60D Public Comment Response

U.S. Department of Education / Federal Student Aid
Docket: ED-2019-ICCD-0132 - DCIA Aging and Compliance Data Requirements for Guaranty Agencies
Comment Response
January 13, 2020
No.
1

Comment ID #
ED-2019-ICCD-0132-0004

Comment

FSA Response

The DCIA Aging and Data Requirements for
Guaranty Agencies document appears to use the
term 'debt' and 'loan' interchangeably and provides no
context for these terms.
Recognizing that borrowers in the FFEL program may
have multiple loans, each with unique default claim
paid dates,
could you please provide an answer to the following
questions to clarify the requirements.
1. Does FSA prefer having one delinquency date per
debtor reported, which would be consistent with TOP
reporting requirements?

Yes; the terms “loan” and “debt” are used
interchangeably. However, Footnote 1 on page 5 of
the guidance states the following:
“The aging methodology to follow and consequently
how to age GA-held debt is independently determined
for each individual debt [emphasis added].”
Therefore, the DCIA reporting requirement is that if a
borrower has multiple loans (debt) with varying
delinquency dates, then the GA would age each loan
(debt) based on its respective default claim date.

2. Or, does FSA want to have multiple delinquencies
per debtor reported and placed in different aging
categories depending on default claim paid date?
3. If the preference is for one reported delinquency
date, should the oldest default claim paid date be
used, or the most recent default claim paid date
(consistent with TOP)?

Page 1 of 3

Revision to Guidance Required?
No.

U.S. Department of Education / Federal Student Aid
Docket: ED-2019-ICCD-0132 - DCIA Aging and Compliance Data Requirements for Guaranty Agencies
Comment Response
January 13, 2020
No.
2

Comment ID #
ED-2019-ICCD-0132-0005

Comment

FSA Response

Please provide guidance for determining the age
category for loans reported on MR-32 where
reinsurance has been REQUESTED but NOT YET
REIMBURSED by FSA.
Per the GAFR instruction guide MR-32 should include
FFEL program loans on which claims have been paid
to lenders and reinsurance has been requested by or
paid to the GA (September 2019 GAFR page 67).
The DCIA Aging and Data Requirements for
Guaranty Agencies document instructs GA's to start
aging when FSA reimburses the GA for a paid claim
(DCIA document page 8).

Revision to Guidance Required?

To resolve this issue, FSA has updated the DCIA
Aging and Compliance Data Requirements document
to state that the claim date (rather than the reinsurance
date) should be used with the Date Acquired Aging
Methodology.

Yes; Table 2.3.1 on page 8 has been
updated to reflect that the lender claim
date (not the reinsurance date) should
be used when determining age under
the Date Acquired Aging Methodology.

Additionally, this revision supersedes the response
previously given to Question 24 of the “FSA
Responses to GA Questions” document distributed
after the meeting held on September 18, 2019.

Additional minor revisions were made
to the document’s planned
implementation date, Title IV claim
types table, and glossary.

This difference in reporting instructions will result in
the sum of lines 2-13 not equaling the sum reported
on MR-32 of the GAFR.
A population of loans reported on MR-32 where
reinsurance was requested but not yet reimbursed
will be excluded on the MR-32 Loan Ending Balance
Aging Data Set.

Page 2 of 3

U.S. Department of Education / Federal Student Aid
Docket: ED-2019-ICCD-0132 - DCIA Aging and Compliance Data Requirements for Guaranty Agencies
Comment Response
January 13, 2020
No.
3

Comment ID #
Question Received Via an
Alternate Channel

Comment

FSA Response

In the Aging Data set (MR32 ending balance), we
need to apply one of two methodologies for aging
each loan based on whether collection efforts have
been suspended or not on the loan. We believe we
can accomplish this with our status codes on our
system but we have over 40 status codes that we will
need to categorize as collection efforts suspended or
not. In order to do that, we need to be clear on how
FSA is defining “suspended collection efforts”. The
only thing I can find is in the Q&A document where it
says “collections on a default claim debt are
suspended as required by law regulation and/or
policy”. Is there a definition of suspended collection
efforts in the new GAFR requirements beyond what is
written in the Q&A document that will help us
categorize our status codes?

There are many reasons why a GA would “suspend
collection activity” on a borrower’s account. We have
listed several example events in Footnote 7 (page 9 of
the Data Requirements guidance) that would trigger
the Frozen Aging Methodology. However, it is not a
comprehensive list of all possible events.
GAs should refer to the Federal Register and any other
Department-provided guidance they are required to
follow to ensure compliance with this methodology.
GAs can also contact FSA’s Program Operations
Division for assistance.
Pursuant to 1.1.1 Limited Purpose of this Document,
we are unable to provide operational guidance beyond
the scope of the preparation of the DCIA Compliance
Data Set.

Page 3 of 3

Revision to Guidance Required?
No.