Campus Partners Update Newsletter
November 1, 2008
Holiday Closing: Thanksgiving, Nov. 27-28, Christmas, Dec. 24-25, New Year's Day, Jan. 1
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Inside Campus Partners Vice President, Loan Operations |
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FTC Red Flag Rules
There has been much news and discussion regarding the FTC’s “Red Flag” rules to assist in the prevention of identity theft. Campus Partners has been working with our legal counsel to implement a plan in compliance with these rules. Schools for which we provide loan servicing should include a copy of our guidelines with their own institutional procedures.
We have included an outline of our guidelines in the attachment below.
Attachment:Campus Partners’ Identity Prevention Program – Red Flag Guidelines
The Financial Institution Regulators, including the Federal Trade Commission (FTC), published final rules on November 9, 2007 (the “Red Flag Rule”) under sections 114 and 315 of the Fair and Accurate Credit Transactions Act (FACTA), which amended the Fair Credit Reporting Act (FCRA). The Red Flag Rule requires “financial institutions” and “creditors” that hold “covered accounts” to develop and implement an identity theft prevention program for new and existing accounts. The Rule had a mandatory compliance date of November 1, 2008.
The FTC posted an announcement to their web site on October 22, 2008, indicating that the FTC will extend the November 1, 2008 deadline to May 1, 2009 to give creditors and financial institutions additional time to develop and implement their programs.
The biggest question was whether schools were required to comply with the Red Flag Rules. ED published an electronic announcement on October 14, 2008 informing schools that the Red Flag Rules “apply to institutions participating in the Federal Perkins program and may apply to other credit programs administered by an institution.” To read the full text of this electronic announcement, go to: http://www.ifap.ed.gov/eannouncements/1014FTCRedFlagRules.html.
You may also access the actual text of the regulations on the FTC web site at: www.ftc.gov/opa/2007/10/redflag.shtm.
Guidance from ED on Verbal Requests for Forbearance
Campus Partners contacted the Department of Education to question the new rules that became effective August 14, 2008 regarding forbearance. The Higher Education Opportunity Act (HEAO) revised Section 464(e) of the HEA to read as follows:
(e) Forbearance — (1) The Secretary shall ensure that, as documented in
accordance with paragraph (2), an institution of higher education shall grant a borrower forbearance of principal and interest or principal only, renewable at 12- month intervals for a period not-to-exceed 3 years, on such terms as are otherwise consistent with the regulations issued by the Secretary and agreed upon in writing by the parties to the loan, if —
(A) the borrower’s debt burden equals or exceeds 20 percent of such borrower’s gross income;
(B) the institution determines that the borrower should qualify for forbearance for other reasons; or
(C) the borrower is eligible for interest payments to be made on such loan for service in the Armed Forces under section 2174 of title 10, U.S.C., and pursuant to that eligibility, the interest on such loan is being paid under subsection (j), except that the form of a forbearance under this paragraph shall be a temporary cessation of all payments on the loan other than payments of interest on the loan that are made under subsection (j).
(2) For the purpose of paragraph (1), the terms of forbearance agreed to by the parties shall be documented by—
(A) confirming the agreement of the borrower by notice to the borrower from the institution of higher education; and
(B) recording the terms in the borrower’s file.
We asked if schools still needed to obtain documentation from the borrower and ED responded, yes. Brian Smith at ED provided the following guidance:
Schools are still required to obtain supporting documentation for forbearances. The HEOA only eliminates the requirement that the forbearance request be in writing, and requires schools to confirm the forbearance agreement with the borrower and record the terms of the forbearance in the borrower’s file. The new language does not change the requirement that the forbearance be granted “on such terms as are otherwise consistent with the regulations issued by the Secretary.” The current regulations continue to require that a forbearance be granted “Upon receipt of. . . supporting documentation” [674.33(d)(2)].
Accepting a Forbearance Processed on Other Loan Types
We have also received questions from our customers regarding whether the school could grant a forbearance based on a forbearance processed on another loan type. This was discussed in the Preamble of the November 1, 2007 Federal Register:
We disagree with the recommendation that schools participating in the Perkins Loan Program be allowed to grant forbearances based on forbearances granted on the borrower’s FFEL Program loans. The mandatory forbearance requirements in the FFEL Program differ from the forbearance requirements in the Perkins Loan Program. Additionally, given that Perkins schools have wide flexibility in granting forbearances in the Perkins Loan Program, the Department sees no value in allowing schools to base Perkins forbearances on forbearances granted in the FFEL Program [Federal Register, November 1, 2007, p. 61962].
