description: tags: ga section

8/14/2019 description: tags: ga section

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FY 1998 Draft Cohort Default Rate Guide Page 121

Information for

Guaranty Agencieson Challenges

What role does a guaranty agency have in aschools participation rate index challenge?

Guaranty agencies are NOT involved in a school's participation rateindex challenge. Schools should submit all participation rate indexchallenges directly to the U.S. Department of Education(Department).

If a guaranty agency receives a participation rate index challengefrom a school, it should immediately contact the school to informthe school that the participation rate index challenge must be sentto the Department at the address shown on page 116 of theParticipation Rate Index Challenge section, and that the challengemust be sent to the Department within 30 calendar days of theschools receipt of its most recent hardcopy draft cohort default ratedata. The guaranty agency should also notify the DepartmentsDefault Management Division that it has contacted the school.

GENERAL INFORMATION


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General Information Information for Guaranty Agencies on Challenges

Page 122 FY 1998 Draft Cohort Default Rate Guide

What role does a guaranty agency have in aschools draft data challenge?

A school may write to a guaranty agency to obtain information tochallenge the schools draft cohort default rate data. A guarantyagency is required to respond to a school's timely submittedchallenge regarding Federal Family Education Loan (FFEL)Program loans for which the agency currently maintains theguaranty. 1 The guaranty agency must provide a copy of itsresponse to the challenge to both the school and the Departmentwithin 30 calendar days of receipt of the schools timely submitteddraft data challenge.

In preparing responses to challenges, guaranty agencies shouldrefer to the Responding to Draft Data Challenges sectionbeginning on page 128.

Once the guaranty agency responds to a schoolstimely submitted draft data challenge, the guarantyagency is not required to respond to subsequentchallenges submitted by the school if the 45 calendarday time frame to submit such challenges hasexpired.

What actions should a guaranty agency takewhen responding to a school's draft data

challenge?The Department recommends that when responding to a schoolschallenge, a guaranty agency should:

thoroughly review this Guide. This will ensure thatthe guaranty agency is aware of all the guidance andrequirements associated with the draft data challengeprocess.

send all correspondence to schools return receiptrequested or via commercial overnightmail/courier delivery. This will be useful to aguaranty agency and the Department in determiningwhether or not a school received the response.

1 34 CFR Section 682.401(b)(15)

QQQQ .... Who is responsiblefor responding to draftdata challenges on loanscurrently maintained bythe Department?

AAAA .... TheDepartments DefaultManagement Divisionwill respond to a schoolsallegations regardingFFEL Program loanscurrently held by theDepartment .

The Departments DirectLoan servicer willrespond to a schoolsallegations regardingDirect Loan Programloans .


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Information for Guaranty Agencies on Challenges General Information


maintain copies of documentation verifying theschool's receipt of all draft data challenge relatedmaterial. This will be useful to a guaranty agencyand the Department in determining when the schoolreceived the response.

send a copy of any draft data challenge relatedmaterial mailed to a school to the Department'sDefault Management Division using the address onpage 125. The Department will use this material tomonitor the draft data challenge process.

AND

retain copies of all draft data challengedocuments provided to schools and the Departmentfor a period of five years from the date the school'schallenge was reviewed.

What role does the Department have in aschools draft data challenge?

The Department is responsible for responding to a schools draftdata challenge if the challenge includes allegations regarding FFELProgram loans currently held by the Department and/or William D.Ford Federal Direct Loan (Direct Loan) Program loans.

The Department's Default Management Division isresponsible for responding to schools' inquiriesregarding FFEL Program loans that are currentlyheld by the Department . These loans are identifiedon the loan record detail report with a guarantor/ servicer code of 555 .

The Department's Direct Loan servicer isresponsible for responding to schools' inquiries

regarding Direct Loan Program loans . These loansare identified on the loan record detail report with aguarantor/servicer code of 0101 .

Even though the current lender/servicer/holder codefor defaulted Direct Loan Program loans is 555, ALLinquiries regarding Direct Loan Program loans areresponded to by the Direct Loan servicer.


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General Information Information for Guaranty Agencies on Challenges


The Department also reviews guaranty agency responses toschools draft data challenges to ensure that the guarantyagency responses are correct. If the Department determines thatthe guaranty agency responses are not correct, the Department willnotify the guaranty agency and the school prior to the release of the

official cohort default rates that the guaranty agencys responses areincorrect and will provide the correct responses. The Department willinstruct the guaranty agency to resubmit the corrected data toNSLDS and will inform the school that if the guaranty agency fails tomake the corrections prior to the release of the official cohort defaultrates the Department will make the corrections after the official cohortdefault rates are calculated.

