Debt Collection Data Requirements for GAs - October 2022

DCIA Aging and Compliance Data Requirements for Guaranty Agencies

Debt Collection Data Requirements for GAs - October 2022

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DCIA Aging and Compliance Data Requirements

for Guaranty Agencies


October 2022













Financial Management Group

Financial Reporting and Analysis Division

























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Table of Contents

  1. Introduction 1

Aging Specifications

  1. DCIA Aging Requirements 5

Data Set Specifications

  1. Preparation of the Data Sets 11

  2. MR-24 Collection Terminations Write-Off Data Set 13

  3. MR-32 Loan Ending Balance Aging Data Set 21

  4. MR-32 & MR-41 Loan Ending Balance Disposition Data Set 25

  5. Submission to FSA 48


Appendixes…………………………………………………………………………………………………………….50

Appendix A – Sample GAFR / ED Form 2000 A

Appendix B – Presentation of MR-32 & MR-41 Loan Ending Balance Disposition Data Set in Microsoft Excel Format B

Appendix C – Mapping GA TOP Referral Business Rules to MR-32 & MR-41 Loan Ending Balance Disposition Data Set Lines C

Appendix D – Guaranty Agency List D

Appendix E – Glossary of Acronyms E




Version Control

Version

Author

Date

Changes

1.0

C. Alsop

10/02/2019

Approved by FSA and released for PRA clearance

1.1

C. Alsop

1/13/2020

Updated planned implementation date, Date Acquired Aging Methodology table, Title IV claim types table, and glossary

1.2

C. Carleton

10/5/2022

Minor edits; updated GA and FSA contacts


    1. Introduction

Federal Student Aid (FSA) uses data supplied by its loan servicers to satisfy mandatory and ad- hoc debt collection reporting requirements related to receivables due from the public. FSA is required to submit receivable information to the United States Department of the Treasury (Treasury), the Office of Management and Budget (OMB), and the Chief Financial Officers’ Council (CFOC).


Treasury, OMB, and the CFOC use receivable financial data to:

  • monitor the effectiveness of government-wide receivable management processes via performance metrics;

  • improve data transparency by publicly releasing agency receivable data on a quarterly basis; and

  • inform the United States Congress (Congress) annually of agency debt collection regulation compliance as required by the Debt Collection Improvement Act of 1996, as amended (DCIA).


    1. Purpose

The purpose of this document is to:

  • communicate debt aging requirements per DCIA;

  • capture detailed information pertaining to the status and collection of Federal Family Education Loan (FFEL) Program loans authorized by the Higher Education Act of 1965, as amended (HEA) and defined by Title IV of the HEA (Title IV) that is not currently available via the Guaranty Agency Financial Report (GAFR) (also known as the ED Form 2000);

  • enable FSA to report complete and accurate data to Treasury, as required; and

  • permit FSA to monitor Guaranty Agency (GA) compliance with DCIA.


      1. Limited Purpose of this Document

This specification document requires the GAs prepare three individual Data Sets, collectively called the DCIA Aging and Compliance Data Set (DCIA Compliance Data Set). To prepare the DCIA Compliance Data Set, this document references accounting transactions and GA-specific operational requirements (i.e., the GAFR, Internal Revenue Service (IRS) Form 1099-C reporting, etc.). Any references are solely intended to facilitate the GA’s efforts to prepare a compliant DCIA Data Set and are not intended to provide requirements beyond the scope of preparing the DCIA Compliance Data Set.


      1. Points of Contact for Technical Questions

Post-implementation, please submit any technical questions about these requirements via email to the following email addresses:

To: FSAFinancePortfolio@ed.gov CC: callis.carleton@ed.gov


To facilitate identification, please enter “DCIA Compliance Technical Question” in the email subject line.


    1. Scope

The scope of this requirements document is the DCIA-specific aging and compliance data requirements. The scope of each of the three Data Sets is discussed later in this document. The three Data Sets are:


  • MR-24 Collection Terminations Write-Off Data Set

  • MR-32 Loan Ending Balance Aging Data Set

  • MR-32 & MR-41 Loan Ending Balance Disposition Data Set


      1. Scope Limitations

The guidance contained in this document is based upon FSA’s policies and business processes as of the date of this document, unless otherwise noted. Any future revision to FSA’s policies and/or business processes may require FSA to update and reissue these requirements.


    1. Frequency

GAs must prepare and submit the individual Data Sets on a monthly or annual basis as follows:


Table 1.3 Data Set Frequency


Data Set

Frequency

MR-24 Collection Terminations Write-Off Data Set (Write-Off Data)

Annually

MR-32 Loan Ending Balance Aging Data Set (Aging Data)

Monthly

MR-32 & MR-41 Loan Ending Balance Disposition Data Set (Disposition Data)

Monthly


    1. Document Organization

This document is organized into the following sections:


Table 1.4 Organization of Requirements Document


Section

Section Description

1.0

Introduction: This section provides an overview of the purpose, scope, and frequency requirement for the reports listed in this document.

Aging Specifications

2.0

DCIA Aging Requirements: This section summarizes the DCIA- compliant aging methodologies applicable to Title IV debt held by GAs.

Data Set Specifications

3.0

Preparation of the Data Sets: This section provides important information necessary to prepare the DCIA Compliance Data Set.

4.0 through 6.0

DCIA Compliance Data Set Specifications: These sections provide details regarding each Data Set’s purpose, scope, frequency, and layout. Line-by-line instructions and a presentation view of the Data Set are also included in each section.

7.0

Submission to FSA: This section explains how to package the files for submission to FSA.

Appendixes

A

This appendix presents an example of an approved GAFR.

B

This appendix presents an example of the Disposition Data Set when uploaded to Microsoft Excel.

C

This appendix provides a mapping of GA TOP Referral Business Rules to the Disposition Data Set lines.

D

This appendix lists active GAs by their GA codes.

E

This appendix lists commonly used acronyms referenced throughout this document.

























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    1. DCIA Aging Requirements

    2. Background

This section describes the compliant methodologies for aging Title IV loan debt for DCIA purposes1. This section also explains how to determine a loan’s eligibility for referral to the Treasury Offset Program (TOP) based upon the loan’s age of delinquency (i.e., greater than 120 days delinquent). This section also explains how to age DCIA-aged debt in accordance with the United States Department of Education (the Department) and Treasury’s Office of General Counsel (OGC) guidance. The methodology described in this section is independent of the methodologies followed to age debt for other purposes including for Title IV. As such, this guidance is not intended to revise or replace any of other aging methodologies the GAs are required to follow.


    1. Definitions of Key DCIA-Related Terms

Listed below are key DCIA-related terms used later in this section and throughout this document. To facilitate identifying these terms, all key terms are capitalized.


  • DCIA Aging Methodology for Title IV Loan Debt: The methodology to age Title IV loan debt for DCIA purposes including determining a debt’s eligibility for referral to TOP based upon its age. Section 2.3 of this document includes a full description of the DCIA Aging Methodologies including: 1) criteria for identifying debt to apply the methodology, 2) methodology for determining debt age in number of days, 3) methodology for calculating dollar amount to report, and 4) criteria for transitioning to another aging methodology.


  • Title IV Default: Per Title IV, a loan enters default if the loan exceeds 270 days of delinquency. 2 Based upon existing business processes, all Title IV debt held and serviced by a GA is in Title IV Default.
















1 The aging methodology to follow and consequently how to age GA-held debt is independently determined for each individual debt.

2 20 U.S.C. 1085(l)


  • Title IV Claim Types: Per Title IV, a GA can request reimbursement from FSA for Defaults and other FFEL Program claims it paid to lenders. Claims paid to lenders and included in the federal receivable3 are aged. Claims paid to lenders and not included in the federal receivable are not aged and, as a result, neither of the two GA-applicable DCIA Aging Methodologies are applicable.






Title IV Claim Types

Included

in the Federal Receivable and Aged for DCIA

Not Included

in the Federal Receivable and Not Aged for DCIA

  • Defaults

  • Death/Disability4

  • Exempt/Lender-of-Last- Resort (LLR)

  • Closed School/False Certification


  • Bankruptcy


  • Unpaid Refunds


  • Other Discharges5



    1. DCIA Aging Methodologies Applicable to GAs

Per DCIA, there are two distinct aging methodologies applicable to GAs. The appropriate methodology is determined by the Title IV Claim Type of the debt (i.e., Defaults, Exempt/LLR are included in the federal receivable and aged; all other claim types are not included in the federal receivable nor aged).


