Answer:
It's important to not only read the regulation, but read the Official Commentary. Here's what it says in Comment #1 to 1026.46(b)(5) regarding the definition of a "Private Education Loan":
A private education loan is one that is extended expressly for postsecondary educational expenses. The term includes loans extended for postsecondary educational expenses incurred while a student is enrolled in a covered educational institution as well as loans extended to consolidate a consumer's pre-existing private education loans.
Note the bold italic part of that comment and I think you have your answer.
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