Are We Required To Adjust Direct Loan Period End Dates If We Extend Or Shorten Our Terms Due To Coronavirus?

This AskRegs Knowledgebase Q&A was updated on February 1, 2023 to note that the COVID-19 national emergency will end on May 11, 2023.

According to the COVID-19 FAQs attached to the U.S. Department of Education's (ED's) March 5, 2020 Electronic Announcement, "Institutions that choose to extend terms that begin on or before June 1, 2020 as a result of the COVID-19 outbreak are not required to change loan period end dates if the loan period was scheduled to end on the term end date."

According to guidance NASFAA received from ED, the same is true if the school chooses to shorten the loan period by shortening the term or academic year (late start or early end). The school is not required to change the loan period begin or end dates in the Common Origination and Disbursement (COD) System for these loans. This flexibility also applies to any changes that occurred after March 5, 2020 to the length of a loan period, regardless of when the loan was or will be originated. In other words, the above rules apply to both existing loans and newly originated loans. For example, if the school is originating a new loan during the term/payment period after March 5, 2020, the school is not required to extend the loan period in COD (unless COD edits block the origination).

NASFAA has confirmed with ED that the August 21st announcement now extends this flexibility to loan periods that include a term/payment period that includes December 31, 2020 or a term/payment period that includes the date on which the qualifying emergency is declared to be over, whichever is later.

Notes:

• This Q&A was previously updated on August 30, 2020 to inform schools that the August 21, 2020 Electronic Announcement extends ED's previous guidance about not changing loan period dates when a school shortens or extends a term/payment period within the loan period.
• Even given these flexibilities, we have been told by schools that COD edits might not allow you to originate a Direct Loan after the end of the loan period associated with the loan. In these cases, you will need to extend the loan period in order to pass the COD edits. We are not aware of any plans to suspend COD edits.