September 2006

Footing the Tuition Bill: New Developments in the Student-Loan Industry and How They Are Changing the Way We Pay for Higher Education

Students and families can finance higher education in three ways: grants, government-backed loans, or private loans. Contemporary research and debate typically focus on grants and federally supported loans. Meanwhile, despite its explosive growth, the private loan market remains minimally researched and poorly understood. This made sense a decade ago, when the private college-loan market was marginal. Today, however, in an era marked by radical changes in the ranks of higher education providers, the makeup of the college-going population, and the availability and utilization of credit, it is time to look much more thoughtfully and imaginatively at the role of private loans.

AEI has launched a new research effort to examine the student-loan industry, the role it plays in higher education finance, and its implications on college access and affordability. AEI director of education policy Frederick M. Hess commissioned scholars and analysts to explore the industry, document its innovations, consider the promise and the peril of private loans, and contemplate the implications it will have on policymakers, students, and those who work in higher education. On September 25, AEI hosted a major public conference at which the research was presented and discussed.

Frederick M. Hess
AEI

With this conference and the subsequent edited volume of conference papers, AEI seeks to bring together both generalist education researchers, for whom much of the material is new, and those who have been engaged in the higher education financing sector for many years. To begin, access to and affordability of a college education is a matter of national policy partly because of the differing attitudes toward the benefits of higher education--is it a public or a private good? The system in place now was created in the late 1950s to address the policy problems of the time, serving a very different population of students with a very different cost of attendance. Yet national debate today still focuses on modifying the current anachronistic structures.

Policy conversations in this area take for granted several fundamental questions: What should college students pay? How can responsibility on the part of students, lenders, and colleges be fostered? Is the system that was created for a small population of college students equipped to handle the demand today? And, can reforms of other lending sectors, like the home loan sector, be useful in the area of college loans? Finally, this conference is intended to ask two broader questions: Can more be done to encourage entrepreneurship and nontraditional tools in order to accomplish the ends we all agree upon? And, if so, what would that entail?

Panel I: The Landscape of Student Loans

John R. Thelin
University of Kentucky

Discussing the history of this policy area and market is an appropriate beginning to the conference and volume. In the last few decades, students, parents, financial aid officers, and policymakers have all begun to discuss the financing of a college education using the term “packaging.” But historically, prior to the entrance of the federal government, colleges were preoccupied with finding enough capable and paying students; thus, student aid was a low priority. The GI Bill first introduced portable student grants, allowing both access and choice to higher education for a finite population of veterans. It was an unexpected policy success, but was not intended to be expanded for other populations of students. The National Defense Education Act of 1958 first emphasized loans, but with generous and flexible conditions for repayment, these loans resembled grantsmuch more closely than loans.

The reauthorization of the Higher Education Act in 1972 was a crucial moment in the sector, when, with very little partisan disagreement, the focus turned toward portable aid individualized for each student. A drift toward loans started to take place in late 1970s, with the Middle Income Student Assistance Act, which was a politically popular measure enacted during an election year. But no policymaker could foresee the rise of loans as the preeminent federal policy. It is important to remember that the primary goal of federal policy programs with respect to higher education is to increase access, choice, and affordability; the secondary goal, then, is the health of the student loan industry.

Andrew Rudalevige
Dickinson College

In 1965, President Lyndon B. Johnson argued that it was the obligation of the federal government to provide as much education to each individual as “he or she could take.” At the time, loans were not intended to be a large part of that commitment, and because the market for these loans was limited, the government provided subsidies for them. In higher education now, however, tuition has risen, state appropriations have fallen, and the student population has risen. This has created a “perfect storm” for increased lending. Student aid used to be a nonpartisan policy area; now it has become an area where the “politics of market-share” has created competition at each stage, heavy regulation, and fiscal pressures.

Various political interest groups have emerged in the sector: student groups, lenders, nonprofit and for-profit providers, and a diverse group of colleges and universities. The policy issues that have arisen include fixed versus variable interest rates, rates of return for lenders, consolidation, risk-sharing, loan limits, and the appropriate role for direct lending. But the system of structures and incentives in place now was built incrementally on an earlier paradigm, and it may not be sufficient for moving forward under the changed conditions for students, lenders, and providers.

