We’re Committed to Transparency
Transparency in Policy Engagement and Political Participation Report
Our goal is to support the success of our customers, employees, and shareholders. We are committed to fulfilling our role as an active corporate citizen with integrity and transparency.
This full-year report covers activities from January 1, 2022 through December 31, 2022. You can also access the previous reports: 2022 Semiannual, 2021 Full Year, 2021 Semiannual, 2020 Full Year, 2020 Semiannual, 2019 Full Year, 2019 Semiannual, 2018 Full Year, 2018 Semiannual, 2017 Full Year, 2017 Semiannual, 2016 Full Year, 2016 Semiannual, 2015 Full Year
Governance
The company’s Government Relations Department, under the direction of the senior vice president for public policy and government relations, is responsible for government relations policies and activities and manages all political activities conducted by or on behalf of Navient. The department reports semi-annually to the Board of Directors’ Nominations and Governance Committee on political contribution matters and major lobbying priorities. As required by its charter, the Nominations and Governance Committee is composed entirely of independent directors and receives periodic reports on political risk, payments made to trade associations, and contributions made to other tax-exempt political organizations, as well as contributions by the company’s Political Action Committee. The company maintains compliance processes intended to ensure that Navient and its employees conduct all its activities in accordance with our Code of Business Conduct and with all relevant laws governing political contributions and lobbying activities.
State and Federal Engagement
Policy proposals, legislation, and regulation can have an impact on our customers, employees, and shareholders. Federal, state, and local policy changes can significantly affect our operations, customer outcomes and service experience, revenues, and costs. Because of this impact, we have a responsibility to engage with policymakers to educate, provide fact-based information, and to advance the success of our company and our stakeholders.
We regularly share our expertise, express our views, and provide public officials with factual briefings to inform their decisions. We monitor legislative activities, analyze trends, and advance ideas to benefit our constituencies. Because of our 50 year history in helping customers navigate their way to financial success, members of Congress, congressional and legislative staff, and other policymakers frequently consult with us about the impact of federal and state proposals.
Federal Lobbying
Meaningful engagement requires Navient to participate in the legislative process. The staff of Navient’s Government Relations Department is registered to lobby and actively lobbies on issues that affect our customers and business. Only members of the Government Relations team are authorized to direct lobbying activities on behalf of Navient. Navient policy requires these professionals to work with counsel to ensure that they conduct their activities in compliance with applicable laws, rules, and regulations as well as maintain the highest standards of professional integrity.
We disclose publicly all federal lobbying topics and expenditures on a quarterly basis, in accordance with the Lobbying Disclosure Act. Navient’s quarterly filings are available at Registrations & Quarterly Activity Reports | Lobbying Disclosure. Navient’s political expenditures reflect our interests as a company and are made without regard for the political preferences of any individual director, officer, or employee.
Navient’s disclosures provide all federal lobbying expenditures, including fees paid to outside consultants. During 2022, Navient engaged the services of the Blue Point DC, Bose Public Affairs Group, Invariant, the Madison Group, 1607 Strategies, and Stumptown Strategies, each of whom also file disclosures on their fees and activities on behalf of Navient. For 2022, Navient spent $1,660,000 on federal lobbying expenditures, including fees paid to outside consultants. This amount was Navient's lowest expenditure in the last 13 years. The chart below shows lobbying expenditures by quarter during that period.
Among the Topics for Which We Have Advocated and for Which We Have Supported Legislation Are:
Better tools and information to help students and their families make informed borrowing decisions and help them successfully realize a return on their higher education investment
Streamlined repayment options to reduce complexity for borrowers and servicers and increase engagement
Bankruptcy reform that allows federal and private student loans to be discharged after a good faith effort to repay
Easier methods to enroll in and recertify federal income-driven repayment programs
Improving assistance to distressed borrowers
Programs that encourage borrowers to contact their student loan servicers
More assistance to borrowers participating in the federal rehabilitation program to help them recover from default
A one-time credit bureau retraction for student loan borrowers who have some delinquencies but have established steady repayment
Improve federal budgeting to assure adequate funding for student loan delinquency and default prevention
Educate policymakers on the differences between private education loans and federal loans and ensuring that assistance is targeted to struggling borrowers
Require third party debt relief companies to disclose prominently the availability of such services from their loan servicer without cost
Monitor and educate on issues relating to financial markets
Employer repayment assistance programs that allow pre-tax dollar benefits to be used for student loan repayment
Issues relating to the collections industry and ensuring government debt collection programs employ industry best practices
Political Contributions
The company’s policies ensure that, consistent with federal law, Navient may not contribute corporate funds or make in-kind contributions to candidates for federal office or to national party committees. Navient does not use corporate funds to make independent political expenditures. We have not spent any corporate funds on communications to the general public that expressly advocate the election or defeat of a federal candidate and we have no plans to spend direct corporate funds on such communications. Navient’s electoral related expenditures reflect our interests as a company and are made without regard for the political preferences of any individual director, officer, or employee.
