Sallie Mae 2012 Annual Report Download - page 92

business goals and within acceptable risk parameters. The committee periodically reports to the Compensation
and Personnel Committee of our Board on our controls and reviews of our incentive compensation plans. We
expect the committee will also work in tandem with our newly formed Enterprise Risk Committee over the
course of the year. Committee membership includes our Executive Vice President — Administration, Chief
Compliance Officer, Chief Credit Officer, Deputy General Counsel responsible for human resources matters, and
our Chief Audit Officer (in a non-voting capacity).
Disclosure Committee. Our Disclosure Committee reviews and approves content of periodic SEC reporting
documents, earnings releases and related disclosure policies and procedures.
Loan Loss Reserve Committee. Our Loan Loss Reserve Committee oversees the sufficiency of our loan loss
reserves and considers current or emerging issues affecting delinquency and default trends which may result in
adjustments in our allowances for loan losses.
Critical Accounting Assumptions Committee. Our Critical Accounting Assumptions Committee oversees
critical accounting assumptions, as well as key judgments and estimates, utilized in preparation of our financial
statements.
Asset and Liability Committee. Our Asset and Liability Committee oversees our investment portfolio and
strategy and our compliance with our investment policy.
Corporate Credit Committee. Our Corporate Credit Committee oversees the overall credit and portfolio
management strategy, policy review and monitoring.
Corporate Compliance Committee. Our Corporate Compliance Committee oversees regulatory compliance
risk management activities for Sallie Mae and its affiliates.
ICE Steering Committee. Our ICE Steering Committee oversees our Internal Controls Excellence (“ICE”)
initiative and Sarbanes-Oxley compliance and sponsors periodic forums in which the top internal control
deficiencies are discussed and analyzed to ensure the control deficiencies are identified, understood by all
relevant affected parties, and have established resolution plans supported by adequate resources.
Customer Products and Services Assessment Committee. Our Customer Products and Services Assessment
Committee considers matters relating to risks affecting us and our wholly- and majority-owned subsidiaries
associated with new, expanded, or modified products or services and makes recommendations regarding
proposed products or service offerings based on their inherent risks and controls.
Risk Assessment
Our Internal Audit Department monitors our various risk management and compliance efforts, identifies
areas that may require increased focus and resources, and reports significant control issues and recommendations
to executive management and the Audit Committee of our Board. At least annually, the Internal Audit
Department performs a risk assessment to identify our top risks used to develop their annual internal audit plan.
The risk assessment focuses on those risks most relevant to us and our subsidiaries (including the Bank).
Risk Appetite Framework
Our risk appetite framework establishes the level of risk we are willing to accept within each risk category
in pursuit of our business strategy. By having a uniform risk appetite framework, it creates linkages across our
businesses to ensure business decisions, monitoring and reporting are made on a consistent basis. Management
and our various corporate committees monitor approved limits and escalation triggers to ensure that our
businesses are operating within the approved risk limits. Risk limits are monitored and reports are provided to
various corporate committees and our Board and its committees, as appropriate. Through ongoing monitoring of
risk exposures, management is able to identify potential risks and develop appropriate responses and mitigation
strategies. Our Board has agreed our Risk Appetite Framework with management and directed management to
continue its development and evolution with the Audit Committee of our Board.
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