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Spring 2010 Federal Perkins Loan Update. Agenda. Budget Update Legislative Update Regulatory Update Perkins Loan Issues Grassroots. Current Federal Perkins Loan Program. Federal Perkins Loan Program Provides long-term, low-interest loans to ~ 500,000 students from ~ 1,700 institutions.
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Agenda • Budget Update • Legislative Update • Regulatory Update • Perkins Loan Issues • Grassroots
Current Federal Perkins Loan Program • Federal Perkins Loan Program • Provides long-term, low-interest loans to ~ 500,000 students from ~ 1,700 institutions. • Total assets of over $8 billion represent over 40 years of FCC, TCC, repayments on previous loans, and Federal reimbursement for loan cancellation
2010 Presidential Budget Request • FY2010 Presidential Budget Request • increase college access and success by expanding financial aid while making it simpler, more reliable, and more efficient.
2010 President’s Budget Request • Increase Pell • Make Pell funding mandatory (not subject to appropriations funding) • Increase by $200 to $5,500 for 2010-11 award year • Then increase by consumer price index plus one percent
2010 President’s Budget Request • End entitlement subsides to FFEL loan program. • On all new loans as of July 1, 2010 • Consolidate federal student loans under William D. Ford Direct Loan Program • Increase efficiency • Less expensive • Savings to finance higher Pell Grants
2010 President’s Budget Request – Perkins • Modernize and expand Perkins Program • New Perkins program = new unsub Direct Stafford Program • Receive 6 billion in “mandatory” funding • Expanded to all schools • From 1,800 to 4,400 • 5% interest would accrue while in school and grace • Other terms and conditions would be same as unsubsidized Stafford • Federal Share of current loans sent to ED • Overhaul of the administration of the program • Fully originated and administrated by the Dept of ED
2010 President’s Budget Request - Perkins • Administration says: • 2.7 million more students will receive loans • Loans to be targeted to needy students and the schools they attend • Schools with many Pell recipients • Colleges encouraged to control tuition • New formula would encourage cost control and targeting of grants to prevent excessive indebtedness • Budget rules require ED servicing • Arcane federal accounting/scoring rules
Congressional Action • Student Aid and Fiscal Responsibility Act of 2009 (SAFRA) – H.R. 3221 • Implements President’s 2010 budget requests • Introduced July 13, 2009 • Full committee markup July 21, 2009 • Passed the House on Sept. 17, 2009 • Vote 253 to 171 • Senate working on their version
What Passed • H.R. 4872 Health Care and Education Affordability Reconciliation Act • House passed on 3/21/10 vote 220-211 • Senate passed with vote 56-43 • H.R. 4872 consists of amendments to health care reform and a modified version of SAFRA. • DCL GEN-10-5 briefly addresses these changes
What Passed • As of 7/1/10, all Stafford, PLUS and Consolidation Loans will be made via the Direct Loan Program. • Additional mandatory funding is provided to augment funds appropriated each year. • increase the federal maximum Pell Grant each year by the change in the Consumer Price Index. • According to ED/Labor Committee the maximum Pell for 2010 is $5,500
What Passed • The legislation uses $13.6 billion of the savings to cover most of approximately $19 billion shortfall in current Pell Grant funding. • Bill does not include ongoing increases in Pell at the rate of inflation plus 1% as in the SAFRA bill. • The annual appropriation process will fund the bulk of each year’s Pell grant. • No guarantee that there will be an annual increase in the total grant.
What Passed • $750 million is included for “College Access Challenge Grants” through 2014. • Rate of $150 million per year. • $50 million goes to assist school transition into Direct Loan program. • $2.55 billion goes to HBCU as well as Minority Serving Institutions
What Passed • Not-for Profit direct loan servicers receive funding if needed. • If meet minimum standards, they would be allocated a minimum 100,000 loan accounts annually, with the first 100,000 eligible for a special pricing tier.
