1 unchanged sentence
SLM Corporation, more commonly known as Sallie Mae, is the premier financial brand in higher education.
−Removed: As an education solutions company, our mission is to power confidence as students begin their unique journeys.
+Added: As an education solutions company, we provide students and their families with the products and services needed to confidently and successfully navigate their higher education journey.
We support students and families navigating to, through, and immediately after higher education.
22 unchanged sentences
1 “ Education pays, 2024,” Career Outlook , U.S.
−Removed: Bureau of Labor Statistics, August 2024.
+Added: Bureau of Labor Statistics, May 2025.
2 https://research.collegeboard.org/trends/education-pays.
The information contained on, or accessible through, the foregoing website does not constitute a part of, and is not incorporated by reference in, this Annual Report on Form 10-K.
−Removed: 2024 Form 10-K — SLM CORPORATION 5
+Added: 4 SLM CORPORATION — 2025 Form 10-K
Our business is focused and aligned to strategic imperatives that set the foundation for our continued success.
−Removed: Our focus remains on maximizing the profitability and growth of our core private student loan business, while harnessing and optimizing the power of our brand and attractive client base.
−Removed: In addition, we continue to seek to better inform the external narrative about student lending and Sallie Mae.
−Removed: We also strive to maintain a rigorous and predictable capital allocation and return program to create shareholder value.
−Removed: We are focused on driving a mission-led culture that continues to make Sallie Mae a great place to work.
−Removed: We also continue to strengthen our risk and compliance functions, enhance and build upon our risk management framework, and assess and monitor enterprise-wide risk.
+Added: Our focus is driving innovation to maximize the sustainable growth and profitability of our core private student loan business.
+Added: Additionally, we aim to accelerate the growth of new lines of business to attract more customers requiring our products and services.
+Added: We are also focused on building the data infrastructure, technology, and talent required to compete in a digital world.
+Added: We seek to create a customer-centric brand as an education solutions company that supports students and families through their higher education journey.
+Added: We are focused on driving greater internal commitment to our mission, brand, and strategy, while we evolve our structure and risk capabilities to support our core private student loan business and emerging new businesses.
Private Education Loans
10 unchanged sentences
There is generally also a “mini-peak” in volume of originations and commitments in the first quarter of our fiscal year, corresponding to the required timing of disbursements prior to the start of the spring semester at most higher education institutions.
+Added: Similarly, we also experience cyclicality with respect to when borrowers are scheduled to exit their applicable grace period and enter full principal and interest repayment status, with the largest volume generally happening in our fourth fiscal quarter, and a smaller wave occurring in our second fiscal quarter.
Our primary Private Education Loan product is the Smart Option Student Loan, which emphasizes in-school payment features that can produce shorter terms and reduce customers’ total finance charges.
8 unchanged sentences
These include the Sallie Mae Law School Loan, the Sallie Mae MBA Loan, the Sallie Mae Graduate School Loan for Health Professions, the Sallie Mae Medical School Loan, the Sallie Mae Dental School Loan, and the Sallie Mae Graduate School Loan.
−Removed: These products were designed to address the specific needs of graduate students, such as longer grace periods for medical students.
+Added: These products were designed to address the specific needs of graduate students.
We also offer two non-cost of attendance loans to support bar study preparation, as well as residency and relocation expenses for medical and dental school students.
+Added: In 2025, we launched the Airline Career Loan which is tailored to the unique needs of students pursuing professional pilot program certificates.
+Added: 2025 Form 10-K — SLM CORPORATION 5
We regularly review and update the terms of our Private Education Loan products.
1 unchanged sentence
We manage this risk by underwriting and pricing based on customized credit scoring criteria and the addition of qualified cosigners.
−Removed: For Private Education Loans originated during the year ended December 31, 2024, our average FICO scores (representing the higher credit scores of the cosigners or borrowers) at the time of original approval were 752, and approximately 90 percent of
−Removed: 2024 Form 10-K — SLM CORPORATION 6
−Removed: those loans were cosigned.
+Added: For Private Education Loans originated during the year ended December 31, 2025, our average FICO scores (representing the higher credit scores of the cosigners or borrowers) at the time of original approval were 755, and approximately 92.8 percent of those loans were cosigned.
In addition, for all loans other than Bar Study loans and Residency and Relocation loans, we require school certification of both the need for, and the amount of, every Private Education Loan we originate (to prevent unnecessary borrowing beyond a school’s cost of attendance), and we disburse the loan proceeds directly to the higher education institutions to ensure loan proceeds are applied directly to the student’s education expenses.
