education department dwight vigna director, default division 1

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Education Department Dwight Vigna Director, Default Division 1

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Page 1: Education Department Dwight Vigna Director, Default Division 1

Education Department

Dwight VignaDirector, Default Division

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Page 2: Education Department Dwight Vigna Director, Default Division 1

FSA Default Division Goals

•Goal 1: Be respectful to our borrowers and find the best solution that will resolve the borrower’s debt regardless of the commission being paid

•Goal 2: Increase the FSA overall collection rate on a year to year basis even though the inventory is also increasing annually

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Page 3: Education Department Dwight Vigna Director, Default Division 1

Default Recoveries- In Billions

Combined EDFY14 - $20.4 $10.63FY13 - $18.2 $ 8.51FY12 - $13.1 $ 3.68FY11 - $12.0 $ 3.40FY10 - $10.2 $ 3.04FY09 - $ 8.8 $ 3.07FY08 - $ 8.9 $ 3.21FY07 - $ 6.9 $ 2.67

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Page 4: Education Department Dwight Vigna Director, Default Division 1

FY14 Top Ten By Recovery Rate

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Rank Agency CollectionsAdjusted Beginning

Inventory Percent1 ARKANSAS 80,087,206 179,678,104 44.57%2 RHODE ISLAND 45,043,494 119,499,832 37.69%3 LOUISIANA 68,486,357 185,040,695 37.01%4 OKLAHOMA 139,862,143 396,963,955 35.23%5 MAINE 17,395,905 50,886,106 34.19%6 ASA (MASS) 1,005,222,247 3,048,566,099 32.97%7 USAF 1,807,459,205 5,647,187,947 32.01%8 NSLP (NEB) 335,207,453 1,062,303,285 31.55%9 MISSOURI 103,599,498 332,591,977 31.15%10 KENTUCKY 143,403,552 476,409,977 30.10%

Page 5: Education Department Dwight Vigna Director, Default Division 1

FY14 Top Ten by Recovery Rate w/o

Consols

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Rank Agency Collections Beginning Inventory Percent1 ARKANSAS 65,972,070 179,678,104 36.72%2 LOUISIANA 61,227,965 185,040,695 33.09%3 OKLAHOMA 120,264,645 396,963,955 30.30%4 RHODE ISLAND 34,592,910 119,499,832 28.95%5 MAINE 14,547,397 50,886,106 28.59%6 USAF 1,551,806,444 5,647,187,947 27.48%7 NELA (WA) 76,462,116 293,788,278 26.03%8 NEW HAMPSHIRE 14,639,002 58,581,342 24.99%9 KENTUCKY 115,032,056 476,409,977 24.15%10 COLORADO 215,090,003 946,197,043 22.73%

Page 6: Education Department Dwight Vigna Director, Default Division 1

FY13 Recovery Rate By Portfolio Combined Program Recovery Rate

P&I Recoveries Recovery Rate

GA $34,502,742,432 $9,721,114,778 28.17%

ED $55,886,286,405 $10,629,996,256 19.02%

Combined $90,389,028,837 $20,351,111,034 22.52%

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Page 7: Education Department Dwight Vigna Director, Default Division 1

