*FFEL Back Office Analysis: Orlando Data Flow Reengineering Focus Group*

*Meeting Minutes*

*Sunday, October 29, 2006 1:00pm to 5:00pm*

Location

Royal Pacific Resort

Room: South China Sea

6300 Hollywood Way

Orlando, FL 32819

**Attendees**

The attendance roster is contained in an accompanying MS-Excel
spreadsheet (OrlandoParticipant.xls) along with another MS-Excel
spreadsheet (OrlandoGroups.xls) containing the breakout session groups.

**Meeting Schedule**

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height="3.8652777777777776in"}

**Topics Discussed**

***Background and Focus Group Vision***

-   Pam Eliadis presented opening remarks, set focus group objectives
    and expectations, and provided background on FFEL data flow
    reengineering efforts

-   Ron Bennett presented current Federal Student Aid improvement ideas

***Breakout Sessions***

There were four individual breakout groups to discuss new ideas to
improve FFEL data flow and to provide feedback on current Federal
Student Aid improvement ideas. Each of the breakout session groups
covered different stages of the FFEL lifecycle, which are described in
the following table:

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***Group A: Certification through Entering Repayment***

> **FAFSA Question:**

-   Debate about asking question "do they want a loan" on the FAFSA.
    Should it be asked or not?

-   Agreement that there is not a good understanding of prospective
    student of the potential need for borrowing that they go expecting
    gift funds.

-   Florida looked at providing a total "might be" eligible for various
    programs as a means of educating prospective student of the list of
    programs where they may have eligibility in the future.

-   All schools don't package loans and not all parents want to come
    through FAFSA system. Families consider financing options outside of
    Federal Student Aid such as private loans and home equity loans.

-   Question is no longer needed.

-   Term "Aid" is confusing in that people think it is money they don't
    have to pay back. Are we using the right terminology?

-   Use of the term "student financial assistance"...may still not
    address confusion. It's a maze for many families to pull together
    various sources to fund college.

-   People think that aid is free money. Need earlier awareness to
    educate on all the different areas of financial assistance: grants,
    scholarships, loans, and work.

> **Loan Certification:**

-   Idea that a loan has to come manually through the system to be
    guaranteed. Administratively burdensome to schools where their
    "system" isn't designed to accommodate. Possibility to pre-populate
    from the school with things like enrollment and eligibility.
    However, schools may not know some of the data.

-   How to address the various points of entry. Students being limited
    by technology for choice of lender.

-   Would you have a central clearinghouse for the information?

-   Information doesn't all reside in one place. Trying to do real-time
    process in a non-real-time structure.

-   Give student the ability to say I'm going to school X using lender
    Y.

-   18 years old and new parents aren't going to know who to go with
    without asking aid office who they should go with.

-   Students may go with a lender that doesn't give them the "best"
    rate, etc.

-   School as lender is probably the best deal for student by the way
    the program in general works.

-   Student choice of lender should be easier for the school and
    students.

-   If not on the preferred school lender list, it's not as easy to
    bring a loan from a non-preferred lender.

-   Should students and parents drive what the school offers since they
    choose the school before the lender?

-   Schools choice of technology drives those decisions.

-   Schools are trying to find best deals in terms of lender offerings
    for their students.

-   Lender needs to "sell" themselves to those schools.

-   Deal with the technological infrastructure that does the limiting of
    lender choice in loan products.

-   Steps that a school takes could be predone cert into a "repository".

-   Repository means someone needs to "house" the data.

-   Pre-certification in a proprietary system.

-   Regulatory support for certification process to have school as
    "gatekeeper". How would you remedy student applying for multiple
    loans?

-   Savvy borrowers versus naïve borrowers.

-   How lender lists are developed is like watching "sausage being
    made".

-   Technology supports status quo.

-   A number of schools/large ones are solely concerned about their
    convenience.

-   Deal with the barriers.

-   Issue of SSNs ....using in Florida account numbers that are
    scrambled version of SSN to derive an "account number." Issue with
    ability to unscramble is a risk.

-   Encrypted account number. Borrowers call though they give you the
    account number.

-   Looking for some other common format that everyone can use.

-   Use of ISIR data as in done in grant/scholarship area with FAFSA
    being the root and an ID assigned at the "genesis". Doesn't think
    that that ID would be easy to prevail. Need to provide a real-time
    service to find this ID because not everyone will have an ISIR data.