Sarah Ducich
Sallie Mae

The student loan process has not been insulated from the budget process historically; in fact, some of the major policy changes to the system have come through the process. For example, many of the reforms of the Middle Income Student Assistance Act were ratcheted back with the Omnibus Budget Reconciliation Act of 1981. Because the federal budget process drives much of what goes on in the industry, landmines of hysteria and spin abound. The last decade has been transformational for the student loan industry; the amount of federal financial aid available to students has more than doubled in the last ten years, including grants, loans, and tax benefits. Because loan growth has come largely from the Stafford Unsubsidized Loan Program, the issue of “indebtedness” for students has come to the forefront. However, the increase in federal borrowing among students is inevitably linked to the increase in the cost of higher education. And tuition costs are impossible to address with federal intervention. Despite drastic increases in federal spending, college affordability has become less attainable. Thus, it seems impossible for the federal government to keep from falling further and further behind in aid while still providing more real money to students.

Terry Hartle
American Council on Education

The federal student loan industry is enormously complex, filled with confusing politics and many budgetary nightmares. Thus, the complexity of these structures means that few policymakers, Congressional staff members, or university administrators are knowledgeable in the area. While there are frequently calls to simplify the programs, the process of simplification would actually be quite complex.

The challenge of this conference and volume will be separating the student loan industry from the larger policy area of access to higher education. The two are inextricably linked. Going back to the first laws governing financial aid, a central tension has been whether financial aid is intended to help the middle class afford college (“choice”) or to help the lower class go to college (“access”). Each subsequent law enacted could be labeled either as choice-driven or access-driven, and this has led to some very confusing and contradictory policies. Federal student loans are now an access program, and that was never their original purpose; they were always intended to help the middle class. This rapid increase in student borrowing begs the question of how much borrowing is too much. But whether student loans have actually increased access remains a mystery. Since 1970, the percentage of low income students going to college has increased, but the percentage of highest income students going to college has increased by an equal amount during that time.

This year’s Congressional budget act opened a new chapter in the history of federal student aid. Two new entitlement programs were created, the Academic Competitiveness Grants program and the SMART Grants (Science and Mathematics Access to Retain Talent) program, both designed to create incentives to high school students. This has fundamentally changed the American student aid system, because for first time, need-based federal aid will now include consideration of a student’s high school curriculum, college grades, and college major.

Panel II: The Industry, the Middlemen, and the Consumers

Alan Greenblatt
Governing

There is an assumption that Congress defines the rules of financial aid. However, financial aid offices play an important role because they implement policies and, in doing so, give shape to them. Financial aid officers are important to students because they put together financial aid packages for students; they are important to the lending industry because they determine who is on a school’s preferred lending list. However, this role of financial aid officers came about largely by accident. Often, financial aid personnel are not trained professionals. As enrollments grew and financial aid increased after 1965, financial aid officers who had previously done the predominantly clerical work associated with financial aid began to play an increasingly pivotal role. The field has attracted people who want to provide access to the neediest students who are capable of college-level work.

Internally, the increasingly complex intersection of tax and education laws, as well as federal programs, has increased the burden on financial aid offices. The heads of the higher education institutions have also increased pressure on the office as larger and larger amounts of money go through financial aid offices each year. Financial aid officers are told which students are admitted and to make the numbers add up. Consequently, they are not often able to help the neediest capable students.

Externally, the explosive growth of private loans market is a threat to financial aid offices as direct-to-consumer marketing prevents financial offices from knowing the total debt that students will incur. There is a tension between the two entities: private lenders are a threat because they can circumvent financial aid offices, but private loans are sometimes a necessary supplement to federal programs. Direct institutional lending is down recently as the Federal Family Education Loan Program (FFELP) loans became more competitive, but government programs have not kept up with the cost of tuition. Financial aid officers recognize that private loans are a necessary evil.

Bridget Terry Long
Harvard University

Loans play a critical role in access to higher education. Median family income is not keeping pace with tuition costs. As states give less in state appropriations, tuition costs are steadily rising. Aid is shifting from need- to merit-based aid and the responsibility for the cost of college is shifting to the students themselves. Students are borrowing more than ever before, and more students are borrowing. The question is how much debt they should assume.

