*FFEL Back Office Analysis: Las Vegas Data Flow Reengineering Focus
Group*

*Meeting Minutes*

*Monday, November 27, 2006 1:00pm to 5:00pm*

Location

Paris Las Vegas

Room: Versailles I&II

3655 Las Vegas Boulevard

Las Vegas, NV 89109

**Attendees**

The attendance roster is contained in an accompanying MS-Excel
spreadsheet (LasVegasParticipantrev.xls) along with another MS-Excel
spreadsheet (LasVegasGroups.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***

**Establish Person Record (FAFSA/ISIR process)**

-   "No problems"; "steady process for us"; Common Line process; the
    main campus branch designation sometimes is confusing

-   SSN problems: Discrepancies between old record and new record (new
    has no eligibility checks, so over award problems); should be a way
    to ensure new loan records are submitted to NSLDS

    -   Issue of providing proof when resolved; new person will be okay,
        but problems with existing person

    -   Identity theft pose additional problems for "true" SSN person;
        problems with merging data with conflicting SSNs

    -   On FAFSA with new SSN, "move" old SSN

    -   Should not reject SSN conflicts; all loans should be on NSLDS

    -   Companies that are no longer around pose problems

-   Identity Theft: Student uses parent's PIN to sign promissory notes
    causes problems

-   Some schools require FAFSA for all programs (including PLUS)

-   Education/outreach needed

-   Divorced parents, etc. still remain problems

> **Determine Aid Eligibility**

-   Federal Agency Eligibility Checks; **why aren't you doing same thing
    as other federal agencies (IRS, DHS, etc.) so that you're doing the
    gov-to-gov communications; so that we don't have to do the
    matches**; secondary eligibility checks (OFAC: Office of Foreign
    Asset Control "terrorist" list, debarment lists) -- could be
    streamlined); but PLUS loans don't require FAFSA? SHOULD BE FEDERAL
    CHECK that Federal Student Aid runs instead of the institutions

    -   Who does it for Direct Loan? Federal Student Aid doesn't check
        against the OFAC

    -   Lenders (bank examinations)

    -   FIFCN: law enforcement agencies??

    -   FAFSA helps with identifying the matches, but only required for
        Staffords, not PLUS loans; schools may be willing to do this on
        the FAFSA if these checks were performed more efficiently

    -   COD: for loans and Pell? (14 month delay between FAFSA and
        disbursement);

    -   NSLDS (notifications, lack of)

    -   WHO IS THE ELIGIBILTY CHECK FOR?

-   New PLUS programs may cause problems for 5^th^ year applicants with
    remaining Stafford eligibility

-   Preferred lender list? Question of inducements vs. preferred lender
    list? How lenders choose to be on a list? Schools can examine list
    of lender products and then choose which is best. FFEL schools
    cannot say no to student who wants to borrow from a lender on the
    list; list should NOT be a mandate (it isn't, actually)

-   Issue of borrower's not being able to borrow on FFELP
    (grad/professional school examples); Direct Loan schools allowed
    students to create 'preferred alternate program lenders'

-   Students approved in one program and not another (Direct Loan vs.
    FFEL PLUS); don't want borrowers to "shop" around; if you're not
    eligible for Direct Loan:PLUS, shouldn't be eligible for FFEL PLUS

-   Credit check program is an issue for Direct Loan versus FFEL PLUS
    eligibility (lender's credit policy may be stricter than federal
    policy)

-   Scenario: student is Pell-eligible but parent doesn't pass PLUS
    credit check

-   Enrollment requirements is another issue that may override program
    eligibility

-   FFEL CommonLine (Use of Common Line ID is "common")

-   Keep FFEL line ID throughout lifecycle

-   Everyone understands how made up, and that it sticks

-   Initial transaction (started at school? Or whoever creates it)

-   Schools may not be setup for Common Line

-   Transfers are smooth

-   Should be added to NSLDS

-   When loan limits increase, the common line ID is critical when
    determining eligibility.