1 unchanged sentence
Our on-campus efforts with more than 2,100 higher education institutions are actively managed by our relationship management team, the largest in the industry, which has become a trusted resource for financial aid offices.
−Removed: Our loans are high credit quality and the overwhelming majority of our customers manage their payments with great success.
+Added: Our loans are of high-credit quality, and the overwhelming majority of our customers manage their payments with great success.
Private Education Loans in repayment include loans on which customers are making interest only or fixed payments, as well as loans that have entered full principal and interest repayment status after any applicable grace period.
4 unchanged sentences
At December 31, 2025, the Bank had total assets of $29.7 billion, including $20.4 billion of Private Education Loans (held for investment), net, and total deposits of $21.5 billion.
−Removed: Previously, the Bank also owned a portfolio of loans insured or guaranteed under the previously existing Federal Family Education Loan Program (“FFELP Loans”).
−Removed: In the fourth quarter of 2024, the Bank sold its remaining portfolio of FFELP Loans to an unaffiliated third party.
−Removed: As of December 31, 2024, the Bank held no FFELP Loans.
Our ability to obtain deposit funding and offer competitive interest rates on deposits will be necessary to sustain our Private Education Loan originations and achieve other business goals.
5 unchanged sentences
“Business — Supervision and Regulation — Regulation of Sallie Mae Bank” for additional details about the Bank.
−Removed: 2024 Form 10-K — SLM CORPORATION 7
+Added: Strategic Partnerships and Loan Program Management
+Added: In 2025, we announced our first private credit strategic partnership.
+Added: This new funding model allows us to establish a capital-light, fee-based revenue strategy that complements our core private student loan business.
+Added: Under our strategic partnership (and any future partnerships that we may enter into), we intend to sell Private Education Loans while maintaining the relationships with customers, retaining servicing for the sold loans, and earning ongoing fees for providing servicing and program management, including industry expertise.
+Added: We expect strategic partnerships to expand our access to scalable and capital efficient funding through innovative structures, while strengthening our loan originations capacity and ability to serve students families.
+Added: 6 SLM CORPORATION — 2025 Form 10-K
Our Lending Philosophy
39 unchanged sentences
• an integrated platform with customer-centric capabilities that allows self-service and empowers our servicing and collections agents, thus streamlining our processes and providing efficiencies;
−Removed: • an online chat function for application support and customer service related inquiries;
+Added: • an online chat function for application support, customer service, and collections related inquiries;
• a mobile application accessible through smart phones;
10 unchanged sentences
(“Scholly”), which was engaged in the business of operating as a scholarship publishing and servicing platform, comprised of websites and mobile application search products that offered custom recommendations for post-secondary scholarships for students, their families, and others as well as related services for scholarship providers.
−Removed: The addition of Scholly assets supports our mission of providing students with the confidence needed to successfully navigate the higher education journey.
−Removed: 2024 Form 10-K — SLM CORPORATION 9
+Added: Scholly supports our mission of providing students with the confidence needed to successfully navigate the higher education journey.
+Added: 8 SLM CORPORATION — 2025 Form 10-K
Key Drivers of Private Education Loan Market Growth
2 unchanged sentences
The amounts students and their families can contribute toward college costs and the availability of scholarships and institutional grants are also important.
−Removed: If the cost of education increases at a pace exceeding the sum of family income, savings, federal lending, and scholarships, more students and families can be expected to rely on Private Education Loans.
+Added: If the cost of education increases at a pace exceeding the sum of family income, savings, federal lending, and scholarships, or the availability of federal education loans, grants, or subsidies and scholarships significantly decrease, more students and families can be expected to rely on Private Education Loans.
If enrollment levels or college costs decline, or the availability of federal education loans, grants, or subsidies and scholarships significantly increases, Private Education Loan demand could decrease.
−Removed: We focus primarily on students attending public and private not-for-profit four-year degree granting institutions.
+Added: Traditionally, we have focused primarily on students attending public and private not-for-profit four-year degree granting institutions.
We lend to some students attending two-year and for-profit schools.
3 unchanged sentences
We expect students who attend and complete programs at for-profit schools to support the same repayment performance as students who attend and graduate from public and private not-for-profit four-year degree granting institutions.
−Removed: Our competitors 1 in the Private Education Loan market include large banks such as Citizens Financial Group, Inc.