The remainder of this section describes each of the two DCIA aging methodologies in more detail. Note, per DCIA, there are only two possible DCIA Delinquency Statuses – Current or Delinquent. Based upon existing business processes, debt held by a GA is always “delinquent” for DCIA purposes.












3 The federal receivable is defined as the amount reported on MR-32 Ending Balance of Defaulted Loans. The amount reported on MR-32 is reported on FSA’s financial statements.

4 Disability claims are also called Total and Permanent Disability Discharge (TPD Discharge) claims.

5 Other discharges include Teacher Loan Forgiveness Program discharges and partial discharges of consolidation loans.


Figure 1 - Relationship between DCIA Aging Methodologies for Debt Held by GAs


      1. Date Acquired Aging

For DCIA purposes, a debt in the Default Title IV Loan Status should be aged using the Date Acquired Aging Methodology unless the Frozen Aging Methodology is triggered.

The following table describes the Date Acquired Aging Methodology.


Shape17 Table 2.3.1 Date Acquired Aging Methodology



Date Acquired Aging Methodology

Applicability and Criteria

Applicable for Title IV

Claim Types

  • Defaults

  • Exempt/LLRs

Criteria to Start Aging Methodology:

  • Default claim debt acquired by FSA via the FFEL claim process (i.e., GA pays a lender’s default claim).

Methodology

Determining Age

  • Number of days delinquent (i.e., delinquency) equals current date less date the GA paid the lender’s claim (claim date). (Note: If collection on a default claim is suspended, aging should resume from the date the GA restarts its

collection efforts.)

Valid DCIA

Delinquency Status(es)

  • Delinquent6

Determining Dollar Value of Delinquency

  • Dollar value of delinquency is the accelerated full balance due including principal, interest, and fees.

Transition to Another DCIA Aging Methodology

Aging Methodology

and Criteria for Switching:

  • Frozen Aging – Collections on a default claim debt are suspended as required by law, regulation, and/or policy.















6 “Delinquent” is the only valid DCIA Delinquency Status for this aging methodology because based upon existing business processes, all Title IV debt held by GAs is delinquent.


      1. Frozen Aging

For DCIA purposes, a debt in the Default Title IV Loan Status should be aged using the Frozen Aging Methodology unless the Date Acquired Aging Methodology is triggered. This methodology should be followed for the duration of the event that triggered the suspension of collection efforts and froze the age of the debt.


The following table describes the Frozen Aging methodology.


Shape19 Table 2.3.2 Frozen Aging Methodology





Frozen Aging Methodology

Applicability and Criteria

Applicable for Title IV

Claim Types

  • Defaults

  • Exempt/LLRs

Criteria to Start Aging Methodology:

  • GA suspends collection efforts for a default claim debt as required by law, regulation, and/or policy.7

Methodology

Determining Age:

  • Age of debt is frozen as of the date the loan entered the Frozen Aging Methodology.

Valid DCIA

Delinquency Status(es):

  • Delinquent8

Determining Dollar Value of Delinquency:

  • Dollar value of delinquency is the accelerated full balance due as of entering the Frozen Aging Methodology (since the accrual of interest and fees is also frozen).

Transition to Another DCIA Aging Methodology

Aging Methodology and Criteria for

Switching:

  • Date Acquired Aging – For default claim debt, the GA resumes collection efforts.











7 Events that may warrant suspended collections include a defaulted debt meeting the criteria for the military deployment benefit, pending discharge due to death, pending discharge due to TPD, and bankruptcy stay/hold.

8 Delinquent” is the only valid DCIA Delinquency Status for this aging methodology because based upon existing business processes, all Title IV debt held by GAs is delinquent.

























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    1. Preparation of the Data Sets

    2. Common Requirements

Sections 4.0–6.0 provide line-by-line instructions explaining the specific information required for each Data Set requirement. Appendixes B and C contain supplemental information which should be used when developing and preparing the Disposition Data.



      1. Common Requirements

The collective DCIA Compliance Data Set must comply with the requirements listed below.


Table 3.1.1 Common Requirements for the DCIA Compliance Data Set


Common Requirements

1.

Report “Number” as the quantity of debts (i.e., number of loans).

2.

Report “Dollars” as the sum of all amount types (i.e., principal, interest, and other fees9, if applicable) that result in activity or a balance.

3.

Sum all activity and balances for a line. If the total results in a debit balance, report the amount as positive. If the total results in a credit balance, report the amount as negative.

4.

Do not use commas for amounts that have four or more digits. For example,

$2,758.39 should be entered as 2758.39; 1,078 debts should be entered as 1078.

5.

Enter all dollar amounts rounded to the nearest cent/penny. Enter all debt quantities as whole numbers without cents/pennies.

6.

Enter a debt number of “0” and dollar amount of “0.00”, unless otherwise stated, if there are no debts that meet the reporting requirements for a given line.

7.

Do not password protect report files unless required to by FSA or your agency’s data protection policies (i.e., because the files contain personally identifiable information or sensitive data).

8.

Submit each data requirement as a Comma-Separated Value [Comma Delimited] (CSV) file and follow the layout specified.










9 Examples of possible other fees include late charges, collection costs, and attorney’s fees.


    1. Section Outline

Each Data Set requirement section follows a consistent outline or format. Specifically, each requirement contains the following sections:

  • Purpose

  • Scope

  • Frequency

  • A high-level overview/summary of the Data Set requirement

  • Line-by-line instructions

  • A presentation of the Data Set in Microsoft (MS) Excel format.


    1. File Layout Requirement

Each Data Set requirement references the following file layout terms:



File Layout Term

Description

Data Element Name

Required field (or “column”) name

Line Name

Required line (or “row”) name

Portfolio Data

Loan data that meets the criteria for each Line Name (i.e., Number and Dollars values reflected in the GA’s system of record)

Identifier Data

GA Code and Reporting Period information required for each line


The specific requirements for each report’s Data Element Names, Line Names, Portfolio Data, and Identifier Data are described in the following sections. GAs should follow the file layout requirement presented for each Data Set requirement as it will ensure that FSA will be able to consolidate data received from multiple GAs across multiple periods of time.


The remainder of this document and the examples presented will focus on a fictitious GA (i.e., GA 999) and its DCIA Compliance Data Set submission for the month-ending March 31, fiscal year (FY) 2020.


    1. MR-24 Collection Terminations Write-Off Data Set

    2. Purpose

The MR-24 Collections Terminations Write-Off Data Set (Write-Off Data) is required in order to monitor GA compliance with IRS Form 1099-C reporting.


    1. Scope

The scope of the data is debt reported on GAFR line MR-24 Collection Terminations during the previous calendar year (CY) (i.e., January through December).


Shape22 Table 4.2 Reporting Period Scope of Collection Terminations



Current Reporting Period


Reporting Period Scope of Collection Terminations to Report

(I.E., Previous Calendar Year)


FY


Quarter

Reporting Cycle Calendar Month/Year


FY 2023

Q1

October

2022



Collection terminations reported during the previous CY (i.e., 2021).

November

2022

=

December

2022


Q2

January

2023







Collection terminations reported during the previous CY (i.e., 2022)*.

February

2023


March

2023


Q3

April

2023


May

2023

=

June

2023


Q4

July

2023


August

2023


September

2023


* Per IRS requirements, if filing electronically, reporting entities must submit Form 1099-C to the IRS by the end of March immediately following the end of the CY being reported (i.e., Form 1099-Cs for collection terminations reported during calendar 2022 should be submitted to the IRS by March 2023).


    1. Frequency

Each GA must prepare Write-Off Data annually. Per IRS requirements, electronically filed Form 1099-Cs are due by the end of March immediately following the end of the CY being reported. Therefore, in accordance with the IRS’ March 31st deadline for electronically filed Form 1099-Cs, Write-Off Data is due to FSA in the following month (i.e., in April of each year).


    1. Overview of Data Set Requirement

The Write-Off Data Set captures information related to activity reported on MR-24 during the previous CY and allocates it by disposition type (i.e., reported to the IRS, not reported to the IRS because the amount was less than $600, and not reported to the IRS for other reasons). The Write-Off Data is reported to FSA via the following Data Elements:


      • Disposition status (i.e., line name)

      • Number

      • Dollars

      • GA code

      • Calendar year.


