According to IRS publication 590 page 49 - http://www.irs.gov/pub/irs-pdf/p590.pdf - The distributions are not more than your qualified higher education expenses are excepted from 10% penalty.
Qualified higher education expenses are tuition, fees, books, supplies, and equipment required for the enrollment or attendance of a student at an eligible educational institution. - page 50 - it doesn't include student loan repayment.
Therefore, student loan repayment is not a valid exception for early withdrawal penalty.
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