Making the Direct Loan Program Work for You

Transcription

1 Making the Direct Loan Program Work for You Direct Loan Tools & Tips 1

2 Wood Mason U.S. Department of Education Federal Student Aid Atlanta, GA

3 Agenda Processing Originating & Disbursing SULA Reports Reconciliation/Program Year Closeout 3

4 Processing 4

5 Make sure your software setup at your school serves you well Correct Release Updates Patches Network Everyone has access that needs access and has the appropriate level of access Stand-alone PCs Does everyone that needs the software have it 5

6 Make sure your software setup at your school serves you well Common Record Enrollment School Code Required field in the Disbursement Block 8-digit OPE ID of the campus of attendance Origination fees 1.068% on Direct Subsidized & Unsubsidized loans FIRST disbursed on or after October 11, 2015 and before October 1, % on Direct PLUS Loans FIRST disbursed on or after October 1, 2015 and before October 1,

7 Make sure your Financial Aid Contacts on the COD Web are up to date and accurate Program Contacts You can create Program Contacts or change contact information for your Program Contacts via the COD Website Financial Aid Administrator Hard-coded and NOT changeable on the COD Website Changed via eligcert.ed.gov 7

8 Make sure your non-award year specific options are correct and appropriate Import web-based transaction responses Y or N e-mpn participation Y or N e-mpn message to your borrower Electronic Entrance Counseling participation Y or N 8

9 Make sure your award year specific options are correct and appropriate Loan Period Date range/term Other Electronic Direct PLUS Request Parent and/or Graduate or Professional student Y or N Begin and end dates 9

10 Originating & Disbursing Direct Loan Awards 10

11 Origination Timely reporting... Do you have a mechanism or process in place that monitors your transmissions to and from COD? Are you reporting your Loan Origination Records (LORs) and Actual Disbursement data promptly? Actual disbursement data (DRI = TRUE) MUST be reported to COD within 15 days of the event Are you importing your COD responses frequently to keep your award data matched to COD data? Are you identifying/correcting rejected data, and returning the corrections to COD promptly? 11

12 Origination Identify and correct rejected data Rejected Direct Loan disbursement data can create unsubstantiated cash Rejected Direct Loan disbursement data can prevent an increase in your CFL and G5 available balance Use Batch screens to help you identify rejected data You can filter a document on rejected data alone Pay attention to your software Import Edit Report if it provides one or run a scan of your database looking for rejected data regularly 12

13 Origination A Direct Loan award can be originated as soon as the COD New Award Year Setup is completed For Award Year the COD New Award Year Setup was implemented on March 14, 2016 If your financial aid software allows, you can originate as soon as COD comes up An actual disbursement on a Direct PLUS Loan originated early does NOT trigger a new credit check 13

14 Origination A Direct Loan award can be originated prior to the borrower completing other required tasks e-mpn Entrance Counseling (if required) PLUS Counseling (if required) Date range/term Other You cannot disburse on the loan until ALL eligibility requirements are met 14

15 Origination A Direct Loan must be originated with substantially equal disbursements Anticipated and/or Actual You cannot front-load or back-load a Direct Loan 15

16 Origination Unless your day-to-day routine prohibits, originate ALL Direct PLUS Loans regardless of the credit decision Associates a credit decision with the award Remember...an actual disbursement on a Direct PLUS Loan originated early does NOT trigger another credit check 16

17 Origination You can originate a Direct PLUS Loan with a credit decision of Denied The loan can be processed and accepted by COD If it passes COD and Program edits The loan will appear on the COD Web Warning Edit Code #036 will be associated with the award You cannot disburse this loan until ALL credit requirements are met 17

18 Origination A borrower whose credit check result is Denied Can secure an approved endorser Can successfully appeal the Denied credit result In both cases the applicant will be REQUIRED to complete PLUS Counseling PLUS Counseling MUST be completed before disbursement of PLUS Loan funds 18

19 Origination COD created a new system-generated credit status response (CRCSxxOP) Keeps you in the loop when a borrower with an original credit decision of Denied is trying to gain eligibility for the award Sent on the approval or denial of an appeal Sent on the acceptance of denial of an endorser Indicates completion of PLUS counseling Contains the <CreditRequirementsMet> tag 19

20 Origination COD created a new Credit Status Report Identifies borrowers whose most recent original credit decision is Denied and has not expired Posted weekly to your school NewsBox CSV format A borrower drops off the report 30-days after... <CreditRequirementsMet> flag = TRUE Award is reduced to $0 The credit decision expiration date has been reached 20