How does a guaranty agency notify theDepartment about the status of a school'schallenge?

A guaranty agency must send the Department a copy of itsresponse to a schools challenge. Please refer to the Responding

to Draft Data Challenges section beginning on page 128 forguidance on how to respond to a school's draft data challenge.

However, in addition to sending the Department a copy of anychallenge-related correspondence sent to a school, each guarantyagency should provide the Department with a monthly status report.The monthly status report provides the Department with an updateon draft data challenges that guaranty agencies receive fromschools after the release of the draft cohort default rates. Thesestatus reports will assist the Department in monitoring the timeframes and work load associated with the draft data challengeprocess.

The status report should be sent to the Department using theaddress on page 125 within 5 working days of the end of eachmonth. For example, the status report for March, 2000 should besent by April 7, 2000.

MONTHLY STATUSREPORTS


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Information for Guaranty Agencies on Challenges Monthly Status Reports


The report should be a cumulative listing of all draft datachallenges. The report should reflect the date the school sent thechallenge to the guaranty agency, the date the guaranty agencyresponded to the schools challenge, the tracking numberassociated with the agency's response, and the date the school

received the response.If a guaranty agency has not received any cohortdefault rate challenge inquiries or requests, theguaranty agency should send a status report markedNo cohort default rate challenge inquiries or requestsreceived."

Once all responses have been provided to all schools and theguaranty agency has not received any subsequent challenges, theguaranty agency should send the Department an updated statusreport marked "FINAL". After the guaranty agency sends theDepartment the final report, the guaranty agency does not need tosend any more monthly status reports until the official cohort defaultrates are released.

The monthly status report should list schools in orderby OPE ID number.

Guaranty agencies should use the format of the sample MonthlyStatus Report spreadsheet, on page 127 to submit reports.

If sent by commercial overnight mail/courier delivery, send the

monthly status report and all copies of letters sent to schoolsregarding the schools cohort default rate to:

U.S. Department of EducationDefault Management DivisionROB-3, Room 39057th and D Streets, SWWashington, DC 20407

If sent by U.S. Postal Service, send the monthly status report andall copies of letters sent to schools regarding the schools cohort

default rate to:

U.S. Department of EducationDefault Management DivisionPortals Building, Room 6300400 Maryland Avenue, SWWashington, DC 20202-5353


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Monthly Status Reports Information for Guaranty Agencies on Challenges


Instructions for Monthly Status Report on Draft Data Challenges Spreadsheet

O n

R o w

1 , e

n t e r e x a c

t l y

t h e s a m e c o

l u m n n a m e s

i n e x a c t

l y t h e

s a m e o r d e r a s

l i s t e d o n

t h e s a m p l e s p r e a d s h e e

t . E n s u r e

t h a

t

c o l u m n n a m e s a p p e a r a

t t h e

t o p o

f e a c h p a g e .

O n

R o w

2 a n

d b e

l o w , i n

c l u

d e

t h e

f o l l o w

i n g

d a

t a f o r e a c

h s c h o o

l

t h a t

h a s s u

b m i t t e d a

d r a

f t d a

t a c h a

l l e n g e .

R e c o r

d a

l l s c

h o o l s

t h a t r e q u e s

t e d c o

h o r t

d e f a u

l t r a

t e d a t a

i n f o r m a

t i o n u s

i n g a s p r e a

d s h e e t s o

f t w a r e a p p

l i c a

t i o n s u c h a s

E x c e

l , L o

t u s

1 - 2 - 3 ,

o r S u p e r c a

l c .

T h e r e s u

l t i n g s p r e a d s h e e

t i s

s e n

t t o

t h e

D e p a r

t m e n t .

T h e s p r e a d s h e e

t s h o u l

d b e p r

i n t e d o n

8 x

1 1 " p a p e r i n

a

l a n

d s c a p e

( h o r

i z o n t a l )

l a y o u

t . A s a m p

l e s p r e a

d s h e e t

f o l l o w s

t h e s e

i n s t r u c t

i o n s .

C o

l u m n

1 :

E n t e r

t h e

s c h o o

l s s i x -

d i g i t O P E I D n u m

b e r .

