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Session # 79 The Changing Data Landscape of Cohort Default Rates Patrick Kennedy Cynthia Battle U.S. Department of Education

Session # 79 The Changing Data Landscape of Cohort Default Rates

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Session # 79 The Changing Data Landscape of Cohort Default Rates . Patrick Kennedy Cynthia Battle U.S. Department of Education . Session Agenda. The Landscape Changes in Cohort Default Regulations Cohort Default Rate Review Default Prevention and Debt Management Strategies - PowerPoint PPT Presentation

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Page 1: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Session # 79

The Changing Data Landscape of

Cohort Default Rates Patrick Kennedy

Cynthia BattleU.S. Department of Education

Page 2: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Session Agenda

The Landscape

Changes in Cohort Default Regulations

Cohort Default Rate Review

Default Prevention and Debt Management Strategies

The Take-A-Ways

2

Page 3: Session # 79 The Changing Data Landscape of  Cohort Default Rates

The Landscape

• Loan default rates increasing for most schools• Educational costs continue to rise• More students borrowing more money • One-in-five households hold student loan debt• Increasing loan delinquency rates • Regulatory transition to 3-year Cohort Default Rate (CDR)

calculation

3

Page 4: Session # 79 The Changing Data Landscape of  Cohort Default Rates

National Cohort Default Rates

4

Page 5: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Session Agenda

The Landscape

Changes in Cohort Default Regulations

Cohort Default Rate Review

Default Prevention and Debt Management Strategies

The Take-A-Ways

5

Page 6: Session # 79 The Changing Data Landscape of  Cohort Default Rates

The 3-Year Cohort Default Rate

• Expands the default tracking window from 2 years to 3 years

• Raises penalty threshold from 25% - 30%• Increases availability of “disbursement relief”

from 10% to 15% (effective 10/01/11)• 34 CFR 668.217 affected the 2009 cohort year

6

Page 7: Session # 79 The Changing Data Landscape of  Cohort Default Rates

7

Regulatory Requirements

Section 34 CFR 668.217: Institutions that have a 3-Year Cohort Default Rate of 30% or greater for any one federal fiscal year is required to establish a Default Prevention Task Force to reduce defaults and prevent the loss of institutional eligibility.

The 3-Year Cohort Default Rate

7

Page 8: Session # 79 The Changing Data Landscape of  Cohort Default Rates

3-Year CDR Corrective Actions

• First year at 30% or more– Default prevention plan and task force– Submit plan to FSA for review

• Second consecutive year at 30% or more– Review/revise default prevention plan– Submit revised plan to FSA– FSA may require additional steps to promote student loan repayment

• Third consecutive year at 30% or more– Loss of eligibility: Pell, DL– School has appeal rights

8

Page 9: Session # 79 The Changing Data Landscape of  Cohort Default Rates

CDR Denominator:#Enter Repayment

Numerator#Default

Publish Rates Cohorts used for Sanctions

FY 2009(3-Year)

10/1/08-9/30/09 10/1/08-9/30/11 September 2012 No Sanction

FY 2010(2-Year)

10/1/09-9/30/10 10/1/09-9/30/11 September 2012 FY 08, FY 09, FY 10

FY 2010(3-Year)

10/1/09-9/30/10 10/1/09-9/30/12 September 2013 No Sanction

FY 2011(2-Year)

10/1/10-9/30/11 10/1/10-9/30/12 September 2013 FY 09, FY 10, FY 11

FY 2011(3-Year)

10/1/10-9/30/11 10/1/10-9/30/13 September 2014 FY 09, FY 10, FY 11

First cohort year where schools will be subject to sanction based on 3-Year Cohort Default Rates

The 3-Year Cohort Default Rate

9

Page 10: Session # 79 The Changing Data Landscape of  Cohort Default Rates

The 3-Year Numerator is the number of a school's borrowers who enter repayment on certain FFEL Program or Direct Loan Program loans during a particular federal fiscal year (FY), which is from October 1 to September 30, and default prior to the end of the next two fiscal years.