    1. Data Set Requirements

Line 1 - Data Element Names

Report the five required Data Element Names as shown in the table below.


Data Element


Data Element Name

1

DISPOSITION_OF_COLLECTION_TERMINATIONS

2

NUMBER

3

DOLLARS

4

GA_CODE

5

CALENDAR_YEAR


Line 1 should display as follows:



Line 2 - Collection Terminations Reported During the Previous Calendar Year

Report the total collection terminations reported on MR-24 during the previous CY.

The table below lists the Data Elements and criteria to report.


Data Element

Criteria

Example

DISPOSITION_ OF

_COLLECTION

_TERMINATIONS

Line Name

Report “Collection Terminations Reported During the Previous Calendar Year”.

NUMBER

Number (i.e., quantity of debts) that meets the scope of the line.

If 5,478 loans meet the criteria for this line, report the value as “5478”.

DOLLARS

Dollar (i.e., debt/loan amount) value that meets the scope of the line.

If $879,652.15 meets the criteria for this line, report the value as “879652.15”.

GA_CODE

3-digit GA Code

Report “999”.

CALENDAR_YEAR

4-digit CY

Report “2019”.




Note About Line 2 Collection Terminations Reported During the Previous Calendar Year

Line 2 serves as a control and must agree to the sum of principal, interest and other amounts for the preceding 12-month CY as reported on GAFR line MR-24. If a GA submits this Data Set and Row 2 does not agree to the preceding 12-month CY MR-24 total, FSA will reject the GA’s submission and return it for correction.



Line 2 should display as follows:



Line 3 - Reported to IRS on Form 1099-C

Report the amount of total collection terminations reported on MR-24 during the previous CY (i.e., reported on Line 2) and reported to the IRS via Form 1099-C.

The table below lists the Data Elements and criteria to report.


Data Element

Criteria

Example

DISPOSITION_ OF

_COLLECTION

_TERMINATIONS

Line Name

Report “Reported to IRS on Form 1099-C”.

NUMBER

Number (i.e., quantity of debts) that meets the scope of the line.

If 72 loans meet the criteria for this line, report the value as “72”.

DOLLARS

Dollar (i.e., debt/loan amount) value that meets the scope of the line.

If $24,893.54 meets the criteria for this line, report the value as “24893.54”.

GA_CODE

3-digit GA Code

Report “999”.

CALENDAR_YEAR

4-digit CY

Report “2022”.


Line 3 should display as follows:



Line 4 - Not Reported and Eligible for 1099-C but Not Required (Less than $600)

Report the amount of total collection terminations reported on MR-24 during the previous CY (i.e., reported on Line 2) that were eligible for 1099-C reporting but were not reported to the IRS via Form 1099-C.

The table below lists the Data Elements and criteria to report.


Data Element

Criteria

Example

DISPOSITION_ OF

_COLLECTION

_TERMINATIONS

Line Name

Report “Not Reported and Eligible for 1099-C but Not Required (Less than $600)”.

NUMBER

Number (i.e., quantity of debts) that meets the scope of the line.

If 10 loans meet the criteria for this line, report the value as "10”.

DOLLARS

Dollar (i.e., debt/loan amount) value that meets the scope of the line.

If $5,789.87 meets the criteria for this line, report the value as “5789.87”.

GA_CODE

3-digit GA Code

Report “999”.

CALENDAR_YEAR

4-digit CY

Report “2022”.


Line 4 should display as follows:



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

Subtract Line 3 and Line 4 from Line 2.

The table below lists the Data Elements and criteria to report.



Data Element

Criteria

Example

DISPOSITION_ OF

_COLLECTION

_TERMINATIONS

Line Name

Report “Not Reported to IRS on Form 1099-C (Must Footnote)”.

NUMBER

The balance remaining after subtracting the Number value of Line 3 and Line 4 from Line 2.

Report the Numbers result of subtracting Line 3 and Line 4

from Line 2 (i.e., 5,396) as

“5396”.

DOLLARS

The balance remaining after subtracting the Dollars amount of Line 3 and Line 4 from Line 2.

Report the Dollars result of subtracting Line 3 and Line 4 from Line 2 (i.e., $84,8968.74) as “848968.74”.

GA_CODE

3-digit GA Code

Report “999”.

CALENDAR_YEAR

4-digit CY

Report “2022”.


Shape23

Note About Line 5 Not Reported to IRS on Form 1099-C

Line 5 should represent collection terminations from the prior CY that were not reported to the IRS on Form 1099-C due to reasons other than being less the $600. The reason(s) for not reporting to the IRS debt included on this line must be explained in a separate footnote. The explanation can be included in the body of the submission email or added as a separate MS Word file attachment. See Section 7.0 Submission to FSA for more information.



Line 5 should display as follows:



    1. File Naming

The GAs should use the following file naming configuration.


Table 4.6 Write-Off Data File Naming Configuration

Required File Naming Configuration

Example

yyyymm-WOFF-ccc

Where

  • “yyyy” = 4-digit fiscal reporting year

  • “mm” = 2-digit fiscal reporting month

  • “WOFF” = data set short name

  • “ccc” = 3-digit GA code

GA 999 will name the CSV or text file for Write-Off Data as of March 31, 2023 as follows:

  • 202306-WOFF-999.csv


    1. Presentation

If the Write-Off Data Set is prepared correctly, when uploaded to MS Excel or MS Access, the Data Set will display as shown:




Shape24

Note About Abnormal Balances

The expected sign for all debt quantities and dollar amounts for this Data Set is positive. Any abnormal balances must be researched and explained. The explanation can be included in the body of the submission email or added as a separate MS Word file attachment. See Section 7.0 Submission to FSA for more information.


























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    1. MR-32 Loan Ending Balance Aging Data Set

    2. Purpose

The MR-32 Loan Ending Balance Aging Data Set (Aging Data) is required in order to age debt per DCIA and to facilitate determining a debt’s eligibility for TOP referral.


    1. Scope

The scope of the data is debt reported on GAFR line MR-32 Ending Balance of Defaulted Loans as of fiscal month-end.


    1. Frequency

Each GA must prepare the Aging Data as of each fiscal month-end for which it also prepares a GAFR report (i.e., monthly).


    1. Overview of Data Set Requirement

The Aging Data captures additional information related to the ending balance of defaulted debt reported on MR-32. The debt is aged per the applicable DCIA aging methodologies (see Section 2.0) and grouped into categories based on the number of days the debt is delinquent. The Aging Data is reported to FSA via the following Data Elements:


      • Aging category (i.e., days delinquent)

      • Number

      • Dollars

      • GA code,

      • Fiscal year

      • Fiscal month


    1. Data Set Requirements

Line 1 - Data Element Names

Report the six required Data Element Names as shown in the table below.


Data Element


Data Element Name

1

AGING_CATEGORY

2

NUMBER

3

DOLLARS


Data Element


Data Element Name

4

GA_CODE

5

FISCAL_YEAR

6

FISCAL_MONTH


Line 1 should display as follows:



Line 2–13 - Debt by Age of Delinquency

Report the quantity of debts and loan ending balance by the age category10.


The required Line Names are the aging categories listed in the table below. The categories are listed by line number.


Line

AGING_CATEGORY

2

1–30 Days Delinquent

3

31–60 Days Delinquent

4

61–90 Days Delinquent

5

91–120 Days Delinquent

6

121–150 Days Delinquent

7

151–180 Days Delinquent

8

181–270 Days Delinquent

9

271–365 Days Delinquent

10

1–2 Years Delinquent

11

2–6 Years Delinquent

12

6–10 Years Delinquent

13

Over 10 Years Delinquent







10 The loan ending balance is derived from the GA’s system of record and corresponds to the balance the GA reported on GAFR line MR-32 as of the month-end reporting date.



Note About Aging Categories

FSA customized the age categories for the Aging Data Set to reflect unique requirements of HEA Title IV debt. Specifically, FSA segregated the age categories into 30-day increments to allow breaks at 120, 180, and 270 days delinquent.


As an example, the table below lists the Data Elements and criteria to report for Line 2, 1–30 Days Delinquent. Note: Lines 3–13 would follow the same format.


