**Cohort Default Rate**

**Guide for**

**Guaranty Agencies & Lenders**

![](media/image1.png)

**Fiscal Year 2004**

**U.S. Department of Education**

**Financial Partners Services**

**TABLE OF CONTENTS**

Introduction\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\......................1

Background\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\....................\...\...\..........1

Cohort Default Rate Formula
2004..............................\...\...\...\...\...\...\..........2

Commonly Asked
Questions............................................................4

Data
Corrections..........................................................................10

Information About Back-Up Data
Printouts\.......\...\...\...\...\...\...\...\......\...\...\...\...\......19

Appendix A: Department of Education Contact
List\...\...\...\...\...\...\.......\...\...\........20

Appendix B: Guaranty Agency
List\...\...\...\...\........\...\...\...\...\...\...\...\.......\...\...\.......\...22

**INTRODUCTION**

This guide contains information about the publication of the Fiscal Year
(FY) 2004 cohort default rates for originating lenders, current holders,
and guaranty agencies participating in the Federal Family Education Loan
(FFEL) Program, as mandated by the Higher Education Act of 1965, as
amended.

**BACKGROUND**

Under Section 430(e) of the Higher Education Act of 1965, as amended
(HEA), the Department of Education (the Department) is required to
publish the cohort default rates of lenders, subsequent holders, and
guaranty agencies and Colleges and Universities participating as a
lender in the FFEL Program. The purpose of this guide is to provide the
student loan industry with information on the calculation of the cohort
default rates.

The term **cohort default rate**[^1]**,** for any fiscal year where 30
or more student borrowers enter repayment is the percentage of those
borrowers who enter repayment on certain FFEL Program loans during a
particular fiscal year and default within the same fiscal year or within
the next fiscal year.

Cohort default rates are calculated for originating lenders, subsequent
holders, and guaranty agencies on the basis of their respective Lender
Identification Numbers (LID) or Guaranty Agency Identification Numbers.
Each assigned number identifies a separate lender or guaranty agency on
record at the Department of Education. The LID provides the guaranty
agencies with a means of reporting loan activity.

The FY 2004 cohort default rates are calculated based on data reported
to the National Student Loan Data System (NSLDS) by the guaranty
agencies. Cohort default rates (CDR) are calculated bi-annually. The
first calculation is known as the draft, which is calculated in January
and distributed in February. The official CDR calculation occurs in July
with a September distribution. The following loan types are included in
the CDR calculation: Subsidized Federal Stafford, Unsubsidized Federal
Stafford, Federal Supplemental Loan for Students[^2] (Federal SLS), and
Federal Consolidation Loans that repaid Federal Stafford or Federal SLS
loans. The NSLDS data submitted by the guaranty agencies are prepared
according to procedures developed by the Department of Education and
reflect activity on the loans through September 30, 2005. Since the FY
2004 cohort default rates are calculated based on data supplied to the
Department of Education by the guaranty agencies, a lender or holder
should address any initial questions on data to these agencies.

Loans made under a Lender-of-Last-Resort program, Federal PLUS loans,
and Federally Insured Student loans are not used in the calculation.
Loans that are transferred from one GA to another are included for the
current GA unless the loan had a default claim within the cohort period
and prior to the transfer. For example, if a loan was originally
guaranteed by the Higher Education Assistance Foundation (HEAF) and was
transferred to the Great Lakes Higher Education Corporation (Great
Lakes), that loan was reported by Great Lakes.

**Cohort Default Rate Formula for FY 2004:**

*\# of students who entered repayment on their loans in FY 2004*

*and defaulted in FY 2004 or FY 2005*

*(Numerator)*

*100 X
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_*

*\# of students who entered repayment on their loans in FY 2004*

*(Denominator)*

Example:

A lender has made loans to 100 students entering repayment in FY 2004
(October 1, 2003 through September 30, 2004). Of those 100 students, 25
defaulted on their student loans prior to October 1, 2004 and had a
default claim paid by the guaranty agency. This lender's FY 2004 cohort
default rate is calculated by dividing 25 by 100 and multiplying the
result by 100 to produce a cohort default rate of 25.0 percent.

**Denominator:** The number of students who entered repayment in FY
2004. If a student has more than one loan included in the data (for
example, two Federal Stafford loans or one Federal Stafford and one
Federal SLS loan), the student will be counted only once. However, if a
student borrowed from more than one lender, he or she is counted in the
calculation for each lender.

**Numerator:** If a student has a loan that entered repayment in FY 2004
and a default claim was paid by the guaranty agency during that fiscal
year or the subsequent fiscal year ending September 30, 2005, the
student is counted in the numerator, even if the student later enters
into a repayment arrangement with the guaranty agency, or the student
subsequently repaid his or her loan in full to the guaranty agency.

**Discharged Loan:** Loans that are discharged due to death, total and
permanent disability, or bankruptcy are not counted in the numerator
when calculating the FY 2004 cohort default rate **if** the guaranty
agency was officially notified of the death, disability, or bankruptcy
**before** a default claim was paid.

Once data for a specific fiscal year is submitted to NSLDS by a guaranty
agency it continues updating on a schedule basis until the rates are
calculated. If you have Technical questions regarding cohort default
rate calculations that cannot be answered by the guaranty agency contact
NSLDS Customer Service Center at (800) 999-8219. Their web address is:
http://www.nsldsfap.ed.gov.

Section 430(e) of the HEA also mandates that originating lenders,
holders, and guaranty agencies have the opportunity to correct cohort
default rate information. If a lender or holder believes that the data
are incorrect and should be changed, it should promptly refer to the
NSLDS web site at http://www.nsldsfap.ed.gov to request back-up data
(loan record detail report). For instructions on how to correct cohort
default rate information go to "Data Correction", page 10. For
information about back-up data printouts go to page 19.

Lenders (or holders) that have questions about the data should contact
the guaranty agency. For a list of guarantors and their telephone
numbers and addresses go to Appendix B, page 22.

Other questions on lender, holder, or guaranty agency default rates may
be referred to the Default Coordination Team, Financial Partners
Services, the address is listed on Appendix A, page 20.

**[Commonly Asked Questions]{.underline}**

**Where can I get a copy of the Cohort Default Rate Guide for Guaranty
Agencies and Lenders?**

1)  website address http://www.ifap.ed.gov/csb_html/newdefault.htm

2)  contact the Financial Partners, Default Coordination Team at (202)
    377-3053.

