description: tags: 97-eda

8/14/2019 description: tags: 97-eda

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FY 1997 Official Cohort Default Rate Guide Page 77

Erroneous Data

Appeal

What is an erroneous data appeal?

An erroneous data appeal is a challenge submitted to the

Department alleging that a schools official cohort default rate isinaccurate because of incorrect data.1

Which schools are eligible to submit anerroneous data appeal?

Only schools that are subject to the following sanctions as a resultof the school's official cohort default rates may submit an erroneousdata appeal:

initial loss of Federal Family Education Loan (FFEL)Program and/or William D. Ford Federal Direct Loan(Direct Loan) Program and Federal Pell GrantProgram eligibility;2

OR

extended loss of FFEL Program and/or Direct LoanProgram and Federal Pell Grant Program eligibility;3

AND/OR

1 34 CFR 668.17(c)(1)(i)(A)2 34 CFR 668.17(b)3 Id.

QUALIFYING


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Erroneous Data Appeal Information for Schools on Appeals

Page 78 FY 1997 Official Cohort Default Rate Guide

possible action to limit, suspend, and/or terminate(LS&T) eligibility to participate in all Title IV StudentFinancial Assistance Programs.4

These schools may only file an appeal based on erroneous data if:

there are disputed data remaining from the schoolsdraft data challenge(s);

AND/OR

there are incorrect new data appearing in theschools official loan record detail report.

Disputed data and incorrect new data are explained in detailbeginning on page 83.

Why should a school submit an erroneousdata appeal?

If eligible, a school should submit an erroneous data appeal if itbelieves that there are disputed data or incorrect new data in theschools official loan record detail report and it has not previouslyappealed the official cohort default rate based on allegations oferroneous data.

In order to appeal based on erroneous data, a schoolmust prove that the recalculated rate using correcteddata would, by itself or in conjunction with animproper loan servicing and collection appeal and/or arequest for adjustment, produce an official cohortdefault rate lower than the applicable sanctionthreshold.

4 34 CFR 668.17(a)(2)

Q .Q . What is a draft datachallenge?

A .A . A draft data challengeis the process used by aschool to correct cohortdefault rate data before theofficial cohort default ratesare calculated.

Please refer to theDepartments FY 1997 DraftCohort Default Rate Guidefor additional information ondraft data challenges.


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Information for Schools on Appeals Erroneous Data Appea


Erroneous Data AppealEligibility Checklist

To be eligible to appeal its official cohort default rate on thebasis of erroneous data, a school must meet ALL of thefollowing criteria:

o The school is subject to a sanction as described onpage 77 and 78

o The school 9y Cuesf tatl its official cohort default rate

OR8

o The schoo'so appea, byl itelf forinl cmbinactionwith7 ae

o The schoolh asNOT previeouly


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Which cohort default rates may a schoolappeal?

The sanctions to which a school is subject determine which cohort

default rates the school may appeal on the basis of erroneous data.

If the school is subject to initial loss of FFELProgram and/or Direct Loan Program and FederalPell Grant Program eligibility, it may appeal on thebasis of erroneous data on any or all of the three mostrecent official cohort default rates on which the loss ofeligibility is basedas long as it has not previouslyappealed that fiscal years official cohort default ratecalculation on the basis of erroneous data. This year,the school may appeal its FY 1995, FY 1996, and/or

FY 1997 official cohort default rates.

If the school is subject to extended loss of FFELProgram and/or Direct Loan Program and FederalPell Grant Program eligibility, it may appeal only themost recent years (in this case FY 1997) officialcohort default rate.

If the school is subject to possible action to LS&T itsparticipation in all Title IV Student Financial

Assistance Programs due to its most recent officialcohort default rate, but it is NOT subject to initial lossof FFEL Program and/or Direct Loan Program andFederal Pell Grant Program eligibility, it may appealonly the most recent (in this case FY 1997) officialcohort default rate.

