Participants: Shannon Sheaf, Vicki Shipley and Tami Sato

WASFAA Federal Relations CommitteeConference Call – July 21, 2016, 2:00 PT

Meeting started at 2:03 p.m.

Welcome, Review June 16th To Do’s, FRC Members

Rachelle Feldman has changed jobs to an institution in NC so Anafe Robinson has replaced her as the CASFAA FRC representative. We welcome back Anafe. She has already offered to help set up the rest of the FRC meetings on CCCConfer.
For to dos from the June meeting a draft document was developed for response to the NPRM and an article on repayment rates was submitted for the newsletter with help from Shannon.

This and That at the NASFAA Conference

This was NASFAA’s 50th year and FAA who have been in the biz for more than 50 years were recognized. Judy Lewis Logue from USD was there and she has 52 years.
Tami summarized some of the key topics, but there wasn’t any earth-shattering news or revelations.
Since site was DC there were many speakers from the hill, downside is many had to leave without Q and A as they had to get back. House reps mostly, no Senators. From now on conference will be late June. Next year is San Diego. Cost issues main reason for change.
Jeff Baker mentioned that an NPRM on state authorization should be published soon. This was the unfinished part on distance learning. There will be a 30 day comment period. FRC discussed how this brings added revenue to states. Loan servicers are being asked to be licensed with an annual fee. (Update: NPRM has been released)
FRC was interested in the experimental sites on entrance and exit counseling. Tami said it was included in his PPT. She will check to see if it is posted and send out to FRC. (Update: It was not included so Tami asked Megan Coval about availability)
Surprisingly not much chatter re GE reporting. NSLDS has been impacted by schools needing data and being pulled into the mess.
FRC asked about the third-party services issue and asked if Jeff had mentioned it. It has been added to audit process and some schools who use an outside entity for delinquency and default prevention/servicing will have to add new policies. A DCL is expected that will have 22 pages of Q and A on issue but it is not expected for another two weeks.

NPRM of Borrower Defenses

Tami read through the NPRM on the flights back and forth to DC. She also reviewed the comments at the website for the docket number but most seemed to be pre neg-reg comments with the majority of them from disgruntled students. Some law associations had more substantial comments. Also ready articles regarding the NPRM. Comment response will be coming out from associations like NASFAA, NACUBO, ACE and maybe the AG’s. Shannon said there has not been much email from other negotiators. Some segments will not send comments because they got most of what they asked for.
FRC decided that comment should be added to the draft documentation on the additional triggers that would make a school require a letter of credit. From the school perspective this could affect both for-profit and non-profits. (Update : Tami has added this issue).
For areas where we agree with the NPRM proposals, we wanted to include our support as other commenters may speak on the negative side.
We did discuss how difficult the NPRM was to go through with the legal arguments that cover every possibility. If the goal is simplification, this will add a lot of complication.
One thing they got right was that the best way for FFEL loans to be discharged is to go through a DL consolidation.
Next step is for FRC to review again before submitting to WASFAA EC

Summary

We did not have any other discussions
We did establish that FRC meetings will be held the 3rd Thursday at 2:00 PT and Tami will set up the dates, while avoiding major holidays and conferences like the FSA.