Supplemental Campus-Based Awards
ED has published Dear Colleague Letter CB-08-11, which provides information about supplemental campus-based awards for the 2008-09 Award Year. Later this month, the Department will distribute the supplemental campus-based awards for the 2008-09 award year to schools that meet the required conditions for receipt of such funds. Because no new Perkins Loan funds were appropriated for the 2007-08 Award Year, no Perkins Loan funds are available for award. The questions and answers included in this DCL explain how the 2008-09 supplemental award funds for each campus-based program were distributed and how schools will be notified of the supplemental awards.
Updated List of TEACH Grant Eligible Institutions
ED has published an updated listing of the institutions that have been approved as “TEACH Grant Eligible Institutions” for the 2008-09 award year. The Department will continue to update the listing as more institutions are approved. The updated listing is included as an attachment with this electronic announcement. Go to: http://www.ifap.ed.gov/eannouncements/093008TEACHGrant.html.
New NSLDS Security Enhancements
ED has published Newsletter 20, announcing new NSLDS Security Enhancements, such as SSN masking and tools to assist Primary Destination Point Administrators (PDPAs) in researching potential security violations at their organizations. To read the entire newsletter, go to: http://www.ifap.ed.gov/nsldsmaterials/1010Newsletter20.html.
Campus Partners is Going Green
Campus Partners is among the growing number of companies, institutions, and individuals that are going green to save natural resources. Our company stopped sending paper reports and newsletters in 2003, and increasingly uses Web conferences to supplement traditional training offerings, thus reducing our carbon footprint.
In recent months, we have provided customers with the opportunity to access documents such as deferment, cancellation, and forbearance forms via System 3i, our interactive Web site for student loan administrators. As the result of availability of imaged documents, we will discontinue sending processed work to customers effective December 1, 2008. Details of our plan follow. A Question and Answer Guide is also attached.
- Effective December 1, 2008, Campus Partners will stop sending processed work to customers.
- This includes processed deferment and cancellation forms. Imaged copies of these processed forms are available via System 3i.
- We will also stop sending the following documents to customers:
- Copy of Acceleration Notices (A special Acceleration Notice Report will be provided through eXpressReports each month)
- Grace Statements returned for Bad Address
- We will continue to send Returned Check Advices and Manual Debit/Credit Bank Account Adjustments to customers.
- Sharon Cameron, Audit and Compliance Specialist for Campus Partners, has reviewed Federal Regulations and has determined that imaged documents that can be reproduced are suitable substitutes for the original documents.
- We have made it easy for customers to access documents via System 3i. Please see the attached Question and Answer Guide for more information.
Attachment: Going Green Question and Answer Guide
Please see “How to Retrieve Imaged Documents on System 3i” by clicking here.
If you any have questions, please contact your Customer Service Representative.
Credit Bureau and Bankruptcy Reporting
We have made important changes to System III and to the credit bureau file to assist us in reporting information to all credit bureaus in Metro 2 format. To better comply with reporting requirements, we have introduced the Credit Bureau Reporting Screen (CRBR). “The Credit Bureau Reporting Screen Mini-Guide” is available as an attachment to this month’s Update.
Bankruptcy reporting is an essential part of accurate credit bureau reporting. Please read this important information to ensure that all fields related to bankruptcy are up-to-date if you process your own work. It is important to enter information in both Consumer Information Indicator fields. The Section One (pages 1-3) of the “Mini-Guide” provide information about these fields and the values that need to be entered.
If you have any questions about these new procedures, our Customer Service Representatives will be glad to assist you with this process in any way possible.
Attachment:Credit Bureau Reporting Screen Mini-Guide
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What’s one of Campus Partners’ best kept secrets? Institutional Loan Servicing! You may not be aware of this, but Campus Partners can handle virtually any requirements for privately funded loan programs. Our flexible servicing system allows us to service thousands of institutional loan programs for our customers with ease. Several of our customers have more than 200 institutional loan programs, all with complex servicing requirements. We would love to add your institution loan program—large or small—to our system. Benefits of Campus Partners institutional loan servicing include:
If you are interested, please contact Debra Pitts at dpitts@campuspartners.com or at 1-800-458-4492, ext. 2272. |
Campus Partners will observe the following holidays in 2009.
