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Full title: Modified chapter 11 plan of reorganization (Second Modified Joint Plan (re 400) (re:358 Chapter 11 plan) filed by James A Bartholomew. (Ashfield, Phillip) (Entered: 07/16/2021)

Document posted on Jul 15, 2021 in the bankruptcy, 81 pages and 0 tables.

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Except as otherwise provided in this Article, all Allowed claims specified in Bankruptcy Code § 507(a)(2), not previously paid, will be paid in full by the Debtors, Chapter 11 Trustee, Liquidating Agent, Disbursing Agent, or Reorganized Debtor, as applicable, as soon as practicable but no later than ten (10) business days following the later of: (i) the Effective Date, or (ii) the date such claim becomes an Allowed claim.Claims, taxes, assessments, professional fees, and other expenses of administration of the Liquidating Fund as may be necessary and appropriate for the operation of the Liquidating Fund, (d) calculate and make distributions from the Liquidating Fund to the holders of all Allowed Claims in accordance with the provisions of this Plan, (e) investigate, prosecute, litigate, settle or compromise any objections to claims, Avoidance Claims, and Causes of Action on behalf of the Debtors and those claims may be settled or compromised without notice and a hearing and without Court approval (but subject to the consent of the Oversight Committee), (f) review, reconcile or object to claims and resolve such objections as set forth in this Plan, (g) object to the amount of any claim on the Debtor’s Schedules if the Liquidating Agent determines in good faith that the claim is invalid, has previously been paid or satisfied, or other grounds exist for an objection, (h) defend, protect, and enforce any and all rights and interests transferred to the Liquidating Fund or Liquidating Agent, (i) retain professionals and incur any reasonable and necessary expenses in performance of its duties, and to the extent such payments are approved by the Oversight Committee, to pay those expenses without any further application to the Bankruptcy Court, (j) pay any and all claims, liabilities, losses, damages, costs, and expenses incurred by the Liquidating Agent, including all fees and expenses of the Liquidating Agent and professionals retained by the Liquidating Agent, (k) file estate or other tax returns, (l) operate assets for periods reasonably required to preserve or maximize value pending liquidation and distribution to Creditors, (m) open, create, or close accounts to deposit, hold, and disburse funds, (n) invest cash in demand or time deposits to obtain market rates of return pending distributions, (o) file any and all reports and motions or requests for relief with the court or any opposition thereto, (p) extend, renew, enter into, authorize, and benefit from any insurance policies, including but not limited to tail coverage for insurance policies in place on the Filing Date, and rights of indemnification, (q) dissolve the Debtors or otherwise wind up any of the Debtors’ corporate affairs and existence, (r) subject to approval of the Oversight Committee, incur indebtedness to fund administration of the Plan, (s) perform any other functions that are necessary to effectuate this Plan and perform its duties as Liquidating Agent, (t) have the power and aut

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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF MINNESOTA Jointly Administered Under Case No. 19-33629 (WJF) In re: Minnesota School of Business, Inc., Case No.: 19-33629 Globe University, Inc., Case No.: 19-33632 Chapter 11 Cases Debtors. SECOND MODIFIED JOINT PLAN OF REORGANIZATION OF THE CHAPTER 11 TRUSTEE AND DEBTORS DATED JULY 15, 2021 The Chapter 11 Trustee and the Debtors propose the following Second Modified Joint Plan of Reorganization (the “Plan”) for approval by the creditors and other interested parties. Subject only to the restrictions and requirements set forth in relevant provisions of the Bankruptcy Code and the Federal Rules of Bankruptcy Procedure (including 11 U.S.C. § 1127 and Fed. R. Bankr. P. 3019), the Plan Proponents reserve all available rights to amend, alter, revise, modify, revoke, or withdraw this Plan prior to its substantial consummation. This Plan is subject to the Bankruptcy Court’s approval and certain other conditions. This Plan is not an offer with respect to any securities. Acceptances or rejections with respect to this Plan may not be solicited until the Bankruptcy Court has approved an accompanying disclosure statement in accordance with section 1125 of the Bankruptcy Code. Any solicitation of this Plan will occur only in compliance with applicable provisions of securities and bankruptcy laws.

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INTRODUCTION The Plan contemplates a reorganization (“Reorganization”) of the Debtors and payment in full of Allowed General Unsecured Claims as of the Effective Date of the Plan from the following sources (“Funding Sources”): (i) proceeds from sales of certain parcels of Real Property owned by MSB’s subsidiaries; (ii) cash in the Debtors’ bankruptcy estates and their subsidiaries; (iii) the Deposit; (iv) loans from refinancing of other parcels of Real Property owned by MSB’s subsidiaries, which loans will be secured by mortgages on the parcels and guaranteed by the Debtors’ principal shareholder; and (v) loans from the Debtors’ principal shareholder in an amount necessary for the Plan. A precondition to the Plan is receipt of final approval from the Department of Education of the Settlement Agreement by and among the Debtors, the State, the Chapter 11 Trustee, and the Department of Education, which Settlement Agreement is attached hereto as Exhibit A. In the unexpected event that final approval is not received from the Department of Education, the Chapter 11 Trustee will modify the Plan to be a liquidating plan.

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TABLE OF CONTENTS ARTICLE I DEFINITIONS ......................................................................................................... 1ARTICLE II CLASSIFICATION OF CLAIMS AND INTERESTS ........................................... 5ARTICLE III SETTLEMENT AGREEMENT ............................................................................ 5ARTICLE IV TREATMENT OF CERTAIN UNCLASSIFIED PRIORITY CLAIMS .............. 64.1 Allowed Administrative Expense Claims ............................................................. 64.1.1 Professional Fees and Expenses................................................................ 64.2 Statutory Fees and Court Costs ............................................................................. 64.3 Unsecured Priority Claims .................................................................................... 64.3.1 Priority Tax Claims ................................................................................... 64.3.2 Other Priority Claims ................................................................................ 7ARTICLE V TREATMENT OF CLASSIFIED CLAIMS AND INTERESTS ........................... 75.1 Class 1 – Lake Area Bank ..................................................................................... 75.1.1 Classification............................................................................................. 75.1.2 Treatment .................................................................................................. 75.1.3 Voting ....................................................................................................... 75.2 Class 2 – Home Federal Savings Bank ................................................................. 75.2.1 Classification............................................................................................. 75.2.2 Treatment .................................................................................................. 75.2.3 Voting ....................................................................................................... 85.3 Class 3 – General Unsecured Claims .................................................................... 85.3.1 Classification............................................................................................. 85.3.2 Treatment .................................................................................................. 85.3.3 Voting ....................................................................................................... 85.4 Class 4 – Claims of Insiders.................................................................................. 85.4.1 Classification............................................................................................. 85.4.2 Treatment .................................................................................................. 85.4.3 Voting ....................................................................................................... 85.5 Class 5 – Intercompany Claims ............................................................................ 85.5.1 Classification............................................................................................. 85.5.2 Treatment .................................................................................................. 95.5.3 Voting ....................................................................................................... 95.6 Class 6 – Equity Interests in MSB ........................................................................ 95.6.1 Classification............................................................................................. 95.6.2 Treatment .................................................................................................. 95.6.3 Voting ....................................................................................................... 95.7 Class 7 – Equity Interests in Globe ....................................................................... 95.7.1 Classification............................................................................................. 95.7.2 Treatment .................................................................................................. 95.7.3 Voting ....................................................................................................... 9

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5.8 Special Provisions Relating to Creditors’ Rights of Setoff .................................. 9ARTICLE VI MEANS OF EXECUTION OF THE PLAN ....................................................... 106.1 Substantive Consolidation .................................................................................. 106.1.1 Confirmation Order ................................................................................. 106.1.2 Treatment of Liabilities Under the Plan.................................................. 106.1.3 Preservation of Legal Separateness ........................................................ 106.2 Revesting............................................................................................................. 106.3 Ongoing Operations ............................................................................................ 116.4 Section 1145 Exemption ..................................................................................... 116.5 Effectuating Documents; Further Transactions; Exemption from Certain Transfer Taxes .................................................................................................... 116.6 Plan Funding ....................................................................................................... 116.7 Causes of Action and Avoidance Claims ............................................................ 116.8 Management of the Reorganized Debtor ............................................................ 126.9 Chapter 11 Trustee after Confirmation Date ...................................................... 126.10 Event of Default under Plan ................................................................................ 126.10.1 Revised Claims ....................................................................................... 126.10.2 Liquidating Fund ..................................................................................... 126.10.3 Liquidating Agent ................................................................................... 126.10.4 Powers and Duties of the Liquidating Agent .......................................... 136.10.5 Compensation and Retention of Professionals ....................................... 146.10.6 Removal of Liquidating Agent ............................................................... 146.10.7 Oversight Committee .............................................................................. 146.10.8 Effectuating Documents, Further Transactions, Exemption from Certain Transfer Taxes ............................................................................ 146.10.9 Liability and Indemnification ................................................................. 156.10.10 Preservation of Causes of Action and Avoidance Claims ................... 156.10.11 Closing of Cases .................................................................................. 16ARTICLE VII DISTRIBUTIONS AND CLAIMS ADMINISTRATION ................................ 167.1 Distributions ........................................................................................................ 167.1.1 Distributions Upon Plan Default – Liquidating Agent ........................... 167.1.2 Distributions Upon Substantial Consummation – Disbursing Agent ..... 167.2 Method of Distribution ....................................................................................... 167.2.1 Payments to Former Students on Account of State’s Claim ................... 177.2.2 Unclaimed Distributions ......................................................................... 177.3 Claims Administration Responsibility ................................................................ 177.3.1 Reservation of Rights to Object to Claims ............................................. 177.3.2 Filing of Objections ................................................................................ 187.3.3 Determination of Claims ......................................................................... 187.4 Procedures for Treating and Resolving Contested Claims ................................. 187.4.1 No Distributions Pending Allowance ..................................................... 18

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7.4.2 Claim Estimation .................................................................................... 187.4.3 No Distribution if Cause of Action Asserted .......................................... 197.4.4 Payment Upon Allowance and Disallowance of Contested Claims ....... 197.4.5 Record Date ............................................................................................ 19ARTICLE VIII EXECUTORY CONTRACTS AND UNEXPIRED LEASES ......................... 198.1 Executory Contracts and Unexpired Leases ....................................................... 19ARTICLE IX CONFIRMATION OF THE PLAN .................................................................... 209.1 Conditions Precedent to Effective Date .............................................................. 209.2 Conditions Precedent to Substantial Consummation .......................................... 209.3 Waiver of Conditions to Confirmation or Effective Date ................................... 209.4 Cramdown ........................................................................................................... 209.5 Effect of Confirmation of the Plan ...................................................................... 209.5.1 Title to and Vesting of Assets ................................................................. 209.5.2 Corporate Action ..................................................................................... 219.5.3 Injunction Against Interference with the Plan ........................................ 219.5.4 Discharge ................................................................................................ 219.5.5 Permanent Injunction .............................................................................. 219.5.6 Exculpation ............................................................................................. 22ARTICLE X RETENTION OF JURISDICTION ...................................................................... 22ARTICLE XI MISCELLANEOUS PROVISIONS ................................................................... 2411.1 Modification of the Plan ..................................................................................... 2411.2 Revocation of the Plan ........................................................................................ 2411.3 Severability of Plan Provisions ........................................................................... 2411.4 Corporate Documents ......................................................................................... 2411.5 Regulated Rates .................................................................................................. 2411.6 Successors and Assigns....................................................................................... 2511.7 Governing Law ................................................................................................... 2511.8 Construction ........................................................................................................ 25EXHIBITS Exhibit A – Settlement Agreement Exhibit B – Oversight Committee By-Laws Exhibit C – Assumed Contracts

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ARTICLE I DEFINITIONS The following words and phrases when used herein shall have the following meanings: 1.1 “Administrative Expense Claim” means a claim of the kind described in Section 4.1 of this Plan. 1.2 “Allowed” means with respect to any claim: (a) a claim that has been scheduled by the Debtors in their Schedules as other than disputed, contingent, or unliquidated and as to which the Chapter 11 Trustee, the Debtors, or any other party-in-interest has not filed an objection; (b) a claim that either is not a Contested Claim or has been allowed by a Final Order; (c) a claim that is allowed in a stipulation or settlement executed prior to or after the Effective Date; (d) a claim relating to a rejected executory contract or unexpired lease that is not a Contested Claim or has been allowed by a Final Order, only if a proof of claim has been timely filed; or (e) a claim as to which a proof of claim has been timely filed and as to which the Chapter 11 Trustee, the Debtors, or any party-in-interest has not filed an objection; and with respect to all claims, only after reduction for applicable setoff and similar rights of the Debtors. 1.3 “Assumed Contracts” means those executory contracts and unexpired leases identified on Exhibit C to this Plan. 1.4 “Avoidance Claims” means all claims, causes of action, or rights to property of either of the Debtors or their bankruptcy estates under sections 544, 545, 547, 548, 549, 550, or 551 of the Bankruptcy Code. 1.5 “Avoidance Claim Deadline” means the deadline applicable in these Bankruptcy cases for asserting Avoidance Claims under Section 544, 545, 547, 548, or 553 of the Bankruptcy Code, as provided for in Section 546(a) of the Bankruptcy Code. 1.6 “Bankruptcy Code” or “Code” means Title 11 of the United States Code. 1.7 “Bankruptcy Rule” or “Rule” means a Federal Rule of Bankruptcy Procedure. 1.8 “Causes of Action” means any and all actions, proceedings, causes of action (including, without limitation, any causes of action of a debtor or debtor in possession or the bankruptcy estate(s) under Chapter 5 of the Bankruptcy Code such as the Avoidance Claims), liabilities, obligations, suits, reckonings, covenants, contracts, controversies, agreements, promises, rights to legal remedies, rights to equitable remedies, rights to payment, rights to object to claims, variances, trespasses, damages, judgments, executions, claims, and demands whatsoever, whether known, unknown, reduced to judgment, not reduced to judgment, liquidated, unliquidated, fixed, contingent, matured, unmatured, disputed, undisputed, secured or unsecured, or whether asserted or assertable directly or derivatively, in law, equity, or otherwise, and all rights thereunder or attendant thereto that belong to either of the Debtors or the bankruptcy estates. 1.9 “Chapter 11 Cases” means Debtors’ pending cases under Title 11 of the United States Code, enumerated in the caption at the top of this Plan.