-   Needs to be ED's number because they are the originator of the
    number.

-   Still though going to need the authentication number.

-   Different number doesn't resolve the issue of security.

-   Generated off of other attributes used in matching the record.

-   Analysis done on generating number. Decided to go "random" with a
    check digit and be done.

-   FSA needs to offer a service to get the identifier.

-   Never going to get rid of SSN...borrower only want to use SSN.

-   School perspective, went with new system, store SSN but system
    assigns a random identifier. Students have learned over time to use
    that number. Only good while student is in school.

-   System catalog to prevent people from getting access to SSN.

-   Deal with system by having unique access that borrower, student, or
    others can use.

-   Can't encrypt paper.

-   If you don't have SSN, you can't steal the identity.

-   Pell ID current uses the SSN as originally reported even if the SSN
    changes.

-   Tighten the security around SSN, do not get rid of it being used.

-   Security breach requires both the SSN and some other piece of data.

-   Guarantor receiving a lot of stuff from lenders to guarantors asking
    questions that "data at rest" is encrypted.

-   Just a headache...everyone spends a lot of energy on security risks.
    Student loans are pretty low risk.

-   Real-time encryption in credit agency reporting.

-   Legally SSN is the identifier.

> **Data Collection:**

-   What exactly does the department want? Delinquent status is
    constantly changing...would be large data, security issue. Very
    dynamic.

-   Concerned with the department wanting to do more like AMF/LPIF maybe
    more around the area of reasonability.

-   Would like to see timelier loan status reporting.

> **Data Integrity:**

-   Lots of problems in terms of basic enrollment data. No incentive for
    the lender to do cleanup. Claims prompts "clean-up". Timely
    reporting of separation data.

-   TERP is really helping the issue that servicers faced with cleaning
    up the data. Edits by guarantor were inconsistent. National
    Clearinghouse is creating a big pipe for a consistent method of
    reporting data.

-   Everyone has some level of responsibility...some take more
    responsibility than others.

-   Big problem because grace period disappears when the data is slow in
    getting in.

-   Should you ask the borrower to be responsible for telling you when
    he or she anticipates on graduating?

-   Bigger deal because of mass of consolidation to know whether
    students have really separated.

> **Disbursement:**

-   Errors in disbursement amount/date accuracy. Can be very fluid as a
    result of conversation.

-   Moving lender name off the summary page to loan detail in place of
    servicer in NSLDS is a problem.

-   Don't like going to the loan detail page for the data provider ID.

-   Determining loan eligibility when borrower has outstanding balances.
    Inability to see original principal versus capped principal. Need a
    common approach to capturing this information.

-   Issue in consolidation with "restarting" deferment eligibility
    clock.

***Group B: Repayment through Closure (non-claims)***

-   Department knows the least about this area. Most of the FFELP
    community reports begin near the end---in default. Opportunity for
    more participation on the Department's part is to help before it is
    too late.

-   NSLDS doesn't know student is out of school until sometime way too
    late. Some way to let the Department and loan holder know enrollment
    more timely. Especially withdrawal -- If Department knows quicker
    the loan holder to know to get to the student know.

-   No reporting that there was actually an exit interview.

-   Often next fall is when NSLDS finds out.

-   If Terp or CH -- can be faster.

-   Often the school knows that a student withdraws.

-   Does exit counseling indicate student isn't coming back? Is there a
    connection between that and reporting enrollment?

-   School does exit interviews with those students graduating. If
    school takes attendance then they know a student has withdrawn. If
    not then, may not ever know.

-   Schools use Guarantor to prepare exit interview packages. Schools do
    an audit log of debt for each student. If they see more aid then
    they won't do exit interview. Entrance counseling is one on one --
    this is done online.

-   Is there value in tracking exit counseling? Could be -- then school
    knows.

-   When lenders receive exit information from schools -- it is usually
    older than.

-   NSLDS enrollment data is old and lenders use the NCH data. School
    fills out exit interview form. Report through the NCH on enrollment.

-   Huge gap in timeliness of enrollment data. Servicer doesn't get this
    quickly from NSLDS through the GA. Servicer should get this data
    quickly.

-   Can we get this data real-time? Are there certain data elements that
    we should capture more quickly? Can we build off what NSLDS
    currently does in the flow?