21 Origination You should also have in place a process to monitor those awards with an original credit decision of Denied A window of opportunity during which the borrower attempts to resolve his or her Denied credit result If there is no resolution by the agreed upon date you can then offer unsubsidized funds to the dependent student Resolution can be achieved after the agreed upon data and still be valid and actionable 21

22 Origination You can increase the loan amount on an originated and accepted Direct PLUS Loan If your financial aid software allows, simply send the increase to COD as a change submission You cannot increase an originated and accepted Direct PLUS Loan if in receipt of a Denied credit decision If the Direct PLUS Loan is not fully disbursed you can do so 22

23 Origination Keep in mind that a school can offer additional unsubsidized loan funds to a dependent student after determination of the inability of the Parent to borrow due to exceptional circumstances Forego the Direct PLUS process altogether Even if the Parent s credit was already approved 34 CFR (c)(1)(ii) DCL ID: GEN

24 Disbursement If the loan period is more than one payment period you must disburse at least once in each payment period Single-term awards MUST be disbursed in two substantially equal disbursements unless your school meets Cohort Default Rate requirements to disburse in one disbursement 24

25 Disbursement The date of disbursement is a defined term It is the date you credit your student s account in the business office or pay the student or parent directly with Title IV funds or your own funds used in advance of receiving Title IV funds The disbursement data reflected in your financial aid system MUST match exactly that in your business office The date of disbursement is the date that starts the clock on interest and certain notifications 25

26 Disbursement Pending disbursements are reflected in the Action Queue If an actual disbursement was reduced to $0 was the loan period adjusted appropriately? Good tool for reconciliation You can release a pending disbursement form the Action Queue 26

27 Search forward or backward by award year A reconciliation tool AND an adhoc pending disbursement list tool 27

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30 Disbursement It s NOT an actual disbursement until the Disbursement Release Indicator (DRI) flag changes from FALSE to TRUE The origination fee is assessed on each disbursement The enrollment school code is a mandatory disbursement level field It is the 8-digit OPE ID of the campus at which the student is taking classes 30

31 Disbursement Actual disbursements and/or an adjustment to an actual disbursement MUST be submitted to COD within 15-days of the event Particularly important to Pell LEU and SULA The enrollment school code is a mandatory disbursement level field It is the 8-digit OPE ID of the campus at which the student is taking classes 31

32 Disbursement An actual disbursement that is rejected will lead to unsubstantiated funds in the D/L Program No bump in your COD Current Funding Level (CFL) and no corresponding bump in your G5 available balance Monitor your software Import Edit Report for rejects Fix them promptly and re-submit the data 32

33 Disbursement An upward adjustment should only be made to correct an erroneously made actual disbursement Interest will be calculated from the Disbursement Sequence #01 If you need to increase an award create additional disbursements to cover the increase 33

34 Disbursement SULA regulations require terms/payment periods with $0 disbursed not be included in the Subsidized Usage Period calculation Make sure any anticipated disbursements are reduced to $0 We ll talk more about SULA in a minute 34

35 SULA 35

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37 SULA Accurate reporting of your academic year and award start/end dates (loan period) is vital to the accurate calculation of a Subsidized Usage Period Academic Year is school defined Minimum of 30 weeks of instruction and 24 semester (36 quarter) hours of credit for a credit hour based program Minimum of 26 weeks and 900 clock-hours of instruction for a program measured in clock-hours 37

38 SULA Make sure your academic year begin/end dates correspond to at least the number of weeks you report Edit Code #046 will be modified with a COD release this Fall to trigger when submitted Academic Year Start/End dates DO NOT equal at least 26 weeks 38

39 SULA Loan Periods are comprised of payment periods A payment period is the period of time for which the disbursement is intended to cover Each payment period has a Payment Period Start Date (PPSD) Disbursement level field A Loan Period should include ONLY payment periods in which the borrower received and retained Direct Loan funds 39

40 SULA To be compliant with SULA requirements it is your responsibility to... Report Academic Year and Award Start/End Dates accurately Adjust loan periods to include ONLY payment periods in which a borrower received and retained Direct Loan funds Reduce any/all pending disbursements to $0 Reduce the award amount to match the amount actually disbursed 40

41 SULA The following FSA communications are invaluable Dear Colleague Letter GEN: Electronic Announcement # 16 11/21/14, Reporting Responsibilities Electronic Announcement #17 4/20/15, Reporting and Misreporting Electronic Announcement #19 9/25/15, Importance of Accurate Reporting: 41

