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Getting Your Perkins PhD

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

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  1. Getting Your Perkins PhD May 17, 2012 Financial Aid has Awarded Perkins – Now What?

  2. We Fear That Which We Do Not Understand • Regulations • Auditors’ Findings • Cohort Default Calculation

  3. Forge a School-Billing Servicer Partnership • Share Knowledge • Support for Audits • Annual Review of Program Setup to Ensure Continued Compliance

  4. 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

  5. The Next Step: Exit Process 34 CFR 674.42(b) HEOA section 488(b) HEA section 485(b)(1)(A) • Graduates • Withdrawn or LTHT • Notification of need to go through exit process • Exits: Online / Mailed • 34 CFR 674.42(b)

  6. The Calm Before the Storm: Grace • Grace Audit Notices • 34 CFR 674.42(c) • Should you do more? • Multiple Grace Periods? • NSLDS Reporting

  7. 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)

  8. Whew: Deferments, Cancellations, Etc. • Deferments • Cancellations • 34CFR 674.52 • Forbearance • Interest due at end of Forbearance • Death and Disability

  9. 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

  10. 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?

  11. 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

  12. 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.

  13. CONGRATULATIONS GRADUATES !! Sal Flores, Chapman University Laurelle Swan, ECSI

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