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The U.S. Department of Education (ED) distributed the FY 2016 3-Year Draft Cohort Default Rates Monday, February 25, 2019.  Under regulations published October 28, 2009, a school’s Cohort Default Rate (CDR) is calculated as the percentage of borrowers in the cohort who default before the end of the second fiscal year following the fiscal year in which the borrowers entered repayment.  This information is the basis of the 3-year CDR.[1]

The Draft CDRs were distributed to schools’ Student Aid Internet Gateway (SAIG) mailboxes.  The CDRs and accompanying Loan Record Detail Reports may also be downloaded through the National Student Loan Data System (NSLDS) via the NSLDS Professional Access Website.
 
Schools should refer to 34 CFR 668.206 and remember the impact that occurs if a school’s FY 2016 official 3-year CDR is equal to or greater than 40% when the official CDR is published in September 2019, or if the school’s 3-year CDR has been 30% or greater for three years.[2]The time period for challenging a school’s FY 2016 3-Year Draft Cohort Default Rate under 34 CFR Part 668, Subpart N began on Tuesday, March 5, 2019, for all schools.  The deadline for submitting an appeal is 45 days from that date.[3]

 The February 25, 2019, Electronic Announcement should be reviewed for further details regarding the method for submitting Incorrect Data Challenges (IDC) and Participation Rate Index Challenges (PRI) since one of the challenges must be made through the eCDR Appeals application and one via a paper hardcopy.  Also, as referenced in the Electronic Announcement, schools should also consult and utilize ED’s Cohort Default Rate Guide which is available on IFAP.
 
Note that schools “that did not have a borrower in repayment, during the current or any of the past cohort default rate periods, did not receive a FY 2016 3-year draft cohort default rate notification package.  These schools are considered to have no cohort default rate data and no cohort default rate.”[4]


Publication Date:  March 19, 2019


[1]See 34 CFR 668.202.[2]See 34 CFR 668.206.[3] See ED’s Cohort Default Rate Guide, Part 4.[4]Electronic Announcement, February 25, 2019.

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This material is presented for informational and educational purposes only and should not be considered to be giving legal advice.