as a non-profit entity and they had
>applied for 50 I(c)(3J statu~.
> 3. Again advised BU to contact borrower - if they were a registered
>non-profit in their state. they ~hould be able to provide documentation.
>4. BC talked to burrower and we received an explanatory letter with the
>articles uf incurpuratiun.
>5. Articles uf Incurpuration slate that they "provide bu~iness and legal
>~ervices." In her lener. she ~(ates they provide "public interest law
>~ervices to indigent population who are conducting legal planning in
>opening ...small bu~inesses."
>6. Borrower i~ an al!omey
>
>Although I'm not ~ure ifthi~ is enough evidence uf the services they
>provide, I think the urganinition qualifies and am included to approve.
>Do
>you agree? Pa~~word to follow. Thanks
>
>(See al!ache<l file: Suit llp Fur Busines~.zip)
>
>Diane Freundel
>(717) 720-3267
>fax-(717) 720-3911
>[email protected]

>
From: !(b)(5)
Cc: .Johnson Debbe: Ninemire Sandra: Sipple-Asher Bessie: Eo.ll.....!ao.
Subject: RE: Super Duper Afterschool Enrichment Program - Segsara Inc
Date: Tuesday, June 26, 201210:49:47 AM
Diane,
I cannot find anything to indicate that thi~ i~ a not-for-profit

entity. My under~tanding of the Nonprofit Corporation Law in California
allow~ corporations to be organized a~ not-for-profit organization; hO\vever,
\Ve cannot get acce~s to the articles of incorporation (which would contain
~pecific language verifying that it is a not-for-profit) to confirm. You
can find more about the exact requirement~ in California here:
l1trp·i/www ~o~ ca [iovibu~ine~~/corpipdfiarticle~icorp art~np.pdf.
As for
the charities database for California. I think thi~ would only include
501(c)(3Js.
We ~hould either deny this one or reach out to the employer for
confirmation that thi~ is not-for-profit.
Jan
> -----Original
Me~~age-----
> From: Diane Freundel [mailtn:dfretmde@pheaa nr[;l On Behalf Of
FedLoan
> PSLF
> Sent: Thursday. June 21. 2012 11:39 AM
>To:
l(b)(5)
> Subject: Super Duper AfteVichool Enrichment Program -
Segsara Inc
>
>
> Hi, We're unable to make a determination on this one.
They checked private
>non-profit.but we can't confirm. CA busine~~ tiling
information
> does not indicate non-profit statu~. We did find another
~ite for CA
> charities that includes a search function.
>
11np·i/caav~rare.ca 11~icJ1aritie~1
> This organization i~ not found on thi~
li~t.
>
> Thanks for your assi~tance! Pa~sword to follow.
>
> (See
attached file: Super Duper Aftershool Enrichment- Seg~ara, Inc.zip)
>
>
Diane Freundel
> (717) 720-3267
> fax-(717)
720-1911
> [email protected]
> This message contains privileged and
> the ahove addres,ee, only. If you
receive this me,sage in error please
attachments.
>
civil and criminal
> message.
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) I:,Johnson Debbe: Battle Cynthia
Subject: RE: Swinom1sh Casino and Lodge
Date: Tuesday, August 18, 201512:37:59 PM
Hi Diane.
We agree that the Swinomi~h Casino and Lodge qualifie~ based on the document~ that were previou~ly attached.
My apologie~ for the delay on this decision.
Thank~,
Taneka
From: Diane Freundel [mailto·dfreunde@lpl1eaa or~l On Behalf Of FedLoan PSLF
Sent: Monday, June 22. 2015 2:45 PM
To: l(b)(5) I
Subject: Swinomi~h Casino and Lodge
Hi Taneka. We have another tribal ca~ino!
ECF i~ certified as government.
We found evidence that it is owned and operated by the tribe. Although we couldn't find clear evidence of how the
ca~ino is organized, we did find evidence that the tribe'~ ~overeign immunity extend~ to the Casino and
Lodge (hotel code pdf). We believe they qualify. Can you plea~e let
u~ know if you agree.
Pa~~word to follow. Thank~!
(See attached file: Swinomi~h Casino & Lodge.zip)
Diane Freundel
Compliance Service~
(717)720-3267
[email protected]
Thi~ me~~age contaim privileged and confidential information intended for the above addre~~ee~ only. If you
From: !(b)(5)
To; FedLoan PSLF
Cc: Battle Cynthia
Subject: RE: Tachi Palace Hotel & Casino
Date: Friday, June 24, 2016 4:30:00 PM
H1Kim,
I'm Just realizing that I did not send a response back to you for this escalation We agree that Ta chi
Palace Hotel & Casino can be approved I was able to find the Santa Rosa Rancheria Ta chi Yokut
Lribe's State Gaming Compact wilh California. ll goes ir1lo more delail on Lhe agreemenl Lhal is
outl1nf'd in the article (1nterf'st1ng rf'ad) you sent over for review
Thanks,
Taneka
Sent: Friday, May 06, 2016 7:51 AM
To: !(bl(51 I
Subject: Tachi Palace Hotel & Casino
Hi Tanekal
We have another tribal entity for you.
We couldn't find too much on the Tachi Palace Hotel & Casino. Although not always a reliable source,
wikipedia indicates that the tribe took over operation in 1994. We also could not find any indication of the
hotel & casino being an B(a) firm. Also we noticed when researching, the employment link on the Tachi
Yokut Tribe website does like the Hotel and Casino. We also located an article that describes the tribe as
having sovereign immunity (you might get a chuckle out of the context of the story surrounding the hotel &
casino).
Given no other evidence indicating it is separately organized from the tribe. we would lean toward
approving this one.
Password to follow. As always, thank you for your assistance I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) I~; Ninemire Sandra: ,Johnson Debbe
Subject: Re: Tacoma Urban League
Date: Monday, June 03, 2013 10:36:56 AM
Hi Diane.
I agree with Kim that thi~ organization doe~ not appear to provide a
qualifying service. There\ nothing to suggest that any of this
organization·~ program~ are school-based. Though. when I tried to access
the organization·~ web~ite. it wa~ blocked by our firewall for "malware".
Let me know if you ~ee ~omething ~pecific that I mi~~ed.
Jan
>
>Hi Jan, We're not sure about thi~ one.
>
>They checked 501 (c)(3) on the ECF for employment from 0810 I111 to
>04/24/13.
>
>According to the IRS Select Check. their 501 (cJ(3) statu~ was revoked on
>05/ I5/ I2: therefore, we can approved from 08101I 11 to 05/14112.
>
>WA Secretary of State website ~hows them as non-profit. but also ~till
>show~ a~ 50 I(c)(3).
>
>We're trying to deterrnine if they provide a qualitYing ~ervice to approve
>as a private non-profit from 05/ 15/ 12 to 04124113. See page 2 of the
>business filing info document. Al~o page 2 of the Tacoma Urban League
>info
>document. I'm thinking they could pu~~ible qualify under "other school
>based services". Kim thinks it's a stretch and doesn't believe they
>qualify.
>
>We appreciate your thoughts. Password tu follow. I got an error me~sage
>while password protecting the zip file. but then was able tu open the
>documenb. Let me know if you have any i~~ue~with it. Thanks
>
>(See al!ache<l file: Tacoma Urban League.zip)
>
>Diane Freundel
>(717) 720-3267
>fax-(717) 720-3911
>[email protected]
>fur the above addressees only. If you
>receive this me~sage in en-or please delete ur <le~troythis me~~age
>and/or attachmenb.
>
>The sender uf this me~sage will fully cooperate in the civil and criminal

From: !(b)(5)
To; FedLoanPSLF
Cc: l(b)(5) I~; NinemireSandra: ,Johnson Debbe
Subject: Re: Tate Monroe Water Assn Inc
Date: Monday, September 16, 2013 3:44:49 PM
Hi Diane.
Thi~ organization doe~ not qualify. Remember. public health employers

that qualify mu~t employ people who work in specific occupation~. and a
water company would not employ those types of people. In addition, we do
not think that thi~ con~titutes public safety for PSLF Though they do
take measure to ensure that the \Vater they provide i~ clean and free of
contaminants. their primary purpose i~ the provi~ion of \Vater to
residences and busine~~e~. Though they do make reference to ensuring
\Vater is 3clean 2, a for-profit corporation would aho be required to do
~o. because it 1~ Federal and State law.
Jan
On 8/30/13. 22:01, "FedLoan PSLF" <[email protected]> wrote:
>
>Hi Jan, I'm pretty sure thi~ employer qualifie~. but wanted to run it by
>you.
>
>They checked 501(c)(3). They are a 50l(cJ(l2) that treat~ and deliver~
>potable water to member~. I think it could be a con~idered a qualitYing
>public health or public ~afety service. Your thought<) Thank~-
>
>Password to follow.
>
>(See attached file: Tate Monroe Water A~~n lnc.zipJ
>
>Diane Freundel
>(717) 720-3267
>fax-(717) 720-3911
>[email protected]
>receive this me~sage in effor please delete or de~troy this me~~age
>and/or attachmenb.
>
From: publicservice
To; Diane Freundel: .l(b~)~(5~)-~
Cc: [email protected]: ~; Ninemire Sandra: Sipple-Asher Bessie
Subject: RE: Teddy Bear Day Care
Date: Monday, February 06, 2012 2:30:11 PM
Diane,
Thi~ one i~ tough, but I think it doe~ not qualify becau~e it

operates for-profit.
The EIN, according to the HIPPA Verification Service

(here:
l1ttp·.//wwwhipaa~racs: mm/Medical Data Validation/F.rnplm·er Identification Nu
mber/EJI\"_Validation.a~px). says the Ell\" i~ valid. What that mean~. exactly.
I don't know. HO\vever, Westlav.-finds no organizations as~ociated \Vith the
EIN, and there is no entry in Pub 78.
As you mentioned. there didn't ~eem

to be a busine~~ tiling in the Idaho Secretary of State's Bu~iness
Organization Database except for an assumed name filing that wa~ for ~omeone
else in a different part of Idaho.
From my understanding. Teddy Bear Day

Care i~ a "gras~root~" movement in childcare that ~tarted in the 1970s.
They have no formal organization or structure, just underlying
principle~-
It'~ very possible that thi~ bo1TOweri~ a ~ole proprietor.

which i~ why there is no record in the state databa~e~. If she is a
proprietor. then she operates for-profit. I think the only way that she
would not be listed in the databa~e~ under her own name or that of "Teddy
Bear Day Care" is if ~he wa~ a proprietor. The only other alternative is a
general partnership (not a limited liability partnership, or something
~imilar, as they are required to tile with the state), but those aho
operate for profit.
However, the borrower checked that ~he provides

licensed or regulated childcare. Idaho law require~ virtually all day care
providers to be licensed. See here;
l1ttp·i/www 211.idalw vnv/da>'cardda>;·carelics;mini;html. Idaho aho allows
citie~ and other municipalities to provide more ~tringent re~trictions,
which, if they exi~t, displace the state requirements. The City of
Pocatello has done so in Title 5. Chapter 28 of the City Code. See here:
l1ttp·i/www ~rerlinvcndifier~ cnm/cnds;bnnkiindex.php· 1bnnk id-601.
Either
way, it looks like this borrower would need a license. As bizarre a~ this
might sound. I called the state and confirmed that the borrower is a
Iicensed childcare provider in the City of Pocatello.
In the end. she

providers a public service. but I do not think she operates not-for-profit.
So, her employment does not qualify.
I think you could either reject the

ECF or call and ask whether she can provide some sort of proof that she
operates not-for-profit, though I don't know what this could he.
Are you
having fun yet'!
Jan
> -----Original Mes,age-----

I mailto:dfreunde(ci)aessuccess.or!l I
> Sent: Monday, February 06, 2012 1:51 PM
>
To: l(b)(5)
> Subject: RE: Teddy Bear Day
Care
>
> Ian, The Ell\" that you typed below i, the one on the form.
thank,
>
> Diane Freundel
> (717) 720-3267
> fax-
(717) 720-1911
> [email protected]
>
>
> 1------------>
> I From:
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
lpublicservice Ll(~b)~(5~)------~
>I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
> I To: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
l"Diane Freundel" <dfreunde@ae,succe,s.org>
>I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
> I Date: I
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1021061201201 :44 PM
>I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
1------------>
> I Suhject:
> 1------------>
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
> IRE:
Teddy Bear Day Care
>I
>
>---------------------------------------------------------------------------
> ---------------------------------------------1
>
>
>
>
>
> Diane.
>
> Can you please type the EIN for me'.' Or confirm that the
one I typed, below.
> i~ COITect?
>
> I cannot find reference to it even in
We~tlaw.
>
> 00-27-3299542
>
> Thanks.
> Jan
>
>>-----Original
Me~~age-----
> > From: Diane Freundel [rnail!{nlfrs;unde(ci)ae~wcce~~nri; I
>>
Sent: Saturday, February 04, 2012 6:04 PM
>>To: IL.(b-")(-'-51
__ _,
>>Subject:
Teddy Bear Day Care
>>
>>
>>I believe thi, is a for-profit entity and
thm does not qualify. I
>>found
>a
>>certificate of assumed business
name on the ID state department site,
>>hut I'm not sure it is the same
entity. The borrower on the ECF
>>listed
> herself a,
>>the owner, hut
the owner on the husine'i'i certificate i, different.
>>Password to follow
in another email. Thanks!
>>
>>(See attached file: Brock_ Teddy Bear Day
Care.7ip)
>>
>>Diane Freundel
>>(717)
720-1267
> >fax- (717) 720-1911
>>
>
>>
>>Thi, me,,age contaim privileged and confidential

> for
> > the above addressees only. If you receive
this me'i'iage in e1Tor
> > plea,e delete or destroy this message and/or
attachment,.
>>
>>The sender of thi'i me'i'iage will fully cooperate in the
civil and
>>criminal pro,ecution of any individual engaging in the
unauthorized
> > u,e of this message.
>>
>
>>
>
>
>
>
>
>

attachments.
>
civil and criminal
> message.
>
>
From: !(b)(5)
Cc: Bl&...!.a!:l.;
Subject: Re: Temple Emanu-EI
Hi Diane.
I agree that we ~hould approve this one. As we have discussed

previou~ly,
houses of wor~hip are not required to file for a 501 (c)(3)
exemption from
the IRS (though most do, becau~e then they can prove it with
documentation
from the JRSJ.
What we should do with hou~e~ of worship that

are not in Pub 78 is approve
them if they appear to meet the criteria for
exemption under 501(c)(3J of
the JRC. Those ba~ic criteria are
here;
l1trp·i/www ir~-linvicharitie~/charitabldarticle/0 id-96099 00 html.
Though I've been using the term hou~e~ of worship (for neutrality), the
IRS
u~e~the term "church", which. true to form. encompasses all hou~e~
of
\vorship, but aho other entitie~. ~uch as conventions and a~~ociation~
of
houses of wor~hip a~ well a~ "integrated auxiliarie~" of home~
of
worship. See here; http'//www ir~ i;nvipphiir~-pdfip 1828 pdf
There i~ a
related i~~ue with "religious organization~" that are not
churche~. They
are required to file for exemption with the IRS unle~~
their receipts are
u~ually les~ than $50,000 per ,mum.
Jan
On 6/6/12 9;53 . "FedLoan PSLF"

<[email protected]> wrote;
>
>Hi, Regarding Erin Glazer's most recent
ECF We can find no evidence of
>her specific synagogue being a
non-profit; however. I did find an article
>about synagogues and non-profit
~tatu~ in general from the t..:nion for
>Reform
>Judaism. If the synagogue

meets the 5 requirements of a 501(c)(3J, then
>they are automatically
considered tax-exempt and do not need to file for
>50l(cJ(l) status.
There', mention in the article of a group exemption
>with
>the Union for
Reform .ludai,m (I believe Temple Emanu-El is a reform
>synagogue - I can't
get hack into their website, it keeps timing out).
>But
>the Union indicates
that they do not have operating control over their
>member,, ,o a group
exemption is not possible.
>
>I think we ,lmuld approve thi, one. Do you
agree'! Password to follow.
>Thanks.
>
>(See attached file: Temple
Emanu-EL7ip)
>
>Diane Freundel
>(717) 720-3267
>fax-
(717) 720-3911
>[email protected]
>This mes,age contain, privileged and
you
>receive this mes,age in error please delete or destroy this
message
>
>The ,ender of this mes,age will fully
engaging
>in the unauthorized use of thi'i message.
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) I~; ,JohnsonDebbe;NinemireSandra
Subject: Re: Texas Eating Disorder Support Services Inc
Hi Diane.
Thi~ one i~ tough.
Texas will not exempt an organization from franchi~e tax unle~~ it i~

federally exempt from income tax. So. we cannot rely only on the franchise
tax certificate~. because an organization can be not-for-profit but not
tax-exempt. While ~ome ~tares don 1t require non-profits to file anything
to be tax-exempt (particularly if organized as a not-for-profit
organization). otheVi do. And, Texas i~ one of them.
So, it 1~ clear form the documentation that the organization is non-profit

and it employes a p~ychologi~t to provide public health ~ervices. Many
p~ychologi~ts work out of their home~. and have family members who do more
administrative work. e.g., admi~~ion~.~o. that doe~n1t nece~~arily raise
many concerns for me. though it1~ ea~y to viev>'that ~u~piciomly.
But as to the full time i~~ue.I think it 1s broader than just that. I
don 1t ~ee how ((5i(6Jlcan be an authorized official a~ to (b)(6l . I think
we should trea~~ an instance where ~elf-certi~o (b)(6) is
required and that we want additional evidence that~work~ full-time
for the organization.
So, the organization qualifie~. but the~e borrowers, maybe not.
Jan
On 6/6/13, 14:20. "FedLoan PSLF" <[email protected]> wrote:
>
>Hi Ian. We're struggling with this one because we think things are
>~u~picious, but we don't believe we have a clear reason to deny and wanted
>your thoughts. We also want to find out if we've had a mi~conception
>about
>Texas business filings.
>
>We originally denied the ECF forl(b)(B) I
We could find no evidence
>of not-for-profit status. We recently received a dispute of that denial
>and another ECF for Heather Ingram, same address as((5i(6)l~ame employer.
>Within the dispute is a le11erfrom theTexas Secretary br-:srat-toffice
>confirming the entity's non-profit statu~.
>
>I. Our fir~t que~tion deals with the Texas bu sines~ filing. We were under
>the impression that if we found a Franchise Tax Account Status on the TX
>Sec of State ~ite. that the entity wa~ ~ubject to taxes and therefore was
>for profit. However, there i~ a Franchise Tax Account Status for Texas
>Eating Disorder Support Services. What is probably a stupid que~tion - I
>know a 50l(c)(3) is tax-exempt, but are non-profits that are not 50l(c)(3)
>al,o tax exempt'!
>j(5i(6Jl
>2L__JandL_
l(5i(6Jl
__ rnified each ~CF.
>form usrng the title "Sole Memher". ~igned
>the title "Director of Admission, and IT". The husi
LJ-
(b)(B)
.
ned
l(b)(6)
form using
t of their
>home, so wouldn't have "admissions." ECFs are certified as private
>non-profits that provide public health ,ervices.
>
>J. Each certified they are working Full Time - 40 hours for~and
>JO
>hours fo~(b)(B) I
>
(b)(6)
>4. Each has another company out of their home. has lnProcessOut-
>small game development for mohile and tahlet devices. (b)(6) has
>lnMindOut Emotional Wellness Center - she', a psychologist.
:(b)(5)
>,_
> ________________________ ~