-   Lenders need to keep the borrowers informed. Finding that statuses
    are incorrect in NSLDS to help inform them of their rights. When
    borrowers come in there is a loan that could be out there that could
    still be on NSLDS. Lenders can't inform borrowers accurately. Also
    -- enrollment data isn't always right.

-   Data is 95-99% accurate.

-   Report online is easy for small school.

-   Brings us back to standards. Reevaluate the roster process.

-   In school consolidation -- timing made balances incorrect due to
    getting it reported.

-   Multiple consolidations (using one CL instead of multiple).

-   In school and repayment -- timing issue when leaves repayment. Up to
    that point, seems good.

-   Sub/unsub --

-   Lender that has good relationship with the borrower -- then can make
    sure they are well informed.

-   Schools are held accountable for reporting enrollment.

-   GA's have to work with each Servicer/Lender and how it is reported.
    Lender manifest, CAM and proprietary methods affects the timing of
    the data getting to the GA before it even gets to NSLDS.

-   CAM is event driven, daily updates. Depends on which GA's are ready
    to get CAM or not. Lenders report differently to GA's really affects
    timeliness. No common standards in the industry.

-   Borrower calls servicer and needs help with benefits -- go to the
    NSLDS to look up borrowers.

-   Common servicing issues in last few years....want rebates and want
    3% Off. Lender can offer the benefits not the servicer. Lenders and
    lender servicers need to have a great working relationship.

-   Need good loan statuses and loan balances -- on individual loans.
    Timeliness is of the utmost importance. No road blocks along the
    way...lenders to report directly quickly. CAM would assist greatly.\
    Common ID -- would solve a lot of things. Common line isn't common.
    Load ID needs to go with loan sales transfers. The Guaranty number
    seems to be moving with the loan, not the common line ID. Florida
    gets monthly reports from lender manifest with little errors --
    unique identifier is what usually stops the loan. If a lender can't
    report it with unique ID. It could follow if required. Is common
    line ID linked with deferment refreshing....sometimes a new 3 years
    of reporting?

-   ELM -- key indicator is common line ID and sequence number to
    identify sub/unsub. ELM only reports up to disbursement.

-   Experiment to report common line ID and sequential number in lender
    manifest -- Looking at adding it to the manifest. Schools are using
    common line ID. Have seen no problems with uniqueness of common line
    ID. Sequence number identifies that the sub/unsub.

-   Who initiates the common line ID? Could be the lender. Schools use
    software and it works with the lenders/GA's etc to generate the
    common line ID. Not all GA's are assigning common line ID's to
    consolidation loans. School based software is important to help
    generate -- ID is used for disbursement. Key to unique loan.

-   Delinquency -- GA gets involved at the 60 days. GA's need to help
    get lenders at this part.

-   GA's may tell schools that delinquency status so the school knows.

-   Schools get reports from GA's on delinquency. Default management
    person -- default prevention regulations. Schools need to data to do
    its work. Right now get from different GA's.

-   Specific topic on exit interviews on deferments and forbearance and
    repayment options. If students don't show for exit interview the
    school sends mail to the student. Some schools are getting very
    aggressive -- holding diplomas and transcripts until exit interview.
    Schools stress the options to protect student and default rates.
    Servicers then send tons of materials...are the students reading
    it??? Sending so much stuff. Lenders sell the loans then start
    getting mail from new lenders and think it is junk mail. How do we
    make sure the student links this to their student loan and old
    lender. Students need to know they can get the information from
    NSLDS or lenders or servicer.

-   NSLDS web site looked confusing to the lender.

-   Students do not want to call anymore?

-   Flows of FFEL data -- GA thinks that the flow works well now. It is
    being massaged at the GA before it comes to NSLDS and that keeps us
    from reconciling and getting duplicative data.

-   Could the CAM record that goes to the GA also go to the Department?

-   How much reconciliation is needed on that data today? Why does the
    Department need it? Can this transaction data be shared?

-   Lender manifest for NSLDS reporting is a huge file of everything on
    a borrower. CAM is smaller records that are much smaller. CAM is
    transaction daily and also does a month end record. Improve how the
    data is reported to NSLDS -- allow for data element reporting.

-   Paid through consolidation -- FAA will not give additional loans
    because loans are still dangling out there.

-   Need to look at percentage of effected students to determine what
    changes are needed.

-   Allowing record level updates not loan level.

-   DLSS data is faster -- especially as closed out by CL.

