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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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Presentation Transcript
slide1
Getting Your Perkins PhD

May 17, 2012

Financial Aid has Awarded Perkins – Now What?

slide2
We Fear That Which We Do Not Understand
  • Regulations
  • Auditors’ Findings
  • Cohort Default Calculation
slide3
Forge a School-Billing Servicer Partnership
  • Share Knowledge
  • Support for Audits
  • Annual Review of Program Setup to Ensure Continued Compliance
slide4
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
slide5
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  • Withdrawn or LTHT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)
slide6
The Calm Before the Storm: Grace
  • Grace Audit Notices
    • 34 CFR 674.42(c)
  • Should you do more?
  • Multiple Grace Periods?
  • NSLDS Reporting
slide7
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)
slide8
Whew: Deferments, Cancellations, Etc.
  • Deferments
  • Cancellations
    • 34CFR 674.52
  • Forbearance
    • Interest due at end of Forbearance
  • Death and Disability
slide9
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
slide10
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?
slide11
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
slide12
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.
slide13
CONGRATULATIONS

GRADUATES !!

Sal Flores, Chapman University

Laurelle Swan, ECSI

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