Compliance Checklist

In preparation for a program review, consider the following issues that typically are examined by reviewers. The relevant section of the Code of Federal Regulations and Common Manual are listed under each category heading.

Admission Requirements

[34 CFR §668.32]
[CM 5.9-5.10]

  • Is your policy to require evidence of a high school diploma, General Educational Development diploma, successful completion of six credits of college work (or equivalent), or a passed Ability to Benefit test for each student? If so, are those documents retained?
  • If you use ATB tests, have you ensured that they are independently administered?
  • If you have additional admissions criteria, do you ensure each student meets those requirements?

Enrollment Agreement

[34 CFR §668.32(a)(1)(i); §682.201(a)]
[CM 2.2.A; 6.15]

  • Are controls in place to ensure that the loan application is not certified prior to the enrollment agreement?
  • Are controls in place to ensure that each enrollment agreement is signed and dated by all appropriate parties?
  • Does each enrollment agreement indicate the program charges? Do the charges correspond with those on the account ledger card or tuition schedule?

Disclosure Statements and Notices

[34 CFR §668 Subparts C and D]
[CM 4.4; 8.2]

  • Are controls in place that ensure applicable disclosure statements (such as graduation rate, placement rate, student right-to-know and campus crime statistics) are provided to each student-borrower?
  • Are controls in place to send to the student, prior to delivering any Title IV funds, a notice that provides information about the amount of funds the student can expect to receive?
  • Do your procedures require the sending of a notice to the student- or parent-borrower before crediting the student’s school account with Stafford- or PLUS loan proceeds?

Noncitizenship/Social Security Number Verification

[34 CFR §668.33; §668.36]
[CM 6.6.A]

  • Do you verify the citizenship (or the eligibility of noncitizens) of each of your student-borrowers?

Programs of Study

[34 CFR §668.3(b); §668.8(b)(2)-(3)]
[CM 4.1.C; 6.1]

  • Are all programs that your institution offers approved by your accrediting and/or state licensing agency?
  • Does your academic year or program length meet minimum regulatory requirements?

Pell Grant Eligibility

[34 CFR §682.201(a)(1)]

  • Do you determine a student-borrower’s eligibility to receive a Pell Grant prior to certifying a loan application?
  • Do you ensure a valid SAR/ISIR has been received prior to delivering funds to each student?

Transfer Students

[34 CFR §668.19]
[CM 8.7.H]

  • Are procedures in place to verify each student-borrower’s previous financial aid via the National Student Loan Data System?
  • Do you verify the current loan status for each of their outstanding loans?

Verification Process

[34 CFR §668 Subpart E]
[CM 6.6.A]

  • Are controls in place to ensure that verification is performed prior to the delivery of loan proceeds for all student-borrowers selected for verification?
  • Are all tax documents signed and dated by the appropriate parties?
  • Is the student’s dependency status verified prior to loan certification?
  • Is the student’s family household size correct?

Entrance Counseling

[34 CFR §682.604(f)]
[CM 4.4.C]

  • Do you conduct entrance counseling prior to the delivery of loan proceeds?
  • Does your entrance counseling provide the borrower with all required information?
  • Do you retain adequate documentation to substantiate the performance of entrance counseling?

Subsidized Federal Stafford Loans

[34 CFR §682.204(a)-(b); §668.2(b); DCL GEN-92-21]
[CM 6.11.A-6.11.B]

  • Are there controls in place to ensure that the certifying official does not certify a loan that exceeds the annual loan limit?
  • Do you have procedures in place to prorate subsidized Stafford loans for periods less than one academic year?
  • Are procedures in place to document fully the student's cost of attendance and to retain that documentation as required?

Unsubsidized Federal Stafford Loans

[34 CFR §682.204(c)-(e); §668.2(b); DCL GEN-92-21]
[CM 6.11.A-6.11.D]

  • Are there controls in place to ensure that the certifying official does not certify a loan that exceeds the annual loan limit?
  • Do you have procedures in place to prorate unsubsidized Stafford loans for periods less than one academic year?
  • For dependent students who receive an additional unsubsidized Stafford loan, do you retain documentation that indicates the lender’s denial of a PLUS loan for the student-borrower’s parent?
  • Are procedures in place to document fully the student's cost of attendance and to retain that documentation as required?

Federal PLUS Loans

[34 CFR §682.204(h); §668.2(b); DCL GEN-92-21]
[CM 6.11; 6.11.C; 6.15.C]

  • Are there controls in place to ensure that PLUS loan amounts do not exceed the cost of attendance minus other financial aid?
  • Are controls in place to ensure each PLUS applicant is an eligible borrower?
  • Are controls in place to ensure each student for whom a parent PLUS loan has been obtained remains eligible?
  • Are procedures in place to document fully the student's cost of attendance and to retain that documentation as required?

Administrative Capability

[34 CFR §668.16; §668.24; §682.203(a)]
[CM 4.2; 4.5]

  • Is there an adequate number of qualified personnel available to administer Title IV loan programs?
  • Are adequate checks and balances and internal controls in place, as well as a division of duties for authorizing payments and delivering FFELP funds?
  • Do you have a process in place for financial aid staff to receive current information as regulations change?
  • Do you keep complete and accurate records for each student for at least three years after the end of the award year in which the student last attended?
  • Are procedures in place to document fully the student's cost of attendance and to retain that documentation as required?

