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Monday, May 18, 2015

The Can’s and Can’ts of Loan Counseling Guidance

Submitted by: Shannon Cross, USA Funds Account Executive

The U.S. Department of Education recently issued Dear Colleague Letter GEN-15-06 about loan counseling requirements and flexibilities. What does the letter explain that you can do — and can’t do?

You can …
·         Require first-year, first-time borrowers to complete entrance counseling via studentloans.gov, or through your own means, provided you include all required information, at a minimum.

You can’t …
·         Require subsequent counseling as a condition of receiving a subsequent Direct Loan disbursement.

You can …
·         Provide additional information as part of the required entrance counseling process. You need to be reasonable regarding the amount and scope of the information.

You can’t …
·         Require students to use the Department’s Financial Awareness Counseling Tool (FACT).
·         Impede a student’s access to Direct Loan funds through overly burdensome additional counseling requirements.

You can …
·         Require that the student complete a test regarding the material presented during the required entrance loan counseling. You also may provide feedback on any incorrect responses.

You can’t …
·         Require a passing score on the test as a condition of receiving a Direct Loan disbursement.

You can …
·         Require students to complete worksheets or exercises — such as those focusing on budgets or estimated earnings — as part of the entrance counseling process.

You can’t …
·         Require the student to justify the need for a loan.

You can …
·         Require students to attend workshops or loan orientation presentations.

You can’t …
·         Prevent the student from receiving loan funds in a timely manner.

You can …
·         Encourage returning or transfer students to review loan balances and loan counseling information.

You can’t …
·         Require subsequent counseling for a student who already received the required entrance counseling, even at another institution. You must assume the student completed entrance counseling if the student received a Direct Loan from another school.

You can …
·         Offer financial literacy courses, either for credit or non-credit.

You can’t …
·         Require the completion of such courses as a condition for receiving a Direct Loan disbursement.

You can …
·         Require students on financial aid warning or financial aid probation (for satisfactory academic progress) to meet certain academic requirements to continue to receive Title IV aid.

You can’t …
·         Require students on financial aid warning or financial aid probation (for satisfactory academic progress) to complete additional loan counseling beyond the requirements for first-time borrowers as a condition for receiving a Direct Loan disbursement.

You can …
·         Incorporate in your default prevention plans voluntary provisions for additional counseling beyond the required entrance counseling for first-year, first-time borrowers.

You can’t …
·         State or imply that this supplemental counseling is required as a condition for a student to receive a loan.

You can …
·         Customize for certain groups of students the initial entrance counseling requirements to include the information or activities allowed by the flexibilities in GEN-15-06.

You can’t …
·         Require subsequent counseling for certain groups of students, just as you cannot require subsequent counseling as a general practice for all students.

For additional resources on loan counseling and successful student loan repayment, visit www.usafunds.org.






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