**What is a cohort default rate?**

The term **cohort default rate** is defined in Section 435(m) of the
HEA. The formula for calculating the cohort default rate is described
below.

\# of students who entered repayment in FY 2004 and

defaulted on or before the end of FY 2005

(Numerator)

100
X\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\# of students who entered repayment in FY 2004

(Denominator)

Example:

A lender has made 100 loans to students entering repayment in FY 2004
(October 1, 2003 through September 30, 2004). Of those 100 students, 25
defaulted on their student loans prior to October 1, 2005 and had a
default claim paid by the guaranty agency. This lender\'s FY 2004 cohort
default rate is calculated by dividing 25 by 100 and multiplying the
result by 100 to produce a cohort default rate of 25.0 percent.

**When is a loan considered to be in default?**

A loan is considered in default for cohort default rate purposes if the
guarantor paid a claim during the cohort period with a claim reason of
default. Closed schools and False certification claims were included in
the calculation prior to February 2003.

**Where does the Department obtain the data for calculating these
lender, holder and guaranty agency cohort default rates?**

The FY 2004 cohort default rates were calculated based on data reported
to the National Student Loan Data System (NSLDS) by the guaranty
agencies. The NSLDS data submitted by the guaranty agencies was prepared
according to procedures developed by the Department and reflect activity
through September 30, 2005.

**How is the numerator calculated?**

If a student entered repayment in FY 2004, defaulted on his or her loan,
and a default claim was paid by September 30, 2005, the student counted
as in default in the FY 2004 cohort default rate calculation, even if
the student later enters into a repayment arrangement with the guaranty
agency or repays his or her loan in full to the guaranty agency. The
Date Entered Repayment is reported by Guaranty Agencies to NSLDS on its
normal submittal file.

**How is the denominator calculated?**

The denominator is the total number of students that entered repayment
in the FY 2004 cohort year. If a student had more than one loan included
in NSLDS (for example, two Federal Stafford Loans or one Federal
Stafford and one Federal SLS loan), the student will be counted only
once. However, if a student borrowed from more than one lender, he or
she is counted in the calculation for [each]{.underline} lender or
guaranty agency.

**Are discharged loans included in the cohort default rate, e.g., death,
disability, or bankruptcy?**

Loans that are discharged due to death, total and permanent disability,
or bankruptcy are counted in calculating the FY 2004 cohort default rate
as a part of the denominator. Loans that are discharged due to death,
disability, or bankruptcy are not counted in calculating the FY 2004
cohort default rate as a part of the numerator **if** the guaranty
agency was officially notified of the death, disability, or bankruptcy
**before** a default claim was paid.

**What opportunity will guaranty agencies, lenders, and holders have to
correct the data?**

Any agency/lender that receives a cohort default rate has the right to
correct their rate but they must provide supporting documentation for a
rate change. To correct the cohort default rate, the lender or holder
must first request the back-up data from the NSLDS web site at
[http://www.nsldsfap.ed.gov]{.underline}. The back-up data comes from
the data that was electronically reported to NSLDS by the guaranty
agencies. For details, see "Data Corrections" page 10.

After requesting and reviewing the data, a lender or holder may contest
its default rate by providing the guaranty agency(ies) with any relevant
documentation to support its contention that the data are incorrect and
should be changed. The guaranty agency must review the documentation and
determine whether it agrees that the data are incorrect. The agency must
notify the lender or holder and the Department, in writing, of its
conclusion. The Department will make the final decision on the
correction(s).

**What is the process for data corrections for lenders and holders?**

For details, see "Data Corrections" on page 10.

What type of allegations may a guaranty agency or lender submit as a
data correction?

-   Data Conflicts

For further details see "What is a Data Corrections" on page 12

What is the difference between an originating lender/holder and the
current lender/holder?

The Originating lender represents the entity that provided and
originated the loan to the borrower. The Current lender represents the
last entity to hold the loan at the time the cohort default rate was
calculated.

Which loan type codes are included in the calculation of Cohort Default
Rates?

Subsidized Federal Stafford (SF and D1), Unsubsidized Federal Stafford
(SU and D2), Federal Supplemental Loan for Students (SL), and Federal
Consolidated Loans (CL, D5 and D6) with specific rules. All other FFELP
loan types are excluded.

Federal Consolidation Loans (CL) are linked back to the underlying loans
paid by consolidation. If the underlying loan entered repayment and is
included in the denominator and the Consolidation Loan defaults in the
cohort period, the borrower will be counted in the numerator for cohort
default rate purposes.

Borrowers of Subsidized Federal Stafford, Unsubsidized Federal Stafford,
Federal SLS, and Federal Consolidation Loans that repaid Federal
Stafford or Federal SLS loans will be included in the calculation of
cohort default rates. Loans made under a Lender-of-Last-Resort program
are not used in the calculation. Loans that are transferred from one GA
to another are included for the current GA unless the loan had a default
claim within the cohort period and prior to the transfer.

**Which loan status codes are included and excluded from the CDR
calculation?**

All Loan Status Codes are included in the Cohort Default Rate
Calculation except abandoned (AL), all uninsured (UA,UB,UC,UD, and UI),
and cancelled (CA) loan status codes.

**How can I get a copy of my loan record detail report?**

# 

# Log onto the NSLDS Web site at [http://www.nsldsfap.ed.gov](http://www.nsldsfap.ed.gov/) or contact Financial Partners, Partner Services, Default Coordination Team at (202) 377-3053. To retrieve this information from the NSLDS website, log on with your NSLDS user id, go to the report tab, and select Report DRC040 GA Cohort Default Rate History Report and select Report DRC045 for the Lender Cohort Default Rate History Report. The report is available in report format or extract format. The file layout for an extract can be found at: <http://ifap.ed.gov/nsldsmaterials/attachments/GA200107attachment1.pdf>

# 

If you have questions on getting an NSLDS user id or need information on
requesting this report, please call the NSLDS Customer Service Center at
1-800-999-8219.