C o

l u m n

2 :

E n

t e r

t h e

s c h o o

l s n a m e .

C o

l u m n

3 :

E n

t e r

M M

/ D D / C C Y Y ( m o n

t h ,

d a

t e ,

y e a r )

t o

i d e n t

i f y t h e d a

t e t h e s c

h o o

l s u

b m i t t e

d t h e d r a

f t

d a t a c h a

l l e n g e .

C o

l u m n

4 :

E n

t e r

M M

/ D D / C C Y Y t o i d e n

t i f y

t h e

d a t e t h e

g u a r a n t y a g e n c y m a

i l e d a r e s p o n s e

t o t h e s c h o o

l .

C o

l u m n

5 :

E n

t e r

t y p e o

f s e r v

i c e

d e

l i v e r y

( i . e .

F e

d e r a

l

E x p r e s s ,

U . S .

P o s t a

l S e r v

i c e ,

A i r b o r n e

E x p r e s s ,

e t c

. ) t h e g u a r a n

t y a g e n c y u s e

d t o d e l

i v e r

i t s

r e s p o n s e

t o t h e s c

h o o

l .

C o

l u m n

6 :

E n

t e r

t h e

t r a c

k i n g n u m

b e r a s s i g n e

d t o t h e

r e s p o n s e

b y

t h e

d e l i v e r y s e r v

i c e .

C o

l u m n

7 :

E n

t e r

M M

/ D D / C C Y Y t o i d e n

t i f y

t h e

d a t e t h e

s c h o o l s

i g n e

d f o r

t h e r e s p o n s e

f r o m

t h e g u a r a n

t y

a g e n c y .

C o

l u m n

8 :

E n

t e r c o m m e n t s

i n t h i s c o

l u m n ,

i f n e e

d e d .

H e a

d e r :

E n t e r

F Y 1 9 9 8 M o n

t h l y S t a t u s

R e p o r t o

n

D r a

f t D

a t a C h a

l l e n g e s

i n t h e c e n

t e r o f

t h e

h e a

d e r a r e a .

I n t h e

l e f t - h a n

d a r e a , e

n t e r t

h e

n a m e o

f t h e g u a r a n t y a g e n c y ,

t h e g u a r a n

t y

a g e n c y

t h r e e

d i g i t g u a r a n

t o r c o

d e , a n

d t h e

n u m

b e r o

f s c

h o o

l s t h a t

h a v e s u

b m

i t t e

d d r a

f t

d a t a c h

a l l e n g e s .

F o o

t e r :

E n t e r t

h e d a

t e i n t h e

l e f t s i

d e o

f t h e

f o o t e r a r e a .

S e t u p a u

t o m a

t i c p a g

i n a t

i o n

i n t h e r i g h

t s i d e o

f

t h e

f o o t e r a r e a s o

t h a

t t h e s p e c i

f i c p a g e n u m

b e r

a n d

t h e

t o t a l n u m

b e r o

f p a g e s s h o w o n e a c h

p a g e ,

f o r e x a m p

l e : p a g e

1 o f

1 0 p a g e s .

S o r t :

T h e r e p o r

t s h o u

l d b e a c u m u l a

t i v e

l i s t i n g o

f a l

l

d r a

f t d a t a c h a

l l e n g e s

i n o r

d e r

b y

O P E I D

n u m

b e r .


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Information for Guaranty Agencies on Challenges Monthly Status Reports


Sample Monthly Status Report on Draft Data Challenges spreadsheet

Please refer to page 124 for information on the time frame thatthis spreadsheet should be submitted and page 126 for detailedinstructions on creating this spreadsheet.

0 4 / 0 7 / 2 0 0 0

[ s e n

d t o t h e

U . S .

D e p a r t m e n t o

f E d u c a

t i o n

P a g e

1 o

f 1

u s i n g

t h e a

d d r e s s s h o w n o n p a g e

1 2 5

. ]

8 .

C o m m e n

t s ,

i f n e e

d e

d

I n

i t i a

l C h a

l l e n g e

I n

i t i a

l C h a

l l e n g e

I n

i t i a

l C h a

l l e n g e

S u p p

l e m e n

t a l C h a l l e n g e

7 .