The 3-Year Denominator is the number of a school's borrowers who enter repayment on certain Federal Family Education Loan (FFEL) Program or William D. Ford Federal Direct Loan (Direct Loan) Program loans during a particular federal fiscal year (FY), which is from October 1 to September 30.

Non- Average 3-Year

Cohort Default Rate

The 3-Year Cohort Default Rate

10

Page 11: Session # 79 The Changing Data Landscape of  Cohort Default Rates

The 3-Year Average Rate Numerator is the number of borrowers who entered repayment in the cohort fiscal year or either of the two preceding cohort fiscal years and who defaulted or met the other specified condition in the cohort default period for the cohort fiscal year in which they entered repayment.

The 3-Year Average Rate Denominator is the number of borrowers who entered repayment in the cohort fiscal year or either of the two preceding fiscal years.

3-Year Average Cohort

Default Rate

The 3-Year Cohort Default Rate

11

Page 12: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Old Benefit Threshold New Benefit Threshold as of 10/1/110%

2%

4%

6%

8%

10%

12%

14%

16%

Old New

CDR Benefit Threshold ChangesThe 3-Year Cohort Default Rate

12

Page 13: Session # 79 The Changing Data Landscape of  Cohort Default Rates

13

3-Year Cohort Default Rate BenefitsEligible School Benefits

A school whose most recent official cohort default rate is less than 5.0% and is an eligible home institution that is originating loans to cover the cost of attendance in a study abroad program

-May disburse loan proceeds in a single installment to a student studying abroad regardless of the length of the student’s loan period.-May choose not to delay the disbursement of the first installment of loan proceeds for first-year first-time borrowers studying abroad.

A school with a cohort default rate of less than 15.0% for each of the three most recent fiscal years for which data are available, including eligible home institutions and foreign institutions,

-May disburse, in a single installment, loans that are made for one semester, one trimester, one quarter, or a four-month period. -May choose not to delay the first disbursement of a loan for 30 days for first-time, first-year undergraduate borrowers.

13

Page 14: Session # 79 The Changing Data Landscape of  Cohort Default Rates

14

CDR Sanction Threshold Changes

Old Sanction Threshold New Sanction Threshold as of 10/1/11

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

Old New

The 3-Year Cohort Default Rate

14

Page 15: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Session Agenda

The Landscape

Changes in Cohort Default Regulations

Cohort Default Rate Review

Default Prevention and Debt Management Strategies

The Take-A-Ways

15

Page 16: Session # 79 The Changing Data Landscape of  Cohort Default Rates

CDRs: The Formula

Numerator

Denominator

Borrowers who entered repayment in one year, and defaulted in that year or the next.

Borrowers who entered repayment during the one-year cohort period.

Cohort Default Rate Review

16

Page 17: Session # 79 The Changing Data Landscape of  Cohort Default Rates

2 to 3-Year CDR (a scenario)

Numerator = # of borrowers from the denominator who default within a FY

Denominator = # of borrowers who enter repayment within a FY

5,000

Year 1 3555000 = .071 or 7.1%

6055000 = .121 or 12.1%

125 230

125 230 250

5,000

Year 1 Year 2 Year 3

Year 2

Cohort Default Rate Review

17

Page 18: Session # 79 The Changing Data Landscape of  Cohort Default Rates

CDRs Are Released Twice A Year

February (DRAFT)

Not publicNo sanctionsNo benefits

September (OFFICIAL)

Public Sanctions apply Benefits apply

Cohort Default Rate Review

18

Page 19: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Challenges, Adjustments, and AppealsChallenges• Incorrect Data Challenge (IDC)• Participation Rate Index Challenge (PRI)

Adjustments• Uncorrected Data Adjustment (UDA)• New Data Adjustment (NDA)

Appeals• Loan Servicing Appeal (LS)• Erroneous Data Appeal (ER)• Economically Disadvantaged Appeal (EDA)• Participation Rate Index Appeal (PRI)

Cohort Default Rate Review

19

Page 20: Session # 79 The Changing Data Landscape of  Cohort Default Rates

20

Cohort Default Rate Review - LRDR

Page 21: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Data Manager

Cohort Default Rate Review

21

Data Manager: Depending on the loan, a data manager may be the Federal Loan Servicer, a

guaranty agency or in some instances, the Department.