−Removed: and PNC Bank, as well as a number of specialty finance companies such as Sofi Technologies, Inc.
+Added: As discussed in more detail in Item 1.
+Added: “Business — Supervision and Regulation — Overview”, certain reforms to the federal student loan program have been enacted into law and will become effective for new borrowers beginning July 1, 2026.
+Added: We anticipate that these changes to the federal student loan program, which establish caps on certain federal student loan programs and eliminate certain federal graduate student loan programs, will increase demand for Private Education Loans, particularly for graduate students and parents.
+Added: As part of our origination expansion initiative, we are working to expand our product offerings and originations capabilities to be ready for this anticipated increase in demand.
+Added: Our primary competitors 1 in the Private Education Loan market include large banks and specialty finance companies such as Citizens Financial Group, Inc., PNC Bank, Sofi Technologies, Inc.
and College Ave, and members of the Education Finance Council.
We compete based on our products, originations capability, price, and customer service.
−Removed: We expect enrollment to remain relatively flat over the next several years.
−Removed: Enrollment at Four-Year Degree Granting Institutions 2
+Added: ______________________
+Added: Enterval Analytics LLC Q3 2025 Private Student Loan Semi Annual Report, January 2026.
+Added: 2025 Form 10-K — SLM CORPORATION 9
+Added: According to the College Board’s study, the full-time equivalent enrollment for undergraduate and graduate students has remained relatively flat since 2020/2021.
+Added: 2 We expect that trend to continue over the next several years.
+Added: Full-Time Equivalent Enrollment 2
(in millions)
−Removed: • According to the U.S.
−Removed: Department of Education’s projections, the enrollment in four-year degree granting institutions is projected to remain relatively flat through 2031.
______________________
−Removed: Enterval Analytics LLC 2024 Q3 Private Student Loan Report, November 2024.
−Removed: Department of Education, National Center for Education Statistics, Enrollment in Degree-Granting Institutions Projection Model, through 2031.
+Added: The College Board-Trends in College Pricing 2025.
+Added: © 2025 The College Board.
These are the most recent sources available to us for this information.
2024/2025 is an estimate.
−Removed: 2024 Form 10-K — SLM CORPORATION 10
+Added: 10 SLM CORPORATION — 2025 Form 10-K
Tuition Rates
8 unchanged sentences
Sources of Funding
−Removed: Private Education Loan originations were an estimated $11.5 billion in AY 2023-2024, an increase of $0.5 billion from AY 2022-2023.
+Added: Private Education Loan originations were an estimated $11.5 billion in AY 2024-2025, consistent with an estimated $11.5 billion of Private Education Loan originations in AY 2023-2024.
The College Board-Trends in Student Aid 2025© The College Board.
4 unchanged sentences
We rely on publicly available sources for market estimates, because we believe it provides a more appropriate basis for comparison of the performance of our business.
−Removed: 2024 Form 10-K — SLM CORPORATION 12
+Added: 12 SLM CORPORATION — 2025 Form 10-K
We estimate total spending on higher education was $536 billion in AY 2024-2025, up from $466 billion in AY 2020-2021.
−Removed: Private Education Loan originations decreased $1 billion from the year-ago period to an estimated $13 billion in AY 2023-2024, and represent just 2.6 percent of total spending on higher education.
+Added: Private Education Loan originations increased $1 billion from the year-ago period to an estimated $14 billion in AY 2024-2025 and represent just 2.6 percent of total spending on higher education.
Over the AYs 2020-2025 period, increases in total spending have been absorbed primarily through increased family contributions.
14 unchanged sentences
These descriptions are qualified in their entirety by reference to the full text of the applicable statutes, legislation, regulations, and policies, as they may be amended, and as interpreted and applied, by federal, state, and local agencies.
−Removed: The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”) was adopted to reform and strengthen regulation and supervision of the U.S.
−Removed: financial services industry.
−Removed: It contains comprehensive provisions to govern the practices and oversight of financial institutions and other participants in the financial markets.
−Removed: It mandates significant regulations, additional requirements, and oversight on almost every aspect of the U.S.
−Removed: financial services industry, including increased capital and liquidity requirements, limits on leverage, and enhanced supervisory authority.
−Removed: It requires the issuance of many regulations, which will take effect over several years.
+Added: Federal law establishes requirements and mandates oversight on almost every aspect of the U.S.
