30d comment response summary

U.S. Department of Education / Federal Student Aid
Docket: ED-2019-ICCD-0132 - DCIA Aging and Compliance Data Requirements for Guaranty Agencies
Comment Response
March 18, 2020
No.
1

Comment ID #
ED-2019-ICCD-0132-0009

Comment

FSA Response

The following question pertains to the MR-32 and MR41 Loan Ending Balance Disposition Data Set.

Debts in scope as of month-end are reported in the
MR-32 and MR-41 Loan Ending Balance Disposition
Data Set (Disposition Data) based on the actual monthend balance but applying the TOP Referral disposition
“rules/criteria” identified in the most recent weekly TOP
Referral process prior to month-end.

How do GAs account for changes that occur in the
disposition of debts between the date the most recent
weekly TOP referral process is executed to the date
the Monthly Form 2000 is processed?

To account for this timing difference, additional lines
are provided to report debts not in scope at the time of
the last TOP referral (lines 119-121) or for which no
disposition could be identified (lines 122-124).
Changes that occur in the disposition of debts between
the date the most recent weekly TOP referral process is
executed prior to the month-end reporting date, and
current month-end reporting date, are ignored. The
impact of this should be minimal since the number of
intervening days would not be expected to exceed
seven days.

Page 1 of 4

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
March 18, 2020
No.
2

Comment ID #
ED-2019-ICCD-0132-0010

Comment

FSA Response

Part 1:
When a debt transitions from the Date Acquired
methodology to the Frozen methodology how is age
determined? Is it calculated as date GA paid lender to
the date the GA suspends collection efforts?

Under “Frozen Aging” the age of the debt (i.e., number
of days delinquent) is equal to its age per Date
Acquired Aging on the date that the GA suspends
collection efforts.
1) If this is the first suspension of collection efforts,
then days delinquent is equal to:
a) Date GA suspends Collection efforts; MINUS
b) Claim Date

Revision to Guidance Required?
Yes.
Tables 2.3.1. and 2.3.2 (Date Acquired
Aging Methodology and Frozen Aging
Methodology respectively) have been
revised to improve clarity in response to
this question. An aging scenario has
also been included as Appendix B.

2) If this is not the first time that collection efforts have
been suspended, then the number of days that
collections were previously suspended AND Frozen
Aging was applicable, must be subtracted from the
result noted in Calculation 1 above.
2

ED-2019-ICCD-0132-0010

Part 2
When a debt transitions from Frozen back to Date
Acquired how is the age determined? Is if calculated
as current date less date GA paid the lender as
though the frozen period never occurred?

No; if, after a period of Frozen Aging, a GA later
resumes its collection efforts for the default claim debt
(i.e. the debt transitions from Frozen Aging back to
Date Acquired Aging) then Number of Days Delinquent
(i.e. the age of the debt) for DCIA purposes will be
calculated as:
• Current Date
MINUS
• Claim Date
MINUS
• Days in Frozen Aging

Page 2 of 4

Yes.
Table 2.3.1 Date Acquired Aging
Methodology has been revised to
improve clarity in response to this
question.

U.S. Department of Education / Federal Student Aid
Docket: ED-2019-ICCD-0132 - DCIA Aging and Compliance Data Requirements for Guaranty Agencies
Comment Response
March 18, 2020
No.
2

Comment ID #
ED-2019-ICCD-0132-0010

Comment

FSA Response

Part 3:
Is the definition of "Suspended" under the Determining
Age section of the Date Acquired Methodology on
page 8 equivalent to the definition of "Frozen" on page
9? In both situations is accrual of interest and fees
frozen?
When we "suspend" collections interest continues to
accrue but payments are not required. Please confirm
if this debt scenario would require the Frozen Aging
Methodology.

The term “suspended” refers only to whether or not the
GA has suspended its collection efforts and not to
whether or not interest is accrued.
The term “Frozen” is used to define the applicable
DCIA Aging methodology after collection efforts have
been suspended by the GA.
Dollar Value of Delinquency is the accelerated balance
due as of the reporting date.
Business rules as they relate to the accrual of interest
after collection efforts have been suspended are the
responsibility of Program Operations. Questions on this
topic are, therefore, outside the scope of the DCIA
Aging and Compliance Data Requirements document
and should be addressed to Program Operations.

Page 3 of 4

Revision to Guidance Required?
Yes.
Table 2.3.2 Frozen Aging Methodology
has been revised to improve clarity in
response to this question, including the
detail of how the dollar value of
delinquency is determined when
Frozen Aging is applicable.

U.S. Department of Education / Federal Student Aid
Docket: ED-2019-ICCD-0132 - DCIA Aging and Compliance Data Requirements for Guaranty Agencies
Comment Response
March 18, 2020
No.
3

Comment ID #
ED-2019-ICCD-0132-0012

Comment

FSA Response

Will Revenue Procedure 2020-11 have any impact on
the necessity of the MR-24 Collection Termination
Write-Off Data Set requirement?

No; it does not have any impact on the MR-24
Collection Terminations Write-Off Data Set (Write-Off
Data) requirement.
Note, however, that Revenue Procedure 2020-11 may
impact the disposition of a given debt with respect to
the Write-Off Data. For example, if the discharged debt
exceeds $600 and meets the criteria presented in the
Revenue Procedure, the discharged debt will be
exempt from 1099-C reporting in the following calendar
year. It would, therefore, be reported on the following
Data Set lines:
•

Line 2-Collection Terminations Reported During
the Previous Calendar Year; and

•

Line 5-Not Reported to IRS Form 1099-C (Must
Footnote).

Page 4 of 4

Revision to Guidance Required?
No.