Data Element

Criteria

Example

AGING_CATEGORY

Debt that is 1 to 30 days delinquent.

Report “1-30_DAYS_DELINQUENT”.

NUMBER

Number (i.e., quantity of debts) that meets the scope of the line.

If 5,742 loans meet the criteria for this line, report the value as “5742”.

DOLLARS

Dollar (i.e., debt/loan amount) value that meets the scope of the line.

If $800,457.00 meets the criteria for this line, report the value as “800457.00”.

GA_CODE

3-digit GA Code

Report “999”.

FISCAL_YEAR

4-digit FY

Report “2020”.

FISCAL_MONTH

2-digit fiscal month

Report “06”.


Line 2 should display as follows:




Note About Lines 2–13

The sum of the total Dollars value of Lines 2–13 must equal the Dollars value reported on MR-32 of the GAFR. If a GA submits this Data Set and the total of these lines does not equal MR-32, FSA will reject the GA’s submission and return it for correction.


    1. File Naming

The GAs should use the following file naming configuration.


Table 5.6 Aging Data File Naming Configuration

Required File Naming Configuration

Example

yyyymm-AGNG-ccc

Where

  • “yyyy” = 4-digit fiscal reporting year

  • “mm” = 2-digit fiscal reporting month

  • “AGNG” = data set short name

  • “ccc” = 3-digit GA code

GA 999 will name the CSV for Aging Data as of March 31, 2023 as follows:

  • 202306-AGNG-999.csv


    1. Presentation

If the Aging Data Set is prepared correctly, when uploaded to MS Excel or MS Access, the data will display as shown:


Shape26

Note About Abnormal Balances

The expected sign for all debt quantities and dollar amounts for this Data Set is positive. Any abnormal balances must be researched and explained. The explanation can be included in the body of the submission email or added as a separate MS Word file attachment. See Section 7.0 Submission to FSA for more information.




    1. MR-32 & MR-41 Loan Ending Balance Disposition Data Set

    2. Purpose

The MR-32 & MR-41 Loan Ending Balance Disposition Data Set (Disposition Data) is needed to monitor GA compliance with DCIA TOP Referral reporting.


    1. Scope

The scope of the data is debt reported on GAFR lines MR-32 Ending Balance of Defaulted Loans and MR-41 Ending Balance on Bankruptcies as of the fiscal month-end.


    1. Frequency

Each GA must prepare the Disposition Data as of each fiscal month-end for which it also prepares a GAFR report (i.e., monthly).


    1. Overview of Data Set Requirement

The Disposition Data captures the combined debt quantities and loan ending balances from the GA’s system of record that correspond to the balances the GA reported on GAFR lines MR-32 and MR-41 as of the same month-end. It summarizes and reports amounts according to the disposition of these debts in the most recent (weekly) TOP referral process executed by the GA before month-end (TOP Referral Process Disposition) and further classifies them by Delinquency Group.

The Disposition Data is reported to FSA via the following ten Data Elements:


Line Name

      1. Line prefix

      2. Line suffix

      3. BizOps number

      4. Line short name

      5. Delinquency group

Portfolio Data

      1. Number

      2. Dollars

Identifier Data

      1. GA code

      2. Fiscal year

      3. Fiscal month


Each debt is mapped to the Disposition Data based on its TOP Referral Process Disposition as identified by the most recent (weekly) TOP referral process executed prior to month-end for the reporting period and is reported on one line only. Data Elements 1–4 collectively identify each


unique TOP Referral Process Disposition reportable as of month-end, while Data Element 5 further classifies the identified debt quantities and dollar amounts into one of three delinquency groups (1-120 days delinquent, 121-180 days, or > 180 days delinquent) using the DCIA Aging methodology described in Section 2.0 of this document. As a result, each TOP Referral Process Disposition is mapped to three consecutive lines ordered by delinquency group. The unique set of values on each line in Data Elements 1–5 comprise the Line Name and provide the reporting scope criteria for the Portfolio Data elements NUMBER and DOLLARS as of the reporting date.

Shape27 Shape28

Value

Definition

Purpose

a

Certified AND Active






Identifies the disposition of debts (within scope as of the reporting date) in the most recent (weekly) GA TOP Referral Process.

b

Not Subject to TOP

c

Due Process Pending Completion

d

Excluded/Inactivated via DCIA Compliant Exclusion

e

Excluded/Inactivated via FSA business rule exception

f

Debt Rejected by Treasury and temporarily excluded

g

Debt excluded via FSA Temporary Generic Hold11

h

Debt excluded via FSA’s Unenforceable Debt Discharge business process12

i

Debt not referred/inactivated that did not meet the requirements to report in any prior category

Identifies debts within scope as of the reporting date, not previously reported.


























The ten Data Elements that make up the Disposition Data have the following definitions:


Data Element


Data Element Name


Data Element Definition

1

LINE_PREFIX

1-character code (“a” through “i”) assigned by FSA to group reported portfolio data into one of nine categories as follows:




11 Category not applicable to GAs

12 This policy exemption is tracked as a separate category in DMCS; in the GA Disposition Data it is included in section “e” with all the other identified TOP referral business rule exemptions.


Data Element


Data Element Name


Data Element Definition

2

LINE_SUFFIX

3-digit code (“000”–“999”)13 assigned by FSA to identify the reporting sequence of each reporting line short name within each “LINE_PREFIX” report category.

3

BIZOPS_NO

3-digit code (“001”–“999” or “N/A” (Not Applicable)) assigned by FSA to identify the TOP Referral Exclusion/ Exception/Instruction business rule and definition per Appendix C that defines the debt to be reported on the line, based on debt’s disposition in the most recent weekly TOP referral. Appendix C maps each FSA TOP Referral business rule to the corresponding Disposition Data line number. Leading zeros are added to the FSA TOP Referral BizOps Number to produce the corresponding three-digit BIZOPS_NO code.

E.g., “1” becomes “001”, “10” becomes “010”, etc.

If debt was not excluded from TOP referral based on an FSA business rule (e.g., because debt WAS referred, or debt was not in portfolio at time of last TOP referral, etc.) then no business rule is applicable and “N/A” is entered in this field.

4

LINE_SHORT_NAME

Text required by FSA that briefly describes the disposition post-TOP referral of debt to be reported on the line.



















13 The Disposition Data Set format is designed to facilitate FSA’s consolidation of data received from GAs and DMCS into one data set for analysis. The DMCS-only reporting categories in the Data Elements BIZOPS_NO, LINE_PREFIX, and LINE_SUFFIX have been omitted, resulting in gaps in the sequence numbers

Shape31

Permitted value

Definition

1–120_DAYS

At least one*, but no more than 120 days delinquent

121–180_DAYS

At least 121, but no more than 180 days delinquent

OVER_180_DAYS

More than 180 days delinquent



Data Element


Data Element Name


Data Element Definition

5

DELINQUENCY_GROUP

One of three delinquency categories that describe, as of the reporting month-end date, the number of days the debt reported on the line is delinquent, per DCIA- compliant aging (as described in Section 2.0 of this document).









*If a debt is acquired via a FFEL default claim on the month- end reporting date, then its calculated age will be zero days delinquent. However, since ALL debts acquired via a default claim are considered delinquent from the moment of acquisition, such debts must be reported in the “1-120_DAYS” delinquency group.



Note: The aging methodology used for the Disposition Data is identical to that used for the Aging Data, except that for the Disposition Data all debts are aggregated into one of only three delinquency groups.

6

NUMBER

Number (i.e., quantity of debts) that meets the scope of the line as defined by the Line Name, as of the reporting date.

7

DOLLARS

Dollar (i.e., debt/loan amount) value that meets the scope of the line as defined by the Line Name.

8

GA_CODE

3-digit GA Code

9

FISCAL_YEAR

4-digit FY

10

FISCAL_MONTH

2-digit fiscal month


    1. Data Set Requirements

Line 1 - Data Element Names

Report the ten required Data Element Names as shown in the table below.



Data Element


Data Element Name

1

LINE_PREFIX

2

LINE_SUFFIX

3

BIZOPS_NO

4

LINE_SHORT_NAME

5

DELINQUENCY_GROUP

6

NUMBER

7

DOLLARS

8

GA_CODE

9

FISCAL_YEAR

10

FISCAL_MONTH


Line 1 should display as follows:



For the Disposition Data lines 2–124, the Identifier Data elements will have identical values on every line for each GA in any given reporting period. If GA 999 prepared Disposition Data as of March 31, 2023, it would report the following values on every line:



Identifier Data Element

Criteria

Example

GA_CODE

3-digit GA Code

Report “999”.

