Transitioning to a 3-Year Cohort Default Rate Cindy Marrs, TG Default Aversion Consultant

1. Transitioning to a 3-Year Cohort Default RateCindy Marrs, TG Default Aversion Consultant Ohio Association Of Student Financial Aid Administrators Ohio College Access Network 2010 Winter Conference “Building Bridges”

2. Topics to be Covered • Cohort Default Rate (CDR) – What is it? • CDR calculation • Notification timelines • Potential benefits and sanctions • Challenges and appeals • Default prevention initiatives

3. National Student Loan Cohort Default Rates Source: Department of Education

4. Comparison of CDRs by sector type Source: Department of Education

5. Comparison of CDRs by loan program Source: Department of Education

6. What is a Cohort Default Rate (CDR)? • A “cohort” is a group of Stafford loan borrowers who entered repayment within a given federal fiscal year (FY). • A “CDR” is the percentage of those students in a school’s cohort who defaulted within a specified period of time: • 2-year CDR: by the end of the next fiscal year • 3-year CDR: within the next two fiscal years

7. CDR Window Illustration Stafford borrowers who enter repayment and default between 10/1/10 and 9/30/12 FY11 2-year CDR = Stafford borrowers who enter repayment between 10/1/10 and 9/30/11 Stafford borrowers who enter repayment and default between 10/1/10 and9/30/13 FY11 3-year CDR = Stafford borrowers who enter repayment between 10/1/10 and 9/30/11

8. CDR: Why Does it Matter? • Schools: • May result in provisional certification or loss of Title IV eligibility • Negative publicity • Additional time and resources to work to manage and reverse high rates • Borrowers: • Damaged credit • Loss of Title IV eligibility • Wage garnishment, court costs, collection costs, treasury offset, loss of professional license, difficulty accessing other forms of credit

9. Trial 3-year CDRs • ED published unofficial, trial 3-year CDRs on December 14, 2009 • Trial information available from the FSA Data center • http://federalstudentaid.ed.gov/datacenter/cohort.html • Data consists of trial rates for FY05, 06, and 07 • ED has indicated they will provide updated trial rates this winter

10. When/How is a School Notified of its CDR? • Draft rates are released to schools in February of each year (non-public information) • Information is sent to schools via e-mail along with the Loan Record Detail Report (LRDR) • LRDR gives detail of each borrower included in the default rate: • Date Entered Repayment • Date of Default (if applicable) • Official rates are published in September of each year(public information)

11. Transition Process • For FY 2008, only a 2-year rate was published • There will be two CDRs published each year for FY 2009, 2010, and 2011 • Draft and official rates will be released for a 2-year calculation, and also for a 3-year calculation • After FY 2011, 2-year rates will no longer be calculated

12. Transition from 2-year to 3-year Rates

13. Transition from 2-year to 3-year Rates

14. Transition from 2-year to 3-year Rates

15. Benefits of Low CDRs • Effective for Direct loans first disbursed on or after 10/1/2011, if a school’s three most recently published 2-year or 3-year CDRs are less than 15 percent: • Loans may be disbursed in one installment in some cases • No 30-day delayed disbursement requirement for first-year, first-time borrowers • The first CDRs on which these could be based are FY 2007, 2008, and 2009 two-year CDRs • Currently this benefit is available for CDRs less than 10 percent

16. Benefits of Low CDRs • If a school’s most recent 2-year or 3-year CDR is less than 5 percent, for students in study-abroad programs: • No required 30-day delay of first disbursement for first-time, first-year undergraduate borrowers • May deliver loan funds in a single disbursement, regardless of the length of the student’s loan period • Benefit is currently available; no change to current policy

17. Consequences of High CDRs • Effective 2012 (with publication of FY 2009 3-year rate), if a school’s 3-year CDR is equal to or greater than 30 percent: • 1st year: School must establish default prevention task force and prepare a plan to submit to the Department • 2nd year: Task force must review and revise plan and submit to the Department • 3rd year: School subject to sanctions (provisional certification or loss of eligibility)

18. Consequences of High CDRs • Default prevention task force • Identify the factors causing the institution’s cohort default rate to exceed the threshold; • Establish measurable objectives and identify steps to take to improve the institution’s rate; and • Specify actions the institution will take to improve student loan repayment, including loan repayment counseling.