If a school is NOT subject to sanctions, the school isnot eligible to file an erroneous data appeal with theDepartment and, if an appeal is filed, the Departmentwill NOT review it. The school may, however, be

eligible to file a request for adjustment.

Please refer to the Request for Adjustment sectionon page 65 for more information on filing a request foradjustment.

Q .Q . If a school is subjectto both initial loss of FFELProgram and/or Direct LoanProgram and Federal PellGrant Program eligibilityAND LS&T, which officialcohort default rates may the

school appeal?A .A . The school mayappeal its three most recentofficial cohort default rates,as long as it has notpreviously appealed theofficial cohort default ratecalculation on the basis oferroneous data.


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The table below summarizes the official cohort default rates that aschool may appeal on the basis of erroneous data

Official Cohort Default Rates That May Be

Appealed on the Basis of Erroneous DataIf a school is subject to ... the school may...

no sanctions NOT appeal

initial loss of FFEL Programand/or Direct Loan Program andFederal Pell Grant Program

appeal FY 1997, FY 1996,* andFY 1995*

extended loss of FFEL Programand/or Direct Loan Program andFederal Pell Grant Program

appeal FY 1997

LS&T only (based on FY 1997cohort default rate) appeal FY 1997

LS&T AND initial loss of FFELProgram and/or Direct LoanProgram and Federal Pell GrantProgram

appeal FY 1997, FY 1996,* andFY 1995*

* Provided that the school has not previously appealed the cohort default rate onthe basis of erroneous data.

How can an erroneous data appeal affect the

schools official cohort default rate?

If, as a result of an erroneous data appeal, the Departmentdetermines that a schools cohort default rate is incorrect, theDepartment will recalculate the rate using the corrected data. Thismay lower, raise, or not affect any of a schools three most recentofficial cohort default rates.

Please refer to page 24 of the Cohort Default Rates section forinformation on adding and subtracting loans from the cohort defaultrate calculation.

Even though the Department may alter a schoolscohort default rate calculation, subsequent copies ofthe school's loan record detail report will not reflectthe change. Therefore, it is important to keep a copyof the Department's final determination letter as theofficial record of the schools cohort default rate.


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Is a request for adjustment a type of anerroneous data appeal?

No, a request for adjustment is NOT a type of an erroneous data

appeal. Requests for adjustment concern changes to data errorsthat were correctly agreed to in a draft data challenge but were notmade. Erroneous data appeals concern disputed data that was notresolved prior to the release of the official cohort default ratesand/or incorrect new data that appeared after the release of theofficial cohort default rates.

A school may be eligible to submit both a request foradjustment and an erroneous data appeal. If a schoolis submitting both, the two have different deadlinesand standards, and they MUST be submitted

separately.

Please refer to the Request for Adjustment section beginning onpage 65 for more information on requests for adjustment.

What are erroneous data?

Erroneous data refer to various types of loan information used tocalculate a schools official cohort default rate that do not match theschools records and/or information from outside sources and theschool believes are incorrect.

Examples of erroneous data would be if, in reconciling the officialloan record detail report against the school's records, a schooldiscovers that:

some borrowers are not reported correctly in theofficial cohort default rate calculation;

AND/OR

some borrowers are omitted entirely from thecalculation.


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When preparing its appeal, a school will want toreview, at a minimum, attendance records, copies ofloan applications, and copies of cancelled checks.Outside sources that a school will want to reviewinclude, but are not limited to, records of lenders,

borrowers, guaranty agencies, the Direct Loanservicer, or other schools where former borrowersenrolled.

Erroneous data may be disputed data and/or incorrect new data.

What is disputed data?

Disputed data occur when the entity responding to a schools draftdata challenge does not agree that a loan is incorrectly included orexcluded from the cohort default rate calculation.