**How are the borrowers of underlying loans in Consolidations counted in
Guaranty Agency Cohort Default Rates?**

> The Cohort Default Rate Program looks at the date entered repayment of
> the underlying loans (loans that NSLDS has linked to a consolidation
> loan) to determine which cohort fiscal year the borrower is counted.
>
> For underlying loans with a status of 'PC', 'PN', or 'DN', the program
> looks to see if the guaranty date of the consolidation loan was on or
> before the end of the Cohort Period (2 year window beginning with
> Cohort Fiscal Year begin date).
>
> If the consolidation loan was made prior to the end of the cohort
> period, then the borrower is counted in the consolidating agencies
> cohort rate.
>
> Likewise, if the consolidation loan defaults the borrower would also
> be counted in the consolidating agencies cohort rate.
>
> If the consolidation loan was made after the end of the cohort period,
> the underlying loan is processed as if no consolidation loan had
> occurred.
>
> Loans with the lender_of_last_resort flag set to 'Y' in NSLDS are NOT
> included in the cohort default rate.

How important is the Date Entered Repayment, as reported to NSLDS, in
the Cohort Default Rate Calculation?

The date entered repayment is integral to the cohort default rate
calculation. As a result, it is important that you ensure that this date
is reported accurately to NSLDS.

1.  For loans closed as a result of consolidation that have not entered
    repayment, set the date equal to the effective date of the loan
    status of 'PC', 'PN', or 'DN'.

2.  The cohort default rate calculation uses the date entered repayment
    to determine which borrower to count in the denominator. Continually
    moving the date entered repayment can cause a loan to be included
    potentially in multiple cohort fiscal year calculations or if the
    date is incorrect, a loan could be included in the wrong cohort
    fiscal year.

3.  Many guarantor systems set the date entered repayment based on the
    anticipated completion date. It is important to update the date
    entered repayment to be equal to the borrower's separation date
    (withdrew, graduated, or less than half-time) plus grace plus one
    day. Furthermore, the anticipated completion date is not used in the
    cohort default rate calculation.

4.  In cases when the borrowers pay the loan in full while in a grace
    period, and prior to the end of the loan period, it is important
    that the date entered repayment be modified to the effective date of
    the loan being paid in full. A future date entered repayment
    remaining on a loan can cause the borrower to be counted in the
    wrong cohort unless it is a cancellation.

5.  Once the loan has entered repayment, this date should not be changed
    except to correct an error. (Do not replace an original Date Entered
    Repayment with the date associated with a new loan, or the date the
    borrower resumes repayment after deferment or forbearance.)

Note: If the loan is paid in full within 120 days of disbursement, then
the loan is cancelled. Cancelled loans do not get counted in the cohort
default rate calculation.

**Reporting Ineligible Borrower Claims Defaults**

A loan for which the borrower is ineligible due to the borrower's or
student's error is treated as a default if the borrower fails to repay
the full amount due within 30 days after the final demand letter is
mailed. For these loans to be appropriately reported to NSLDS and to be
included in the calculation for cohort default rates, it is important
that the reason code for these claims be reported as 'DF'.

######## How does the cohort default rate affect the loans being consolidated?

In order for a consolidation loan to be considered in the cohort default
rate calculation a **link** must be established between the underlying
loan and the consolidation loan. The link between an underlying loan and
a consolidation loan is established according to procedures developed by
the Department of Education. 

**Linking**

To link an underlying loan and consolidation loan, the underlying loan
must be reported as paid through consolidation (loan status codes
\'PC\', \'PC\' or \'DN\'). If an underlying loan is reported as paid
through consolidation, then a match to a consolidation loan is
attempted. The link is established when the underlying loan has a loan
status indicating that the loan has been paid through consolidation and
the loan status date is 210 days on or after the loan date of the
consolidation loan. Thus, if the paid through consolidation loan status
date of the underlying loan is prior to the loan date of the
consolidation loan, the underlying loan will **[not]{.underline}** be
linked to the consolidation loan and the consolidation loan will not be
included in the cohort default rate.

 

Borrower 1: There are 4 loans with a date entered repayment within the
cohort year. They are reported as paid through consolidation on
10-21-2003. The consolidation loans have loan dates of 10-30-2003 and
01-09-2006. Since the paid through consolidation loan status date of
**10-21-2003 is prior to** the consolidation loan date of **10-30-2003**
**and not within 210 days of** the other consolidation loan date of
**01-09-2006**, the consolidation loan is not linked to the underlying
loans and thus, **is not** **included** in the cohort default rate.

 

Borrower 2: There are 13 loans with a date entered repayment within the
cohort year. They are reported as paid through consolidation on
02-05-2004. The consolidation loan has a loan date of 02-05-2004. Since
the paid through consolidation loan status date of **02-05-2004 is
within the 210 days on** or after the consolidation loan date of
**02-05-2004**, the consolidation loan is linked to the underlying loans
and thus, **is included** in the cohort default rate.

 

Borrower 3: There are 4 loans with a date entered repayment within the
cohort year. They are reported as paid through consolidation on
09-21-2004. The consolidation loan has a loan date of 10-04-2004. Since
the paid through consolidation loan status date of **09-21-2004 is prior
to** the consolidation loan date of **10-04-2004**, the consolidation
loan is not linked to the underlying loans and thus, **is not**
**included** in the cohort default rate.

 

Borrower 4: There are 4 loans with a date entered repayment within the
cohort year. They are reported as paid through consolidation on
07-06-2004. The consolidation loans have a loan date of 07-26-2004.
Since the paid through consolidation loan status date of 07-06-2004 is
prior to the consolidation loan date of 07-26-2004, the consolidation
loan is not linked to the underlying loans and thus, **is not included**
in the cohort default rate.

 

**Data Corrections**

Under Section 430(e) of the HEA, lenders, holders, and guaranty agencies
are allowed the opportunity to correct cohort default rate information.
The Department calculates cohort default rates based on data submitted
to NSLDS by guaranty agencies. The Department selects certain relevant
fields from NSLDS, compiles the data by borrower and lender code, and
then performs the calculations necessary to determine the cohort default
rate.

Although a student\'s loan records may be included in both the Federal
Stafford and Federal SLS data because he or she had both Federal
Stafford and Federal SLS loans from the same lender or holder entering
repayment in the same fiscal year, the student is only counted once in
the cohort default rate calculation. Likewise, if there are multiple
loan records for the student for one of the loan programs, the student
is still counted only once. If a student borrowed from more than one
lender, he or she is counted in the calculation for each lender. You
should note that the data reflects the status of loans through September
30 of the year following the cohort year. Thus, data for the FY 2004
cohort year reflects the status of loans only through September 30,
2005.