FISCAL_YEAR

4-digit FY

Report “2023”.

FISCAL_MONTH

2-digit FY month

Report “06”.


Therefore, the remainder of this section omits the above-mentioned Data Elements from the tables presented.


Note About the Disposition Data Line Name Values

The Disposition Data format is designed to facilitate FSA’s consolidation of data received from GAs and DMCS into one data set for analysis. The DMCS-only reporting categories for the Data Elements BIZOPS_NO, LINE_PREFIX, and LINE_SUFFIX, have been omitted, resulting in gaps in the sequence numbers.

Shape32


Lines 2–4: Debt Certified and Active

Report on each line (as Number and Dollars respectively) the combined debt quantities and loan ending balances from the GA’s system of record that correspond to the balances the GA reported on GAFR lines MR-32 and MR-41 as of the month-end reporting date that, based on the most recent weekly TOP Referral prior to the reporting month-end, have a TOP Referral Process Disposition “Debt Certified and Active” AND meet the line’s DELINQUENCY_GROUP criteria. If GA 999 identified the following debt:






Line

Debt in Scope on Reporting Date with TOP Referral Process Disposition:

“Debt Certified and Active”

Line Name

Portfolio Data

LINE_ PREFIX

LINE_ SUFFIX

BIZOPS

_NO

LINE_ SHORT_NAME

DELINQ- UENCY_

GROUP


NUMBER


DOLLAR

2

a

10

N/A

Debts Certified

and Active

1-120

_DAYS

207

55,700.56

3

a

10

N/A

Debts Certified

and Active

121-180

_DAYS

3,008

1,815,062.46

4

a

10

N/A

Debts Certified

and Active

OVER_180

_DAYS

1,012

9,999,950.12


Based on the criteria above, the sample Lines 2–4 would display as follows:



Lines 5–118: Debt Not Certified/Inactivated Based on TOP Referral Business Rule

Report on each line (as Number and Dollars respectively) the combined debt quantities and loan ending balances from the GA’s system of record that correspond to the balances the GA reported on GAFR lines MR-32 and MR-41 as of the month-end reporting date for any debts NOT “Certified and Active” (or, if previously certified, inactivated) because, based on the most recent weekly TOP Referral prior to the reporting month-end, they have a TOP Referral Process Disposition that meets the requirements of the FSA TOP Referral business rule in Appendix C that maps to the line’s required BIZOPS_NO value AND meet the line’s DELINQUENCY_GROUP criteria. If GA 999 identified the following debt:







Line

Debt in Scope on Reporting Date with TOP Referral Process Disposition:

“Debt Not Certified/Inactivated Based on TOP Referral Business Rule”

Line Name

Portfolio Data

LINE_ PREFIX

LINE_ SUFFIX

BIZOPS

_NO

LINE_ SHORT_NAME

DELINQ-

UENCY_ GROUP


NUMBER


DOLLAR

5

b

10

1

Zero Balance

(Closed) Debts

1-120

_DAYS

2

-

6

b

10

1

Zero Balance

(Closed) Debts

121-180

_DAYS

-

-

7

b

10

1

Zero Balance

(Closed) Debts

OVER_180

_DAYS

-

-

8

b

20

53

Credit Balance

Debts

1-120

_DAYS

3

(2,000.22)

9

b

20

53

Credit Balance

Debts

121-180

_DAYS

-

-

10

b

20

53

Credit Balance

Debts

OVER_180

_DAYS

-

-

11

b

30

2

Debts 0-120 days delinquent per

65DN Agreement

1-120

_DAYS

8,115

805,847.47

12

b

30

2

Debts 0-120 days

delinquent per 65DN Agreement

121-180

_DAYS

-

-

13

b

30

2

Debts 0-120 days

delinquent per 65DN Agreement

OVER_180

_DAYS

-

-

14

c

10

24

Due process not initiated (Awaiting Treasury

Address)

1-120

_DAYS

-

-






Line

Debt in Scope on Reporting Date with TOP Referral Process Disposition:

“Debt Not Certified/Inactivated Based on TOP Referral Business Rule”

Line Name

Portfolio Data

LINE_ PREFIX

LINE_ SUFFIX

BIZOPS

_NO

LINE_ SHORT_NAME

DELINQ-

UENCY_ GROUP


NUMBER


DOLLAR

15

c

10

24

Due process not initiated (Awaiting Treasury

Address)

121-180

_DAYS

3

6,000.00

16

c

10

24

Due process not initiated (Awaiting Treasury

Address)

OVER_180

_DAYS

9

68,043.06

17

c

20

23

Due process not

initiated (deliverable)

1-120

_DAYS

-

-

18

c

20

23

Due process not initiated

(deliverable)

121-180

_DAYS

4

11,300.14

19

c

20

23

Due process not

initiated (deliverable)

OVER_180

_DAYS

1

2,600.00

20

c

30

22

In due process,

period not expired

1-120

_DAYS

-

-

21

c

30

22

In due process,

period not expired

121-180

_DAYS

2

4,000.00

22

c

30

22

In due process,

period not expired

OVER_180

_DAYS

2

54,000.17

23

d

10

3

Debt balance >$0

but < $25

1-120

_DAYS

-

-

24

d

10

3

Debt balance >$0

but < $25

121-180

_DAYS

52

100.00

25

d

10

3

Debt balance >$0

but < $25

OVER_180

_DAYS

15

100.00

26

d

20

4

Pseudo-SSN

(Begins with 9)

1-120

_DAYS

-

-

27

d

20

4

Pseudo-SSN

(Begins with 9)

121-180

_DAYS

1

2,000.00






Line

Debt in Scope on Reporting Date with TOP Referral Process Disposition:

“Debt Not Certified/Inactivated Based on TOP Referral Business Rule”

Line Name

Portfolio Data

LINE_ PREFIX

LINE_ SUFFIX

BIZOPS

_NO

LINE_ SHORT_NAME

DELINQ-

UENCY_ GROUP


NUMBER


DOLLAR

28

d

20

4

Pseudo-SSN

(Begins with 9)

OVER_180

_DAYS

1

2,000.00

29

d

30

5

Request for Formal Review/Document

ation

1-120

_DAYS

-

-

30

d

30

5

Request for Formal Review/Document

ation

121-180

_DAYS

2

1,500.00

31

d

30

5

Request for Formal Review/Document

ation

OVER_180

_DAYS

2

1,500.00

32

d

40

6

Pending

Discharge - Death (non-grant)

1-120

_DAYS

-

-

33

d

40

6

Pending Discharge - Death

(non-grant)

121-180

_DAYS

3

6,203.00

34

d

40

6

Pending Discharge - Death

(non-grant)

OVER_180

_DAYS

3

106,203.18

35

d

50

7

Pending Discharge - Disability (TPD)

(non-grant)

1-120

_DAYS

-

-

36

d

50

7

Pending Discharge - Disability (TPD)

(non-grant)

121-180

_DAYS

5

17,001.42

37

d

50

7

Pending Discharge - Disability (TPD)

(non-grant)

OVER_180

_DAYS

5

9,500.00






Line

Debt in Scope on Reporting Date with TOP Referral Process Disposition:

“Debt Not Certified/Inactivated Based on TOP Referral Business Rule”

Line Name

Portfolio Data

LINE_ PREFIX

LINE_ SUFFIX

BIZOPS

_NO

LINE_ SHORT_NAME

DELINQ-

UENCY_ GROUP


NUMBER


DOLLAR

38

d

60

8

Pending Discharge - Closed School

(non-grant)

1-120

_DAYS

-

-

39

d

60

8

Pending Discharge - Closed School

(non-grant)

121-180

_DAYS

3

5,100.00

40

d

60

8

Pending Discharge - Closed School

(non-grant)

OVER_180

_DAYS

3

5,100.00

41

d

70

9

Pending Discharge - False Certification

(FFEL, FISL, DL)

1-120

_DAYS

-

-

42

d

70

9

Pending Discharge - False Certification

(FFEL, FISL, DL)

121-180

_DAYS

1

10,003.17

43

d

70

9

Pending Discharge - False Certification

(FFEL, FISL, DL)