-   Lender and GA using CAM -- much better feedback from their schools
    when they go out to GA websites. CAM data is much timelier. GA to
    NSLDS can be set up to be more quickly.

-   SLMA conflict report -- to confirm prior to disbursing aid. If GA's
    are getting this that quickly and talking to schools. Should go to
    FSA faster.

-   Are we looking at a subset of loans? It is small, but it is the very
    important piece. Timeliness should be fixed up front...not giving
    the school a manual work around.

-   This direction is valuable --

-   Look at systems and infrastructures.

-   Reconciliation becomes an issue. Lenders are reporting the data and
    how does this affect GA's payments, GAFR, CDR's and they lose
    control etc.

-   Basic agreements between lenders and GA's.

-   Strengthening communication between GA's and Lenders. GA needs to
    the portal but the timeliness is an issue. Stop gaps needs to be
    removed.

-   Enrollment reporting is very important in making NSLDS successful.
    (LTH and W).

-   Would the higher CDR rate be using the wrong enrollment?

-   Need a better date for when the borrower actually entered repayment.

-   NSLDS has come a long way.

-   GAFR and NSLDS reporting -- reconciling is hard. Matching at end of
    year. Definitions

***Group C: Claim Filing through Closure***

> **Data standard CAM CCI for filing claims**

-   Within that exceptional performer v. non exceptional performers

-   Exceptional performers not examined as closely so some things go
    through that shouldn't (example loans going through that should not)

    -   GA would kick it back to the servicer

    -   Would find eventually take them send it back and get the money
        back

    -   Helped to reduce claim staff since don't have to review each one

> **Promissory note:**

-   CCI form has loan dates

-   GA should get original p-note

-   Lender sends hard copy to the GA unless e-sign

-   Like the image of p-notes idea (one lender said they already have
    that in house)

-   FSA would need the p-notes when they are assigned

-   If need digital images more and more it's a sign that the process is
    broken

    -   Machine can't look at a digital image a person can

    -   Should be as machine to machine ready as possible

    -   Not intent of electronic process

-   Currently, lender holds the note and sends the hard copy of note to
    GA

-   When to send the note?

    -   Origination

    -   During assignment

-   Does FSA really want to store all of the p-notes for each loan?

-   Need to recreate the loan for certain times

    -   Dissect problems and mitigate/fix

    -   Need for digital image means there are problems

    -   What happened that makes someone look at a digital image

-   What is there on that p-note that you don't already have (usually
    just the signature or references)

    -   Standardization of imaging for whoever holds the note

    -   Recreated images

-   Comfort in seeing and having paper

    -   Also needed for court

    -   If they have e-signed

-   What information should be passed to whoever holds the loan at that
    moment

    -   As it goes to the GA for a paid claim what needs to be sent

    -   As GA sends it to ED then what needs to go with the loan

    -   What actually gets assigned are the worst of the worst and
        that's where you most of the problems

    -   How much information can be provided up front then there will be
        minimal information that needs to be passed to ED (minimize the
        amount of data that needs to be pulled)

    -   How much information should be collected at front end

        -   Origination: we get demographic information, application,
            repayment, payments, date of last payment, loan status, past
            due, references all reported to the GA,

        -   CCI form documents all information that was used to pursue
            collections example phone calls

        -   House data in one area

        -   Instead of sending it to the guarantor send it to one place
            and guarantor can go there to get it

-   FSA could be single POC to house a central repository

    -   May get questions of role of guarantor

-   If everything is open and current process doesn't exist that
    requires GAs to hold certain information

    -   If central place that lender reports to then GA would just
        verify all of the information is still there (GA rep said it
        would be great)

    -   GA could update the same information for those that get assigned
        to ED

-   Along the way from origination things are being added along the way

    -   Activity updated in the database

    -   Define what you are trying to do with that data so don't collect
        data you don't need (don't want to gather everything just what
        you need because it is not the system of record)

-   Lender sells a loan to other lenders

-   Any problems?

-   Lender that buys thoroughly reviews it (someone has a record of
    where this loan has been)

-   Believe it works pretty well

-   Electronic processes are they unique to each lender?