If you are an originating lender or holder and believe that the cohort
default rate was calculated based on erroneous data, contact the
guaranty agency. If you discover discrepancies between the information
in your records and the data provided to the Department by the guaranty
agencies, you should try to resolve the problem with the guaranty agency
that submitted the data to the Department. You should submit to the
guaranty agency all the relevant documentation supporting your
contention that the data relating to a particular loan are incorrect and
should be changed. The guaranty agency (GA) will review the
documentation that you submit and determine whether it believes to be
erroneous by the GA, then they will notify the Department in writing.
Financial Partner Services will review the Data provided by the GA and
make a final determination on whether the data provided is incorrect. If
the correction is approved by the Department, the guaranty agency will
be notified and will make the appropriate changes in the default rate
information provided to NSLDS.

*The process for data correction is as follows:*

1.  Lenders or holders are urged to promptly request back-up data (loan
    record detail report) from the NSLDS web site at
    [http://www.nsldsfap.ed.gov](http://www.nsldsfap.ed.gov/) if they
    believe their cohort default rates were calculated on the basis of
    incorrect data. (Back-up data is an extract of the loan records that
    formed the basis for calculating your lender or holder cohort
    default rate.)

2\. After reviewing the back-up data, the lender or holder should submit
the appropriate documentation to the guaranty agency in support of its
contention that the data are incorrect. Such documentation should
include the borrower\'s name, social security number, and the nature of
the error in each case. Supporting documentation could include copies of
the guarantor\'s notice of a change on the Student Status Confirmation
Report, canceled checks, or copies of other pertinent information. To
ensure timely processing of the request, borrowers should be listed in
social security number order. A lender or holder should identify the
cohort year to which the corrections apply. All requests to the guaranty
agency for a correction should be signed by an official of the lender or
holder who is authorized to act on its behalf in this regard.

3\. The guaranty agency should analyze a lender\'s or holder\'s request
for data correction and determine whether it will agree with or deny the
request for a correction.

4\. When the guaranty agency has completed its analysis of the request
for data correction, the lender or holder must be notified of the
agency\'s conclusions. A copy of the letter from the guaranty agency
agreeing with or denying the data correction must be sent to the Default
Coordination Team at the address listed below.

U.S. Department of Education

Financial Partners, Partner Services

Union Center Plaza, 11^th^ Floor

400 Maryland Avenue, S.W.

Washington, D.C. 20202-5138

ATTN: Default Coordination Team

**What is a data correction?**

After the release of the official cohort default rates, the U.S.
Department of Education (the Department) provides guaranty agency and
lenders an opportunity to review the original data. Guaranty agencies
must submit incorrect data to the Department for corrections. Lenders
must submit incorrect data to the guaranty agency for corrections. The
process of correcting data is called a "data correction."

**Can guaranty agencies or lenders submit a data correction?**

Any guaranty agency or lender that receives an official cohort default
rate is provided the opportunity to correct its most recent official
cohort default rate. Correcting official cohort default rate data
enables a guaranty agency or lender to request a correction to what it
believes to be inaccurate data contained in the guaranty agency's or
lender's loan record detail report for the official cohort default
rates.

What type of allegations may a guaranty agency or lender submit as a
data correction?

-   Data Conflicts -- not able to report on a loan because of a
    data/identifier conflict

**What benefit will a guaranty agency or lender gain from submitting a
data correction?**

If it is determined that the official cohort default rate data submitted
by the guaranty agency or lender is inaccurate, the [guaranty
agency]{.underline} or [lender]{.underline} official cohort default rate
should reflect the change. The change to the data may lower, raise, or
not affect the cohort default rate.

**How does a guaranty agency submit a data correction?**

Timing is critical when submitting a data correction. In order to submit
a data correction, the guaranty agency must review the loan record
detail report for the official cohort default rates to determine if the
loan record detail report contains any inaccurate data. If the guaranty
agency believes the loan record detail report contains inaccurate data,
it should submit a data correction listing of the guaranty agency's
incorrect data allegations to Financial Partner Services with the
inaccurate data. The guaranty agency must submit the data correction
within 45 calendar days of the publication of the official rate.

The guaranty agency must list separate data correction allegations for
each loan record that the guaranty agency believes contains inaccurate
data.

######## How does a lender submit a data correction?

Timing is critical when submitting a data correction. In order to submit
a data correction, a lender must review the loan record detail report
for the official cohort default rates to determine if the loan record
detail report contains any inaccurate data. If the lender believes the
loan record detail report contains inaccurate data, it should submit a
data correction listing to the guaranty agency with their incorrect data
allegations. The lender must submit the data correction within 30
calendar days of the publication of the official rate to the guaranty
agency. The guaranty agency has 15 calendar days to review the lender's
incorrect data submission and make the determination on whether the data
provided is incorrect. The guaranty agency must notify the lender and
the Department, in writing, of its conclusions.

A lender must list separate data correction allegations for each loan
record that the lender believes contains inaccurate data.

The data correction must include the following items:

-   **A completed incorrect data correction spreadsheet that lists the
    inaccurate data reflected on the loan record detail report.**

Figure 1 is a sample guaranty agency data correction spreadsheet to
Financial Partner Services.

Figure 2 is a sample lender data correction spreadsheet to the guaranty
agency.