OVER_180

_DAYS

1

52,003.98

44

d

80

10

Pending Discharge - Unpaid Refund

(FFEL, FISL, DL)

1-120

_DAYS

-

-

45

d

80

10

Pending Discharge - Unpaid Refund

(FFEL, FISL, DL)

121-180

_DAYS

2

4,000.00






Line

Debt in Scope on Reporting Date with TOP Referral Process Disposition:

“Debt Not Certified/Inactivated Based on TOP Referral Business Rule”

Line Name

Portfolio Data

LINE_ PREFIX

LINE_ SUFFIX

BIZOPS

_NO

LINE_ SHORT_NAME

DELINQ-

UENCY_ GROUP


NUMBER


DOLLAR

46

d

80

10

Pending Discharge - Unpaid Refund

(FFEL, FISL, DL)

OVER_180

_DAYS

2

4,000.00

47

d

100

12

Pending Discharge - ID Theft (FFEL,

FISL, DL)

1-120

_DAYS

-

-

48

d

100

12

Pending Discharge - ID Theft (FFEL,

FISL, DL)

121-180

_DAYS

1

2,055.00

49

d

100

12

Pending Discharge - ID Theft (FFEL,

FISL, DL)

OVER_180

_DAYS

1

2,055.00

50

d

110

13

Bankruptcy

Exclusion

1-120

_DAYS

-

-

51

d

110

13

Bankruptcy

Exclusion

121-180

_DAYS

100

20,000.00

52

d

110

13

Bankruptcy

Exclusion

OVER_180

_DAYS

599

492,500.83

53

d

120

14

Military Exclusion

1-120

_DAYS

-

-

54

d

120

14

Military Exclusion

121-180

_DAYS

7

14,000.00

55

d

120

14

Military Exclusion

OVER_180

_DAYS

7

14,000.00

56

d

130

16

Adversary

Proceeding Exclusion

1-120

_DAYS

-

-

57

d

130

16

Adversary Proceeding

Exclusion

121-180

_DAYS

53

201,000.99






Line

Debt in Scope on Reporting Date with TOP Referral Process Disposition:

“Debt Not Certified/Inactivated Based on TOP Referral Business Rule”

Line Name

Portfolio Data

LINE_ PREFIX

LINE_ SUFFIX

BIZOPS

_NO

LINE_ SHORT_NAME

DELINQ-

UENCY_ GROUP


NUMBER


DOLLAR

58

d

130

16

Adversary Proceeding

Exclusion

OVER_180

_DAYS

5

701,000.36

59

d

150

18

Formal Appeals

1-120

_DAYS

-

-

60

d

150

18

Formal Appeals

121-180

_DAYS

20

48,153.13

61

d

150

18

Formal Appeals

OVER_180

_DAYS

15

40,000.00

62

d

160

19

SSA Disabled

Match (non-grant)

1-120

_DAYS

-

-

63

d

160

19

SSA Disabled

Match (non-grant)

121-180

_DAYS

3

6,233.00

64

d

160

19

SSA Disabled

Match (non-grant)

OVER_180

_DAYS

3

6,233.00

65

d

170

20

FEMA Disaster

Area

1-120

_DAYS

-

-

66

d

170

20

FEMA Disaster

Area

121-180

_DAYS

2

5,090.00

67

d

170

20

FEMA Disaster

Area

OVER_180

_DAYS

2

5,090.00

68

d

190

25

PIF via AWG

1-120

_DAYS

-

-

69

d

190

25

PIF via AWG

121-180

_DAYS

2

5,901.00

70

d

190

25

PIF via AWG

OVER_180

_DAYS

2

5,901.00

71

d

200

27

Post 65DN Rehab

(5 on-time payments)

1-120

_DAYS

-

-

72

d

200

27

Post 65DN Rehab (5 on-time

payments)

121-180

_DAYS

16

8,000.00






Line

Debt in Scope on Reporting Date with TOP Referral Process Disposition:

“Debt Not Certified/Inactivated Based on TOP Referral Business Rule”

Line Name

Portfolio Data

LINE_ PREFIX

LINE_ SUFFIX

BIZOPS

_NO

LINE_ SHORT_NAME

DELINQ-

UENCY_ GROUP


NUMBER


DOLLAR

73

d

200

27

Post 65DN Rehab (5 on-time

payments)

OVER_180

_DAYS

11

8,000.00

74

d

210

36

Pending

Consolidation

1-120

_DAYS

-

-

75

d

210

36

Pending

Consolidation

121-180

_DAYS

5

49,919.00

76

d

210

36

Pending

Consolidation

OVER_180

_DAYS

5

11,000.00

77

d

220

45

Restitution Debts

(bRestitn)

1-120

_DAYS

-

-

78

d

220

45

Restitution Debts

(bRestitn)

121-180

_DAYS

1

2,650.00

79

d

220

45

Restitution Debts

(bRestitn)

OVER_180

_DAYS

1

2,650.00

80

d

230

48

VA Disabled

Match (non-grant)

1-120

_DAYS

-

-

81

d

230

48

VA Disabled

Match (non-grant)

121-180

_DAYS

1

2,220.00

82

d

230

48

VA Disabled

Match (non-grant)

OVER_180

_DAYS

1

2,220.00

83

d

240

47

Hardship

1-120

_DAYS

-

-

84

d

240

47

Hardship

121-180

_DAYS

11

7,500.15

85

d

240

47

Hardship

OVER_180

_DAYS

1

3,500.00

86

d

250

50

Court-Ordered

Settlement

1-120

_DAYS

-

-

87

d

250

50

Court-Ordered

Settlement

121-180

_DAYS

1

2,100.00

88

d

250

50

Court-Ordered

Settlement

OVER_180

_DAYS

32

2,100.00






Line

Debt in Scope on Reporting Date with TOP Referral Process Disposition:

“Debt Not Certified/Inactivated Based on TOP Referral Business Rule”

Line Name

Portfolio Data

LINE_ PREFIX

LINE_ SUFFIX

BIZOPS

_NO

LINE_ SHORT_NAME

DELINQ-

UENCY_ GROUP


NUMBER


DOLLAR

89

d

260

51

Litigation Hold

1-120

_DAYS

-

-

90

d

260

51

Litigation Hold

121-180

_DAYS

1

3,500.00

91

d

260

51

Litigation Hold

OVER_180

_DAYS

1

73,598.44

92

e

10

26

SSN Change

1-120

_DAYS

-

-

93

e

10

26

SSN Change

121-180

_DAYS

1

1,950.00

94

e

10

26

SSN Change

OVER_180

_DAYS

1

1,950.00

95

e

70

33

Pending Discharge - 9/11 Survivors (Grants,

FFEL, FISL)

1-120

_DAYS

-

-

96

e

70

33

Pending Discharge - 9/11 Survivors (Grants,

FFEL, FISL)

121-180

_DAYS

1

3,750.00

97

e

70

33

Pending Discharge - 9/11 Survivors (Grants,

FFEL, FISL)

OVER_180

_DAYS

1

3,750.00

98

e

100

40

Borrower Defense

(FFEL, Perkins)

1-120

_DAYS

-

-

99

e

100

40

Borrower Defense

(FFEL, Perkins)

121-180

_DAYS

1

2,670.00

100

e

100

40

Borrower Defense

(FFEL, Perkins)

OVER_180

_DAYS

1

9,541.60

101

e

120

15

Unenforceable Debt Discharge

Process

1-120

_DAYS

-

-






Line

Debt in Scope on Reporting Date with TOP Referral Process Disposition:

“Debt Not Certified/Inactivated Based on TOP Referral Business Rule”

Line Name

Portfolio Data

LINE_ PREFIX

LINE_ SUFFIX

BIZOPS

_NO

LINE_ SHORT_NAME

DELINQ-

UENCY_ GROUP


NUMBER


DOLLAR

102

e

120

15

Unenforceable Debt Discharge

Process

121-180

_DAYS

2

4,259.00

103

e

120

15

Unenforceable

Debt Discharge Process

OVER_180

_DAYS

1

2,000.00

104

e

130

46

Pending

Subrogation

1-120

_DAYS

-

-

105

e

130

46

Pending

Subrogation

121-180

_DAYS

20

18,000.54

106

e

130

46

Pending

Subrogation

OVER_180

_DAYS

5

812,000.77

107

e

140

44

Mixed (Debit/Credit)