-   Challenge is that not all GAs use common line (some have wrapped
    their own ID with the common line ID)

-   Would be nice for school to be notified that transferred student has
    an active loan at another institution and to aggregate NSLDS review;
    time lag between ISIR and origination (over-cert); the NSLDS gives
    an alert at the student level, but not the aggregates; time-lag for
    transfer monitors; when trying to certify loan needs aggregate data

-   NSLDS should contain real-time data on originations and
    disbursements

-   From a FFEL perspective, repository can't really be real-time;
    real-time may be some other system/interface;

-   Industry is accepting standards

-   Aggregate issues & Concurrent (dual) enrollment/ distance education/
    creates certification/recert issues

-   Issue with certifying at two different places but is disbursed from
    one

-   Should disbursement from one school "kill" the other school's
    certification?

-   Timing of certification is important

-   Need disbursement alerts

-   POLICY ISSUE, NEED TO RESEARCH THIS

-   Both schools should be made aware of the student's plan

-   Lack of technology integration allows these problems to persist

-   Hard to "batch" monitor for 14K borrowers in NSLDS; hard to tell
    what aggregate maximums are

-   ED-Express should use loan aggregate information from NSLDS

-   Should be a safeguard that throws out re-cert/orig. when risks occur

-   School is responsible for ensuring max. isn't overrun; GA provides
    good internal control for this; problem is when two schools with 2
    different guarantors

> **Process Promissory Notes**

-   Collecting P-notes with FAFSA

-   Risk that borrowers don't understand implications because of
    application activity

-   Don't like current process of collecting the p-notes, but first
    bullet is risky

-   Pulling paper P-notes for defaulters is a cumbersome process

> **Additional Ideas**

-   One way of transmitting data (with nice data definitions) whether
    it's front end, or assigning an account: USE THE SAME RECORD instead
    of using another file format and mailing boxes of papers; paper
    process should be eliminated; if you need paper from original
    source, ask source when needed

-   Mailing paper with SSN: NO MORE!!!

-   Disbursement and delivery are two different data points for
    alternative loan programs

-   Eliminate paper checks (but small schools will have trouble) -
    Automated funds hit to school's roster so disbursement is real time
    to student); problem is some schools are technology-challenged or
    some schools require a paper check (when check is cut, funds are
    obligated!)

-   NSLDS: loans can be in there 30 years; statuses constantly changing;
    reporting is constant; prioritize statuses for NSLDS; should a
    guaranteed loan be reported daily? Once a month? Quarter? (current
    process doesn't match reporting requirements); "fetching" will be
    costly to ED

-   ED should create policy that "eliminates magnetic tape submission,
    etc." once changes are made

-   Reporting should be made once change is triggered, not when the
    reporting requirement states so; don't send the ENTIRE record, just
    the element that changes (flat file vs. XML -- ED should take
    advantage of XML)

-   Non-compliant CommonLine institutions need to jump onboard in order
    for the reporting improvements to be possible

-   ED should come up with minimum reporting standards so make the
    transformation easier to adapt (rather than one big bang change): 3
    --year window to migrate to the new transport mechasim/layouts

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

-   ED's Goal -- Gather data once---no duplicate data

-   Should we continue to collect in one source and how does data flow?

-   For example, if data is reported in one place, it could be used in
    many different ways---e.g. ED could possibly add one or two new
    fields and use information reported for assignment\--just make it
    easier for data to come in

-   When a loan enters repayment is important as date is used to
    calculate when loan enters default. When a loan enters default, the
    loan is thrown in the cohort rate calculation and affects trigger
    rates.

-   Problem with the data from the lender is that a borrower could be in
    an in-grace status to repayment to deferment within one cycle and
    the latest status may not be in NSLDS, especially if you wait for
    something to happen before reporting.

-   ED may receive different dates from schools or lenders.

-   There are different ways to collect data e.g. CAM, etc. ED should
    look at standards in industry e.g. common line ID. Can Federal
    Student Aid use lender/GA industry standard?

-   Loans guaranteed and loan disbursed pretty consistent in community.
    Loan ID is used in loan origination but dies off.

-   Different numbers may be designated and used in different systems.
    GAs and/or servicers may have system limitations to capture the
    common line ID.

-   How is common line ID created and who creates it? Whoever creates
    the loan record (i.e., school or lender) creates the ID. Used to be
    ELM mapped but now doing itself. The common line ID may be used to
    distinguish loans.

-   The common line ID is not used in clearing house

-   Uses SSN in common link but common line ID could be used

-   Gets loans from school but do not receive anything to link to
    specific loan---just student information but could extend this to
    common line ID

-   Gets common line ID from lender and the ID is used upfront.

