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PresentersWilliam BlotChief Financial OfficeFederal Student AidU.S. Department of EducationMargaret AyanianBusiness OperationsFederal Student AidU.S. Department of EducationPatricia Trubia Program ComplianceFederal Student AidU.S. Department of Education. Introduction. Target Audie
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1. FFEL Loan PurchaseParticipation Program Operational Closeout Webinar
June 3, 2009
2.
Presenters
William Blot
Chief Financial Office
Federal Student Aid
U.S. Department of Education
Margaret Ayanian
Business Operations
Federal Student Aid
U.S. Department of Education
Patricia Trubia
Program Compliance
Federal Student Aid
U.S. Department of Education
3. Introduction Target Audience:
Personnel at FFEL lenders, guaranty agencies, and custodians who administer the Department’s 2008-2009 Loan Purchase programs.
4. Introduction (Cont.) Webinar Objectives:
Review program termination procedures and related cut-off dates defined in the Master Participation Agreement (MPA) and the Master Loan Sale Agreement (MLSA).
Review timeline for final sales (puts).
5. Agenda Deadline to execute MPA
Deadline for current MPA holders to execute MLSA
Cut-off to sell Participation Interests (PI)
Notification Requirement
Final Puts
Loan Eligibility
Timeline
Guidelines
Final Redemptions
Termination
Post-termination compliance AUPs/audits
Questions
6. Deadline to Execute Legal Agreements MPA
The Department will not execute an Adoption Agreement to enter into a Participation Agreement with any sponsor after July 1, 2009.
To execute this agreement, it is prudent to submit the MPA package as soon as possible, but no later than 7 business days in advance of the cut-off (i.e., June 22, 2009), in case the Department requires additional information or changes to submitted documents.
7. Deadline for Agreements (Cont.) MLSA
In order to exercise the put option, the sponsor (together with its Eligible Lender Trustee, if applicable) must have an executed MLSA on or before July 1, 2009.
To execute this agreement, it is prudent to submit the MLSA package as soon as possible, but no later than 7 business days in advance of the cut-off (i.e., June 22, 2009), in case the Department requires additional information or changes to submitted documents.
The deadline to execute an MLSA has already lapsed for lenders not in an MPA.
8. General Cut-off Date to Sell PI Sponsors without an MLSA may only sell participation interests through the date of termination (i.e., July 1, 2009).
Sponsor s with an MLSA must generally exercise the option to sell participation interests (i.e., to submit funding requests) by August 1, 2009.
Participation Interests sold (i.e., participation funding requests paid) follow the standard funding request process as defined in EA#53.
9. Exceptions to General Cut-off Date Sponsors may sell participation interests after August 1, 2009 only if the loans meet the following conditions, as defined in Section 1 of the MPA:
1st disbursement on the loan was made by 7/1/09.
1st disbursement was participated by 8/1/09.
the final disbursement will occur no later than 9/30/09.
this final disbursement is participated no later than 30 days after the date of final disbursement, but no later than 9/30/09.
the loan must be put to the Department and the sponsor must notify the Department of an intent to sell [put] this loan.
10. Notification to Closeout Participation All sponsors shall notify the Department as soon as possible with respect to their plans through the Loan.Participation@ed.gov mailbox to indicate whether they will sell their loans and/or redeem their participation interests, when they will do so, and in what amounts.
Sponsors must provide notification no later than August 14, 2009
11. Email Notification Template (draft)