19. Provisional Certification • Provisional certification may result when ED determines that “the school has impaired administrative capability.” (Cohort Default Rate Guide, page 4.5 – 13) • School may be subject to additional conditions in its Program Participation Agreement during provisional certification.

20. Provisional Certification • During transition period • Single 2-year CDR of 25 percent or greater • Effective when the third 3-year rate is published in September 2014 • Two 3-year CDRs of 30 percent or greater in last three years

21. Loss of Eligibility • During transition period, without a successful adjustment or appeal: • If school’s most recent 2-year CDR is greater than 40 percent, the school will lose eligibility to participate in the Direct Loan program. • If school’s three most recent 2-year CDRs equal or exceed 25 percent, the school will lose eligibility to participate in the Direct Loan and Pell Grant programs.

22. Loss of Eligibility • Beginning in September 2014, without a successful adjustment or appeal: • If school’s most recent 3-year CDR is greater than 40 percent, the school will lose eligibility to participate in the Direct Loan program (no change) • If school’s three most recent 3-year CDRs equal or exceed 30 percent, the school will lose eligibility to participate in the Direct Loan and Pell Grant programs.

23. Can a School Challenge its Draft CDR? • Draft CDR challenges: • Incorrect data challenge • Participation rate index challenge • Challenges must be submitted within 45 days of the date the school receives its draft CDR in mid-February.

24. Incorrect Data Challenges Of the borrowers who defaulted, 91% did not receive their full 6-month grace period due to late or inaccurate enrollment notification by the school. Source: ED's August 2008 Analysis of Federal Direct Loan Portfolio

25. Can a School Adjust its Official CDR? • Adjustments—official CDR: • Uncorrected data adjustment: must be submitted to the Department or data manager within 30 days of the date the school receives its official CDR in mid-September. • New data adjustment: School must initiate request for new data adjustment within 15 days of the date the school receives its official CDR in mid-September

26. Can a School Appeal its Official CDR? • Official CDR Appeals: • Erroneous data appeal • Loan servicing appeal • Economically disadvantaged appeal • Participation rate index appeal • Average rates appeal • Thirty or fewer borrowers appeal • Appeals are submitted to the Department for review

27. Challenges and appeals

28. Default Prevention Initiatives • School CDR management initiatives • “Split-loan servicing” considerations • Industry default prevention initiatives

29. Default Prevention Initiatives • Within DL, of the borrowers who defaulted, 70% withdrew without completing their academic program. Source: ED's August 2008 Analysis of Federal Direct Loan Portfolio

30. School CDR Management Initiatives • Renew focus on retention efforts • Enhance counseling sessions • Provide financial literacy workshops • Increase contact with delinquent borrowers • Hire private default prevention servicers to work cohort borrowers • Partner with guarantors to use online cohort management systems

31. Split Loan Servicing Considerations • NSLDS will play a critical role in helping borrowers and schools manage 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 and selling federal portfolios • FFELP loans that have been purchased by ED • FFELP to FDLP transition

32. Split Loan Servicing Considerations • Some borrowers in the FY 2009 and subsequent cohorts will have loans “Put” (sold) to the Department • Date of default=361st day of delinquency • Still FFELP loans, but guarantors do not have loan detail information for Put loans

33. Split Loan Servicing Considerations • NSLDS is where borrowers can obtain information about their federal student loan(s) • Provides loan amount(s) and loan holder(s) • www.nslds.ed.gov • Remind them during exit counseling!

34. Split Loan Servicing Considerations • NSLDS can also help schools: • Locate a borrower’s loan servicer • Obtain important reports pertaining to delinquency and Put loans • A school should refer to NSLDS Newsletters #25, #27, and #28 as those letters cover: • Delinquency reports available for Put and Direct loans • Delinquent Borrowers Page, Delinquent Borrower Report

35. Industry Default Prevention Initiatives • Strategic call campaigns • Drop-out vs. graduate strategies • Unemployment deferment focus

36. Industry Default Prevention Initiatives • Early withdrawal counseling • Calls during grace period • Early-stage delinquency program • Late-stage delinquency team

37. CDR Resources • ED's Default Prevention and Management page • http://ifap.ed.gov/DefaultManagement/ DefaultManagement.html • TG's Default Prevention Resources page • www.tgslc.org/default/resources.cfm • TG's Managing Your Cohort Default Rate webinar • www.tgslc.org/training/ webinars