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Getting Your Perkins PhD. May 17, 2012. Financial Aid has Awarded Perkins – Now What?. We Fear That Which We Do Not Understand Regulations Auditors’ Findings Cohort Default Calculation. Forge a School-Billing Servicer Partnership. Share Knowledge Support for Audits

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Getting Your Perkins PhD

May 17, 2012

Financial Aid has Awarded Perkins – Now What?


We Fear That Which We Do Not Understand

  • Regulations

  • Auditors’ Findings

  • Cohort Default Calculation


Forge a School-Billing Servicer Partnership

  • Share Knowledge

  • Support for Audits

  • Annual Review of Program Setup to Ensure Continued Compliance


The Beginning: Making the Loan, In-School Status

  • Entrance Interviews

  • Prom Notes

    • 34CFR 674.31

    • DCL CB-06-11

    • TILA, Reg Z

  • Annual Disclosures

    • 34CFR 674.16(a)

    • 34 CFR 674.19(e)(4)(iii)

  • Red Flag Rules

    • FTC 16 CFR 681

  • Tax Forms

    • IRS Publication 970


The Next Step: Exit Process

34 CFR 674.42(b)

HEOA section 488(b)

HEA section 485(b)(1)(A)

  • Graduates

  • Withdrawn or LTHT

  • Notification of need to go through exit process

  • Exits: Online / Mailed

    • 34 CFR 674.42(b)


The Calm Before the Storm: Grace

  • Grace Audit Notices

    • 34 CFR 674.42(c)

  • Should you do more?

  • Multiple Grace Periods?

  • NSLDS Reporting


Uh-Oh: Here Comes Repayment

  • Billing: Monthly vs. Quarterly, etc.

    • 34 CFR 674.41(a)

    • 34 CFR 674.43

  • Multiple payment options

  • Consolidation and LVCs

    • HEA Section 428C(a)(3)


Whew: Deferments, Cancellations, Etc.

  • Deferments

  • Cancellations

    • 34CFR 674.52

  • Forbearance

    • Interest due at end of Forbearance

  • Death and Disability


Say It Isn’t So: Delinquency & Default

  • 60-Day Final Demand Letters and 90-Day Due Diligence Calls

    • 34 CFR 674.43(b)

    • 34 CFR 674.43(c)

  • Definition of Default

  • Cohort Default and the Orange Book

    • http://ifap.ed.gov/perkinscdrguide/1011PerkinsCDR.html

  • Skip-Tracing

    • 34 CFR 674.44


Far from the Pathway: Looking into the Abyss

  • Government Assignment

    • HEA Section 463(a)(5)

  • State Tax Offset

    • IRS Reform Act of 1998

  • Perpetual Billing

  • Settling

  • Can you collect after 7 years?


To the Rescue: Pre-Collections and Collection Agencies

  • Pre-Collections

    • Internal

    • External

  • Credit Bureau Reporting and E-OSCAR

    • 34 CFR 674.45(a)(1)&(b)

  • DRAP

    • Dear Colleague Letter CB-05-11

  • Rehabilitation

  • Acceleration

  • Collection Agencies


Successful Conclusion: Paid in Full

  • Prom Notes vs. PIF Letters

    • 34 CFR 674.19(e)

  • Retention of Original Notes

    • 34CFR 674.19(e)(4)(iii)

  • Replenishes your Perkins Program

  • They key to success? Communication with your borrowers.


CONGRATULATIONS

GRADUATES !!

Sal Flores, Chapman University

Laurelle Swan, ECSI


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