>
>(See attached file: Texas Eating Disorder Support Services Inc.zip)
>
>Diane Freundel
>(717) 720-3267
>fax-(717) 720-3911
>[email protected]
>
>This mes~age contain~ privileged and confidential information intended
>receive this mes~age in error please delete or destroy this message
>
>The ~ender of this mes~age will fully cooperate in the civil and criminal
>in the unauthorized use of thi~ message.
From: !(b)(5)
To; FedLoanPSLF
Cc: l(b)(5) I:Eo..s..w.a..o.;
Subject: RE: Texas Municipal League
Date: Wednesday, April 16, 201410:49:18 AM
Attachments: Re Colorado Municipal Leaque.msq
Hi Diane,
After looking at the con,titution of the league (here: http:i/www trnl oq;/rnern con~titution), this is the same a, the
Colorado Municipal League. which we said qualified as a local intergovernmental organization.
Jan
Frnm: Diane Freundel [mailto·dfreunde@lpl1eaaor~I On Behalf Of FedLoan PSLF
Sent: Wedne,day, April 09. 2014 9:50 AM
To: l(b)(5) I
Subject: Texa, Municipal League
Hi Jan. This is another public interest law service, que,tion.
Employer certified private non-profit, public intere,t law ,ervices.
Employer is 501(cJ(4)
Texas Municipal League Hi,tory pdfhas ,ome general information - page, 2 and 3 and they do have a Legal
Service, division.
I don't think they qualify but we wanted to get your opinion.
Pa<;<;word
to follow. Thank,
(See attached file: Texa, Municipal League.zip)
Diane Freundel
Compliance Service,
(717)720-3267
fax-(717) 720-3911
[email protected]
Thi, rne'i'iage contaim privileged and confidential information intended for the above addre'i'iee, only. Jfyou
receive thi'i rne'i'iage in error plea,e delete or de,troy thi'i rne'i'iage and/or attachment,.
The sender of thi'i rne'i'iage will fully cooperate in the civil and criminal prosecution of any individual engaging in
the unauthorized u,e of this mes,age.
From: !(b)(5)
To; "FedLoanPSLF"
Cc: EQ&J.a.n; Battle Cynthia:,Johnson Debbe:l(b
0 0 )0(50)_~
Subject: RE: Texas Nurses Association
Hi Diane.
We al~o agree that thi~ organization doe~ not qualify. It i~ another 501(c)(6) organization that,just like you would
expect. advocate~ for nuVie~in the state of Texas. Among other things. the organization develop~ best practices for
nur~e~.and advocates for variou~ legislation. It i~. e~~entially. the N ASF AA of nurses (but limited in geography).
They are claiming to provide public health service~. Of course, ·'public health" include~ '·nuVie~.nuViepractitioner~,
and nurses in a clinical ~etting", but the organization doesn't ~eem to employ individuah who are working in that
capacity. Thi~ organization hire~ nuVie~.but they do not practice nuViing. Among other administrative thing~. the
nur~e~that work for the organization ·'provide support and oveViight to association activities relating to nursing
practice and monitor. evaluate. and re~pond to evolving issues affective nursing practice and policy in Texas··.
So, thi~ is not public health.
Jan
Sent: Monday, July 07. 2014 12:23 PM
To: l(b)(5) I
Subject: Texa~ Nurses As~ociation
Hi Jan. I apologize that I'm behind in sending these to you. I'll be ~ending several over the next few day~.
We're confident in our denial of this one. but the borrower i~ di~puting our deci~ion (the 34 page document in the zip
file). The organization i~ a 501(c)(6J. We don't believe it provide~ a qualifying public service. It~ mi~~ionis
"moving the nursing prote~~ion forward through leadeVihip.
advocacy, and innovation." Can you plea~e let us knO\vwhat you think?
Pa~~word to follow. thank~!
(See attached file: Texa~ Nur~es Association.zip)
Diane Freundel
Compliance Service~
(717)720-3267
fax-(717) 720-3911
[email protected]
Thi~ me~~agecontaim privileged and confidential information intended for the above addre~~ee~only. If you
From: !(b)(5)
To; FedLoan PSLF;.l(~b)~(5~)-~
Subject: RE: The Alliance for Economic Development of Oklahoma City, INC.
Date: Monday, September 24, 2012 3:30:06 PM
Hi Diane.
We agree The Alliance for Economic Development of OKC does not provide a qualifying service. This situation i~
similar to the Riverfront Busine~s Di~trict case that Ian provided a respon~e on a few weeks ago. In addition to the
direct information provided, some of our rea~oning i~ based on the following statements:
The last 4uote is from the President. who signed the ECF From http-/iokc hj1iok)abrnni1/article 17) 9 forrnin;_'-lilt'
alliance html
....Ward 2 Councilman Ed Shadid ~ay~he has concern~ with how the funds will be ~pent and who will keep an eye
on the alliance, calling thi~ "uncharted tenitory.''
"This is not an entity that provides guuds and service~ tu the public.'' he ~ays. 'There is no quid pro quo in terms uf
'we pay X amount of dollars and we get thi~ amount in return.' We're going to pay the salaries. the lease. the copy
machine. everything. regard le~~of what we get in return.''
Looking ahead. O'Connor says the group will keep close tabs on the budget. and then determine what it will need tu
re4uest for the 2012-13 focal year. She says while some have questioned what the citiLens are ge!ling for their
money. the alliance will help save money by working with several entities and pooling financial resources.
"We've set up a nonprofit consulting firm that ba~ically is providing professional services to all of these public
entities involved in economic development." she says.
Let us know if you have any questions.
Sandy
mrl On Behalf Of FedLoan PSLF
From: Diane Freundel [mi1ilt()'([l'rrnndr@·pbr;1;1
Sent: Monday, September 17, 2012 4:09 PM
To: l(b)(5) I
Subject: The Alliance for Economic Development of Oklahoma City. !KC.
Hi. Some of the escalated ECF~ may need to wait for Ian's return. but I wanted tu ~end them.
The certifying official checked both the government and the 50l(c)(3) boxes. We determined that they are a 50l(c)
(4) and as such would need to provide a 4ualifying ~ervice. We're having trouble determining if they provide a
4ualifying ~ervice. I also think they could pu~sibly be qua~i-governmenL
As~istance i~ always appreciated! Password tu follow. Thanks.
(See a!lached file: The Alliance for Economic Development of Oklahoma City.
Inc.Lip)
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
[email protected]
This me,,age contaim privileged and confidential information intended for the ahove addressee, only. If you
From: !(b)(5)
To; FedLoan PSLF
Cc: Battle Cynthia: ~;l 0(b0)0(50)_~
Subject: RE: The Ark of Little Cottonwood
Date: Wednesday, February 18, 2015 9:56:45 AM
Thank~ for update, Diane. I'm glad the bo1TOwersubmitted the tax tramcript even though it wa~ not required. I don't
know that I would have noticed the discrepancy otherwise.
FYI- I'm still working on the pending e~calation~. I hope to have a more ~ub~tantive update for you next week.
Have a good day.
Taneka
To: Chiala~tri. Taneka
Cc: Battle, Cynthia; FedLoan PSLF: Foss, Jan:.l(_bl_(5_1
__ _,
Subject: RE: The Ark of Little Cottonwood
Hi Taneka. t..:ponfurther review, the Bu~ine~s Unit ~houldn't have

e~calated thi~ one to Compliance because the employment period wa~ prior to the di~buViementdate of her Direct
Consolidation Loan: therefore, it
doe~n·t quality. However. regarding your email below. we were not
previou~ly advised to research tax tran~cript~ when determining employment that cannot be certified. In thinking
about it, we've had so few ofthe~e. I don't think we've had another borrower provide this type of information.
In the future, ifwe receive thi~ level of detail, we'll review it more
closely. Thanks for your a~si~tance!
Diane Freundel
Compliance Service~
(717)720-3267
[email protected]
Frorn:"Chiala~tri. Taneka" <[email protected]>

To:"Diane Freundel" <[email protected]>
Cc:"FedLoan PSLF" <[email protected]>. Ll(b~)~(5~1__ _,
l(b)(5) I
"Battle, Cynthia"
<[email protected]>. "Fo~~.Jan"<[email protected]>
Date:02/09/2015 I0:04 AM
Subject:RE: The Ark of Little Cottonwood
Hi Diane.
I reviewed the documents regarding The Ark of Little Cottonwood and comulted with Jan regarding my findings.
There are a few discrepancie~ between the buffuwer's claim of full-time empluyment as repurted on her ECF when
matched against the borruwer' s tax transcript for 2010 and 2011. Fur 2010 and 2011, the burrower received
unemployment compensation of $11, I 84 and $11,424, respectively (Form 1099-GJ. Ian also reviewed the
unemployment ,ite for Utah, and found that unemployed individual,:
.. must report any gro'i'i earnings for the week the work is performed, regardle'i'i of when you are paid. You can
earn up to 10% of your weekly benefit amount and still receive the full weekly benefit amount. If you earn over 30%
of your weekly benefit amount then a dollar for dollar deduction will he taken. However, if you earn an amount
equal to or more than your weekly benefit amount, or work 40 hour, or more, you will not he eligible for payment
that week."
Therefore, the borrower can't have been working 40 hours per week and also receiving unemployment unless the
employment and the benefits are for different time period,, in which case she is providing fal,e information tom, or
they are for the same periods, in which ca,e ,he is either providing false information concerning the hour, worked or
,he defrauded the state of Utah.
Additionally, I looked up the Bureau of Labor Stati,tics for Mental Health and Substance Ahuse Social Workers for
Utah. The data is from 2013 hut the high salary is reported at $69300 and the low ,alary is reported at $23,100. The
borrower's salary for 2011 falls within this range hut her ,alary for 2010 is well below this range (even adjusting for
a yearly 5% cost of living increa,e). I believe this also indicate, that the borrower is over-estimating her year,
worked (and/or her claim of full-time
employment) for the Ark of Little Cottonwood.
\Ve suggest a letter he written to the borrower asking her to reconcile the discrepant information.
If you have any concerns regarding this information please let me know.
Thank,,
Taneka
Frorn: Diane Freundel [mailto·dfreunde@lpl1eaa or~I On Behalf Of FedLoan PSLF
To: l(b)(5) I
Subject: The Ark of Little Cottonwood
Hi Ian, This question concern, an employer who is no longer in husine'i'i

and the borrower was unable to get certification. \Ve did confirm that the
entity wa, 50 I (c)(3). The borrower provided W-2s and certified herself a,
40 hrs per week for two full years 1/2/1 0 to 12/31 I I 1. We used the
calculation provided by Bessie Sipple-Asher in 2012 that gave a method for taking a salary from a W-2, looking at
the minimum wage for the year certified, and ming the hour, per week and number of weeks worked from the ECF
to detennine if the salary on the W-2 is greater than this calculation.
I don't think we ever discus,ed what we should consider as full-time employment for an entity that i, no longer m
existence. Using the calculation described above, this borrower's earnings from 20 IO do not equate to full-time
employment based on a 40 hour work week (the average numher of hours per week as certified hy the borrower). If
the employer's definition of full-time had heen between 30 and 38 hours, then her earnings would indicate full-time
employment.
Confused'!'! Password to follow. Thanks for your help!
(See attached file: Ark of Little Cottonwood.zip J
Diane Freundel
Compliance Services
(717)720-1267
[email protected]
This me,,age contaim privileged and confidential information intended for the ahove addressee, only. If you
This me<;<;agecontaim privileged and confidential information intended for the ahove addressee, only. If you
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) I~; NinemireSandra:,Johnson Debbe
Subject: Re: The Center for Health Care Services
Diane,
I agree that this one can be approved as government.
Section 533.035 of the Texas Code creates Local Mental Health Authorities throughout the State of Texas,
whose JObit is to oversee mental health 1ntheir defined, geographic region. The authorities are delegated
the power of the "Executive Commissioner" of the Texas "Health and Human Services Commission", a state
agency.
In add1t1on,Section 534.001 and following establishes "Community Mental Health Centers", which are
specifically defined as governmental entities.
The Center for Health Care Services is listed on the Texas Department of Health's website as both a Local
Mental Health Authority and a Community Mental Health Center. See here and here.
lac
Hi Ian, another one where we know they qualify, but can't categorize them.
1. They checked private non-profit and 4 qualifying services on the ECF-

emergency management, early childhood education, public service for
elderly/disabled, and public health.
2. Based on their history, info from Wikipedia (indicates they are the
local mental health authority) and the TX state website (indicates they are
funded by the TX Dept of State Health Services Mental Health and Substance
Abuse Div1s1on),we think they could be government.
Your thoughts? Password to follow. thanks!
(See attached file: The Center for Healthcare Services.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax-(717) 720-3911
[email protected]
you
The sender of this message will fully cooperate 1nthe civil and criminal prosecution of any individual
engaging
in the unauthorized use of this message
From: !(b)(5)
To; FedLoanPSLF
Cc: l(b)(5) I
Eo..s..w.a..o.;
Battle Cynthia:Odom Christian
Subject: RE: The Cypress Club
H1Kim,
FSA found evidence on the Cypress Club's website and Form 990 that they also provides nursing
services through their on-site health care center so we need to escalate this organization to OGC for
addilional review.
Th;rnks,
Taneka
Sent: Wednesday, May 17, 2017 1 :27 PM
To: !(b)(51 I
Subject: The Cypress Club
Hi Tanekal We reviewed this employer in April and ultimately denied. They are 501 (c)(4), but we
determined that they do not directly provide a qualifying public service. Based on our research, The
Cypress Club is a housing (retirement) community for older adults. Basically they are an independent
senior living community, where they are not necessarily providing "services" to the elderly.
The borrower has ultimately escalated and requested a re-review as she stated they should qualify as
they are an assisted living/ senior living organization .. Due to this, I am forwarding for your review.
Any guidance you can provide is appreciated. Password to follow. Thanks I
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; FedLoanPSLF
Cc: l(b)(5) I
Eo..s..w.a..o.;
Subject: Re: The Institute for Family Enrichment
Date: Monday, December 30. 2013 10:40:04 AM
Hi Diane.
Like you, I can find no evidence that the organization i~ a

not-for-profit. I wa~ able to find it in We~tlaw. but was unable to find
anything other than what you had done. So, we need documentation from the
employer that this is non-profit, e~pecially because we know it 1~ not a
501(c)(3J.
Jan
>
>Hi Jan, Thi~ one i~ a bit confu~ing.
>
>ECF is certified a~ 50 I(c)(3J with employment dates of 9/712012 to
>10/24/2013
>
>According to IRS Select Check, they lost 50 I(c)(3J ~tatu~on 11/15/2010
>
>According to an inactive bu~iness filing, it appears they were initially
>for profit
>
>According to the cu1Tentbminess filing, they are an LLC providing social
>service~
>
>Their web~ite indicate~ they provide an array of ~ervices for and on
>behalf
>of children, adolescents. adult~ and familie~ acro~s the state of Hawaii
>
>Information on the service~ they provide indicate they employ
>p~ychiatri~ts
>and regi~tered nurses, su I think they can be considered tu provide public
>heaHh services, but we can't determine if they are a private non-profit.
>
>Thanks again! Pas~wurd tu follow.
>
>(See al!ache<l file: The Institute fur Family Enrichment.zip)
>
>Diane Freundel
>(717) 720-3267
>fax-(717) 720-3911
>[email protected]
>receive this me~sage in error please delete ur <le~troythis me~~age
>and/or attachmenb.
>
From: ~
To; !(b)(5)
Subject: Re: The Keith Haring Foundation - Retraction
Date: Wednesday, November 23, 2016 1 :40:35 PM
It seems like we just don't have a lot of facts and it would be a lot less frustrating if FedLoan
servicing just calls the foundation and asks if she is an employee.
Do we know if the same authorized official signed both forms?
51__
On Nov 23. 2016, at 13:23, ~!(b_l(_ 5l______
~!,L!(_bl(_ ~lwrote:
I know it's the holiday because I'm getting soft. I know that the answer is likely
"no" but I want to run this by you before sending the response.
I did some additional research on the borrower below. I believe she works for the
foundation but is paid through the non-profit Keith Haring Foundation LLC.
Her Linked In lists that she is an archivist for the foundation and I found a random
job posting that lists her as an employee. http://palmerblog.liu.edu/wp
content/up loads/2012/05/The-Ke ith-H a ring-Found at ion. pdf
Her 2014 W2 lists her as an employee for the LLCand I reviewed the foundation's
full 990 (the foundation is a 501c3) on the GuideStar and they don't list the LLCas
a disregarded entity.
The fact that the certifying official turned in an updated ECFwith only the
foundation EIN listed concerns me. I'm thinking FedLoan should contact the
authorizing official to clarify that the borrower is not now employed by the
foundation or request that the borrower provide update copies of her W2 to
show that she is paid through the foundation. Or do you think that is unnecessary
and we should just approve the retraction.
The Keith Haring Foundation - Palmer School

pal merblog. liu .edu
-hP <e1th f-;:o1·1np;

;:01rndat1011-hP <e1th f-;:o1·1np;
;:01rndat1rn \.Vekrr"f'S
fur c1Sprir1g 20:..Ci/\rd1ivc':, l11lu11shiµ. hi':, i':, c; uric dc;y c1'Neck
c;µµlicc111l':,
fli'ld rrs1t1rn for a

Sent: Wednesday, November 23, 2016 8:19 AM
To: l(b)(5J I
Subject: The Keith Haring Foundation - Retraction
Good morning Taneka! Not sure if you are in the office today because of the holiday.
We have a borrower who submitted her ECF in April 2015 indicating her employer is The
Keith Haring Foundation. The EIN provided on the form linked up to the Keith Haring Studio
LLC. At the time we requested a W-2 to confirm the EIN as the foundation was definitely
eligible, but we didn't believe the Keith Haring Studio LLC qualified. The borrower returned
her W-2 in June 2015, but it wasn't escalated to us until just recently.
The W-2 confirms that she is paid by the Keith Haring Studio LLC. We could not find
evidence that the Keith Haring Studio LLC is 501 (c)(3) or a disregarded entity of the
foundation; however, we found evidence that the Keith Haring Studio is possibly not-for-
profit, but nothing conclusive. Even though they are not-for-profit, they do not perform a
We were going to automatically deny the ECF; but discovered that the borrower submitted
a subsequent ECF indicating she was employed directly by the Keith Haring Foundation
under their EIN. This ECF was approved by the Business Unit. Since we now have the W-2
confirming employment by the Keith Haring Studio LLC, we need to retract the approval
under the Keith Haring Foundation as the borrower was erroneously certified as being
employed by that organization.
Password to follow. Thanks and have a happy Thanksgiving!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
Code:PHEAA
From: !(b)(5)
To; FedLoan PSLF
Cc: l
Battle Cynthia: ,Johnson Debbe: 0(b
0)0(50)_~
Subject: RE: The National Board of Boiler and PressureVessel Inspectors
Date: Thursday, October 30, 2014 1 :33:26 PM
Hi Diane.
We agree that thi~ qualifie~ at a not-for-profit organization that provides public safety ~ervices.
Jan
From: Diane Freundel [mailto·dfreunde@lpl1eaa or~l On Behalf Of FedLoan PSLF
Sent: Monday, September 08. 2014 2:37 PM
To: l(b)(5) I
Subject: The National Board of Boiler and Pres~ure Ve~sel Inspector~
Hi Jan. Can you please take a look at thi~ one. It's a 501(cJ(4) and typically tho~e entitie~ don't themselve~ provide
a qualifying public service; however, we think thi~ one might.
I. Certified as private non-profit that provide~ public ~afety.
2. Mi~~ion on the Form 990 is that they "promote uniformity in the admini~tration and enforcement of boiler and
pre~sure ve~sel safety".
3. Ba~ed on their website, they offer comprehensive training programs for in~pector~ and pre~~ure equipment
professionah. They aho inve~tigate accidents and issues with code compliance.
We tend to think they qualify. Your thoughts'! Pa~~word to follow.

thank~!
(See attached file: The l\"ational Board of Boiler & Pre~~ure Vessle
ln~pectors.zip)
Diane Freundel
Compliance Service~
(717)720-3267
fax-(717) 720-3911
[email protected]
Thi~ me~~age contaim privileged and confidential information intended for the above addre~~ee~ only. Jfyou
the unauthurized use uf this me~sage.
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) IBattle Cynthia:,JohnsonDebbe
Subject: RE: The Options Clearing Corporation
Date: Monday, April 27. 2015 8:29:51 AM
H1Diane,
I agree with you. The Options Clearing Corporation does not qualify for the basis of Public Service
Loan Forgiveness. They are not governmental, their business filing shows they are based out of
Delaware. In my opinion, the Options Clearing Corporation's status is similar to how the federal loan
servicers manage their direct loan portfolios under the authority of the Department of Education.
Please let me know if you have additional concerns on this one.
Thanks,
Taneka
To: l(b)(5) I
Subject. The Options Clearing Corporation
Hi Taneka, We'd like your input on this employer. They certified as
government, but they are owned by several stock exchanges and operate under the jurisdiction of
the SECand the CFTC.We don't believe they qualify.
As always, we appreciate your time. Password to follow. Thanks!
(See attached file· The Options Clearing Corporation.zip)
Diane Freundel
Compliance Services
(717) 720-3267
[email protected]
From: !(b)(5)
To; FedLoan PSLF
Cc: Battle Cynthia: 1(~b)~(5~1..,...~
0
Subject: RE: The Osler Institute Inc
Date: Monday, July 06, 2015 3:51 :33 PM
Hi Diane.
The O~ler Institute does not quality as an employer for the purposes of PSLF. In rendering it~ decision, OGC
focu~ed on the definition of "public education" a~ being limited to K-12 education. Therefore. continuing medical
education providers, ~uch a~ the Osler ln~titute, and continuing legal education organizations would not qualify.
Since OGC is limiting the definition of "public education" to K-12. FSA is raising the que~tion of whether "public
education" a~ a qualifying ~ervice could ever include a higher education organization (that doe~ not qualify as a
501(c)(3J).
I'll keep you po~ted on a re~ponse.
Thank~,
Taneka
----Original Me~sage-----
From: l(b)(5) I
Sent: ThuViday, June 18. 2015 3:02 PM
To: FedLoan PSLF
Cc: l(b)(5) I
Battle, Cynthia
Subject: RE: The Osler Jmtitute Inc
I was hoping to have a deci~ion for this one but we are going to need to e~calate this to OGC. J'l1 update you a~ ~oon
a~ \Ve hear something back.
Thank~,
Taneka
mrl On Behalf Of FedLoan PSLF
Frorn: Diane Freundel [mi1ilt()'([l'rrnndr@·pbr;1;1
Sent: ThuViday, May 2 L 2015 11:51 AM
To: l(b)(5) I
Subject: The O~ler Jn~titute Inc
Hi Taneka. We'd like your thoughts on thi~ one.
They certified as private non-profit providing public education (continuing medical education handwritten on ECF).
They are a 50 I (cJ(6).
As they stated. they do provide Continuing Medical Education (CME) ~e~sions that appear to be similar to
Continuing Legal Education (CLE) ~e~~iom. We can't recall having one of these before. We're struggling with
whether they meet the definition of public education because I believe their ~e~~iomare typically ~eminar style at
hotels.
We got the following from Jan on 8119114regarding Society of Digital

