The First Marblehead Corporation strives to maintain the confidence of our stockholders by adhering to the highest ethical and business standards. During the past year, we have been reviewing our corporate governance policies and procedures and comparing them against those identified as best practices by various authorities in corporate governance and the practices of other public companies. We have also been mindful of the provisions of the Sarbanes-Oxley Act of 2002, the new and proposed rules of the SEC and the requirements of the New York Stock Exchange. In December 2005, we amended our Code of Conduct to establish a more stringent policy with respect to gifts and gratuities.

We will continue to review and, when appropriate, take additional steps in the future to strengthen our corporate governance practices to ensure that we are focused on the long-term benefit of our stockholders.