-   It would be helpful to use common line ID from school so agency
    would know which loan was paid off, etc. It would be helpful in
    delinquency, etc.

-   GAs don't store information like NSLDS --information is stored
    differently in system; however, they could store it and pass it.

-   The common line ID could be used for consolidation. Currently, there
    is no way to link the underlying loans to a consolidation loan, but
    could use this ID if it is a unique loan ID. The consolidation loan
    could also have a common line (unique) ID, and the loan ID could be
    on the LVC.

-   An algorithm could be used. The data size would have to be expanded
    on GA and lender systems. In some cases, they are hitting 40 loans
    for one borrower

-   The ID is !4 plus 3 sequence number

-   The GA and lender data storage would be multiplied overnight to
    capture common line ID.

-   Suggested using common area for borrower --e.g., notepad---it is
    cheaper to keep data than to archive data.\
    Reporters only send only data that changes to NSLDS. NSLDS does
    store creator number---NSLDS gives it back but it is not helpful.

-   Does Perkins loans get common line ID? A. There is not a process to
    designate common line ID. Perkins should follow common line id.

-   Sounds like it would not be difficult to store, even though there
    may be transmission and storage issues.

-   Loans may be identified based on first disbursement date; however,
    this date may not be consistent as cancellations occur. There is an
    anticipated disbursement date, an actual disbursement date; and then
    it can change because of a cancellation. If first disbursement is
    cancelled, the second disbursement becomes real first disbursement
    date. This is important because HERA changed fees and interest rate
    may change. Systems need to have flexibility to change or else will
    have errors. If there are different dates, who is right?

-   Think it is good idea for GA to report loan and for lender to
    provide updates---e.g., loan in grace, deferment---that is, lender
    should report change in status

-   However, if only changes are reported, information can be out of
    sync as cannot recreate transmission if information is rejected. How
    do GAs know errors being corrected?

-   NSLDS would need staff to work with lender services to correct the
    data. GA needs information from lender and NSLDS needs information
    from lender

-   So information may not be consistent between NSLDS and GAs.

-   Who is the best source for information?

-   Nothing to show NSLDS data different from GA data. The data affects
    GAs financially and affects trigger rate.

-   School's perspective is that information is going from lender to
    middle man and then to NSLDS.

-   If there is a discrepancy, will the information be the first one in
    or the bigger guy? There may be discrepancies in disbursement dates
    or separation dates or students never attended school.

-   As previously discussed, there may be errors in the disbursement
    date due to cancellation. Lenders get notified in case of school
    cancellations. If the cancellation not being reported, the GA gets
    overpaid.

-   Currently, if there is a cancellation, the money is sent back to the
    school and then to the disbursing agent to send back to us. This
    takes too long and may have auditing issues because records
    disagree. This all gets back to timeliness of data. FFEL data is not
    timely. The date may flow frequently to the GA but not to NSLDS. ED
    noted that GAs can report daily to NSLDS starting in January.

-   The responsibility of reporting will still be with the GA. GAs
    report monthly and then do full submissions quarterly. Perhaps GAs
    should report everything twice per month. From a computer
    perspective, it is easier to send everything then just changes

-   There are different standards to collect data. Xml is just a
    spreadsheet. Several participants indicated that they do not know
    enough about it. People talk about xml

-   Problem is people say they like to do it, but can't do it

-   Timeliness is most important for:

    -   Eligibility

    -   Cancellations

    -   Award amounts

-   There are cases where there is a consolidation loan but no
    underlying loans indicated as consolidated.

-   Data should be collected when we need data. It should be real time
    data system but that would be next to impossible. Everyone has
    different system -- we are not trying to build giant system with all
    information linked into GA/lender systems.

-   Perhaps GAs should have two pieces to report -- one sooner or later
    and one monthly.

-   Need common edits -- GA system and NSLDS system. Lenders have best
    data. GA does not pick up information until loan is delinquent.

-   Don't want to changes roles and responsibility---perhaps lender
    could send information to GA and to NSLDS. Need reporting standards
    or possibly NSLDS report to GAs; however, somebody has to compare
    two places of reporting and see where there are discrepancies. GAs
    don't want to overlay lender information. GA's perspective is that
    the lender information has to be correct.

-   Lender would have to clear up two places of errors. There are cases
    where loans from 1986 have not been reported to NSLDS.\
    \
    Urges NSLDS not to use edits.