Agencies:
Hi Diane.
Sorry for the delay on this one. We wanted to run it by our attorney, but he wa~ on leave for a while. We've settled,
however. on a definition of pub Iic education! For PSLF. public education ~ervices are tho~e that provide educational
enrichment or support directly to student~ or their familie~ in a ~chool or a ~chool-like setting. The Society of Digital
Agencies i~ a 50l(c)(6) organization whose mi~~ion is, according to their Form 990, is to provide infrastructure.
proce~~e~,and products to enable collaboration between member~ around education, best practices, and advocacy.
When you look at their web~ite, they in no way appear to actually be an organization that is about "public
education". Contrary to their "mission", they ~eem to be about marketing.
In ~hort, we agree that this organization doesn't quality.
Jan
Thank~ for your help! Pa~~word to follow
(See attached file: The O~ler Institute Inc.zip)
Diane Freundel
Compliance Service~
(717)720-3267
[email protected]
receive thi~ me~sage in error plea~e delete or de~troy thi~ me~~ageandlor attachment~-
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) ICynthia: ,Johnson Debbe
Subject: RE: T1shom1ngoApartments Inc
Date: Tuesday, November 04, 2014 9:54:38 AM
Hi Diane.
We do not think that this organization provide~ ~ervices to the elderly and di~abled. Section 8 homing is available
widely to low-income individuals, and anyone can be a Section 8 hou~ing provider
Jan
Sent: Tuesday, September 16. 2014 3:27 PM
To: l(b)(5) I
Subject: Tishomingo Apartments Inc
Hi Jan. We're not ~ure about this one. Our fiVit inclination was to deny, but decided to run it by you based on
additional re~earch we did.
I. ECF certified as private non-profit providing public ~ervice to disabled and elderly.
2. Organization i~ 50 I(c)(4J - their mis~ion on the Form 990 i~ providing low income housing to low-income
families and the elderly with HUD Section
8 a~~istance.
3. We looked at information from the IRS (attached) to determine what type~ of ~ervices an organization mu~t
providetobe501(c)(4). IRC501
(c)(4) embrace~ two general cla~~ifications - social welfare organizations and local as~ociations of employees:
therefore. Tishomingo would fall under ~ocial welfare organization~- Based on the information we found (~ee
highlights on page~ 4-5 of IRS attachment) we now think they could quality.
We appreciate your a~~istance! Password to follow. Thanks.
(See attached file: Tishomingo Apartment~ Inc.zip)
Diane Freundel
Compliance Service~
(717)720-3267
fax-(717) 720-3911
[email protected]
From: Sipple-Asher Bessie

To; !(b)(5) ,~
Subject: RE: Town of Morocco, IN
Date: Tuesday, February 14. 2012 11:31 :08 AM
Hi Diane,
Fur self-certified forms we will need ~upporting evidence. So.

the options you prupose are correct. If she wanb ~umeune ebe in the
clerk's uffice tu ~ign, ~he can resubmit. Otherwise, she shuuld ~ubmit her
W2's {and, ideally, a paystub) frum each year she includes on her ECF
I'm
working on finaliLing the guidance to you on supporting evidence and in
short, the best evidence i~ W2 + a paystub for each year of employment.
w,
can make do with a W2 only if the annual income is rea~onable tu ~upport a
claim uf full-time employment for the number of weeks reported.
I'll get
thi~ to you soon.
Be~~ie
From: l(b)(5) I
Sent: Tue~day, February 14, 2012 10:54 AM
To: Foss, Ian: Sipple-Asher,
Be~~ie
Subject: FW: Tuwn uf Morucco, II\
Did ~omeone reply tu Diane on this

one? I just see a "Thank yuu" but nut a response. Ju~t checking.
Thanks.
[nwil111·dl'rrunde(Iz);w~~11cq;~~
11q;lOn Behalf Of FedLoan PSLF
Sent: Friday,
February 10, 2012 4: 18 PM
To: l(b)(5) I
Subject: Town of Muroccu,
IN
Good afternoon, We have anuther uni4ue situation. The burrower signed

her own form as the certifying official. We were going tu deny it, but on
further review I verified on the Town's website that she i~ the Town Clerk
{attached). When it is a small town such as this one, we're not ~ure who
would be the certifying official.
Pu~sible options are tu advi~e her that

someone else will need to certify her employment date~ and average huur~ per
week, or she will need to send u~ additional documentatiun to ~upport the
dates and hour~ per week.
Your thoughts?
Pa~w>'ord to follow.
Thanks!
{See
a\lached file: Rainford Tuwn of
Muruccu.zip)
This message contains privileged and confidential

information intended for the above addre~sees unly. If yuu receive this
message in errur please delete or destruy this message and/or attachments.
The sender of this message will fully cuoperate in the civil and criminal
prosecution of any individual engaging in the unauthuriLed use uf this
message.
From: Sipple-Asher Bessie

To; ~; ~lfb~J(~5)~~
Cc: Ninemire Sandra: ,Johnson Debbe
Subject: RE: Transforming Lives Academy (PSLF)
Date: Thursday, June 28, 2012 1 :53:11 PM
I think it's a good start that the organization qualities and that she works
there. The other part, that she'~ paid by the organization for full-time
work is what need~ to be supported. We provided PHEAA guidance that the pay
~hould rea~onably ~upport that the person \vorks for the stated number of
houVi. using the hourly federal minimum wage a~ the lower limit, but we
didn't decide what to do if ~omeone's pay does not meet minimum wage for the
hOUVi~tated.
I'm hesitant to go on a 2011 W2 alone, became if she wa~

only paid for one month'~ work, it might be a very ~mall amount. The more
pay~tub~ ~he has, the stronger her ca~e will be that she\ a FT paid
employee. But what would we do if she only pays heVielf sporadically and
for a very ~mall amount (less than minimum wage)'.'
Bessie Ko
Sipple-A~her
Federal Student Aid
U.S. Department of
Education
Tel: 202-377-3145
[email protected]
-----Original
Me~~age-----
From: Fo~~. Ian
Sent: ThuViday, June 28. 2012 1:42 PM
To:
Sipple-A~heL Be~sie: cl(~b)~(5~)
__ _,
Cc: Ninemire. Sandra: Johnson.
Debbe
Subject: RE: Transforming Live~ Academy (PSLF)
You dun'( think it's

acceptable to simply ask fur a 2011 W-2, to cunfirm that she'~ a paid
employee and then go un that assumption alune'' Are yuu saying that ~he
needs to pruvide pay stub~ tu cuver the whole period that her W2 doe~n·t, or
just ~umething during the time period. e.g .. her la~t pay ~tub for 2012, to
cunfirm that she's still a paid employee?
I just don't want borrowers who

would be classified as entrepreneurial (and "~ucial" une~ at that) tu be
unduly burdened becau~e they did something great like ~tart their own
nut-for-prufit organinition.
> From:
Sipple-Asher, Be,sie
> Sent: Thursday, .lune 28, 2012 1: IX PM
>To:
l(b)(5)
> Cc: Ninemire, Sandra: Johnson, Dehhe; Foss, Ian
> Subject:
RE: Tran,fonning Lives Academy (PSLFJ
>
> We should a,k her to ,uhmit as
much supporting evidence as she can
> provide. As an employee of the
company, she should have heen issued a
> W-
> 2 for 2011, which would
confirm her employment and support that ,he is
> a paid employee, rather
than a volunteer. \Ve should use the hegin
> date of
> 11/29/11 unless an
earlier date is noted on the articles of
> incorporation that she offered
to provide.
>
> We may not he ahle to count any months of 2012 until she
can provide
> 2012's W2- unless she has paystuhs for this period.
>
>
Thank,,
> Be'i'iie
>
>
> Be'i'iie Ko Sipple-A,her
> Direct Loan, Divi,ion
>
Federal Student Aid
> t..:.S. Department of Education
> Tel: 202-377-3145
>
[email protected]
>
> -----Original Me'i'iage-----
> From:
l(b)(5)
> Sent: Thursday. June 28. 2012 12:51 PM
> To: Sipple-A,her.
Bessie
> Cc: Ninemire, Sandra; John,on, Dehbe; Foss, Jan
> Subject: FW:
Tran,forrning Live, Academy (PSLFJ
>
> Be'i'iie, what do you think ,he ,hould
provide') The organization
> qualities, but thi, is a self-cert.
>
>The
111inoisCorporations database shows that the name of the borrower

> is the
name of the agentiincorporator, so that adds credence to her
> story;
however, her beginning employment date on the ECF is I 0/24/2011
> and the
incorporation date i, 11/2912011 in the datahase--,o if we go
> on the fact
that thi, entry in the Illinois database i, enough, we
> would have to have
FedLoan set the start date to 11/29/2011 because
> that's all the
information we have that's authoritative.
>
> What do you think'!
>
>>
I mailto:[email protected]~] On Behalf Of
> > FedLoan PSLF
>>Sent: Friday,
June 22, 2012 11:08 AM
>>To: l(b)(5) I
>>Subject: Tran,forming Lives
Academy
>>
>>
>>Hi, This issue concerns self-certification of
employment when no
>>one else can certify. We talked about it last month
and I indicated
>>we had one. I was supposed to ,end it to you ,o you
could determine
>>what the borrower would need to provide. I just
realized that I
>>neglected to send it
> to you.
> > I apologize.
>>
>>
The borrower is the only employee - founder, owner, pre,ident. She
>>has
,ome volunteer help, hut they couldn't really certify her full
>>time
employment/ number of hours. She offered to provide her
> > articles of
incorporation.
>>The organization currently qualifies as a private
non-profit
>>providing qualifying service. According to the bo1TOwer,
>
> Tramforming Lives Academy i'i entirely education based. They teach
>>
Iiteracy classes, English, computer skills, career building ,kill,.
>>
etc. They teach GED cla'i'ie'i
> and mentor people.

>>She did apply for
50 I (c)(3) status, which is the hox ,he checked on
>>the ECF. and expects
to receive it in July.
>>
> > Plea,e advi,e. Password to follow.
Thank,!
>>
>>(See attached file: Transforming Lives Academy.zip)
>>
>>
Diane Freundel
>>(717)720-3267
>>fax-(717)
720-1911
>>This me<;<;agecontaim privileged and
confidential information
>>intended for the ahove addressees only. If
you receive this message
>>in error please delete or de,troy this me<;<;age
andlor attachment,.
>>
>>The sender of this me<;<;agewill fully cooperate
in the civil and
>>criminal prmecution of any individual engaging in the
unauthorized
> > u,e of this message.
From:
To; I
FedLoanPSLF
Cc: NinernireSandra:Sipple-AsherBessie:,JohnsonDebbe:~
Subject: RE: Transit Employees Federal Credit Union
Date: Thursday, May 10, 2012 8:23:05 AM
Diane,
After escalating this employer to OGC and OPE, we have determined that Federal Credit Unions are
not governmental entities for the purposes of PSLF.Therefore, this one at least doesn ♦t qualify.
Though, that being said, I don ♦ t know how any of them ever would qualify.
Thanks for your patience.
Ian
From: lcclbccl("'5)'---'
Sent: Friday, April 27, 2012 4.40 PM
To: Fedloan PSLF;l(b)(5) I
Cc: Foss, Ian; Ninem1re, Sandra, Sipple-Asher, Bessie; Johnson, Debbe
Subject: RE Transit Employees Federal Credit Union
Diane,
Credit Unions are tricky. Though all are not-for-profit by definition, there are two types: State-
Insured Federal Credit Unions and Federal Credit Unions.
This one is a Federal Credit Union. That is a designation that can only be granted by an independent
federal governmental agency, called the National Credit Union Adm1nistrat1on, pursuant to 12 USC
1752 et seq. All credit unions that received a designation are tax-exempt under a group exemption
granted by the IRSto the NCUA under Section SOl(c)(l) of the Internal Revenue Code and all
deposits, up to $250,000 are backed by the full faith and credit of the United States by the NCUA.
Section SOl(c)(l) of the IRC is for instrumental1t1es of the United States. Therefore, 11.b.i.o.k
that
Federal Credit Unions, if you can verify that they are designated as such by the NCUA (there's a
database at NCUA.gov; for this one, search for charter number 3764}, qualify as federal
governmental organizations. Because l ♦ m not sure, 1 ♦ 11 have to run this one by others here
before giving you a final answer.
1 ♦ 11 reserve my thoughts on state-chartered credit unions for another day.
Ian
> PSLF
> Sent: Friday, April 27, 2012 9 38 AM
> To: l(b)(5) I
> Subject: Transit Employees Federal Credit Union
>
>
> Hi, We have another one we're unsure of.
>
> They checked box bas a 501(c)(3). We couldn't find anything in Pub 78 or in
> the BMF for DC. We did a general google search about the tax exempt status
> of federal credit unions and determined that they are tax-exempt, but under
> IRC 501(c)(14).
>
> Since they are not a 501(c)(3), we don't think they provide a qualifying
> public service. Do you agree? Password to follow. Thanks!
>
> (See attached file Transit Employees FCU.zip)
>
> Diane Freundel
> (717) 720-3267
> fax- (717) 720-3911
> [email protected]
>
> message.
From:
To; I
FedLoanPSLF
Cc: NinernireSandra:Sipple-AsherBessie:,JohnsonDebbe:~
Diane,
After escalating this employer to OGC and OPE, we have determined that Federal Credit Unions are
not governmental entities for the purposes of PSLF. Therefore, this one at least doesn't qualify.
Though, that being said, I don't know how any of them ever would qualify.
Thanks for your patience.
Ian
From: l(b)(5J I
Cc: Foss, Ian; Ninemire, Sandra; Sipple-Asher, Bessie; Johnson, Debbe
Diane,
Credit Unions are tricky. Though all are not-for-profit by definition, there are two types: State-
Insured Federal Credit Unions and Federal Credit Unions.
This one is a Federal Credit Union. That is a designation that can only be granted by an
independent federal governmental agency, called the National Credit Union Administration,
pursuant to 12 USC 1752 et seq. All credit unions that received a designation are tax-exempt under
a group exemption granted by the IRSto the NCUA under Section 501(c)(1) of the Internal Revenue
Code and all deposits, up to $250,000 are backed by the full faith and credit of the United States by
the NCUA.
Section 501(c)(1) of the IRC is for instrumental1t1es of the United States. Therefore, I ib..Lo.t.
that
Federal Credit Unions, if you can verify that they are designated as such by the NCUA (there's a
database at NCUA.gov; for this one, search for charter number 3764}, qualify as federal
governmental organizations. Because I'm not sure, nl have to run this one by others here before
giving you a final answer.
I'll reserve my thoughts on state-chartered credit unions for another day.
Ian

> From: Diane Freundel fmailto:[email protected]) On Behalf Of FedLoan
> PSLF
> Sent: Friday, April 27, 2012 9.38 AM
> To: l(b)(5) I
> Subject: Transit Employees Federal Credit Union
>
>
> Hi, We have another one we're unsure of.
>
> They checked box bas a 501(c)(3). We couldn't find anything in Pub 78 or in
> the BMF for DC. We did a general google search about the tax exempt status
> of federal credit unions and determined that they are tax-exempt, but under
> IRC 501(c)(14).
>
> Since they are not a 501(c)(3), we don't think they provide a qualifying
> public service. Do you agree? Password to follow. Thanks!
>
> (See attached file Transit Employees FCU.zip)
>
> Diane Freundel
> (717) 720-3267
> fax- (717) 720-3911
> [email protected]
>
> message.
From: !(b)(5)
To; "FedLoanPSLF"
Cc: l(b)(5) I
,JohnsonDebbe:Battle Cynthia
Subject: RE: Tri-Special Ut1l1tyD1stnct
Date: Friday, August 21 2015 8:28:49 AM
H1Diane,
We agree that the Tri-Special Utility District is quasi-government. We looked up the Water Code in
the state constitution for Texas. There is a section (listed below) stating that these districts shall be
governmental agencies.
Sec. 59. CONSERVATIONAND DEVELOPMENTOF NATURAL RESOURCESAND PARKSAND
RECREATIONALFACILITIES;CONSERVATIONAND RECLAMATION DISTRICTS.(a) The conservation
and development of all of the natural resources of this State, and development of parks and
recreational facilities, including the control, storing, preservation and distribution of its storm
and flood waters, the waters of its rivers and streams, for irrigation, power and all other useful
purposes, the reclamation and irrigation of its arid, semiarid and other lands needing irrigation,
the reclamation and drainage of its overflowed lands, and other lands needing drainage, the
conservation and development of its forests, water and hydro-electric power, the navigation of
its inland and coastal waters, and the preservation and conservation of all such natural resources
of the State are each and all hereby declared public rights and duties; and the Legislature shall
pass all such laws as may be appropriate thereto.
(b) There may be created within the State of Texas, or the State may be divided into, such
number of conservation and reclamation districts as may be determined to be essential to the
accomplishment of the purposes of this amendment to the constitution, which districts shall be
governmental agencies and bodies politic and corporate with such powers of government and
with the authority to exercise such rights, privileges and functions concerning the subject matter
of this amendment as may be conferred by law."
Please let me know if you have questions or concerns.
Thanks,
Taneka
From: Diane Freundel [mai1to:[email protected] On Behalf Of FedLoan PSLF
To: l(b)(5) I
Subject. Tri-Special Utility District
Hi Taneka,
We previously received an ECFfor this employer and could not confirm that it was 501(c}(3) as
originally certified; however, our research indicated it may be a governmental entity. In addition, it
appeared the borrower/certifying official had originally selected government on the ECF, but erased
it or whited it out. After receipt of the first ECF,we
requested proof of governmental status. In response, the borrower
provided a Sales and Use Tax Exemption Certification for the state of Texas as proof. The certificate
indicates the organization's tax exemption status is because it's a political subdivision and the
certificate references Rule
3.322 for Exempt Organizations (included in attachment}. This Rule states that " ...any county, city,
special district or other political subdivision of the State of Texas..." is considered an entity that is
always exempt.
While we don't believe this certificate, by itself, is sufficient evidence of governmental status, the
borrower has submitted a new ECFcertifying as a government entity. These items, in conjunction
with our research, lead us to believe the organization is government/quasi-government.
Along with the above listed documents, we've included the following:
- 2004 Form 990 for Tri-Water Supply Company, same EIN, showing 501(c)(12)
- 501(c)(12) revocation for Tri-Special Utility District, same EIN, as of
5/15/11
- Notice of Special Called Meeting for Tri Special Utility District. We believe this confirms
government/quasi-government status
- Notes to Financial Statements show Tri-County Special Utility District is governmental - we believe
they are possibly the same/related organizations, although they are listed separately on the city's
Chamber of Commerce website {see Both Companies Listed .. pdf).
(See attached file· Tri Special Utility District.zip)
Diane Freundel
Compliance Services
(717) 720-3267
dfreu nde@phea a.org
Code:PHEAA
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) I Eo..s..w.a..o.;
,Johnson Debbe;Battle Cynthia
Subject: Re: Trust Africa
Date: Friday, November 29, 2013 3:29:24 PM
HI Diane,
Yes, a 501(c)(3) qualifies regardless of whether it is "international" We address this in the PSLFQ&A
document. See Q.42.
Ian
On 11/26/13, 9:57, "Fed Loan PSLF''<[email protected]> wrote:
Hi Ian, I think we can approve this one, but want to be sure since all of
their work is done in Africa. ECFis certified as a 501(c)(3). The Form
990 also shows as 501(c)(3). Even though their primary address is In
Senegal, the 990 indicates that their state of legal dom1c1leis DC.
Please confirm.
Password to follow. Thanks and Happy Thanksgiving!
(See attached file: Trust Africa.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax-(717) 720-3911
dfreundeCWpheaa
org
yoo
The sender of this message will fully cooperate In the civil and criminal prosecution of any 1ndiv1dual
engaging
From: ~
To; !(b)(5)
Subject: Re: Uniform Law Commission
Date: Tuesday, June 13, 2017 3:11 :47 PM
., . ., . .. 1(b)(6)
(b)(6)
(b)(6)
From: Kimberly A Myers on behalf of Fed Loan PSLF

Sent: Thursday, June 1, 2017 3:48:26 PM
To: l(b)(5J I
Cc: Odom, Christian; Battle, Cynthia; Fed Loan PSLF; Foss, Ian
Subject: Uniform Law Commission
Hi Taneka! I wanted to run this employer by you.
They certified as not-for-profit providing public interest legal services. While their website and other
information indicate they are not-for-profit, I believe they may be quasi-governmental. On the Form 990 of
the foundation, this organization is listed as being under Section 115, which is indicative of quasi-
governmental organizations. However, I couldn't find anything conclusive in their bylaws or otherwise.
Any guidance would be appreciated. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; FedLoan PSLF
Cc: Odom Christian; Battle Cynthia: Eo..ss...J.a.o.;
cl(b~)(~5~)
-~
Subject: Re: Uniform Law Comm1ss1on
Date: Tuesday, June 13, 2017 3:48:33 PM
Hi Kim,
FSA read on the Uniform Law Commission's website that the organization was
founded in 1892 via an "interstate compact"; however, we are unable to locate it.
Could you have the Business Unit reach out to the authorized official for a copy of this
document so that we could continue the review of this organization.
Thanks,
Taneka

To: l(b)(5J I
Cc: Odom, Christian; Battle, Cynthia; Fed Loan PSLF;Foss, Ian
Subject: Uniform Law Commission
Hi Tanekal I wanted to run this employer by you.
They certified as not-for-profit providing public interest legal services. While their website and other
information indicate they are not-for-profit, I believe they may be quasi-governmental. On the Form 990 of
the foundation, this organization is listed as being under Section 115, which is indicative of quasi-
governmental organizations. However, I couldn't find anything conclusive in their bylaws or otherwise.
Any guidance would be appreciated. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
Cc: Bl&...!.a!:l.;
Ninemire Sandra: Sipple-Asher Bessie
Subject: RE: Univ of TN Genetics Center
Date: Friday, February 10, 2012 9:21:41 AM
That'~ correct. The organization qualifies as a governmental employer.
>
[mailto:dfreunde@aewJCce~~-or~ l On Behalf Of
> FedLoan PSLF
> Sent:
Thursday, February 09, 2012 7:55 PM
> To: l(b)(5) I
> Subject: Univ of
Tl\" Genetic~ Center
>
>
> EIN - 00-62-6001636
>
> The Genetic~ Center i~
part of the t..:nivof TN Medical Center
>
l1trp·i/wwwutrnedicalcs:nteror~iahmn-u~/
>
> Certifying official checked
box c and public health. I know Univ of TN qualities
> as a government
organization. The Ell\" provided i~ for the Univ of TN.
> believe the
Genetic~ Center i~ a qualifying employer (government
> organization), but
would like to verify. Thank~.
>
> Diane Freundel
>
(717)720-3267
> fax- (717) 720-3911
> [email protected]
>
>
>
>

> the above addre~~ee~only If you receive this
message in error plea~e
> delete or de~troy this me~~age and/or
a\lachments.
>

civil and criminal
> message.
>
>
From: Foss Ian

To; Lawrence M. Ross
Bee: l(b)(5) I FedLoan PSLF
Subject: RE: University Dental Resident Services, PC
Date: Monday, October 27, 2014 2:34:00 PM
H1L;irry,
Based on :he articles of org2nIzatIon, UDRS, like UMPS would be considered 2 not for profit
organiz2tion :ha: provides public health services. This would m2ke UDRSa qualifying employer for
Lhe purµose:, uf lhe PSLI Program
l;rn Foss
From: Lawrence M. Ross [mailto:[email protected]]
To: Foss, Ian
Subject: University Dental Resident Services, PC
Dear Mr. Foss,
I am writing to confirm that University Dental Resident Services, PC (UDRS), like its sister
organization, University Medical Resident Services, PC, is a qualifying employer for the Public Service
Loan Forgiveness Program (PSLFProgram). UDRSserves as the employer of record for dental
residents and fellows In accredited graduate dental education programs sponsored by the State
University of New York at Buffalo. Like UMRS, we believe that UDRSis a qualifying public service
organization eligible for the PSLFProgram because it is a private not for profit organization that,
while not tax exempt under Section 501(c)(3) of the Internal Revenue Code, provides public health
services.
Attached to this email is the UDRSCertificate Of Incorporation, as restated in 1992. To my
knowledge, this document has not been modified since its restatement and remains in full force and
effect. As we did with University Medical Resident Services, PC, I respectfully ask that you please
confirm in writing UDRS' eligibility as a qualifying employer under the PSLFProgram following your
review of the Certificate of Incorporation.
Thank you.
Sincerely,
Larry Ross
Lawrence M. Ross
Member
HUR Z &FINE,P.C. Hurwitz & Fine, P.C.

