Incorrect Data Challenge Presenter: Thomas Kokis Director of Student Financial Literacy Berkeley College

2 FY Year Draft Cohort Default Rates ED plans to release FY year draft CDRs on February DAYS TO REVIEW FOR TECHNICAL ISSUES 45 day challenge period

3 Challenges Incorrect Data Challenge (IDC) Adjustments Uncorrected Data Adjustment (UDA) New Data Adjustment (NDA) Challenges and adjustments -Challenges are submitted by a school after the release of draft cohort default rates using the Loan Record Detail Report -A successful challenge will “fix” data that was used to calculate rates

4 Focus: lower your CDR eCDR Appeals process overview Remove defaulters: Borrower did not enter repayment for cohort period Remove defaulters: Borrower did not default during cohort period Add borrowers: Other borrowers entered repayment for cohort period

5 Data challenge terms Anticipated Completion Date (ACD) School certifies the loan Last Date of Attendance (LDA) Often not the same as the ACD Date Entered Repayment (DER) Guarantor calculates based on enrollment data Claim Paid Date (CPD) Date loan status becomes default

6 Before you start Required NSLDS access eCDR package and eCDR Appeals login School’s President/CEO letter (Word or PDF format) 45 calendar days to submit Supplementary materials Cohort Default Rate Guide

7 Data challenge in five steps 1.CDR education 2.eCDR package 3.School report (optional) 4.Research borrowers using NSLDS 5.Prepare and submit IDC via eCDR Appeals

8 Step 1: CDR education Data challenge timeline Feb draft rate 45 calendar days official rate Sept submit incorrect data challenge data manager responds 30 business days receive draft 6 business days

9 Step 1: CDR education 2013 three-year CDR timeline Default Sept If 451 borrowers enter repayment in this date range… …and 85 of those default in this range… Repayment 85 (Numerator) 451 (Denominator) = 18.8% three-year CDR

10 Step 2: The Draft CDR Data Files SHDRLROP Cover Letter SHCDRROP Loan Record Detail Report SHCDREOP Extract Record Detail Report * Verify that the overall CDR (Num/Den) on the Letter matches the SHCDRROP (Loan Record Detail Report)

11 Step 3: School report (optional) Add or remove borrowers? There are two ways to lower your default rate Remove defaulted borrowers from the cohort Add non-defaulted borrowers to the cohort Where to start? Consider the following Impact each change makes Divide one by denominator Time constraint (45 days) Available resources Prioritize Example 10/100 = 0.01 * 100 = 10% CDR 1/100 = 0.01 * 100 = 1% impact to CDR 10/111 = 0.09 * 100 = 1% impact to CDR

12 Step 3: School report (add borrowers) Run a school report Last day of attendance between these dates: 2013 three-year cohort: March 30 th 2012 and March 29 th 2013 Compare results with your draft file Research in NSLDS for continuous enrollment If borrower in your school report but not in the draft file with continuous enrollment: add to denominator

13 Step 4: Research borrowers Access NSLDS records Loan summary Loan detail Enrollment detail Determine correct DER Does enrollment reporting support DER? If not, what is the appropriate DER? Would correction change the borrower’s cohort year?

14 Step 4: Research borrowers Determine the cohort year Review the enrollment reporting This is used when calculating the DER LDA + six months grace = DER Cohort yearDER between

15 SF – FFEL Stafford SUB Status: DF as of 05/ COLLEGE NAME HERE – Guaranteed Amt:3,500Disbursed Amt:$1,750OPB:$1,961Agg. OPB:$1,750 Loan Date:07/26/2011Sep. Loan Ind:ALoan Period:08/21/2011 – 05/19/2012 Last Disb. Date:08/11/2011Last Disb. Amt:$1,750Acad. Lv:2 GA:GUARANTOR NAME HERE Servicer:SERVICER NAME HERE Step 4: Research borrowers Status: as of 05/14/ Loan summary Loan Detail DF

16 Step 4: Research borrowers Loan Type:SF – FFEL STAFFORD SUB Loan Period Start:08/21/2011Academic Level:2 Loan Period End:05/19/2012Data Provider Loan ID: Sched. Repayment Date:10/04/2012Separate Loan Ind:A Date of Default for CDR:05/14/2014Delinquency Date:N/A Borrowed at OPEID: Interest Rate:6.8% FIXED Borrowed at Name:COLLEGE NAME HERE Loan detail Details for Loan 1 ? DER CPD

17 Step 4: Research borrowers COLLEGE NAME HERE Reported By StatusEff. DateActiveACDCert. DateCert. Method Date Received School Withdrawn04/03/2012NoN/A04/23/2011School Batch 04/24/2011 School Leave of Absence 10/30/2011No03/15/201502/20/2011School Batch 02/23/2011 School Full Time07/26/2011No03/15/201512/19/2010School Batch 12/21/2010 School Full Time07/26/2011No03/15/201510/24/2010School Batch 10/27/2010 Enrollment detail Data from LRDR file: Default date: 5/14/2014 DER: 10/04/2012 CY: 2013 Correct data: Default date: 5/14/2013 DER: 5/01/2012 CY: 2012

18 Step 5: Prepare and submit IDC eCDR Appeals process All schools must register Create a new profile and obtain login Initiate a new IDC Prepare and submit IDC

19 Step 5: Prepare and submit IDC IFAP—default management

20 Step 5: Prepare and submit IDC eCDR appeals system

21 Step 5: Prepare and submit IDC eCDR Appeals System

22 Data manager’s response DM must respond within 30 days Response to allegations Agree Disagree Will provide supporting documentation Schools receive updates via

23 Note DL servicers Report “technical defaults” to NSLDS at day 270 Actual defaults don’t take place until day 361

eCDR Appeals process overview REGISTER LOG IN CREATE PROFILE SUBMIT IDC REVIEW

25 eCDR process overview School roles Case preparer May initiate and prepare a new case Case manager Has same abilities as a Case Preparer Ability to submit an IDC case

26 Resources Three eCDR Appeal guides IDC user guide UDA user guide NDA user guide Four recorded school trainings Registration for eCDR appeals Preparing and submitting: IDC, NDA and UDA

27 eCDR recorded school trainings Provide name No recording key required

28 eCDR recorded school trainings Provide address and Company/school name

29 eCDR recorded school trainings Select view or download

30 Resources Phone: Website: ifap.ed.gov/DefaultManagement/DefaultManagement.html E-Appeals:

This workshop is intended to be a guide that introduces various personal finance topics. It is not intended to provide financial advice and it is not meant to be professional guidance. Thomas Kokis Director, Student Financial Literacy Berkeley College Financial Awareness Basics (FAB) Thank You! Questions?