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Split Servicing of Student Loans. A Pending Crisis or – Just a Temporary Pain in the #$% Presenters: William Cheetham – LeMoyne College John View – SUNY– Env. Science & Forestry Anne Del Plato – Nelnet. Agenda. Background on split-loan servicing
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Split Servicing of Student Loans A Pending Crisis or – Just a Temporary Pain in the #$% Presenters: William Cheetham – LeMoyne College John View – SUNY– Env. Science & Forestry Anne Del Plato – Nelnet
Agenda • Background on split-loan servicing • Federally-owned loans and ED servicers • Options available to help students manage split-loan servicing • Taking inventory • Consolidation Option • Communication • Resources
Background on Split-loan Servicing • Split-loan servicing—borrowers with multiple loans serviced by multiple servicers • Split-loan servicing is not a new phenomenon • An increased focus in today’s environment due to: – Lenders exiting FFELP, selling portfolios to secondary markets – FFELP loans that have been purchased by ED – Schools transitioning from FFELP to FDLP
Federally-owned Loans and ED Servicers • ED owns both FDLP loans and FFELP purchased loans – FFELP purchased loans are loans made under FFELP by lenders and subsequently purchased by ED – June 2009, ED awarded servicing contracts to four new servicers – New servicers currently service FFELP purchased loans for ED and will be assigned FDLP loans by August 31, 2010
Federally-owned Loans and ED Servicers • New ED servicers – Fedloan Servicing (PHEAA) – Great Lakes Educational Loan Service,Inc. – Nelnet – Sallie Mae • Existing ED servicers – Department of Education Student Loan Servicing(ACS) – Direct Loan Servicing Center (ACS)
Federally-owned Loans and ED Servicers • Servicer assignment: • The goal is to assign all of a borrower’s federally-owned loans to the same servicer • – This has not automatically occurred for all • borrowers • – ED is working to resolve situations where a • borrower’s federally-owned loans are assigned • to two or more ED servicers • – Over time, assignment of a borrower’s • federally-owned loans to the same servicer will become standard operating procedure
Federally-owned Loans and ED Servicers • Q: How will a school know which ED servicer is servicing a borrower’s FFELP purchased loan? • A: The ED servicer is identified in NSLDS. • Schools can use the new report entitled “Status of Loans Purchased by ED report” (PLPED3)
NSLDS Access and Security Rules of Behavior You are “Agreeing”
Federally-owned Loans and ED Servicers • Q: How long will it take for the ED servicer to report information to NSLDS on the transfer of a FFELP purchased loan? • A: ED servicers report to NSLDS weekly. Newservicer info is available within 7 to 10 business days after the transfer has been completed. • Contact the Federal Student Aid Research and Customer Care Center at (800) 433-7327 or fsa.customer.support@ed.gov for assistance
Split Servicing: Former FFELP Schools * Most, but not all loans entered the PUT program during these years. ** ED plans to move these borrowers to one servicer.
Split Servicing – Direct Loan Schools • All loans are federally-owned. • Small percentage are split. • ED plans to move all borrowers to one servicer. • Most of this movement to occur by early Winter 2011
Split Servicing and Repayment • If more than one servicer, borrower will make payments to all. • Will increase minimum payments in most cases. • If deferment or forbearance needed, borrower will need to contact all.
Taking Inventory • Q: Where can borrowers obtain information about their federal student loan(s)? • A: National Student Loan Data System (NSLDS) at www.nslds.ed.gov • Provides loan amount(s) and loan holder(s)
Taking Inventory • Q: What happens to a borrower’s loan(s) when he or she leaves school? • A: A Perkins loan either: • Enters a 9-month grace period • Enters a 6-month post-deferment grace period • A: A Stafford loan either: • Enters a 6-month grace period • Enters repayment
Taking Inventory • Q: What happens to a borrower’s loan(s) when (s)he leaves school? • A: A Grad PLUS loan either: • Enters a 6-month deferment • Enters repayment • A: A parent PLUS loan either: • Enters a 6-month deferment, if requested • Enters repayment
Taking Inventory • Q: What happens to a borrower’s loan(s) when he or she leaves school? A: A federal consolidation loan: • Enter repayment A: For non-Title IV loans: • Enter repayment based on the terms and conditions of loan
Taking Inventory • Q: What should a borrower expect from his or her loan holder(s)? A: Repayment disclosure notice(s) • Outlines the terms of the loan(s) borrowed • Provides the repayment options available • Establishes the first payment due date
Taking Inventory • Q: What does the loan holder expect ofthe borrower? A: The loan holder expects the borrower to: • Select a repayment plan • Make timely payments on the loan(s) • Provide updated contact information whenever it changes • Contact the loan holder whenever he or she is having difficulty managing repayment
Taking Inventory • Q: What should a borrower expect when a FFELP loan has been purchased by ED? A: The borrower will receive correspondencefrom the ED servicer that contains the pertinent contact information. • The borrower will be responsible for managing repayment with the ED servicer
Taking Inventory • Q: For those borrowers with FFELP purchased loans serviced by ACS, how will a borrower know when his or her loan(s) have been transferred to one of the new ED servicers? A: ED is in the process of transferring FFELP purchased loans currently serviced by ACS to new ED Servicers
Taking Inventory • Q: Is it possible for the borrower to have combined billing for both FFELP purchased loans and regular FFELP loans that are with the same servicer? A: Combined billing is not possible in this instance. Because federal law requires federally-owned loans to be processed through a federal payment lockbox, and prohibits the processing of payments on loans that are not federally-owned through this lockbox, borrowers are required to make separate payments.