1300 Liberty Bu1ld1ng Buffalo NY 14202
ATTORNEYS AT LAW
tel (716) 849-8900 fax (716) 855-0874
website I vCard I map I email
I\UF"FA.LO ALBANY ALBION AM.HERST loNG !SUND NIAGARA fA.LlS PALM IIL\CH GARDENS lORONTO
From: Foss Ian

To; Lawrence
M. Ross
Cc: cmaloney@buffalo
ed11
Bee: l(b)(5) I Fedloan PSLF
Subject: RE: University Medical Resident Services. PC
Date: Wednesday, October 01, 2014 10:51 :00 AM
Hello Mr Ross,
We have reviewed the documentation that you provided and agree that University Medical Resident
Service, PC, 1sa qualifying employer for Lhe PSLFprogram because il 1sa nol-for-profil orgar11,:al1on
that, while not tax-exempt undn Section 501 (c)(3) of the Internal Revenue Code, provides puhl1c
health services
The official process by which Lhe Deparlmenl acknowledges Lhal an employer is a qual1fyir1g
organization for the PSLFprogram is through the suhm iss1on of the Employment Cnt1fication for
Public Service Loan Forgiveness, available here. I recommend that you have employees of the
organization submit this form In Section 3 of the form, take care to select box "c" in Item 3, and to
Lher1indicale lhal UMRS provides "public health" services.
l(ind regards,
Ian FO':,':,
From: Lawrence M. Ross [mailto:[email protected]]

Sent: Friday, September 19, 2014 10:09 AM
To: Foss, Ian
Subject: University Medical Resident Services, PC
Dear Mr. Foss,

Thank you for taking the time yesterday to speak to me. As we discussed, I believe that University
Medical Resident Services, PC (UMRS) is a qualifying public service organization under 34 CFR
68S.219 by virtue of the fact that the organizational documents for UMRS demonstrate that it is a
private not for profit organization that provides a public service. Attached to this email is the UMRS
Certificate of Incorporation, as restated in 1992. To my knowledge, the document has not been
modified since this restatement and remains in full force and effect.
1
This document should confirm UMRS eligibility as a qualifying employer under the Public Service
Loan Forgiveness Program. Yesterday, you made reference to the corporate by-laws. Should you
need to see the by-laws as well, I will retrieve the corporate minute book and forward them to you.
Hopefully this is not necessary.
After your review of the certificate of incorporation, I ask that you kindly confirm in writing UMRS'
eligibility as a qualifying employer under the Program. Thanking you in advance, I remain,
Respectfully yours,
Larry Ross
Lawrence M. Ross
Member
Hurwitz & Fine, PC.
HUR Z &FINE,P.C. 1300 LibertyBu1ld1ngB11ffaloNY]4202

tel (716) 849-8900
ATTORNEYS AT LAW begi11_of_the_skype_h1ghl1ght111g fax (716) 855-
0874
website I vCard I map I email
I\UF"FA.LO ALBANY ALBION AM.HERST loNG !SUND NIAGARA fAUS PALM IIL\CH GARDENS lORONTO
Call
Send SMS
Call
Send SMS
Add to Skype
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) IEo..s..w.a..o.;
Battle Cynthia: ,Johnson Debbe
Subject: Re: Upper Sioux Community dba Prairies Edge Casino Resort
Date: Friday, August 08. 2014 11 :25:30 AM
HI Diane,
The documentation you sent me indicated that this organization received a Federal contract.
This reminded me to check whether It was an 8(a) firm (under the Small Business Adm1nistrat1on's
parlance), and, if so, whether It could ever be considered qualifying 1fIt was. SBA regulations at 13 CFR
124.109(c)(2) says that the organization that is owned by a tribe (i.e., by the trial government), must be
considered legally separate from the tribe, itself, must be run on a for-profit basis, and must waive
sovereign immunity. So, any tribal 8(a) organIzatIon would not be considered tribal government. This would
make it s1m1larto other organizations that we have said are not "tribal government". This organization Is not
an 8(a) organization (see here). So, it's not disqualified on that basis.
Given the casino's website, which indicates that It Is owned and operated by the tribe, and given no other
evidence 1nd1catingthat It Is separately organized from the tribe, I agree that It Is tribal governmental, and,
thus, qualifies.
On 7/14/14, 14:50, "Fed Loan PSLF"<FedLoanPSLFCcilpheaa

org> wrote:
Hi Ian, Can you please review this one? Based on what we found, we think
they are a part of the tribal government, which is what they certified.
(See attached file: Upper Sioux Community dba Prairie's Edge Casino
Resort.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax-(717) 720-3911
[email protected]
yo,
The sender of this message will fully cooperate In the civil and criminal prosecution of any individual
engaging
From: ~
To; !(b)(5)
Subject: RE: URS Energy and Construction Inc - Retraction
Date: Friday, January 06. 2017 4:35:36 PM
(b)(6)
From: l(b)(5J I
To: Foss, Ian
(b)(6)
From: Foss, Ian

To: l(b)(5J I
Subject: RE: URS Energy and Construction Inc- Retraction
From: Foss, Ian

To: [{bl(51 I
(b)(6)
From: l(b)(5J I
To: Foss, Ian
Subject: Fw: URS Energy and Construction Inc - Retraction
Hi Ian,
Below is retraction that was approved from 2008 - 2015 for URS Energy and Construction.
From what I can tell, URSworks as a contractor to the government. I'll forward the documents
for our Monday meeting.
I also did a search on the certifying official and although the individual, David Frye, has a
government email one of the sites I came across has him listed at a contractor for URS. I
sincerely hope that the borrower has not just been letting his coworker certify these forms
over the years.
Thanks,
Taneka
From: 1(b_l(_5_1
0 --~
Sent: Friday, January 6 2017 2:02 PM
1
To: Fedloan PSLF

Cc: l(b)(5J
Subject: Re URSEnergy and Construction Inc - Retraction
Hi Kim,
In the attachment you included a PDF of an organization's Schedule R showing that they do
not control URS Energy and Construction but I was unable to see what organization the Form
990 was for? Do you know?
Thanks,
Taneka

To:!(bl(51 I
Subject: URS Energy and Construction Inc - Retraction
Hi Tanekal The employer, URS Energy and Construction, Inc, was recently escalated to us for review. On
the ECF, the employer certified as governmental, 501 (c)(3) and private not-for-profit performing multiple
public services (Emergency management, public safety and public health). One thing to note is that the
certifying official appears to be from the CDC, as the form was certified with an email of [email protected].
In performing a search of the borrower, we found that the borrower is directly employed by URS and not
the CDC. While this organization has changed names over the years through mergers, etc, they
organization itself is for-profit.
This particular borrower has submitted ECFs previously, and these were approved in error by the
Business Unit. Currently he is showing approved from 1/1 /08 to 11/19/15. This is the only impacted
borrower.
I have attached all ECFs we have received and the research we have performed. Please advise on the
retraction. Password to follow. Thanks!
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code PHEAA

To; Ninemire Sandra
Cc: Sipple-Asher Bessie;~; "[email protected]";l(b~)~(5~)-~
0
Subject: Re: US Air Force
Date: Monday, February 06, 201210:42:33 AM
Thank~ everyone. I would like to discuss thi~ further when we meet.

I'm
concerned we're going to get a lot of the~e. for example. the
Cleveland
Clinic checked private non-profit when they are a
501(c)(3J.
Until we meet. we'll contact the employeVi that checked the

incorrect box.
We'll aho keep copies of the~e ~owe can go through them
together.
Diane Freundel
Compliance Service~
(717)720-3267
fax-(717)
720-3911
[email protected]
1------------>
I From: I
1------------>
>---------------------------------------------------------------------------
-------------------------------------------------------------1
l"l\"inemire.
Sandra" <[email protected]>
I
>---------------------------------------------------------------------------
-------------------------------------------------------------1
1------------
>
I To:
1------------>
>-----------------------------------------------
-------------------------------------------------------------1
l"Sipple-Asher, Bessie" <[email protected]>.

0b)0(5°)---,
"'[email protected]:'" <[email protected]>. '1(
I
~,(b~)(~5)-----~
>-----------------------------------------------
-------------------------------------------------------------1
1------------
>
I Cc:
1------------>
>---------------------------------------------------------------------------
-------------------------------------------------------------1
l"Fms,
Jan" <[email protected]>, "'kmyer,@pheaa.org'" <[email protected]>
>---------------------------------------------------------------------------
-------------------------------------------------------------1
1------------
>
I Date:
1------------>
>---------------------------------------------------------------------------
-------------------------------------------------------------1
102/06/20 12
09:24 AM
I
>---------------------------------------------------------------------------
-------------------------------------------------------------1
1------------
>
I Subject:
1------------>
>---------------------------------------------------------------------------
-------------------------------------------------------------1
IRe: CS Air
Force
>---------------------------------------------------------------------------
-------------------------------------------------------------1
Good
~olution Be~~ie.
----- Original Message-----

From: Sipple-A~her.
Bessie
To: Ninemire. Sandra: 'dfreunde@ae~succe~s.org'
<dfreunde@aes ~ucces~.org>:
!(b)(5) !
Cc: Foss, Jan: '[email protected]'
<[email protected]>
Sent: Mon Feb 06 08:09:49 2012
Subject: RE: US Air
Force
Hi Diane,
I think in such ca,es we should contact the certifying

official. Thi,
,erves two purposes:
I) to confirm that the organi7ation i,

indeed qualifying and in the correct
category (in thi, case, government)
2)
it notifies the official which category to check for future ECFs.
Once we
get confirmation from the employer the correction should he noted
and
approved.
Thank,,
Bessie
Direct Loans
Divi,ion
Federal Student Aid
Tel:
202-177-3145
[email protected]
From:
Ninemire, Sandra
To:
'[email protected]'; .l(b_l_(5_1
__ ~
Cc: Sipple-Asher, Be,,ie: Foss,
Jan; 'kmyer<;@pheaa.org'
Subject: Re: US Air Force
I think we accept it. It

,ounds like the employer might have been a little
confu,ed how to complete
the form. How do other<;feel?
Is there anything we can do to en,ure they

under'itand how to complete the
form? ls there a Q&A out of thi,
one'.'
----- Original Message-----

<dfreunde@aes,ucces,.org>
To: l(b)(5) I
Cc: Sipple-Asher. Bes,ie: Foss,

Jan: [email protected] <[email protected]>:
l(b)(5) Ninemire, I
Sandra
Sent: Mon Feh0608:02:I I 2012
Subject: RE: US Air Force
Hi Ian,
We didn't talk ahout accepting/rejecting ECFs hased on the
incorrect hox
heing checked. Provided the employer is qualifying, I think
we should
accept it. Thoughts'! Thanks.
Diane Freundel
Compliance Services
(717)
720-1267
fax- (717) 720-3911
[email protected]
1------------>
I From.
1------------>
>---------------------------------------------------------
---1
lpuhlic,ervice
l(b)(5)
>-------------------------------------------------
-----------1
1------------>
I To:
I
1------------>
>---------------------------------------------------------
---1
l"Diane Freundel" <dfreunde@ae,,ucce,,.org>,

r)(5)
b)(5)
I
>-----------------------------------
-------------------------1
1------------>
I Cc:
I
1------------>
>---------------------------------------------------------
---1
l"[email protected]" <[email protected]>, "Foss, Ian"

<[email protected]>,
"Ninemire, Sandra" <[email protected]>,
"Sipple-Asher. I
IBessie"
<Be,, ie Ko.Si pp le A, [email protected]>
I
>------------------------------------------
------------------1
1------------>
I Date:
I
1------------>
>---------------------------------------------------------
---1
1021061201208:55
AM
I
>---------------------------------------------------------------------
-------------------------------------------------------------------1
1-----
------->
I Subject:
I
1------------>
>---------------------------------------------------------
---1
IRE: US Air
Force
>------------------------------------------------------------------
----------------------------------------------------------------------1
Diane,
This actually is the US Air Force. The Ell\" i, the one used for
the Air
Force (many Google searche, all provide the same one, which matches
the
form). I think the borrower filled out the form incorrectly, and
checked
the last category hecause he saw "military services".
I don't
recall whether the protocols we developed indicated that you should
reject
or accept the ECF in ,uch an instance.
Jan
> -----Original Mes,age-----

>
From: Diane Freundel [mailto:dfreunde(a'\aessucce,s.or~]
> Sent: Saturday,
February 04, 2012 7:Jfi PM
> To: l(b)(5) I
>
Subject: US Air Force
>
>
> We know this i, a qualifying employer -
government. However, the
certifying
> official checked "private
non-profit", and "military ,ervice".
> After thinking ahout thi,, we're
unsure what a private non-profit
organization
> providing military ,ervice
would he. I found the following website.
> Are
these
> the types of
organizations that would fall under this
> category'.' Pa'i'iword to follow.
Thank,!
>
> http:1/\vww.privaterrnlitarx.or~I
>
> (See attached file:
Gaither. USAF.zip J
>
> Diane Freundel
> (717)
720-1267
> fax-(717) 720-3911
> [email protected]
>
>

for
message m error
> please delete or destroy this me'i'iage and/or
attachments.
>
civil and
> criminal prosecution of any individual engaging in the
unauthorized
> use of this me,sage.
>
>
This me'i'iage contaim privileged and

the ahove addressees only. If you
receive thi'i rne,sage in error plea,e
delete or destroy thi'i message and/or
attachment,.
The sender of thi'i rne'i'iage will fully cooperate in the civil

and criminal
pro,ecution of any individual engaging in the unauthorized u,e
of
this
message.
Thi, rne'i'iage contaim privileged and confidential

information intended for the above addres,ee, only. If you
receive thi'i
message in error plea,e delete or de,troy thi'i message and/or attachment,.
The sender of this me'i'iage will fully cooperate in the civil and criminal
pro,ecution of any individual engaging

in the unauthorized me of this
message.
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5)
Subject: Re: Valley View Casino and Hotel
Date: Thursday, November 14, 201311 :30:49 AM
Hi Diane.
Jim escalating this to OGC now that we have one that is (to me at least)
decidedly governmental in character. Skyview wa~n1t of that caliber. and
OGC likes to keep it~ decisions narrow.
Jan
On 10/18/13. 20: 12, "Fed Loan PSLF" <[email protected]> wrote:
>
>Hi Jan, We're glad you're back!! We have two Tribal ca~inos to run by
>you. Thi~ i~ the fir~t one.
>
>In addition to the folder for Valley View, attached i~ the guidance you
>provided on Sky Dancer Hotel and Casino. Based on your re~earch on Sky
>Dancer. you indicated that you thought only two of the five common
>structures of tribal businesse~ would qualify - unincorporated and tribal
>subdivi~ion~-
>
>From what I could find. Valley View i~ managed by the San Pasqual Ca~ino
>Development Group. Inc. which is a tribally-chartered corporation. so I
>don't think they qualify. The official certified a~ government.(an
>entity
>of the San Pa~qual Band of Mission Indians).
>
>
>(See al!ache<l file: Valley View Casino & Hotel.Lip)(See
>attached file: RE_ Skydancer Hotel and Casino Tribal .p<ll)
>
>Diane Freundel
>(717) 720-3267
>fax-(717) 720-3911
>[email protected]
>receive this me~sage in error please delete or <le~troy this me~~age
>and/or attachmenb.
>
>The sen<ler of this me~sage will fully cooperate in the civil and criminal
>pro~ecution of any indivi<lual engaging
>in the unauthoriLe<l u~e of this message.
From: !(b)(5)
To; FedLoan PSLF
Cc: Bl&...!.a!:l.;
Battle Cynthia:,Johnson Debbe:cl(b
0 )0(5
0)_~
Subject: Re: Valley View Casino and Hotel
Date: Monday, December 09. 2013 2:03:20 PM
Hi Diane.
We agree that thi~ qualifie~ a~ '·government".
Jan
On 11/14/13. 1 l:30,cl(b~)~(5~)
--~lcl(b~)(~5~) -----~I wrote:
>Hi Diane.
>
>Jim e~calating thi~ to OGC now that we have one that i~ (to me at lea~t)
>decidedly governmental in character. Skyview wasn 1t of that caliber, and
>OGC like~ to keep its deci~ion~ na1TOw.
>
>Ian
>
>On 10/18/13, 20: 12. "FedLoan PSLF' <[email protected]> wrote:
>
»
>>Hi Ian. We're glad you're back!! We have two Tribal ca~ino~ to run by
>>you. This is the first one.
»
>>In addition to the folder for Valley View. attached is the guidance you
>>provided on Sky Dancer Hotel and Ca~ino. Based on your research on Sky
>>Dancer, you indicated that you thought only two of the five common
>>mucture~ of tribal bu~ine~ses would qualify - unincorporated and
>>tribal
>>sub<livisiun~.
»
>>Frum what I could fin<l.Valley View i~ managed by the San Pas4ual Ca~inu
>>Development Group. Inc, which is a tribally-chartered curpuration. so I
>>don't think they 4ualify. The ufficial certified as governmenl.(an
>>entity
>>of the San Pasqual Ban<l of Mission Indians).
»
>>Password to follow. Thanks!
»
>>(See a\lached file: Valley View Ca~inu & Hotel.zip) (See
>>attached file: RE_ Sky<lancer Hutel and Casino Tribal .pdf)
»
>>Diane Freundel
»(717) 720-3267
»fax- (717) 720-3911
>>[email protected]
>>This message contains privileged and confidential inforrnatiun inten<led
>>for the above a<l<lresseesonly. If yuu
>>receive this message in error please <lelete or destroy this message
»
>>The sender of thi, me,sage will fully cooperate in the civil and criminal
>>pro,ecution of any individual engaging
>>in the unauthori7ed u,e of this message.
>
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) I Eo..s..w.a..o.;
Battle Cynthia: .Johnson Deb be
Subject: Re: ValleyNet and ECF Holding
Date: Monday, January 27. 2014 1 :48:19 PM
Hi Diane.
I think it was appropriate to approve the ECF Holding ECF becau~e the
3controller 2 i~ a representative that one could rea~onably expect to be
able to speak authoritatively to the borrower 1~ employment (they
frequently handle payroll and the like. particularly in ~maller
organizations).
A CIO, however, is not a representative that would u~ually be considered

an 3 authorized otficial2. ~o I think it1~ entirely appropriate to
follow-up again. and ask for evidence of the name change (I can't find
anything more than you can) well as que~tion whether the individual i~ an
authorized official for the purposes of PSLF. The former question would
go to whether the organization qualifie~ beyond the revocation date of it~
501(c)(3J statu~- The latter que~tion would go to whether we 1d need to go
an 3 alternative 2 route and use W-2s to confirm employment.
Jan
>
(b)(6)
I
>
>We receive<l an ECF from ECF Holding LLC, certified as a government entity
>by John Van V ugh!, Controller. Employment dates were 11/ Ii 13 tu l l /12/ 13
>(<lateof certification). We determined that ECFiber is government and ECF
>Holding LLC is a wholly owned subsidiary of ECFiber. We approved this
>employer as government.
>
>We then reviewed an ECF for ValleyNet Inc. certified as a 501(c)(3) by
>John
>Van Vught. CIO. certified on 11/8/13 for employment <latesuf6/l/l l to
> 10/31/13. Each employer has a different EIN. We were having trouble
>categuriLing ValleyNet when Kim recognized a relationship with ECF
(b)(6)
>
>The VT corporations website provides access to filed <lucuments and we ~aw
>no indication of a name change. One item on ECFiber's website says they
>work in partnership with Valley Net. a non-profit. We don't believe they
>are the same company.