After the release of the official cohort default rates, a school mayappeal on the basis of disputed data if:

the school included the error in its draft datachallenge;

AND

the entity that responded to the draft data challengedid NOT agree with the error the school alleged;

AND

the school believes that the entitys response to theerror is incorrect;

AND

the alleged error is included in the calculation of theschools official cohort default rate;

AND

the school is subject to sanctions.

After the release of the official cohort default rates,allegations of disputed data must be re-addressed tothe entity that responded to the draft data challengeprior to submitting the allegations of disputed data tothe Department.


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What is incorrect new data?

Incorrect new data occur when data are used in the official cohortdefault rate calculation in a manner that is different from the way

the data was used in the draft cohort default rate calculation. Forexample, a non-defaulted loan was included in the draft cohortdefault rate calculation BUT excluded from the official cohort defaultrate calculation.

After the release of the official cohort default rates, a school mayappeal on the basis of incorrect new data if:

the school discovers that a loan on its official loanrecord detail report is used in the cohort default ratecalculation in a different manner than on its draft loan

record detail report;

AND

the school determines that the change did NOT resultfrom its draft data challenge;

AND

the school believes that the way the loan is beingused in the official cohort default rate calculation is

incorrect;

AND

the school is subject to sanctions.

If the official data are the same as the draft data, andthe school did NOT challenge the data as a part of itsdraft data challenge, it may NOT appeal the data asincorrect new data as a part of an erroneous dataappeal.5 If these data issues are appealed to the

Department, they will NOT be reviewed.

5 34 CFR 668.17(j)(7) (published December 1, 1995)

Q .Q . What causes newdata to appear in the officialcohort default ratecalculation?

A .A . NSLDS iscontinuously being providednew/updated information.The draft cohort default ratesare calculated in the springand approximately sixmonths later, the officialcohort default rates arecalculated. Therefore, thedata used to calculate thedraft cohort default rate maybe different than the dataused to calculate the officialcohort default rate.


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What types of allegations may a school submitas a part of an erroneous data appeal?

The following are examples of various types of disputed and/orincorrect new data allegations a school may submit as a part of itserroneous data appeal. Prior to submitting these allegations to theDepartment as a part of an erroneous data appeal, the school mustfirst submit an erroneous data request to the entity responsible forthe loan.

Incorrect date entered repayment (DER)

If a school believes that the DER for a loan listed onthe loan record detail report is incorrect, it shouldinclude documentation in its appeal to support thecorrect DER and proof that the guarantyagency/Direct Loan servicer or lender received thedocument in a timely manner.

Loan received an insufficient grace period

If a school believes that a loan received an insufficientgrace period, the school should determine if the DERlisted in the schools loan record detail report iscorrect. If the DER is incorrect, the school shouldinclude documentation in its appeal to support the

correct DER and proof that the guarantyagency/Direct Loan servicer or lender received thedocument in a timely manner.

Loan received an insufficient delinquency period

If a school believes that a loan received an insufficientdelinquency period, the school should determine if theDER and default date/claim paid date listed in theschools loan record detail report are correct. If theDER and/or default date/claim paid date are incorrect,the school should include documentation in its appeal

to support the correct DER or default date/claim paiddate and proof that the guaranty agency/Direct Loanservicer or lender received the document in a timelymanner.

Q .Q . Who is responsiblefor responding to erroneoudata requests?

A .A . The entity identifiedby the guarantor/servicercode on the loan recorddetail report is responsiblefor responding to requestsfor verification of error.

Please also refer to page 4for a summary of who isresponsible for respondingerroneous data requests.


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If the documentation submitted by the school as apart of its appeal was never originally received by theguaranty agency/Direct Loan servicer or lender, orwas not received in a timely manner, and the schoolhas not provided proof that it submitted the

documentation to the guaranty agency/Direct Loanservicer or lender in a timely manner, the guarantyagency/Direct Loan servicer may respond that theDER was determined based on the best informationavailable at the time, and as a result, no change iswarranted.