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1.10 “Claim” means a “claim,” as defined in section 101(5) of the Bankruptcy Code, against either of the Debtors. 1.11 “Confirmation Date” means the date on which the Confirmation Order is entered. 1.12 “Confirmation Order” means the order confirming this Plan. 1.13 “Contested Claim” means: (a) a claim that was scheduled by the Debtors in their Schedules as a disputed, contingent, or unliquidated claim and that has not been otherwise Allowed; (b) a claim that is not an Allowed claim because the Chapter 11 Trustee, Debtors, or other party-in-interest has objected to allowance of the claim under sections 502(b) or 503 of the Bankruptcy Code and Bankruptcy Rule 3007; (c) any secured or unsecured portions of a secured claim that is the subject of a motion for determination of the value of security under section 506(a) of the Bankruptcy Code and Bankruptcy Rule 3012; (d) any claim held by a creditor against which the Chapter 11 Trustee or the Debtors has demanded the recovery of property pursuant to section 502(d) of the Bankruptcy Code, without regard to whether such claim was previously an Allowed claim; (e) a claim that is subject to final adjudication in a proceeding outside the Court against one or more of the Debtors’ insurers; or (f) a claim whose validity or amount is subject to determination in an adversary proceeding that has not been resolved by a Final Order. 1.14 “Court” means the United States Bankruptcy Court for the District of Minnesota. 1.15 “Creditor” means a holder of a claim entitled to distributions under the Plan. 1.16 “Debtors” means the debtors in these Chapter 11 Cases—Minnesota School of Business, Inc. and Globe University, Inc. 1.17 “Department of Education” means the United States Department of Education. 1.18 “Deposit” means the funds deposited by the Debtors in the Hennepin County District Court on account of fees and costs ordered in pre-bankruptcy litigation between the Debtors and the State, having a current balance of $332,589. 1.19 “Disbursing Agent” shall mean James A. Bartholomew, as set forth in Section 7.1.2(a) of this Plan. 1.20 “Disclosure Statement” means the Disclosure Statement for this Plan, as may be further revised, modified, or amended. 1.21 “Effective Date” means the first business day following the day on which the conditions of Section 9.1 of this Plan have been satisfied. 1.22 “Estate Assets” means all of the Debtors’ right, title, and interest in and to property of whatever type or nature as provided in section 541 of the Bankruptcy Code, including Avoidance Claims and Causes of Action, that are not expressly abandoned or otherwise transferred under this Plan. 1.23 “Equity Interest” means an “equity security” as defined in section 101(16) of the Bankruptcy Code.

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1.24 “Equity Interest Holder” means the holder of an Equity Interest in either of the Debtors. 1.25 “Exculpated Trustee Parties” means and the Chapter 11 Trustee, as well as his agents, employees, attorneys, accountants, financial advisors, consultants, and representatives (solely in their capacities as such). 1.26 “Exculpated Debtor Parties” means the Debtors, as well as their shareholders, directors, officers, agents, employees, attorneys, accountants, financial advisors, consultants, and representatives (solely in their capacities as such). 1.27 “Filing Date” means November 20, 2019. 1.28 “Final Determination” means a determination under non-bankruptcy law that has not been stayed, reversed, or amended and to which (a) the time to appeal or seek review or rehearing has expired, and (b) no appeal or petition for review or rehearing was filed or, if filed, remains pending. 1.29 “Final Order” means an order of the Court for which the time to appeal from such order has expired, and which has not been reversed, stayed, modified, or amended. 1.30 “Funded” means cash placed into the Disbursing Account in the total amount sufficient to pay (i) the Allowed General Unsecured Claims existing as of the Effective Date in the approximate amount of $23,898,840; (ii) all Allowed Administrative and Priority Claims as of the Effective Date; and (iii) a reserve (determined by the Chapter 11 Trustee in his sole discretion) in an amount sufficient to pay in full all estimated Administrative Claims (including professional fees, Chapter 11 Trustee fees, and U.S. Trustee fees and any costs associated with closing the Bankruptcy Cases), and any Contested Claims in the event such claims become Allowed. 1.31 “Funding Deadline” means the date that is thirty (30) days after the Effective Date; provided, however, that the Funding Deadline may be extended in ten (10) day increments, not to exceed thirty (30) days in total, at the discretion of the Chapter 11 Trustee, in consultation with the holders of Allowed General Unsecured Claims. 1.32 “General Unsecured Claims” means any Claim that is not an Administrative Claim, Priority Tax Claim, or Unclassified Priority Claim, and is not otherwise classified in Class 1, Class 2, Class 3, Class 5, Class 6 or Class 7. 1.33 “Globe” means Debtor Globe University, Inc. 1.34 “Home Federal Loan” has the meaning set forth in Section 5.2.1 of this Plan. 1.35 “Impaired” means, with respect to a Class of Claims or Equity Interests, a Claim or Equity Interest that is “impaired” within the meaning of sections 1123(a)(4) and 1124 of the Bankruptcy Code. 1.36 “Lake Area Bank Loan” has the meaning set forth in Section 5.1.1 of this Plan. 1.37 “Liquidating Agent” means the person identified in Section 6.10.3 of this Plan.

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1.38 “Liquidating Fund” has the meaning set forth in Section 6.9.2 of this Plan. 1.39 “MSB” means Debtor Minnesota School of Business, Inc. 1.40 “Other Priority Claims” means the claims described in Section 3.3.2 of this Plan. 1.41 “Plan” means this Chapter 11 Plan of Reorganization as revised or modified or amended. 1.42 “Plan Default” shall occur automatically if the Plan is not Funded on or prior to the Funding Deadline. 1.43 “Priority Tax Claim” means a claim that is entitled to priority in payment pursuant to section 507(a)(8) of the Bankruptcy Code. 1.44 “Record Date” means the last date on which a claim transfer will be recognized. The Record Date is the Confirmation Date. 1.45 “Reorganized Debtor” means Minnesota School of Business, Inc., on and after Substantial Consummation. 1.46 “Retained Causes of Action” means Causes of Action held by MSB or Globe for recovery of non-federally guaranteed loans made by MSB or Globe to former students; provided, however, that the Retained Causes of Action shall not include (i) Causes of Action relating to any former student eligible to claim restitution as determined by the State Court in the State Court Litigation, including, without limitation (a) those former students contained on the list of students eligible to claim restitution that the Debtors produced to the State in 2017, and (b) those former students identified on Attachment A to the Settlement Agreement; and (ii) any loans that were determined by the State Court in the State Court Litigation to violate Minnesota state law. 1.47 “Schedules” means the Debtors’ schedules of assets and liabilities and the statement of financial affairs on file with the Clerk of the United States Bankruptcy Court for the District of Minnesota, as amended or modified in accordance with Bankruptcy Rule 1009. 1.48 “Settlement Agreement” shall mean the settlement agreement attached hereto as Exhibit A. 1.49 “State” means the State of Minnesota by and through its Attorney General Keith Ellison. 1.50 “State Court” means the Hennepin County District Court. 1.51 “State Court Litigation” means the pre-petition civil enforcement action brought by the State against MSB and Globe in Hennepin County District Court, entitled Minnesota v. Minnesota School of Business, et al., Case No. 27-cv-14-12558. 1.52 “State’s Revised Claim” shall mean the State’s total Allowed unsecured claim as reduced to $15,801,879.00 by the Settlement Agreement.

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1.53 “Statutory Fees and Court Costs” means court costs and fees payable by the Debtor under 28 U.S.C. § 1930 and United States Trustee fees. 1.54 “Substantial Consummation” occurs when the Debtors have Funded the Plan, so long as the Plan is Funded on or before the Funding Deadline. 1.55 “Unclassified Priority Claims” means the claims described in Article III of this Plan. 1.56 “Unsecured Claims” means all claims that are unsecured, including Unsecured Priority Claims and General Unsecured Claims. 1.57 “Unsecured Priority Claims” means the Priority Tax Claims and Other Priority Claims. 1.58 “Voting Deadline” means the deadline for voting to accept or reject the Plan. ARTICLE II CLASSIFICATION OF CLAIMS AND INTERESTS The following table designates the classes of claims against and equity interests in the Debtors and specifies which of those classes are (i) impaired or unimpaired by the Plan and (ii) entitled to vote to accept or reject the Plan in accordance with section 1126 of the Bankruptcy Code.
Table 1 on page 10. Back to List of Tables
Class Designation Impaired Entitled to Vote
N/A Administrative Expense
Claims
N/A No
N/A Priority Claims N/A No
1 Lake Area Bank No No
2 Home Federal Savings Bank No No
3 General Unsecured Claims Yes Yes
4 Claims of Insiders Yes Yes
5 Intercompany Claims Yes Yes
7 Equity Interests in MSB No No
8 Equity Interests in Globe No No
*N/A = Not applicable. ARTICLE III SETTLEMENT AGREEMENT The terms and provisions of the Settlement Agreement are fully incorporated into this Plan.

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ARTICLE IV TREATMENT OF CERTAIN UNCLASSIFIED PRIORITY CLAIMS Certain Allowed claims which are not classified will be treated as follows: 4.1 Allowed Administrative Expense Claims Except as otherwise provided in this Article, all Allowed claims specified in Bankruptcy Code § 507(a)(2), not previously paid, will be paid in full by the Debtors, Chapter 11 Trustee, Liquidating Agent, Disbursing Agent, or Reorganized Debtor, as applicable, as soon as practicable but no later than ten (10) business days following the later of: (i) the Effective Date, or (ii) the date such claim becomes an Allowed claim. 4.1.1 Professional Fees and Expenses The Debtors and Chapter 11 Trustee have paid and intend to pay professional fees and expenses during the Chapter 11 Cases as allowed by Court orders. Professional fees and expenses incurred through the time of Plan confirmation and not previously Allowed will be subject to Court approval after the Effective Date on a timeline to be determined by the Court. Any such Allowed claims will be paid first from any retainers, and then by the Chapter 11 Trustee, Disbursing Agent, or the Liquidating Agent, as applicable, as such Allowed claims are approved by the Court. All fees incurred by Fredrikson & Byron, P.A. during the period between the appointment of the Chapter 11 Trustee and the Effective Date will be paid solely by the Reorganized Debtor as soon as practicable after (i) Substantial Consummation, and (ii) Fredrikson’s filing of a statement of compensation with the Court as required by Section 329 of the Bankruptcy Code. For purposes of clarity, (i) neither the Debtors’ estates nor the Chapter 11 Trustee are responsible for such fees under the Plan, which will be paid exclusively by the Reorganized Debtor after the Plan is fully Funded and Substantial Consummation has occurred; and (ii) none of amount Funded into the Disbursing Account under the Plan will be used to pay Fredrikson’s fees. 4.2 Statutory Fees and Court Costs Court costs and fees payable by the Debtors under 28 U.S.C. § 1930 will be paid by the Debtors or Reorganized Debtor, as applicable, no later than ten (10) business days after the Effective Date or as required under the Office of the United States Trustee’s quarterly payment guidelines. The Debtors have remained current on such payments. After confirmation, the Reorganized Debtor or the Liquidating Agent, as applicable, will continue to pay quarterly fees to the Office of the United States Trustee and file quarterly reports with the Office of the United States Trustee until these cases are closed by the Court, dismissed, or converted. This requirement is subject to any amendments to 28 U.S.C. § 1930(a)(6) that Congress makes retroactively applicable to confirmed Chapter 11 Cases. 4.3 Unsecured Priority Claims 4.3.1 Priority Tax Claims Allowed Priority Tax Claims will be paid by the Debtors or Reorganized Debtor, as applicable, as soon as practicable but no later than ten (10) business days following the later of: (i)

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the Effective Date, or (ii) the date on which such Priority Tax Claim becomes an Allowed Priority Tax Claim. The Proponents do not anticipate any Allowed Priority Claims. 4.3.2 Other Priority Claims All other Allowed claims not specifically treated in this section and entitled to priority under § 507(a) of the Bankruptcy Code will be paid by the Debtors or Reorganized Debtor, as applicable, in full in cash as soon as practicable but no later than ten (10) business days following the later of: (i) the Effective Date, or (ii) the date on which such claims are Allowed. ARTICLE V TREATMENT OF CLASSIFIED CLAIMS AND INTERESTS 5.1 Class 1 – Lake Area Bank 5.1.1 Classification Classification. Class 1 consists of all Allowed claims arising against the Debtors from that certain Business Loan Agreement dated December 12, 2016, as amended and/or renewed, between (i) Lake Area Bank, as lender, and (ii) MSB and MSB Holdings – Lakeville, LLC, as co-borrowers (the “Lake Area Bank Loan”). 5.1.2 Treatment As of the Effective Date, the Lake Area Bank Loan will continue to be paid in accordance with the terms of the applicable loan documents and MSB will reaffirm its obligations thereunder. 5.1.3 Voting Class 1 is Unimpaired and therefore is deemed to have accepted the Plan. 5.2 Class 2 – Home Federal Savings Bank 5.2.1 Classification Class 2 consists of all Allowed claims against the Debtors arising from that certain Business Loan Agreement dated December 30, 2013, as amended December 30, 2018, between (i) Home Federal Savings Bank, as lender, and (ii) MSB, Globe, and MSB Holdings – Rochester, LLC, as co-borrowers, and that certain Reserve Account Agreement dated December 23, 2016 (together, the “Home Federal Loan”). 5.2.2 Treatment As of the Effective Date, the Home Federal Loan will continue to be paid in accordance with the terms of the applicable loan documents and MSB will reaffirm its obligations thereunder. Home Federal Savings Bank shall retain its interest in the Reserve Account.

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5.2.3 Voting Class 2 is Unimpaired and therefore is deemed to have accepted the Plan. 5.3 Class 3 – General Unsecured Claims 5.3.1 Classification Class 3 consists of General Unsecured Claims. 5.3.2 Treatment Except to the extent that that a holder of an Allowed General Unsecured Claim agrees to a less favorable treatment, each holder of an Allowed General Unsecured Claim shall receive on account of, and in full and complete settlement, release and discharge of such Claim, payment in full in cash on the later of (i) five days after Substantial Consummation; (ii) the date on which such General Unsecured Claim becomes Allowed or as soon thereafter as practicable; or (iii) such other date as may be ordered by the Bankruptcy Court. 5.3.3 Voting Class 3 is Impaired and is therefore entitled to vote to accept or reject the Plan. 5.4 Class 4 – Claims of Insiders 5.4.1 Classification Class 4 consists of all Allowed Insider Claims, other than claims classified in Class 5. 5.4.2 Treatment Except to the extent that that a holder of an Allowed insider claim agrees to a less favorable treatment, Allowed insider claims shall remain outstanding valid obligations. Such claims, however, will be subordinated to Allowed General Unsecured Claims. For the avoidance of doubt, in the event of a Plan Default, Allowed insider claims shall be subordinated to Allowed General Unsecured Claims. 5.4.3 Voting Class 4 is Impaired and therefore entitled to vote to accept or reject the Plan. Such votes, however, will not be counted with respect to determining whether the Plan has been accepted by an impaired class under 11 U.S.C. § 1129(a)(10). 5.5 Class 5 – Intercompany Claims 5.5.1 Classification Class 5 consists of all Allowed claims held by MSB against Globe and all Allowed claims held by Globe against MSB.

