Copyright 2010 NSLP

Upcoming Federal

Disclosures

Upcoming Federal

DisclosuresJuly, 2010

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Disclosure backgroundDisclosure background

• Requirement ensure:– Informed student loan borrower– Borrower lender choice– Transparency and high ethical standards– Preferred lenders based on best interest of

borrower

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Lender disclosuresLender disclosures

• By 2-14-10– ED must determine minimum lender

disclosures – The disclosures must be provided to

prospective and current students– As of this writing (3-19) form not yet available

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Private Education Loan DisclosuresPrivate Education Loan Disclosures

• Form available now http://www.ifap.ed.gov/dpcletters/attachments/GEN1001A-AppSelfCert.pdf

• See Dear Colleague (GEN-10-01) for additional information http://www.ifap.ed.gov/dpcletters/GEN1001.html

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Preferred Lender Agreements (PLA) disclosuresPreferred Lender Agreements (PLA) disclosures• Schools with PLA’s must disclose on your website and in

all informational materials that describe education loans:– Maximum amount of aid available under title IV– Information about model disclosure form– Any FFEL loan application from any eligible lender will

be processed– TILA (Truth in Lending Act) disclosures are available

at http://www.fdic.gov/regulations/laws/rules/6500-300.html#fdic6500128

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Preferred Lender Agreements (PLA) disclosuresPreferred Lender Agreements (PLA) disclosures

• Informational materials are– Publications, mailings, electronic messages or

materials distributed to prospective or current students

– Describe/discuss financial aid opportunities available

• Must be provided annually for consideration before a student borrows

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Private Loan disclosuresPrivate Loan disclosures• If your school provides information about

private loans you must– Provide prospective borrowers with TILA

disclosures– Inform borrowers of possible Title IV loans

and the terms may be more favorable– Private Loan disclosure must be presented

distinctly different that Title IV loan information

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Private Loan disclosuresPrivate Loan disclosures• If your school provides information about

private loans you must:– Must to ED an annual report for each PLA

lender• Disclosures provided on school’s preferred list• Detailed reasons why on the list as well as the

benefits to the borrower– Make the report available to the public,

prospective and current students

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Direct Loan disclosuresDirect Loan disclosures• Does your school provides information

about private education loans?– Then your school must:

• Concurrently provide information in the model disclosure form developed by ED or a comparable form your school designed

• Provide it to all currently and prospective students

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Campus Safety DisclosuresCampus Safety Disclosures• Fire safety

– Statistics, annual safety report and fire log• Missing students

– Policies and procedures• Emergency Notification

– Policies• Crime Reporting

– Changes to Hate Crime reporting

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Other Campus DisclosuresOther Campus Disclosures• Text Book

– Provisions are statutory and apply to each school receiving federal financial assistance

• Peer-to-Peer file sharing – Policies and sanctions related to unauthorized

• Educational Outcomes– Placement and types of employment– Types of graduate and professional education– Retention rates– Completion and graduation rates

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Additional DisclosuresAdditional Disclosures• Plans for improving the academic program• Student body diversity• Vaccines• Services and facilities for students with

intellectual disabilities• Terms and Conditions under which

students receive FFEL, DL and Perkins loans

• Transfer of Credit• Net price calculator

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Code of conductCode of conduct• If a school participates in an Federal Student Aid

(FSA) loan program, it must publish and enforce a code of conduct. When developing the code of conduct, the school should refer to DCL GEN-08-12 for further details.

• The code of conduct applies to the officers, employees, and agents of the school and must also prohibit employees of the financial aid office from receiving gifts from a lender, guaranty agency or loan servicer.

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Code of conduct (con’t.)Code of conduct (con’t.)• The code must also prohibit financial aid office

staff (or other employees or agents with responsibilities with respect to education loans) from accepting compensation for consulting arrangements or contracts to provide services to, or on behalf of a lender relating to education loans, and service on an advisory board, commission, or group established by lenders or guarantors, except for reimbursement for reasonable expenses.

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Other changesOther changes

• General definition of a Higher Education Institution

• Definition of Proprietary Institution of Higher Education

• Master calendar updates• Cost of attendance (COA)• Total income • Untaxed income and benefits

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Other changesOther changes• Independent student issues• Social Security number • Distance education and correspondence schools• IRS data retrieval • Regaining eligibility after a drug conviction• Teach Grant Ability To Serve (ATS) form change• Borrower eligibility for federal interest subsidy• Total and permanent disability FFEL discharges

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QuestionsQuestions

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For more informationFor more information

National Student Loan Program1300 O St.Lincoln, NE 68508 www.nslp.org800-735-8778

Send questions to AskPolicy@nslp.org