+Added: financial services industry, including consumer protection laws and regulations, capital and liquidity requirements, limits on leverage, and enhanced supervisory authority.
Additionally, states are taking an increased interest in directly regulating the conduct and practices of student loan lenders and servicers.
1 unchanged sentence
This represents a significant change from the past in which states generally did not issue laws and regulations tailored specifically to the student loan origination and servicing industry.
+Added: Passage of H.R.1
+Added: The passage of H.R.1 in July 2025 (“H.R.1.”) introduced significant changes to federal student loan programs, effective July 1, 2026, with limited grandfathering for existing borrowers.
+Added: Key changes to federal student loan programs and repayment options under H.R.1 include:
+Added: • the elimination of Grad PLUS loans for graduate students;
+Added: • the capping of Parent PLUS loans at $20,000 annually and $65,000 lifetime per student;
+Added: • new Graduate loan limits of $20,500 annually ($100,000 lifetime) for non-professional degrees and $50,000 annually ($200,000 lifetime) for professional degrees;
+Added: • new universal lifetime borrowing cap across all federal programs;
+Added: • an overhaul of the federal student loan repayment structure including the introduction of the Repayment Assistance Plan (RAP), requiring payments of 1%–10% of adjusted gross income, with forgiveness after 30 years;
+Added: • a phase-out of existing income-driven repayment plans (e.g., SAVE, PAYE, ICR) by July 1, 2028;
+Added: • stricter forbearance and deferment provisions.
Consumer Protection Laws and Regulations
6 unchanged sentences
• the Equal Credit Opportunity Act and Regulation B, which prohibit creditor practices that discriminate on the basis of race, religion, and other prohibited factors in extending credit;
+Added: 14 SLM CORPORATION — 2025 Form 10-K
• the Servicemembers Civil Relief Act, which applies to all debts incurred prior to commencement of active military service (including education loans) and limits the amount of interest, including fees, that may be charged;
4 unchanged sentences
• the Telephone Consumer Protection Act, which governs communication methods that may be used to contact customers;
−Removed: 2024 Form 10-K — SLM CORPORATION 14
• the Gramm-Leach-Bliley Act, which governs the ability of financial institutions to disclose nonpublic information about consumers to non-affiliated third parties;
1 unchanged sentence
Consumer Financial Protection Bureau
+Added: The CFPB is the Bank’s primary consumer compliance supervisor with compliance examination authority and primary consumer protection enforcement authority.
The CFPB has broad authority to promulgate regulations under federal consumer financial protection laws and to directly or indirectly enforce those laws, including providing regulatory oversight of the Private Education Loan industry, and to examine financial institutions for compliance.
1 unchanged sentence
It has authority to prevent unfair, deceptive, or abusive acts and practices by issuing regulations or by using its enforcement authority without first issuing regulations.
−Removed: Under the Biden Administration, the CFPB was active in its supervision, examination, and enforcement of financial services companies, notably bringing enforcement actions, imposing fines, and mandating large refunds to customers of several large banking institutions.
−Removed: The enforcement and regulatory posture of the CFPB under the Trump Administration is unclear.
−Removed: The CFPB is the Bank’s primary consumer compliance supervisor with compliance examination authority and primary consumer protection enforcement authority.
−Removed: The UDFI and FDIC remain the prudential regulatory authorities with respect to the Bank’s financial strength.
The Private Education Loan Ombudsman within the CFPB is authorized to receive and attempt to informally resolve inquiries about Private Education Loans.
The Private Education Loan Ombudsman is required by law to report to Congress annually on the trends and issues identified through this process.
−Removed: The CFPB continues to take an active interest in the student loan industry, undertaking a number of initiatives related to the private education loan market and student loan servicing.
−Removed: The CFPB and the U.S.
−Removed: Department of Education share complaint information from borrowers and meet quarterly to discuss, among other things, the nature of complaints received and available information about the resolution of complaints.
+Added: The CFPB recently indicated its intent to deemphasize student loans in its supervision and examination priorities going forward.
+Added: Further, the operational, enforcement and regulatory posture of the CFPB under the current federal administration is currently unclear.
Regulation of Sallie Mae Bank
5 unchanged sentences
Numerous other federal and state laws and regulations govern almost all aspects of the operations of the Bank and, to some degree, our operations and those of our non-bank subsidiaries as institution-affiliated parties.