Thirty-five percent of all undergraduates take out loans, while about 50 percent of full-time, full-year undergraduates take out loans. Many students use loans to attend private, four-year colleges and universities, but there are also loans for public institutions or for-profit institutions. The federal government is still the primary lender, but private loans are the fastest growing type of financial aid. Increasingly, the middle 50 percent of families are accessing the newer private loans. The proportion of aid coming from private sources has tripled in the past ten years.

Since the changes in 1992, the levels of cumulative debt have increased drastically. The American Council on Education found that one-third of students were in unmanageable debt. With the limits scheduled to increase in July of 2007, will more students be in the same situation? We are just beginning to see the long-term repercussions for the level of debt among the first generation to take out loans after the 1992 reauthorization of the Higher Education Act. Will debt affect post school decisions like marrying and buying a home? Will debt affect students’ decisions to go into public service?

Alternatively, some students may not have access to enough debt. Students from minority groups are taking on debt in higher numbers, but there is insufficient data about those who decide not to take on debt and not to go to school. Restricting access to debt may or may not be advisable, as some students do not know the repercussions of their loan activities. People generally agree that there is counseling for students taking on debt. This is the tension between trying to increase access and choice and at the same time protecting students from the harmful repercussions of high levels of debt.

Sandy Baum
College Board and Skidmore College

Financial aid officers participating in the national dialogue tend to come from institutions that develop their officers into trained professionals. However, other institutions do not do that. It is true that financial aid officers do care about increasing equity and access to education and there are those who are resisting the change away from this value system. More importantly, does the resistance to private loans have to do with the desire to maintain the power of financial aid officers? There is no evidence of such resistance.

It is necessary to look at the motivations on all sides of the market. Imperfections in the student loan market may mean that the financial aid officers have an important role in providing information. Private lenders may want to exclude financial aid officers from the process for their own profit. Should government and institutions intervene in the market to make it work better for students? Financial aid officers may not have the means or the perspective to perform that role.

It is necessary to determine why students are looking for and taking out loans in the private loan market. Are students going to the private market because they need more money, or because of effective direct-to-consumer (DTC) advertising? Will loan limit increases cause people to borrow more? What is the relationship between the supply and demand for student loans?

Don Betterton
Betterton College Planning

Greenblatt’s statements about financial aid officers are inaccurate. However, the roles of financial aid officers have changed because they are increasingly being asked to manage an institution’s enrollment. Enrollment management means directing the amount of money toward students, not in need, to get the enrollment and academic qualifications that a college wants. Admissions and financial aid functions have merged and taken on the goal of increasing efficiency rather than pursuing the old egalitarian values that ensured students’ financial aid needs were met. For example, if there is $20,000 to disburse, it is more efficient to give this amount in smaller merit scholarships to more desirable students than to give greater amounts to a few high-need students. When there is not enough money to go around, the institution starts to “gap” students by giving financial aid packages that do not meet a student’s need, leaving them to pursue private-sector loans.

However students decide to fund their education, they should get the best information possible no matter what the source of the loan is. Financial aid offices can serve as a clearinghouse of loan information if they broker good deals with outside lenders. It is important that students properly compare loan options and that they only borrow as much as they need at the best rates.

The critical problem is that student debt may have long-term consequences for students and that many students do not know how much to borrow. Students need more information and discernment about financial aid. It is often all too easy to get a loan, and many students do not realize the extent of their commitment. Students and parents are responsible for getting the necessary information about loans before taking them on.   

Panel III: Profiling the Industry

Joseph Keeney
School Choice Investments

With the increasing cost of college and the loan limits under the FFELP program, the private student loan sector is growing more quickly than the federal loan sector. Direct-to-consumer marketing of private loans has made students more aware of alternative private loans. 

There are five components of the student loan industry: program design and marketing, borrower inquiry, loan origination and disbursement, loan securitization, and loan servicing. There are important differences between the servicing of private and federal student loans. Federal student loans are guaranteed; private student loans are not. Private student loans are not discharged in bankruptcy and thus are usually recovered to some degree. Default rates for private loans are lower than that for federal loans, though default rates for federal loans are also declining due to improved debt management and additional counseling by financial aid officers for students taking on debt. The profits in the private loan industry can also be affected by origination fees, risk of loss, and early repayment.

A large proportion of federal student loans are securitized, while a small number of private student lenders are securitizing private loans. Securitization has become increasingly common for private loans, with asset-backed securities being sold to largely European investors. Of the $850 billion in asset-backed securities issuance last year, student loans comprised 9 percent. Thus, while investors prefer the guaranteed federal student loans, they have showed a willingness to invest in private student loans as well.