D a

t e t h e s c

h o o

l

s i g n e

d f o r

t h e

r e s p o n s e

f r o m

t h e

g u a r a n

t y a g e n c y

( M M / D D / C C Y Y o r

l e a v e

b l a n k

)

0 4 / 0 4 / 2 0 0 0

0 3 / 2 3 / 2 0 0 0

0 4 / 0 2 / 2 0 0 0

6 .

T r a c

k i n g

N u m

b e r

8 2 0 0 0 0 0 0 0 0 0 0 0 0 0 0

8 3 0 0 0 0 0 0 0 0 0 0 0 0 0 0

8 4 0 0 0 0 0 0 0 0 0 0 0 0 0 0

5 .

S e r v

i c e

t y p e

F e

d e r a

l E x p r e s s

P o s t a

l S e r v

i c e

P o s t a

l S e r v

i c e

4 .

D a

t e t h e g u a r a n

t y

a g e n c y m a

i l e

d

a

r e s p o n s e

t o t h e s c

h o o

l

( M M / D D / C C Y Y o r

l e a v e

b l a n

k )

0 4 / 0 1 / 2 0 0 0

0 3 / 2 0 / 2 0 0 0

0 4 / 0 1 / 2 0 0 0

3 .

D a

t e t h e s c

h o o

l

s u

b m

i t t e d t h e

c h a

l l e n g e

t o t h e

G A

( M M / D D / C C Y Y )

0 3 / 1 3 / 2 0 0 0

0 3 / 1 8 / 2 0 0 0

0 3 / 2 0 / 2 0 0 0

0 4 / 0 6 / 2 0 0 0

2 .

S c

h o o

l ' s

N a m e

T r a

i n i n g

I n s t

i t u t e

S c h o o

l o f B u s i n e s s

E l e c t r i c a

l I n s t

i t u t e

E l e c t r i c a

l I n s t

i t u t e

1 .

S c

h o o

l ' s

O P E I D

n u m

b e r

0 0 0 0 0 1

0 0 0 0 0 2

0 0 0 0 0 3

0 0 0 0 0 3

F Y 1 9 9 8 M o n

t h l y S t a t u s

R e p o r t

O n

D r a f

t D a

t a C h a

l l e n g e s

S t a t e G u a r a n

t y A g e n c y

1 1 1

2 s c

h o o l s

N o

t e :

T h i s i s a s a m p

l e

s p r e a d s h e e

t . S e e

i n s t r u c t

i o n s

o n

t h e p r e v i o u s p a g e .


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Responding to Draft Data Challenges Information for Guaranty Agencies on Challenges


How should a guaranty agency respond to aschools draft data challenge?

Step 1: Within 30 calendar days of receiving the school'sdraft data challenge, a guaranty agency shouldreview this Guide to determine if the schoolschallenge is timely .

The time frames associated with a schoolsdraft data challenge are outlined in the DraftData Challenge section beginning on page 86.

Step 2: Within the time frame described in Step 1 (i.e.,within 30 calendar days of receiving the school's draftdata challenge), a guaranty agency should notify theschool and the Department if the schools draftdata challenge is untimely .

If the school did not send its draft data challengewithin 45 calendar days of the schools receipt of itsmost recent hardcopy draft cohort default rate data,the guaranty agency should NOT review any part ofthe schools draft data challenge. In its response tothe school, the guaranty agency should explain that itis unable to review the challenge because the schoolmissed the regulatory deadline. The guaranty agencyshould refer the school to the Draft Data Challengesection beginning on page 75, and simultaneouslysend a copy of the letter to the Department. 2

The Department mails draft cohort default ratesat an announced time and tracks schoolsreceipt of the rates. Before denying a schoolsdraft data challenge on the basis of a latesubmission, a guaranty agency should contactthe Department to verify the actual date theschool received its draft cohort default ratedata.

2 64 Fed. Reg. 58974 (November 1, 1999) (Preamble to Final Rule)

RESPONDING TO DRAFTDATA CHALLENGES

Time framesmay overlap.Read ALLsteps.


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Information for Guaranty Agencies on Challenges Responding to Draft Data Challenges


Please refer topages 95 and97 of the"Draft DataChallenge"section for asamplespreadsheetfrom a schooland for asample loanrecord detailre ort.

If the schools submission due date falls on aweekend or a federal holiday, a school maysend its draft data challenge to the guarantyagency no later than the next federal businessday.