State Contributions
Navient made no contributions to state or local elected officials or candidates during 2022.
Trade Associations
Navient participates in several trade associations that provide their members a variety of services including technical assistance and best practices. Trade associations may also advocate on major public policy issues of importance to their members and the communities they serve. For most of these organizations, the primary purpose of Navient’s membership is for professional development, technical assistance, and best industry practices. Our payments for membership dues come with the recognition that we may not always agree with all the positions of an organization or its individual members. On occasion, some of these organizations may undertake specific projects on behalf of their members for which additional fees and expense reimbursements may be paid in addition to membership fees disclosed below.
Navient does not coordinate or earmark corporate funds toward election-related activity at the federal, state, or local level, including contributions and expenditures in support of, or in opposition to, any candidate for any office, ballot initiative campaign, political party committee, or political action committee (PAC).
Below is a list of the membership fees paid to the principal organizations¹ in which Navient renewed a membership or became a new member at any point during 2022 and which may have conducted some lobbying activity:
| Trade Association | 2022 Membership and Other Fees |
|---|---|
| ACA International | $4,525 |
| American FinTech Council | $25,000 |
| HR Policy Association | $18,500 |
| International Education Council | $5,200 |
| International Bridge, Tunnel & Turnpike Association | $10,400 |
| National Association-Student Financial Aid Administrators | $6,995 |
| Society For Corporate Governance | $2,600 |
| Student Loan Servicing Alliance | $7,400 |
| Structured Finance Association | $50,000 |
527 Political Organizations
Navient does not provide funding to groups organized under Section 527 of the Internal Revenue Code other than those listed below. Our contributions to these groups are membership dues and are not earmarked to support the election of any specific candidate nor for funding specific expenditures or communications. In addition, we do not consult with these groups regarding the expenditure of their funds.
Below is the list of four 527 groups that Navient contributed to in 2022.²
| Organization | 2022 Membership and Other Fees |
|---|---|
| Democratic Attorneys General Association | $40,000 |
| Democratic Governors Association | $25,000 |
| Republican Attorneys General Association | $40,000 |
| Republican Governors Association | $25,000 |
Political Action Committee
The Navient Political Action Committee (PAC) is funded solely through voluntary contributions from eligible employees. The PAC supports candidates, parties, and committees on a bipartisan basis. The PAC does not contribute in connection with U.S. presidential elections.
Navient’s corporate policy requires that contributions from Navient’s PAC promote company interests without regard for the private political preferences of executives. The Navient PAC is governed by a board comprised of senior leaders from several corporate functional and geographic areas as well as business units. The PAC Board annually reviews and approves a giving framework. The board is chaired by the senior vice president for public policy and government relations. In deciding who to support, PAC leadership considers candidates who represent the communities we serve, who represent diverse communities, those who serve on relevant committees or in leadership, and those who have shown support for policies and initiatives of importance to the company, its customers, and shareholders. We aim to be bipartisan in our contributions and in 2022, we gave evenly to Democrats and Republicans.
Contributions from Navient’s PAC, as required by law, are reported in filings with the Federal Election Commission and are made publicly available.
Navient 2022 Political Contribution Snapshot
JANUARY 1, 2022 THROUGH DECEMBER 31, 2022
The following lists shows each contribution made by the Navient PAC during 2022.
