Legally mandated student loan entrance counseling attempts to prepare first-time borrowers of federal student loans for this challenge; yet, researchers hypothesized that the online modules most borrowers use for this purpose have significant shortcomings. This report (the third in a series of five from TG Research) describes a study in which researchers observed, recorded, and interviewed student loan borrowers as they went through federally mandated student loan entrance counseling using online counseling modules. By coding and analyzing data from these interviews, researchers identified how different aspects of the modules, especially the topics they attempt to cover, fail to account for first-time borrowers' inexperience and learning needs. Based on these findings, researchers offer recommendations for counseling module designers, financial aid practitioners, and policymakers. Three appendices are included. [For the related reports, "Informed or Overwhelmed? A Legislative History of Student Loan Counseling with a Literature Review on the Efficacy of Loan Counseling. Research Report," see ED579985; "From Passive to Proactive: Understanding and Improving the Borrower Experience with Online Student Loan Exit Counseling. Research Report," see ED579880; "Above and Beyond: What Eight Colleges Are Doing to Improve Student Loan Counseling. Research Report," see ED579872; and "Effective Counseling, Empowered Borrowers: An Evidence-Based Policy Agenda for Informed Student Loan Borrowing and Repayment. Research Report," see ED579879. This article was written with the assistance of Carla Fletcher, Kasey Klepfer, and Jeff Webster.]