-   There's standard data just not reported in the same way

-   Information driven by regulation

-   Exceptional performers apply to ED (97% compliance rate) and get
    paid higher rate on the claim

-   Due to regulation what information needs to be passed through

-   Any information that you think is not needed

**Discharge process**

-   determining eligibility:

    -   Conditional discharge rejects (goes back to the forms that were
        supplied)

**Default collection: TOP**

-   it works pretty well because FSA doesn't change it very much

-   pretty standardized

-   weekly reconciliation process works pretty well also

FFEL Current Improvement Ideas (Borrower Services go out to lender and
GA websites)

-   Loan holder responsible for reporting

    -   Would create problems if there are optional flows

    -   If loan holder has options to report this way or the other

    -   Would create problems if lender doesn't report to GA

    -   Double work load if report to both GA and FSA

        -   Would only report to FSA

    -   Lender reports directly to FSA how does GA get updated?

        -   Form 2000 will be different then what NSLDS shows

        -   GA would have to develop a system to pull information from
            NSLDS (increases staff)

    -   The report isn't the issue, need to make it more timely may be
        the issue

    -   How often does FSA want the information?

-   Currency of the information is not the same for all information

    -   Reporting frequency that can keep up with important information

-   How much need is there for developing technology for real-time for a
    few data elements when most monthly is enough

-   NCHELP lender manifest snapshot updated monthly

    -   Payments

    -   CAM is event driven

    -   Lenders and servicers are moving towards CAM preferred by GAs

    -   Community working towards more timely information

    -   If trading only CAM can have 10 changes for one loan (need
        auditing controls) each change will be a transaction

    -   Same number of transactions for each of the loans that are held
        (is what is done with snapshot)

    -   Most guarantors require lender manifest and CAM

        -   Several are moving towards CAM

    -   Wish list is to report more frequently to the Department

    -   Lender manifest is monthly and is the data used for NSLDS

        -   Problems with the manifest

        -   Loan-level not disbursement level

        -   If there has been a partial cancellation on the loan can't
            tell which loan the cancellation has been applied as well as
            amount

        -   CAM is disbursement, loan, and borrower level

        -   What is reported to NSLDS is the loan level also

-   Use common line unique ID carry through all the way

    -   Only every loan after 1988 since it has been captured back to
        1988 if we institute something else it'll be every loan after
        implementation date.

    -   It has been used throughout the lifecycle ( if it's sold it goes
        ) one of the most used standards

    -   Like the enterprise Aid ID

    -   The way the common line ID is constructed it is usable for FSA
        to use with DL

    -   No more new IDs use what is already there

    -   Common line unique to that specific loan

    -   First party that sends an electronic version of that loan (has
        unique portion of the common line ID)

    -   Common line has been adopted throughout the community

-   Need standards

    -   Common identifier matching

    -   FSA needs to work more closely with the community to vet these
        ideas

    -   Before put new IDs need to talk with identifier matching with
        the community

    -   Methodology has to be the same

-   For identifying borrowers not using SSN

    -   Use account numbers

    -   Must go back to the beginning of the FAFSA process

    -   How does the ID get passed to lender and schools?

    -   Would like a format similar to the SSN to save the community
        money

    -   Are we creating a new ID that will have to be protected as well
        as the social (if replace SSN with an ID)

    -   What organization is going to move away from social security
        number?

    -   Person identifier discrepancies to match ID to SSN

-   Routing ID

    -   Used to identify a participant

    -   Likes routing ID as a destination is a good idea not a good idea
        for identifying partners

    -   Routing ID as it is defined now to replace OPE id, LID, GID,
        Servicer ID and so forth is not a good idea

    -   Will need 10 routing IDs for Sallie Mae

    -   What problem is trying to be solved?

    -   Within the FFEL community a problem doesn't exist

        -   Can easily track the partners

        -   What is the point behind it

    -   Mike Sessa: FAMS/SIS many people adopt what FSA does because
        they have to

        -   There are some organizations use the Fise codes and how the
            Fise code maps to OPE ID

        -   Some organizations lag and don't adopt for years

        -   ID and methodology is only as good if everyone uses it
            (mandate migration to IDs)

        -   Common line ID works because everyone uses it ... if FSA
            would use it could solve some problems

        -   GID/LID/OPEID is part of the common line unique ID

    -   Do not want to use routing IDs if we are using the common line
        unique ID

-   Lender is already responsible with what they report

    -   Lender systems will need to be in sync with Federal Student Aid

    -   Will create a lot more confusion and manual work

    -   GA will have to sync up with Federal Student Aid too

    -   Get some banks with just three loans example 4000 banks in Texas
        alone and there are some that don't have computers

    -   What is the issue and the goal?