Navient PAC Contributions to U.S. House of Representatives
| U.S. House Candidate | State | District | 2022 Contribution |
|---|---|---|---|
| Rep. Alma Adams (D) | NC | Congressional District 12 | $2,000 |
| Rep. Joyce Beatty (D) | OH | Congressional District 03 | $4,000 |
| Rep. Lisa Blunt Rochester (D) | DE | At Large | $1,000 |
| Rep. Matt Cartwright (D) | PA | Congressional District 08 | $4,500 |
| Rep. Yvette Clarke (D) | NY | Congressional District 09 | $1,000 |
| Rep. Emmanuel Cleaver (D) | MO | Congressional District 05 | $1,500 |
| Rep. Jim Clyburn (D) | SC | Congressional District 06 | $2,000 |
| Rep. James Comer (R) | KY | Congressional District 01 | $1,000 |
| Rep. Henry Cuellar (D) | TX | Congressional District 28 | $1,000 |
| Rep. Byron Donalds (R) | FL | Congressional District 19 | $2,000 |
| Rep. Tom Emmer (R) | MN | Congressional District 06 | $5,000 |
| Rep. Chuck Fleischmann (R) | TN | Congressional District 03 | $1,000 |
| Rep. Michelle Fischbach (R) | MN | Congressional District 07 | $1,000 |
| Rep. Brian Fitzpatrick (R) | PA | Congressional District 01 | $1,500 |
| Rep. Virginia Foxx (R) | NC | Congressional District 05 | $1,000 |
| Rep. Andrew Garbarino (R) | NY | Congressional District 02 | $1,000 |
| Rep. Sylvia Garcia (D) | TX | Congressional District 29 | $1,000 |
| Rep. Al Green (D) | TX | Congressional District 09 | $1,000 |
| Rep. French Hill (R) | AR | Congressional District 02 | $2,500 |
| Rep. Ashley Hinson (R) | IA | Congressional District 01 | $2,500 |
| Rep. Steven Horsford (D) | NV | Congressional District 04 | $1,500 |
| Rep. Bill Huizenga (R) | MI | Congressional District 02 | $1,000 |
| Rep. Chris Jacobs (R) | NY | Congressional District 27 | $1,000 |
| Rep. Robin Kelly (D) | IL | Congressional District 02 | $1,000 |
| Rep. Darin LaHood (R) | IL | Congressional District 18 | $2,500 |
| Rep. Nick Langworthy (R) | NY | Congressional District 23 | $1,000 |
| Rep. Julia Letlow (R) | LA | Congressional District 05 | $2,000 |
| Rep. Stephen Lynch (D) | MA | Congressional District 08 | $1,000 |
| Rep. Blaine Luetkemeyer (R) | MO | Congressional District 03 | $3,500 |
| Rep. Nicole Malliotakis (R) | NY | Congressional District 11 | $500 |
| Rep. Lisa McClain (R) | MI | Congressional District 10 | $1,000 |
| Rep. Sheila Cherfilus McCormick (D) | FL | Congressional District 20 | $2,000 |
| Rep. Gregory Meeks (D) | NY | Congressional District 05 | $1,000 |
| Rep. Dan Meuser (R) | PA | Congressional District 09 | $1,000 |
| Rep. Kweisi Mfume (D) | MD | Congressional District 07 | $1,000 |
| Rep. Mariannette Miller-Meeks (R) | IA | Congressional District 02 | $1,000 |
| Rep. Joe Morelle (D) | NY | Congressional District 25 | $1,000 |
| Rep. Jay Obernolte (R) | CA | Congressional District 23 | $1,000 |
| Rep. Sean Patrick Maloney (D) | NY | Congressional District 18 | $1,000 |
| Rep. Stacy Plaskett (D) | USVI | At Large | $1,000 |
| Rep. David Scott (D) | GA | Congressional District 13 | $1,000 |
| Rep. Victoria Spartz (R) | IN | Congressional District 05 | $2,000 |
| Rep. Elise Stefanik (R) | NY | Congressional District 21 | $1,000 |
| Rep. Bryan Steil (R) | WI | Congressional District 01 | $1,000 |
| Rep. Eric Swalwell (D) | CA | Congressional District 15 | $1,500 |
| Rep. Beth Van Duyne (R) | TX | Congressional District 24 | $1,000 |
| Rep. Maxine Waters (D) | CA | Congressional District 43 | $1,000 |
| Rep. Nikema Williams (D) | GA | Congressional District 05 | $1,500 |
Navient PAC Contributions to U.S. Senate
| U.S. Senate Candidate | State | District | 2022 Contribution |
|---|---|---|---|
| Sen. Katie Britt (R) | AL | United States Senate | $1,000 |
| Sen. Ted Budd (R) | NC | United States Senate | $1,000 |
| Sen. Tom Cotton (R) | AR | United States Senate | $3,000 |
| Sen. Joni Ernst (R) | IA | United States Senate | $5,000 |
| Sen. Chuck Grassley (R) | IA | United States Senate | $1,000 |
| Sen. Bill Hagerty (R) | TN | United States Senate | $5,000 |
| Sen. Patty Murray (D) | WA | United States Senate | $1,000 |