Christopher Mazzeo
Independent consultant

With the growth of the private student loan industry, it is important to consider who is taking out private loans, how they differ from those who take out federal loans, and how the characteristics of that population might inform future policy decisions. While the impression is that private loans are largely taken out by wealthy students, the reality is that about 40 percent of private loan borrowers are actually from the bottom two income quartiles of students going to college.

Loan limits for federal programs have not increased since 1992, so unmet need is one possible explanation for the growth of the private loan industry. Only 50 percent of students taking out private student loans, however, have already taken the maximum loan under the Stafford program. The other half of private borrowers has not maximized the Stafford loan program or has not taken out federal loans at all. College choice may explain why part of the population is taking out private loans without maximizing federal loans, as some students may do so in order to attend the more expensive school of their choice. Still, a large portion of students at less expensive two-year colleges are also taking out private loans instead of federal loans. Many students’ decisions to take out private loans remain unexplained.

There are three populations taking out student loans: those students whose needs are not met by the federal student loan programs and take out private loans as a supplement, those students who do not take out the full Stafford loan but take out private loans as well, and those students who are opting to take out private loans in the place of federal loans. Those not taking out the full Stafford loan may benefit from being provided more information or counseling about the options available to them. However, it is those who take out private, rather than federal, loans who require further study.

Christopher Cronk
Banc of America Securities

In the past, lenders have largely been the processors of federal student loans. Now, many lenders have taken on private loans as well. With loan limits failing to increase with the cost of attending college, the need for private loans has become more important. The consumer finance business is an asset-backed industry and, five years ago, private loans made up only $4 billion of the $850 billion of the asset-backed securities market. Today, it comprises $13 billion.

From the standpoint of securitization, it has been the exception rather than the rule that FFELP and private assets would be separated when sold to investors. The formula was that a lender would need three or four federal loans for every private loan a lender wanted to fund. With more prevalent private loans today, the demand is closer to two, or two and a half federal loans for every private loan. This discrepancy presents a problem because European based investors prefer loans that are guaranteed by the federal government. They are willing to pay more for the government-guaranteed loan than they are for the government-guaranteed loan and the private loan together or even the private loan separately. In this way, the development of the capital markets is forcing lenders to securitize private loans and federal loans separately. As federal loans are no longer capable of funding private loans, it is necessary to develop a model for financing private loans. Third party investors may not be willing to take the same risks on private loans as lenders and are more likely to assess the loans with more caution. For private lenders, this requires a larger spread of interest rates for students and families with variable credit ratings.

Arthur Hauptman
Independent consultant

It is important to recognize how federal student loans set the stage for its development of the private student loan market. Federal loans emerged because lenders were not willing to offer private student loans. Now that private student loans have developed, it is important to understand how they currently relate to the federal loan programs and how they should relate to the federal loan programs in the future.

The private loan market sector is a derivative of the federal loan programs. Four policy decisions in federal loans over the past years have created the market for private loans. The generous consolidation provision for lenders and borrowers, for which the government pays, is an expensive program that limits the number of students who can be offered federal loans. In-school interest subsidies are the biggest cost of the federal loan programs and have not only stunted the growth of loan limits but also caused the program’s benefits to be distributed inequitably. The decision to make laws to determine what the lender yields in the program, rather than using market mechanisms, has had a significant impact. Finally, the array of paperwork used for federal loans has made the program too complicated for some students and their parents to readily understand.

Finally, when we did not think a private loan market was possible, we chose to guarantee rather than to insure the student loans provided by the federal government. Now that we have the private loan market, it would be interesting to think again what an insured--rather than a guaranteed--program would look like. Additional issues to consider are the different kinds of private loans, the role of CFOs at colleges and universities, the profitability of the private loan market, and the negative aspects of private loans.

Panel IV: The Alternative Loan Universe

Richard Lee Colvin
Columbia University

There is tremendous growth in the private student loan business. Entrepreneurs look at the structure and the rules of the business and try to find a niche, and entrepreneurship has been one of the driving forces behind the private loan market. It should not be surprising; rather it is something that we hope for and expect.