-   NSLDS does not collect delinquency information, but is useful for
    budget purposes.\
    How many times borrower goes in and out of repayment---a loan can go
    in and out of delinquency many times. It would be helpful for NSLDS
    to know the number of days delinquent; however, this changes so much
    from month to month.

-   It would be easier to query GA/lender portfolio, as they can get
    information quickly---e.g., how many loans cancelled; delinquent;
    etc. Would rather answer the question on spot then to build system;
    however, this means in order to answer question, would have to shop
    for direct, perkins, FFEL, etc. to collect data.

-   OMB will tell ED what they need. If number of days delinquent is
    reported to nslds, can query NSLDS to get information. It is hard to
    do at borrower level---e.g. borrower may go into delinquency with
    one lender and be current with another. Borrower does not know had
    two lenders.

-   Encountered borrower who says did not receive check issued back in
    1996.

-   How accurate is information if borrower is 60 days delinquent and
    tomorrow current. How is delinquency calculated? May report
    delinquency today and the borrower is current tomorrow. The balance
    owed "AS OF DATE" is crucial in reporting.

-   TERP and clearing house is a total enrollment reporting process and
    is the most automated, hands off process

-   May be a borrower has loans later than separation date---possible
    that borrower changed schools.

-   School -- student indicates no longer enrolled but school has to
    have service date

-   School reports to clearing house. Could be 30 days easily

-   Student may enroll for another class

-   Special allowance section information changes as they find out
    borrower was in school and then sees adjustments\--Billing
    adjustments can go back ten years or more

-   Enrollment data is reported to NSLDS as well as who is graduating
    and who is withdrawing---this dates jumps around because serivcers
    throw anticipated graduation date. Should ask the student not the
    servicer. The servicer puts student in repayment

-   May 31 -- school reports repayment date as May 31 but student
    returns in fall, but school does not change date. This is the cause
    of retroactive information\--loan sent for servicing but borrower
    still in school. Student may not change date because there is fee
    involved if date is changed so student does not do it. Borrower will
    tell when they left but not when they are in school \-\--borrowers
    only report things to their benefit

-   Information from lender so information is pretty current---felt that
    NSLDS is cleanest ever been. Data changed because of HERA, etc. so
    needs to be more flexible in changes. GAs are receiving an over 99
    percent pass rate on NSLDS. Nice if everyone had the same
    edits/errors because of the success level

-   Is there data collected that is not needed. Need consistent data.

-   Tried to use NSLDS for forms 2000 but couldn't use because different
    information

-   Reporting on financial form\--even though duplicate reporting serves
    as check and balance method. Duplicate reporting on LARS as well.

-   Promissory notes: when loan transfer from one lender to another,
    where does it live?

-   Disbursement agent or third party servicer \-- must have data on who
    has application for claim processing. Servicing lender has to sort
    to get this information. May be paper or E-signed. Need records of
    who holds Guarantee. Must track all this information

-   Used to be in own shop. Need to look at disbursement to figure out
    who originated loan.

-   When loan is sold, only uses certified copy. Promissory note is not
    tied to each loan

-   What can we do to help back end process? What would be useful? Felt
    only odd student who denies received loan.

-   Lender does not want to pay claims without true and exact copy.
    Exception performers do not have to submit promissory note, but most
    GAs still require promissory note in claim.

-   Would be helpful if MPN was viewable. Nothing to show is if student
    disputes one loan on MPN. Can use Notice of loan guaranty but school
    is the best source, but schools only keep information for five to
    seven years. GAs have information seven years after fully paid and
    some decided keep always. Liability of lender is null. Lender should
    have imaged note but will not have specific loan tied to MPN.

-   Exit counseling:

-   School uses own system to determine who needs exit counseling. They
    sent exit materials in mail if student withdraws. Records reflect
    offered exit counseling and will send information to lender.
    Documented that they sent data.

-   School offered sessions but will not offer if not required. Do we
    know how many defaulted loans because of no exit session. Schools
    will not push unless default rate goes up.

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

**Reaction to Current Improvement Ideas and FFEL Community
Recommendations**

-   Discussed the judgment account function at ECMC

-   FFEL common line -- ECMC with bank transfers from community and ED
    with all the transfers coming and going---Common line used but not
    enough to be helpful with reconciliation. Data transfer result in
    the creation of duplicate loans. The group endorses Federal Student
    Aid developing and implementing common standards.