Regular

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Regular

FY14 FY13 FY12

GA $659,831,565 $759,645,000 $754,654,568

ED $611,186,860 $562,750,765 $539,983,209

Combined $1,271,018,425 $1,322,395,765 $1,294,637,777

Page 8: Education Department Dwight Vigna Director, Default Division 1

TOP

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TOP

FY14 FY13 FY12

GA $800,957,923 $848,556,209 $990,651,634

ED $1,300,561,456 $1,331,685,591 $555,242,177

Combined $2,131,519,379 $2,180,241,800 $1,545,893,811

Page 9: Education Department Dwight Vigna Director, Default Division 1

Rehabilitations

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Rehabilitations

FY14 FY13 FY12

GA $5,232,338,236 $4,736,266,045 $4,400,196,618

ED $7,383,519,787 $5,758,179,306 $1,761,800,453

Combined $12,615,858,023 $10,494,445,351 $6,161,997,071

Page 10: Education Department Dwight Vigna Director, Default Division 1

AWG

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AWG

FY14 FY13 FY12

GA $665,888,004 $655,890,260 $668,323,580

ED $558,532,023 $291,422,130 $345,010,734

Combined $1,224,420,026 $947,312,390 $1,013,334,314

Page 11: Education Department Dwight Vigna Director, Default Division 1

Direct Consolidations

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Regular

FY14 FY13 FY12

GA $2,362,099,050 $2,711,129,883 $2,584,213,293

ED $746,196,131 $567,475,161 $474,247,061

Combined $3,108,295,181 $3,278,605,045 $3,058,460,354

Page 12: Education Department Dwight Vigna Director, Default Division 1

FY14 GA Consolidations

Highest percentage was 34.84%Lowest percentage was 10.60%

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Consolidations Total Collections % of Total $2,362,099,050 $9,721,114,778

24.30%

Page 13: Education Department Dwight Vigna Director, Default Division 1

FY14 Top Ten Consolidators

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Rank AgencyConsolidation

Collections Total Collections Percent1 VERMONT 8,377,493 24,048,014 34.84%2 MISSOURI 35,392,859 103,599,498 34.16%3 PENNSYLVANIA 330,067,127 976,591,712 33.80%4 NSLP (NEB) 112,837,907 335,207,453 33.66%5 NORTH CAROLINA 14,046,710 41,785,790 33.62%6 SOUTH CAROLINA 22,929,424 68,425,667 33.51%7 NORTH DAKOTA 2,457,924 7,448,445 33.00%8 MASS (ASA) 330,104,832 1,005,222,247 32.84%9 ECMC (VA) 500,842,026 1,825,526,288 27.44%10 TENNESSEE 33,293,776 121,651,842 27.37%

Page 14: Education Department Dwight Vigna Director, Default Division 1

Collection PerformanceCPCS #13-19 Avg. - Unrestricted

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Page 15: Education Department Dwight Vigna Director, Default Division 1

Collection PerformanceQuarterly CPCS #13-19Avg. – Small Business

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Page 16: Education Department Dwight Vigna Director, Default Division 1

60.99%37.81%

0.30%0.82%

0.07%Inventory

DirectFFELFISLPerkinsOther

Portfolio Characteristics

September 2013• Size: $55,886,286,405

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Page 17: Education Department Dwight Vigna Director, Default Division 1

Portfolio Characteristics

September 2014• Size: $65,961,695,813

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61.29%

37.73%

0.25% 0.67%0.06%

Direct

FFEL

FISL

Perkins

Other

Inventory

Page 18: Education Department Dwight Vigna Director, Default Division 1

Collections 3-Year Forecast

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2014 2015 2016 2017

Inventory $55.B $65.B $76.5B $88.5B

Collections $10.6B $12.5B $13.9B $15B

Page 19: Education Department Dwight Vigna Director, Default Division 1

Treasury Offset Program PY2014 P&I Certified

GA $23,673,661,746

ED $29,951,216,165

Total $53,624,877,911

• ED Collections - $1,331,685,591

• GA Collections - $ 848,556,209

• Total - $2,180,241,800

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Page 20: Education Department Dwight Vigna Director, Default Division 1

Treasury Offset Program

• Certification processing is on schedule• Cindy sent the Action Code e-mail• GA Certification files are due 11/3 -11/7• Inactivation file will be processed on 11/12/2014• Certification files are sent to Treasury on 12/8/2014

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Page 21: Education Department Dwight Vigna Director, Default Division 1

Consolidations

• Used be one Consolidation Servicer• Now we have multiple and we have to keep the

consolidation even across them• New forms were created but not really relate to the

change• The new process use a web application• We created a new contract to support the web

application

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Page 22: Education Department Dwight Vigna Director, Default Division 1

Consolidations

• The Default process as well as the GA process uses a schedule for who to send your consolidations to

• Issue in the beginning that we believe are now fixed

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Page 23: Education Department Dwight Vigna Director, Default Division 1

Rehab Processing

• Started the IBR R&A process in July 2012• Basic rules were get the information over the

phone to complete the IBR calculator and document the values on the borrower’s account