+Added: 2025 Form 10-K — SLM CORPORATION 15
Actions by Federal and State Regulators
1 unchanged sentence
Under this authority, the Bank’s regulators can require it to enter into informal or formal supervisory agreements, including board resolutions, memoranda of understanding, written agreements, and consent or cease and desist orders, pursuant to which the Bank would be required to take identified corrective actions to address cited concerns and refrain from taking certain actions.
−Removed: 2024 Form 10-K — SLM CORPORATION 15
Enforcement Powers of Regulators
3 unchanged sentences
Regulators have flexibility to commence enforcement actions against institutions and institution-affiliated parties, and the FDIC has the authority to terminate deposit insurance.
−Removed: When issued by a banking agency, cease and desist and similar orders may, among other things, require affirmative action to correct any harm resulting from a violation or practice, including by compelling restitution, reimbursement, indemnifications, or guarantees against loss.
+Added: When issued by a banking agency, cease and desist and similar orders may, among other things, require affirmative action to correct any harm resulting from a violation or practice, including by compelling restitution, reimbursement, indemnification, or guarantees against loss.
A financial institution may also be ordered to restrict its growth, dispose of certain assets, rescind agreements or contracts, or take other actions determined to be appropriate by the ordering agency.
14 unchanged sentences
The Company may change its common stock dividend policy at any time.
−Removed: We expect that the Bank will pay dividends to the Company as may be necessary to enable the Company to pay any declared dividends on its Series B Preferred Stock and common stock and to consummate any common share repurchases by the Company under the Company’s share repurchase programs.
+Added: We expect that the Bank will pay dividends to the Company as may be necessary to enable the Company to pay any declared dividends on its Series B Preferred Stock and common stock and to consummate any common
+Added: 16 SLM CORPORATION — 2025 Form 10-K
+Added: share repurchases by the Company under the Company’s share repurchase programs.
The Bank declared $700 million, $570 million, and $550 million in dividends for the years ended December 31, 2025, 2024, and 2023, respectively, with the proceeds primarily used to fund share repurchase programs and stock dividends.
−Removed: Our Board of Directors has authorized share repurchase programs during prior years, the most recent of which occurred in January 2024 (for a program of up to $650 million of common stock).
+Added: Our Board of Directors has authorized share repurchase programs during prior years, including a share repurchase program which was approved in January 2024 (for a program of up to $650 million of common stock).
+Added: As of December 31, 2025, we had $33 million of capacity remaining under the 2024 Share Repurchase Program (as hereinafter defined).
+Added: The 2024 Share Repurchase Program expired on February 6, 2026.
+Added: On January 22, 2026, we announced a new share repurchase program (the “2026 Share Repurchase Program”), which became effective on January 22, 2026 and is expected to be completed over the next approximately 24 months ending on February 4, 2028.
+Added: The 2026 Share Repurchase Program permits us to repurchase shares of our common stock from time to time in various transaction formats including, but not limited to, tender offers, open market purchases, accelerated share repurchases, negotiated or block purchases, and/ or pursuant to trading plans in accordance with Rules 10b5-1 and 10b-18 of the Securities and Exchange Act of 1934, as amended (the “Exchange Act”), up to an aggregate repurchase price not to exceed $500 million.
Under the share repurchase programs, purchases take place as and when we determine in open market or private transactions made based upon the market price of our common stock, the nature of other investment opportunities or growth projects, our cash flows from operations, and general economic conditions.
−Removed: The share repurchase programs do not require us to acquire any specific number of shares, and may be modified, suspended, extended, or terminated by us at any
−Removed: 2024 Form 10-K — SLM CORPORATION 16
+Added: The share repurchase programs do not require us to acquire any specific number of shares, and may be modified, suspended, extended, or terminated by us at any time.
We repurchased 12.8 million and 11.6 million shares during the years ended December 31, 2025 and 2024, respectively.
−Removed: As of December 31, 2024, we had $402 million of capacity remaining under the 2024 Share Repurchase Program (as hereinafter defined).
See Notes to the Consolidated Financial Statements, Note 13, “Stockholders’ Equity” in this Form 10-K for additional information.
16 unchanged sentences
Assessment rates for insured banks also are subject to adjustment depending on a number of factors, including significant holdings of brokered deposits in certain instances and the issuance or holding of certain types of debt.
+Added: 2025 Form 10-K — SLM CORPORATION 17
With respect to brokered deposits, an insured depository institution must be well capitalized under the prompt corrective action framework in order to accept, renew, or roll over such deposits without FDIC clearance.