Step 3: If the draft data challenge is timely, within the timeframe described in Step 1 (i.e., within 30 calendardays of receiving the school's timely submitted draftdata challenge), a guaranty agency should revieweach allegation submitted by the school.

Determine if the allegations presented by theschool are based on loans that are currentlyheld by the agency.

If the loans are not held by the agency, notifythe school that the allegation(s) should besubmitted to the entity that currently maintainsthe guarantee on the loan. Remind the schoolthat all allegations must be submitted to theappropriate entity within 45 calendar days ofthe schools receipt of its hardcopy draft cohortdefault rate data.

Determine if all relevant material is presentincluding, but not limited to:

a spreadsheet identifying the loans thatthe school is requesting the guarantyagency review;

a copy of applicable pages from therelevant loan record detail report(s) .

Each allegation must be accompaniedby at least one page of a loan recorddetail report;

Example

Q .Q .Q .Q . How should aguaranty agency respondif a school challenges theaccuracy of a FFELProgram loan that isconsidered in default dueto the default on aconsolidation loan?

AAAA . The guarantyagency should confirmthe date enteredrepayment of the FFELProgram loan and explainthat the FFEL Programloan that was paid-in-full

through consolidation isconsidered in defaultbecause the consolidatedloan defaulted within thesame cohort period inwhich the FFEL Programloan entered repayment.

If a different guarantyagency guaranteed theconsolidation loan, theschool should be referredto that agency for anyquestions pertaining tothe default of theconsolidation loan.


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Please refer topage 89 of the"Draft DataChallenge"section forexamples ofsupportingdocumentation

A school should include the pageof the loan record detail reportwhere the borrower appears, orwhere the borrower shouldappear. A school should provide

both pages of the loan recorddetail report if the borrowerappears or should appear at theend of one page or at thebeginning of the next page.

If the borrower is moved from oneyear to another, a school shouldinclude the page of the loanrecord detail report where theborrower currently appears, and

the page of the loan record detailreport where the borrower shouldappear.

AND

relevant supporting documentationincluding, but not limited to:

a signed and dated copy of aletter to the relevant lender orguaranty agency that informsthe entity of the borrowers lastdate of attendance or less-than-half-time date (whichever isearlier) and provides evidencethat the information was mailed tothe relevant lender or guarantyagency in a timely manner (i.e., acertified mail receipt);

AND/OR

Example


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Please refer topage 92 of the"Draft DataChallenge"section for anexample.

a signed and dated copy of aStudent Status ConfirmationReport (SSCR) or an NSLDSSSCR screen print that timelyinforms the lender and/or

guaranty agency of theborrowers last date ofattendance or less-than-half-timedate (whichever is earlier);

AND/OR

a copy of a cancelled check ,front and back, or otherdocumentation showing that theborrowers loan was cancelled in-

full within 120 days ofdisbursement by the lender.

If a school fails to provide theguaranty agency with all thenecessary information, theguaranty agency may ask theschool to submit the missinginformation. However, the schoolmust submit this additionalinformation to the guaranty

agency within the 45 calendarday deadline for submitting draftdata challenges.

Research each allegation to determine ifdocumentation maintained by the guarantyagency supports or refutes the schoolsallegation.

Please refer to pages 80 through 85 of the"Draft Data Challenge" section for a list of thedifferent types of possible allegations.

Example


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Make a determination on each allegationlisted on the schools spreadsheet.

If a borrower has multiple loansguaranteed and currently held by theguaranty agency, the guaranty agencymust address all of the borrowers loansassociated with the school in question.

Agree with the school if thedocumentation maintained by theguaranty agency supports the schoolsclaim or if the school has demonstratedthat the correct information was timelysubmitted to the lender and/or guarantyagency.

If the guaranty agency responseindicates that a loan has beenrepurchased, the guarantyagency must provide the originalclaim paid date, the reason theloan was repurchased, andwhether any subsequent claimswere filed.

OR

Disagree with the school if thedocumentation maintained by theguaranty agency refutes the schoolsclaim and the school failed todemonstrate that the correct informationwas timely submitted to the lenderand/or guaranty agency. If the guarantyagency disagrees with the school, theguaranty agency must explain why itdisagrees with the school.

There are a number of reasons why aguaranty agency might disagree with theschools allegations of error. Forexample, the school might have:


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Please refer to

page 139 for asamplespreadsheet.

made only general allegationsabout the loan record detailreport and/or the draft cohortdefault rate data;

failed to provide evidence that theguaranty agency and/or lenderwas timely notified of a changein status for the borrower;

AND/OR

failed to provide acceptablesupporting documentation foran allegation.