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5.5.2 Treatment As of the Effective Date, all intercompany claims between the Debtors shall remain outstanding obligations between the Debtors. Such claims, however, will be subordinated to Allowed General Unsecured Claims. For the avoidance of doubt, in the event of a Plan Default, Allowed Insider Claims shall be subordinated to Allowed General Unsecured Claims. 5.5.3 Voting Class 5 claims are Impaired and are entitled to vote on the Plan. Such votes, however, will not be counted with respect to determining whether the Plan has been accepted by an impaired class under 11 U.S.C. § 1129(a)(10). 5.6 Class 6 – Equity Interests in MSB 5.6.1 Classification Class 6 consists of all Equity Interests in MSB. 5.6.2 Treatment Class 6 Equity Interests shall retain their interests in MSB. 5.6.3 Voting Holders of Class 6 Equity Interests are Unimpaired under the Plan and are therefore not entitled to vote on the Plan. 5.7 Class 7 – Equity Interests in Globe 5.7.1 Classification Class 7 consists of all Equity Interests in Globe. 5.7.2 Treatment Holders of Equity Interests in Globe shall retain their interests. 5.7.3 Voting Holders of Class 7 Equity Interests are Unimpaired under the Plan and are therefore not entitled to vote on the Plan. 5.8 Special Provisions Relating to Creditors’ Rights of Setoff Nothing in this Plan shall expand or enhance a creditor’s right of setoff, which shall be determined as of the Filing Date. Nothing in this Plan is intended to, or shall be interpreted to,

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approve any creditor’s effectuation of a post-Filing Date setoff without the consent of the Chapter 11 Trustee unless prior Court approval has been obtained. ARTICLE VI MEANS OF EXECUTION OF THE PLAN 6.1 Substantive Consolidation 6.1.1 Confirmation Order The Plan contemplates and is predicated upon the Confirmation Order substantively consolidating the Debtors’ Estates and the Chapter 11 Cases as set forth herein. Entry of the Confirmation Order shall constitute the Bankruptcy Court’s approval, pursuant to sections 105(a) and 1123(a)(5)(C) of the Bankruptcy Code, effective as of the Effective Date, of the substantive consolidation of the Estates of the Debtors for the purposes of confirming and consummating the Plan, including, without limitation, voting, confirmation, and Distributions under the Plan. 6.1.2 Treatment of Liabilities Under the Plan On and after the Effective Date, (i) all liabilities of the Debtors shall be treated as though they were pooled, (ii) each Claim filed or to be filed against either Debtor shall be deemed filed as a single Claim against, and a single obligation of, the Debtors, (iii) all Claims held by a Debtor against the other Debtor shall be treated as provided for in Section 5.5.2 of this Plan, (iv) no Distributions shall be made under the Plan on account of any Claim held by a Debtor against the other Debtor, and (v) any liability of any of the Debtors shall be one obligation of the substantively-consolidated Debtors and any Claims based upon such joint or several liability shall be treated as one Claim against the substantively consolidated Debtors. 6.1.3 Preservation of Legal Separateness The substantive consolidation of the Debtors under the Plan shall not (other than for purposes related to funding Distributions under the Plan) affect (i) the legal and organizational structure of the Debtors, (ii) executory contracts or unexpired leases that were entered into during the Chapter 11 Cases or that have been or will be assumed or rejected, (iii) the ability to subordinate or otherwise challenge Claims on an entity-by-entity basis, (iv) any Causes of Action or defenses thereto, which in each case shall survive entry of the Confirmation Order as if there had been no substantive consolidation of the Estates of the Debtors, and (v) distributions to the Debtors from any insurance policies or the proceeds thereof. Notwithstanding the substantive consolidation called for herein, each Debtor shall remain responsible for the payment of U.S. Trustee fees pursuant to 28 U.S.C. § 1930 until its particular case is closed, dismissed, or converted. 6.2 Revesting As of Substantial Consummation, all assets of Globe will be transferred to and vest in MSB, and all such assets shall thereafter remain in MSB, as the Reorganized Debtor, free and clear of all liens, charges, encumbrances, claims, or interests pursuant to § 1141(b) of the Bankruptcy Code, except as otherwise provided in the Plan.

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6.3 Ongoing Operations MSB, as the Reorganized Debtor, shall continue in existence on and after Substantial Consummation. 6.4 Section 1145 Exemption To the maximum extent provided by section 1145 of the Bankruptcy Code and applicable non-bankruptcy law, the offering, issuance, and distribution of any securities issued and distributed pursuant to the Plan will be exempt from, among other items, the registration and prospectus delivery requirements of section 5 of the Securities Exchange Act of 1933 and any other applicable state and federal law requiring registration and/or delivery of a prospectus prior to the offering, issuance, distribution, or sale of securities subject to the provisions of section 1145(b)(1) of the Bankruptcy Code relating to the definition of an “underwriter” in section 2(a)(11) of the Securities Act. To the extent that such exemption under section 1145 is not available with respect to the offering, issuance and distribution of any securities issued and distributed pursuant to the Plan, such offering, issuance and/or distribution, as applicable, will be made pursuant to the exemption set forth in Section 4(a)(2) of the Securities Act or another exemption thereunder. In addition, any securities contemplated by the Plan and any and all agreements incorporated therein, will be subject to (i) compliance with any rules and regulations of the SEC, if any, applicable at the time of any future transfer of such securities or instruments; (ii) the restrictions, if any, on the transferability of such securities and instruments; and (iii) applicable regulatory approval, if any. 6.5 Effectuating Documents; Further Transactions; Exemption from Certain Transfer Taxes The Reorganized Debtor, the Debtors and/or the Liquidating Agent, as the case may be, shall be authorized to execute, deliver, file, or record such contracts, instruments, releases, and other agreements or documents and take such actions as may be necessary or appropriate to effectuate and implement the provisions of this Plan, including, but not limited to, all documentation required by purchasers and title companies to transfer real property on behalf of the Reorganized Debtor, the Debtors, or the Liquidating Fund. Pursuant to section 1146(a) of the Bankruptcy Code, the following shall not be subject to any stamp tax, real estate transfer tax, mortgage recording tax, sales or use tax, or similar tax: (a) the creation of any mortgage, deed of trust, lien, or other security interest; (b) the making or assignment of any lease or sublease; or (c) the making or delivery of any deed or other instrument of transfer under, in furtherance of, or in connection with this Plan, including any merger agreements, agreements of consolidation, restructuring, disposition, liquidation or dissolution, deeds, bills of sale, or assignments executed in connection with any of the foregoing or pursuant to this Plan. 6.6 Plan Funding The Plan shall be Funded on or before the Funding Deadline from the Funding Sources. 6.7 Causes of Action and Avoidance Claims Upon Substantial Consummation and only in such event, all Causes of Action (including Avoidance Claims), except for the Retained Causes of Action, shall be released and waived by the Chapter 11 Trustee, the Debtors, and Debtors’ estates. The Reorganized Debtor shall have no right

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to pursue any Causes of Action except for the Retained Causes of Action upon Substantial Consummation. To the extent permitted by applicable law, the deadline to bring Avoidance Claims under Section 546(a) of the Bankruptcy Code is hereby extended to the later of (i) the Avoidance Claim Deadline, or (ii) the date that is three months after the Plan Default. Notwithstanding the foregoing, any defendant subject to an action asserting Avoidance Claims is not precluded from contesting the validity of the extension provided in part (ii) of this paragraph. 6.8 Management of the Reorganized Debtor On and after Substantial Consummation, Terry Myhre shall continue to be the President of the Reorganized Debtor and Kenneth McCarthy shall continue to be the Chief Financial Officer of the Reorganized Debtor. The Reorganized Debtor shall have no authority or control over the Disbursing Agent or the Disbursing Account. 6.9 Chapter 11 Trustee after Confirmation Date The Chapter 11 Trustee shall continue to serve in such capacity through the earlier of (i) Substantial Consummation, or (ii) the date of a Plan Default. 6.10 Event of Default under Plan Upon the occurrence of a Plan Default and only in such event, the following shall occur: 6.10.1 Revised Claims Notwithstanding anything to the contrary in this Plan or the Settlement Agreement, in the event of a Plan Default (i) the State shall have an Allowed General Unsecured Claim of $35,0000,000; (ii) the Department of Education will not be entitled to the Borrower Defense Discharge Claim as set forth in the Settlement Agreement; and (iii) Tuition Options, LLC shall be entitled to an Allowed General Unsecured Claim of $117,415. 6.10.2 Liquidating Fund All Estate Assets shall become part of a liquidating fund (“Liquidating Fund”), which shall be used for the administrative costs of administrating the Plan and for payments to holders of Allowed Claims and Equity Interests in accordance with the terms of the Plan under the direction of the Liquidating Agent. The transfer of assets and rights to the Liquidating Fund shall not be construed to destroy or limit any such assets or rights or be construed as a waiver of any right, and such rights may be asserted by the Liquidating Fund as if the asset or right was still held by the Debtors. 6.10.3 Liquidating Agent James A. Bartholomew, the Chapter 11 Trustee, shall serve as the Liquidating Agent. In the event of the resignation or termination of the Liquidating Agent, any successor Liquidating Agent shall be appointed by the Oversight Committee. The Liquidating Agent’s primary tasks are to receive the Liquidating Fund, liquidate assets, pursue causes of action, administer claims, and

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distribute proceeds for the benefit of Creditors. The Liquidating Agent will file a motion, application, or other request to close the Debtors’ Chapter 11 Cases when the cases have been fully administered. 6.10.4 Powers and Duties of the Liquidating Agent Subject to the direction and consent of the Oversight Committee, in addition to the powers and authority specifically provided elsewhere in the Plan, the Liquidating Agent shall receive the Liquidating Fund, have the powers of an agent to act for the holders of claims under the Plan on account of such claims and be a “representative of the estate” as set forth in 11 U.S.C. § 1123(b)(3)(B) together with the power and authority to (a) hold, manage or sell the Estate Assets, (b) effectuate all actions and execute all agreements, instruments and other documents necessary to implement the provisions of this Plan, including, but not limited to, all documentation required by purchasers and title companies to transfer real property on behalf of the Debtors (or its subsidiaries) and the Liquidating Fund, (c) establish reserves for Contested Claims, taxes, assessments, professional fees, and other expenses of administration of the Liquidating Fund as may be necessary and appropriate for the operation of the Liquidating Fund, (d) calculate and make distributions from the Liquidating Fund to the holders of all Allowed Claims in accordance with the provisions of this Plan, (e) investigate, prosecute, litigate, settle or compromise any objections to claims, Avoidance Claims, and Causes of Action on behalf of the Debtors and those claims may be settled or compromised without notice and a hearing and without Court approval (but subject to the consent of the Oversight Committee), (f) review, reconcile or object to claims and resolve such objections as set forth in this Plan, (g) object to the amount of any claim on the Debtor’s Schedules if the Liquidating Agent determines in good faith that the claim is invalid, has previously been paid or satisfied, or other grounds exist for an objection, (h) defend, protect, and enforce any and all rights and interests transferred to the Liquidating Fund or Liquidating Agent, (i) retain professionals and incur any reasonable and necessary expenses in performance of its duties, and to the extent such payments are approved by the Oversight Committee, to pay those expenses without any further application to the Bankruptcy Court, (j) pay any and all claims, liabilities, losses, damages, costs, and expenses incurred by the Liquidating Agent, including all fees and expenses of the Liquidating Agent and professionals retained by the Liquidating Agent, (k) file estate or other tax returns, (l) operate assets for periods reasonably required to preserve or maximize value pending liquidation and distribution to Creditors, (m) open, create, or close accounts to deposit, hold, and disburse funds, (n) invest cash in demand or time deposits to obtain market rates of return pending distributions, (o) file any and all reports and motions or requests for relief with the court or any opposition thereto, (p) extend, renew, enter into, authorize, and benefit from any insurance policies, including but not limited to tail coverage for insurance policies in place on the Filing Date, and rights of indemnification, (q) dissolve the Debtors or otherwise wind up any of the Debtors’ corporate affairs and existence, (r) subject to approval of the Oversight Committee, incur indebtedness to fund administration of the Plan, (s) perform any other functions that are necessary to effectuate this Plan and perform its duties as Liquidating Agent, (t) have the power and authority to administer the closure of the Chapter 11 Cases, and (u) if and to the extent required to effectuate any action necessary in the performance of the Plan or wind up of the Debtors’ corporate affairs and existence, have the power and authority to reconstitute the board of directors of the Debtors, by: (i) re-appointing one or more of the former directors (specifically, those who were serving on the Filing Date) who agree to the reappointment, or (ii) seeking an order of the Court appointing a board of directors. In all circumstances, the Liquidating Agent will act in the best interests of the Creditors.

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6.10.5 Compensation and Retention of Professionals The Liquidating Agent will be entitled to be paid reasonable compensation and expenses from the Liquidating Fund in accordance with the provisions of Section 326(a) of the Bankruptcy Code, subject to the consent of the Oversight Committee. The Liquidating Agent will be entitled to retain professionals without court approval but with consent of the Oversight Committee to assist in its duties, and will be entitled to pay such professionals reasonable compensation and expenses, subject to the consent of the Oversight Committee. Subject to the consent of the Oversight Committee, the Liquidating Agent may hire former employees and other “insiders” (as that term is defined in the Bankruptcy Code) of the Debtors for post-confirmation services, and may pay such individuals reasonable compensation and expenses. The Liquidating Agent may retain attorneys, consultants, and other professionals that represent the Debtors or the Chapter 11 Trustee, subject to the consent of the Oversight Committee. Fees that the professionals incur after a Plan Default may be paid out of the Liquidating Fund, subject to the consent of the Liquidating Agent and Oversight Committee, or by Court Order. Any dispute as to such compensation and expenses between the Liquidating Agent, its professionals, and the Oversight Committee, or any objection by any party in interest as to such compensation and expenses, will be resolved by the Court on motion. 6.10.6 Removal of Liquidating Agent At any time upon thirty (30) days’ written notice to the Liquidating Agent and upon a unanimous vote by the members of the Oversight Committee, the Oversight Committee may file a notice with the Court stating that it has removed the Liquidating Agent and appointed a successor Liquidating Agent. The notice shall identify the successor Liquidating Agent. 6.10.7 Oversight Committee The Oversight Committee shall consist initially of: (i) a representative of the State, and (ii) a representative of the Department of Education. The Oversight Committee may act with as few as two members. In the event that a resignation or termination of members of the Oversight Committee reduces the number of members to less than two members, then one successor member shall be appointed by the remaining member and the Liquidating Agent. The Oversight Committee will monitor the Liquidating Agent and all activities set forth in this Plan. The Oversight Committee will have the power and authority to ratify or reject decisions of the Liquidating Agent, and in its discretion, the Oversight Committee may delegate to the Liquidating Agent such power and authority as it deems proper. The members of the Oversight Committee will not be paid for their services except for reimbursement of actual expenses incurred by such members. The Oversight Committee will be governed by by-laws substantially in the form of those attached as Exhibit B. In the event that a vote by the Oversight Committee results in a tie vote, the Liquidating Agent (although not a member) shall be entitled to vote on that issue as set forth in the by-laws. 6.10.8 Effectuating Documents, Further Transactions, Exemption from Certain Transfer Taxes The Liquidating Agent shall be authorized to execute, deliver, file, or record such contracts, instruments, releases, and other agreements or documents, and take such actions as may be necessary or appropriate to effectuate and implement the provisions of this Plan, including, but not

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limited to, all documentation required by purchasers and title companies to transfer real property on behalf of the Debtors’ subsidiaries or the Liquidating Fund. Pursuant to section 1146(a) of the Bankruptcy Code, the following shall not be subject to any stamp tax, real estate transfer tax, mortgage recording tax, sales or use tax, or similar tax: (a) the creation of any mortgage, deed of trust, lien, or other security interest; (b) the making or assignment of any lease or sublease; or (c) the making or delivery of any deed or other instrument of transfer under, in furtherance of, or in connection with this Plan, including any merger agreements, agreements of consolidation, restructuring, disposition, liquidation or dissolution, deeds, bills of sale, or assignments executed in connection with any of the foregoing or pursuant to this Plan. 6.10.9 Liability and Indemnification Neither the Liquidating Agent nor any member of the Oversight Committee, nor any of their designees, employees, professionals, or agents will be liable for the act or omission of any other designee, employee, professional, or agent, nor will the Liquidating Agent or the Oversight Committee members be liable for any act or omission taken or omitted to be taken in their respective capacities, other than acts or omissions resulting from willful misconduct, gross negligence, or fraud. The Liquidating Agent, Oversight Committee members, and their designees, employees, professionals, and agents shall be indemnified and held harmless, including the cost of defending such claims and the attorney fees in seeking indemnification, by the Liquidating Fund against any and all claims arising out of their duties under this Plan, except to the extent their actions constitute willful misconduct, gross negligence, or fraud. 6.10.10 Preservation of Causes of Action and Avoidance Claims Upon the occurrence of a Plan Default, the Liquidating Agent shall be vested in and retain, as the representative of the estates under section 1123(b)(3)(B) of the Bankruptcy Code, all Causes of Action, including Avoidance Claims, and the Liquidating Agent may enforce or not enforce, consistent with its fiduciary duties, any Causes of Action that the Debtors, the Chapter 11 Trustee, the estates, or the Liquidating Agent may hold against any entity. No person may rely on the absence of a specific reference in the Plan or the Disclosure Statement to any Cause of Action against them as any indication that the Debtors, Chapter 11 Trustee or the Liquidating Agent will not pursue any and all available Causes of Action against them. The Debtors and Chapter 11 Trustee expressly reserves all Causes of Action, including Avoidance Claims, for later enforcement by the Liquidating Agent, unless and until Substantial Consummation occurs. Therefore, no preclusion doctrine shall apply to a Cause of Action upon, after, or as a consequence of, the Confirmation Order. The Liquidating Agent may, at its option, compromise any Cause of Action, Avoidance Claim, or any other claim, interest, or objection retained herein after a Plan Default without notice and a hearing and without Court approval, subject to unanimous approval by the Oversight Committee. To the extent required by the Bankruptcy Code, the Liquidating Agent is hereby designated as the “Plan Representative.” All recoveries on the Causes of Action and Avoidance Claims shall be retained by the Liquidating Agent for making distributions under this Plan after a Plan Default. Nothing in this Plan shall shorten or otherwise affect the Liquidating Agent’s deadline to assert Avoidance Claims or other Causes of Action as governed by section 546(a) of the Bankruptcy Code or other applicable law.