**[Figure 1 - Sample Guaranty Agency Data Correction]{.mark}**

**[Spreadsheet to Financial Partner Services]{.mark}**

Cohort FY: 2004 Number of Borrowers: 1

From: Coralville Agency Number of Loans: 2

Code: 123

To: Partner Services

+---+----------+-----------+-------+-------+----------+-------+-------+
|   | **A**    | **B**     | **C** | **D** | **E**    | **D** | **E** |
+---+----------+-----------+-------+-------+----------+-------+-------+
| * | **Bo     | **B       | *     | *     | **Ind    | ##### | **    |
| * | rrower's | orrower's | *Type | *Date | icator** | # Ori | Comme |
| 1 | SSN**    | Name**    | of    | of    |          | ginal | nts** |
| * |          |           | Lo    | Guara | **of     |       |       |
| * |          |           | ans** | nty** | Se       | **OPE |       |
|   |          |           |       |       | parate** | ID**  |       |
|   |          |           |       |       |          |       |       |
|   |          |           |       |       | **Loan** |       |       |
+---+----------+-----------+-------+-------+----------+-------+-------+
| * | 123      | Smith,    | SF    |       |          |       |       |
| * | -45-6789 | Bill      |       |       |          |       |       |
| 2 |          |           |       |       |          |       |       |
| * |          |           |       |       |          |       |       |
| * |          |           |       |       |          |       |       |
+---+----------+-----------+-------+-------+----------+-------+-------+
| * | 234      | Jones,    | SU    |       |          |       |       |
| * | -56-7890 | Mary      |       |       |          |       |       |
| 3 |          |           |       |       |          |       |       |
| * |          |           |       |       |          |       |       |
| * |          |           |       |       |          |       |       |
+---+----------+-----------+-------+-------+----------+-------+-------+
| * | 345      | Brown,    | SF    |       |          |       |       |
| * | -67-8901 | James     |       |       |          |       |       |
| 4 |          |           |       |       |          |       |       |
| * |          |           |       |       |          |       |       |
| * |          |           |       |       |          |       |       |
+---+----------+-----------+-------+-------+----------+-------+-------+
| * |          |           |       |       |          |       |       |
| * |          |           |       |       |          |       |       |
| 5 |          |           |       |       |          |       |       |
| * |          |           |       |       |          |       |       |
| * |          |           |       |       |          |       |       |
+---+----------+-----------+-------+-------+----------+-------+-------+

Date 10/14/2005 Page 1 of 1

**[Figure 2 - Sample Lender Data Correction]{.mark}**

**[Spreadsheet to the Guaranty Agency]{.mark}**

Cohort FY: 2004 Number of Borrowers: 1

From: Bank of Coralville Number of Loans: 2

Code: 123456

To: Guaranty Agency

Code: 123

+---+----------+----------+--------+-------+---------+-------+--------+
|   | **A**    | **B**    | **C**  | **D** | **E**   | **D** | **E**  |
+---+----------+----------+--------+-------+---------+-------+--------+
| * | **Bo     | **Bo     | **Type | *     | **In    | **    | **Comm |
| * | rrower's | rrower's | of     | *Date | dicator | Origi | ents** |
| 1 | SSN**    | Name**   | L      | of    | of      | nal** |        |
| * |          |          | oans** | Guara | S       |       |        |
| * |          |          |        | nty** | eparate | **OPE |        |
|   |          |          |        |       | Loan**  | ID**  |        |
+---+----------+----------+--------+-------+---------+-------+--------+
| * | 123      | Smith,   | SF     |       |         |       |        |
| * | -45-6789 | Bill     |        |       |         |       |        |
| 2 |          |          |        |       |         |       |        |
| * |          |          |        |       |         |       |        |
| * |          |          |        |       |         |       |        |
+---+----------+----------+--------+-------+---------+-------+--------+
| * | 234      | Jones,   | SU     |       |         |       |        |
| * | -56-7890 | Mary     |        |       |         |       |        |
| 3 |          |          |        |       |         |       |        |
| * |          |          |        |       |         |       |        |
| * |          |          |        |       |         |       |        |
+---+----------+----------+--------+-------+---------+-------+--------+
| * | 345      | Brown,   | SF     |       |         |       |        |
| * | -67-8901 | James    |        |       |         |       |        |
| 4 |          |          |        |       |         |       |        |
| * |          |          |        |       |         |       |        |
| * |          |          |        |       |         |       |        |
+---+----------+----------+--------+-------+---------+-------+--------+
| * |          |          |        |       |         |       |        |
| * |          |          |        |       |         |       |        |
| 5 |          |          |        |       |         |       |        |
| * |          |          |        |       |         |       |        |
| * |          |          |        |       |         |       |        |
+---+----------+----------+--------+-------+---------+-------+--------+

Date 10/14/2005 Page 1 of 1

-   **Copies of the appropriate pages from the loan record detail
    report(s).**

-   **Copies of relevant supporting documentation.**

```{=html}
<!-- -->
```
-   **A letter on the guaranty agency or lender's letterhead.**

> The letter must include the guaranty agency code, a statement
> indicating that the lender is submitting a data correction, and the
> cohort fiscal year to which the data correction applies. The letter
> must feature a subject line that reads "Subject: Cohort FY \[insert
> cohort fiscal year being used in the data correction\] Data
> Correction." The letter must include a certification that the
> information provided is true and correct under penalty of perjury. The
> lender's President/CEO/Owner and a guaranty agency's
> President/Director/CEO must sign the letter, and a signature block
> showing the signer's name and job title must follow the signature.
> Figure 3, page 15 is a sample guaranty agency data correction letter
> to a data manager. Figure 4, page 16 is a sample lender data
> correction letter to a data manager.

[]{.mark}

[]{.mark}

[]{.mark}

[]{.mark}

[]{.mark}

[]{.mark}

[]{.mark}

######### [Figure 3 - Sample Guaranty Agency Data Correction]{.mark} 

######### [Letter to the Financial Partner Services]{.mark} 

Coralville Agency

9765 Arts Lane

Coral City, Iowa 12345-9765

1-234-56-7890

October 14, 2006

U.S. Department of Education GA Code 123

Financial Partners, Partner Services

Union Center Plaza, 11^th^ Floor

400 Maryland Avenue, SW

Washington, DC 20202-5138

ATTN: Default Coordination Team

Subject: Cohort FY 2004 Data Correction

Dear :

Coralville Agency, GA Code 123, is challenging the cohort FY 2004
official cohort default rate data found in our loan record detail report
for the official cohort default rates. Please see the enclosed
spreadsheet, pages from the loan record detail report for the official
cohort default rates, and supporting documentation.

I, the undersigned, certify under penalty of perjury, that all
information submitted in support of this uncorrected data adjustment is
true and correct.

Thank you for your consideration.