>
> We confirmed that Valley Net lost 50 I (c )(3 J statu, effective 2115113, so we
>could approve employment from fi/1111 to 2/14111, ifwe can verify that the
>harrower worked there. We don't helieve they provide a qualifying
>service,
>so his employment from 2/15/13 to I 0131113wouldn't qualify.
>
>A google search for John Van Vught does tie him to ECFiher and hi,
>Linkedln
>profile indicate, he's an Independent Accounting Professional.
>
>Our concern is whether John Van Vught can certify the ValleyNet
>employment.
>We wouldn't have questioned it had we not reviewed hoth of these ECF, ,o
>close together.
(b)(6)
>ro11ow. man1ss.
>
>(See attached file: ECF Holding. LLC.zip) (See attached
>file: Valleyl\"et Inc.zip)
>
>Diane Freundel
>(717) 720-3267
>fax- (717) 720-3911
>[email protected]
>This mes,age contain, privileged and confidential information intended
>receive this mes,age in error please delete or destroy this message
>
>The ,ender of this mes,age will fully cooperate in the civil and criminal
>in the unauthorized use of thi'i message.
From: !(b)(5)
Cc: ~: Sipple-Asher Bessie: Ninemire Sandra
Subject: RE: VHS/Valley Health System
Date: Friday, February 17, 20121:01:19 PM
Attachments: Valley Baptist Medical Center - Harl1nqen.pdf
This is a for-profit entity. See attached.
Found it here:
l1ttp i/www d~h~~rate-tx.u~/1.ics;n~s:e-Re~i~trant-Permitks:
a~px.
>
[mailto:dfreunde@aewJCce~~-or~ I On Behalf Of
> FedLoan PSLF
> Sent:
Tuesday, February 07, 2012 8:37 PM
> To: l(b)(5) I
> Subject: VHS/Valley
Health System
>
>
> For tracking purposes, we're going to try u~ing this
mailbox again.
>
> When doing a search for this employer, we found that
their name i~ actually
> VBMC- Valley Baptist Medical Center and they are
part of the Valley Baptist
> Health Sy~tem and the larger Valley Health Care
Network.
>
> We could not find anything under the Texas li~ting for the Ell\"
provided and a
> search for Valley Baptist Medical Center came up. but the
result~ ~eemed to
> be inconclusive.
>
>
l1ttr~ i/ourcpa cra-~tare tx u~icnailnds;x.html
>
> In doing a ~earch for
Valley Health Care Network (included in attachment),
> the search indicated
they are an exempt agency. Furthermore. their website
> indicates they are
not-for-profit .
>
> One key thing to note, the Valley Baptist Health
System's main web~ite page
> indicates that they are "a faith ba~ed regional
health system focu~ed on
> improving the lives of the people it ~erve~by
providing high quality health

> care and medical education throughout South
Texas guided hy the healing
> and teaching mini,try of Jesus Christ"
(included in attachment).
>
> The EIN on the form was not found in IRS Puh
78, hut a search of the name
> came up with 3 entitie, at the address on the
ECF:
> Valley Baptist Health Sy,tem - Ell\" 00-74-29743% Valley Baptist
Holdings - Ell\"
> 00-20-5394169 Valley Health Care Network - EIN
00-74-2729113
>
> ECF is also in attachment.
>
> Password to follow
>
>
(See attached file: David_ Valley Health.zip)
>
> Thanks
>
> Diane
Freundel
> (717) 720-3267
> fax- (717) 720-3911
>
[email protected]
>
>

> the above addre,,ee, only If you receive this
message in error plea,e
> delete or de,troy this me'i'iage and/or
attachment,.
>
> The ,ender of this message will fully cooperate in the
civil and criminal
> me'i'iage.
>
>
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) I:Battle Cynthia: ,Johnson Debbe
Subject: RE: Vietnam Veterans of America
Date: Monday, April 27. 2015 1 :12:13 PM
Hi Diane.
Jan and I aho ~ent the Vietnam Veteran~ of America to OGC for a final determination.
(b)(6)
I'll keep you updated on the re~ult.
Thank~,
Taneka
Sent: Friday. April 17. 2015 3:28 PM
To: l(b)(5) I
Subject: Vietnam Veteram of America
Hi Taneka. We'd like your input on thi~ one.
ECF i~ certified as private non-profit providing public interest law ~ervices and public service~ for individuah with
disabilitie~ and the elderly.
Organization is a 501 (c)( 19) and wa~ chartered by the US Congress.
They seem to primarily advocate on behalf of veterans.
According to his Linkedln profile. the borrower is an attorney at VVA.

We did find evidence that VVA founded Vietnam Veteram of America Legal Service~ (VVALS) - ~ee page 2 of
"About VVA.pdf'. However. on page 1 of the same document it state~ that VY Ai~ funded without any contribution
from any branch of government. Ba~ed on thi~. we don't believe they qualify because 685.219(b) Definitiom,
Public Jntere~t Law refers to legal ~ervices provided by a public ~ervice organization funded in whole or in part by a
local, State. Federal or Tribal government.
Plea~e confirm. Pa~~word to follow. Thanks!
(See attached file: Vietnam Veteran~ of America.zip)
Diane Freundel
Compliance Service~
(717)720-3267
[email protected]
Thi~ me~~agecontaim privileged and confidential information intended for the above addre~~ee~only. Jfyou
The sender of thi~ rne~~age will fully cooperate in the civil and criminal prosecution of any individual engaging in
From: !(b)(5)
Cc: Bl&...!.a!:l.;
Ninemire Sandra: Sipple-Asher Bessie: ,Johnson Debbe
Subject: RE: Vinson Hall, LLC
Date: Monday, November 05, 2012 2:16:53 PM
Diane,
I can find the organization under its old EIN (52-0857863) and name (Vinson Hall Corporation) on-file
with the IRS in the business master file. The organization converted to an LLCfrom a corporation on
June 27, 2011.
So, as long as the conversion from the corporation to LLCdid not cause the organization to lose its
501(c)(3) status, it should continue to qualify. I agree with you that LLCscan be not-for-profit (see, in
addition to the VA code, this l..lnkto the Secretary of State's website} in Virginia, and Vinson Hall LLC
holds itself out as a not-for-profit organization on its website.
From what I can discern, the organization would not be obligated to update its name and EIN with
the IRS until it files its next Form 990. An organization must file its Form 990 by the 15th day of the
5th month after its fiscal year ends. Since its 2010 Form 990 was filed on November 15, 2011, I
would expect its 2011 Form 990 to be filed in a few weeks, and that's when the IRSshould pick up
the name/EIN change. That Is, if the IRSstill believes this is a 501(c}(3} organization. Because of all of
the requirements that the IRS has for treating LLCsas 501(c)(3) organizations-see here and here-
(specifically, that LLCsseeking 501{c){3) status require all members of the LLCto be other 501(c)(3)s
or government instrumentalities}, I'm not sure that we can approve this one on the organization's
word, alone. Especially because we do not know who the members of the LLCare. It might be best
to wait and see what happens with the IRS.
Lastly, I'd note that public charities like this organization are required to register with the State of
Virginia (see here). I could not find Vinson Hall in the state's database. However, I could find the
organization as being tax-exempt in Virginia under its old name (see~).
Ian
From Diane Freundel [mailto:[email protected]] On Behalf Of Fedloan PSLF
To: l(b)(5) I
Subject Vinson Hall, LLC
Hi Ian, We're having trouble with the attached. We found an
organization by the name of Vinson Hall Corporation that is/was a 501 {c){3); however, the EIN didn't
match what the employer provided on the
ECF.A call was made to the employer (documentation of discussion is
included in attachment). The certifying official said they changed their name/EIN around June 2011
and they are still a 501(c)(3). The phone rep asked for proof and the certifying official advised us to
check with the IRS or Guidestar. We can't confirm that the new organization is a 501
(c)(3). I did some research to determine if a non-profit can be
organized as an LLC in Virginia. The one thing I found {included in
attachment} seems to indicate they can.
Your assistance is appreciated. Password to follow. I got an error
message when I zipped/encrypted the file, but when I opened it, it seemed
to be OK. Let me know if you can open the documents and I'll
zip/encrypt again. Thanks!

(See attached file, Vinson Hall.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fa,- (717) 720-3911
[email protected]
From: !(b)(5)
To; FedLoan PSLF; publicservice
Cc: Bl&...!.a!:l.;
Subject: RE: VisionQuest
Date: Friday, April 13. 2012 9:38:41 AM
Diane,
It looks like this is a for-profit corporation.
The EIN ties back to the name VisionQuest National, Ltd (thanks, Westlaw). I first searched in the
Pennsylvania corporations database, because there's where the borrower is employed, and found
that the state of incorporation was Arizona, so I searched there and found that was a for-profit
corporation (see here).
The entity♦s website indicates that it provides services to the public that fill a vacuum left by the
government. I suspect that they are a government contractor (state or local), and therefore think
that they qualify as working ♦for the government♦ because that♦ s who their client is. As we
know, that ♦s not enough.
Ian
> PSLF
> Sent: Thursday, April 12, 2012 10:16 PM
> To: l(b)(5) I
> Subject: VisionQuest
>
>
> Hi, We have another difficult one. They checked box a. They are a
> "comprehensive national youth services organization." They started out as
> for profit, then became employee owned (see selected pages from history).
>
> The PA business filing for VisionQuest Nonprofit Corportion says they are
> nonprofit (Business Filing). There is also a PA business filing for V1sionQuest
> National, Ltd, dba TurnAround Products.
>
> There is an AZ Business filing for VisionQuest Nonprofit Corporation (same as
> PA). There is also an AZ Business filing for Vis1onQuest National, Ltd
> - for profit. When I googled the EIN, the only thing I came up with was
> the Visionquest National employee stock attachment which indicates the EIN
> is for VisionQuest National for profit.
>
> I think the employer is for profit and therefore does not qualify. As
> always, appreciate your thoughts. Password to follow. Thanks!
>
> (See attached file, Vis1onQuest.zip)
>
> Diane Freundel
> (717) 720-3267

> fax- (717) 720-3911
> [email protected]
>
> message.
From: !(b)(5)
To; FedLoanPSLF
Cc: ~: l(b)(5) INinemireSandra:Sipple-AsherBessie:,JohnsonDebbe
Subject: RE: Voyageur - Consortium
Date: Wednesday, January 23, 201310:11:10 AM
EIN for Leona Group LLC: 38-3311066. The registered address for the Detroit entry 1nWestlaw is:
8666 QUINCY ST, DETROIT,Ml 48204.
There is no record of the EIN on the ECFin Westlaw or anywhere else, which leads me to believe
that this EIN is for the charter school, itself.
I can add the following details about charter schools, generally, in Michigan:
•Charter schools are required to be organized as not-for-profit corporations under Michigan
law;
• Charters schools 1n Michigan are "government instrumentalities" for the purpose of IRC Section
115 (they are exempt from federal income tax),
•Charter schools 1n Michigan are government agencies;
•Charter school boards of directors and employees have government immunity;
•Charter schools have the power to issue municipal bonds (though liability attaches only to the
not-for-profit organization, not the chartering authority).
Information about the school, itself, may be obtained from the authorizer's website. Specifically, the
contract between the authorizer and the school (the charter, if you will) is available here, and is
incredibly detailed {over 200 pages). The contract provides a great deal of information about
11
"education service providers at the charter school (which would be the Leona Group for this
school), which specifically requires that the agreement between the school and the provider not
contain any provision that restricts the school from hiring its own staff. The contract also requires
that any agreement between the school and the provider stipulate which personnel will be
employees of the provider and which will be employees of the school. From what I can discern, all
positions at the school {as inferred from the position description in the contract) are fulfilled by the
Leona Group.
In sum, I still don't know for sure who "employs" the borrower. I'd like to think that, because the EIN
for the Leona Group wasn't on the ECF,that she is employed by the school. However, her profile
suggests that she is employed by the Leona Group. If the borrower is employed by the school,
clearly, the borrower qualifies {probably in the government category). If the borrower is employed
by the Leona Group, then the borrower doesn't qualify. In light of what I've detailed above, I would
call the certifying official, and ask whether the borrower is an employee "was hired and paid by" the
school or the "educational service provider", the Leona Group. The certifying official should know
the difference between the two.
To: l(b)(5) I
Subject Voyageur - Consortium
Hi Ian, This is a confusing charter school case.
It started as Voyageur Academy (K-5) which is non-profit as indicated in their business filing. In 2000
they expanded to include 6 in the Academy
and 7-12 in the Consortium College Prep High School. They are managed by
the Leona Group (for-profit).

On the ECF,the name is Voyageur - Consortium. They did not check a main
box (a, b, c), but did check public education under c. Based on our most
recent discussions about charter schools, I was going to approve this one.
When we googled the borrower's name, we found her profile on the school's website (oddly, if you
start at the school's website and try to access her profile, and 3 other employees, you get an error
message.) Her profile states that she has been employed with the Leona Group since 1998 - leading
me to believe she is not employed by the non-profit school. We can't tie
the EIN to any entity. Can you find anything on Westlaw? If not, do
you agree that we should deny?
(See attached file Voyageur - Consortium.zip}
Diane Freundel
Compliance Services
(717) 720-3267
fax- (717) 720-3911
[email protected]
This message contains privileged and confidential 1nformat1on intended for the above addressees
From: !(b)(5)
To; FedLoanPSLF
Cc: l(b)(5) I
Battle Cynthia:Eo.ll...J.a.o.;
Odom Christian
Subject: Re: VT Consultants OBA Nine East Network
Date: Tuesday, June 13, 201712:30:53 PM
Hi Kim,
FSAagrees that VT Consoultants OBA Nine East Network should be remain denied for PSLF
purposes since they are for-profit.
Thanks,
Taneka

To: l(b)(5J I
Subject: VT Consultants OBA Nine East Network
Hi Taneka! We had previously denied this employer as they are for-profit. The employer has now
submitted a letter requesting reconsideration. She indicated they are state supported and provide public
and school-based services to children with hearing loss and language delays. Although they are
supported by the state, it still does not negate the fact that they are for-profit; therefore, we believe they
should still be denied. However, since it is a dispute, I am escalating for review.
Kimberly A Myers
Compliance Services
[email protected]
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; FedLoan PSLF; publicservice
Cc: Bl&...!.a!:l.;
Subject: RE: Waialae Elementary Public Charter School
Date: Monday, July 30, 2012 5:09:53 PM
Diane,
I apologize for the delay.
I think that charter schools in Hawaii are probably governmental as well. Though Hawaii's state law is
not as clear on this point as Massachusetts' law, it seems that Hawaii Revised Statute Section 3028-
9(d), which says" Notwithstanding any law to the contrary, as public schools and entities of the
State, neither a charter school nor the office may bring suit against any other entity or agency of the
State" supports this conclusion.
So, as long as we can determine that the borrower works for the charter school, and not some third-
party with whom the charter school has contracted for services, including teaching services, then the
employment will qualify under the government category.
My searching turns up nothing to suggest that the borrower is employed by anything other than the
charter school, itself.
And, as to the charter school overhaul in Hawaii, I think it passed, with an effective date of the date
of enactment. See here.
Ian
To: l(b)(5J I
Subject Waialae Elementary Public Charter School
H1Ian, Here is another charter school that appears to manage itself. See
hcsao.pdf. Also, they checked government on ECF.
Research indicates that there is pending legislation in Hawaii that may overhaul their charter schools
(Mar 2012} - some expressed concern that there was not an explicit requiring a charter school to be
non-profit In
the new legislation. See Hawaii charter school overhaul article.
The Waialae School Foundation {different EIN) is a 501(c)(3).
At least as of April 2004 Hawaii prohibited for-profit organizations from operating or managing a
charter school. See charter school laws and partnerships article.
This one seems like it should be government. Your thoughts? Password
to follow. Thanks!
(See attached file Wai'alae Elementary Public Charter.zip}
Diane Freundel
Compliance Services
(717} 720-3267
fax-(717} 720-3911
dfreunde@pheaa org
From: !(b)(5)
Cc: Bl&...!.a!:l.;
Ninemire Sandra: Sipple-Asher Bessie
Subject: RE: Walls Universal Home Health and Hospices
Date: Tuesday, February 21 2012 4:55:39 PM
I agree thi~ i~ for-profit. I would aho note that it i~ not exempt form
franchise tax in Texa~, \Vhich i~ a common bminess tax from \Vhich
non-profit~ are frequently
exempt.
l1trr~·.//ourcpacra-~tare rxu~icnai~s;rvletlcpaapp cna CoaGetTp'.'Pv-

tpid&Search_Nm=W al1~0/t,20&Button=~earch&Search_lD= 175274231OI
>
[mailto:dfreunde@aew1cce~~-or~l On Behalf Of
> FedLoan PSLF
> Sent: Friday,
> To: l(b)(5) I
> Subject: Walls Univer~al
Home Health and Ho~pice~
>
>
> Good afternoon, Plea~e ~ee the attached.
We believe this entity\ other
> regi~tered legal busine~~ name i~ UniveVial
Health Service~ ( ~ee HIPAA
> Space doc). Ba~ed on the other attachments,
\Vecannot conclu~ively
> determine that it is a non-profit. We believe it
is more likely a
> for-profit and would recommend denying. Plea~e confirm.
Pa~W>'Ord to
> follow. Thanks!
>
> (See attached file: Wynn_Walls t..:niveral
Home Health and Ho~pice~.zip)
>
> Diane Freundel
>
(717) 720-3267
> fax-(717) 720-3911
> [email protected]
>
>
> This me~~age contain~ privileged and cunfidential

> the above addressees only. If you receive !hi~

attachments.
>
civil and criminal
> message.
>
>
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) IBattle Cynthia:,JohnsonDebbe
Subject: RE: Warm Springs Geo V1s1ons
Date: Friday, July 10. 2015 12:40:25 PM
H1Diane,
We agree that Warm Springs Geo Visions does not qualify. They are legally separate and would not
be considered tribal government. Further, the language in Article II, Section(s) 2 and 3 of the Third
Amended Tribal Charter of Warm Springs Geo Visions Enterprise is just standard language (pps. 11-
12) that tribal charters are required to have in order to maintain their status as 8(a) firms under the
SBA.
Thanks,
Taneka
To: l(b)(5) I
Subject. Warm Springs Geo Visions
Hi Taneka, Although this employer is owned and operated by a tribe, we previously denied it without
escalating to you. We determined it is an 8
(a) firm under the SBA. In previous guidance from Ian on Upper Sioux Community dba Prairies Edge
Casino Resort, he advised that 8(a) entities are for profit by definition and must be considered legally
separate from the tribe.
This borrower is disputing our denial of Warm Springs Geo Vision and submitted additional
documentation {see attached containing Resolution No.
10,594 and Third Amended Tribal Charter). The Resolution No. 10,594
clarifies that Geo Visions is an 8(a) firm under the SBA and the amended charter establishes that Geo
Visions can sue and be sued. In addition, the amended articles continue on to state that Geo Visions
is without power to waive the sovereign immunity of the Confederated Tribes beyond a waiver set
forth 1nthe charter. We believe they should remain denied. Please let us know if you agree. Thanks!
(See attached file· Supplemental documentation.pdf)
Diane Freundel
Compliance Services
(717) 720-3267
[email protected]
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) I~; ,Johnson Debbe: Sipple-Asher Bessie: Ninemire Sandra
Subject: Re: WateReuse Association
Hi Diane.
For the ~ame reason a~ the a~~ociation of ~chool boards (Kan~a~J.\Ve do

not think that thi~ organization qualifies for PSLF became it does not
provide a qualifying service. The organization's primary purpo~e is is~ue
advocacy, and the "education" that it provides is not "public education".
It'~ not that it is not providing education to the public; rather, it's
that the education i~ provide~ is not structured and pedagogical enough to
qualify. We're really looking for something like a primary, secondary. or
po~tsecondary ~chooL or something ~imilar, in the public education
category.
Jan
On 12/24/12 15:51 , "FedLoan PSLF" <[email protected]> wrote:
>
>Hi Jan, I'm not ~ure about thi~ one. Kim thinks it qualifies becau~e it
>provides public education [it'~ a 501(c)(6)]. However_ I don't think they
>provide "public" education. Although their mission i~ to "advance the
>beneficial and efficient u~es of high-quality. locally produced.
>sustainable water ~ource~for the better environment through advocacy,
>education and outreach, research, and membership", because they are a
>trade
>association that ~erve~ it'~ members, I'm not ~ure they provide public
>education. Please take a look at the attached. We appreciate your
>assi~tance! Pa~~word to follow. Thanks.
>
>
>(See al!ache<l file: WateReuse A~suciatiun.zip)
>
>Diane Freundel
>Curnpliance Service~
>(717) 720-3267
>fax-(717) 720-3911
>[email protected]
>This me~sage contains privileged and cunfidential information intended
>receive this me~sage in en-or please delete ur <le~troythis me~~age
>and/or attachmenb.
>
>The sen<leruf this me~sage will fully cooperate in the civil and criminal
>pro~ecution uf any indivi<lual engaging
>in the unauthoriLe<lu~e of this message.
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) I~; Ninemire Sandra: ,Johnson Debbe; Battle Cynthia
Subject: Re: Wayne County Mediation Tribual Assoc1at1on
Date: Thursday, August 29, 2013 4:05:08 PM
Hi Diane.
Sorry for the delay on this one. The organization qualities as a