New Year’s Day |
Thursday, January 1 |
Martin Luther King, Jr. Birthday |
Monday, January 19 |
President’s Day |
Monday, February 16 |
Memorial Day |
Monday, May 25 |
Independence Day (observed) |
Friday, July 3 |
Labor Day |
Monday, September 7 |
Thanksgiving |
Thursday, November 26 & Friday, November 27 |
Christmas |
Thursday, December 24 & Friday, December 25 |
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"Campus Partners always amazes me. I have yet to find a challenge they have not met." Sandie Rosko |
This month we are profiling Jeff Gruwell, Vice President, Loan Operations. Jeff has extensive experience in working with student loans and oversees campus-based and private loan operations. To learn more about Jeff, check out this month’s “Inside Campus Partners.”
Student Loans 101 Workshops Schedule
Our final Student Loans 101 of the year is scheduled for November 13-14, 2008 at our office in Winston-Salem, North Carolina. Our newly expanded training room now seats more people so register now and bring a group for this superlative training. Times for the workshop are listed below to help you in making travel arrangements.
Time: 1st day: 8:30 AM- 4:00 PM 2nd day: 8:30 AM - 12:30 PM
To register, fax a completed registration form to Debra Pitts at 336-607-2025.
Attachment: Registration Form for 2008
Study Hall is in Session!
Our Study Hall schedule appears below. Be sure to join us on December 11 for our next Web conference, entitled All about Collections.
To register for this event, please contact Debra Pitts at dpitts@campuspartners.com. A schedule for 2009 wll be published soon.
Study Hall Schedule
| Topic | Date |
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All About Collections |
Thursday, December 11 2:00 to 3:30 Eastern |
We will publish a list of conferences we will attend in 2009 soon.
Cutoff dates for October, November, December, and January are presented below:
Transaction
|
Oct. 2008 |
Nov. 2008 |
Dec. 2008 |
Jan. 2009 |
|---|---|---|---|---|
Last day to receive collection payments |
10/28 |
11/21 |
12/26 |
1/27 |
Last day to receive regular payments |
10/29 |
11/24 |
12/29 |
1/28 |
Last day for online payments |
10/31 |
11/26 |
1/2 |
1/30 |
Date final post begins |
10/31 |
11/28 |
1/2 |
1/30 |
Report date used for final post |
10/31 |
11/30 |
12/31 |
1/31 |
Last day deposits created for deposit to bank account |
10/31 |
11/26 |
12/31 |
1/30 |
2009 Cutoff Dates
Month |
Last day to receive collection payments |
Last day to receive regular payments |
Last day for on-line payments |
Date final post begins |
Report date used for final post |
Last day deposits created for deposit to bank account |
December 2008 |
12/26/2008 |
12/29/2008 |
1/2/2009 |
1/2/2009 |
12/31/2008 |
12/31/2008 |
January 2009 |
01/27/2009 |
01/28/2009 |
01/30/2009 |
01/30/2009 |
01/31/2009 |
01/30/2009 |
February 2009 |
02/24/2009 |
02/25/2009 |
02/27/2009 |
02/27/2009 |
02/28/2009 |
02/27/2009 |
March 2009 |
03/24/2009 |
03/25/2009 |
03/27/2009 |
03/27/2009 |
03/31/2009 |
03/27/2009 |
April 2009 |
04/27/2009 |
04/28/2009 |
05/01/2009 |
05/01/2009 |
04/30/2009 |
04/30/2009 |
May 2009 |
05/26/2009 |
05/27/2009 |
05/29/2009 |
05/29/2009 |
05/31/2009 |
05/29/2009 |
June 2009 |
06/23/2009 |
06/24/2009 |
06/26/2009 |
06/26/2009 |
06/30/2009 |
06/26/2009 |
July 2009 |
07/28/2009 |
07/29/2009 |
07/31/2009 |
07/31/2009 |
07/31/2009 |
07/31/2009 |
August 2009 |
08/25/2009 |
08/26/2009 |
08/28/2009 |
08/28/2009 |
08/31/2009 |
08/28/2009 |
September 2009 |
09/25/2009 |
09/28/2009 |
10/2/2009 |
10/2/2009 |
09/30/2009 |
09/30/2009 |
October 2009 |
10/27/2009 |
10/28/2009 |
10/30/2009 |
10/30/2009 |
10/31/2009 |
10/30/2009 |
November 2009 |
11/20/2009 |
11/23/2009 |
11/25/2009 |
11/27/2009 |
11/30/2009 |
11/25/2009 |
December 2009 |
12/28/2009 |
12/29/2009 |
12/31/2009 |
12/31/2009 |
12/31/2009 |
12/31/2009 |
January 2010 |
01/26/2010 |
01/27/2010 |
01/29/2009 |
01/29/2009 |
01/31/2009 |
01/29/2009 |