• In March 2013 we create some new rules• Require either Tax information or an ADOI form to

validate information from the phone

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Page 24: Education Department Dwight Vigna Director, Default Division 1

Rehab Processing

• July 1, 2014 implemented the new regulations• Require documentation and supporting

documentation for ADOI form• Require a rehab agreement from all borrowers• PCA are not supposed to set up a rehab until all

documentation is received and imaged into the borrower’s account

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Page 25: Education Department Dwight Vigna Director, Default Division 1

Rehab Processing

• Numbers from FY 2014• 338,370 borrowers through regular rehab process• 5932 Borrowers through BSR process• 671 Borrowers through both• 343,631 Unique borrowers rehabbed (an average of

28.6k per month)• Our average prior to the FY 2012 change was under

10,000 borrowers per month

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Page 26: Education Department Dwight Vigna Director, Default Division 1

Rehab Processing Numbers*• 91% of borrowers are using the 15% rule leaving 9%

using the Financial Information Statement (FIS)• 6% of the rehab borrowers are in or were recently

in an AWG• The average rehab payment amount is $48.13

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* - Based on sampling of 3,559 borrowers

Page 27: Education Department Dwight Vigna Director, Default Division 1

Department Purchasing GA Rehabs - Requirements• Notice of Intent Form Submission• Plan to use the deal IDs and the EA27/EA80 for file

transfer processing• The GA will also send a Bill of Fees

• File must be transferred to Servicer 4 business days prior to date of transfer

• The Servicer will do standard loan edits• The Servicer creates a Loan Detail Schedule and

reconcile to the GA Bill of Fees

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Page 28: Education Department Dwight Vigna Director, Default Division 1

Department Purchasing GA Rehabs - Requirements• The Servicer will send the Loan Detail Schedule to

the GA and FSA CFO• GA will send necessary collateral one business day

prior to the transfer date• The Servicer will perform collateral review• The Servicer will report to NSLDS

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Page 29: Education Department Dwight Vigna Director, Default Division 1

IRS Skip Tracing

• We have a signed CMA• We have to make system changes in order to use

the CMA• Currently scheduled for February 2016

• There will be audits from the IRS on this process• New Training must be done for all staff that

includes IRS FTI (Federal Tax Information) requirements

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Page 30: Education Department Dwight Vigna Director, Default Division 1

IRS Skip Tracing

• Neither ED nor its Contractors (PCA or GA) may re-disclose the IRS Address unless legal parameters in the Internal Revenue Code (IRC) (section 6103) are followed, which are in addition to those required by the Privacy Act!

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Page 31: Education Department Dwight Vigna Director, Default Division 1

NDNH Match

• A working draft document is now being reviewed• We believe the IRS process will also be a part of this

match• This is also scheduled for February 2016

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Page 32: Education Department Dwight Vigna Director, Default Division 1

DMCS O&M Contract

• Transition date was 8/1/2014• First monthly release was a complete success• There are 8 Quarter releases that start with

11/2014 and go through 8/2016• There are monthly release that will fix outstanding

issues

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Page 33: Education Department Dwight Vigna Director, Default Division 1

DMCS O&M Contract

• Release Themes and Dates:• 11/14 – Rehab and Suspense• 2/15 – Loan Exchange, Transaction Processing• 5/15 – PCA, Refunds• 8/15 – TOP, Bankruptcy, Finance• 11/15 – AWG, NSLDS• 2/16 – Images, Interfaces, Compromise• 5/16 – Notices, Consolidation, DOJ• 8/16 – Cleanups, PCA Invoicing, Web

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Page 34: Education Department Dwight Vigna Director, Default Division 1

DMCS O&M Contract

• How does this affect the GAs?• No changes today• There will be a transition of the data center at some

future point

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Page 35: Education Department Dwight Vigna Director, Default Division 1

PCA Contracts

• Eleven Small Business Awards were made in October

• Three were incumbents• Current time frame for their first release of

borrower is August 2015• Unrestricted Procurement is still on-going

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Page 36: Education Department Dwight Vigna Director, Default Division 1

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Questions?

