Compliance is Our Expertise

So You Can Focus on Yours

Policy to Practice

Evidens Group, a certified women-owned small business (WOSB), is a consulting firm managed by individuals with extensive experience in providing policy clarification, guidance, training, and compliance review services to organizations dedicated to the education lending industry. We assist clients in successfully implementing and complying with the myriad of complex laws and regulations related to the origination, servicing, and collection of private and federal post-secondary education loans. In addition to our expansive knowledge of the Higher Education Act, which governs the Title IV loan programs, we possess expertise in the application of numerous federal and state consumer laws to education loan programs, such as servicer licensing, repayment disclosure, credit reporting, privacy, and electronic communication.

Our structured, reliable process provides clients with the tools and documentation needed to transform “policy to practice.” Please check out our policy analysis and compliance review services.

Contact Evidens Group to learn more about how we can be a valuable partner with your organization.

A Proven Track Record

We have significantly reduced our compliance-related costs since partnering with Evidens Group. Evidens Group’s “policy to practice” service allows us to focus on the operations and financial aspects of loan servicing and collections for FFELP and Direct loans as well as private loans. Evidens is constantly monitoring and analyzing the ever-changing laws and regulations applicable to our business and consulting with us on the application of such changes to ensure we remain fully compliant.

Brenda Cox

Chief Development Officer, UHEAA

Services

New Laws & Regulations

Evidens Group recognizes the value of timely and accurate analyses of enacted legislation, corresponding regulations, and governing agency guidance (collectively referred to as “policy changes”) that impact the servicing of private, Federal Family Education Loan Program (FFELP), and Federal Direct Loan Program (Direct) loan portfolios. Learn more about the laws for which we provide support.

Evidens Group can:

  • Monitor for pending and final policy changes in accordance with the laws listed below by:
    • Reviewing the Federal Register (published daily)
    • Reviewing notices published by various governing agencies
    • Reviewing notices in various trade publications that cover such topics as student loan policy changes, debt collection, privacy, and consumer protection
    • Participating in targeted, value-added industry associations and workgroups.
  • Provide written, detailed analyses of policy changes in an easy-to-understand manner. Each policy change includes the source of the change, the effective date, a plain-English description of the change, and a brief summary of the prior policy, if any.
  • Participate in internal teams to further explain policy changes and answer questions to enable effective, accurate assessments of servicing requirements.
  • Provide written assessments of implementation plans designed to ensure compliance, including a review of procedures, system changes, phone scripts, borrower correspondence, marketing materials, and web pages.

Compliance Review

Evidens Group realizes the valuable benefits that a customized, comprehensive compliance review provides to your organization’s leadership. Our compliance review services include the evaluation of existing operational policies, procedures, and practices applicable to your private and/or federal education loan portfolios in order to identify compliance with applicable statutes and regulations, including UDAAP (Unfair, Deceptive or Abusive Acts or Practices) violations highlighted by the Bureau of Consumer Financial Protection (BCFP). A detailed report is provided which highlights compliance gaps, weaknesses, and risk concerns along with recommendations for achieving compliance and/or improvement. Evidens Group can also assist in creating written policies, a necessary element of a Compliance Management System (CMS) required by the BCFP.

Ongoing Policy Analysis

Evidens Group understands the need to receive accurate and thorough analyses for the resolution of policy issues, improvement of internal procedures, implementation of new products or services for your private, FFELP and Direct loan portfolios.

Evidens Group can:

  • Respond to policy inquiries relating to situations that arise during the origination, servicing, and collection of private, FFELP and Direct loans.
  • Review process flows, borrower correspondence, web pages, phone scripts, brochures, presentations, etc., for new products and services to assess compliance.
  • Participate in project teams to present and explain applicable policy rules and provide written assessments of implementation plans, including a review of procedures, system changes, phone scripts, borrower correspondence, marketing materials, and web pages.
  • Provide policy training relative to new or existing private, FFELP and/or Direct loan policies.

Laws

Evidens Group’s breadth of knowledge and experience includes:

  • BAPCPA (Bankruptcy Abuse Prevention & Consumer Protection Act)
  • BSA (Bank Secrecy Act)
  • CAN-SPAM (Controlling the Assault of Non-Solicited Pornography & Marketing Act)
  • COPPA (Children’s Online Privacy Protection Act)
  • Dodd-Frank (Dodd-Frank Consumer Financial Protection Act)
  • ECOA (Equal Credit Opportunity Act)
  • E-SIGN (Electronic Signatures in Global & National Commerce Act)
  • FCRA (Fair Credit Reporting Act)
  • FDCPA (Fair Debt Collection Practices Act)
  • GLBA (Gramm-Leach-Bliley Act) and state security breach laws
  • HEA (Higher Education Act)
  • MLA (Military Lending Act)
  • SCRA (Servicemembers Civil Relief Act)
  • State student loan servicer licensing and borrower protection laws
  • TCPA (Telephone Consumer Protection Act)
  • TILA (Truth in Lending Act)
  • TRA (Taxpayer Relief Act)
  • USA PATRIOT Act (Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept & Obstruct Terrorism Act)

Leadership

Evidens Group is led by Elise Nowikowski, who began her career in the higher education lending industry in 1984 and has enjoyed collaborating with industry colleagues and federal policy personnel to influence federal student loan policymaking. Prior to forming Evidens Group, Elise worked for Nelnet, an industry leader in education lending. Given her nineteen-year tenure with Nelnet, Elise has extensive knowledge of the program policy rules applicable to origination, servicing, and collection of private and federal student loans. As a Managing Director at Nelnet, Elise was instrumental in establishing policy analysis processes which were cited as an industry best practice for providing consistent, timely, and accurate guidance to internal management. Elise began her career in the student loan industry as an auditor of a student loan portfolio. She served on the National Student Clearinghouse board for eight years and on the Student Loan Servicing Alliance (SLSA) board for twelve years.

Elise earned a bachelor’s degree in accounting and a master’s degree in business administration from the University of South Florida as well as a Certified Public Accountant (CPA) license from the state of Florida. She also obtained a master’s degree in organizational leadership from Bellevue University in Nebraska. Elise is a Certified Compliance and Ethics Professional and maintains her designation by earning the required continuing education units and attending the Society of Corporate Compliance and Ethics conference.

Elise Nowikowski

Elise Nowikowski

Principal

Ready to reduce compliance costs?

Call 904-527-3548 or contact us below.