-   Group recommends providing adequate time to implement any new
    standards and or requirements. FFEL community would like to be
    involved with developing these standards, this focus group is a good
    starting point

-   There are loan identifier implementation concerns with current loans
    -- how would they be handled with implementation of the new common
    identifier methodologies?

-   FFEL data definitions... everybody (Federal Student Aid and the FFEL
    Community) develop standards and edits. Everybody should use the
    same standards and edits. If properly implemented, this would be
    welcome among the FFEL community. GA and servicers would welcome
    this consistency. Federal Student Aid is not trying to implement new
    standards, but utilize existing standards. Not only Common Line but
    the CAM. Common Line is a higher level - used from school to
    originator.. disbursed out. CAM is the communications standard
    between GA and lenders/servicers. Both are existing data standards.
    Is it difficult to follow FFEL common line to follow loan through
    out the life of the loan. Cannot use the current Common Line file
    but Common Form Record could potentially be converted to XML. There
    have been conversations with the GA community. Currently CAM is
    using XML.

-   Recommendations: use Common Line and CAM. The unique identifiers
    must be used by all users of FFEL. The Loan ID would use the common
    record. CAM only has the latest record (TRANSACTION DRIVEN) not the
    history of the loan. If you want the whole history you need to pick
    up the identifier which is the key to ensuring consistency across
    the board. Reporting data more frequently would ensure better
    accuracy

-   Identifiers must be mandated by Federal Student Aid. Group
    recommends keeping old identifiers for current loans. Once the
    cut-off occurs will all loans automatically get this new ID?
    Origination process would determine how the identification process
    will work.

-   Data transfer process: secure network and ability to transfer large
    XML data files securely

-   Lender/Servicer responsible for reporting directly to Federal
    Student Aid: does Federal Student Aid really want to receive these
    transactions?

-   Access to source data to reconcile what's going on between GA's ...
    METEOR. Loan status with transactions. Consistent standard is "loan
    status" important to keep what's currently working well.

> **Unique Identifiers**

-   Servicers do not always get loan ID but if they get it they keep it.
    No standards for transferring load data from one entry to another.
    Depends on life cycle of loan. Loan identifiers can be received that
    are not complete. Consistency issues arise with incomplete
    identifiers.

-   RID affects kindergarten through College, if different from the
    OPEID. Within community RID's totally different.

-   For SID is the concept to use SSN, response unique Federal Student
    Aid ID. Sallie Mae and NELNET are currently developing unique ID's
    which don't use SSNs. No consistency currently however. Common
    Manual has methodology for identifying or creating unique
    identifier. Borrower interface something other than SSN used to
    identify borrower. Problem with duplication and transposed numbers
    still exist.

-   Routing ID for Lenders. Lenders are consistently changing ID's.
    School w/ lender servicer, guarantor or vendor during origination on
    behalf of the lender and back office. Discussed during the
    Electronic Standards workgroup. Encouraging better communication. If
    school has understanding with lender... incentives for schools using
    certain standards.

-   If Federal Student Aid developed standards the community would
    welcome the changes, however, depending on timing of the
    implementation. Flexibility of having how the data gets into the
    process is important.

-   Collect the correct data once -- pass to relevant systems.

> **Claim Filing through Closure Improvement Ideas**

-   Lender/Servicer responsible for reporting directly to Federal
    Student Aid: Data would still have to go through the GA so the
    lender would be forced to report to both Federal Student Aid and the
    GA. Information of holder. Sallie Mae would prefer to report
    directly which would eliminate reconciliations. Servicers don't want
    to report to both, but GA's need the reporting information.
    Reconciliation issues, if this reporting idea is implemented,
    Federal Student Aid would be in the reconciliation business if
    lenders started reporting directly to Federal Student Aid. Going to
    data source for reconciliation, if necessary.

-   Would it make sense for Lender/Servciers to report any information
    directly to Federal Student Aid, i.e., disbursements., Federal
    default fee ... GA needs the information so lender would have to
    report to them also.

> **Claim Filing through Closure**

-   The current layout from GA to Federal Student Aid is 1,000 bytes, if
    Federal Student Aid does the assignment.