Doing business on the Internet is an important part of private lenders’ success. Part of what makes private loans popular is being able to originate loans quickly and at low cost. In general, taking out private loans for education is very easy and quick, while the federal loan system is complicated.

There is a need for such transparency as revealing the interest rates of loans. Private lenders’ methods of gauging risk and pricing work two ways: they make it more expensive for those who need loans the most, but make more money available to more people. Policies should aim to decrease the large profits in the private loan industry without stifling innovation.

There are various questions that do not yet have answers. What are the approval rates for private lenders? How much are students borrowing? What is the income distribution of the borrowers? Critics wonder if there is sufficient demand for such loans and wonder how the loans will be affected by higher interest rates. Is this the way we should finance higher education? Will this system maximize human potential and draw on ingenuity and entrepreneurship, or will it drive tuition increases and merely maximize profits?

Joseph Williams
Education Sector

A generation ago, policy discussions about financing higher education would not have included private loans, because without securitization, private financing was not possible. EduCap pushed the envelope in making securitization the standard practice in the student loan industry. In doing so, EduCap has provided capital to many students who did not qualify for traditional student aid.

In the 1980s, James Whalen, then executive director of the Consortium of Universities in the Washington, D.C., area, realized that there were many Americans left out of the existing loan programs who could not afford to pay for higher education. These people were not poor enough to qualify for federal student loan programs but not wealthy enough to pay for higher education on their own. Whalen worked with officials in Washington to issue $50 million in municipal bonds to make low-cost loans available to students. This endeavor eventually became EduCap.

Students do not get much information from financial aid offices about alternative loans. To expand their business, companies like EduCap found ways outside of financial aid offices to reach students with financial need. For example, it developed partnerships with major corporations around the country which were able to offer private student loans as a benefit to their employees. This innovation, along with the securitization of student loans, and the idea that outstanding debt could be counted as an asset, was important to the development of the nontraditional loan industry. EduCap changed the way private loans were seen by Wall Street.

John A. Hupalo
First Marblehead

First Marblehead approaches loans in a balanced manner by considering various perspectives and interests. The loan industry is an emotional business because it finances people’s dreams. The two previous speakers’ arguments are more like historical fiction than accurate accounts of the development of innovation throughout the history of the industry.

Higher education is an area in the economy that has not restructured, perhaps because of the tension between its potential for public good and its economic realities. The private loan industry is trying to supplement the work being done by the federal loan programs, but there have been some fundamental changes in how students look at loans.

The private loan industry is not fairly represented in the media, which often does not demonstrate how private loans increase access. Private loans help to meet students’ financial needs by creating different opportunities for different students. It is important for federal loan programs and private lenders to work together to maximize the good in both programs. Private loans and federal loans can together leverage scarce federal dollars and provide more educational opportunities.

Catherine B. Reynolds
EduCap and Loan to Learn

By making loans without a government guarantee, EduCap has helped the middle class gain access to higher education. There are many different borrowing needs, and it makes sense to have a variety of programs to meet them. Twenty years ago, this was a revolutionary idea. The Internet has helped to disseminate information and strengthened the loan underwriting process.

In 1990, the FFELP volume was about $12.2 billion, of which 79 percent were Subsidized Stafford Loans. In 2000, Stafford loans represented 20 percent of loan volume. The FFELP program has gone from a need-based program to one that is less need-based and reflects the private loan industry in the late 1980s and early 1990s. One of the greatest barriers to higher education is access, specifically for needy students. There is an enormous group of students who have need that the private loan industry cannot address. Helping these students is the right role for government.

For most families, higher education is the second greatest expense after the purchase of their homes. Borrowers want to understand the process and the terms of their loans. The process should provide dignity, transparency, and clarity to the customer. With its focus on the customer, EduCap is an example of how the private loan sector can help do this. EduCap has had a default rate of approximately 1 percent per annum for twenty years. This shows not only that strong underwriting is critical but also that people highly value their commitment to higher education.

Panel V: Looking Forward

William D. Hansen
Chartwell Education Group

Federal aid’s original goal was for dollars to follow the students instead of the institution. Many of the programs designed were intended to be supplemental--to fill the gaps of other programs and enable colleges to reach out to lower-income students. We should likewise focus on access, choice, and accountability. The Higher Education Act has been amended constantly, which has not been helpful.