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6.10.11 Closing of Cases The Chapter 11 Trustee shall retain full authority to close these Chapter 11 Cases on and after the Effective Date, Substantial Consummation, and/or a Plan Default. ARTICLE VII DISTRIBUTIONS AND CLAIMS ADMINISTRATION 7.1 Distributions Except as provided elsewhere in the Plan, distributions shall be made as set forth in the treatment of each class of claims. 7.1.1 Distributions Upon Plan Default – Liquidating Agent In the event of a Plan Default and in accordance with Section 6.9.3 of this Plan, the Liquidating Agent shall be responsible for liquidating Estate Assets and making distributions, including interim distributions as deemed practicable by the Liquidating Agent and Oversight Committee, with a final distribution after determining that all Estate Assets, including Causes of Action and Avoidance Claims, that feasibly could be liquidated have been liquidated and that the next distribution will be the final distribution. 7.1.2 Distributions Upon Substantial Consummation – Disbursing Agent Upon Substantial Consummation, the following provisions shall apply: a. Disbursing Agent James A. Bartholomew will be responsible for making distributions required under the Plan as the Disbursing Agent from the Disbursing Account. In the event the Disbursing Agent resigns or is no longer able to serve in such capacity, the State shall appoint the successor Disbursing Agent. b. Disbursing Account The amount Funded under the Plan shall be segregated into a separate bank account (“Disbursing Account”) held by the Disbursing Agent. The Disbursing Account shall be used for payment of holders of Allowed Claims in accordance with the terms of the Plan. The Disbursing Agent shall have sole authority and control over the Disbursing Account. c. Distribution to State The State’s Revised Claim will be deemed paid and satisfied as of the date the amounts Funded under this Plan are placed into the Disbursing Account. 7.2 Method of Distribution Unless otherwise agreed to by the claim holder or otherwise provided herein, distributions under this Plan will be made by check, mailed with first class postage pre-paid, to the holder of each claim at the address listed on its proof of claim as of the Record Date, or if no proof of claim

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has been filed by the date of the hearing on confirmation, to the address listed on the Schedules as of the Record Date. Distributions shall be deemed made when postmarked. 7.2.1 Payments to Former Students on Account of State’s Claim Payments to Former Students on account of the State relating to Usury Loan Restitution Claims and Student Cash Restitution Claims can be made directly by the Disbursing Agent or Liquidating Agent, as applicable, to former students at the sole direction of the State. In the event a payment delivered by the Disbursing Agent or Liquidating Agent, as applicable, directly to a Former Student is returned with no indication of the Former Student’s forwarding address, the Disbursing Agent or Liquidating Agent, as applicable, will hold such payment for a period of 120 days from the date of return to allow the State time to locate the Former Student. If not claimed by the Former Student and the State cannot locate the Former Student within that timeframe, the payment will be delivered by the Disbursing Agent or Liquidating Agent to the Unclaimed Property Division of the Minnesota Department of Commerce. In the event that a payment delivered by the Disbursing Agent or Liquidating Agent to a Former Student is not returned but remains uncashed as of the date that is 60 days after postmarked delivery date of the payment, the Disbursing Agent or Liquidating Agent, as applicable, shall cancel the check and hold such payment for an additional 120 days to allow the State time to locate the Former Student. If at that point the Former Student has not claimed the payment or the State has not located the Former Student, it will be delivered by the Disbursing Agent or Liquidating Agent to the State to be placed in the Unclaimed Property Division of the Minnesota Department of Commerce. 7.2.2 Unclaimed Distributions In the event a distribution check to the holder of an Allowed Claim pursuant to the Plan is returned to the Liquidating Agent or Disbursing Agent, with no indication of the payee’s forwarding address, the Liquidating Agent or Disbursing Agent, as applicable, will hold such payment for a period of 90 days from the date of return. If not claimed by the payee by the end of that period, the payment will be delivered to the Unclaimed Property Division of the Minnesota Department of Commerce. In the event a distribution is not returned but remains uncashed as of the date that is 60 days after postmarked delivery date of the distribution, the Disbursing Agent or Liquidating Agent, as applicable, shall cancel the check and hold such payment for an additional 60 days. If at that point the payee has not claimed the payment, it will be delivered to the Unclaimed Property Division of the Minnesota Department of Commerce. 7.3 Claims Administration Responsibility 7.3.1 Reservation of Rights to Object to Claims Unless a claim is specifically Allowed under the Plan, or otherwise Allowed prior to or after the Effective Date, the Debtors, Reorganized Debtor, Chapter 11 Trustee, Disbursing Agent, or Liquidating Agent, as applicable, shall have and retain any and all objections to any and all

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claims and motions or other requests for the payment of claims, whether administrative expense, secured, or unsecured, including, without limitation, any and all objections to the validity or amount of any and all alleged administrative expense claims, priority tax claims, liens and security interests, whether under the Bankruptcy Code, other applicable law, or contract. 7.3.2 Filing of Objections Unless otherwise ordered by the Court in the Confirmation Order, any objections to claims, except objections to administrative expense claims or objections arising under 11 U.S.C. § 502(d), will be filed no later than sixty (60) days after the Effective Date (unless such day is not a business day, in which case such deadline will be the next business day thereafter) or at such later date as approved by the Court. Any claim objections arising solely under 11 U.S.C. § 502(d) are not subject to the 60-day deadline and may be pursued through an adversary proceeding asserting an Avoidance Claim. 7.3.3 Determination of Claims Except as otherwise agreed by the Reorganized Debtor, Debtors, Chapter 11 Trustee, Disbursing Agent, or the Liquidating Agent, as applicable, any Claim as to which a proof of claim or motion or other request for payment was timely filed in the Chapter 11 Cases may be determined and liquidated pursuant to (a) a Final Order of the Court, or (b) a Final Determination under applicable non-bankruptcy law, and will be deemed Allowed in such liquidated amount and satisfied in accordance with this Plan. Unless and until Substantial Consummation, nothing contained in this Plan, the Disclosure Statement, or the Confirmation Order will constitute or be deemed a waiver of any claim, right, interest, or Cause of Action that the estates, the Chapter 11 Trustee, the Liquidating Agent, or the Liquidating Fund may have against any person in connection with or arising out of any claim or claims, including, without limitation, any rights under section 157(b) of Title 28 of the United States Code. On and after Substantial Consummation, the Disbursing Agent and Reorganized Debtor shall have the authority to assert, compromise, settle, otherwise resolve, or withdraw any objections to Claims, and compromise, settle, or otherwise resolve any other form of contested Claims, without further approval of the Bankruptcy Court. 7.4 Procedures for Treating and Resolving Contested Claims 7.4.1 No Distributions Pending Allowance Notwithstanding any other provision of this Plan, no payments or distributions will be made with respect to the portion of a Claim that is a Contested Claim unless and until all objections to such Contested Claim have been settled or withdrawn or resolved by a Final Order, and the Contested Claim at issue has become an Allowed Claim. 7.4.2 Claim Estimation The Debtors, the Chapter 11 Trustee, Disbursing Agent, or the Liquidating Agent, as applicable may request estimation or limitation of any Contested Claim that is contingent or unliquidated pursuant to section 502(c) of the Bankruptcy Code; provided, however, that the Court will determine (i) whether such Contested Claim is subject to estimation pursuant to section 502(c)

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of the Bankruptcy Code and (ii) the timing and procedures for such estimation proceedings, if any. Unless provided otherwise in an order of the Court, the estimated amount shall constitute the Allowed amount of such Claim or a maximum limitation on such claim, as the Court may direct; provided, however, that if the estimate constitutes the maximum limitation on such claim, the Debtors may elect to pursue supplemental proceedings to object to the ultimate allowance of such Claim. The foregoing shall not limit the rights granted by Section 502(j) of the Bankruptcy Code. 7.4.3 No Distribution if Cause of Action Asserted Notwithstanding any other provision in this Plan and except for claims that are Allowed Claims pursuant to a Final Order of the Bankruptcy Court entered prior to the Confirmation Date, no payment or distribution will be made with respect to all or any portion of a Claim or Allowed Claim held by a claimant against whom a Cause of Action is asserted unless and until such Cause of Action has been settled or withdrawn or has been determined by Final Order. 7.4.4 Payment Upon Allowance and Disallowance of Contested Claims At such time as a Contested Claim becomes, in whole or in part, an Allowed claim, the Disbursing Agent or the Liquidating Agent, as applicable, shall distribute to the holder thereof the distribution(s) to which the holder is then entitled under the Plan. 7.4.5 Record Date The Record Date for any claim transfers shall be the Confirmation Date. Payments under the Plan will be mailed to the address of the holder of the Allowed Claim as of the Record Date until the holder of the Allowed Claim as of the Record Date notifies the Debtors, Chapter 11 Trustee, or Liquidating Agent, as appropriate, in writing of a different address. ARTICLE VIII EXECUTORY CONTRACTS AND UNEXPIRED LEASES 8.1 Executory Contracts and Unexpired Leases The executory contracts and unexpired leases identified on Exhibit C shall be deemed assumed as of Substantial Consummation or Plan Default, without the need for further notice or action, order, or approval of the Bankruptcy Court. The Reorganized Debtor in the event of Substantial Consummation or Liquidating Agent in the event of a Plan Default, shall satisfy the applicable requirements of section 365 of the Bankruptcy Code, including payment of any default amount and any actual pecuniary loss resulting from such default (“Cure Amount”). The Cure Amount for each Assumed Contract identified on Exhibit C shall be paid as of the date of assumption or on such other terms as the counterparty to such Assumed Contract otherwise agrees, in full satisfaction of amounts required to be paid pursuant to section 365(b)(1)(B) of the Bankruptcy Code. Entry of the Confirmation Order shall constitute, pursuant to sections 365 and 1123 of the Bankruptcy Code, approval of the assumption of the Assumed Contracts. Except for the Assumed Contracts, all other executory contracts and unexpired leases not previously assumed or rejected by Order of the Court in the Bankruptcy Cases or as otherwise provided for in the Bankruptcy Code shall be deemed rejected as of the Effective Date. Entry of

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the Confirmation Order shall constitute, pursuant to sections 365 and 1123 of the Bankruptcy Code, the approval of the rejection of all such executory contracts and unexpired leases. To the extent not subject to a claims bar date set forth in any prior or subsequent order of the Court, claims arising out of the rejection of an executory contract or unexpired lease must be filed with the Court no later than 30 days after the entry of the Confirmation Order and, upon allowance, shall be an Allowed General Unsecured Claim, unless such claimant is an insider, in which case the claim will be treated as an insider Claim in Class 4. Any rejection claims not filed within such applicable time periods shall be forever barred from receiving a distribution under the Plan. ARTICLE IX CONFIRMATION OF THE PLAN 9.1 Conditions Precedent to Effective Date The following are conditions precedent to the occurrence of the Effective Date: (i) the Confirmation Order shall have been entered by the Bankruptcy Court and be a Final Order, be in full force and effect, and not subject to any stay or injunction; and (ii) approval of the Settlement Agreement through the Plan. 9.2 Conditions Precedent to Substantial Consummation Substantial Consummation shall not occur unless (i) the Effective Date has occurred, and (ii) the Debtors have Funded the Plan by the Funding Deadline. 9.3 Waiver of Conditions to Confirmation or Effective Date The conditions to Confirmation and the conditions to the Effective Date may be waived or modified in whole or in part at any time by the Proponents. 9.4 Cramdown The Proponents requests confirmation under section 1129(b) of the Bankruptcy Code with respect to any impaired class that has not accepted or is deemed not to have accepted this Plan pursuant to section 1126 of the Bankruptcy Code. 9.5 Effect of Confirmation of the Plan 9.5.1 Title to and Vesting of Assets To the extent allowed by section 1141(b) of the Code, as of Substantial Consummation, all property of the Debtors and the estates vests in the Reorganized Debtor, and such property is free and clear of all liens, encumbrances, claims, and interests of creditors and equity security holders, except to the extent the Plan explicitly provides that such liens, encumbrances, claims, or interests are retained. From and after Substantial Consummation, the Reorganized Debtor, may operate, use, acquire, and dispose of property in accordance with the Plan, free and clear of any restrictions of the Bankruptcy Code and the Bankruptcy Rules, and in all respects as if there were no pending case under any chapter or provision of the Bankruptcy Code, except as provided in the Plan.