-   Ideas for more timely reporting

    -   CAM system

        -   FFEL community needs help to identify pieces of information
            that needs to be collected more timely

        -   Or access to real-time data

        -   Who is responsible for security of that

    -   Guidance from FSA

        -   Real-time screens for schools

        -   Avoid gathering information you know isn't going to be
            current

            -   Last payment date/ current deferment status examples

                -   These dates/information will not be current why
                    collect it... better to have real time data for some
                    of this

            -   All providers have web inquiry (80%) incremental cost to
                move to real-time data

            -   This real-time data is provided to schools anyway

            -   Need to identify what can be reported periodically and
                what we need real-time

-   Like the Data Store and Data Warehouse

    -   Will this data be required to meet NSLDS edits? Edit data the
        same way NSLDS does to keep garbage out

-   Why data is being reported: some status needs to be reported
    immediately some periodically

    -   Need more discussion

    -   Maybe eligibility data should be reported real-time

    -   Liked that business process drive data requirements

    -   Daily v. weekly v. monthly v. quarterly

        -   One process does not fit all

        -   Look at why the data is being reported

    -   Identify information that we don't need to collect

    -   What are we judging people on (benchmarks, error rate,
        acceptance rate) difficulties with this (loans to guarantee)

        -   (loan period begin date rather than loan guarantee date)

    -   Triggers may be affected with changes in benchmark (may have to
        adjust the trigger rates)

        -   How/why they are calculated

    -   GAFR and Form 2000

-   Whenever you are looking at something new comeback to the FFEL
    community for existing standards that we may not be aware of

-   Survey could be used

***Group D: Consolidations***

> **Verify consolidation eligibility**

-   When comes into my shop enter information on system. Enter Sub
    portions and if HEAL. If loan consolidation already populated
    somewhere would help or make life easier.

> **Send/receive Loan Verification Certificates (LVC)**

-   Make it electronic in away that some entities have implemented it
    would help. There is going to be push back on this because some
    lenders would want borrowers to keep their loans with their
    organization. Today, the holder of the loan has the time to call the
    borrower to offer counseling.

-   One member does not see a reason for a LVC. From the borrower
    perspective, I want to consolidate with this lender. Why do we need
    the ten days?

-   Unintended consequences might not provide upfront benefits if they
    feel they are going to lose loans or hold asset through maturity.

-   There is a big push for guarantors to rehabilitate and not
    consolidate loans. There should be a big push for guarantors to
    counsel borrowers. Guarantors should have that ten day period also.

-   (default loans) Borrowers don't want to spend nine months to
    rehabilitate; they would rather consolidate. They want it now and
    worry about paying it later.

> **How could we streamline what we do now?**

-   Timeliness of the data; data errors, etc. Timing of data is most
    critical point.

-   Need to sit down with each business process to discuss timeliness
    needs.

-   It all parties needing to share information staring with the
    schools. Very critical from schools to lenders and need software
    vendors.

> **Payoff underlying loans**

-   Have to start at beginning with common identifiers. Today, does not
    mean if data one loan necessarily mean that other loan belongs to my
    organization. Additional work needs to be done to determine where
    loan is by going out to multiple other sources.

-   Having the ability to associate the underlying loan with some kind
    of identifier; has to be a way to tie the underlying identifiers to
    the consolidation loan. Need to have a primary for both.

-   Maybe we can use the clearing house as a index. Clearing house knows
    all FFEL, Direct and most Perkins. They know who has guaranteed a
    loan. Everything has been reported there. If borrower needs to
    include all loans, could hit the clearinghouse to get up-to-date
    info. NSLDS has the data, but not up-to-date. You can real-time to
    web services to get that real-time data. No one would have more
    accurate info than the loan holder.

-   Must have an absolutely up to date balance and the only where to get
    that is from the servicer.

-   If we can aggregate sources of data it would work, but not coming
    from one repository. If we do that it could become stale data. You
    have to go out their using web services; using consistent
    technology. Fresh technology; web technology.

-   Need to reduce borrower confusion

-   What data elements would help? Unique identifier; reporting data
    timely. Eliminate omissions. Accurate credit bureau reporting.
    Schools should have real-time data from lenders to determine
    eligibility. Does not now happen universally. Borrowers need
    real-time data as well.

> **Communicate with borrower**

-   Need to reduce borrower confusion.

-   Need a valid e-mail address

-   Exit loan counseling

-   Phone calls?