Entity responsible for maintaining and managing the data used in calculating cohort default rates.

Page 22: Session # 79 The Changing Data Landscape of  Cohort Default Rates

CDR Guide CDR Guide

CDR Guide

The “Cohort Default Rate Guide” (Guide) is a publication that the U.S. Department of Education designed to assist schools with their 2-Year and 3-Year FFEL and Direct Loan Program cohort default rate data. The Guide has been updated and should be used as a reference tool in understanding cohort default rates and processes.

Cohort Default Rate Guide

22

Page 23: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Operations

Perform

ance

Divisio

n20

23774259

Operations Performance Division Phone: 202-377-4259

E-mail: [email protected]

Website: ifap.ed.gov/DefaultManagement/DefaultManagement.html

E-Appeals: https://ecdrappeals.ed.gov/ecdra/index.html

Contact Information

Cohort Default Rate Review

23

Page 24: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

Default Prevention Strategies

# 1 Borrower

Communication

# 2 Financial Literacy

for Borrowers

# 3 Communication Across Campus

# 4 Timely and

Accurate Enrollment Reporting

# 5 Review NSLDS

and School Based Data

# 6 Servicer

Relationship

24

Page 25: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

Students don’t know…• How much aid they have• Where it comes from• Who paid for it• Whose money it really isThis reduces the likelihood that it will be spent effectively.

What is “financial aid”?

1 Borrower Communication

25

Page 26: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

1 Borrower Communication

Result … Lack of Understanding “I went to those financial aid workshops at my high school but those weren't helpful really at all…”

“…an email saying this is what you're getting. But they don't

really tell you where it's coming from or why you're getting it, so I don’t know.”

“It would be helpful if there was an

email explaining what each of the things are and where they're

coming from and what they're doing

and when you'll have to pay them

back, and that kind of stuff.”

26

Page 27: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Implications for the Borrower

Credit report damage (7-year minimum) Wage garnishment Seizure of federal and state tax refunds Seizure of portion of any federal payment Legal action in federal district court Title IV ineligible May lose state occupational license May have difficulty obtaining mortgage or car loans May be unable to rent an apartment May be turned down for jobs Collection costs

1 Borrower Communication

Default Prevention and Debt Management Strategies

27

Page 28: Session # 79 The Changing Data Landscape of  Cohort Default Rates

28

“What are the most important things a student should know as he/she prepares for

loan repayment?”

There are several important messages to deliver to borrowers as they are leaving school and entering repayment:

Check NSLDS to identify all federal loans and identify the servicer(s) Provide servicers with updated contact information Sign up for online account access Sign up for automatic debit to ensure timely payments and receive a 0.25% interest rate reduction Call the servicer to obtain information on repayment options that best meet the borrower’s financial situation Understand that servicers are there to help!

1 Borrower Communication

Default Prevention and Debt Management Strategies

28

Page 29: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

Default Prevention Strategies

# 1 Borrower

Communication

# 2 Financial

Literacy for Borrowers

# 3 Communication Across Campus

# 4 Timely and Accurate

Enrollment Reporting

# 5 Review NSLDS

and School Based Data

# 6 Servicer

Relationship

29

Page 30: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

2 Financial Literacy for Borrowers

• Correlation exists between increased financial literacy and decreased defaults

• Schools can play an important role – Some schools make it part of their first year curriculum– Some schools offer a class for credit, if possible

• There are many free resources available– federal, non-profits, lenders, guarantors

• Consider online financial literacy programs• Counsel students on credit card usage

30

Page 31: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Money Smart - A Financial Education Program

U.S. Federal Reserve System

Default Prevention and Debt Management Strategies

Financial Literacy Information Sources

31

Page 32: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

2 Financial Literacy for Borrowers

All counseling products on StudentLoans.gov highlight financial literacy concepts:

Entrance Counseling – required to receive a federal loan

Exit Counseling – required when the student graduates, leaves school or drops below half-time enrollment

Financial Awareness Counseling – optional• Cannot be required as condition for disbursement• Cannot replace Entrance Counseling

32

Page 33: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

2 Financial Literacy for Borrowers

Dynamic counseling tools help the student: Make informed decisions about postsecondary funding Understand their repayment obligation, using the students

loan information in NSLDS Develop a budget Estimate monthly student loan payments Explore paying interest while in-school and during periods

of deferment and forbearance Explore the impacts of deferment and forbearance Learn about income-driven repayments plan options Indicate a repayment plan preference (Exit Counseling)

33

Page 34: Session # 79 The Changing Data Landscape of  Cohort Default Rates

All counseling products present basic financial literacy concepts in discreet learning modules.

Your Student LoansLoan BasicsFree Money First Types of Student

Loans

Manage Your Spending while in School

Live Within Your Means

Borrow Smart

Estimate What You will Owe, Spend & Earn• Monthly Expenses• Monthly Income

Understand Repayment

Avoiding DefaultPostpone or Lower

Your PaymentsForgive or Cancel

Your DebtsDelinquency &

Default

Plan for the FutureYour Income &

TaxesYour Credit &

IdentityCredit Cards &

Other Borrowing

Understand Your Loans

Manage Your

Spending

Plan to Repay

Avoid Default

Make Finances a

Priority

2 Financial Literacy for Borrowers

Default Prevention and Debt Management Strategies

34

Page 35: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

Default Prevention Strategies

# 1 Borrower

Communication

# 2 Financial

Literacy for Borrowers

# 3 Communication Across Campus

# 4 Timely and Accurate

Enrollment Reporting

# 5 Review NSLDS

and School Based Data

# 6 Servicer

Relationship

35

Page 36: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

3 Communication Across Campus

The prevention and management of loan default is a school-wide effort and not the sole responsibility of the financial aid office.

To promote success, school officials should examine their communication procedures for effectiveness and inclusiveness.

Your default prevention team can serve as the vehicle for cross campus communications.

Form YOUR Default Prevention Team -

It’s Everybody's Business!

36

Page 37: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

3 Communication Across Campus

YOUR Default Prevention Task Force should drive your default prevention process:

Assess the resources you have available

Team participants SHOULD be across campus

Identify the purpose of the task force

Detail responsibilities of determining risk37

Page 38: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention Task Force

3 Communication Across Campus Forming the Team

A group of specialists who will ultimately conduct data analysis to determine the reasons for default at your school and formulate a set of intervention strategies

Select a leader for the group; Consider appointing an institutional Default Coordinator

Use your current resources to create effective, customized default prevention programs that compliment existing efforts

38

Page 39: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention Task Force

3 Communication Across Campus Activities for the Team

Study your student population. Identify any common characteristics of your defaulters and non-defaulters, and borrowers and non-borrowers

Build on Early Intervention strategies already in existence

Discuss your current strategies and determine what works and what may need some improvement

39

Page 40: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention Task Force

3 Communication Across Campus Activities for the Team

Work closely with your servicers and lenders

Find out what type of tools and services are available from your servicers/lenders

Fine-tune your Loan Servicing procedures for the period while the borrower is at your school

Have clear and precise procedures with a timeline of dates to take appropriate actions

40

Page 41: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention Task Force

3 Communication Across Campus Activities for the Team

Fine-tune your servicing efforts during the grace period and repayment

Have clear and precise procedures with a timeline of dates to take appropriate actions

Review all of your borrower education materials

Make sure all of your materials are current and up-to-date. Look for new materials to incorporate into your training

41

Page 42: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention Task Force

3 Communication Across Campus Activities for the Team

Review your results and make the necessary enhancements

Always look for ways to improve whatever you are doing. Use evaluations or surveys to get input from the students and staff

DOCUMENT! Create YOUR default prevention plan!

