[Lender] Follow-up to ED Liquidity Webinar
Edington, Rick
redington at ogslp.org
Tue Jul 1 17:33:53 CDT 2008
As a follow-up to the ED Webinar held today, and especially for those
interested lenders who were not able to attend, we wanted to highlight a
few noteworthy and important items that were brought up both during
recent industry calls with ED and in the Webinar today.
* Filing of Notice of Intent to Participate- If your organization
anticipates any potential need to exercise either the "put" or both the
"put" and the "participating interest" option, it is critical that you
file a Notice of Intent to Participate with ED in a timely manner. Be
sure to consider the possibility of selling loans to another party who
would want to participate. If you have not filed a Notice of Intent,
the other party you sell loans to will not be able to participate with
the loans you have sold to them. Notices of Intent to Participate
received by ED within 15 days after publication in the Federal Register
(by July 16, 2008) will allow lenders the right to "put" loans
originated on or after 5/1/08. Notices of Intent to Participate filed
after the 15 day window of publication in the Federal Register will
result in lenders being able to "put" ONLY loans made on or after the
date ED receives the Notice of Intent from the lender. Notices of
Intent do NOT obligate the lender to actually participate; they only
serve to endow the lender with the future right to participate in the
option(s). FYI- the original Notice of Intent to Participate form is
being corrected and will be posted to ED's site tonight or tomorrow.
Below is a link to the site.
http://federalstudentaid.ed.gov/ffelp/
Note- More documents, the presentation from today's Webinar and Q
& A listings will be posted to this site by ED.
* "Custodian" requirement- A third-party custodian will be
required for lenders. The Custodian must be a National or
State-chartered bank that is an eligible lender pursuant to 435 (d) (1)
(A) of the HEA.
* Allowable back-end borrower benefits- As a reminder, the only
allowable back-end borrower benefit on loans to be sold to ED is the
reduction of one-quarter of one percent in the loan's interest rate if
the borrower elects to have his or her monthly payments paid
automatically through an electronic debit process. Up-front borrower
benefits such as origination and default fee payments continue to be
allowed since they would have been paid prior to the sale of the loan.
* Program Questions & Answers- ED is expected to post Q & A's
received from the industry prior to and during the Webinar on their
site. As a benefit of Mary Mowdy's participation in industry conference
calls in her role as NCHELP Board Chair, we are providing a listing of
trade association Q & A's submitted to ED prior to the Webinar and a
copy of a letter from trade associations concerning servicing and
guarantee of loans purchased by ED. These documents are encrypted and
will be stored on our site at the following link:
http://www.ogslp.org/schools-lenders/olac_docs/olac_index.shtml. The
password for both files is:
ffe!plenders0K (note- use a zero, not the
letter "0")
ED has indicated that there will be future Webinars and information
posted to their site. We encourage you to bookmark their site and to
check back for additional information. OGSLP will keep you updated,
including any notices of future related ED Webinar offerings.
Rick
Rick Edington
Director for School/Lender Services, Default Prevention & Outreach
Oklahoma Guaranteed Student Loan Program
A division of the Oklahoma State Regents for Higher Education
P.O. Box 3000
Oklahoma City, OK 73101-3000
405-234-4333 fax: 405-234-4551
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