Consolidation • Enables borrower to combine one or more federal student loans into a single new loan with one holder (and consequently, a single servicer) • At the time of consolidation, lender or ED pays off outstanding balances of loans included in the consolidation
Consolidation • Q: Who can consolidate? Is there a fee? A: Any federal student loan borrower, including: • Borrowers with student loans • Borrowers with parent loans • Borrowers with student and parent loans There is no fee to obtain a Consolidation loan
Consolidation • Types that may be consolidated include: • Federal Family Education Loans • Federal Direct Loans • Federal Perkins Loans • Health Professions Student Loans • Nursing Student Loans • Health Education Assistance Loans
Consolidation • Q: What is the general eligibility criteria? • A: A borrower: • Must be in grace period or in repayment – No grace for a Grad PLUS loan; borrower can consolidate while in school because loan is in repayment – Repayment includes deferment periods May be delinquent or in default on one or more existing loans
Consolidation • Factors to consider: • Brings together loans with multiple lenders for convenience of one payment • May lower loan payments by lengthening repayment period • May be able to lock in a more favorable interest rate (for loans with a variable interest rate, if those rates are low during the year the borrower consolidates)
Consolidation • Factors to consider: • May lose some or all of grace period • May lose certain borrower benefits • Perkins loans lose: – Deferment subsidy when consolidated – Cancellation eligibility when consolidated
Consolidation • Factors to consider: • Certain deferments may be lost, but these older deferments are not used frequently • Borrowers retain ability to request most major deferments after consolidation – In-school – Unemployment – Economic hardship
Consolidation • Factors to consider: • May increase total cost of loan – If borrower lengthens repayment period, will pay more interest over life of the loan
Temporary Loan Consolidation Authority • New, temporary loan consolidation authority created by the Health Care and Education Reconciliation Act of 2010 – The main purpose of this temporary authority is to allow borrowers who may have lender-held FFELP, Direct, and FFELP purchased loans to combine them into a single loan • For Consolidation loan applications received by ED on or after July 1, 2010, and before July 1, 2011
Temporary Loan Consolidation Authority • Eligibility: Borrower must have loans in at least two of the following categories – Federal Direct loan, – FFELP loan held by a lender --FFELP purchased loan • Borrower must have at least one eligible loan in the above categories that has not yet entered repayment (this includes loans in a grace period
Temporary Loan Consolidation Authority • Terms and conditions: Direct Consolidation loan made under this authority has the same terms and conditions that apply to regular Consolidation loans, except – The weighted average interest rate applied to a Consolidation loan made under this provision will not be rounded up to the nearest 1/8th of one percent – However, if the Consolidation loan includes one or more variable rate Stafford loans made July 1, 1994 June 30, 2006, the weighted average is rounded up to the nearest 1/8th of one percent
Temporary Loan Consolidation Authority • Benefits: • A borrower can obtain a single loan with a single holder before repayment begins • • The weighted average interest rate is not rounded up to the nearest 1/8th percent unless a variable rate Stafford loan made July 1,1994 – June 30, 2006 is included in the Consolidation loan.
Temporary Loan Consolidation Authority • Considerations: • A Stafford loan borrower will lose the sixmonth grace period if he or she consolidates while in school • Parent and Grad PLUS borrowers will lose the six-month post-enrollment deferment benefit if they consolidate while in school • A borrower who consolidates while in school has not received exit counseling, therefore may not have enough information to make an informed decision
Temporary Loan Consolidation Authority • • The regular consolidation loan program may continue to be used—it has not gone away. – However, all of the loans that are being consolidated must have entered repayment prior to consolidation
Communication • Strategically communicate with borrowers today to help set the right expectation • Encourage borrowers to open and read loan holder correspondence • Focus on the importance of NSLDS outside the realm of student loan counseling
Communication • Offer supplemental counseling above and beyond traditional entrance and exit sessions • Provide comprehensive information on consolidation • – May be the right option on an individualized basis to help students manage repayment – Encourage students to make larger payments on the consolidation loan • As a reminder, extending the repayment term will likely increase the overall cost of the loan
Resources for Borrowers • www.federalstudentaid.ed.gov • www.nslds.ed.gov • ED’s Federal Student Aid Information Center at 1-800-4-FED-AID or (800) 433-3243
Resources for Schools • www.ifap.ed.gov – ED electronic announcements on IFAP related to Loan Servicing Information dated: • 08/28/2009, 09/16/2009, 03/26/2010 www.fsaconferences.ed.gov/pastconferences.html • 2009 Federal Student Aid Conference presentations entitled: • Direct Loan Servicing, Additional Loan Servicers, and NSLDS Update