WASFAA Federal Relations Committee (FRC) Conference Call – August 26, 2015, 2:00 PT

Participants: Anafe Robinson, Helen Faith, Shannon Sheaff, Vicki Shipley, Beryl Schantz and Tami Sato

Meeting started at 2:04 p.m.

Welcome, Review of 8/29 Minutes, To Do’s

  • Tami welcomed FRC members on the call. Classes have or will be starting at many of our institutions so it is a busy time of year.
  • There was only one To Do from our last meeting and Tami submitted the WASFAA council approved letter that FRC recommended to regulations.gov.

This and That

  • A Federal Register requested comment on the 2016-2017 FAFSA and related forms. The actual draft documents were not included in the FR. Anafe said she had these as they utilize them for high school nights. To Do: Anafe will forward 2016-2017 documents to Tami for FRC distribution. After discussion, it was decided that comment from FRC was not needed but maybe we should review these documents first. The deadline date for submitting comments is October 13, 2015 so we still have time. Tami did mention that the FAFSA will no longer provide a list of other schools the student requested the FAFSA be sent to. Apparently some schools were using it for targeted recruiting efforts and priority financial aid funding to students who listed their school first.
  • Tami compiled a list of the presidential candidates sorting out some of the main financial aid issues. Not surprising the good sound bites like debt free college and refinancing of student loans are a part of many of their education platforms. Surprised at proposal to eliminate the DE and allow states to run financial aid and calls for the government not to profit from student loans. Even Trump feels that is wrong.
  • The August 21 COD Processing Update had a blurb abouta Title IV Refund issue in G5 where an error message pops up saying the action failed and that Pay.gov is not available. If reprocessing is attempted it will result in a duplicate refund. Schools should call the G5 Hotline to confirm whether the refund was submitted successfully. The problem Tami sees is that resolving the issue will be with the next G5 system update which will be in the middle of November.

Next Negotiated Rulemaking/Hearings

  • Information on this FR notice was sent to members with a list serve message. The main regulation proposed will be to clarify and streamline the loan forgiveness process for student borrowers who file a “defense to repayment” claim on their DL loans. ED also intends to strengthen provisions to hold colleges accountable for the wrongdoing that results in such loan forgiveness.
  • Two hearings will be held: Washington DC on September 10th and San Francisco, CA on September 16th. We discussed whether we could send a presenter to testify. Scott Cline, incoming CASFAA President is in the bay area and he might be able to do this. To Do: Anafe will ask him if he would be willing to testify and if so could it be for CASFAA and WASFAA. Beryl is in Sacramento and she might be able to testify for WASFAA. She will consult her college.
  • The deadline to submit written comments is September 16th and WASFAA should be able to meet that deadline and provide suggested additional topics that should be considered by the negotiating committee. Here are the topics that were discussed:
  1. Defaulted loans that have been paid in full without going through the loan rehabilitation process should not be included in the CDR.
  2. Borrowers who passed away prior to their loans entering default should not be treated as defaulted for purposes of the CDR calculation just because of timing of when the servicer receives documentation and the time for servicer processing and notification to NSLDS.
  3. Loan counseling restrictions need to be lifted to empower institutions to design and implement debt management and financial literacy campaigns in ways that are most effective for their students.
  4. Institutions should be permitted to challenge instances of split servicing in the CDR challenge/adjustment/appeals processes if the defaulted borrower had at least one loan that was not in default listed on the LRDR.
  5. SULA regulations should go through negotiations to improve and provide better implementation of the regulations from what DE interprets.
  6. R2T4 continues to be a problem for schools and students. This process needs to be made less complex and changed so that there are not unintended negative consequences for students.
  7. Borrowers who have made qualifying payments for PSLF and then consolidate should have their pre-consolidation payments counted toward the maximum repayment period of 10 years/120 payments.
  8. Borrowers who have rehabilitated their loans close to the timing of CDR calculation are still included in the schools default rate because it takes 2-3 months to process the claim and make updates in NSLDS.

Summary

  • In other discussion issues we pondered GE Electronic announcement #59 and the verbiage in chapter 4 of the updated GE User Guide. Kevin Jensen, WASFAA past-president, felt that members needed to be made aware of the issue of how we can check if there is a mismatch between what DE believes are our GE programs and what programs we submitted GE reports on. Update: Helen sent FRC clarification on the issue which Kevin agreed was the issue. Tami read the NASFAA TN article on GE reporting issues and felt this description of the issue could be to provided members. A list serve message was sent along with a link to GE Electronic Announcement #59.
  • There wasn’t any unfinished or new business to discuss.
  • The next FRC conference call meeting will be Wednesday, September 23 at 2:00 PT