Page 37: Education Department Dwight Vigna Director, Default Division 1

Department of Education Regulatory Update

NCHER Knowledge Symposium

Nathan ArnoldU.S. Department of Education

November 3, 2014

Page 38: Education Department Dwight Vigna Director, Default Division 1

Gainful Employment

Issue renegotiated following District Court ruling in 2012

Three negotiations: Sept. 9 -11, Nov. 18 -20, Dec. 13, 2013

Consensus not reached NPRM published on March 25, 2014 Final rule published October 31, 2014 Effective July 1, 2015

Page 39: Education Department Dwight Vigna Director, Default Division 1

Gainful Employment• Covers all programs at proprietary institutions

and non-degree programs at other institutions• Debt to earnings metrics: passing is 8% of

annual income, 20% of discretionary income• Establishes three levels of compliance: passing,

zone, and failing• Eligibility not affected by program cohort default

rate metric proposed in NPRM• Program ineligible if it fails 2 of 3 consecutive

years or is in zone 4 consecutive years• Disclosures on costs, earnings, debt, completion

Page 40: Education Department Dwight Vigna Director, Default Division 1

Violence Against Women Act Violence Against Women Act reauthorized

March 7, 2013 Made changes to Clery Act institutional reporting

requirements

Three Negotiations: Jan. 13 – 14, Feb. 24 – 25, March 31 – April 1,

2014

Consensus reached NPRM published June 20, 2014 Final rule published October 20, 2014 Effective July 1, 2015

Page 41: Education Department Dwight Vigna Director, Default Division 1

Violence Against Women Act

• Requires institutions to:– Maintain statistics on dating violence, domestic violence,

sexual assault, and stalking– Provide, and describe in annual security reports,

prevention and awareness campaigns– Provide a prompt, fair, and impartial disciplinary

proceeding, and provides for requirements governing that proceeding

– Provide information and support services to victims

Page 42: Education Department Dwight Vigna Director, Default Division 1

Program Integrity and Improvement Four negotiations:

Feb. 19 - 21, March 26 - 28, April 23 – 25, May 19 – 20, 2014

Cash management State authorization of distance education programs State authorization of foreign locations of domestic

institutions Definition of PLUS adverse credit history Repeat coursework Clock-to-credit hour conversion

Tentative agreement reached on some issues, but overall consensus not reached

Page 43: Education Department Dwight Vigna Director, Default Division 1

Program Integrity and Improvement• Definition of PLUS adverse credit history

• NPRM published on August 8, 2014• Final rule published October 23, 2014• Effective July 1, 2015, ED will implement early

– Revised definitions and amounts apply to both Parent PLUS and Grad PLUS loans

– Revised adverse credit definition• If the applicant has one or more debts with combined outstanding balance

greater than $2,085 that is: (1) 90 or more days delinquent or (2) Placed in collection or charged off during previous two years of credit report

– $2,085 can be increased by ED based on CPI if the change would be ≥ $100

– Borrowers with extenuating circumstances or endorser must complete counseling

Page 44: Education Department Dwight Vigna Director, Default Division 1

Teacher Preparation

• Teacher Preparation Negotiated Rulemaking Committee– Negotiations were held in November 2012– Consensus not reached– NPRM currently under review at OMB– Except for the Teach Grant component, these

proposed regulations are not subject to the Master Calendar requirements

Page 45: Education Department Dwight Vigna Director, Default Division 1

Pay As You Earn Expansion– Federal Register Notice published Sept. 3, 2014– We propose to develop regulations that:

Allow more student Direct Loan borrowers to qualify for PAYE

Target the new PAYE option to borrowers who would otherwise struggle to repay their student loans

– Interested parties may suggest additional issues for consideration at two hearings or in writing: Washington, D.C. (Oct. 23, 2014) Anaheim, California (Nov. 4, 2014) Written suggestions must be received by Nov. 4,

2014; see notice on regulations.gov for instructions

Page 46: Education Department Dwight Vigna Director, Default Division 1

Pay As You Earn Expansion

• Planned Negotiated Rulemaking on Expansion of PAYE Repayment plan– Negotiating sessions would begin Feb.