Sincerely,

Name

President, Coralville Agency

Enclosures

**[Figure 4 - Sample Lender Data Correction]{.mark}**

######### [Letter to the Guaranty Agency]{.mark} 

Bank of Coralville

9745 Arts Lane

Coral City, Iowa 12345-6789

1-234-56-7890

October 14, 2006

OPE ID 123456

Compliance Officer

State Guaranty Agency

132 Ocean Front Road

Black Diamond Bay, Nebraska 3212-0132

Subject: Cohort FY 2004 Data Correction

Dear Compliance Officer:

Bank of Coralville, OPE ID 123456, is challenging the cohort FY 2004
official cohort default rate data found in our loan record detail report
for the official cohort default rates. Please see the enclosed
spreadsheet, pages from the loan record detail report for the official
cohort default rates, and supporting documentation.

I, the undersigned, certify under penalty of perjury, that all
information submitted in support of this uncorrected data adjustment is
true and correct.

Thank you for your consideration.

Sincerely,

Name

President, Bank of Coralville

Enclosures

The Department recommends that a guaranty agency or lender send all data
corrections correspondence return receipt requested or via commercial
overnight mail/courier delivery. This will be useful to a guaranty
agency or lender if it is asked to authenticate the timeliness of its
data correction. A guaranty agency or lender should maintain the
documentation that verifies the receipt of the data corrections as well
as all electronic and hardcopy documentation submitted as a part of the
data correction process. [If a guaranty agency does not meet the 45
calendar-day time frame for submitting a data correction, the data
correction will not be reviewed. If a lender does not meet the 30
calendar-day time frames for submitting a data correction, the data
correction will not be reviewed.]{.underline}

-   **The guaranty agency should determine if its documentation supports
    or refutes each of the data correction allegations listed on the
    lender's spreadsheet.**

If the guaranty agency agrees with the lender's data correction
allegations that a change should be made, it must correct the data in
its internal data system and in NSLDS.

The guaranty agency must provide supporting documentation if the
guaranty agency disagrees with the lender's data correction allegations.
The guaranty agency's response must include the following:

-   **A spreadsheet of the lender's responses to the guaranty agency
    list of alleged errors.**

-   **Copies of supporting documentation for each incorrect data
    correction allegation.**

-   **A letter on the lender's letterhead with the guaranty agency or
    lender's name and OPE ID number.**

The letter must indicate that the guaranty agency is responding to the
lender's data correction and state the cohort fiscal year to which the
response applies. The letter must feature a subject line that reads
"Subject: Cohort FY 2004 Incorrect Data Correction Response." The letter
must include a statement that a copy of the response has been sent to
Financial Partners Services, Default Coordination Team. The responsible
guaranty agency official must sign the letter, and the signature must be
followed by a signature block showing the signer's name and job title.

The guaranty agency sends its response to the lender and a copy of the
response to Financial Partners Services, Default Coordination Team.

What does Financial Partners Services (FPS) do with a guaranty agency
data correction request?

Financial Partners Services, Default Coordination Team will review the
guaranty agency's data correction request and determine whether it will
agree with or deny the request for correction. FPS will notify the
guaranty agency of its conclusions upon completion of its analysis of
the GA's request for data correction. A copy of the letter from FPS,
Default Coordination Team agreeing or denying the data correction will
be sent to the guaranty agency.

#### Information About Back-Up Data Printouts

**How to Read Back-Up Data Printout**

A back-up data printout, called a \"Loan Record Detail Report,\" is an
extract of the loan records that forms the basis for calculating your
lender or guaranty agency cohort default rate.

In your loan record detail report you will find general information,
including the name of the lender or guaranty agency, the corresponding
ID code, the cohort year covered, and the rate calculation date.

Information on how to find the NSLDS web site, loan record detail report
and downloading instructions can be found at the following web sites:

<http://ifap.ed.gov/nsldsmaterials/attachments/GA200107attachment1.pdf>
or

<http://ifap.ed.gov/nsldsmaterials/attachments/LLS200101Attachment1.pdf>

[http://www.ifap.ed.gov](http://www.ifap.ed.gov/).

NOTE: Information on how to retrieve the loan record detail report,
including screen shots, is provided in the updated section of the
Guaranty agency or lender Cohort Default Rate Guide in Chapter 2.6 "
General Information Tools" which is available only via download from the
web site.

**Privacy Act Notice**

Back-up data contains material of private nature. The use of this
material is covered by the U.S. Privacy Act and may also be governed by
State and local laws and regulations, as well as by your own policies.
You should take appropriate steps to safeguard this material and ensure
that it is used and disposed of appropriately.

##### 

##### 

##### 

##### 

##### 

##### 

##### 

##### 

####### Appendix A

**Department of Education Contact List**

**For technical data processing questions regarding the calculation of
the default rates, contact:**

U.S. Department of Education

NSLDS Customer Service Center

\(800\) 999-8219

http://www.nsldsfap.ed.gov

**For copies of regulations, Dear Colleague Letters, and other student
aid publications, contact:**

U.S. Department of Education

Student Aid Information Center

P.O. Box 84

Washington, D.C. 20044-0084

\(800\) 433-3243

http://www.ifap.ed.gov or

www.fp.ed.gov

**For other questions on lender, holder, or guaranty agency default
rates, contact:**

U.S. Department of Education

Default Coordination Team

Financial Partners Services, Partner Services Group

Union Center Plaza, 11^th^ Floor

400 Maryland Avenue, S.W.

Washington, D.C. 20202-5138

\(202\) 377-3053

http://www.fp.ed.gov

**To resolve errors in your lender (or holder) back-up data (loan record
detail report), contact the guaranty agency that reported the data to
the Department. A list of the guaranty agencies and their addresses is
included on Page 22, \"Guaranty Agency List\".**

**For information on school cohort default rates, contact:**

U.S. Department of Education

Default Management Division

Union Center Plaza 084F

400 Maryland Avenue, S.W.

Washington, D.C. 20202-5353

\(202\) 377-4258

http://www.ifap.ed.gov/csb_html/newdefault.htm

##### **Appendix B**

**Guaranty Agency List**

This section lists the names, addresses, and other identifying
information of the guaranty agencies. The address may be used to contact
guaranty agencies to resolve discrepancies in backup data. However, do
not use this address if a guaranty agency has provided you with a
different address or addressee.

Each agency is listed in alphabetical order by the name of the state in
which it is the primary guarantor. The three-digit guaranty agency code
listed in parentheses for each agency is the coding system used by the
Department to identify each guaranty agency.