42

Page 43: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

Default Prevention Strategies

# 1 Borrower

Communication

# 2 Financial

Literacy for Borrowers

# 3 Communication Across Campus

# 4 Timely and

Accurate Enrollment Reporting

# 5 Review NSLDS

and School Based Data

# 6 Servicer

Relationship

43

Page 44: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

4 Timely and Accurate Enrollment Reporting

44

• Critical for administration of Title IV Loan Programs• Ensures students’ rights are protected• Essential for – Proper servicing of loan throughout the life cycle of

the loan – Preventing defaults– School cohort management

The IMPORTANCE of Enrollment Reporting

Page 45: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

4 Timely and Accurate Enrollment Reporting

45

• NSLDS places students on a roster based on reporting of federal aid

• COD disbursement records now require the “Enrollment School Code”

• It is important that schools add financial aid recipients to their rosters if the students are not listed

Report Students Where They Attend

Page 46: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

4 Timely and Accurate Enrollment Reporting

46

Report Students Where They Attend

• Students should be reported at two locations of the same 6-digit OPEID ONLY IF the student is actually attending both

• If the student is not enrolled at both locations, report the correct location for the student

• If a student appears on a roster of an incorrect location, use the “Move to” functionality to report the correct location for the student

Page 47: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

Default Prevention Strategies

# 1 Borrower

Communication

# 2 Financial

Literacy for Borrowers

# 3 Communication Across Campus

# 4 Timely and Accurate

Enrollment Reporting

# 5 Review NSLDS

and School Based Data

# 6 Servicer

Relationship

47

Page 48: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

5 NSLDS and School Based Data The NEED for Data!

In order to Conduct Risk Analysis – You NEED DATA!Academic Data – Program completion rates, retention

rates, data at the student levelNSLDS – Review NSLDS (default and delinquency) data

along with school data about defaulters and non-defaulters

Servicer Data – Servicers offer customized reports

Remember! You need someone to work the data!

48

Page 49: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

5 NSLDS and School Based Data The NEED for Data!

Conducting Risk Analysis:• Use data to create a picture of borrowers at-risk of

default• ‘Who’ is not enough• ‘Why’ will require input of academic, student affairs

and other professionals• Knowing ‘why’ is necessary to create targeted, useful

and measureable interventions

49

Page 50: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

5 NSLDS and School Based Data What Does the Data Tell You?

One of the jobs on your Default Prevention Team:• Determine the source of your default risk;• Determine what steps your school will take to reduce default risk;• Remember your team represents all parts of the institution

(including management), which will contribute to risk reduction activities;

• Allocate school resources to default reduction activities;• Assess the effectiveness of default reduction activities over time

Are they working?

50

Page 51: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

5 NSLDS and School Based Data Reducing Default – Risk Interventions

Two ways to think about reducing default risk:

(1) Assisting borrowers by enhancing their knowledge of loan responsibilities and processes and by strengthening their relationship with their loan servicer

(2) Assisting borrowers by enhancing educational and employment outcomes

51

Page 52: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

5 NSLDS and School Based Data Reducing Default – Risk Interventions

Create interventions based upon your data

Targeted vs. ‘best practices’ interventionsMost efforts are targeted at identified riskUtilizing Intervention OpportunitiesUtilizing ‘leverage’ where it existsAdding general best practices to targeted efforts

52

Page 53: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Remember…. The right student admitted to the right educational

program, with the right student support services delivered at the right time, leading to program completion and employment…in addition to traditional default aversion strategies…that’s default prevention!

Default Prevention and Debt Management Strategies

53

Page 54: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

5 NSLDS and School Based Data School Reports: NSLDS

• Reports for Data Accuracy– Date Entered Repayment Report– School Repayment Info Loan Detail – School Cohort Default Rate History – Enrollment Reporting Summary

• Reports for Default Prevention – School Loan Portfolio Report – Date Entered Repayment Report– Borrower Default Summary – Exit Counseling – Delinquent Borrower Report

54

Page 55: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Main Menu – Requesting a Report

55

Page 56: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

5 NSLDS and School Based Data School Reports: NSLDS

The School Portfolio Report (SCHPR1) provides details on borrowers and loans in your current loan portfolio Based on loan repayment begin date If your school has merged, previous school codes are

included Available in Extract only

The Delinquent Borrower Report (DELQ01) is used to assist with default prevention. Current data can be obtained on the DELQ01 webpage under the tab marked "Aid."