-   Need to educate the borrower that he should be doing that
    consolidation

-   Needs to be some standard

-   How much of background data that borrower needs to see?

-   See at a minimum, Lender, school, need to know what is on the system
    as enrollment status, who the guarantor is. Everything needs to be
    laid out very clear for borrower.

-   Try to communicate benefits that were associated with that loan, and
    the possibility of losing these. What is the best thing to do? A
    calculator tool.

-   The literacy about the program in general would be beneficial.
    Students are responding to direct loan marketing. Many students are
    illiterate about the program. Dangers are missing a defaulted loan
    and then they cannot consolidate anymore.

> **Let's refocus and get away from program and continue to discuss how
> we get the data.**

-   There is a mechanism to communicate data, but has not been
    implemented by everyone. Everyone should use the mechanism before we
    go out to create a new one. We should make it a requirement that all
    use current mechanisms in place.

-   What do you wish you had that you do not see now?

-   A way to identify and update our actual underlying loans regardless
    of who is doing the consolidation. Who would do it? Don't know. But
    if we had a common identifier. Where would we get it from? That is
    an issue. If we required a package of certain data fields, we could
    use that to identify the underling loans.

-   We could use the common line ID which many of our loans have.

-   Have we missed anything. No, I think there is solid framework. The
    way that the details are currently organized can fall apart. You
    have to have communication between organizations to standardize the
    defining of details.

-   Who houses the common line ID? Some keep it all, but that is not
    true with all organizations.

-   We need to give everyone time to get on the same page to setup
    common matching criteria. We have to get the right information from
    the source when needed. Web services is the method should be used.
    Need a system that would aggregate all of the information; there was
    a suggestion that ed would be the holder of this info.

-   We need to include the whole community in data consolidation.

> **Data Integrity Standards**

-   Accuracy rates are good. Don't think we have issues with data
    integrity. Integrity is good, but timeliness is not good. Need fresh
    and tasty data. Through web services get data. What if still under
    or overpayment? Shouldn't be a problem because all data there. Maybe
    need some kind of standards to issue the payoff check. Would
    continue to follow regulatory standards to address under or over
    payments. You are going to have some organizations who will say this
    will be ok and others who will not be so receptive.

> **If you could solve?**

-   Make it simpler for the borrower.

-   Question: Whoever reports should be responsible for the data. All we
    are saying that the doer is not always responsible.

-   Is there information that could be reported by the lender if the
    current loan holder is there something can be reported to help it to
    be timelier. This would be purported by the kind of data being
    reported.

-   We are on the right track when FSA wants to link data collection to
    business requirements.

-   What are unallocated consolidations? Don't need to look at anymore.

-   What is the biggest barrier to getting all of this done? Money and
    resources.

-   Think everyone in FFEL community realizes that we need to make
    changes in the way we handle data. Regulatory and efficiency. There
    are things that we must do to keep the customer happy.

> **Enrollment Reporting What would that look like?**

-   They would like too see a consistent process for this kind of
    reporting and have it (info) come from the clearinghouse.

> **Wrap Up**

-   From what we have here, what we are looking at here, will it get us
    through on some of the things we have discussed.

-   Document that was sent to us on Monday, could we have earlier in the
    future.

***Breakout Session Presentations***

> **Group A: Certification through Entering Repayment**
>
> *Presentation Notes*

1.  Do you want a loan question on the FAFSA causes a lot of confusion
    about losing eligibility for other programs

2.  Term "Aid" misperceived

    a.  Better early awareness

3.  Process of loan certification inherently prohibits borrower choice
    of lender. Technical decision driven limits lender choice

4.  Make SSN more secure not create new ID for person

5.  If new student ID, needs to come from Federal Student Aid

6.  Ensure responsibility for data integrity of enrollment data

7.  Easy identification of all parties to a loan

8.  Definitive tracking of original principal outstanding versus capped
    interest to principal

> *Audience Comments*

-   Accurate disbursement amounts and dates

-   For number 6 Entity capturing the data originally because of
    servicers... should be the source of the data integrity

> **Group B: Repayment through Closure (non-claims)**
>
> *Presentation Notes*
>
> Data collection