11 unchanged sentences
Any loan by us to the Bank would be subordinate in right of payment to depositors and to certain other indebtedness of the Bank.
−Removed: 2024 Form 10-K — SLM CORPORATION 17
Community Reinvestment Act
2 unchanged sentences
Failure to adequately meet these criteria could result in additional requirements and limitations on the Bank.
−Removed: The Bank has received a CRA rating of Outstanding.
+Added: The Bank received a CRA rating of Outstanding on its most recent review.
Data Privacy and Data Security Laws and Regulations
4 unchanged sentences
The privacy regulations also restrict information sharing among affiliates for marketing purposes and govern the use and provision of information to consumer reporting agencies.
−Removed: Federal and state banking agencies have adopted regulations for maintaining the security and confidentiality of consumer information, and the Bank is subject to such regulations, as well as certain federal and state laws or regulations for notifying consumers in the event of a security breach.
+Added: Federal and state banking agencies have adopted regulations for maintaining the security and confidentiality of consumer information, and the Bank is subject to such regulations, as well as certain federal and state laws or regulations for notifying consumers or governmental agencies in the event of a security breach.
In addition, we must comply with increasingly complex and rigorous data privacy and data security laws and regulations enacted or adopted to protect business and personal information.
3 unchanged sentences
At the state level, California passed the California Consumer Privacy Act (the “CCPA”), which became effective on January 1, 2020, and the California Privacy Rights Act (the “CPRA”), which expands upon the CCPA and brought additional compliance obligations with respect to certain processing of personal information of California residents once it came into effect in most material respects on January 1, 2023.
−Removed: The CCPA and CCRA apply to for-profit businesses that conduct business in California and meet certain revenue or data collection thresholds.
−Removed: The CCPA and CCRA contain several exemptions, including an exemption applicable to information that is collected, processed, sold, or disclosed pursuant to the GLBA.
−Removed: However, the definition of personal information is expanded under the California statutes to apply to certain data beyond the scope of the GLBA exemption.
−Removed: Additionally, numerous other states have enacted or are in the process of enacting state-level data privacy and data security laws and regulations relating to the collection, storage, handling, use, disclosure, transfer, security, and other processing of personal information.
+Added: The CCPA and CPRA apply to for-profit businesses that conduct business in California and meet certain revenue or data collection thresholds.
+Added: The CCPA and CPRA contain several exemptions, including an exemption applicable to information that is collected, processed, sold, or disclosed pursuant to the GLBA.
+Added: However, the definition of personal information is expanded under the California statutes to apply to certain data
+Added: 18 SLM CORPORATION — 2025 Form 10-K
+Added: beyond the scope of the GLBA exemption.
+Added: Additionally, numerous other states have enacted or are in the process of enacting state-level data privacy and data security laws and regulations relating to the collection, storage, handling, use, disclosure, transfer, security, and other processing of personal information, including the personal information of minors in some cases.
+Added: Further, laws in all 50 U.S.
+Added: states require businesses to provide notice under certain circumstances to consumers whose personal information has been disclosed as a result of a data breach.
Misuse of or failure to secure certain personal information could result in violation of data privacy or data security laws and regulations, proceedings against the Company by governmental entities or others, damage to our reputation and credibility, and could negatively affect our business, financial condition, and results of operations.
1 unchanged sentence
adopt similar laws or if a comprehensive federal data privacy or data security law is enacted, or if regulators whose authority we are subject to adopt additional or amend existing data privacy or data security regulations, we may expend considerable additional resources to meet these requirements and the overall risk to the Company could incrementally increase depending upon the reach and application of any such laws or regulations.
−Removed: State Regulation of Student Loan Lenders and Servicers
−Removed: In certain states, laws regulating the conduct of student loan lenders and servicers may apply to and impact the origination and servicing practices of the Bank.
+Added: State Regulation of Student Loan Lenders, Holders, and Servicers
+Added: In certain states, laws regulating the conduct of student loan lenders, holders, and servicers may apply to and impact the origination, holding, and servicing practices of the Bank and/or other Company subsidiaries.
While these state laws vary in content, they generally include components relating to licensure and oversight by state authorities and the creation of specialized student loan ombudsman offices to oversee the student loan industry operating within these states.
−Removed: These laws may also include requirements pertaining to payment processing, customer communications, the handling of customer inquiries and complaints, information concerning loan repayment options, access to borrower account records, the processing of disability applications and borrower requests to remove cosigners from loans, and debt collection, among other
−Removed: 2024 Form 10-K — SLM CORPORATION 18
−Removed: requirements.