-   For Nelnet loan assignment, or common format, option to send if
    necessary. If the forward for assignment accounts. Common format for
    lender, GA and ED. Coding delays reporting account information. The
    SAIG could be the one reporting

-   Loan at lender to GA this is where CAM comes in (good thing and
    really working). Some GA's accept and do get but some don't. If the
    GA get's the CAM they will use it.. Is the promissory note sent to
    the GA? Not necessarily

-   Direct Loan does capture Master promissory note. Digital imaging
    only provided if needed. Not necessary to transfer documentation all
    the time, just send what is requested. GA can house the promissory
    note and if needed Federal Student Aid can request retrieval,
    especially if electronically signed. If lender doesn't have the
    information someone needs to make sure that it knows who collected
    that note and will have to explain the process. With the promissory
    note, if GA disburses the loan the GA has, if the lender has, in
    most cases the a promissory note is sent to the GA. Only required to
    keep for 5 years but when note is transferred from place to place
    it's hard to fine. Why not let GA maintain the promissory note and
    send to Federal Student Aid as required or requested.

-   With the CAM the process, it is much improved in the community. GA
    is trying to review claim timely and if lender reporting directly
    this causes reconciliation. On assignments is the promissory note
    going to Borrower Services? There is a lot of work on involved in
    assignments and if Federal Student Aid could review the information.
    The assignment data is probably in NSLDS and community feels that
    Federal Student Aid should use the assignment data from NSLDS.
    Random reasons for rejection of promissory note. No consistency with
    standards. If information is already in NSLDS, anything Federal
    Student Aid can do to streamline this process. Timeliness of Federal
    Student Aid's acceptance or rejecting of files. Timeliness important
    in addition to accuracy of data submitted.

> **Treasury Offset Process**

-   Once a year and process is working pretty well. Offset process works
    very well and GA's receive Treasury notification promptly. Data flow
    for assignments, TOP and NSLDS should be consistent.

-   GAFR reporting consistency and reconciliation and we would have to
    deal with inconsistencies with the prior populations. Discussion
    about claims paid based on NSLDS reporting. Community didn't argue

-   Rehabilitation loans discussed in general but the discussion was
    about Borrower Services rehabilitation program.

-   Common file layout..... stressed the importance of getting this
    initiative standardized.

***Group D: Consolidations***

-   Driven by peak interest rates cycles, hampers processing

-   LVC takes 45-60 days to collect and the parents and students were
    adversely affected with this last round. Parents were upset with
    loan holders, as they were afraid they were missing out on new
    rates.

-   Some holders were not aware that the one holder rule was "going"
    away, which delayed processing.

-   Loans not out there fast enough on NSLDS. This caused problems with
    verifying loan eligibility.

**Overview of Consolidation Steps**

-   Borrower makes application.

-   List of student's loans.

-   Lender sends out certification of lender.

-   Required to fill out within 10 business days.

-   Lender uses information to calculate weighted average and determine
    amount of consolidation.

-   Old lender reports to NSLDS (PIF through consolidation).

-   New lender reports new consolidation to NSLDS.

-   Holding lenders are reluctant to release, so they say they have an
    application in-house or deny for a ridiculous reason.

-   What would make it better:

-   LVC Clearinghouse that took all the loans in to monitor average
    response. Direct Loan comes back within 10 days. Other lenders
    (current holders) have more problems. Welfare of student and parent
    should be the focus.

-   Consolidation lender should inform student that they did not include
    a loan, so they can add within 180 days.

-   Loans are being left out of consolidation. Loans are being
    consolidated and then the student has other loans go into default.
    Need a way for the borrower to know who the holder of the loan is,
    so they can make better decisions.

-   Rehab is used to get borrower into repayment.

> **Linking Underlying Loans to Consolidation Loan**

-   School perspective -- it would be very helpful. Rely on reporting on
    loans and there is some duplicate reporting. There is double
    counting or loans are left out -- have to manually look up data on
    NSLDS and are still guessing.

-   Would be nice if consolidating lender reported which loans they were
    consolidating to NSLDS. Currently, they have information by bucket,
    not by loan (loan holder).

-   Looking at aggregate information. Hard to tell true principal,
    needed to determine if student is eligible for new loans.

-   Go back to borrower with an Addendum (based on research from NSLDS)
    asking borrower whether they intended to exclude (especially
    Perkins).