Please refer to page 89 for

examples of acceptablesupporting documentation.

Step 4: Within the time frame described in Step 1 (i.e.,within 30 calendar days of receiving the school's draftdata challenge), a guaranty agency should compile alist of the guaranty agencys responses to theschools alleged errors.

Record the responses to each of the school'salleged errors on a spreadsheet that followsthe format of the sample Draft Data ChallengeResponse spreadsheet.

Provide comments on why the guarantyagency agrees or disagrees with each of theschools allegations.

Step 5: Within the time frame described in Step 1 (i.e.,within 30 calendar days of receiving the school's draft

data challenge), a guaranty agency should send theschool a response to its draft data challenge andalso send a copy of the response to theDepartment .

Due date forresponding tothe challenge

Example


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The Department recommends that:

each guaranty agency submit the completedresponse to the school's draft data challengeusing the format of the sample Draft DataChallenge Response letter shown on page141;

each guaranty agency include the spreadsheetcreated in Step 4 in its response;

AND

each guaranty agency compile its responseand mail the response via return receiptrequested or via overnight courier delivery tothe school with a copy to the Department sentto the address provided on page 136.

The recommended materials for the guaranty agencyresponse are shown on page 135.

Step 6: Respond to any subsequent inquiries from aschool within 5 working days of the receipt of theschool's timely inquiry and send a copy of theresponse letter to the Department.

If a guaranty agency does not agree with the school'ssubsequent inquiry, the agency should indicate thatits previous response was its final response.

Schools must submit subsequent inquiries within 5working days of receiving the agencys response toits initial inquiry.

QQQQ .... Do guarantyagencies have to providecopies of supportingdocumentation to theDepartments DefaultManagement Division?

AAAA .... No , guarantyagencies do not need toprovide copies ofsupporting documentation

to the DepartmentsDefault ManagementDivision.


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A guaranty agency should send the following to the school:

The section behind Component 1 contains:

A letter on the guaranty agencys letterhead with

the schools OPE ID number ;

the schools name ;

a statement indicating that the guaranty agency isresponding to the schools draft data challenge ;

the fiscal year to which the response applies;

the signature of the responsible official at theguaranty agency, followed by a signature blockproviding the signers name and job title .

AND

an indication that a copy was sent to theDepartment .

Guaranty agencies should use the sample Draft Data ChallengeResponse letter on page 141.

The section behind Component 2 contains:

A list, in spreadsheet format, of the guaranty agencys responsesto the schools alleged errors.

Guaranty agencies should use the sample Draft Data ChallengeResponse spreadsheet on page 139. A guaranty agency mustprovide data on each of the elements listed on the samplespreadsheet.

If a borrower has multiple loans , the guarantyagency must address all of the borrowers loans

associated with the school in question.

Component 1

Component 2


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If sent by commercial overnight mail/courier delivery, send theDepartment's copy of the draft data challenge response to:

U.S. Department of EducationDefault Management Division

ROB-3, Room 39057th and D Streets, SWWashington, DC 20407

If sent by U.S. Postal Service , send the Department's copy of thedraft data challenge response to:

U.S. Department of EducationDefault Management DivisionPortals Building, Room 6300400 Maryland Avenue, SWWashington, DC 20202-5353


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Guaranty Agency Response to Draft Data Challenge Example

Draft Data Challenge Received by the State Guaranty Agency

Within 30 calendar days of receiving the school's draft data challenge, the guaranty agency:

determined whether the school's challenge was timely (please refer to Step 1 onpage 128);State Guaranty Agency received Electrical Training Institute's FY 1998 draft datachallenge on March 14, 2000. State Guaranty Agency checked to verify that thechallenge was timely submitted. According to the Department, the school receivedits draft cohort default rate data on February 16, 2000. According to the postmarkon the service delivery package, the draft data challenge was submitted to theagency on March 10, 2000. Because the challenge was submitted within 45calendar days of the school's receipt of its draft cohort default rate data, thechallenge was timely submitted.

determined whether the loans listed on the school's spreadsheet are currently heldby the agency (please refer to Step 3 on page 129);