56

Page 57: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

5 NSLDS and School Based Data Food For Thought: Students At Risk

• Finances / Needs • Financial Attitude

• Spending Compulsion• Attitude toward debt

• Financial Aptitude• Dependent-care• Transportation • Housing• Transition difficulties

• Poor study habits• Under-prepared, basic skill needs• Language barriers• Feel unwelcome, no “campus

connection”• First generation: No role models

or family support

57

Page 58: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

5 NSLDS and School Based Data Food For Thought: Post College Risk Factors

• Income • Highest Income Earned• Occupation• Indebtedness

• Other More Important Loans to Pay

• Marital Status, basic skill needs• Number of Dependents• Filing for Unemployment

Insurance• Dissatisfaction with Educational

Program

58

Page 59: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

5 NSLDS and School Based Data Food For Thought: Typical Findings

• Never Contacted • Developmental Courses• Late Admits• Did Not Graduate• Gradated but No License• Late Majors• Exit Counseling• Level of Indebtedness

• Academic Preparedness• Grad with Minimum GPA• Feel unwelcome, no “campus

connection”• No Jobs in Profession• College Majors• Attendance Factors• Student Employment

59

Page 60: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

5 NSLDS and School Based Data Food For Thought:

Your findings may look like this…or they might not!

Do the leg-work, let your data lead the way.

That is the surest way to end up with an effective default prevention plan; one that is right for your school and your borrowers.

60

Page 61: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

Default Prevention Strategies

# 1 Borrower

Communication

# 2 Financial

Literacy for Borrowers

# 3 Communication Across Campus

# 4 Timely and Accurate

Enrollment Reporting

# 5 Review NSLDS

and School Based Data

# 6 Servicer

Relationship

61

Page 62: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

6 Servicer Role and Relationship

Comply with legislative regulatory requirements and provide unique services to borrowers and schools

For Borrowers:• Educate and inform borrowers regarding

the tools and options available to assist in the management of their student loans

• Offer multiple repayment options tailored to borrower preferences (i.e. online payments, ACH, check, etc.)

• Provide self-service tools for borrowers and options to receive bills and/or correspondence electronically

For Schools:• Offer dedicated services to schools

• Help schools to manage delinquency activities and cohort default rates

Federal Loan Servicers

62

Page 63: Session # 79 The Changing Data Landscape of  Cohort Default Rates

63

Allocations based on rankings Survey results Default statistics

Most points for first place One point for last place

Borrower Satisfaction

School Satisfaction

FSA and Partner Satisfaction

Default Prevention Measures

Servicer Performance

Score

Measuring Performance

Percent of new loans = percent of points

63

Page 64: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

6 Servicer Role

Delinquency stage begins when the loan becomes past due – that is, when the borrower does not make the scheduled payment. Collection continues until the past due amount is satisfied or resolved.

During delinquency servicers contact borrowers by phone, e-mail and mail and work with the borrower to resolve the delinquency.

64

Page 65: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

6 Servicer Role and Relationship Federal Loan Servicers

Sample Due Diligence Resolution Activities:

Stage Servicer Resolution Activities

Early 1-120

Up to 8 callsUp to 5 letters and /or e-mails

Mid121-240

Up to 8 callsReference calls

Up to 4 letters and / or e-mails

Late241-360

Up to 6 callsReference calls

Up to 5 letters and / or e-mails

65

Page 66: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

6 Servicer Role and Relationship Federal Loan Servicers

Delinquency Support Activities:

Provide outbound targeted calling campaigns along with inbound call center representatives to help borrowers become current

Utilize electronic communication methods, such as e-mail, to keep borrowers informed about account status

Work with schools to obtain current available contact information - Utilize a variety of tools to get the most current data to contact borrowers (skip tracing on delinquent accounts)

Work in partnership with the school community to assist borrowers in the later states of delinquency

66

Page 67: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

6 Servicer Role and Relationship School Servicer Partnership

Delinquency Support Activities:

All servicers work to gather feedback and find ways to partner with schools on default prevention

Face to face meeting on school campuses Financial aid conference attendance Presentations at conferences Proactive phone calls E-mail communication

67

Reminder...Visit the Federal Loan Servicers in the exhibit hall!