The Higher Education Assistance Foundation (HEAF) ceased operations on
December 31, 1993. In preparation for the closing, HEAF transferred its
remaining guarantees on loans not in default to other guaranty agencies.
Affected lenders were notified of the guaranty agency now holding their
student loan guarantees which were originally issued by HEAF. The new
guaranty agency will be reported on the back-up data. The Department
possesses the records on defaulted loans on which HEAF paid default
claims to lenders. The Educational Credit Management Corporation (ECMC),
(formally the Transitional Guaranty Agency (TGA)), processes records
relating to a small number of loans guaranteed by HEAF that were not
transferred to other agencies and for loans guaranteed by HEAF that were
paid as or subsequently became Chapter 13 bankruptcy claims. ECMC also
holds and services Chapter 13 default bankruptcies for numerous guaranty
agencies that, on a voluntary basis, transfer these portfolios to ECMC.

The Puerto Rico Higher Education Assistance Corporation (PRHEAC) ceased
operations on April 15, 1994 and all guarantees were transferred to the
Great Lakes Higher Education Corporation (GLHEC). GLHEC will hold all
defaulted loans and related records previously held by PRHEAC. **NOTE:
If your organization is correcting its default rates based on erroneous
data, the possible errors must be identified to Great Lakes.**

The Mississippi Guaranty Student Loan Agency (MGSLA) ceased operations
on September 30, 1994 and all guarantees were transferred to the United
Student Aid Funds, Inc. (USAF). USAF will hold all defaulted loans and
related records previously held by MGSLA. **NOTE: If your organization
is correcting its default rates based on erroneous data, the possible
errors must be identified to USAF.**

The Student Loan Fund of Idaho, Inc. (SLFI) has been replaced (July 1,
1994) by the Northwest Education Loan Association (NELA) as the
designated guarantor. **NOTE: If your organization is correcting its
default rates based on erroneous data, the possible errors must be
identified to SLFI.**

The State Student Assistance Commission of Indiana (SSAC) ceased
guarantor operations on July 31, 1995 and all guarantees were
transferred to United Student Aid Funds (USAF). USAF holds all defaulted
loans and related records previously owned by SSAC. **NOTE: If your
organization is correcting its default rate based on erroneous data, you
must notify USAF of the possible errors.**

The Maryland Higher Education Loan Corporation (MHELC) ceased guarantor
operations on June 30,1995 and all guarantees were transferred to United
Student Aid Funds (USAF). USAF holds all defaulted loans and related
records previously owned by MHELC. **NOTE: If your organization is
correcting its default rate based on erroneous data, you must notify
USAF of the possible errors.**

The Delaware Higher Education Loan Program (DHELP) ceased guarantor
operations on April 24, 1996 and all guarantees were transferred to
Pennsylvania Higher Education Assistance Agency (PHEAA). PHEAA will hold
all defaulted loans and related records previously held by DHELP.
**NOTE: If your organization is correcting its default rate based on
erroneous data, you must notify PHEAA of the possible errors.**

The State Education Assistance Authority (SEAA) in Virginia has been
replaced (July 1, 1996) by the Educational Credit Management Corporation
(ECMC) as the designated guarantor. **NOTE: If your organization is
correcting its default rate based on erroneous date, you must notify
ECMC of the possible errors.**

The Ohio Student Aid Commission (OSAC) ceased guarantor operations
effective August 1, 1996 and all guarantees were transferred to Great
Lakes Higher Education Corporation (GLHEC). GLHEC will hold all
defaulted loans and related records previously held by OSAC. **NOTE: If
your organization is correcting its default rate based on erroneous
data, you must notify GLHEC of the possible errors.**

The Alabama Commission of Higher Education (ACHE) ceased operations in
December 1996 and all guarantees have been transferred to Kentucky
Higher Education Assistance Authority (KHEAA) as of June 1996. KHEAA
will hold all defaulted loans and related records previously held by
ACHE. **NOTE: If your organization is correcting its default rate based
on erroneous data, you must notify KHEAA of the possible errors.**

Northstar Guarantee Incorporated ceased operations in December 1997 and
all guarantees were transferred to Great Lakes Higher Education
Corporation (GLHEC). GLHEC holds all defaulted loans and related records
previously held by Northstar. **NOTE: If your organization is correcting
its default rate based on erroneous data, you must notify GLHEC of the
possible errors.**

The Oregon State Scholarship Commission (OSAC) ceased operations on
December 31, 2004 and all guarantees were transferred to the Educational
Credit Management Corporation (ECMC). ECMC will hold all defaulted loans
and related records previously held by OSAC. **NOTE: If your
organization is correcting its default rates based on erroneous data,
you must notify ECMC of the possible errors.**

**Alabama, AL (701)**

SEE Kentucky

**Alaska, AK (702)**

SEE United Student Aid Funds, Inc.

**Arizona, AZ (804)**

SEE United Student Aid Funds, Inc.

**Arkansas, AR (705)**

Student Loan Guarantee Foundation of Arkansas

219 South Victory

Little Rock, AR 72201-1884

\(501\) 372-1491

**California, CA (706)**

California Student Aid Commission/Edfund

10834 International Drive

Rancho Cordova, CA 95670

\(916\) 526-7900

**Colorado, CO (708)**

College Access Network

One Denver Place

999 18th Street, Suite 425

Denver, CO 80202-2471

\(303\) 305-3000

**Connecticut, CT (709)**

Connecticut Student Loan Foundation

525 Brook Street

Rocky Hill, CT 06067

\(860\) 257-4001

**Delaware, DE (710)**

SEE Pennsylvania

**District of Columbia, DC (611)**

See Massachusetts

**Educational Credit Management Corporation (ECMC) (927/951)**

(Formerly the Transitional Guaranty Agency (TGA))

American National Bank Building

101 East 5th Street, Suite 2400

St. Paul, MN 55101

\(651\) 221-0566

**Florida, FL (712)**

State of Florida, Department of Education

Office of Student Financial Assistance

Turlington Building

1940 North Monroe Street

Suite 70

Tallahassee, FL 32399-0400

\(850\) 410-5200

**Georgia, GA (713)**

Georgia Higher Education Assistance Corporation

2082 East Exchange Place, Suite 200

Tucker, GA 30084

\(770\) 724-9132

**Hawaii, HI (815)**

SEE United Student Aid Funds, Inc.

**Idaho, ID (716)**

Student Loan Fund of Idaho, Inc.

