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Financial Institution Letters

February 2, 2015

Guidance on Private Student Loans with Graduated Repayment Terms at Loan Origination

Printable Format:

FIL-6-2015 - PDF (PDF Help)


The agencies1, in conjunction with the State Liaison Committee (SLC), have issued Guidance on Private Student Loans with Graduated Repayment Terms at Loan Origination (Student Loan Guidance). The Student Loan Guidance recognizes that students leaving a higher education program may prefer more flexibility with their payments as they transition into the labor market. Financial institutions that originate private student loans with graduated repayment terms should prudently underwrite the loans and provide disclosures that clearly communicate the timing and the amount of payments to facilitate a borrower's understanding of the loan's terms and features.

Statement of Applicability to Institutions Under $1 Billion in Total Assets: This Financial Institution Letter applies to FDIC-supervised institutions that originate private student loans.



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FDIC Financial Institution Letters (FILs) may be accessed from the FDIC's Web site at

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Paper copies may be obtained through the FDIC's Public Information Center, 3501 Fairfax Drive, E-1002, Arlington, VA 22226 (877-275-3342 or 703-562-2200).

1 The agencies include the Board of Governors of the Federal Reserve System, the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency. The SLC is a member of the Federal Financial Institutions Examination Council.