Page 68: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

6 Servicer Role and Relationship School Servicer Partnership

Delinquency Support Activities for Schools: (Examples)

Default Management Training and Webinars Analyzing Servicer Specific Reports and Tools Late Stage Delinquency Efforts Incorrect Data Challenges

Work the CDR data Timely Enrollment Reporting

68

Page 69: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

6 Servicer Role Federal Loan Servicers

Servicer Support – Cures:

Within 30 – 60 days of delinquency, a large percentage of delinquent accounts can be cured if servicers have good contact information

Borrowers that hit 270 days delinquent have a greater chance of remaining delinquent and even defaulting

Partner with the servicers to help borrowers in the later stages of delinquency!

69

Page 70: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

6 Servicer Role Federal Loan Servicers

Example Strategies for Targeting At-Risk Borrowers:

Borrowers with High Balance

Borrowers that have

Withdrawn

Financial Aid Awareness Counseling

Understand Income Driven Repayment Plans

Postponement Options Sign-up for Account Access

70

Page 71: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

6 Servicer Role and Relationship Federal Loan Servicers

Servicer Communication Channels for Borrowers: All servicers have toll free numbers for borrowers to

contact (phone, fax, and e-mail) Use IVR (integrated voice response) systems

Allow self-service for those that prefer Make payments over the phone Includes option to speak to a representative

All servicers have a dedicated staff to assist borrowers Financial literacy (online tools and webcasts to help borrowers with

budgeting, managing credit, and loan repayment)

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Default Prevention and Debt Management Strategies

6 Servicer Role and Relationship Federal Loan Servicers

Servicer Counseling – In the Grace Period:

Establishes a relationship with the borrower

Ensures the correct repayment status

Discusses the appropriate repayment plan

Promotes self-service through the web

Updates and enhances borrower contact information

Discusses consolidation options

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Default Prevention and Debt Management Strategies

6 Servicer Role and Relationship School Role

Identifying Students At Risk:

Does your school have an “early warning” system? Take attendance? Issue mid-term grades which provide clues as to whether or

not student will persist? Alerts from faculty members, student support staff: who has

missed classes? failed tests? had adjustment challenges?

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Default Prevention and Debt Management Strategies

6 Servicer Role and Relationship What Schools Can Do While a Borrower is Still In School

Engaging At-Risk Borrowers:

Target at-risk borrowers with early/extra exit loan counseling, financial literacy training, and collect additional contact Information.

Which at-risk borrowers?• Students on academic probation• Students who express intention to withdraw• Students currently enrolled in programs producing a

disproportionate number of defaulters

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Default Prevention and Debt Management Strategies

6 Servicer Role and Relationship What Schools Can Do While a Borrower is In Grace

Engaging At-Risk Borrowers:

Steps to take:• Validate contact information• Re-enrollment assistance• Transfer assistance• Prepare borrower for repayment• Provide employment counseling and search preparation• Job placement assistance• Assist the borrower establish a relationship with their servicer

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Default Prevention and Debt Management Strategies

6 Servicer Role and Relationship What Schools Can Do Once a Borrower is In Repayment

Engaging At-Risk Borrowers:

Reach out to at-risk borrowers and facilitate the critical contact with the loan servicer to prevent default.

• Early Stage Delinquency: Target borrowers 30-120 days delinquent

• Mid Stage Delinquency: Target borrowers 121-240 days delinquent

• Late Stage Delinquency : Target borrowers 241+ days delinquent

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Default Prevention and Debt Management Strategies

6 Servicer and School Partnership Helping Defaulters

When federal student loans default, borrowers are provided with opportunities to clear their credit history. Borrowers with defaulted student loans can regain eligibility for federal student aid and return to good standing with their loan servicer.