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9.5.2 Corporate Action Upon Substantial Consummation, all matters provided for herein that would otherwise require approval of the stockholders or directors of the Debtors shall be deemed to have occurred and shall be in effect from and after Substantial Consummation pursuant to the applicable general corporation law of Minnesota, without any requirement of further action by the stockholders or directors of the Debtors. 9.5.3 Injunction Against Interference with the Plan The Plan is binding on the Debtors, any Creditor, any holder of Equity Interests, or others to the full extent provided in section 1141(a) of the Code. All entities who are bound by the Plan, including entities with claims not listed on the Schedules, or who are listed on the Schedules as disputed, unliquidated, or contingent and who did not timely file proofs of claim, are hereby enjoined and prevented from commencing or continuing any judicial or administrative proceeding or employing any process to interfere with the consummation or implementation of the Plan or the payments to be made hereunder, including commencing or continuing any judicial or administrative proceeding or employing any process against the Debtors, their estates, or the Chapter 11 Trustee; provided, however, such injunction shall not prohibit any entity from pursuing actions they may have against non-debtor third parties, except as otherwise set forth in the Plan. Notwithstanding the foregoing, the State, Chapter 11 Trustee, Liquidating Agent, and Disbursing Agent, as applicable, are entitled to take such actions as necessary in the pre-bankruptcy litigation between the State and the Debtors to (i) file quarterly or other reports as directed by the state court; (ii) release the Deposit for purposes consistent with this Plan; and (iii) take other actions necessary to conclude proceedings in the litigation. 9.5.4 Discharge To the extent permitted by § 1141 of the Bankruptcy Code, Substantial Consummation of the Plan shall serve to discharge, waive, and release the Reorganized Debtor from any debt that arose before Substantial Consummation and any debt of a kind specified in Sections 502(g), 502(h), or 502(i) of the Bankruptcy Code, regardless of whether or not proof of the Claim based on such debt was filed or deemed filed under Section 501 of the Bankruptcy Code, such Claim is allowed under Section 502 of the Bankruptcy Code, or the holder of such Claim has accepted the Plan. To the extent permitted by the Bankruptcy Code, the payments of, distributions on account of, or treatments of Claims in this Plan are deemed to satisfy in full all Claims. For the avoidance of doubt, the Debtors will not receive a discharge in the event of a Plan Default. 9.5.5 Permanent Injunction In the event of Substantial Consummation, and except as provided in this Plan, as of the Effective Date and subject to its occurrence, all persons that have held, currently hold, or may have asserted a claim, a Cause of Action or other debt, liability, interest, or other right of a holder of an equity interest that is discharged, released, or terminated pursuant to the Plan, are hereby permanently enjoined from commencing or continuing against the Debtors, in any manner or in any place, any: action or other proceeding; enforcing, collecting, or recovering in any manner any

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judgment, award, decree, or order; creating, perfecting, or enforcing any lien or encumbrance; and/or asserting a set-off, right of subrogation, or recoupment of any kind against any debt, liability or obligation. 9.5.6 Exculpation Subject to the occurrence of the Effective Date, none of the Exculpated Trustee Parties shall have or incur any liability to any holder of a claim or interest for any act or omission in connection with, related to, or arising out of, the Chapter 11 Cases and this Plan, the solicitation of this Plan, the pursuit of confirmation of this Plan, the consummation of this Plan, the administration of this Plan, or the property to be distributed under this Plan; provided, however, that: (a) nothing herein is meant to or shall be deemed to expand or otherwise modify the scope of 11 U.S.C. § 1125(e); (b) nothing herein is meant to or shall be deemed to affect the police and regulatory activities of governmental agencies; (c) the Exculpated Trustee Parties shall be entitled to rely upon the advice of counsel with respect to their duties and responsibilities under this Plan; and (d) nothing in this Plan shall, or shall be deemed to, release or exculpate the Exculpated Trustee Parties with respect to their respective obligations or covenants arising pursuant to this Plan, or for any gross negligence, willful misconduct, or fraud. Subject to the occurrence of Substantial Consummation, none of the Exculpated Debtor Parties shall have or incur any liability to any holder of a claim or interest for any act or omission in connection with, related to, or arising out of, the Chapter 11 Cases and this Plan, the solicitation of this Plan, the pursuit of confirmation of this Plan, the consummation of this Plan, the administration of this Plan, or the property to be distributed under this Plan; provided, however, that: (a) nothing herein is meant to or shall be deemed to expand or otherwise modify the scope of 11 U.S.C. § 1125(e); (b) nothing herein is meant to or shall be deemed to affect the police and regulatory activities of governmental agencies; (c) the Exculpated Debtor Parties shall be entitled to rely upon the advice of counsel with respect to their duties and responsibilities under this Plan; and (d) nothing in this Plan shall, or shall be deemed to, release or exculpate the Exculpated Debtor Parties with respect to their respective obligations or covenants arising pursuant to this Plan, or for any gross negligence, willful misconduct, or fraud. ARTICLE X RETENTION OF JURISDICTION Notwithstanding the entry of the Confirmation Order, the occurrence of the Effective Date, and the occurrence of Substantial Consummation of the Plan, the Court shall retain such jurisdiction over the Chapter 11 Cases after the Effective Date as is legally permissible to the full extent permitted by the Code, including jurisdiction to: a. Allow, disallow, determine, liquidate, reduce, classify, re-classify, estimate, or establish the priority or secured or unsecured status of any claim, including the resolution of any request for payment of any Administrative Expense Claims, and the resolution of any objections to the amount, allowance, priority, or classification of claims; b. Determine all questions and disputes regarding title to the assets of the estates to the extent required for the implementation or execution of the Plan;

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c. Either grant or deny any applications for allowance of compensation or reimbursement of expenses authorized pursuant to the Bankruptcy Code or this Plan for periods ending on or before Substantial Consummation; d. Resolve any matters related to the assumption, assumption and assignment, or rejection of any executory contract or unexpired lease to which the Debtors were or are a party or with respect to which the Debtors may be liable and to hear, determine and, if necessary, liquidate any claims arising therefrom; e. Ensure that distributions to holders of Allowed claims are accomplished pursuant to the provisions of this Plan; f. Decide or resolve any motions, adversary proceedings, contested or litigated matters, and any other matters and either grant or deny any applications involving the Debtors or the Chapter 11 Trustee that may be pending on the Effective Date or brought thereafter; g. Enter such orders as may be necessary or appropriate to implement or consummate the provisions of this Plan and all contracts, instruments, releases, and other agreements or documents entered into or delivered in connection with this Plan, the Disclosure Statement, or the Confirmation Order; h. Resolve any cases, controversies, suits, or disputes that may arise in connection with the consummation, interpretation, or enforcement of this Plan or any contract, instrument, release, or other agreement or document that is entered into or delivered pursuant to this Plan, or any entity’s rights arising from or obligations incurred in connection with this Plan or such documents; i. Modify this Plan before or after the Effective Date pursuant to section 1127 of the Bankruptcy Code; modify the Disclosure Statement, the Confirmation Order or any contract, instrument, release, or other agreement or document entered into or delivered in connection with this Plan, the Disclosure Statement, or the Confirmation Order; or remedy any defect or omission or reconcile any inconsistency in any Court order, this Plan, the Disclosure Statement, the Confirmation Order, or any contract, instrument, release, or other agreement or document entered into, delivered, or created in connection with this Plan, the Disclosure Statement, or the Confirmation Order, in such manner as may be necessary or appropriate to consummate this Plan; j. Issue injunctions, enforce the injunctions contained in this Plan and the Confirmation Order, and enter and implement other orders or take such other actions as may be necessary or appropriate to restrain interference by any entity with consummation, implementation, or enforcement of this Plan or the Confirmation Order; k. Enter and implement such orders as are necessary or appropriate if the Confirmation Order is for any reason or in any respect modified, stayed, reversed, revoked, or vacated, or distributions pursuant to this Plan are enjoined or stayed; l. Determine any other matters that may arise in connection with or in relation to this Plan, the Disclosure Statement, the Confirmation Order, or any contract, instrument, release, or other agreement or document entered into or delivered in connection with this Plan, the Disclosure Statement, or the Confirmation Order;

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m. Enforce or clarify any orders previously entered by the Court in the Chapter 11 Cases; n. Enter a final decree closing the Chapter 11 Cases; o. Determine matters concerning state, local, and federal taxes in accordance with sections 346, 505, and 1146 of the Bankruptcy Code, including any Contested Claims for taxes; p. Recover all assets of the Debtors and the estates, wherever located; and q. Hear any other matter not inconsistent with the Bankruptcy Code. ARTICLE XI MISCELLANEOUS PROVISIONS 11.1 Modification of the Plan Subject to the restrictions on alteration, amendment, and modification set forth in section 1127 of the Bankruptcy Code, the Proponents reserve the right to alter, amend, or modify this Plan before the Effective Date. 11.2 Revocation of the Plan The Proponents reserve the right to revoke or withdraw this Plan prior to the Confirmation Date. If the Proponents revoke or withdraw this Plan, or if confirmation does not occur, then this Plan shall be null and void in all respects, and nothing contained in this Plan shall: (a) constitute a waiver or release of any claims by or against the Debtors, (b) prejudice in any manner the rights of the Debtors or any other party in interest, or (c) constitute an admission of any sort by the Debtors or any other party in interest. 11.3 Severability of Plan Provisions If, prior to Confirmation, any term or provision of this Plan is held by the Court to be invalid, void, or unenforceable, the remainder of the terms and provisions of this Plan shall remain in full force and effect and shall in no way be affected, impaired, or invalidated by such holding, alteration, or interpretation. The Confirmation Order shall constitute a judicial determination and shall provide that each term and provision of this Plan, as it may have been altered or interpreted in accordance with the foregoing, is valid and enforceable pursuant to its terms. 11.4 Corporate Documents The certificates of incorporation of the Debtors and related documents will be amended to the extent necessary as required by section 1123(a)(6) of the Bankruptcy Code and as may otherwise be required by this Plan. 11.5 Regulated Rates This Plan affects no rates subject to approval by any governmental regulatory commission.

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11.6 Successors and Assigns The rights, benefits, and obligations of any entity named or referred to in this Plan shall be binding on, and shall inure to the benefit of, any heir, executor, administrator, successor, or assign of such entity. 11.7 Governing Law The rights, duties, and obligations arising under the Plan shall be governed by, and construed and enforced in accordance with, the Bankruptcy Code and, to the extent not inconsistent therewith, the laws of the State of Minnesota, without giving effect to principles of conflict of laws. 11.8 Construction The section headings contained in this Plan are for reference purposes and shall not affect in any way the meaning or interpretation of the Plan. To the extent of any inconsistencies between the information contained in the Disclosure Statement and the terms and provisions of the Plan, the terms and provisions of the Plan shall govern. [signature page follows]

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SIGNATURE PAGE TO SECOND MODIFIED JOINT PLAN OF REORGANIZATION OF THE CHAPTER 11 TRUSTEE AND DEBTORS DATED JULY 15, 2021 IN WITNESS WHEREOF, the undersigned has executed this Second Modified Joint Plan of Reorganization as of the date set forth above. James A. Bartholomew, Chapter 11 Minnesota School of Business, Inc. Trustee By: Terry Myhre Its: President/Chairman Globe University, Inc. By: Terry Myhre Its: President/Chairman STINSON LLP FREDRIKSON & BYRON, P.A. /e/ Phillip J. Ashfield /e/ Clinton E. Cutler Edwin H. Caldie (#0388930) Clinton E. Cutler (#0158094) Phillip J. Ashfield (#0388990) James C. Brand (#387362) 50 South Sixth Street Suite 2600 Samuel M. Andre (#0399669) Minneapolis, MN 55402 200 South Sixth Street Telephone: 612.335.1500 Suite 4000 Facsimile: 612.335.1657 Minneapolis, MN 55402-1425 (612) 492-7000 COUNSEL TO THE CHAPTER 11 TRUSTEE ATTORNEYS FOR THE DEBTORS

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EXHIBIT A Settlement Agreement

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AGREEMENT THIS AGREEMENT (“this Agreement”) is made and entered into by and among the following parties (“the Parties”): James A. Bartholomew, Chapter 11 Trustee (“the Trustee”) for Globe University (“Globe”) and Minnesota School of Business (“MSB”), the State of Minnesota by and through its Attorney General Keith Ellison (“the State”), Terry L. Myhre and Kathryn M. Myhre, on behalf of the equity owners of MSB and Globe (“the Myhres”), the United States Department of Education (“Education”), and Tamara Blanchette, plaintiff in the matter Blanchette v. DeVos, 19-cv-1774 (D.D.C.) (“Blanchette”). Recitals A. On November 20, 2019, MSB and Globe filed petitions seeking protection under Chapter 11 of the United States Bankruptcy Code 11 U.S.C. § 101 et seq. (the “Bankruptcy Code”), in the cases entitled In re Minn. Sch. of Bus., No. 19-33629 (Bankr. D. Minn.), and In re Globe Univ., Inc., No. 19-33629 (Bankr. D. Minn.) (the “Bankruptcy Cases”). B. On May 13, 2020, James A. Bartholomew was appointed as Chapter 11 Trustee in the Bankruptcy Cases and continues to serve as the Trustee. C. Prior to the Bankruptcy Cases, the State and the Debtors were parties to a pre-petition civil enforcement action brought by the State against MSB and Globe in Hennepin County District Court, entitled Minnesota v. Minnesota School of Business, Inc. et al., Case No. 27-cv-14-12558 (the “State’s Litigation”), in which the State, acting in its parens patriaeauthority and Minn. Stat. § 8.31, sought restitution for former students in MSB’s and Globe’s criminal justice program (the “Former MSB/Globe Students”). D. On September 9, 2016, the Hennepin County District Court issued its Findings of Fact, Conclusions of Law, and Order (the “FFCLO”), finding that MSB and Globe violated the Minnesota Consumer Fraud Act, Minn. Stat. § 325F.69, and Deceptive Trade Practices Act, Minn. Stat. § 325D.44, in its marketing, recruitment, and advertising of its criminal justice program. The court subsequently issued a Second Amended Order for Restitution on July 21, 2017, in which it established a process for Former MSB and Globe Students to submit claims in order to qualify for payment of restitution. E. Certain Former MSB/Globe Students, identified in Attachment A to this Agreement (the “Participating Students”), testified at the trial in the State’s Litigation or submitted claims to participate in restitution awarded to the State. F. The State filed Claim No. 95 in the MSB bankruptcy case and Claim No. 9 in the Globe bankruptcy case (together, “the State’s Claims”) asserting claims arising from the State’s Litigation. G. After MSB and Globe objected to the State’s Claims, the parties to such objections entered into a compromise, approved by the Bankruptcy Court on December 22, 2020, pursuant to which the State was granted an allowed unsecured claim in the amount of $35,000,000 in the Bankruptcy Cases.