+Added: These laws may also include requirements pertaining to registration, reporting, payment processing, customer communications, the handling of customer inquiries and complaints, information concerning loan repayment options, access to borrower account records, the processing of disability applications and borrower requests to remove cosigners from loans, and debt collection, among other requirements.
Notably, these laws often include provisions for enforcement of alleged violations by state regulators as well as private litigation by aggrieved consumers.
15 unchanged sentences
For any securitizations that are treated as off-balance sheet, including any loan sale transactions structured as securitizations, we comply with the Dodd-Frank risk retention rules by retaining (for a requisite period) an “eligible vertical interest” comprised of a five percent interest in each class of ABS interests issued in any such transaction;
−Removed: for future off-balance securitizations, we may also comply with the Dodd-Frank risk retention rules by retaining (for a requisite period) a single interest entitling the holder to five percent of any amounts payable by the trustee in respect of each interest issued by the issuing trust.
+Added: for future off-balance securitizations, we may comply with the Dodd-Frank risk retention rules in a different manner.
+Added: 2025 Form 10-K — SLM CORPORATION 19
Anti-Money Laundering, the USA PATRIOT Act, and U.S.
Economic Sanctions
−Removed: The USA PATRIOT Act of 2001 (the “USA Patriot Act”), which amended the Bank Secrecy Act, substantially broadened the scope of United States anti-money laundering laws and regulations by imposing significant new compliance and due diligence obligations, creating new crimes and penalties, and expanding the extra-territorial jurisdiction of the United States.
−Removed: Treasury Department has issued a number of regulations that apply various requirements of the USA Patriot Act to financial institutions such as the Bank.
−Removed: These regulations impose obligations on financial institutions to maintain appropriate internal policies, procedures, and controls to detect, prevent, and report money laundering and terrorist financing and to verify the identity of their customers.
+Added: The Bank is subject to the reporting and recordkeeping requirements of the Bank Secrecy Act (“BSA”) and its implementing regulations.
+Added: The BSA was amended by the USA PATRIOT Act of 2001, which substantially broadened the scope of United States anti-money laundering laws and regulations by imposing significant new compliance and obligations, creating new crimes and penalties, and expanding the extra-territorial jurisdiction of the United States.
+Added: Treasury Department and federal banking regulators have issued a number of regulations that apply various requirements of the BSA to financial institutions such as the Bank.
+Added: The BSA and its implementing regulations impose obligations on financial institutions to, among other things, maintain internal policies, procedures, and controls to detect, prevent and report money laundering and terrorist financing and to maintain programs to verify the identity of their customers, among other requirements.
In addition, U.S.
law generally prohibits or substantially restricts U.S.
−Removed: persons from doing business with countries and territories that are the subject of comprehensive territorial sanctions designated by the U.S.
+Added: persons from doing business with countries and territories that are the subject of comprehensive territorial sanctions imposed by the U.S.
Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) or with persons that are the subject of sanctions administered by OFAC or other agencies.
+Added: OFAC sanctions programs also impose other restrictions on certain investments and dealings.
We maintain policies and procedures designed to ensure compliance with relevant U.S.
laws and regulations applicable to U.S.
−Removed: persons, including the Bank Secrecy Act, as amended, and its implementing regulations and U.S.
+Added: persons, including the BSA, as amended, and its implementing regulations and U.S.
economic sanctions.
3 unchanged sentences
These prohibitions are subject to a number of important exclusions and exemptions that, for example, permit insured depository institutions and their affiliates to trade for risk-mitigating hedging and liquidity management, subject to certain conditions and restrictions.
−Removed: The Volcker Rule
−Removed: 2024 Form 10-K — SLM CORPORATION 19
−Removed: does not have a meaningful effect on our current operations or those of our subsidiaries, as we do not materially engage in the businesses prohibited by the Volcker Rule.
+Added: The Volcker Rule does not have a meaningful effect on our current operations or those of our subsidiaries, as we do not materially engage in the businesses prohibited by the Volcker Rule.
Human Capital Resources and Talent Development
12 unchanged sentences
We also provide matching gifts for team members to support their interests and needs and those of their communities.
−Removed: 2024 Form 10-K — SLM CORPORATION 20
+Added: 20 SLM CORPORATION — 2025 Form 10-K
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.