qua~i-governrnental organization.
Jan
>
>Hi Jan, Another public interest law service~ question.
>
>Employer i~ a 50l(c)(4). According to their Form 990, their
>mi~sion/activities is the mediation of civil law~uits as an aid to the
>court~- I aho found information in a document titled The Wayne County
>Mediation Program in the Ea~tern Di~trict of Michigan that indicates it's
>an independent nonprofit organization created by the circuit court to
>provide a pool of mediator~ for it~ ca~e~ and admini~trative support
>necessary to operate hearing~.
>
>I think they provide a qualifying ~ervice, but Kirn doe~n't think they do.
>We appreciate your help! Password to follow.
>
>(See attached file: Wayne County Mediation Tribual Assoc.zip)
>
>Diane Freundel
>(717) 720-3267
>fax-(717) 720-3911
>[email protected]
>receive this me~sage in error please delete or de~troy this me~~age
>and/or attachmenb.
>
>pro~ecutiun of any individual engaging
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b0 )0(50)_~
Battle Cynthia: Tiongquico Rene: 0
Subject: Re: Wind Creek Hosp1tal1ty
Hi Kim,
Rene and the policy group also revised this escalation and we agree that this Wind Creek can
be approved and do not need to provide additional documentation that they are
governmental.
Thanks,
Taneka
From: Ll(b_l(_51
__ ~
Sent: Monday, August 8, 2016 3:42:05 PM
To: Fedloan PSLF
Cc: l(b)(5J IBattle, Cynthia; Tiongquico, Rene
Subject: RE, Wind Creek Hospitality
Hi Kim,
My apologies for the delay. In researching, Rene came across the Poarch Creek Indians Tribal
Gaming commbsion sile rorms. The sile has vendor applications for publicly traded and non-
publicly traded companies. Additionally, we came across employment information that would
suggest that the casino offers 401k plans to employees.
After reviewing this employer, Rene and I believe that PHEAA will need to go back to the employer
for definitive information to prove that the casino is governmental.
Thanks,
Taneka
From: Kimberly /\ Myers [mailto:[email protected]] On Behalf Of FedLuan PSLF
Sent: Thursday, July 07. 2016 8:56 i\M
To: l(b)(5) I
Subject: Wind Creek Hospitality
Hi Taneka! We have another tribal entity/ca~inu fur you.
PC! Gaming Authority d/b/a Wind Creek Ho~pitality is an authority of the Poarch Band of Creek Indians. Thi~
entity shows no indication of being an 8(a) firm. In addition, their privacy policy on the website indicate, that it i~
wholly owned by the tribe.
We located ,omc court cases regarding thi, entity (we only saved one a, they all appeared similar). The court
granted the motion to dismi~~ based on sovereign immunity.
Given no other evidence indicating it i~ ~cparatdy organized from the tribe, we would lean toward approving thi,
one.
Password to follow. Thank,!
Kimberly A Myers
Compliance Service~
kmn::r~@phs:aa.nri;
(717) 720-2630
and/or attachments.
Code:PHEAA
From: !(b)(5)
To; "Diane Freundel"'
Cc: l(b)(5) I FedLoanPSLF;Battle Cynthia: ,Johnson Debbe; ~
Subject: RE: Wind River Casino
Date: Monday, March 09. 2015 9:25:25 AM
H1Diane,
I consulted with Ian regarding the Wind River Casino. Would you be able to go back to the employer
and ask;
• if casino employees are considered to be employed through the tribal agency, and
• if the casino has sovereign immunity under the tribe?
If the employer can provide us with additional documentation to show that the casino is not
separately organized from the Northern Arapaho Tribe that would helpful in allowing us to make an
informed decision.
Ian- please chime in if I am missing something here.
Thanks,
Taneka
Sent: Thursday, February 05, 2015 11:03 AM
To: l(b)(5) I
Subject. Wind River Casino
Hi Ian, We'd like your input on this one.
1. ECFis certified as government.
2. Website indicates the casino is owned and operated by the tribe.
2. Business filing for casino shows a filing type as "trademark"
3. W-2 shows employer's name as Northern Arapahoe Enterprise 2 - no business filing found and we
couldn't find anything else about this entity.
4. Northern Arapahoe Code, Title 3. Gaming - we marked some things on pages
5-6, 7, and 11-12. Page 7 indicates the tribe established the Northern
Arapaho Gaming Agency that is responsible for the operation of the tribe's
casinos. We couldn't find anything indicating that the casino is
separately organized from the tribe. We also didn't find it listed on the SBA website as an 8(a) entity.
We think they qualify. Thanks for your help! Password to follow.
(See attached file, Wind River Casino.zip)
Diane Freundel
Compliance Services
(717) 720-3267
[email protected]
From: !(b)(5)
To; FedLoanPSLF
Cc: ~: l(b)(5) INinemireSandra:Sipple-AsherBessie:,JohnsonDebbe
Subject: Re: Wonderland Nursery School
Date: Wednesday, October 17, 2012 12:45:50 PM
HI Diane,
I do not think that this one qualifies. Though they hold themselves out as a not-for-profit, it's pretty clear
that they're not a 501(c)(3) organization. So, they must provide a qualifying service.
The only place that they would fit is "early childhood education" However, the parenthetically following It
on the form, in the regulations, and in the law, is all-inclusive. So, to qualify under that category, the
organization must be (1) licensed or regulated child care, (2) Head Start, or (3) State-funded pre-
k1ndergarden
My understanding of New York law is that to be state-funded pre-kindergarted, you have to opt-into the
"voluntary registration" framework, which this organization has not done. In addition, though New York
does regulate/license child care facil1t1es,I cannot f.Lo.d.
that Wonderland is licensed, and, given the
requirements of Section 390 of the New York Social Services Law, I think Is exempted from the l1censure
requirement because it does not meet the definition of a "child care day center"; specifically, it provides
care for less than three hours per day (see the contract between the school and parents here). So, that
means that it does not need a license, and therefore will not show up in a database. Now, the application
New York implementation regulations for Section 390; specifically, Section 415.1(1) of Part 415 of the
regulations of the Office of Children and Family Services states that, even if an entity is not required to
register, it may still be required to comply with other applicable regulations. However, I could not find any
regulations that would apply to a child care facility In the vein of Wonderland Nursery School, and lb.Ls.
unofficial document describing the regulatory framework for all early childhood education programs In New
York confirms that the Wonderland-sort of organization is not subject to regulation.
Therefore, they do not qualify (because they are also not In the Head Start database).
On 10/8/12 20:58, "Fedloan PSLF"<[email protected]>wrote:
Hi Ian, We're having trouble with this one. They checked private
non-profit providing other school based services - early childhood program
There Is one mention ofthe1r not-for-profit status on their registration
form We could find no business filing. I checked the NY state website -
they have a voluntary registration for nonpublic nursery schools and
kindergartens, but I couldn't find Wonderland I also checked to see if
they were a licensed day care provider In NY and couldn't find them. Can
you find anything? Password to follow. Thanks!
(See attached file: Wonderland Nursery School.zip)
Diane Freundel
Compliance Services
(717) 720-3267
fax-(717) 720-3911
[email protected]
you
engaging
1nthe unauthorized use ofth1s message
From: !(b)(5)
Cc: Bl&...!.a!:l.;
Subject: RE: World Bank Group
Attachments: The lnternat1onal Orqanization Immunities Act.docx
Diane,
You're correct. Based on Q&A 49, the Wnrld Bank cine~not qualify.
It i~ a public international, intergovernmental nrganization that fit~ none
nf the categorie~ of qualifying employer, de~pite being tax-exempt under the
Internal Revenue Cnde. This i~ not unlike the ~ituation for a 501(c)(4J
nrganization, that i~ tax-exempt but provides no qualitYing
~erv1ce.
Because the EIN i~ tied to the World Bank (~pecifically, the

International Bank for Reconstruction and Development). I doubt that the
bo1TOwerin questinn wnrk~ for the US delegatinn tn the Bank. The Pre~ident
nfthe Bank ha~ historically been an American. who i~ a Federal governmental
employee. and may be staffed be Federal governmental employee~. Again.
though, here it appear~ a~ thnugh the borrower falh into the category of
World Bank employee. not Federal government employee.
See attached for a

write-up nf international organizatinn~ and their ~tatu~under CS
law.
Jan

[rnailto:dfreunde(a)pheaa nrvI C)n Behalf C)f Fed Loan
> PSLF
> Sent: Friday, May
18.20121:47PM
> To: Ll(b-'-)('-5)=~c'
> Subject: World Bank Group
>
>
>Hi,
Based on Q&A 49, I don't think this organization qualifies since it i~ an
>
intergovernmental organization: however. unlike the United l\"ations
> example
in the Q&A. I'm unsure if the World Bank Group ha~ a ~imilar
> structure. I
reviewed their website and couldn't find anything that point~ to
> a U.S.
corn mittee/ delegation/ etc.
>
> Wikipedia indicates they are technically a
part of the t..:nitedNation~ ~y~tem,
> although a citation for thi~
information is mi~~ing, and that each in~titution in
> the group is owned hy

its memher government,.
>
> My thought, are that they do not qualify. Do
you agree'.' Thi, one has
> attached certification became the employer
wouldn't complete the form.
> We'll handle that when we determine if they
qualify.
>
> Password to follow. Thanks.
>
> (See attached file: World
Bank Group.zip)
>
> Diane Freundel
> (717) 720-3267
>
fax- (717) 720-3911
> [email protected]
> This message contains privileged
and confidential information intended for
> the above addres,ee, only. If
you receive this message in error please
> delete or destroy this message
andlor attachment,.
>
> The ,ender of this message will fully cooperate in
the civil and criminal
> me'i'iage.
From: Foss Ian

To; FedLoan PSLF; .l(~b)~(5~)-~
Cc: l(b)(5) I:~; Ninemire Sandra: Sipple-Asher Bessie: ,Johnson Debbe
Subject: RE: Yelverton Enrichment Services
Thi~ too i~ a for-profit entity. As Kirn found. they i~~ued common stock,
the hallmark of a for-profit corporation. And, I've relied upon, in the
ca~e of other North Colonia-based employers. the B-clas~ forms versus the
N-cla~~ forms.

[mailto:dfreunde@aewJCce~~-or~ l On Behalf Of
> FedLoan PSLF
> Sent: Monday.
> To: l(b)(5) I
> Subject: Yelverton
Enrichment Services
>
>
> Another tough one that Kim researched today. No
EIN and only part-time.
> but we're trying to determine if the employer
qualifie~-
>
> ECF indicate~ it'~ Yelverton Enrichment Service~. A google
~earch ~hows
> Yelverton Enrichment Services with the same address as the
ECF in variou~
> directorie~ ~uch as yellow page~. Google aho ~how~
Yelverton'~
> Enrichment Service~. but their website is under con~truction
(copy of page
> in attachment). l\"C Busine~~ Filings ha~ Yelverton's
Enrichment Services
> with a different addre~s. A review of their article~
of incorporation indicate it
> i~~ued common stock and is therefore for
profit. Also by reviewing their
> filing~, they filed several addres~
change~, but none that
> match the address un the ECF. We think they are
for profit. We'll deny
> for no EIN, but we'd also like tu notify the
bunower if we think it'~ for-profit,
> ~o she doesn't ju~( provide an
EIN.
>
> Additional information from Kirn:
> I noticed the type uf document
filed was the B-01 form. In reviewing their
> website for forms that
nun-profits would need tu file, they begin with a 'N'.
> The 'B' forms are

for bminess corporations. See both links below.
>
>
11ttp: '/W\\'\V.~ecretarx _,tale. nc. uslcorporatio n ,/Form~. a~px "!Pl tern Id- 54 297
>
31 & Type= N onprofit%20Corporati on
>
11ttp: i/W\\'\V.~ecretarx _,tale. nc. uslcorporatio n ,/Form~. a~px "!Pl tern Id- 54654
>
9l&Type=Bu,inessCorporation
>
> Password to follow. thanks.
>
> (See
attached file: Yelverton Enrichment Services.7ip)
>
> Diane Freundel
>
Compliance Services
> (717) 720-3267
> fax-(717) 720-3911
>
[email protected]
>
>

> the above addres,ee, only. If you receive this
attachments.
>
civil and criminal
> me'i'iage.
>
>
From: !(b)(5)
To; FedLoan PSLF
Cc: l(b)(5) I Eo..s..w.a..o.;
Battle Cynthia: Odom Christian
Subject: State of Illinois Comptroller
Hi Kim,
In light of IHSSbeing under escalated review, FSAwill also need to escalate the State of Illinois
Comptroller to OGC for review.
Thanks,
Taneka
AmeriCorps Borrowers - 06.30.2015

New guidance is forthcoming in regards to how we handle borrowers serving in an
AmeriCorps program. Until the new guidance is received, all ECF's for borrowers
serving in AmeriCorps programs MUST be added to the PSLF Organization
Database for Compliance review.
If you have any questions, please see your lead or supervisor.
1
PIKBa .
Employment
Certification Form
Review Manual
Legal and Compliance Services
EMPLOYMENT CERTIFICATION FORM REVIEW MANUAL
Table of Contents
Document Version Control .................................................................................... 3

Summary .................................................................................................................. 3
Acronyms ................................................................................................................. 3
Foundational Material ............................................................................................ 4
Section 1: PSLF Employer Database .................................................................... 5
1.1 Locate Escalated Employer ............................................................................ 5
1.2 Access the ECFthrough FileNet ..................................................................... 6
1.3 Review the Employment Certification Form ..................................................... 7
Section 2: Resources ............................................................................................. 8
2.1 All Governmental Organizations ..................................................................... 8
2.2 Tribal Organizations ...................................................................................... 9
2.3 Tax Exempt/501(c)(3) Organizations ............................................................ 10
2.4 Private Not-For-Profit Organizations ............................................................. 11
2.5 Qualifying Public Services ............................................................................ 12
2.6 Determining if Charter Schools are Not-For-Profit .......................................... 13
2.7 Private Not-For-Profit Health-related Reviews................................................ 14
2.8 Handling Conflicting/Erroneous Information .................................................. 15
Section 3: Taking Action on ECF ........................................................................ 15
3.1 Approve Employer....................................................................................... 15
3.2 Deny Employer ........................................................................................... 16
3.3 Return Record to Supervisor ........................................................................ 16
3 .4 Refer ECFto FSA........................................................................................ 17
3.5 PSLFEmployer Retractions .......................................................................... 18
Section 4: Additional lnformation ....................................................................... 21
4.1 Alternative Certification ............................................................................... 21
4.2 Employer No Longer Exists or Employer Refusing to Certify ............................ 22
Related Documents .............................................................................................. 23
Related Letters ..................................................................................................... 23
Related Technologies/Reports ............................................................................ 23
Employment Certification Form Review Manual

Proprietary & Canf1rfentia/
EMPLOYMENT CERTIFICATION FORM REVIEW MANUAL
Screens................................................................................................................. 23
Work Queues/Action Request Codes (ARCs) ............................................................ 23
00~ .................................................................................................................... ~
Appendix A ............................................................................................................. 25
A.1 Accessing COMPASS5 M •••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• 25
Appendix B ............................................................................................................. 25
B.1 Saving Documentation in Compliance Drive .................................................. 25
Appendix C: Employment Certification Form .................................................... 27
Resources/Authority ............................................................................................ 32
Employment Certification Form Review Manual

Proprietary & Conf1rfentiaf
Document Version Control
VERSION PURPOSE/CHANGE AUTHOR/ REVIEWER DATE
1.0 Initial Draft Kim Myers 3/6/2013

1.1 Approved Kim Myers 1/22/2015
2.0 Updating Format and Flow Theresa Helwig 7/7/2016
2.1 Provided additional comments/sunnestions Kim Mvers 7/11/2016
2.2 Provided clarification Kim Myers 08/02/2016
2.3 Published Theresa Helwig 01/03/2017
3.0 • Added new section: PSLFEmployer Retractions Theresa Helwig
• Reviewed
• Published Kim Myers
Theresa Helwia 04/27/2017
Summary
The purpose of this document is to provide general processes and resources for designated Compliance employees to
use when conducting Employment Certification Form reviews.
There may be instances where even after researching the employer you are still unsure if you can approve. In these
instances, these casesshould be reviewed with the Senior Compliance Coordinator/Compliance Manager.
Acronyms
ARC Action Request Code
BMF Business Master File
BU Business Unit
DBA Doing Business As
ECF Employment Certification Form
EDGAR Electronic Data Gathering Analysis and Retrieval system
Employer Identification Number: An Employer Identification Number (EIN) is also

EIN known as a Federal Tax Identification Number, and is used to identify a business
entity. Generally, businesses need an EIN.
PHe.aa Employment Certification Review Manual

Proprietary & Conf1d!"nlial Page I3
EMMA Electronic Municipal Market Access
FLS Fed Loan Servicing
FSA Federal Student Aid
IRS Internal Revenue Service
PHEAA Pennsylvania Higher Education Assistance Agency
PSLF Public Service Loan Forgiveness
RACF Resource Access Control Facility
SEC Securities and Exchange Commission
soc Standard Occupation Classification
Foundational Material
The Business Unit (BU) performs the initial review of all Public Service Loan Forgiveness (PSLF) Employment
Certification Forms (ECFs) received by Fedloan Servicing (FLS). If the employer is private not-for-profit, a
charter school, the BU determines an employer does not qualify, or if the BU cannot determine whether the
employer qualifies, the ECF is escalated to Compliance. The BU must also escalate the ECFto Compliance if
Compliance previously approved the employer more than 12 months in the past.
Only employers that are escalated by the BU should be reviewed by Compliance. If the employer was
previously approved or denied within the past 12 months, it should be returned to the BU with a comment.
All reviews should be conducted based on the specific box checked on the ECF. However, when researching, it
may be determined that the employer actually falls under another category. All categories should be
reviewed for eligibility prior to denying the request.
All prior ECFsshould be reviewed to ensure no approval or denial errors were made previously. Also be aware
that several ECFsmay be in one image, so it is important to scroll through the entire imaged document to
locate the correct ECFthat requires review.
It is important to save any evidence found during research regarding the qualifying status of the employer.
See Appendix B for instructions on saving information to the appropriate folder.

Proprietary & Conf1d!"17.lial Page I4
Section 1: PSLF Employer Database

1.1 Locate Escalated Employer
1) Access the PSLF Database (Employer Database) by clicking on the shortcut to open WAPC
Launchpad.
2) Select PROCESSINGTOOLS,and then PSLFORG DATABASE

a) See your supervisor for the link path to the database
3) Select PUB SERVICEORG UNDER REVIEW-COMPLIANCE tab to access escalated employers for
Compliance review
a) To view specific information about the employer, including representative comments, select
the VIEW DETAIL button.
b) The following details are displayed:
i} PH or P # of the processing individual
ii) ECFStatus (pending, hold, completed)
iii) Date ECF Completed
iv) SSN of the borrower
v) Name of the employer (listed as Pub Service Org)
vi) Website of the employer
vii} EIN of the employer
viii) City of the employer
ix) State of the employer
x) Type of Organization (government, not-for-profit, AmeriCorps, private not-for-profit, Peace

Corps)
xi) Type Not-For-Profit (public safety, law enforcement, public interest legal services, early
childhood education, individual with disabilities/elderly, public health, public education,
public library services, school library services, other school based services, emergency
management)
xii) Date Entered
xiii)Reviewer
xiv)lnconclusive Type (W2 needed, Paystubs needed, proof of not-for-profit status needed,
proof of qualifying public service needed, articles of incorporation needed, letter from
employer needed, other)
xv) Status (approved, approved religious, denied, inconclusive, under review)
xvi)Denial Reason

xvii) Date approved/denied
xviii) Comment history
xix) New comment
c) To leave the record about an employer and to access another employer, select CANCEL
4) If not already added, add the escalated employers to the ECFREVIEWStab of the Compliance
spreadsheet (ECF Reviews 2012-2016) saved to compliance$1(bl( 5l I
b)(5) . .
1.2 Access the ECF through FileNet
*
1} From the Employer Database details screen, capture the borrower's SSN
NOTE: The oldest open employer entry with Compliance should be worked first.
2} Using Internet Explorer. go to

l(b)(5)
3} log in using your HERA P/PH# and password
4} Enter the SSN into the "Account Number or SSN" field
5} Press Enter
6} Access the "FLS Servicing library" by selecting VIEW LIST (if multiple libraries appear}
7} Select the most recent PSECFtask, identified under the column "Action Request Code," by
selecting VIEW DOCUMENT
i;?;NOTE:If t~ere is not a PSECFtask, check other Action Request Codes (ARCs) since an ECFcan
be logged incorrectly.
a) Use the arrows at the bottom of File Net to page through the document until you get to the
page that contains the Employment Information section of the ECF
b) If the document you selected does not coincide with the escalated employer, close the
document and select the next most recent ECF
i) Select SEARCHRESULTSfrom the top of the FileNet page
ii) Select VIEW DOCUMENT of the next most recent ECF
8) Save the ECFdocumentation in the Compliance Drive
a) See Appendix B for further instructions
9) Determine if employer was previously approved/denied
a) Review the Compliance spreadsheet
i) Press your CTRLand F key simultaneously
ii) Type the name of the employer or EIN in the FIND WHAT field

Proprietary & Conf,ct!"nlial Page I 6
iii) Select FIND ALL
iv) Review identified records to determine if employer was previously approved/denied
b) If employer was previously approved/denied within the last 12 months, return the ECFto the
BU Supervisor
i) Proceed to Section 3.3 to return the record
c) If employer was not previously reviewed, proceed to Section 1.3
1.3 Review the Employment Certification Form

1) Review the ECFto ensure the borrower is not also the certifying official
a) If borrower is the certifying official, return the record to the BU to contact borrower to have
another individual authorize the form
i) See Section 3.3 to return record
2) Take note of the employer's name, EIN, address and which type of public service organization box
was selected. This information will be needed when researching employer.
U NOTE:Some employers provide the DOING BUSINESSAS (d/b/a) name, so further research,
such as checking employer's website, may be needed to determine official name
3) Review the ECFfor any additional pages or stray comments made by the employer or borrower
a) If any pertinent information (EIN, address, etc.) is missing from the ECF,review COMPASS5 M
{ITL2U,ITD2A),
i) See Appendix A for instructions on accessing/reviewing COMPASSsM, or FileNet {PSCOM)
as appropriate to ensure the BU attempted to obtain the missing information.
ii) If BU did not obtain the missing information, return the record to the BU Supervisor
through the database to obtain the missing information
(1) See Section 3.3 to return record
4) Save the ECFand any pertinent information
i) See Appendix B for further instructions.