What needs to happen: • To regain Title IV eligibility a student must make at least six voluntary

on-time payments for six consecutive months. • To rehabilitate a defaulted loan a student must make at least nine full

voluntary payments within 20 days of their monthly due date over a 10 month period.

• Consolidation is an option to bring the account current, but does not remove the default record from a student's credit report.

• Pay the loan in full.

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Page 78: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Default Prevention and Debt Management Strategies

6 Servicer and School Partnership Helping Defaulters

Benefits of rehabilitating defaulted loans: • Students will regain all benefits such as deferments, forbearance, loan

forgiveness, and repayment options.• Regain eligibility for federal student aid.• Default status will be removed from credit report.• Wage garnishment and withholding of income tax return will cease.

Who to contact: • Debt Management Collection Services (DMCS)

– 1-800-621-3115

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Default Prevention and Debt Management Strategies

6 Servicer Role and Relationship Strategies – Reactive vs. Proactive

Reactive: Challenging the Draft - Incorrect Data Challenge Focused efforts on specific cohort year Late Stage Delinquency

Proactive: Team Approach Campus-wide default prevention effort Default Prevention and Management Plan

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Remember….

Default Prevention & Management

Is Everybody's Business!

Page 80: Session # 79 The Changing Data Landscape of  Cohort Default Rates

Session Agenda

The Landscape

Changes in Cohort Default Regulations

Cohort Default Rate Review

Default Prevention and Debt Management Strategies

The Take-A-Ways

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Page 81: Session # 79 The Changing Data Landscape of  Cohort Default Rates

3 Important Take-a-ways from this Session

(1): Default Prevention is Everybody's Business!Default prevention is a school-wide effort and not the sole responsibility of the

financial aid office.

(2): You NEED DATA!In order to conduct risk analysis and identify your defaulters you need data.

(3): Partner with the Federal Loan Servicers Your default prevention plan should incorporate the products and services offered by

the Federal Loan Servicers. Get to know your servicers!

The Take-A-Ways

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Need Assistance?

FSA – Default Prevention Team

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FSA - Default Prevention Team was created to assist schools with:

Developing / refining their default prevention plan.

Assessing the resources schools have available in order to establish their team.

Understanding default risk through the use of servicer and NSLDS reports and tools.

Please send your request to:

[email protected]

Contact Us!

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Resources

Cohort Default Rate • The Cohort Default Rate Guide

http://www.ifap.ed.gov/DefaultManagement/guide/CDRGuideMasterVersion.html

Delinquency and Default Management• Electronic Announcement – Delinquency Prevention Activities and Webinars

-- Monitor IFAP for updates http://www.ifap.ed.gov/eannouncements/071411DefaultPreventionResourceInfoSite.html

Assessments• FSA Assessments http://

www.ifap.ed.gov/qahome/qaassessments/defaultmanagement.html

Presentations• Federal Loan Servicer Panel Discussion http://ifap.ed.gov/presentations/2012FSAConference.html

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Federal Loan Servicers Borrower Contact #

Aspire Resources Inc. 1-855-475-3335

CornerStone 1-800-663-1662

COSTEP 1-877-292-8639

Direct Loan Servicing Center (ACS) 1-800-848-0979

EDGEucation Loans 1-877-292-7470

EdManage 1-855-479-0490

ESA/Edfinancial 1-855-337-6884

FedLoan Servicing (PHEAA) 1-800-699-2908

Granite State – GSMR 1-888-556-0022

Great Lakes Educational Loan Services, Inc. 1-800-236-4300

KSA Servicing 1-877-292-4825

MOHELA 1-888-866-4352

Nelnet 1-888-486-4722

OSLA Servicing 1-866-264-9762

Sallie Mae 1-800-722-1300

VSAC Federal Loans 1-888-932-5626

Resources – Federal Loan Servicers

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Thank You!

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FSA Contact Information

Patrick Kennedy Phone: 214-661-9480E-mail: [email protected]

Cynthia BattlePhone: 202-377-3261E-mail: [email protected]

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