Balance Debts

1-120

_DAYS

-

-

108

e

140

44

Mixed

(Debit/Credit) Balance Debts

121-180

_DAYS

1

4,500.00

109

e

140

44

Mixed (Debit/Credit)

Balance Debts

OVER_180

_DAYS

1

4,500.00

110

e

150

52

Closed debt with

debit balance

1-120

_DAYS

-

-

111

e

150

52

Closed debt with

debit balance

121-180

_DAYS

1

1,900.00

112

e

150

52

Closed debt with

debit balance

OVER_180

_DAYS

1

1,900.00

113

e

160

54

Unrelated EIN matches borrower

SSN

1-120

_DAYS

-

-

114

e

160

54

Unrelated EIN matches borrower

SSN

121-180

_DAYS

1

1,000.00






Line

Debt in Scope on Reporting Date with TOP Referral Process Disposition:

“Debt Not Certified/Inactivated Based on TOP Referral Business Rule”

Line Name

Portfolio Data

LINE_ PREFIX

LINE_ SUFFIX

BIZOPS

_NO

LINE_ SHORT_NAME

DELINQ-

UENCY_ GROUP


NUMBER


DOLLAR

115

e

160

54

Unrelated EIN matches borrower

SSN

OVER_180

_DAYS

1

1,000.00

116

f

10

38

Treasury Reject

1-120

_DAYS

103

55,800.96

117

f

10

38

Treasury Reject

121-180

_DAYS

15

2,635.00

118

f

10

38

Treasury Reject

OVER_180

_DAYS

1

2,635.00


Based on the criteria above, sample Lines 5–10 would display as follows:



Shape33

Note About Disposition Data Lines 8, 9 and 10

Disposition Data Lines 8, 9 and 10 report debts with a credit balance. Enter the debt quantity (NUMBER) as a positive number but the amount (DOLLAR) as a negative amount. These are the only data lines where a negative dollar amount will be reported, unless the net amount meeting the reporting criteria for any other line is abnormal.



Lines 119–121: Debt Not Tested

Report on each line (as Number and Dollar respectively) the combined debt quantities and loan ending balances from the GA’s system of record that correspond to the balances the GA reported on GAFR lines MR-32 and MR-41 as of the month-end reporting date for debts that were not tested for TOP Referral Disposition because they were not in scope at the time of the last (weekly) TOP referral before month-end AND also meet the line’s DELINQUENCY_GROUP criteria. If GA 999 identified the following debt:






Line

Debt in Scope on Reporting Date with TOP Referral Process Disposition:

“Debt Not Tested”

Line Name

Portfolio Data

LINE_ PREFIX

LINE_ SUFFIX

BIZOPS

_NO

LINE_ SHORT_NAME

DELINQ- UENCY_

GROUP


NUMBER


DOLLAR

119

i

5

N/A

Debt not in portfolio at time of last TOP

referral

1-120

_DAYS

3

3,000.01

120

i

5

N/A

Debt not in portfolio at time of last TOP

referral

121-180

_DAYS

-

-

121

i

5

N/A

Debt not in portfolio at time of last TOP

referral

OVER_18 0

_DAYS

-

-


Based on the criteria above, sample Lines 119–121 would display as follows:



Lines 122–124: Debt Not Otherwise Classified

Report on each line (as Number and Dollar respectively) the combined debt quantities and loan ending balances from the GA’s system of record that correspond to the balances the GA reported on GAFR lines MR-32 and MR-41 as of the month-end reporting date for debts that did not meet the reporting criteria for any prior line (i.e., Lines 2–121) AND also meet the line’s DELINQUENCY_GROUP criteria. If GA 999 identified the following debt:






Line

Debt in Scope on Reporting Date with TOP Referral Process Disposition:

“Debt Not Otherwise Classified”

Line Name

Portfolio Data

LINE_ PREFIX

LINE_ SUFFIX

BIZOPS

_NO

LINE_ SHORT_NAME

DELINQ-

UENCY_ GROUP


NUMBER


DOLLAR

122

i

10

N/A

Debt does not meet definition for any prior

report line

1-120

_DAYS

-

-

123

i

10

N/A

Debt does not meet definition for any prior

report line

121-180

_DAYS

-

-

124

i

10

N/A

Debt does not meet definition for any prior

report line

OVER_180

_DAYS

-

-


Based on the criteria above, sample lines 122–124 would display as follows:



Note About Disposition Data Lines 122–124 Debt Not Otherwise Classified

Since the TOP referral process is designed to identify the appropriate disposition of every debt within the GA portfolio that meets the scope definition on the date the TOP referral process is executed, no dollar amount or debt quantity is expected to be reported on these lines. Any valid dollar amount and debt quantity reported represents either debt that was incorrectly mapped or debt with characteristics that the referral or reporting process did not identify. The GA must fully research any such debt quantity or dollar amount reported and provide a detailed written explanation when the Disposition Data Set is submitted, either included in the body of the submission email or attached as a separate MS Word file.


    1. Data Validation

Note About Validation of Data Before Submission

It is FSA’s expectation that GAs will carefully review the Disposition Data Set each month prior to submission to ensure on-going compliance with the Disposition Data requirements. The review should include, but is not limited to, the following Data Validation Tests.

FSA will reject the Disposition Data submitted if it does not comply with requirements or if a required explanation is not provided.


Validation Test 1 – Validate Number of Disposition Data Lines Against Requirement

The Disposition Data Requirements detailed in Section 6.5 above explicitly require that each GA submit Disposition Data that includes 124 lines (including the Data Element Names in Line 1).

FSA will reject the Disposition Data if the total number of lines is not equal to 124.




Note About Disposition Data Validation Test 1

Validation Test 1 serves as a control for the Disposition Data and must result in a calculated line number variance of zero. If a GA submits Disposition Data where this test results in a variance other than zero, FSA will reject the GA’s submission and return it for correction.


Validation Test 2 – Validate Disposition Data Against Control Total

The Disposition Data requirements described in Section 6.5 above are designed to capture the combined debt quantities and loan ending balances from the GA’s system of record that correspond to the balances the GA reported on GAFR lines MR-32 and MR-41 as of the month- end reporting date. FSA will validate the Disposition Data submitted by each GA against the sum of the MR-32 and MR-41 GAFR lines the GA submitted for the same reporting period. For example, assume GA 999 submitted a GAFR and Disposition Data with the following data as of March 31, 2023:



Validation - Debt in Scope on Reporting Date

Data Source

Dollar Amount

GAFR Line MR–32

15,169,908.06

GAFR Line MR–41

563,824.23

Subtotal: Disposition Data Control Total

15,733,732.29

Total Dollar amount reported in Disposition Data Element “Dollars”, Lines 2–124

15,733,732.29

Control Difference:

0.00


Since the Control Difference is zero, the Disposition Data would PASS Validation Test


Note About Disposition Data Validation Test 2

Validation Test 2 serves as a control for the Disposition Data and must result in a calculated Control Difference value of zero. If a GA submits Disposition Data where this test results in a Control Difference value other than zero, FSA will reject the GA’s submission and return it for correction.


    1. Naming Configuration

The GAs should use the following file naming configuration.


Table 6.7 Disposition Data File Naming Configuration


Required File Naming Configuration

Example

yyyymm- DISP-ccc

Where

  • “yyyy” = 4-digit fiscal reporting year

  • “mm” = 2-digit fiscal reporting month

  • “DISP” = data set short name

  • “ccc” = 3-digit GA code

GA 999 will name the Disposition Data as of March 31, 2023 as follows:

  • 202306-DISP-999.csv


    1. Presentation

If the Disposition Data Set is prepared correctly, when uploaded to MS Excel or MS Access, the data will display as shown:



The above image shows only the first few lines of the Disposition Data. For a complete example, please refer to Appendix B.



Note About Abnormal Balances

Except for Lines 8–10, the expected sign for all debt quantities and dollar amounts in this Data Set is positive. Any abnormal balances must be researched and explained. The explanation can be included in the body of the submission email or added as a separate MS Word file attachment. See Section 7.0 Submission to FSA for more information.

