Frequently Asked Questions
Does Our Reporting To The Clearinghouse Need To Change Once We
Transition To Direct Lending?
No. In fact, the same reporting schedule guidelines apply before, during, and after you fully transition to Direct Lending.
The Clearinghouse’s weekly reporting to guarantors, lenders, and servicers includes reporting to the Direct Loan servicers through NSLDS.
This reporting satisfies compliance with federal regulation
§685.309(b)(2),
which states that Direct Loan participants notifications need to be sent to the
Secretary.
What Is The Regulatory Reporting Requirement For Enrollment
Information That Is Evaluated During An Audit?
Schools are required to:
- Complete and return Student Status Confirmation Reports (SSCRs) within 30
days of receipt (§682.610(c)(1)). The Clearinghouse will do this for you
once you designate us as your servicer with the Department of Education (ED) and report your enrollment
information according to your Clearinghouse transmission schedule.
- Report students who are no longer enrolled at least half-time directly to
loan holders within 30 days, unless your school plans to submit its next
SSCR within 60 days (§682.610(c)(2)).
The Clearinghouse reports enrollment information automatically to our
participating loan holders for you after you report your enrollment data to us.
Our Auditor Notified Us That Enrollment Was Not Reported To NSLDS Within The
Required 30 And 60 Days, What Do I Do?
-
Review these regulatory
guidelines: §668.22, § 682.605
and §682.610.
Federal regulations state that enrollment reporting compliance is established by reporting to
the Secretary OR directly to the guaranty agency or lender, see §682.610(c)(2).
The Student Status Confirmation Reports (SSCRs) must be returned to the
Secretary or guaranty agency within 30 days of receiving the roster, see §682.610(c)(1).
If you sent us an enrollment update, it will be included in our weekly
transmission to the student loan community fulfilling §682.610(c)(2).
- Review the student’s notification history on the Clearinghouse secure
Web site. Click the "Student-Look Up" tab and select the following options:
Enrollment History
Deferment & Electronic Notification History
NSLDS SSCR Notification History
When a status change is discovered after it has occurred, compliance is
determined based on the date you identify the status change (“date of
determination”). The applicable regulatory references are § 682.605
and § 668.22(b) or (c).
You can provide
your auditor with a more complete enrollment reporting overview by referencing the information on the Clearinghouse secure Web site
and “active and inactive” NSLDS Enrollment Detail screens.
Is Compliance For Retroactive Status Changes Determined By The
Status Change Effective Date Or The Certification Date?
When a status change is discovered after it has occurred, compliance is
determined based on the date you identify the status change ("date of
determination"). The applicable regulatory references are §682.605 and
§668.22(b) or (c).
What Happens With Students Who Do Not Return To School After
The Summer Break?
If a student notifies you that he or she will not return, you should report
the student's last date of at least half-time attendance (probably the end date
of the previous term) to the Clearinghouse as soon as possible. If the student
simply does not `show' for the fall term, the Clearinghouse will determine his
or her last date of attendance based on the last data you reported for the
student. Your first-of-term report should be provided to the Clearinghouse no
later than three weeks after the term has started in order to comply with §682.605(a).
How Does My Clearinghouse Transmission Schedule Correlate With My SSCR
Schedule?
We will work
with the Department of Education (ED) to align your Student Status Confirmation Reports
(SSCRs) creation schedule to
your Clearinghouse transmission schedule, once you establish it. Typically,
ED presets a generic bimonthly SSCR schedule. However, your Clearinghouse
transmission schedule prompts an SSCR reporting schedule that is specific to
your academic calendar
and unique enrollment reporting demographic.
An SSCR is scheduled for the month following a required enrollment transmission,
as listed on your Clearinghouse
transmission schedule. Establishing an accurate transmission schedule and
reporting data to the Clearinghouse as scheduled ensures that your enrollment
data is reported to NSLDS on time via the SSCR process. This fulfills the SSCR
completion requirement in §682.610(c)(1).
Your prompt reporting to the Clearinghouse enables us to
proactively report enrollment to lenders and/or guaranty agencies on your
behalf. If you sent us an enrollment update, it will be included in our weekly
transmission to the student loan community. This establishes
the foundation for the timely servicing of student loans and prevents delinquent
and/or defaulted student loans, see §682.610(c)(2).
Customizing your Clearinghouse transmission schedule to your student demographics,
academic calendar and policies for enrollment management and adhering to the
schedule you create will ensure your compliance
with regulatory guidelines, as specified in
§668.22, § 682.605
and §682.610.
Need Additional Help Answering Auditors' Questions?