First, for the past twenty to thirty years, the federal government has relied on states and public-private relationships to build today’s loan infrastructure. Second, student bodies are changing: there are more students, older students, and more minority students. Many current K-12 reforms in state and federal programs will bolster higher education; they will produce better-educated high school seniors and, in turn, better-prepared college students. Third, the key issue examined before was whether federal aid (in terms of grants and loans) increased tuition. The conclusions were mixed, but ultimately we found that neither Pell grant aid nor loans increased college tuition.

In order to ensure that the right students are getting the right amount of money to go to the right schools, we need a more efficient and more accountable system. Options include repealing tax code subsidies, adding money to Pell grants, auctioning the direct loan portfolio off to the private sector, and privatizing the Perkins program.

We have many foundations interested in helping to increase access to higher education. These foundations must subsidize lower rates, create better aid packages, improve access, and build new and innovative programs that leverage money better in the private market place.

Richard George
Great Lakes Higher Education Corporation

More and more, private loan programs are growing in a direct-to-consumer market. They are bypassing the traditional school channel relationships that for so long have determined market share. Traditionally, this juncture has been a crucial counseling point for students and families. Our path of increasing complexity in the student loan industry will have negative results for students and the industry.

How do we fix this? We must allow market-driven price competition and unlimited borrowing in place of fixed interest rates. Congress will never find the “right” answer to ongoing debates about lender yield versus borrower rates. If we let market forces rule, the composite monthly rate for most loans would decrease. In addition to federal loan guarantee retention, redirected subsidy and rationalization, market-based competition, and limited low-income borrowing, we need to increase financial literacy and counseling programs. Too many borrowers take out loans and then do not think about loan indebtedness for another four years.

It is time to reassess our programs because we are not moving in a positive direction. If we are able to redirect and rationalize federal subsidies; uncap the availability of Title IV guarantees, allowing borrowing of up to the cost of education minus other aid; allow the market to set interest rates; and eliminate the largest cohort of low income borrowing, we will have a bright future.

Alan Bersin
California Secretary of Education

Private loans are not going away. The political and market dynamics that produced them are here to stay, so the issue must be how to work with this industry and not how to resist it. Today we keep hearing that we should direct grants and subsidies toward the lowest socioeconomic groups and the private loan programs toward all others. The private sector should be more capable of differentiating and offering real solutions to policymakers.

We should not take the federal loan guarantee in its current form as a given. The purpose of a guarantee is to lower an interest rate. What we ought to be asking is why the private sector is unable to segment the use of loan guarantees in the way it has in credit scoring.
 
Few other sectors of the economy are so government-dependent as higher education; we are coming to this deregulation stage late. The costs of the industry seem to be leading to integration and concentration that are producing multiple conflicting roles. We have to acknowledge these different roles--between those who are administering, originating, or packaging loans--because there are inherent conflicts of interest throughout the industry. It is important to distinguish between disclosure and transparency. Disclosure, in the legal and security law sense, is being very clear about what your duty is and what your interest is--and how that may conflict with the people you are purporting to serve. People outside and inside the student loan industry are flying blind. We need to be able to differentiate between consumer protection and education goals.

Robert Shireman
Project on Student Debt

We aim to engage low income families and students more fully in higher education. This includes encouraging students to enroll in the first place, enroll in the right places, and enroll in such a way that allows them to focus on their studies, complete their degree, and go on to the workplace or to further schooling.

When considering potential Pell grant increases, we should first turn to the financing and processing mechanisms instead of considering cutting potential student loan subsidies. Low-income students will likely need to borrow additional funds. We need to be careful about cutting down in-school interest subsidies broadly because in doing so, we undermine our aforementioned goal.

We should be concerned that increasing these grants without real thought about how loan programs are organized may move us toward an environment where lenders are determining who goes to college--an arrangement that would inevitably favor high-income families who have more experience with credit markets. Low-income students are not only disadvantaged because they lack experience with credit markets or they underestimate the value of attending college; the reality is that they also face greater risks in borrowing.

It is troubling to see lenders begin to determine who attends college. We are seeing more schools package private and federal loans together without students understanding the details and terms of their loans. It is not realistic to expect a student entering college to understand the various details of different kinds of loans.

AEI research assistants Morgan Goatley, Rosemary Kendrick, and Juliet Squire, and intern Peter Mui, prepared this summary.