Mr. Arnold has served since August 2018 and bears full accountability for Navient's severe underperformance — the stock lost nearly 40% over three years while the company's disclosed peer group gained an average of nearly 85%, a gap of 124.5 percentage points that far exceeds our 20-point threshold; the 5-year picture offers no relief as the stock is down 30% over five years while peers gained a median of nearly 15%, confirming sustained rather than transient underperformance.

Mr. Bramson has served since May 2022 and his tenure meaningfully overlaps the three-year underperformance period during which Navient lost nearly 40% while peers gained nearly 85%; the 5-year check likewise confirms sustained underperformance, so no mitigation applies; additionally, the board is combining the Chair and CEO roles in Mr. Bramson, a significant governance concentration that warrants further concern for independent shareholders.

Ms. Cabral has served since December 2014 and carries full accountability for Navient's severe stock underperformance — down nearly 40% over three years versus a peer median gain of nearly 85%; the 5-year TSR also shows underperformance against peers (NAVI -30.2% vs peer median +14.8%, gap of -45.0pp exceeds the 20pp threshold), confirming this is not a transient trough, so no 5-year mitigant applies.

Mr. Klane has served since May 2019 and his full tenure covers the three-year underperformance period; Navient's stock fell nearly 40% while peers gained nearly 85%, a 124.5-percentage-point gap far exceeding our 20-point trigger, and the 5-year data shows continued underperformance against peers, so the 5-year mitigant does not apply.

Mr. Lawson joined in August 2021, which is more than 24 months before the meeting date and means he is not exempt from the TSR trigger; his tenure covers the bulk of the three-year underperformance window during which Navient lost nearly 40% versus a peer median gain of nearly 85%, and the 5-year check also shows sustained underperformance, so no mitigant applies.

Mr. Yowan has served on the board since March 2017 and as CEO since May 2023; as an executive director he is subject to the same TSR trigger as all other directors under our policy, and Navient's nearly 40% stock decline over three years versus peers' nearly 85% gain represents a 124.5-percentage-point gap far exceeding our threshold; the 5-year underperformance against peers is also confirmed, so no mitigant reduces this to a FOR vote — note that this director-level AGAINST vote is independent of the separate Say on Pay evaluation.