42 Reports 42

43 Reports Reports are vital to efficient and accurate Direct Loan Program participation Reports are described in Volume VI, Section 8 of the COD Technical Reference Reports are posted to your school NewsBox on the COD Website and/or transmitted to your SAIG mailbox Reports can be received in several different formats and coverage periods select the one that works best for your school 43

44 Reports Direct Loan Booking Warning Report Identifies originated Direct Loans needing a linked MPN or actual disbursement or both to book Identifies MPNs received with no linked Direct Loan Origination Record (LOR) Monthly in your SAIG mailbox or COD Web school NewsBox 44

45 Reports Pending Disbursement Listing Report A weekly report that identifies anticipated disbursements that should be reported to COD as actual disbursements, or that should be reduced to $0 Provides list of pending disbursements 45 days in the future or any date in the past Delivered to your SAIG mailbox and posted to the COD Web in your school NewsBox 45

46 Reports Direct Loan Actual Disbursement List A weekly report that identifies actual disbursements accepted by, and posted to, COD Monitor to ensure actual disbursement amounts and actual disbursement dates match exactly actual disbursement amounts and actual disbursement dates on student accounts Delivered to your SAIG mailbox and posted to the COD Web in your school NewsBox 46

47 Reports Additional Direct Loan weekly reports Entrance Counseling Report PLUS Counseling Report MPN (Master Promissory Note) Report Expired MPN Report MPNs Due To Expire Report Weekly Credit Status Report 47

48 Reconciliation 48

49 Who is responsible for reconciliation? Anyone that touches the money! The secret to successful reconciliation? KNOW WHERE THE MONEY IS! 49

50 Reconciliation The Direct Loan School Account Statement (SAS) is the document that you MUST reconcile to It reflects the official Department of Education Ending Cash Balance (ECB) Your Direct Loan Program must be reconciled monthly 34 CFR (b)(5) The Financial Aid Office staff and the Business Office staff should check-in with each other regularly and frequently 50

51 Reconciliation Regularly run a report out of your financial aid system to identify data NOT accepted Weekly/Bi-weekly Resolve ALL rejected data and re-submit to COD promptly Monitor disbursement data to ensure it is flagged as actual disbursement as appropriate Reconcile internally regularly and frequently 51

52 Reconciliation Return funds promptly and appropriately To the correct Program and Award Year Return funds electronically via G5 If returned for a regulatory reason you MUST reduce the disbursement/award in COD accordingly 52

53 COD Reconciliation tools The Direct Loan SAS Disbursement Detail On Demand Report can help Request in fixed-length format via the COD Web data request Content options include Year-To-Date, Month- To-Month, or Date Range The fixed-length file format can be imported into the COD Report Reader available on the COD Web for a Spreadsheet view 53

54 COD Reconciliation tools Use the funding screens on the COD Web to monitor your cash and disbursement activity School Summary Information Immediate look at unsubstantiated cash School Summary Financial Information Emulates the cash data on the School Account Statement Dynamic data that changes as financial activity takes place 54

55 Keep your contacts up to date 55

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57 COD Reconciliation tools Use the funding screens on the COD Web to monitor your cash and disbursement activity School Funding Information Beginning CFL and increases amount/date Dynamic data Available G5 balance 57

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59 COD Reconciliation tools Use the funding screens on the COD Web to monitor your cash and disbursement activity Cash Activity Data on EVERY drawdown from G5 for an academic year Substantiated or not 59

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61 Program Year Closeout Occurs when you ve completed expected origination and disbursement activity for the award year You must ensure ALL cash management and disbursement reporting requirements have been met Your Ending Cash Balance MUST be $0 Your Net Accepted and Posted Disbursements in COD MUST equal your Net Drawdowns in G5 61

62 Program Year Closeout Pay attention to your School Account Statements as they come in and to communications from FSA and COD 30-days after your last award year end date COD will send a monthly Remaining Balance communication until you resolve the balance to $0 Upon receipt of your last School Account Statement reflecting a $0 Ending Cash Balance closeout the Program year on the COD Web 62

63 Program Year Closeout 63

64 Program Year Closeout DON T WAIT FOR THE DEADLINE DATE! Closeout the Program Year as soon as you are finished with processing for that award year COD will be happy to re-open a closed Program year if you need to make any unforeseen adjustments Remember all your disbursement data MUST be in to COD within 15 days of the event 64

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