This AskRegs Knowledgebase Q&A was updated on March 3, 2021 to reflect additional guidance NASFAA has received from the U.S. Department of Education (ED) regarding acceptable signatures on the Statement of Educational Purpose.
Yes. The following guidance applies to verification of identity and Statement of Educational Purpose and is from the April 3, 2020 Electronic Announcement:
"For those borrowers in verification groups V4 or V5, the flexibilities listed below apply if the institution is unable to receive the required documents in person or by mail (e.g., qualified staff are not on campus to complete this task or students are not able to mail documents). These flexibilities also apply if the applicant or student is unable to provide the required documents in person or cannot provide notarized documents by mail.
We suspend the in-person submission and notary requirements for V4 and V5 verification. The institution may allow an applicant or student to submit copies of the required verification documents electronically to the institution. This may occur by uploading a photo of the documents (including from a smartphone), PDF, or other similar electronic document through a secure school portal, by email, etc.
We also recognize that forms of identification (such as a driver’s license) may expire with no real and reasonable opportunity for renewal due to social distancing requirements. Institutions may accept a copy of an expired document if it expired after March 1, 2020."
Of course, the Statement of Educational Purpose still must be signed. According to guidance NASFAA has received from ED, under normal circumstances the hardcopy with the original "wet" signature must be maintained in the student's file. However, due to COVID-19, the school may accept an electronic signature using a stylus or finger to sign the document, or an image of the individual’s signature affixed to the document, to complete the Identity/Statement of Educational Purpose verification requirement, but only for the effective period noted below.
Schools also have asked about Skype and Facetime options, for which we also do not have a direct answer from ED. See also AskRegs Q&As, Can We Allow Students To Send Verification and Other Documents Via Email Due To Coronavirus? and Can We Accept Photographed Or Scanned Documents By Smartphone Or Text Due To COVID-19?
The Statement of Educational Purpose must accompany a government issued photo ID. And, it still can be sent by postal mail. Unfortunately, ED's guidance does not mention students who did not previously have a government-issued photo ID and are currently unable to get one due to office closures and social distancing.
Effective Period of COVID-19 Exception: Per the January 15, 2021 Electronic Announcement and attached chart, the above guidance now applies through the end of the payment period that begins after the date on which the COVID-19 federally declared national emergency is rescinded.
Reporting: According to the FAA Access to CPS Online Demo System, when exercising the above flexibilities, you report Identity Verification Results code "2--Verification completed remotely, no issues found" when using the above flexibilities and reporting this in FAA Access. According to guidance NASFAA received from ED, the school also uses code "2" for students who were able to complete the verification requirement using a notary public (that counts as "remotely").
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