| Sen. Eric Schmitt (R) | MO | United States Senate | $1,000 |
| Sen. Tim Scott (R) | SC | United States Senate | $2,500 |
| Sen. Jon Tester (D) | MT | United States Senate | $1,000 |
Navient PAC Contributions to Leadership Committees
| Leadership PAC | Sponsor | 2022 Contribution |
|---|---|---|
| BARR PAC | Rep. Andy Barr (R-KY) | $5,000 |
| BLAINE PAC | Rep. Blaine Luetkemeyer (R-MO) | $1,000 |
| Blue Hen PAC | Sen. Chris Coons (D-DE) | $5,000 |
| EMMER PAC | Rep. Tom Emmer (R-MN | $1,000 |
| Hoosier PAC | Sen. Mike Braun (R-IN) | $2,500 |
| I Got Your Back PAC | Rep. Lisa Blunt Rochester (D-DE) | $2,500 |
| Innovation Political Action Committee | Rep. Patrick McHenry (R-NC) | $5,000 |
| MARSHA PAC | Sen. Marsha Blackburn (R-TN) | $2,500 |
| TIM PAC | Sen. Tim Scott (R-SC) | $2,500 |
Navient PAC Contributions to Congressional Caucus and Party
| Party/Caucus | 2022 Contribution |
|---|---|
| Across the Aisle PAC (D) | $5,000 |
| CHC Bold PAC (D) | $5,000 |
| Congressional Black Caucus PAC (D) | $5,000 |
| DCCC (D) | $15,000 |
| DSCC (D) | $15,000 |
| Elect Democrat Women (D) | $5,000 |
| Equality PAC (D) | $5,000 |
| Hispanic Leadership Trust (R) | $2,500 |
| NRCC (R) | $15,000 |
| NRSC (R) | $5,000 |
| Team Blue PAC (D) | $5,000 |
| Value In Electing Women PAC (R) | $2,500 |
| Wonder Woman PAC (R) | $1,000 |
Other Political Activity
Navient does not engage in, and expends no resources in support of, groups organized under Section 501(c)(4) of the Internal Revenue Code.
Navient does not engage in and expends no resources for grassroots lobbying communications, defined as any communication directed to the general public that (a) refers to specific legislation or regulation, (b) reflects a view on legislation or regulation, and (c) encourages the recipient of the communication to take action with respect to the legislation or regulation.
Navient does not engage in influencing and expends no resources to influence the outcome of ballot measures.
Subsidiaries of Navient may participate in and be members of various industry associations that engage with government entities at the state and local level regarding policies, programs, and best practices. Such organizations include specialized industry groups in fields such as transportation, revenue, and health.
Other than as disclosed above, Navient does not belong to any other tax-exempt organizations whose purpose it is to influence federal or state policy, including organizations that write and endorse model legislation.
Employee Engagement
Navient encourages employees to participate in political and civic activities of their choosing. Our employees have the right to participate in the political process by making personal contributions from personal funds, subject to applicable legal limits. In accordance with our Code of Business Conduct, employees may not be reimbursed or otherwise compensated by Navient for any such contributions, and political activity must take place on personal rather than company time. The Code of Business Conduct requires employee interactions with government officials maintain the highest standards of ethical behavior.
To learn more, visit Navient.com.
Facts sheets and FAQs Navient.com/facts
Corporate governance Navient.com/investors
¹ We define principal organizations to include those trade associations that participated in lobbying activity and in which the company maintained a corporate membership and where our annual expenditures exceeded $1,000. We do not consider a trade association to be a principal organization if our employees are members to satisfy professional licensing requirements. In addition to the national organizations listed in the table, Navient is a member of state and local chambers of commerce where we have a significant employee presence.
² The amounts for Republican Attorneys General Association and Democratic Attorneys General Association each include $25,000 for 2023 memberships paid in advance.