School Loan Certification

[34 CFR §682.603; §682.200(b)]
[CM 6.5; 6.15]

  • Do you include loan fees in the COA?
  • Do you have controls in place to ensure that the number of months in a student’s budget equals the number of months in the student’s loan period?
  • Do you have procedures in place to verify that the expected family contribution from the SAR/ISIR matches the EFC on the loan application?
  • Do you verify that loan amounts do not exceed each student’s need based on all financial aid the student has received?
  • Do you verify each student-applicant is an eligible borrower (for example, is not in default).

Satisfactory Academic Progress

[34 CFR §668.16(e); §668.34]
[CM 8.4]

  • Do you verify that each student has achieved SAP prior to delivering each loan disbursement or at other specific times during the academic year?
  • Does your policy contain both a qualitative component (for example, grades) and a quantitative component (for example, a maximum period of time a student is permitted to complete each program)?
  • Do you evaluate each student’s SAP at regular intervals to ensure the student is on track to timely complete the student’s program of study?

Loan Check Processing/Cash Management

[34 CFR §668 Subpart K; 34 CFR §682.604(a)-(e)]
[CM 8.7-8.9]

  • Do you have controls in place to delay the delivery of loan proceeds to first-year, first-time borrowers? Note waivers to this requirement in GEN-06-02.
  • Do you deliver EFT funds within three business days?
  • Are there controls in place to ensure the student remains eligible for the loan funds at the time of disbursement?
  • Are there controls in place to ensure students in a study-abroad program remain eligible for loan funds at the time of disbursement?
  • Are controls in place to ensure that no loan funds are delivered while a student is on an approved leave of absence?
  • Are procedures in place to notify student-borrowers each time EFT funds are credited to their accounts?
  • Do you have procedures in place to ensure that funds are returned to the lender if they cannot be promptly delivered to the student?
  • In the case of a late disbursement, do you ensure that the borrower meets eligibility criteria for a late disbursement before delivering the loan proceeds?
  • Have you confirmed that any bank or investment account that includes Title IV, HEA program funds includes the phrase “Federal Funds” in the name of the account, or that a notice was sent to the bank or investment company notifying them that the account contains Title IV, HEA program funds?

Leave of Absence

[34 CFR §668.22(d)-(j)]
[CM 9.3]

  • Do you have procedures in place to ensure that all approved LOAs are requested in writing by the applicable student?
  • Do you take appropriate measures to ensure that the sum of the length of all LOAs granted to a student in a single 12-month period does not exceed 180 days?
  • Do you publish a written LOA policy and have procedures in place for all students to receive a copy of the policy?

Last Date of Attendance (LDA)

[34 CFR §668.22(b)-(c); §682.605]
[CM 9.4]

  • Are there controls in place to ensure that each student’s LDA is properly documented and the LDA used for Return of Title IV Funds purposes is the same LDA used for NLSDS reporting purposes?
  • Do you report the LDA to the applicable lender or guarantor if your scheduled enrollment reporting to NSLDS is more than 60 days in the future?
  • Do you have procedures that describe the method for determining the date of withdrawal at your institution?

Refunds

[34 CFR §668.22; §682.607]
[CM 9.5]

  • Do you have staff knowledgeable in the use of the federal Return of Title IV Funds calculation?
  • Does your refund policy include the use of a pro-rata calculation when necessary?
  • Are controls in place to ensure refunds are made within 45 days of determining a student withdrew?

Notice of Refund to Student

[34 CFR §682.607(a)(2)]

  • Are there controls in place that ensure students are notified of any refunds simultaneous to the school sending the refund to the lender?

Exit Counseling

[34 CFR §682.604(g)]
[CM 4.4.D]

  • Are there regular procedures for scheduling and performing exit counseling with upcoming graduates?
  • Are there procedures in place to mail exit counseling materials to each student within 30 days of determining that the student has withdrawn?
  • Are there procedures in place to notify lenders and guarantors of updated demographic information within 60 days of its receipt?
  • Do you retain adequate documentation to substantiate the performance of exit counseling?
  • If exit counseling is provided by a third party, have you reviewed and approved the counseling materials?

Student Consumer Information

[34 CFR §668.41-48]
[CM 4.4.A-B]

  • Do you, on an annual basis, provide consumer information concerning the school to all enrolled students, and upon request, to prospective students?
  • As part of such consumer information, do you provide financial assistance information regarding your programs, including a description of all federal-, state-, local-, private- and institutional aid programs?
  • Does your consumer information include a description of student rights and responsibilities specifically addressing financial assistance under Title IV programs?

Default Management Plan

[School’s Default Management Plan]

  • If you have a default management plan that requires you to contact borrowers during their grace period, do you have procedures in place that ensure timely contact?
  • If you have a default management plan that requires you to contact borrowers who are delinquent in repaying their loan(s), do you have procedures in place that ensure timely contact?
  • If you have a default-management plan, and it includes obtaining additional references, are controls in place to ensure that those references are obtained prior to disbursement?