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H. The restitution awarded to the State as part of the State’s Litigation includes, among other amounts, refunds to Participating Students of amounts financed through federal student loans from (or guaranteed by) Education and owed by Participating Students, including but not limited to costs, fees, interest and other charges, for attendance at MSB and Globe between 2009 and 2016 (the “Federal Loan Obligations”), as well as reimbursement of amounts paid by Participating Students on those loans. I. Based on limited student loan data held and provided by Education, MSB’s and Globe’s tuition and payment records, and payment information provided to the State by student loan servicers related to the Federal Loan Obligations, the Trustee has reasonably estimated past payments made to or collected by Education, whether voluntarily or involuntarily, towards the Participating Students’ Federal Loan Obligations (the “Federal Loan Restitution”). J. The Debtors, in their schedules of assets and liabilities filed in the Bankruptcy Cases, scheduled an unliquidated and disputed claim in favor of Education for chargebacks of potential discharged student loans. K. Education filed Claim No. 8 in the Globe bankruptcy case and Claim No. 60 in the MSB bankruptcy case asserting that MBS and Globe owed Education $1,852,889 due to the discharge of federal student loans made or guaranteed by Education due to MSB’s and Globe’s closure (together, “Closed School Discharge Claim”). L. After MSB and Globe objected to the Closed School Discharge Claim, MSB, Globe, and Education entered into a compromise (the “Closed School Discharge Compromise”), approved by the Bankruptcy Court on October 16, 2020, pursuant to which Education was granted an allowed claim of $1,350,000 and was permitted to offset $331,039.38 in funds owed Globe against this claim, resulting in a remaining Closed School Discharge Claim in the amount of $1,018,960.62. M. Education is party to litigation brought by Blanchette against Education on June 18, 2019, entitled Blanchette v. DeVos, No. 19-cv-1775 (D.D.C.) (the “Blanchette Litigation”), in which Blanchette (who is a Participating Student), on behalf of herself and a putative class of Former MSB/Globe Students, alleges that their Federal Loan Obligations are subject to “borrower defense discharge applications” pursuant to 34 C.F.R. § 685.206 and § 685.222, rendering such loan obligations unenforceable against Former MSB/Globe Students, and that Education unlawfully subjected Former MSB/Globe Students to involuntary collection procedures based on the Federal Loan Obligations. N. Education has agreed to treat the Participating Students as having filed borrower defense discharge applications. As a result, each of the Participating Students has a borrower defense discharge application on file with Education. O. Education, in connection with a denial of recertification of MSB and Globe as Title IV lenders issued on December 6, 2016, reviewed relevant documents from the Minnesota Litigation, including the FFCLO and the Second Amended Restitution Order, and determined that such Orders established that MSB and Globe, inter alia: (1) committed fraud involving federal student loan program funds; and (2) substantially misrepresented the nature

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of its criminal justice program and the employability of criminal justice program graduates. Education is adjudicating Participating Students’ borrower defense discharge applications based on these violations of Minnesota law. P. Education contends that it holds contingent claims against the Estate and the Myhres for reimbursement, should it grant borrower defense discharges to the Participating Students (the “Borrower Defense Liabilities”). The Myhres, Debtors, and Chapter 11 Trustee contend that Education is not entitled to any such claims based on, among other possible defenses, a release of claims in the Closed School Discharge Compromise. Q. The Trustee and Debtors filed on March 15, 2021, a Joint Chapter 11 Plan of Reorganization, as modified on April 29, 2021 (the “Plan”)1 under which one hundred percent (100%) of all allowed unsecured claims shall be paid after Substantial Consummation, subject to the terms set forth in this Agreement. As set forth in the Plan, the Debtors and Myhres must provide full Funding on or before the Funding Deadline in order for Substantial Consummation to occur. R. The Parties wish to obtain certainty and alleviate the substantial risks, costs, and delays associated with further litigation and/or collection related to the matters described herein. S. The Parties have negotiated a fair and global resolution of the matters referenced in this Agreement and have executed this Agreement subject to approval of the Bankruptcy Court. Agreement NOW THEREFORE, for good and valuable consideration, the receipt and sufficiency of which are hereby expressly acknowledged, the Parties agree as follows: 1. Confirmation of Chapter 11 Plan. The Trustee and Debtors shall seek confirmation of the Plan paying and satisfying in full one hundred percent (100%) of all allowed unsecured claims after Substantial Consummation. This Agreement shall be attached as an Exhibit to the Plan or included with a plan supplement to be filed prior to confirmation of the Plan, and the provisions of the Plan shall incorporate the material terms of this Agreement. MSB, Globe, and the Myhres agree to cooperate with the Trustee’s efforts to confirm and fund the Plan. 2. Adjustment to State’s Allowed Claim. Except in the case of default as provided in paragraph 10 below and as otherwise provided in this paragraph, the Allowed State Claim is hereby reduced by $19,198,121 and is hereby allowed in the amount of $15,801,879 (the “State’s Adjusted Allowed Claim”). In addition, any BDDC Adjustment Amount (as described in paragraph 4 below) shall be added to the State’s Adjusted Allowed Claim up to a maximum of $7,000,000. The State will allocate the BDDC Adjustment Amount to the Participating Students 1 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the Plan.

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whose borrower defense discharge application are denied or whose loans are not discharged or released for other reasons, as additional restitution on account of the outstanding amount of the Participating Students’ Federal Loan Obligations. The amount paid on the State’s Adjusted Allowed Claim will be distributed by the State, or agent authorized by the Plan, to the Participating Students as determined by the Attorney General pursuant to Minn. Stat. § 8.31. Distributions by the State to Participating Students will include the Federal Loan Restitution. The Trustee and the State may also agree to permit the Trustee (or other agent designated under the Plan) to remit such amounts determined in the Attorney General’s discretion directly to the Participating Students from the Disbursing Account or as otherwise allowed by the Plan. The State, Trustee and/or other agent designated under the Plan shall use all reasonable efforts to make Federal Loan Restitution payments to Participating Students, and shall provide a certification (the “Payment Certification”) in writing within thirty (30) days after the Funding Date designated in the Plan, specifying: (1) the payments of Federal Loan Restitution that have been made to Participating Students; and (2) any payments have not been released to Participating Students and the reason such payments have not been released. 3. Borrower Defense Discharges or Release. Education’s receipt of any payment for its Borrower Defense Discharge Claim (as defined in Paragraph 4 below) is conditioned on it completing adjudication of all Participating Students’ borrower defense discharge applications (“Discharge Determinations”). If Education is unable to complete Discharge Determinations within thirty (30) days after Substantial Consummation, Education shall provide written notice to the parties to this Agreement, indicating the Discharge Determinations that have not been made and its projected time for completing such Discharge Determinations. If any Participating Student’s borrower defense discharge application is denied as part of the Discharge Determination, Education may, to the extent permitted by federal law, review and determine whether such Participating Student’s Federal Loan Obligations can be discharged or released for any other reason (“Supplemental Determination”). 4. Stipulated Claim Allowance to Education. Education is hereby granted a stipulated allowed general unsecured claim of $7,000,000 for the Participating Students’ Borrower Defense Liabilities against each of MSB and Globe (the “Borrower Defense Discharge Claim”), provided that the United States is not waiving, and may exercise at any time, all rights of setoff or recoupment that it may hold concerning such claim, and the Borrower Defense Discharge Claim shall be treated as secured to the extent of such right, if any, and provided further, that in no event shall Education be entitled to receive more than $7,000,000 in cash and the value of any such setoff or recoupment against the Borrower Defense Discharge Claim. Education’s Borrower Defense Discharge Claim will be against both MSB’s and Globe’s bankruptcy estates, provided that Education is only entitled to a single satisfaction and recovery for the Borrower Defense Discharge Claim. The United States shall provide written notice to all parties to this Agreement upon completion of all the Discharge Determinations and Supplemental Determinations, and the Trustee shall then pay in cash the Borrower Defense Discharge Claim amount as adjusted, if any as provided herein, or satisfied through setoff or recoupment within fourteen (14) days after such notice, provided that, if Education denies any Participating Student’s borrower defense discharge application as part of the Discharge Determination and does not discharge or release the Participating Student’s loan as part of the Supplemental Determination, Education’s total Borrower Defense Discharge Claim shall be

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reduced by the amount of the Participating Student’s outstanding Federal Loan Obligation at the time of Education’s adjudication (“BDDC Adjustment Amount”). In the event the Plan is not Funded by the Funding Deadline, Education will not be entitled to the Borrower Defense Discharge Claim through this Agreement, but reserves the right, if any, to assert any claims relating to any Borrower Defense Liability. 5. Education’s Closed School Loan Discharge Claims. The Borrower Defense Discharge Claim is separate from and does not subsume the Closed School Discharge Claim. This Agreement does not alter or amend the Closed School Discharge Compromise. In the event Substantial Consummation occurs under the Plan, the Closed School Discharge Claim shall be paid in full within fourteen (14) days following Substantial Consummation. 6. Education’s Release. Except as provided below in paragraph 7, upon Substantial Consummation, Education releases and forever discharges the Trustee in his capacity as Trustee of the bankruptcy estates of the Debtors; MSB; Globe; all current and former officers, directors, and employees of MSB and Globe; and the Myhres from any and all Participating Students’ Borrower Defense Liabilities. The release provided for in this paragraph shall in no way affect, alter, limit, extend, or ratify the release of claims provided by Education in the Closed School Discharge Compromise. 7. Limitation on Release. The release provided in paragraph 6 does not release or affect any other claim, liability, or cause of action of the United States not the subject of such releases, and without any party conceding the existence or merits thereof, the United States does not release any other claim, liability, or cause of action for: (i) any civil, criminal, or administrative liability arising under Title 26 of the United States Code (the Internal Revenue Code); (ii) any criminal liability; (iii) any liability under subchapter III of chapter 37 of Title 31 of the United States Code; (iv) any liability that is based on conduct in violation of antitrust laws; (v) any claim of any agency of the United States of America other than Education, or any of the mutual obligations in this Agreement. 8. Dismissal of Blanchette Litigation. No later than ten (10) days following Education’s discharge of the Federal Loan Obligations described in this Agreement (including any loan obligation owed to Education by Blanchette) and Blanchette’s receipt of her portion of any restitution amount paid pursuant to the State’s Adjusted Allowed Claim, Blanchette and Education shall prepare and file such documents as are necessary to effectuate a dismissal of the Blanchette Litigation with prejudice. 9. Blanchette’s Release. Effective upon Education’s discharge of Federal Loan Obligations as described in paragraph 3 (including any loan obligation owed to Education by Blanchette) and Blanchette’s receipt of her portion of any amount paid pursuant to the State’s Adjusted Allowed Claim, Blanchette hereby releases and forever discharges Education, together with its predecessors, representatives, independent contractors, agents, assigns, and successors in interest, from any and all actions, causes of actions, claims, suits, proceedings, known or unknown, which she hereto ever had, now has, or may have or shall have, arising out of or resulting from any claim made by Blanchette, or that could have been made by Blanchette, in

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connection with or related in any way to her portion of the Federal Loan Obligations, including the claims she has asserted in the Blanchette Litigation. 10. Bankruptcy Court Approval/Effectiveness. This Agreement will be incorporated into the Plan. The terms of this Agreement and the effectiveness thereof are subject to and conditioned upon either a final, non-appealable order of the Bankruptcy Court: (1) approving the terms of this Agreement and authorizing the Trustee to enter into the Agreement; or (2) confirming the Plan, provided that the order approves the terms of this Agreement and authorizes the Trustee to enter into the Agreement. 11. Condition Precedent to Effectiveness. The occurrence of Substantial Consummation under the Plan is a condition to the effectiveness of this Agreement, and the failure of such condition shall constitute a default under this Agreement. Upon such a default, the terms of this Agreement (including, without limitation, the releases contained herein and the adjustment of the State’s Allowed Claim) will have no further force or effect, and the rights and obligations of the parties shall revert to their pre-settlement positions. 12. Execution and Delivery. This Agreement may be executed in counterparts, which taken together shall constitute one agreement binding on all the Parties. Electronically transmitted signatures shall be valid and binding to the same extent as signatures delivered in original. In making proof of this Agreement, it will be necessary to produce only one copy signed (or reproduced from an electronically delivered signature) by the Party to be charged. 13. Amendment to the November 27 Agreement. Except as set forth in this Agreement, the November 27 Agreement between the Trustee, the State, and the Myhres remains in full force and effect in accordance with its terms. If there is a conflict between this Agreement and the November 27 Agreement, the terms of this Agreement shall prevail. 14. Integrated Agreement. This Agreement constitutes all agreements, covenants, representations, and warranties, express or implied, oral or written, of the Parties; all prior and contemporaneous conversations, negotiations, possible and alleged agreements, representations, covenants and warranties are merged herein; and this is an integrated agreement. This Agreement may not be enlarged, modified or altered, except in a writing signed by all the Parties hereto expressly referencing this Agreement. 15. No Presumption against Drafter. Each Party acknowledges that, with the assistance of counsel, it has participated in the drafting of this Agreement. The Parties agree that this Agreement has been negotiated at arm’s length by parties of equal bargaining power, each of whom was represented by competent counsel of its own choosing. None of the Parties hereto shall be considered to be the drafter of this Agreement or any provision hereof for the purpose of any statute, case law or rule of interpretation or construction that would or might cause any provision to be construed against the drafter hereof. 16. Capacity. Each Party declares and represents that it is competent to execute this instrument and that it is duly authorized, and has the full right and authority, to execute this Agreement on behalf of the Party for whom he or she is signing.

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17. Governing Law and Enforcement. This Agreement and any interpretation of this Agreement shall be governed by Federal law. To the extent that state law would inform the Federal rule of decision, the applicable state law to inform the Federal rule of decision shall be the laws of the State of Minnesota. The Bankruptcy Court retains jurisdiction to interpret and enforce this Agreement. (signature pages follow)

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(cid:45)(cid:88)(cid:79)(cid:92)(cid:3)(cid:20)(cid:24)

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IN WITNESS WHEREOF, the undersigned have executed this Agreement. Dated: ____________, 2021 UNITED STATES DEPARTMENT OF JUSTICE Augustus T. Curtis Trial Attorney United States Department of Justice Civil Division 1100 L. Street NW WashingtonD.C.20005 (202 598-7524 Robert C. Merritt Trial Attorney United States Department of Justice Civil Division 1100 L. Street NW WashingtonD.C.20005 (202 598-7524 Attorneys for the United States DepartmentofEducation Dated: __Ju_n_e_ _9______, 2021 KEITH ELLISON Minnesota AttorneyGeneral BY: ADAM WELLE Assistant Attorney General 445 Minnesota Street, Suite 120 St Paul, MN 55101 adam.welle@ag.state.mn.us (651) 757-1425 Attorneys for the State of Minnesota, Attorney General Keith Ellison

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Globe University, Inc. •~ fV ,2021 mes Bartholomew Chapter 11 Trustee Minnesota School of Business, Inc. - Dated~ 2021 ames Bartholomew Chapter 11 Trustee Dated: _____, 2021 Terry L. Myhre, on behalf of himself and the equity owners of Minnesota School of Business, Inc. and Globe University, Inc. Dated: _____, 2021 Kathryn M. Myhre, on behalf of herself and the equity owners of Minnesota School of Business, Inc. and Globe University, Inc. Dated: _____, 2021 Robyn K. Bitner (D.C. Bar No. 1617036) NATIONAL STUDENT LEGAL DEFENSE NETWORK 1015 15th Street N.W., Suite 600 Washington, D.C. 20005 Telephone: (202) 734-7496 E-mail: robyn@defendstudents.org Attorney for Tamara Blanchette

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Globe University, Inc. Dated: ____________, 2021 James Bartholomew Chapter 11 Trustee Minnesota School of Business, Inc. Dated: ____________, 2021 James Bartholomew Chapter 11 Trustee Dated: ____________, 2021 Terry L. Myhre, on behalf of himself and the equity owners of Minnesota School of Business, Inc. and Globe University, Inc. Dated: ____________, 2021 Kathryn M. Myhre, on behalf of herself and the equity owners of Minnesota School of Business, Inc. and Globe University, Inc. Dated: ____J_u_n_e_ 9____, 2021 Robyn K. Bitner (D.C. Bar No. 1617036) NATIONAL STUDENT LEGAL DEFENSE NETWORK 1015 15th Street N.W., Suite 600 Washington, D.C. 20005 Telephone: (202) 734-7496 E-mail: robyn@defendstudents.org Attorney for Tamara Blanchette

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Attachment A

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials JA 413182 JA 837184 LA 1442502 CA 914080 HA 1228532 JA 431583 JA 555066 MA 223516 MA 259107 MA 1038068 DA 568814 CA 50118 SA 667505 IA 599976 NA 808936 JA 396904 KA 699236 HA 952144 KA 1224909 EA 307061 PA 1134198 CA 1113946 AA 874960 SA 1415949 AA 595005 JA 1469076 DA 417941 AA 543219 DA 576620 SB 1036898 SB 673326 CB 940235 LB 390565 KB 1137620 KB 542620 JB 1412681 EB 264039 JB 1432282 GB 1187333