State Guaranty Agency checked column 10 of Electrical Training Institute'sspreadsheet and determined that the school had identified the loan as beingguaranteed by the State Guaranty Agency. The State Guaranty Agency thenverified in its system that the loan was currently held by the agency.

determined whether all the relevant material was present for each allegationincluding (please refer to Step 3 on pages 129 through 131):

the school's spreadsheet (please refer to page 95 for the samplespreadsheet from the school);

the applicable pages from the relevant loan record detail reports (pleaserefer to page 97 for sample loan record detail reports from the school);

AND

supporting documentation (please refer to page 99 for sample supportingdocumentation from the school).

reviewed the allegation regarding David Smith presented by the school in its draftdata challenge:

State Guaranty Agency's records confirm that timely notification of David's changein enrollment status was provided by the school. As a result, the agency agreedthat David's FFEL Program Stafford loan should be removed from the school's FY1998 cohort default rate and placed in the school's FY 1997 cohort default rate.

prepared a spreadsheet that indicated the correct data associated with David's loan(please refer to the sample spreadsheet response on page 139);

AND

created a cover letter to Electrical Training Institute responding to the school's draftdata challenge (please refer to the sample cover letter on page 141.

State Guaranty Agency then sent the material to Electrical Training Institute at the address on theschool's cover letter and sent a copy to the Department's Default Management Division.


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Sample Draft Data Challenge Response Spreadsheet

Please refer to Step 3 on page 129 for information on the time frameassociated with completing this spreadsheet and page 138 fordetailed instructions on creating this spreadsheet.

S t a t e G u a r a n

t y A g e n c y

E l e c t r i c a l

T r a

i n i n g

I n s t

i t u t e

O P E I D 1 1 1 1 1 1

N u m

b e r o

f a l

l e g a

t i o n s :

1

F Y 1 9 9 8 D r a

f t D a t a

C h a l

l e n g e

R e s p o n s e

9 .

C o m

m e n

t s

A g r e e . T

h e g u a r a n

t y

a g e n c y

' s r e c o

r d s

i n d i c a

t e

t h a

t t h e s c

h o o

l t i m e

l y

s u b m

i t t e

d t h e

i n f o r m a

t i o n

o n

D a v i

d ' s c h a n g e

i n

e n r o

l l m e n

t .

8 .

E f f e c

t

o n

C D R

c a

l c .

( N , D ,

o r

B )

- B + D

7 .

F Y ( s )

a p p

l .

F Y 1 9 9 8

F Y 1 9 9 7

6 .

C P D ,

D D

, I C R D

,

o r

N / A

( M M / D D / C C Y

Y

o r

l e a v e

b l a n k )

0 9 / 0 5 / 1 9 9 9

5 .

D a

t e

e n

t e r e

d

r e p a y m e n

t

( D E R )

( M M / D D / C C Y Y )

0 5 / 1 3 / 1 9 9 7

4 . E a

r l i e r o

f

L T

H o r

L D A

( M M / D

D / C C Y Y )

1 1 / 1 2 / 1 9 9 6

3 .

T y p e

o f l o a n

( U s e c o

d e s

o n

i n s t r u c t

i o n s )

S F

2 .

B o r r o w e r ' s

N a m e

D a v i

d S m

i t h

1 .

B o r r o w e r ' s

S S N

1 1 1 - 1

1 - 1

1 1 1

0 3 / 2 1 / 2 0 0 0

P a g e

1 o

f 1

N o

t e :

T h i s i s a s a m p

l e

s p r e a

d s h e e t .

S e e

i n s t r u c t

i o n s

o n

t h e p r e v i o u s p a g e .


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Sample Draft Data Challenge Response Letter

Please refer to Step 5 on page133 for more information on the time frame ofissuing this letter.

May 21, 2000

Robert Young OPE ID#: 111111

PresidentElectrical Training Institute1234 Main StreetLeonardtown, Wisconsin 12345-6789

Dear Mr. Young:

This is State Guaranty Agency's response to Electrical Training

Institute's, OPE ID# 111111 , FY 1998 draft data challenge.Please see the enclosed spreadsheet.

Sincerely,

Bob Tucker Bob Tucker, CEOState Guaranty Agency

Enclosure

cc: U.S. Department of Education, Default Management Division

Subject: FY 1998 Draft Data Challenge Response

State Guaranty Agency1234 Trueman RoadLusby, North Carolina 98765-4321(111) 222-3333

Sample Letter


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