Are There Exceptions To the Signature Requirement For Identity/Statement of Educational Purpose Due To Coronavirus?

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This AskRegs Knowledgebase Q&A was updated on August 24, 2020 to reflect extended deadlines in the August 21, 2020 Electronic Announcement. Per the announcement, the following guidance now applies through the end of the payment period that includes December 31, 2020 or the end of the payment period that includes the end date for the federally declared qualifying emergency related to COVID-19, whichever occurs later.

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 the U.S. Department of Education (ED), under normal circumstances the hardcopy with the original "wet" signature must be maintained in the student's file. The April 3rd guidance only waives the requirement to present the documents in-person to a school official or a notary; it does not appear to waive the wet signature requirement. 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.

NASFAA is attempting to obtain guidance for these unresolved issues. As soon as we have definitive answers to these questions, we will update this AskRegs Q&A and push it out in Today's News.

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 has received from the U.S. Department of Education (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").

Note: This AskRegs Q&A was previously updated to note that schools should use Identity Verification Results code "2" when reporting students via FAA Access.

AskRegs Q&As represent NASFAA's understanding of regulatory and compliance issues. They are FOR INTERNAL USE ONLY. While NASFAA believes AskRegs Q&As are accurate and factual, they have not been reviewed or approved by the U.S. Department of Education (ED). If you should need written confirmation of AskRegs information for audit or program review purposes, please contact your ED School Participation Division. NASFAA shall not be liable for technical or editorial errors or omissions contained herein; nor for incidental or consequential damages resulting from the furnishing, performance, or use of this material.