2015: Three sessions Approximately 3 days each At roughly monthly intervals

Page 47: Education Department Dwight Vigna Director, Default Division 1

Other Regulatory Activity• Loans II Package

– Loan rehabilitation, updates/consolidation of FFELP and Direct Loan regulations, AWG, closed school discharge

– Final rule published November 1, 2013

• 150% Direct Subsidized Loan Limit– Limits receipt of Direct subsidized loans to 1.5X the length

of borrower’s currently enrolled program– Loss of eligibility and interest subsidy after reaching limit– Affects new borrowers on/after July 1, 2013– Final rule published January 17, 2014– Exempt from negotiated rulemaking and master calendar

Page 48: Education Department Dwight Vigna Director, Default Division 1

SCRA Dear Colleague Letter• Improved Administration of the Servicemembers

Civil Relief Act for Direct Loan and FFEL Borrowers (GEN-14-16), published August 25, 2014– Result of work with DOJ to simplify process for loan holders

to confirm eligibility for benefits §527 of the SCRA– FFEL lenders authorized to use DOD’s DMDC database– Military orders and borrower request no longer required– Lenders/servicers using DMDC to grant the interest rate

limitation not subject to program liabilities if DMDC is found to be incorrect

– Independent confirmation of DMDC information (i.e. military orders) not required, but DMDC information must be retained in borrower’s file

Page 49: Education Department Dwight Vigna Director, Default Division 1

ED Servicing Summit• One-day session on servicing is to explore various

topics of interest to student borrowers, consumer advocates, financial aid administrators, and policy makers

• Town hall meeting with Undersecretary Mitchell, break-out discussion sessions

Monday, December 1, 2014

8:30 A.M. – 5:00 P.M. (ET)

Omni Hotel at CNN Center, Atlanta• Registration:

fsaconferences.ed.gov/servicingsummit.html

Page 50: Education Department Dwight Vigna Director, Default Division 1

CONTACT INFORMATION

Nathan ArnoldOffice of Postsecondary Education

202-219-7134

[email protected]

Pam MoranOffice of Postsecondary Education

202-502-7732

[email protected]

Page 51: Education Department Dwight Vigna Director, Default Division 1

Ombudsman GroupFY 2014 Activities Summary

November 3, 2014NCHER Knowledge Symposium

Customer ExperienceU.S. Department of Education

Page 52: Education Department Dwight Vigna Director, Default Division 1

Highlights of FY 2014

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• Received 300,000th (all-time) customer contact

• Received total of 38,665 contacts in FY 2014

• Published blog post in collaboration with NCHER SL Ombudsman Caucus

• Awarded contract and began transition to new call center and case management support

NCHER Knowledge Symposium – November 2014

Page 53: Education Department Dwight Vigna Director, Default Division 1

FY 2014 Contact Volumes

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• 80% of requests from customers resolved in first/initial contact

• Top 5 Overall:• FSA Assistance – 7051• Account Balance – 6437• Repayment Plans/Amounts – 4551• Loan Cancellation/Discharge – 3691• Default -- 3462

• Credit Reporting issues were the basis for 1953 contacts

NCHER Knowledge Symposium – November 2014

Page 54: Education Department Dwight Vigna Director, Default Division 1

FY 2014 Case Outcomes – Research Cases

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• 38.1% of cases received and closed during the year resulted in “Confirmation”• Highest proportion: Bankruptcy (59.2%)

• 32% resulted in “Action”• Highest proportion: NSLDS (74.9%)

• 18.4% resulted in “Information”• Highest proportion: Wage Garnishment (31.9%)

NCHER Knowledge Symposium – November 2014

Page 55: Education Department Dwight Vigna Director, Default Division 1

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Other Activities in FY 2014

• 1191 customers reported being referred from CFPB; 467 referred to CFPB

• Hosted four conference calls with student loan borrower interest groups

• Implemented a new customer survey using American Customer Satisfaction Institute (ACSI) methodology (September)

NCHER Knowledge Symposium – November 2014

Page 56: Education Department Dwight Vigna Director, Default Division 1

Thank you!

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Joyce DeMoss, Ombudsman [email protected] 202-377-3992

Questions?

NCHER Knowledge Symposium – November 2014