-   Borrowers are in such a hurry to take advantage of new interest
    rates; that they don't know about their aggregate issues or where to
    go for help.

-   Student NSLDS view is easier and laid out nicely. Create a new
    "clean" view for other servicers. Provide the information the
    company needs to see.

-   Push information to student. After the Consolidation tell the
    borrower to review their records to see if their new account is
    correct.

-   Federal Student Aid would query NSLDS and send information to
    borrower on new Consolidation loans and other loans still on record.
    Would require timely reporting by lenders.

-   Growth in Consolidations is recent. Front end marketing companies
    involved, which then pass it on to processing company. Processing
    company might not care about sweeping in all the loans. Provide
    NSLDS information to marketing companies.

-   Bump up exit interview process to provide breakdown of loans to
    student. Would be limited to NSLDS information (reporting
    timeliness).

-   Loans are sold, so student does not know who is the lender vs. the
    servicer vs. holder. So they have no idea who the lenders are when
    filling out their application.

-   Consolidation application processor must inform borrower of
    outstanding loans.

> **Common Line Standard**

-   Common Account Maintenance (CAM) -- standard way to communicate
    information. Not all GAs use CAM, but it is evolving. Paper process
    is necessary for proprietary and rejects. PC based process for small
    entities (it's not known about/being used). Buckets and personal
    information.

-   Regulations are the only way to standardize practices by GAs.

-   Report actual principal paid through consolidation, not total
    balance.

-   Is the problem with reporting to NSLDS? Aggregate amount does not
    capture what needs to be used for eligibility. What is outstanding
    principal? Need information for credit reform requirements.
    Underlying reporting to NSLDS should include outstanding principal
    (need to break out capped interest).

-   Most of it has to do with timing. Problem accounts that don't fit
    into the algorithm will still be a problem.

-   If account is linked, do we have to go the step further?

-   Redefinition of aggregate amount.

-   Regulatory changes will be necessary to enforce broad changes.
    Identify were this is necessary.

> **Data Integrity**

-   LVC reporting timeliness is the issue. Can take up to 60 days. Go to
    source of data for information.

-   Using current technologies, Schools could find the data. Reporting
    data more often is important, but may not solve the issue.

> **Common Identifier**

-   It's a good thing.

-   Use Common Line ID -- Best potential option, but won't solve all the
    problems. Old loans won't have these IDs. Might require refinement
    -- discussion would be needed to determine. Go forward...

-   RID resistance -- ID who your trading partner is. Cutting down on
    the number of IDs. Provide further information on it.

-   Private loans have problems with the common line ID flows, because
    they did not generate the ID. Creates matching issues. Not full
    compliance with schools. Becoming more common. (Statutory change)

> **Single Federal Student Aid Gateway**

-   Consistent way to report to ED.

-   Mailbox is designated to a specific SSN/person at an agency.

-   Make it consistent with how the community is reporting information.

> **Reporting Standards**:

-   Instead of visually looking at NSLDS, send information in XML
    standards. API link. Must protect data.

-   Want to be able to poll NSLDS electronically (batch file) for LVC
    data.

-   Need an academic year attached to a loan.

-   Block editing -- include pieces of data that can be updated, and
    reject the ones that are wrong (e.g., do not reject financial data
    because a borrower address is in the wrong format).

-   Converting CAM records to XML. ESC looked into some issues, but the
    business requirements did not seem to support changes. Would revisit
    if that changes.

-   Keep the terms consistent, but not vague.

-   See batch record timeliness improvements. Alert was not in line with
    web updates (web date was prior to alert). (COD)

-   Audit trail of changes, instead of just last date of update. See
    what the status was on the date of the award.

***Breakout Session Presentations***

**Group A: Certification through Entering Repayment**

-   Require FAFSA for PLUS to get student eligibility checks

-   Process all eligibility upfront and match with other Federal
    agencies during the application process

-   Do not reject a new loan that is valid; so that we keep the good,
    "new" loan record and move old loan

-   Build upon existing industry standards, e.g. CommonLine, file
    formats, data element definitions

-   "Right"-time data on certain elements, as opposed to all elements;
    standardize transport mechanisms; ability to report only changes

-   Improve eligibility communication, especially with loan aggregates,
    provide disbursement alerts for dual enrollments