Proprietary & Conf1d!"17.lial Page I7
Section 2: Resources
Listed below are the resources that should be used to thoroughly research employer eligibility for PSLF.The resources
are organized by the options listed on the ECF.These resources, paired with training, assist in accurately identifying
which employers will be approved or denied.
2.1 All Governmental Organizations
Government organizations include Federal, state, local, or Tribal government organizations, agencies,
or entities; public child or family service agency; a Tribal college or university; or the Peace Corps or
AmeriCorps. This does not include a member of the U.S. Congress, as they are not eligible; however,
congressional staffers are eligible. Also, tribal casinos do not automatically qualify.
According to regulations, governmental organizations automatically qualify for PSLF.Therefore, the

type of public service does not need to be verified. The only exceptions are tribal organizations. See
Section 2.2 for additional steps that need to be taken to verify if a tribal organization can be approved
for PSLF.
• Employer Identification Number (EIN) Validation Website:

o After entering in the EIN, a banner will appear either confirming or denying whether the EIN is
valid.
• GuideStar: The world's largest source of information on not-for-profit organizations.

o Sign-in or create a free account (click on Create Account), if you haven't already done so.
TIP: Search the employer by the EIN and by the name in case the employer/borrower made a
typo on their EIN. If the employer made a small mistake by switching two numbers, update
the EIN in the database and process accordingly.
o Review the employer's GuideStar record, if found, for language indicating the employer is
government. If so, the employer can be approved (Section 3.1).
■ Ex. This organization is not required to file an annual return with the IRS because it is an
arm of a state or local government.
* NOTE: Government Organizations will not typically have filed an IRS Form 990 1 . This is
one way to verify that an organization is in fact associated with the government.
• EMMA (Electronic Municipal Market Access): EMMA provides documents and data derived from a
number of sources.
o Use the "Quick Search" function in the upper right hand corner of the homepage to search the
name of the organization. Variations of the name may need to be tested if the organization
includes an abbreviation.
1 An IRS Form 990 is a Return of Organization Exempt From Income Tax form. This form is used by tax-exempt
organ1zat1onsand nonexempt charitable trusts.

Proprietary & Conf,d!"ntial Page I 8
o Review the ISSUERNAME column for the employer in question. The employer can be approved
if they are listed as an issuer (Section 3.1).
~ TIP: You may need to try different variations of the employer name
C· If no results are displayed, the organization most likely does not issue bonds.
• Google EIN:
~ TIP: Format the Google search with the word "EIN" followed by the actual EIN using the
hyphen (Ex. EIN 12-3456789).
C· Review results to determine if the EIN is tied to the government. If results specifically show
that EIN is tied to a governmental agency, the organization can be approved (Section 3.1).
C· Results may show that the EIN is listed on another organization's Form 990. Review other
organization's Form 990 Schedules I and R to determine the type of entity listed for the
employer's EIN.
NOTE: Research may indicate that an EIN provided on an ECFbelongs to another
* organization. Compliance needs to determine if there is a link between the

organizations. If the link cannot be determined, return the record to the BU to request
W-2s (Section 3.3).
• Google for employer website if not included on the ECF:

o If the domain is .gov or .mil, the agency can be approved (Section 3.1).
C· If the employer is a public school, not including charter schools, the organization can be
approved. For charter schools, see Section 2.6.
o If domain is not .gov or .mil, search state and/or local government websites. If listed on a
government website, determine if employer is actually part of the government, or the
*
government website is simply providing a list of entities, such as licensed day care providers.
NOTE: Being listed on a government website does not mean that the employer is a
government entity
• Google for financial statements:

C· In the search box, type in the employer name followed by "Financial Statements." If located,
review the financial statements for any language indicating the employer is governmental
(e.g., political subdivision, body politic, etc.). The employer can be approved , if acceptable
language exists (Section 3.1}.
C· If the financial statements indicate that the employer participates in the state's retirement
program, the organization is a government agency and can be approved (Section 3.1}.
2.2 Tribal Organizations
It is important to determine the relationship between a tribe and a tribal casino.
• System for Award Management Website: An official website of the U.S. government that
combines federal procurement systems and the Catalog of Federal Domestic Assistance into one
system.

o This website should be used to determine if a casino is regarded as a distinct entity from the
tribe itself.
o On the homepage of the website, select "Search Results" from the last column titled "Search
Records. Use the "Quick Search" function in the upper right hand corner of the homepage to
search the name of the organization. Variations of the name may need to be tested if the
organization includes an abbreviation.
o If the casino is a tribal 8{a) organization under the Small Business Administration's parlance 13
CFR 124.109(c)(2), the entity is not a qualifying employer for PSLF(Section 3.2).
o If no results are displayed, the organization is most likely not a tribal 8(a} organization.
• Google casino:
o Google the casino to determine if it is owned and operated by the tribe or if they have
sovereign immunity 2 . Also, look for their by-laws or constitution to make a determination for
qualification.
2.3 Tax Exempt/501(c)(3) Organizations
• GuideStar: The world's largest source of information on not-for-profit organizations.
TIP: Search the employer by the EIN and by the name in case the employer/borrower made a
typo on their EIN. If the employer made a small mistake by switching two numbers, update
the EIN in the database and process accordingly.
o Review the Form 990 to determine the employer's filing status (Item I -Tax-exempt status)
C· If 501(c)(3), employer automatically qualifies but additional review is needed to determine if
agency actually employs paid employees or only accepts volunteers.
■ In Part I of the Form 990, if line 5 is "O" then the organization does not have employees.
Request a W-2 to determine who pays the borrower (Section 3.3).
• Google EIN provided on the ECF:
C· If the Google search brings up a BrightScopc entry, the organization may be for-profit and
should be reviewed further.
C· Review any other pieces of information that result from the EIN search to determine if the
employer can be classified as 501{c)(3).
• IRS Exempt Organizations Select Check tool (former Publication 78): Exempt Organizations Select
Check is an on line search tool that allows users to search for and select an exempt organization
and check certain information about its federal tax status and filings.
o Search in the Exempt Organization Select Check Tool and select the radio button beside "Are
Eligible to Receive Tax-Deductible Charitable Contributions." If employer appears, review the
column titled Deductibility Status. The employer can be approved (Section 3.1) if "PC" is listed.
2 Tribal Nations are given sovereign immunity, which prohibits suit against a Tribe unless it has waived its immunity, has
consented to be sued, or Congress has expressly retracted the immunity.

o If any other status is listed, they are not-for-profit, but must be reviewed to determine if the
employer performs a qualifying public service (Section 2.5).
o If the employer does not appear, return to the Exempt Organization Select Check Tool and
select the corresponding radio buttons to search if the employer was automatically revoked or
filed a Form 990-N (e-postcard). If the employer appears under the search for being
automatically revoked, review the date listed in the Revocation Date column. Any certified
employment prior to this date can be approved (Section 3.1}.
• IRS Business Master File (BMF}: The Exempt Organization Business Master File Extract {EO BMF)
includes cumulative information on exempt organizations. The data are extracted monthly and are
available by state and region.
C· Search by selecting the state where the employer's corporate office is located. Review the
Subsection Code (Column I) in the spreadsheet that coincides with the employer. The
employer can be approved if Subsection Code (Column I) is 3 (Section 3.1).
o The employer should be reviewed as private not-for-profit (Section 2.4) if the subsection code
(Column I) is something other than 3 and the entity is NOT a religious entity. If subsection code
(Column I) is something other than 3 and the entity IS clearly a religious entity, the employer
*
may be approved.
NOTE:Religious entities may self-certify as a 501(c}(3) organization, and therefore may

not be listed in IRS Exempt Organizations Select Check or IRS BMF even though the
employer qualifies.
• Review the employer's website:

C· If employer is wholly owned by another organization (e.g., a hospital that is owned by a larger
organization}, search the above resources using the name of the parent organization and/or
EIN. If parent organization is not found, the organization must be reviewed to determine if
they are Private Not-For-Profit. If parent organization is found, search the entity on GuideStar:
■ Review the Form 990 Schedule H, Section A to determine if the employer is a Hospital
Facility of the parent organization. If employer is found here and the parent organization is
501(c)(3), the employer may be approved (Section 3.1).
■ Review the Form 990 Schedule R, Part 1 Identification of Disregarded Entities to determine
if the employer is a Disregarded Entity. If employer is found here and the parent
organization is 501(c)(3), the employer may be approved (Section 3.1).
2.4 Private Not-For-Profit Organizations
• SEC/EDGAR(Electronic Data Gathering, Analysis, and Retrieval system): EDGAR performs

automated collection, validation, indexing, acceptance, and forwarding of submissions by
companies and others who are required by law to file forms with the U.S. Securities and Exchange
Commission (SEC).Anyone can access and download this information for free.
o Use the Company Filings Search to search for the employer under Company Name. If the
organization is found, the company is a for-profit business and should be denied {Section 3.2).

Proprietary & Conf1d!"nlial Page I 11
• State Corporation Bureau or Secretary of State website (for the state of the employer): A compiled
list of links for legal professionals and others who are looking for quick access to the corporate
information available in on line searchable databases maintained by the Secretary of State for any
given state.
C· Search for the state in which the corporate office is located. If search provides corporation
status (not-for-profit, for-profit, etc.) and employer is listed as not-for-profit, the organization
should be reviewed for qualifying public service in Section 2.5. Any employer listed as for-
profit should be denied (Section 3.2).
• If the business filing indicates that organization owns stock, this is typically an indication
that the organization is for-profit and should be further reviewed.
• Review the employer's website:

o If the website provides no indication of not-for-profit status or qualifying public service, the
employer must provide additional information to verify not-for-profit or qualifying public
service status.
o If the website indicates that the employer is not-for-profit, but no other verification of not-for-
profit status is found, the employer should be escalated to FSA (Section 3.4).
o If the website indicates that the employer is not-for-profit and verification is found, the
employer should be reviewed for qualifying public service in Section 2.5.
• Skilled Nursing Facility Directory (nursing homes): This nursing home directory contains over
*
15,600 skilled nursing facilities in the United States.
NOTE: This resource should be used as a last resort if no conclusive information can be
found.
o Perform a search using the zip code and select the appropriate nursing home to review the
Ownership Type. If the Ownership Type is eligible, the organization can be approved (Section
lil
o See Section 2.7 for more information related to determining if Private Not-For-Profit health
institutions qualify as performing a public service.
2.5 Qualifying Public Services

• Employer must perform one of the following public services to qualify:
o Emergency management
o Military service
o Public safety
o Law enforcement
o Public interest legal services: Refers to legal services provided by a public service organization
that are funded in whole or in part by a local, State, Federal, or Tribal government
C· Early childhood education: Including licensed or regulated child care, Head Start, and State
funded pre-kindergarten
C· Public service for individuals with disabilities
o Public service for the elderly

o Public health: Includes nurses, nurse practitioners, nurses in a clinical setting, and full-time
occupations, such as those defined by the Bureau of Labor Statistics
C· Public education: Includes services that provide educational enrichment or support directly to
students or their families in a school or school-like setting
C· Public library services
o School library services
C· Other school-based services
~·'-7 NOTE: Some not-for-profit employers may seem like they should qualify; however, FSA
M
determined that they do not qualify .. These employers include: credit unions, social
workers, and most associations.
• State Corporation Bureau or Secretary of State website (for the state of the employer): A compiled
list of links for legal professionals and others who are looking for quick access to the corporate
information available in on line searchable databases maintained by the Secretary of State for any
given state.
o Review the Articles of Incorporation, if available, under the agency's business filing to
determine which type of public service the organization provides.
• Google website: In order to determine if confirmed not-for-profit performs a qualifying public

service.
C· If no match (account for acronyms, abbreviations, etc.), review name of employer and
determine if you strongly feel they may provide a qualifying public service or if it appears the
ECFmay escalate and result in multiple denials. If name of employer leads you to think they
may provide a qualifying public service (e.g., medical facility, school, etc.), or the ECFhas the
potential to escalate, return the record through the database to contact employer for more
information (Section 3.3).
C· If name of employer leads you to think they do not provide a qualifying public service (e.g.
staffing agency} and there's no reason for the ECFto escalate, deny for the reason we could
find no evidence they perform a qualifying public service (Section 3.2).
o If a match is found and the website clearly indicates that employer provides a qualifying public
service, the organization can be approved (Section 3.1).
o If a match is found and the website indicates that the employer does not provide a qualifying
public service, the organization can be denied (Section 3.2).
o If you cannot determine if employer performs qualifying public service, deny with a request for
evidence of what types of qualifying public service they perform (Section 3.2).
2.6 Determining if Charter Schools are Not-For-Profit
NOTE: Charter schools in Hawaii and Massachusetts are automatically classified as government
and will not be managed by another entity. Charter schools in these states can be
automatically approved as government.

• Review charter school's website: Charter schools can be run by a managing entity, which can be
for-profit, depending on the state in which the charter school is established. In particular, the
employees of charter schools managed by the Leona Group are actually employed/paid by the
Leona Group, which is a for-profit entity.
C· If the website research shows that the charter school is managed by another entity, return the
record to request more information from the BU {Section 3.3).
C· If the charter school is not managed by another entity, process the ECFbased on the EIN
provided on the form.
C· If the EIN belongs to another entity, review the eligibility of the entity that holds the ElN. If the
entity that holds the EIN is solely a payroll processing company (ex. ADP, PEO), the charter
school itself should be reviewed for eligibility and not the payroll processing company.
o If the entity that holds the ElN is not related to the charter school, return the record to the BU
supervisor to request the borrower's W-2 or a copy of the borrower's paystub (Section 3.3).
• Take note if the EIN provided on the form belongs to the charter school itself or to another entity,
as this may signify they are managed by another organization.
2.7 Private Not-For-Profit Health-related Reviews
Health-related organizations include social work organizations and health/dental plans.
NOTE: You may not be able to determine if certain organizations perform a qualifying public
service (e.g., organizations for certain groups of individuals). In these instances you must
review the employer to see if they employ individuals that meet the criteria for certain
Standard Occupation Classification (SOC) codes.
• Review Open Job Positions (search for careers on employer's website):

o Review to see if the employer has a posted position for an individual that would meet the
criteria for Standard Occupation Classification (SOC)codes for 29-0000 or 31-0000.
• The 2010 Standard Occupational classification System (Bureau of Labor Statistics): The 2010
Standard Occupational Classification (SOC)system is used by Federal statistical agencies to classify
workers into occupational categories for the purpose of collecting, calculating, or disseminating
data.
o Review the job categories under "29-0000 Healthcare Practitioners and Technical
Occupations" and "31-0000 Healthcare Support Occupations." If any open position at the
organization is performing the service of a job category found under 29-0000 or 31-0000, the
employer qualifies and can be approved {Section 3.1).
TIP: If you are unsure if an open position meets the criteria for a job category in the
SOC, review the particular state's definition for the job in question (e.g., nursing) in
conjunction with the job posting to determine if the employer qualifies. The state's
definitions can be found by searching the state's statutes.
o If significant uncertainty remains, escalate the employer to FSA (Section 3.4).

2.8 Handling Conflicting/Erroneous Information
• If any of the following scenarios are encountered, return the record to the BU supervisor, outline
the reason the record is returned, and/or request the borrower's W-2 or a copy of the borrower's
paystub (Section 3.3).
o EIN that does not coincide with an EIN identified for the employer through research.
*
NOTE: If the employer/borrower made a small mistake by switching two numbers,
update the EIN in the database and process accordingly.
C· EIN that was identified as belonging to another organization and no relationship between the
organizations can be identified.
o Any other issue that requires more clarification before you can conclusively approve or deny
(e.g., you need to determine where the BU obtained the EIN, there is a notation on a cover
letter that contradicts what is on the ECF,etc.).
Section 3: Taking Action on ECF

This section provides instruction for notifying the BU of the outcome of the escalated ECFfor PSLF.
3.1 Approve Employer

1) Select the specific employer (View Details)
2) Select MAKE EDITS
*
a) Use the drop down selections for TYPEOF ORG to select the appropriate type of organization
NOTE: If you determine an employer falls into multiple categories -with

of AmeriCorps and Peace Corps, as they should always be approved under their
the exception
respective category- always choose the category according to hierarchy (government

first, not-for-profit second, and private not-for-profit third). For example, if you
determine an employer is government and not-for-profit, you should approve them
under government.
i} Gov Org- For Government
ii) Not-For-Profit- For 501(C){3)
iii) Private Not-For-Profit- For Not-For-Profits That Are Not 501(C)(3)
iv) AmeriCorps
v) Peace Corps
b) Use the drop down selections for TYPE NON-PROFITto select the appropriate type of not-for-
profit qualifying service (only used when Private Non-For-Profit from step immediately above
is selected)
i) Emergency Management

ii) Military Service
iii) Public Safety
iv) Law Enforcement
v) Public Interest Law Services
vi) Early Childhood Education
vii) Individuals with Disabilities/Elderly
viii)Public Health
ix) Public Education
x) Public Library Services
xi) School Library Services
xii) Other School Based Services
c) Use the drop down box beside Status and select 'Approved'
i) Enter a comment in the comment box stating why the employer was approved, followed
by your initials. Comment typically just restates the type of employer, e.g., Employer is
private not-for-profit providing public education. DF
ii) Select SAVE
3.2 Deny Employer

a) Use the drop down box beside Status and select DENIED
i) Enter a comment in the comment box stating why the employer was denied, followed by
your initials, e.g., Employer is for profit. DF; Employer is private not-for-profit, but doesn't
provide a qualifying public service. OF
ii) Select SAVE
3.3 Return Record to Supervisor

a) Use the drop down box beside Reviewer and select SUPERVISOR
i) Enter a comment in the comment box stating why the record is being returned, followed
by your initials, e.g., We are unable to tie EIN on ECFto employer. Please contact borrower
for a copy of their W-2. OF
ii) Select SAVE

Proprietary & Conf1d!"17.lial Page I 16
3.4 Refer ECF to FSA

1) Draft email to FSA outlining questions
a) WinZip and password protect any attachments, including the ECF, needed for the e-mail
~e~m_□_l_a_v_e~,-fo~l~d~e-,
-□-re_,_,i_a_11_sl_11_c_,_e-at_e_d_i□_c_a_m_□_li_a_□_cJ--bl-(-I--------~~
5
5
i) cl(~~lf-
l~e-s~s
ii) Right click on main folder

iii) Select WINZIP
iv) Add to Zip File
v) Make selection under options ENCRYPTADDED FILES
vi) ClickADD
vii} Select OK from caution window pop-up
fbJ(5)
viii) Enter password l
~----------------------~
ix) Reenter password
x) Click OK
xi) Close window
b) Attach WinZip file to e-mail (Note: Password must be forwarded in a separate e-mail)
c) Send e-mail to rl(5l l(place "employer name" in subject line)
2) Send password tojtbJ(5J Inseparate e-mail (place "PW employer name" in subject
line) ~-------~
3) Move employer to FSA review in Employer Database
a) Select the specific employer (View Details)
b) Select MAKE EDITS

i) Use the drop down box beside Reviewer and select FSA
ii) Enter a comment in the comment box stating that the employer was referred to FSA,
followed by your initials.
iii) Select SAVE
4) Update ECF Reviews 2012-2016 spreadsheet with outcome of review and save

3.5 PSLF Employer Retractions
Effective November 15, 2016, any PSLFEmployer decision that should be retracted must be escalated
to FSA for review. The BU will forward an email containing the applicable employers to be retracted
and all effected ECFsto the Fedloan PSLFMailbox. The following process should be used by
Compliance to escalate the retractions to FSA.
1} Once several retractions are received from the BU, create a folder in
fb)(5)
a) Name the new folder Employer Retractions_yyyy.mm.dd
i) Ex: If the retractions are sent on April 19, 2017, the name of the folder would be "Employer
Retractions 2017.04.19"
2} Create a new Excel spreadsheet with the same name as the folder
3} Include four columns on the spreadsheet titled:
a) Employer
b) Number of Borrowers Impacted
c) Date of Oldest Approval
d) Reason for Retraction
4) Using the information provided in the BU's email, fill in the following columns on the spreadsheet
appropriately
a) Employer
b) Number of Borrowers Impacted
c) Date of Oldest Approval
"tr NOTE:List the Employers in alphabetical order