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials TB 845640 TB 563205 AB 876496 MB 904167 AB 626874 RB 389336 RB 230399 AB 1251368 SB 994087 AB 873915 BB 928540 DB 667971 SB 979221 LB 1177256 JB 806216 EB 969497 RB 1046769 TB 870261 AB 102326 PB 700490 TB 917393 AB 703129 MB 387790 SB 694862 KB 829493 TB 540127 NB 700617 SB 935791 TB 886360 BB 681140 EB 1030602 AB 175919 DB 870691 LB 643742 CB 69435 KB 280851 CB 345537 CB 906915 JB 924869

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials TB 402566 TB 51418 AB 641091 MB 289542 KB 631991 TB 820083 VB 538706 JB 924788 AB 233356 CB 1304671 MB 967238 CB 605166 AB 51513 JB 1026933 AB 445723 WB 1404020 KB 619098 RB 620705 JB 879640 RB 976340 NB 341496 RB 1320887 JB 904706 JB 832970 MB 166571 LB 1162880 DB 578466 LB 439421 ZB 1379276 CB 918134 RB 259579 DB 1468093 AB 434779 CB 1471554 LB 951857 KB 1261687 LB 178979 JB 1075700 BB 546602

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials SB 547762 NB 807763 SB 946951 DC 850855 CC 1039571 AC 1221028 DC 623419 AC 627146 CC 1062772 RC 346787 SC 1422863 AC 1265059 MC 601207 AC 649451 LC 891370 BC 665288 SC 936186 VC 875568 KC 579202 AC 1375294 BC 313597 LC 543627 EC 876410 AC 878037 TC 553409 SC 991973 RC 584520 JC 881941 KC 1399696 AC 1292185 CC 886270 EC 654558 BC 813723 BC 1165939 AC 1160988 JC 655421 MC 381686 DC 903175 JC 643543

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials RC 875553 AC 669544 ZC 642214 JC 654839 LC 611387 NC 703009 DC 828779 KC 332895 PC 570640 TC 651773 MC 1351783 TC 826536 SC 283188 NC 291465 TD 1067431 FD 1390300 SD 875918 SD 806772 AD 113866 ND 638729 JD 1359026 RD 350490 JD 951912 JD 1019681 JD 930544 RD 1143532 JD 1178236 SD 1429983 KD 1131903 AD 860071 JD 398146 LD 1028268 AD 1236109 LD 421796 JD 564962 BD 562006 KD 554701 SD 618698 LD 953954

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials ED 184866 BD 673786 BD 389640 PD 1352093 TD 590375 LD 581754 CD 1015451 CE 903995 SE 448355 AE 1468390 CE 1020553 FE 1059645 ME 606707 TE 333705 DE 805927 JE 212121 BE 342637 LE 673421 KE 826031 TE 1383422 ME 578423 SE 949501 TE 974612 EE 199311 SE 557760 SE 915285 KE 1013194 MF 322726 PF 1431955 VF 912133 MF 1103536 NF 559331 AF 1080663 PF 913258 MF 911418 EF 1114105 DF 915191 CF 199222 JF 829727

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials BF 405575 SF 344943 SF 444473 JF 1041411 KF 1281572 MF 913752 CF 289274 KF 1178521 TF 305948 CF 331094 SF 53885 BF 811208 TF 949878 JF 613965 DF 921868 NF 331139 AF 1203927 SF 1166819 HG 1022050 JG 423688 AG 659785 CG 1112744 EG 821991 SG 875692 KG 564423 JG 435979 BG 805844 TG 1137285 LG 1052673 NG 815135 NG 1182946 SG 626844 RG 860956 RG 951082 KG 426687 BG 599342 SG 54196 NG 668260 HG 964090

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials JG 942682 MG 126788 CG 971666 LG 799846 BG 1080318 HG 1181940 KG 398128 CG 631743 EG 345541 CG 1176935 CG 261935 RG 598693 BG 1084985 TG 169800 AG 185942 CG 334790 BG 849970 RG 866550 TG 823014 CG 1084957 AG 1181298 TH 888409 RH 696344 AH 818255 BH 939094 JH 848145 AH 575752 JH 223461 TH 1112245 KH 932256 AH 1059612 SH 812135 DH 890514 JH 646282 MH 683229 GH 971369 VH 159771 SH 985712 AH 661761

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials RH 317225 BH 285605 MH 618811 GH 622105 HH 133199 WH 283270 CH 426440 MH 320760 MH 352214 SH 662069 HH 55051 SH 649212 SH 620403 WH 830087 CH 1473343 JH 571473 KH 350045 AH 591355 JH 683835 EH 922741 RH 919656 SH 1171056 TH 1258794 JH 926853 SH 1016652 KH 814653 IH 444024 TH 1031123 SH 1001934 DH 1153427 KH 312029 KH 128221 DH 267494 AH 959416 TH 244871 TH 569928 DH 1278340 MH 1065440 MH 586262

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials JI 335821 HI 951001 HI 988238 SI 1382161 SJ 907025 AJ 571237 SJ 155443 JJ 1190134 VJ 861789 KJ 171224 JJ 404599 JJ 306086 DJ 807967 TJ 546147 CJ 971213 AJ 282461 BJ 541907 MJ 335168 DJ 1327026 RJ 894164 MJ 973592 AJ 818646 AJ 973046 KJ 602565 BJ 615399 CJ 1221458 AJ 814148 SJ 1135896 AJ 609756 SK 88304 CK 606115 AK 801197 VK 349382 CK 843204 DK 1345597 MK 627183 SK 1210620 JK 698339 TK 873070

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials TK 920078 MK 623636 TK 568545 JK 996184 SK 825589 VK 900373 TK 1096842 SK 826393 AK 118388 KK 52139 MK 56812 JK 1347280 JK 967071 MK 203265 KK 1379798 JK 611439 KK 190633 BK 319558 LK 620472 MK 664037 KK 664657 AK 893073 JK 433257 GK 879056 TK 911484 AK 595582 RK 977157 VK 944535 DK 328961 BK 1012977 KK 881055 BK 835779 KK 925437 AK 548062 SK 1003642 KK 556282 AL 596884 LL 885866 JL 413426

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials AL 386743 LL 813916 LL 405319 BL 837980 JL 308930 JL 867763 SL 1086893 JL 682529 VL 800949 TL 447482 SL 581782 KL 820880 NL 425095 JL 557864 TL 1349582 CL 1307536 BL 220666 SL 672582 JL 978166 AL 559954 WL 646017 TL 1342574 AL 922274 CL 160967 RL 1243276 LL 130667 AL 410091 ML 578162 HL 1384384 JL 1148784 BL 147467 CL 1421782 JL 327543 RL 1152139 EL 568522 AL 57706 VL 624588 TL 855150 HL 1161976

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials JL 159369 JL 663381 LL 1230106 JL 1037619 TL 859001 CL 814484 SL 186975 JL 327373 CM 248177 MM 617306 AM 408547 AM 579941 DM 905568 SM 937454 TM 411635 TM 328498 KM 989632 NM 200174 KM 343923 CM 403645 MM 811012 TM 1116763 NM 1188491 SM 322142 MM 900726 DM 702670 TM 621514 TM 921078 RM 631212 SM 808068 SM 687333 SM 1393396 HM 1356988 LM 95653 NM 332443 MM 1046863 KM 210023 FM 58360 KM 1068800

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials SM 846607 EM 131788 PM 447665 JM 416056 HM 676747 DM 341530 AM 1028529 GM 1188904 NM 177262 MM 416116 NM 685318 EM 648554 SM 607926 AM 918371 KM 923115 JM 1106732 RM 1075853 MM 1165521 TM 564131 JM 1083792 IM 964151 MM 654577 SM 413299 EM 258875 JM 989504 HM 348918 RM 815919 DM 1227747 RM 910152 KM 547259 JM 875166 CM 846895 PM 837093 NM 646998 IM 1106285 FM 397436 AM 629787 SM 650101 CM 1397263

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials AM 928959 SM 229308 CM 1235994 TM 412192 TM 970385 DM 1206186 JM 98957 CM 667989 JM 1066370 MN 145184 KN 999912 MN 606849 AN 1438297 TN 827272 MN 967863 KN 382005 DN 445513 MN 1238731 AN 1263954 KN 1305915 SN 1125832 TN 814626 EN 569567 TN 414459 KN 595321 SN 973539 BN 317461 JN 1106123 FN 1119188 MN 646898 AO 856320 TO 100871 GO 1381779 AO 442300 PO 923478 HO 1189473 LO 699185 BO 816672 TO 271827

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials MO 588261 HO 574314 SO 1185717 TO 820942 MO 1244650 SO 59766 AO 859297 BO 889753 AO 961603 AO 979105 AO 609910 CO 800187 JO 541764 CP 699084 KP 972500 KP 248679 CP 1132743 HP 1373176 SP 948729 SP 801277 TP 570035 TP 624383 CP 435945 VP 875416 EP 439063 GP 311596 MP 1078725 RP 846545 AP 434785 KP 328151 SP 889064 SP 659751 CP 680493 DP 391090 DP 626032 KP 886681 AP 180936 AP 936523 YP 1039968

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials KP 824668 AP 1215183 KP 1378307 CP 966244 JP 699788 AP 985989 CP 828594 AP 248250 NP 607402 JP 658570 GP 104009 TP 1065974 EP 971495 SP 1033148 SP 1116203 JP 244923 AP 835812 KP 1039344 HQ 428159 JQ 834096 KR 971813 SR 612846 SR 1344814 AR 653826 MR 1014318 KR 390997 KR 1112404 LR 1255269 FR 1075034 ER 581044 NR 172365 AR 1299260 JR 259521 MR 968747 RR 942633 JR 691461 LR 868148 TR 398901 KR 806941

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials NR 547773 AR 867298 RR 960373 LR 972430 CR 545452 WR 969382 CR 687539 CR 350574 BR 589853 RR 578989 SR 896177 ER 993067 RR 1013441 MR 1093490 JR 305836 TR 106309 HR 1102608 NR 293890 SR 622479 DR 106529 MR 900504 LR 691904 CR 1156813 LR 589627 DR 1113758 JR 822958 PR 1370212 AR 700538 TR 625600 SR 1208138 VS 649858 TS 1027084 JS 1339196 AS 419640 ES 1133645 KS 922370 IS 891659 NS 430033 SS 608883

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials KS 576906 MS 621026 AS 1383815 JS 929712 MS 1113746 DS 439201 MS 282740 CS 195504 SS 1223601 BS 1120380 KS 697371 PS 943472 BS 1307290 SS 1092561 MS 1172613 BS 302511 SS 627996 AS 855392 LS 545504 TS 1468505 JS 907329 AS 583661 DS 664587 TS 1329587 DS 673738 JS 1065481 BS 1140927 DS 660640 ES 283070 RS 614006 JS 434772 LS 680610 NS 426151 KS 1438191 CS 813436 JS 657615 LS 263991 JS 1358928 MS 1310338

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials JS 430299 RS 423768 NS 872833 MS 1170016 AS 1337134 JS 438203 CS 844126 DS 859583 MS 1466748 TS 576827 MS 859501 TS 665678 CS 1097063 JS 1114463 KS 297869 KS 206221 AS 688707 LS 389414 SS 302013 BS 389057 TS 606024 MS 289787 AS 613812 TS 189064 KS 1122879 JS 438304 VS 437230 CS 1069245 CS 329162 JS 157256 TS 683451 RS 1268112 CS 860211 AS 992873 SS 552736 JS 1074190 CS 645135 AS 1250234 HS 641129

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials ES 627473 TS 949217 KS 155196 CS 569889 JS 1119597 DS 679824 JS 1407065 ZS 917715 MS 185229 HS 642249 MT 554284 ET 409946 ST 594825 RT 925539 KT 1013395 MT 1445974 AT 591577 KT 954619 AT 1126761 BT 1346909 AT 236594 LT 916737 DT 1133569 NT 1077261 DT 693018 CT 352052 MT 414934 NT 1369256 PT 949986 KT 820516 JT 279214 CT 890048 BT 1115179 ET 947030 NT 916630 OT 1043322 HT 562943 RT 327638 MT 1067469

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials RT 903105 ST 558676 KT 855047 JT 241994 BT 890613 AT 1100633 AT 968481 MT 694367 MU 1041602 SU 649281 AU 651262 JV 686084 WV 550208 DV 658186 CV 349896 PV 624813 VV 558521 CV 588827 SV 1231831 SV 987158 AV 1271516 SV 885493 EV 914790 JV 1144390 KV 556616 AW 254365 SW 585508 DW 627922 ZW 388712 DW 867833 MW 445183 LW 1178312 TW 1077196 SW 1257257 SW 691827 TW 687504 SW 538642 KW 397989 CW 1092464

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials SW 1132325 DW 408633 JW 872183 BW 603177 RW 968467 GW 852806 EW 584439 BW 1258602 JW 1169060 CW 575616 RW 210735 SW 1012706 DW 154511 YW 978454 KW 440460 CW 946562 AW 1105120 MW 603046 MW 701194 BW 949245 MW 941863 AW 1355723 MW 402383 CW 302509 NW 594571 JW 646374 SW 1016046 MW 243210 TW 1244097 NY 418941 TY 552894 TY 564043 BZ 832618 EZ 669851 AZ 814954 JZ 683539 AZ 662988 AZ 336022 NZ 589325

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Schedule of Participating Students with outstanding Federal Loan ObligationsAttachment A to Settlement Agreement Student  Student ID Initials Total 920

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EXHIBIT B Oversight Committee By-Laws

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BY-LAWS OF THE OVERSIGHT COMMITTEE In re MINNESOTA SCHOOL OF BUSINESS, INC. AND GLOBE UNIVERSITY, INC. Case Nos. 19-33629, 19-33632 1. THE COMMITTEE. 1.1. Appointment of Committee. On _________, 2021, the United States Bankruptcy Court for the District of Minnesota (“Bankruptcy Court”) entered an order confirming the Joint Plan of Reorganization (“Plan”) filed by the Minnesota School of Business, Inc. (“MSB”), Globe University, Inc. (“Globe” and, together with MSB, the “Debtors”), and James A. Bartholomew, in his former capacity as Chapter 11 Trustee (“Chapter 11 Trustee” and, together with the Debtors, the “Proponents”). Pursuant to the Plan, all Estate Assets1 became part of the Liquidating Fund, which shall be used to liquidate remaining Estate Assets and distribute the proceeds according to the terms of the Plan under the direction of the Liquidating Agent. Under Section 6.10 of the Plan and as a result of the Plan Default, this Oversight Committee was appointed to undertake the powers and duties granted to it as set forth in the Plan, including monitoring the Liquidating Agent and the activities set forth in the Plan. 1.2. The members of the Oversight Committee are referred to individually herein as a “Member” and collectively as the “Members.” The functions of the Oversight Committee are set forth in the Plan. All Members of the Oversight Committee shall have the duties imposed upon committee members pursuant to 11 U.S.C. § 1103. 1.3. Membership. The Oversight Committee is composed of the Members listed in Exhibit A, which also identifies the representatives for the respective Members where appropriate. The Oversight Committee shall initially consist of two Members that hold significant claims against the Debtors. 1.4. Chairperson. The Oversight Committee will select its chairperson (“Chairperson”) at its first meeting. In the event the Chairperson resigns or for any other reason is unable to serve, the majority of the Members entitled to vote shall choose a successor. Additionally, such a majority may at any time, with or without cause, replace the Chairperson at: (i) a meeting called with at least three days’ advance written notice, or (ii) a meeting attended by all Members. 1.5. Other Professional Persons. Pursuant to Section 6.10.3 of the Plan, James A. Bartholomew will serve as the Liquidating Agent. The Liquidating Agent will be entitled to be paid reasonable compensation and expenses from the Liquidating Fund in accordance with the provisions of Section 326(a) of the Bankruptcy Code, subject to the consent of the Oversight Committee. The Liquidating Agent is entitled to retain professionals to assist in its duties and to pay such professionals’ reasonable compensation and expenses, subject to the consent of the Oversight Committee. Through execution of these By-Laws, the Oversight Committee consents to the Liquidating Agent’s retention of (i) Stinson LLP, to serve as the Liquidating Agent’s general 1 All capitalized terms not otherwise defined herein shall have the meanings given to them in the Plan.