-   Automate process and eliminate as much paper as possible

-   Eliminate paper checks

-   Transfer of paper at time of assignment, and only move when needed

-   More ad-hoc reporting from NSLDS, e.g. searching CDR for the
    borrowers and/or programs that are served by a particular
    institution

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

-   Loan holder responsibility

    -   Good: lender is best source for timely, accurate information

    -   Challenges:

        -   consistent reporting standards needed

        -   consistent edits

        -   consistent definitions

        -   reconciliation,

        -   GA financial issues informed, rejected data from NSLDS

-   Common Aid ID

    -   Good: follows loans throughout lifecycle; commonly used;
        consolidation

    -   Challenge: implementing across all programs, and identifying
        loan ID that pertains to entire lifecyle, and not just initial
        stages

-   Link data to requirements

    -   Good: collecting only what's needed, when needed

    -   Challenges: allow transactional reporting? (ie, month-end,
        real-time, etc.), defining who's data is best during
        reconciliation

-   Other captured items

    -   P-note: who holds the original note? (lender, originator,
        disbursing agent, etc.); certified copies sometimes go to
        guarantors????

    -   Exit counseling -- schools don't have consistent way to manage
        this; should NSLDS capture this information?

    -   Anticipated graduation date: often students report dates that
        are not accurate and enter repayment early; need to improve the
        reporting process since many sources can provide this
        information

**Group C: Claim Filing through Closure**

-   Need for common identifier for loans to prevent duplicate bookings,
    payments, etc.

-   ED should implement standards for these identifiers and give ample
    time for community to adapt to these new standards

-   What about loans already booked? (no answer to this yet)

-   Make no assumptions about existing loans; need specific loan
    identifiers -- get all information needed

-   Data should be standardized with common definitions and edits

-   Need common edits for everybody (GAs, lenders, ED, schools,
    servicers)

-   Needs to be consistency from originations from schools all they way
    through lifecycle

-   GAs use standard claim filing (CAM) process; problem with CAM-
    concern that history is lost when loans are moved from one holder to
    another; ED should review CAM to ensure we don't fix something
    that's not broken

    -   CAM is a standard way that lenders and lender servicers
        transport information

    -   Include CAM with the CommonLine discussions!

    -   CAM only keeps the most current record; there must be a way to
        maintain the entire history from holder to holder

-   If RID is different from OPE ID, then problems are inherent

-   School identifier -- use of the name, DOB, etc; use of identifier
    other than SSN might be a problem; how can we deal with rolling out
    a system with new identifiers?

-   Don't want to report to ED and GAs; only report to one entity; by
    reporting to multiple entities, information can quickly get out of
    synch and burden reconciliation process

-   Loan holder responsibility concerns -- will GAs get the information
    they need if lenders submit directly to ED? The distinction we want
    to make is there are specific systems require significant
    re-engineering of those processes

-   Claim filing through closing: standardize submission format
    reporting to DCSS and NSLDS

**Group D: Consolidations**

-   Timeliness of LVC: some schools not adhering to ten day turnaround
    time

-   Idea: LVC Clearinghouse used by ALL

-   Timeliness of reporting information to NSLDS & payoffs to NSLDS

-   Consolidators should inform borrowers of loans not included to
    educate borrowers of their rights and reasons why not included

-   Idea: Pushing data to borrowers to assist them to find information
    on their own; but where will holder get data from?

-   Originating consolidator should report what loans they are
    consolidating

-   Report outstanding principal at time of payoff

-   Provide simple NSLDS view for consolidators for student's
    indebtedness

-   Provide easy access to originators for consolidated loans

-   Idea: ED sends information to new consolidation borrowers to
    increase awareness of "what you just did, what wasn't included,
    etc."

-   Use source of data when data timeliness critical to business need,
    e.g. eligibility;

-   Use CommonLine ID as standard identifier; but allow ample time to
    adopt

-   Collect academic year and associate that with loan

-   Associate Gateway with entity, and not with person

-   Need better understanding of RID

-   Gather "pieces" or "blocks" of data, instead of "all or nothing"

-   Consistent data definitions

**Open Discussion**

-   Collecting payoff on loan and outstanding principal; if we collect
    loan payoff, then additional information would be helpful??????

-   Really be helpful to get audit trail on NSLDS to help us know that
    changes were made because award decisions may be based on past data
    unknowingly

-   DataStrategy@ed.gov