190 Queen Anne Avenue North

Suite 300

Seattle, WA 98109

\(206\) 461-5300

**Illinois, IL (717)**

Illinois Student Assistance Commission

1755 Lake Cook Road

Deerfield, IL 60015

\(847\) 948-8500

**Indiana, IN (718)**

SEE United Student Aid Funds, Inc.

**Iowa, IA (719)**

Iowa College Student Aid Commission

200 10th Street

Fourth Floor

Des Moines, IA 50309-3609

\(515\) 242-3344

**Kansas, KS (620)**

SEE United Student Aid Funds, Inc.

**Kentucky, KY (721)**

Kentucky Higher Education Assistance Authority

1050 U.S. 127 South

Suite 102

Frankfort, KY 40601-4323

\(502\) 696-7200

**Louisiana, LA (722)**

Louisiana Office of Student Financial Assistance

1885 Wooddale Blvd., Suite 324

Baton Rouge, LA 70821-9202

\(225\) 922-1012, 1 800-259-0790

**Maine, ME (723)**

Maine Education Assistance Division

Finance Authority of Maine

5 Community Drive

Augusta, ME 04332-0949

\(207\) 623-3263

**Maryland, MD (724)**

SEE United Student Aid Funds, Inc.

**Massachusetts, MA (725)**

American Student Assistance

330 Stuart Street, Berkeley Place

Boston, MA 02116-5292

\(800\) 999-9080

**Michigan, MI (726)**

Michigan Higher Education Assistance Authority

Hannah Building

1^st^ Floor

Lansing, MI 48933

\(800\) 642-5626

**Minnesota, MN (727)**

SEE Wisconsin

**Mississippi, MS (728)**

SEE United Student Aid Funds, Inc.

**Missouri, MO (729)**

Coordinating Board for Higher Education

3515 Amazonas Drive

Jefferson City, MO 65109-5717

\(573\) 751-2361

**Montana, MT (730)**

Montana Guaranteed Student Loan Program

2500 Broadway

Helena, MT 59601-4989

\(406\) 444-6594

**Nebraska, NE (731)**

Nebraska Student Loan Program

1300 O Street

Lincoln, NE 68508-1511

\(402\) 475-8686

**Nevada, NV (732)**

SEE United Student Aid Funds, Inc.

**New Hampshire, NH (733)**

New Hampshire Higher Education Assistance Foundation

4 Barrell Court

Concord, NH 03301

\(603\) 225-6612

**New Jersey, NJ (734)**

New Jersey Higher Education Assistance Authority

Guaranteed Student Loan Program

4 Quakerbridge Plaza

P.O. Box 540

Trenton, NJ 08625-0540

\(800\) 792-8670

**New Mexico, NM (735)**

New Mexico Student Loan Guarantee Corporation

3900 Osuna, N.E.

Albuquerque, NM 87109-2230

\(505\) 345-3371

**New York, NY (736)**

New York State Higher Education Services Corporation

99 Washington Avenue, Twin Towers

Albany, NY 12255

\(518\) 473-7087

**North Carolina, NC (737)**

North Carolina State Education Assistance Authority

10 Alexander Drive

Research Triangle Park, NC 27709

\(919\) 549-8614

**North Dakota, ND (738)**

Student Loans of North Dakota

North Dakota Guaranteed Student Loan Program

715 East Broadway

Bismarck, ND 58501-5524

\(701\) 328-5754

**Ohio, OH (739)**

SEE Wisconsin

**Oklahoma, OK (740)**

Oklahoma State Regents for Higher Education

Guaranteed Student Loan Program

421 North West 13^th^ Street

Oklahoma City, OK 73103-3000

\(405\) 234-4300

**Oregon, OR (741)**

SEE Educational Credit Management Corporation

**Pennsylvania, PA (742)**

Pennsylvania Higher Education Assistance Agency

1200 N. 7th Street

Towne House

Harrisburg, PA 17102-1444

\(717\) 720-2860

**Puerto Rico, PR (772)**

SEE Wisconsin

**Rhode Island, RI (744)**

Rhode Island Higher Education Assistance Authority

560 Jefferson Boulevard

Warwick, RI 02886-1320

\(401\) 736-1100

**South Carolina, SC (745)**

South Carolina State Education Assistance Authority

Interstate Center

15 Berry Hill Road

Suite 210

Columbia, SC 29210

\(803\) 798-0916

**South Dakota, SD (746)**

Education Assistance Corporation

115 First Avenue, S.W.

Aberdeen, SD 57401

\(605\) 622-6423

**Tennessee, TN (747)**

Tennessee Student Assistance Corporation

Parkway Towers, Suite 1950

404 James Robertson Parkway

Nashville, TN 37243-0820

\(615\) 741-1346

**Texas, TX (748)**

Texas Guaranteed Student Loan Corporation

Tower of the Hill

13809 N. Highway 183

Suite 100

Austin, TX 78750-1250

\(512\) 219-5700

**United Student Aid Funds, Inc. (USAF) (800)**

United Student Aid Funds, Inc.

10475 Crosspoint Boulevard

Suite 230

Indianapolis, IN 46256-3323

\(317\) 806-1210

**Utah, UT (749)**

Utah Higher Education Assistance Authority

60 South 400 West

5^th^ Floor

Salt Lake City, UT 84101-1284

\(801\) 321-7200

**Vermont, VT (750)**

Vermont Student Assistance Corporation

One Main Street

Winooski, VT 05404-2601

\(802\) 655-9602

**Virgin Islands, VI (778)**

SEE Wisconsin

**Virginia, VA (751)**

SEE Educational Credit Management Corporation

**Washington, WA (753)**

Northwest Education Loan Association

190 Queen Anne Avenue, North

Suite 300

Seattle, WA 98109

\(206\) 461-5300

**West Virginia, WV (654)**

SEE Pennsylvania

**Wisconsin, WI (755)**

Great Lakes Higher Education Corporation

2401 International Lane

Madison, WI 53704

\(608\) 246-1800

**Wyoming, WY (656)**

SEE United Student Aid Funds, Inc.

[^1]: The cohort default rate is defined in Section 435(m) of the HEA.

[^2]: Federal SLS loans have not been issued since July 1, 1994.
    However, it is possible for a Federal SLS loan to be included in a
    recent cohort default rate calculation if the borrower has recently
    entered into repayment on the Federal SLS loan.