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bankruptcy counsel (“Counsel”), and (ii) Winthrop & Weinstine, P.A. to serve as special counsel relating to Avoidance Actions (“Special Counsel”). 1.6. Resignation. A Member may resign at any time by giving written notice thereof to the Liquidating Agent and a copy to Counsel. 1.7. Replacement of Representative of Member. If any representative of a Member that is a corporate entity resigns, dies, is no longer employed by, or is no longer an agent of the Member represented, or for any other reason is unable to serve, the Member represented shall have the absolute right to designate a successor representative or alternate, as the case may be, which shall be any authorized employee or agent of such Member. 1.8. Resignation, Removal, and Replacement Members. In the event of the resignation or removal of any Member of the Oversight Committee, the Oversight Committee shall perform all of its functions with its reduced number (disregarding such vacancy for purposes of determining a majority). The Oversight Committee may act with as few as two (2) members. If the resignation or removal reduces the number of members to less than two (2) members, then one successor Member shall be appointed by the remaining Member and the Liquidating Agent. 2. MEETINGS AND ACTION BY THE OVERSIGHT COMMITTEE. 2.1. Calling and Notice. Meetings of the Oversight Committee may be called by the Chairperson, the Liquidating Agent, or by Counsel, and shall be called by Counsel, the Liquidating Agent, or the Chairperson upon the request of two of the voting Members. Notice of the time and place of each meeting of the Oversight Committee shall be given to each Member and its counsel no less than two (2) business days in advance of such meeting except when such notice is impractical or unreasonable due to exigent circumstances. No notice of an adjourned meeting need be given, other than by announcement at the meeting at which the adjournment is taken and by reasonable notice (under the circumstances) to any Members and their counsel who were not present at such meeting. The Oversight Committee shall endeavor, whenever feasible, to determine at each meeting when the next meeting shall be held. If feasible, each notice of a meeting shall be in writing; if not, notice may be given orally, by telephone or otherwise. 2.2. Place of Meetings; Meetings by Conference Call. Meetings of the Oversight Committee shall be held at such place as designated by the Oversight Committee. Meetings shall be held in person or by conference call. 2.3. Meeting Agenda. The agenda for regularly scheduled meetings shall be prepared by Counsel. Any Member or the Liquidating Agent may supplement the Agenda by circulating additional items by email to all other Members, the Liquidating Agent, and Counsel. If feasible, a proposed agenda will be circulated to each Member, the Liquidating Agent, and Counsel at least one (1) business day in advance of each Oversight Committee meeting. 2.4. Quorum. A majority of all voting Members shall constitute a quorum for the transaction of business at any meeting. A quorum shall include Members attending in person, by Proxy (with respect to any Oversight Committee votes within the scope of such Proxy), and by telephone connection as long as such connection is sufficient for all attending Members to hear each other attending Member (in each such case, such Member deemed to be “Present”).

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2.5. Voting; Polling by Telephone. Each voting Member shall be entitled to one vote, and may attend and vote (a) by its representative, or (b) through a designated alternate. Subject to Section 2.7, all issues to be voted on shall be decided by a simple majority of those present at the meeting in which the vote takes place. Each Member shall have the right to authorize any other Member to cast the Member’s vote for them (“Voting by Proxy”) in the event that the Member is not able to attend or participate by telephone in a meeting. Action of the Oversight Committee shall be authorized by the vote of a majority of the Members Present at the time of the vote if there is a quorum. A Member who abstains shall be counted as voting. A Member recused from voting under Section 2.7 shall not be counted as voting. In the event that a vote by the Oversight Committee results in a tie vote on an issue other than a vote under Section 2.7(b), the Liquidating Agent (although not a Member) shall be entitled to vote on that issue. The designation of alternates at meetings may be in such form, written or oral, as may be acceptable to the Chairperson, upon advice of Counsel. If the matter to be voted on is one of significance and urgency, as determined by a majority of the Members Present, with the advice of Counsel, a reasonable effort shall be made during the meeting to poll by telephone or email all absent Members, provided that the failure to reach any such absent Member will not affect the validity of any vote otherwise proper under these By-Laws. Telephone or email votes solicited pursuant to this section, along with Votes by Proxy, shall be given full voting effect, and may be counted in computing a quorum in respect of the relevant action. Attendance at meetings of the Oversight Committee shall be limited to Members, their respective counsel, the Liquidating Agent, professionals or agents employed or retained by the Oversight Committee, and other persons invited by the Oversight Committee for special or limited purposes. 2.6. Action Without Meeting. Any action required or permitted to be taken by the Oversight Committee, or any subcommittee, may be taken without a meeting provided that a reasonable effort is made to contact each Member or subcommittee member for its vote and to notify each ex officio member of the pendency of such action, and the action voted on is approved by no less than a majority of the entire Oversight Committee or subcommittee then acting as such. Such polling shall be conducted by the Chairperson or by Counsel acting upon the direction of the Chairperson, or by the chairperson of a subcommittee. Any action taken pursuant to this section shall be memorialized in writing and filed with the minutes of the Oversight Committee or subcommittee, as the case may be. 2.7. Conflicts of Interest. In the event that any matter under review or consideration by the Oversight Committee may involve a conflict of interest with respect to any Member, such Member shall disclose such potential conflict of which he or she has knowledge, shall be removed from voting on the matter voluntarily or, if determined by the Oversight Committee to involve a conflict of interest, may be excluded by vote of a majority of the Members then Present and not subject to such conflict of interest from that portion of the meeting at which such matter is considered. (a) A Member shall be deemed to have an irrebuttable conflict in matters concerning: (1) any potential or actual Causes of Action (as that term is defined in the Plan) asserted against the Member; and (2) any potential or actual Contested Claim (as that term is defined in the Plan) involving a claim asserted by the Member.

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(b) Counsel shall make a determination as to whether a Member should be excluded from a meeting or any portion thereof and shall submit a recommendation to the Oversight Committee in respect of each potential conflict unless the Member voluntarily abstains from voting or otherwise participation in the consideration of the matter giving rise to a potential conflict. Any Member subject to an alleged conflict of interest that does not fall within the scope of Section 2.7(a) shall be provided with a reasonable opportunity to be heard and to provide other Members with additional information and/or refute any allegations of its alleged conflict of interest prior to any Oversight Committee vote regarding such Member’s alleged conflict of interest. Whether a conflict of interest exists as to a particular Member or group of Members will be determined on an individual basis and each Member shall have the opportunity to be heard and have the Oversight Committee vote in connection with its alleged conflict of interest. For the purpose of a vote under this Section to exclude a particular Member from a meeting, the Member not allowed to vote shall not be counted for a quorum. Also, for purposes of a vote under this Section, if Counsel recommended that more than one Member be excluded from a meeting for a substantially similar reason (“Excluded Members”), and if one or more of the Excluded Members requests a reasonable opportunity to be heard on the conflict issue, the Excluded Members shall not be entitled to vote on whether a conflict of interest exists on that issue for any other Excluded Member. Additionally, for the purpose of a vote under this Section, a majority vote is required to overrule Counsel’s recommendation to the Oversight Committee on issues of potential conflicts. For clarification, in the event of a tie vote, Counsel’s recommendation is adopted. (c) Consistent with the foregoing, the Member having a conflict of interest shall not have access to summaries, analyses, reports or work product prepared by the professionals of the Oversight Committee with respect to the matter in which the conflict of interest exists, except to the extent determined to be appropriate under the circumstances in the discretion of the Oversight Committee. (d) Each Member of the Oversight Committee retains the right to appear in the Chapter 11 cases of the Debtor in respect of its own interests and to take a position different from that of the Oversight Committee, provided, however, that no Member shall purport to represent or speak for the Oversight Committee in connection therewith. While all Members acknowledge that they are acting in a fiduciary capacity as defined by law, nothing contained in these By-Laws shall: (i) prevent any Member from exercising or seeking to enforce or protect any of its rights as an individual creditor or other party-in-interest; or (ii) otherwise affect the ability of any Member to act in its capacity as an individual creditor or other party-in-interest as it may deem appropriate, whether or not such actions are opposed by the Oversight Committee. 3. ACTION BY REPRESENTATIVES OF THE OVERSIGHT COMMITTEE. 3.1. Chairperson. The Chairperson shall preside at the meetings of the Oversight Committee. Subject to the vote of the Oversight Committee, the Chairperson shall have such powers and duties as are set forth in these By-Laws or as the Committee assigns to him. 3.2. Emergency Motions. Subject to Section 2.5, the Chairperson, with the advice of Counsel, or Counsel shall be empowered, without prior Oversight Committee action or consent, to consent to or otherwise act upon applications or motions for court orders on an emergency basis if the Chairperson, with the advice of Counsel, or Counsel determines that it is

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not feasible to obtain a vote of the Oversight Committee pursuant to these By-Laws. The Chairperson and Counsel will make best efforts under the circumstances to communicate with as many Members of the Oversight Committee as possible before taking any such actions. The Oversight Committee shall be advised of any court orders, motions or applications so acted upon by the Chairperson pursuant to this section promptly thereafter. 3.3. Subcommittees. The Oversight Committee may, with the advice of Counsel, form one or more subcommittees to serve at the Oversight Committee’s pleasure, with such powers and duties as the voting Members of the Oversight Committee shall determine. 3.4. Professionals’ Actions. The Oversight Committee’s professionals shall act at the request of the Oversight Committee (or, when appropriate, a subcommittee) or the Chairperson, and shall perform the duties specified in their respective orders of retention, together with such implementing duties as are set forth in these By-Laws or as may be requested by the Chairperson, the Oversight Committee, or a subcommittee. 3.5. Secretary. There shall be no secretary for the Oversight Committee. In lieu thereof, Counsel shall maintain minutes of the meetings which shall include a list of the Members Present and the Oversight Committee action with respect to any motion or resolution. The minutes shall be circulated to the Members for approval as soon as practicable. 4. MISCELLANEOUS. 4.1. Ex Officio Members. There shall be no ex officio members of the Oversight Committee without the express approval of the Oversight Committee upon a vote of the majority of participating members voting on such issue. Such ex officio members shall be subject to any and all restrictions contained in these By-Laws including, but not limited to, Section 4.2. Ex officio members shall not be permitted to vote on any matters. 4.2. Confidentiality. Each Member of the Committee is aware of the fiduciary duty to unsecured creditors of the Debtor and agree that it shall act in accordance with such duty in dealing with confidential information. Except to the extent otherwise required by 11 U.S.C. § 1102: (i) all information, documents and matters of whatever nature and kind disclosed to the Oversight Committee (unless such information becomes generally available to the Oversight Committee on a non-confidential basis); (ii) all information or documents generated by the Oversight Committee, the Liquidating Agent, or by any of the Oversight Committee’s professionals, or by any Member or counsel to any Member for the Oversight Committee’s use; and (iii) all communications between Members in their capacity as such, including information regarding specific positions taken by Members, and all matters discussed at Oversight Committee meetings and the minutes thereof (collectively, (i), (ii) and (iii) are referred to as “Confidential Information”), are confidential and shall not be disclosed or revealed to third parties in any manner whatsoever, except that a Member may share any such Confidential Information with its attorneys and financial consultants, provided that the person or entity receiving such disclosure agrees to be and is bound by these rules of confidentiality. With respect to any required disclosure of Confidential Information by a Member to a third party by order of a court of appropriate jurisdiction, such Member shall promptly advise

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Counsel of such disclosure or prospective disclosure and shall reasonably cooperate with Counsel’s efforts to obtain a protective order or other appropriate remedy to protect the confidentiality of such information. With respect to any required disclosure of Confidential Information relating to the Debtor, the Member shall advise Counsel as promptly as reasonably possible prior to such disclosure, and Counsel shall immediately notify the Debtor and the Debtor’s counsel so that the Debtor may seek a protective order or other appropriate remedy to protect the confidentiality of such information. Upon the resignation or removal of a Member, such Member shall promptly return to counsel to the Liquidating Agent or destroy any non-public or confidential material (including copies thereof) received by the Member solely in its capacity and in the course of its tenure as a member of the Committee. Notwithstanding the resignation or removal of a member, such Member shall continue to be bound by the confidentiality provisions of these By-Laws. Each Member hereby acknowledges that it may be receiving material, non-public information regarding the Debtors and (1) that the trading of claims or securities of the Debtor while in possession of such information may be subject to various federal and/or state laws; and (2) Section 7.4.5 of the Plan provides for a Record Date for claim transfers. No Member shall have the right to transfer its membership in the Oversight Committee. 4.3. Causes for Removal From Oversight Committee. Upon receiving a recommendation from the Liquidating Agent, a Member, or Counsel, the Oversight Committee may elect to remove a Member under the following circumstances: (a) For a breach of any of his/her fiduciary duties as a Member; (b) For a breach of Section 4.2 of these By-Laws; (c) For conduct that would warrant removal of a member of any committee by the United States Trustee or the court pursuant to 11 U.S.C. §§ 1102-1103. A Member may be removed by the affirmative vote of not less than two-thirds of the Members entitled to vote on such matters. 4.4. Media Communications. No Member shall communicate directly with the public or the media as a representative of the Oversight Committee, unless the Oversight Committee has so authorized the communication to be made by majority vote. Nothing in these By-Laws shall preclude any Member from sharing public, non-confidential information concerning this bankruptcy case with other creditors. 4.5. Expenses. Reasonable and actual expenses of the Oversight Committee and of Members incurred in connection with Oversight Committee business may be submitted to the Liquidating Agent, with a copy to Counsel, in order to seek reimbursement from the Liquidating Fund pursuant to Section 6.10.7 of the Plan. Unless approved in advance by the Chairperson, with the advice of Counsel, reasonable expenses shall not include the expenses of any person other than a designated representative of a Member, an alternate, or a person invited by the Oversight Committee or by the Chairperson to attend an Oversight Committee meeting or participate in an

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Oversight Committee-related function. Requests for reimbursement shall be itemized and reasonably detailed, and shall include receipts where practicable. 4.6. Amendments. These By-Laws may be amended, repealed or adopted by the vote of a majority of the Members of the Oversight Committee entitled to vote. 4.7. Execution of These By-Laws. These By-Laws may be executed in any number of counterparts, each of which shall constitute an original, and all such counterparts shall constitute one and the same instrument. Delivery of an executed counterpart of a signature page to these By-Laws by telecopier or email shall be as effective as delivery of a manually-executed counterpart of a signature page of these By-Laws. IN WITNESS WHEREOF, the undersigned Members have executed these By-Laws on this ____ day of ____________, 2021.

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EXHIBIT C Assumed Contracts

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ASSUMED CONTRACTS
Table 1 on page 81. Back to List of Tables
COUNTERPARTY CONTRACT CURE AMOUNT
Insperity Professional Employee Org. Health Insurance Services $0

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