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    1. Submission to FSA


Note About Validation of Data Before Submission

To ensure on-going compliance with the DCIA Compliance Data Set requirements, FSA will perform a quality control review of the GA’s submission package for each reporting period. This review will include confirming that the GA’s submission agrees with the related GAFR MR lines and that variance explanations have been provided when required. FSA will reject the submission if it does not reconcile to the highlighted MR lines or if a required explanation is not provided. GAs must therefore review their submissions carefully prior to delivery.


    1. Contents of the DCIA Compliance Data Set Submission

GAs can prepare the DCIA Compliance Data Set in Excel; however, the files must be saved and submitted to FSA as individual CSV files. For example, if a GA submits a GAFR for a reporting period that has FFEL Program activity or balances, then the GA must also submit separate CSV files - one for each of the required Data Sets.


GAs must submit the following as appropriate:

      • The applicable individual Data Set files,

      • The Disposition Data explanation (i.e., for “Debt Not Otherwise Classified”), if necessary,

      • The required Write-Off Data explanation, if necessary and

      • Any abnormal activity or balance explanations, if necessary.


Explanations can be included in the body of the submission email or added as a separate MS Word file attachment. Additionally, submitted files should not be password protected unless required by the GA’s or FSA’s data protection policies (i.e., because the files contain personally identifiable information or sensitive data).


    1. Delivery Instructions

GAs should prepare an email with the contents of the submission package attached and send it to the following FSA email addresses:


To: FSAFinancePortfolio@ed.gov CC: callis.carleton@ed.gov


Please indicate the reporting month and FY in the subject line of the email as follows:


Table 7.2 Submission Email Subject Line


Subject Line

Example

DCIA Compliance Data Set mm–yyyy


Where

  • “mm” = 2-digit fiscal reporting month

  • “yyyy” = 4-digit fiscal reporting year

For the reporting period ending March 31, 2023, the subject line should be as follows:

  • DCIA Compliance Data Set 06-2023


    1. Due Date

GAs must submit the DCIA Compliance Data Set no later than close of business (COB) on the due date specified below.


Table 7.3 DCIA Compliance Data Set Due Dates



FY Reporting Period End Date


Applicable to the Following Months


Due Date

Number of Data Sets Required to Be Submitted

If month-end…

Oct, Nov, Jan, Feb, April, May, Jul, and Aug

COB 12th business day of the following month.

2 Data Sets*

If quarter-end…

Mar

COB 8th business day of the following month.

3 Data Sets**

If quarter-end…

Dec, Jun, and Sep

COB 8th business day of the following month.

2 Data Sets*

* Write-Off Data Set isn’t required

** Write-Off Data Set is required


Business day is based upon the Federal government calendar. COB is 5 p.m. Eastern time.























Appendixes

























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Appendix A – Sample GAFR / ED Form 2000


Appendix A – Sample GAFR / ED Form 2000


Note: The sample GAFR presented below is for example purposes only. Its purpose is to highlight the relationship between specific GAFR MR lines and the DCIA Compliance Data Set.

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Shape46

Shape47




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Appendix B – Presentation of MR-32 & MR-41 Loan Ending Balance Disposition Data Set in Microsoft Excel Format


MR-32C & MR-41 Loan Ending Balance Disposition Data Set (Disposition Data)






















Appendix C – Mapping GA TOP Referral Business Rules to MR-32 & MR-41 Loan Ending Balance Disposition Data Set Lines


Mapping of FSA GA TOP Referral Business Rules to Disposition Data Line Numbers






Note About Top Exclusions/Exceptions for GAs

The TOP Referral Exclusion/Exception Business Rules for GAs are the responsibility of Program Operations. Questions concerning the TOP referral business process are outside the scope of this document and should be addressed to Program Operations accordingly.





















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Appendix D – Guaranty Agency List

Appendix D – Guaranty Agency List




GA

Code


GA State


GA Name

708

Colorado

Colorado Student Loan Program dba College Assist

712

Florida

Florida Department of Education, Office of Student Financial Assistance (OSFA)

721

Kentucky

Kentucky Higher Education Assistance Authority (KHEAA)

722

Louisiana

Louisiana Office of Student Financial Assistance (LOSFA)

725

Massachusetts

American Student Assistance dba Massachusetts Higher Education Assistance Corporation (MHEAC)

726

Michigan

Michigan Guaranty Agency (MGA)

731

Nebraska

Nebraska or National Student Loan Program (NSLP)

733

New Hampshire

New Hampshire Higher Education Assistance Foundation

735

New Mexico

New Mexico Student Loan Guarantee Corporation

736

New York

Higher Education Services Corporation (HESC)

737

North Carolina

North Carolina State Education Assistance Authority (NCSEAA)

740

Oklahoma

Oklahoma College Assistance Program (OCAP)

742

Pennsylvania

Pennsylvania Higher Education Assistance Agency (PHEAA)

748

Texas

Texas Guaranteed Student Loan Corporation

749

Utah

Utah Higher Education Assistance Authority (UHEAA)

750

Vermont

Vermont Student Assistance Corporation (VSAC)

755

Wisconsin

Ascendium Education Solutions

927

Minnesota

Educational Credit Management Corporation I

951

Minnesota

Educational Credit Management Corporation II
























Appendix E – Glossary of Acronyms


Appendix E – Glossary of Acronyms


Acronym / Term

Description

65-Day Notice Period

Required period of notification to the borrower that delinquent Title IV debt will be sent to TOP for administrative offset unless the borrower enters into a Rehabilitation Agreement or Repayment Agreement prior to the end of the 65-day notice period or responds with a timely Request for Review or Request for Documents. The 65-Day Notice sent during this period satisfies the requirement to complete TOP due process before referring a debt to TOP.

Aging Data

MR-32 Loan Ending Balance Aging Data Set

CFOC

Chief Financial Officers’ Council

Claim Date

The date a Guaranty Agency pays a lender’s claim.

COB

Close of Business

Congress

The United States Congress

CSV

Comma-Separated Value (Comma Delimited)

CY

Calendar Year

DCIA

Debt Collection Improvement Act of 1996, as amended

DCIA Compliance Data Set

DCIA Aging and Compliance Data Set (i.e., the three Data Set requirements, collectively)

Department

United States Department of Education

Disposition Data

MR-32 & MR-41 Loan Ending Balance Disposition Data Set

Exception

A set of criteria, not authorized by DCIA, that when met FSA excludes a debt from referral to TOP or inactivates a debt already at TOP. This set of criteria is based upon FSA policy. An example of excepted debt is debt determined to be unenforceable but not yet closed out.

Exclusion

A set of criteria that is compliant with DCIA, that when met, FSA may exclude a debt from referral to TOP or inactivate a debt already at TOP as authorized by DCIA. Examples of excluded debt include debt less than $25 dollars, debt in bankruptcy, etc.

FFEL

Federal Family Education Loan Program

Form 1099-C

IRS Form 1099-C, Cancellation of Debt

FSA

Federal Student Aid

FY

Fiscal Year

GA

Guaranty Agency


Acronym / Term

Description

GAFR

Guaranty Agency Financial Report (ED Form 2000)

HEA

Higher Education Act of 1965, as amended

IRS

Internal Revenue Service

LLR

Lender-of-Last Resort

MR

Monthly Report

MR-24

Collection Terminations (GAFR Line Reference)

MR-32

Ending Balance of Defaulted Loans (GAFR Line Reference)

MR-41

Ending Balance on Bankruptcies (GAFR Line Reference)

MS

Microsoft

OGC

Office of General Counsel

OMB

Office of Management and Budget

Rehabilitation Agreement

Default resolution agreement available to qualified defaulted Title IV borrowers under the terms of which if the borrower makes nine on-time payments (i.e., pays within 20 days of the due date) during a period of ten consecutive months, the debt will be considered “rehabilitated.” The rehabilitated loan is repurchased by a lender or assigned to FSA, clearing the default and resetting the delinquency age to zero (i.e., “current” ).

Reinsurance Date

The date the Department reimburses a GA for a previously paid claim.

Repayment Agreement

For the DCIA aging, the term Repayment Agreement is reserved to refer to any non-rehabilitation repayment agreement entered into by the borrower after the default of their Title IV debt.

Title IV

Title IV of the Higher Education Act of 1965, as amended

TOP

Treasury Offset Program

TPD

Total and Permanent Disability

Treasury

United States Department of Treasury

Write-Off Data

MR-24 Collection Terminations Write-Off Data Set


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