1.  Report up enrollment/exit counseling data to FSA/community...

2.  Report delinquency info to FSA

    a.  To form a proactive relationship with the borrower

    b.  Don't reject entire record for one small problems (i.e. middle
        name)

    c.  Break up reporting structures

    d.  Send some information to GA and to FSA

> Data process flow

1.  Process works well -- more need areas of improvement than overhaul

2.  Specific data elements need "real-time" (i.e., enrollment,
    eligibility, and account balance)

3.  Get enrollment info in NSLDS immediately

4.  Standard process (4 enrollment reporting and loan detail

5.  Implement real-time capability

> Data Integrity

1.  Common line ID (standard Aid ID) across student lifecycle

2.  Standardize data definitions

> *Audience Comments*

-   Lender: We were told by one of our servicers department would not
    let them do it more than every 30 days

-   Lender Servicers send to GA

-   GA reports to NSLDS

-   NSLDS would allow GA to submit data as often as they wish

-   It's how the servicer and GA are setup for frequency of reporting

-   Web-based solution for real-time data?

    -   Having a tool for borrowers/schools to access a product to get
        real-time data

    -   Also heard don't have a manual work around

**Group C: Claim Filing through Closure**

> *Presentation Notes*

1.  What is the point behind the routing id? (need clarification)

2.  Don't change the routing id if FSA decides to use common-line id

3.  If timeliness of reporting is the issue work with community to
    identify what data is needed sooner or from another source

4.  A data store/warehouse with edits

5.  We need to look at why the data is being reported

6.  How is the data being used in benchmarking

7.  How does it affect triggers

8.  Talk to the community about existing or developing standards

9.  Not necessarily digital image; electronic machine to machine

10. Look at what's wrong in the front that requires the need to
    reconstruct the loan on the back-end

11. Define what data is needed when

12. More discussion would be needed re; GA regulatory requirements

13. Loan holder responsible for reporting -- options may create
    problems; may create problems in GA reporting

> *Audience Comments*

-   What changes could be made to improve oversight?

    -   Department's lack of oversight regarding GA claim payments

    -   Have a company that originated the loan, serviced the loan,

    -   How do you go in and look at the fact that Vertically integrated
        partners just passing paper through

-   We Focused on Data flow rather than roles of GA, FSA, and lenders

-   Oversight would be easier if we had better data

**Group D: Consolidations**

> *Presentation Notes*

1.  Timeliness of data to aggregate from source systems

    a.  Real time v. timely

2.  adoption of common technology

3.  consolidation association to underlying loans

4.  communication with borrower

    a.  email address

    b.  educate

5.  enrollment reporting consistent process

6.  enforce common criteria moving forward

> *Audience Comments*

-   Discussion on why we need to have LVC process why can't we not just
    get the payoff amount

    -   We have a standard of 10 days that is not being enforced

    -   Have borrowers that have to pay higher interest rates for a
        longer period of time even though they submitted by the deadline

    -   LVC takes 10 days to process

    -   There are other reasons why to keep the LVC

        -   Not lose the loan

        -   Loan may be ineligible, it's needed for a check

    -   Can't hold all lenders to the same process checks that he is
        doing as a lender

-   What regarding data flows can we improve?

    -   If tracking the underlying loans and Payoff amount recorded in
        the system no need for LVC

    -   More timely data on statuses (same improvements discussed
        before)

> **Open Discussion**

-   Discussed -- perfect world it would take resources, money, and time
    to make these changes and a lot of time other projects get put ahead
    of us

-   Data integrity -- discussed that now data integrity benchmarks are
    very high

    -   The issue is timely data not really data integrity

    -   98% accurate is pretty good

-   PEPS redesign -- came up with ideas, then it came to crunch time and
    90% of ideas were jettisoned

    -   Are we going to circle back with the community to get priority
        of the improvement ideas

-   Do not give options... standardize

-   Once a decision is made FSA should look at it's own migration to
    common record and came up with a three year migration plan

    -   Then we got rid of Pell, DL, and CB file formats and went to the
        common record

    -   The community appreciates a realistic migration strategy

    -   If people see that there is an opportunity to migrate over three
        years they can work with their systems to see how they can best
        fit in

    -   Good migration strategy can bring everything and everybody
        together

-   Prioritize on pain points

-   What are the department's pain points?

    -   FFEL data still collected on 640 byte flat file on a schedule we
        set up with GAs.

    -   FFEL data isn't timely common issue heard by schools

    -   Aggregates that affect eligibility

    -   Receive questions from congress and policy

    -   Need better analytics

    -   How can we better serve our customer