~~-----------------~
5
5) Open the internal employer spreadsheet located in(bl( l
Compliance Team ~------------------~
6) Review the internal employer spreadsheet to determine the reason for the retraction.
a) Ex: the employer is for-profit; the employer is not-for-profit and not providing a qualifying
public service; etc.
7) Add the reason for the retraction to applicable column in the newly created spreadsheet.
8) Access the employer files for the retracted employers

a) Go to bJ(5l
~----------------------~
b) Locate the applicable employer files
i) Select the appropriate employer folder
ii) Right Click on the folder

iii) Select Copy
c) Return to the Employer Retractions_yyyy.mm.dd folder
i} Right click in the folder

ii) Select Paste
d) Review the contents of the employer folders that were copied over
i} Remove any unnecessary ECFsthat are in the folder
9} Copy the ECFsfrom the business unit's original email and paste them in the respective employer's
folders that were copied over in the previous step.
10) Once the spreadsheet is complete and the Employer Retractions_yyyy.mm.dd folder contains all
of the necessary information, winzip the folder.
a) Right click on the file and find WinZip
i) An additional menu of options will appear, select ADD TO ZIP FILE
b) On the screen that appears, select ENCRYPTADDED FILES (under Options)
c) Select ADD
fbJ(5)
d) Create a password usingl
i) (b)(5)
e) Re-enter password
f) Select OK
(b)(5) I
l
11) Send an email to~-------~from the FedLoan PSLFemail box
a) Include the zipped folder in the email
12) Send a separate email to 51______
L(b_l(_ ~from the Fedloan PSLFemail box
a) Include the password for the zipped folder
13) Move the email that was received from the business unit in the FedLoan PSLFMailbox to the
"Retractions" folder until a response is received from FSA
14) Act on guidance from FSAwhen they respond
a) Respond to the email from the BU located in the "Retractions" folder with the guidance
provided by FSA
b) If FSA requests the retraction letter
i) Inform the BU of their request and monitor the mailbox for the retraction letter
ii) Once the letter is received,
*
(1) Make any necessary edits
NOTE: Ensure the file name includes the name of the employer

b)(5)
iii) Create a new folder i
~-----------------------~
(1) Name the folder the employer's name
iv) Save the retraction letter to the newly created folder
v) Winzip the folder named after the employer
(1) Right click on the file and find WinZip
(a) An additional menu of options will appear, select ADD TO ZIP FILE
(2) On the screen that appears, select ENCRYPTADDED FILEs(under Options)
(3) Select ADD
(4) Create a password bJ(5J

(a) (b)(5)
(5) Re-enter password
(6) Select OK
5
vi) Send an email t4bl( l lfrom the Fed Loan PSLFemail box
(1) Include the zipped folder in the email
vii) Send a separate email to(bl(5l from the FedLoan PSLFemail box
~-------~
(1) Include the password for the zipped folder
viii)Move the email with the retraction letter that was received from the BU to the "Letters
Sent to FSA" folder in the Fed Loan PSLFmailbox
c) If FSA does not request a retraction letter

i) Create a folder in tbe"fb~l(~
5I--------------------------~
[b)(5)
ii) Copy and paste the letters provided by the BU into the newly created folder
iii) Winzip the folder
(1) Right click on the file and find WinZip
(a) An additional menu of options will appear, select ADD TO ZIP FILE
(2) On the screen that appears, select ENCRYPTADDED FILES(Under Options)
(3) Select ADD

(4) Create a password(bl( 5l
(b)(5)
(5) Re-enter password
(6) Select OK

ii) Send an email tofbl( 5l t from the FedLoan PSLFemail box
(1) Include the zipped folder in the email

iii) Send a separate email to l(bl(5l ltrom the Fedloan PSLFemail box
~-------~
(1) Include the password for the zipped folder
Section 4: Additional Information

4.1 Alternative Certification
1) If an exception occurs and the borrower provides alternative certification, review it for required
information
a) Certification must contain
i) Name of employer
ii) EIN of employer
iii) Address of employer
iv) Full-time/part-time status of borrower/employee
v) Dates of employment of borrower/employee
vi) Signature and date of authorized official of the borrower's employer
vii) Contact information for the authorized official
b) If alternative certification does not contain all of the required pieces (except for
signature/ date/ contact information),
i) Return record to BU to contact employer for missing information
(1) See Section 3.3
c) If alternative certification does not contain signature/date/contact information for authorized

official,
i) Return to BU Supervisor as a denial
*
(1) See Section 3.3
NOTE:This is returned to the BU Supervisor solely to point out that the

documentation should never have been escalated to Compliance since required
information was missing.
2) If all required information is present, follow steps on reviewing employer
a) See Section 2

4.2 Employer No Longer Exists or Employer Refusing to Certify

1) If borrower checks the box on ECFindicating he/she is unable to obtain certification because the
organization no longer exists or the organization refused to certify, follow steps on reviewing
employer (see Section 2) to determine if employer qualifies
2) Review the documentation of pay. (refer to document provided by FSA-Supporting

5
m nt ti n-draft021612 found afbl( l
(b)(5) "----------------------~
3) If the documentation of pay is not provided, return to the BU to request the borrower provide
documentation of income.
a) See Section 3.3
NOTE: A W-2 is required, and paystubs are encouraged, but optional.

Related Documents
(b)(5)
ECF Reviews 2012-
2016
FSA Supporting (b)(5)
Documentation -
Employer No Longer
Exists
(b)(5)
PSLF Q&A Document
Related Letters
Letter ID Description
Not Applicable
Related Technologies/Reports
Screens
Screen Name System Mode Description
TDZA COMPASS SM I Activity Display
TLZU COMPASS SM I Public Service Loan Forgiveness Screen
Work Queues/ Action Request Codes (ARCs)
Name Code Description
PSCOM Not Applicable Public Service Loan Forgiveness Comment
PSECF Not Applicable Public Service Loan Forgiveness ECF

Other
Name Description
System used to review account level data. Accessed by using the

COMPASSSM
HERA session link on the desktop.
h tt12:LLwww. hi 12a comLM ed icaI Data Val id ati onL Em12I

as12ace. Oy'er Id
EIN Validation Website
cntification NumbcrLEIN Validation.as12x
Electronic Municipal Market Access

:LL
httr::1 em ma. msrb .orgLSearchLSearch .asQ:X
(EMMA) Website
Employer Database Access database used to house escalated employer reviews
File Net Repository of imaged documents
GuideStar htt12:LLwww .gu idesta r.orgL
http://www. i rs .gov /Ch a rities-&-N on- Profits/Exempt-Organizations-

IRS Business Master File (BMF)
Business-Master- File-Extract-EO-B MF
IRS Exempt Organizations Select h tt12:LLwww. i rs .gov [Ch a rities-&-N o n-Profits[Exe m 12t-Organizations-
Check tool {former Publication 78) Select-Check
SEC/EDGAR (Electronic Data h tt12:l[www.sec.gov Ledgar. shtm I

Gathering, Analysis, and Retrieval
system)
Skilled Nursing Facilities Website httQ:l[www.skillednursingfacilitics.org[dircctor'iL
State Corporation Bureau or httr::1:LLwww.coordinatedlegal.comLSecretar}'.OfState.html

Secretary of State website
httQs :l[www.sam.gov Lr::1ortalLSAML?r::10

rta I:com r::1on
e ntl d= 3 lbe 779b-
ffb 7-4907-b 7bl-
System for Award Management
e 7 4a85af25d6&i nteracti onstate= J BPNS rOOABXcOABBfa n Nm QnJ QZ
Website
Gd IVm IldOIkAAAAAQA TL2QzZi9 mdWS j dGlvb m FslmQzcAAH X 19 FTOZf
Xw* * &r::1ortal:t1£12e=action#l#l
The 2010 Standard Occupational httpJ /www.bls.gov/soc/

classification System

Appendix A
A.1 Accessing COMPASS''•'
1) Open the shortcut to the HERAsystem located on your desktop
2) Type PHEAA, press enter
3) Enter your username (ph/p #) and RACF password, press enter
4) Clear your screen by pressing your 'Pause/Break' key
5} Set up your bridge key, if you haven't done so already
a) From a clear screen type 'PFCH' and press Enter
b) Beside the key you would prefer as your bridge key, type
51
"rb_l(_
___ ~
c) Press Enter
6} From a clear screen, type the screen you want to accessfbl( 5l rallowed by the SSN
and press Fl. ~------~
Appendix B
B.1 Saving Documentation in Compliance Drive
1) From FileNet (for ECF),website and/or resource document, select FILE,then PRINT
2) Select CUTEPDF WRITER, for Acrobat Reader or ADOBE PDF if you have Adobe Acrobat Pro
a) If you do not have either, contact the Help Desk for instructions on how to install CutePDF
Writer
3} Select the page range you want to save
<;\ TIP: If saving a Form 990 from GuideStar, it is usually appropriate to only save the first page
~ and any other pages specifically used; e.g,. Schedule R
4) Select PRINT
5
5} Once the box pops up, use the drop down arrow and select the compliancJbl( l For
Compliance staff, this is typically thefbl( 5l I I~----~
a) Select the FEDLOANSERVICINGsubfolder
b) Select the PSLFsubfolder
c) Select the ECFsREVIEWEDsubfolder
foldE:r I .
r·J1c:,1,
6) Create a subfolder for the employer by selecting the ----~- icon
a) If a subfolder already exists, save the new ECFto the existing folder using ECFand the date
received (ex-fbl(5J
~------~

i} The save has been completed
b) If a subfolder does not already exist, proceed to Step 7
7) Name the folder using the name of the employer
8) Press Enter
9) Select the newly created folder
10) Change the File Name as appropriate
11) Press SAVE

12) Repeat steps to save additional information
~ TIP: When saving future information, skip the steps describing how to create an employer
folder since once has already been established.

Appendix C: Employment Certification Form
PUBLIC SERVICE LOAN FORGIVENESS (PSLF): 0MB No. 1845-0110

Form Approved
EMPLOYMENT CERTIFICATION FORM Exp. Date 12/31/2017
William D. Ford Federal Direct Loan (Direct Loan) Program
WARNING: Any person who knowingly makes a false statement or misrepresentation on this form or on
PSLF ECF any accompanying document 1s subject to penalties that may me lude fines. impmonment. or both. under
the U.S. Criminal Code and 20 U.S.C. 1097.
SECTION 1: BORROWER INFORMATION
Please enter or correct the following information.
D Check this box if any of your information has changed.
SSN
Date of Birth
Name
Address
City State Zip Code
-----
Telephone - Prim<1ry
Telephone - Alternate
Email (Optional)
SECTION 2: BORROWER AUTHORIZATIONS, UNDERSTANDINGS, AND CERTIFICATIONS
Before signing, carefully read the entire form. For more information on PSLF,visit StudentAid.gov/publicservice.
I authorize:
1. My employer or other entity having records about the employment that 1sthe bam of my request to make information
from those records available to the U. S Department of Education (the Department) or its agents or contractors.
2. The entity to which I submit this request and its agents to contact me regarding my request or my loans at any cellular
telephone number that I provide now or in the future using automated telephone dialing equipment or artificial or
prerecorded voice or text messages.
I understand that:
1. To qualify for PSLF,I must make 120 qualifying payments on my Direct Loan(s) while employed full-time by a qualifying
employer or employers. Neither the 120 qualifying payments nor the employment have to be consecutive.
2. To qualify for PSLF,I must be employed full-time by a qualifying employer when I apply for and receive PSLF.
3. lfl qualify for forgiveness, only the remaining balance on my Direct Loan(s) will be forgiven.
4. By submitting this form, my student loan(s) held by the Department will be transferred to Fedloan Servicing.
5. The Department may request supplemental documentation substantiating my employment.
6. The Department will notify me 1nwr1t1ng or electronically of the number of qualifying payments I have made while
employed full-time by a qualifying employer and how many more I must make before I am eligible to apply for PSLF.
7. The Department will notify me in writing or electronically if the form that I submit is incomplete, or if it determines that
my employment or payments do not qualify for PSLF.The Department will explain the reason for the determination
and the steps I need to take to correct the form or make qualifying payments.
8. The Department wil I retain this certification form until I submit my application for forgiveness.
I certify that all of the information I have provided on this form and 1nany accompanying document 1strue, complete. and
correct to the best of my knowledge and belief.
n Check this box if you cannot obtain certification from your employer because the organization is closed or because the
organization has refused to certify your employment. The Department will follow up to assist you in getting
documentation of your employment. Complete Section 3, but do not complete Section 4.
Borrower's Signature _____________________ _ Date --------

Page I o/6

Borrower Name Borrower SSN
SECTION 3: EMPLOYER INFORMATION (TO BE COMPLETED BY THE BORROWEROR EMPLOYER)
1, Employer Name: 10. Is your employer tax-exempt under Section 501 (c)(3)
of the Internal Revenue Code?
D Yes - Skip to Section 4.
2. Federal Employer ldentif1cat1on Number (FEINI D No - Continue to Item 11.
11. Is your employer a not-for-profit organization?

Your employer's EIN may be found on your Wage D Yes - Continue to Item 12.
and Tax Statement (W-2).
D No - Your employer does not qualify.
3. Employer Address: 12. Is your employer a partisan political organization?

D Yes - Your employer does not qualify.
4. Employer Website (if any): D No - Continue to Item 13.
13. ls your employer a labor union?

D Yes - Your employer does not qualify.
5. Employment Begin Date:
D No-Continue to Item 14.
14. Indicate which service or services your employer
6. Employment End Date: provides and then continue to Section 4, if
appropriate:
OR - Emergency management
LI Still Employed Military service {See Section 6)
7. Employment Status: D Full-Time D Part-Time _ Public safety
8. Hours Per Week (Average)

= Law enforcement
Public interest legal services (See Section 6)
Include vacation, leave time, or any leave taken
Early childhood education (See Section 6)
under the Family Medical Leave Act of 1993. lfyour
employer 1sa 501 (c)(3) or a not-for-profit organization,
do not include any hours you spent on religious
= Public service for individuals with disabilities
- Public service for the elderly
Instruction, worship services, or proselytizing.
9. Is your employer a governmental organization?

= Public health (See Section 6)
Public education (See Section 6)
A governmental organization is a Federal, State,
Public library services
local, or Tribal government organization, agency, or
entity, a public child or family service agency, a Tribal
college or university, or the Peace Corps or
= School library services
- Other school-based services
AmeriCorps.
D Yes - Skip to Section 4. - None of the above -your employer does not
qualify.
D No - Continue to Item 10.
SECTION 4: EMPLOYER CERTIFICATION (TO BE COMPLETED BY THE EMPLOYER)

By signing, I certify that the information in Section 3 is true, complete, and correct to the best of my knowledge and belief
and that I am an authorized official (see Section 6) oft he organization named in Section 3. Complete the rest of this Section.
Note: If any of the information is crossed out or altered in Section 3, you must initial those changes.
Authorized Official's Name Authorized Official's Phone
----------
Autho n zed Official's Title Authorized Official's Email
Authorized Official's Signature Date

-------------- --------
Page2 of 6
PRe.aa' Employment Certification Review Manual

SECTION 5: INSTRUCTIONS FOR COMPLETING THE FORM

You may submit information about multiple employers by submitting one copy of Sections 1 and 2 (Page 1), and one copy of
Sections 3 and 4 (Page 2) per employer. When completing this form, type or print using dark ink Enter dates as month-day-
year (mm-dd-yyyy). Use only numbers. Example: March 14, 2016 = 03-14-2016. If any information 1scrossed out or altered in
Section 3, it must be initialed by your employer. For more information about PSLFand how to use this form, visit
StudmtAirl.gov/puhlics0rv1rC'. Return the completed form to the address shown in Section 7.
SECTION 6: DEFINITIONS
AmeriCorps position means a position approved by the Peace Corps position means a full-time assignment
Corporation for National and Community Service under under the Peace Corps Act as provided for under 22 U.S.C.
Section 123 of the National and Community Service Act of 2504.
1990 (42 U.S.C.12573). Public education includes services that provide
An authorized official is an official of a public service educational enrichment or support directly to students or
organization (including AmeriCorps or the Peace Corps) their families in a school or a school-like setting.
who has access to the borrower's employment or service Public Interest legal services refers to legal services
records and is authorized by the public service organization that are funded in whole or in part by a local, State, Federal,
to certify the employment status of the organization's or Tribal government.
employees or former employees, or the service of Public health includes nurses, nurse practitioners,
AmeriCorps or Peace Corps volunteers. nurses in a clinical setting, and full-time professionals
Eligible loans are loans that are not in default and made engaged in hcJ th cJrc prJctitioner occupJtions and hcJ th
under the William D. Ford Federal Direct Loan (Direct Loan) support orrnpat1om, as such terms are defined by the
Program. Bureau of Labor Statistics.
Early childhood education includes licensed or A public service organization is a private not-for-profit
regulated child care, Head Start, and State funded pre- organization that is not a labor union or a partisan political
kindergarten. organization and that provides at least one of the following
An employee means an individual who is hired and paid public services: ( 1} emergency management. (2) military
by the organization. service, (3) public safety, (4) law enforcement, (5) public
Full-time means working in qualifying employment in interest legal services, (6) early childhood education, (7)
one or more jobs for the greater of: (1) An annual average of public service for individuals with disabilities and the
at least 30 hours per week or. for a contractual or elderly, (8) public health, (9) public education, (1 OJpublic
employment period of at least 8 months, an average of 30 library services, (11) school library services, or (12) other
hours per week; or (2) Unless the qualifying employment is school-based services.
with two or more employers, the number of hours the Qualifying payments are separate, on-time, full monthly
employer considers full time. payments made on a Direct Loan after October 1, 2007
Government includes a Federal, State, local or Tribal under a qualifying repayment plan.
government organization. agency or entity; a public child or Qualifying employment includes employment by the
family service agency; or a Tribal college or university. government, employment by a not-for-profit organization
An on-time payment is a payment made no more than that is tax-exempt under Section 501 (c)(3) of the Internal
15 days after the due date for the payment. Revenue Code, AmeriCorps position, a Peace Corps position,
law enforcement means service performed by an or employment at a public service organization.
employee of a public service organization that is publicly Qualifying repayment plans include the Revised Pay As
funded and whose principal activities pertain to crime You Earn (REPAYE}plan, the Pay As You Earn (PAYE) plan,
prevention, control or reduction of crime, or the the Income-Based Repayment (IBR)plan, the Income-
enforcement of criminal law. Contingent Repayment (ICR)plan, the 10-Year Standard
Military service means service on behalf of the U.S. Repayment plsn (Standard Repayment plan with a
Armed Forces or the National Guard performed by an maximum 10-year repayment period), and any other Direct
employee of a public service organization. Loan repayment plan, but only 1fpayments are at least equal
to the monthly payment amount that would be required
under the Standard Repayment plan with a 10-year
repayment period.
Page 3 of6
PRe.aa~ Employment Certification Review Manual


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OBTAINED BY STUDENT BORROWER PROTECTION CENTER AND AMERICAN FEDERATION OF TEACHERS UNDER THE FREEDOM OF INFORMATION ACT

We also need to forward American Public Transportation Association to OGCfor review. We

WP. will st;irt our rP.VIP.V,'

From: Kimberly A Myers [mailto:[email protected]] On Behalf Of Fedloan PSLF

Hi Tanekal This one is a borrower dispute, so we are forwarding for review.

Password is the same as the previous employer I forwarded over. Thanks!

From: Wast1ington Aaron

Call me when you can to discuss.

From: Arnold, Nathan

Let me know if I'm just confusing things or if I can be of further help

From: Washington, Aaron

From: Edmondson, Samantha [mailto:[email protected]]

Hi Nathan & Aaron,

Any insight would be greatly appreciated!

From: Kimberly A Myers <[email protected]>

From '"Foss. Ian'" <[email protected]>

To Kimberly A Myers <[email protected]>

C~ Diane Freundel <[email protected]>, "Chialastn. Taneka" <[email protected]>

C~llc 04113/2016 08:42 AM

SL,,;.ecl [external]Re. PSLF - American Bar Association

This is very helpful. Thank you!

One last request (for now).

On Apr 11, 2016, at 15:45, Kimberly A Myers <[email protected]> wrote:

From '"Foss. Ian" <Ian [email protected]>

To "'Kimberly A Myers"' <kmyers@pheaa org>

C~ Diane Freundel <[email protected]>, '"Chialastn. Taneka"' <[email protected]>

C~llc 04108/2016 02:56 PM

SL,,;.ecl [external]RE: RE. PSLF -American Bar Association

From: Kimberly A Myers [mailto:kmyers@J;Jheaa.org]

From '"Chralastri, Taneka"' <Taneka Chralastrr@ed gov>

From: Foss, Ian

From: Kimberly A Myers <[email protected]> on behalf of Fed Loan PSLF

fo Fedloan PSLF <[email protected]>

Dc1l~ 08/08/2016 04:08 PM

SL,8_cct [external]RE: Students First

From: Kimberly A Myers (mailto:[email protected]] On Behalf Of Fedloan PSLF

Subject: Students First

Hi Taneka! This one is a little complicated.

Password to follow. Thanks I

From: Foss Ian

Can you look at this?

Begin forwarded message:

From: "Gold, Stephanie J." <[email protected]>

Thank you for your consideration.

Hogan Lovells US LLP

Tel -1 202 637 5600

!-'lease consm'cr //10 cnvrromncnt before pm1t111pth:s c ma.'i

About Hogan Lovells

From: Chialastri Taneka

I'm in another meeting n1be about 5 minutes late.

From: Foss Ian

From: Kimberly A Myers on behalf of Fedloan PSLF

From: KimberlyA MYArSon behalf of FedLoan PSLF

From: Kimberly A Myers <[email protected]> on behalf of Fed Loan PSLF<[email protected]>

Password to follow. Thanks!

From: Kane Rachel

Got it, thanks'

From: Tiongquico, Rene

Anolher PSLFloans issue lor our PLI-OPE call.