What Passed • $2 billion is set aside for community colleges via Trade Adjustment Act funding under the Dept of Labor. • The larger American Graduation Initiative was dropped from bill due to budget issues.
What Passed • Income-based Repayment was modified for new borrowers beginning 2014. • Borrower payments are limited to 10% of discretionary income. (reduced from 15%) • Unpaid balance would be forgiven after 20 years. (reduced from 25%)
What Passed • $25 million is provided in fiscal year 2010 and 2011 for Direct Loan servicers “to retain jobs at locations where such servicers were servicing FFEL loans on 1/1/10.
What Passed • For one year beginning 7/1/10, borrowers who are not in repayment on all there loans can consolidate into the Direct Loan Program if they have loans in at lease two of the following categories; • FFELP Loans, • FFELP loans that have been sold to the Department • Direct Loans
What Passed • The Current Perkins Loan Program is not touched! • The administration's proposal (and passed by the House in Sept) to create a new “Direct Perkins Loan Program” was deleted in its entirety.
What’s Next • COHEAO will turn it’s attention to extend and expand the current Perkins Program. • Most important matter (because of timing) is appropriations. • President’s FY2011 budget request was written in the expectation of the “Direct Perkins” • No FCC or Cancellation funding is currently requested.
What’s Next • Need to address the 2012 sunset for Perkins. • It requires the federal share of the Perkins Loan revolving fund to be sent to the Department or ED • This date has been extended several times, last in 2007. • COHEAO’s high priority to eliminate or extend this clause.
Perkins Loan Issues • Economic Hardship Deferment • College Cost Reduction and Access Act (CCRAA, P.L. 110-84). • Definition changes effective 7/1/09 • Eliminates the 20/220 qualification for Econ HD.
Perkins Loan Issues • FISAP Perkins Loan Changes • New Lines: • New cancellations authorized by HEOA plus corresponding instructions • Short-term loans to the Fund and reimbursement to the institution of short-term loans to the Fund plus instructions • Transfer of FWS to Perkins Loan Fund
Perkins Loan Issues • Total and permanent disability discharge for borrowers designated as unemployable due to a service-related condition by Veterans Affairs • New TPD form posted • DCL GEN-09-02 • Two DCLs on Veteran’s TPD discharge • Process • Policy
Perkins Loan Issues • DCL 09-07 • Procedures for discharging Title IV loans by determination by the Dept of Veterans Affairs • VA determines discharge on one of two standards: • A determination that the veteran has a service-connected disability (or disabilities), that are 100% disabling; or • A determination that the veteran is totally disabled based on an individual unemployability determination.
Perkins Loan Issues • Following procedures must be followed: • Borrower must apply to loan holder for TPD • Completes section 1 and 3 of TPD • Physician is not required to sign Section 4 of TPD • Instead borrower submits documentation from the VA showing the determination of unemployability or 100% disabled • Schools review TPD for completion and attached VA documentation. • Make preliminary determination of eligibility
Perkins Loan Issues • If eligible for TPD based on VA documentation, submit TPD form and VA documentation to the Department. • DO NOT assign loan • The Department will review submitted paperwork and determine final eligibility. • Department will instruct school to discharge the loan • No three year conditional waiting period • School cancels the loan • And refunds any payments made on or after effective date
Perkins Loan Issues • If TPD was denied by school or Department • School must notify borrower and borrower must resume payments • Loan is deemed in forbearance from date of collection activity was suspended • During discharge process, schools must provide borrower with phone number to call if they have questions.
Perkins Loan Issues • Dear Colleague Letter CB-09-06 and CB-09-05 • Published 9/28/09 • Approval of the revised Perkins MPN and Addendum to Perkins MPN • MPN contains changes to cancellation, rehabilitation, forbearance and deferment • Must begin using by 12/31/09
Questions? Lori Hartung Todd, Bremer & Lawson, Inc. lori.hartung@TBandL.com 1-800-849-6669