Yesterday, the Department of Education announced that it had released the Official Cohort Default Rates (“CDR”) for Fiscal Year 2016.  The FY2016 rates track students whose loans entered repayment between October 1, 2015 and September 30, 2016 as well as student borrower defaults that occurred between  FY 2016 and the following two fiscal years (October 1, 2015 through September 30, 2018).  

Schools should review their eCDR notification packages rates immediately.  In the event your institution is subject to sanction based on the FY2016 CDR, it is critical that your institution review its Loan Record Detail Report and assess whether the school qualifies for either an adjustment or appeal, e.g., uncorrected  data adjustment, erroneous data appeal, loan servicing appeal, economically disadvantaged appeal, etc.

Each of these remedies has a deadline for submission, and ED can reject any application for adjustment or appeal that is untimely, incomplete, or inaccurate. The timeline for requesting an adjustment, challenge, or appeal begins on the sixth business day following ED’s announcement of the release of the official CDR.  This year that time frame will commence on October 1, 2019. 

If you have any questions about your available remedies or strategies for managing CDRs, contact Steve Chema at 703-934-2660 or stchema@glpclaw.com