Loan incorrectly converted using date-specificand/or month-specific methodology

The repayment date for FFEL Program loans must bedate-specific (for example, 2/16/1996) NOT month-

specific (for example, 2/1996) if the loan wasconverted into repayment on or after March 1,1996.

If a lender failed to use date-specific methodology toconvert a loan into repayment on or after March 1,1996, the school should submit the allegation as apart of its appeal.

Federal SLS Loan not linked to an FFEL ProgramStafford Loan

If a school believes a Federal SLS loan should belinked to an FFEL Program Stafford loan, the schoolshould determine, for any Federal SLS loan that wasNOT reported in a cohort period prior to FY 1993, ifthe borrower has both a Federal SLS loan and anFFEL Program Stafford loan that were both obtainedin the same period of continuous enrollment.

If the borrower has both a Federal SLS and an FFELProgram Stafford loan given during the same periodof continuous enrollment, the date the borrower

entered repayment for the Federal SLS loan is thesame as the date the borrower entered repayment forthe FFEL Program Stafford loan. In all otherinstances, the date the borrower entered repaymentfor the Federal SLS loan is the day following the daythe borrower is no longer enrolled on at least a half-time basis.


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If the DER for the Federal SLS loan is listed on theloan record detail report incorrectly, the school shouldinclude the allegation as a part of its erroneous dataappeal.

Under the above guidelines, which wereimplemented beginning with FY 1993 cohortdefault rates, a Federal SLS loan that wasreported as having entered repayment prior toFY 1993 might also meet the criteria to beincluded in FY 1993 or later. To prevent thepossibility of double-counting loans, anyFederal SLS loan that was reported in a cohortperiod prior to FY 1993 will remain in thatcohort period and not be reported again.

Loan was repurchased by the lenderIf a school believes that a loan was repurchased bythe lender and should be removed from the cohortdefault rate calculation, the school should determinewhy the loan was repurchased.

v If the loan was repurchased by the lenderbecause the guaranty agency determined thatthe lender failed to meet the insurancerequirements, the loan is an uninsured loan.

Uninsured loans are not included in either thenumerator or the denominator of the cohortdefault rate calculation.

v If the loan was repurchased because thelender incorrectly submitted the loan to theguaranty agency and the lender immediately

requested the loan be returned, the loan wasnot a defaulted loan and should be removedfrom the numerator of the cohort default ratecalculation, UNLESS the lender subsequentlysubmitted another claim on the loan and that

claim was paid within the cohort period theloan entered repayment.


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v If the loan was repurchased because theborrower established a new payment planand was making payments or if thelender/servicer simply requested therepurchase (i.e., a courtesy repurchase), the

loan is still considered a defaulted loan forcohort default rate purposes and should beincluded in both the numerator anddenominator of the cohort default ratecalculation, UNLESS the loan meets therehabilitation criteria discussed in the specialcircumstances chart on page 21.

If a school believes that a loan does not belong in theschool's cohort default rate calculation, the schoolshould include the allegation as a part of its erroneousdata appeal.

What role does a guaranty agency have in aschools erroneous data appeal?

A guaranty agency6 is required to respond to a schools timelysubmitted erroneous data request for those loans on which theagency currently maintains the guaranty. The agency mustrespond to the school's erroneous data request within 15 workingdays of receiving the request.

If the guaranty agency does not respond within 15 working days,

the school should advise the Departments Default ManagementDivision in writing of the delay.

The deadline for a school to submit its appeal to theDepartment is based on the date the school receivesits last response to ALL of its erroneous datarequest(s).

In its response to a schools request, the guaranty agency willaddress each of the schools allegations. However, the guarantyagency is NOT required to respond to an erroneous data request ifthe 10 working day time frame to submit such requests has expired.

Please refer to the Information for Guaranty Agencies on Appealssection beginning on page 243 for more information on guarantyagency responsibilities and the "Timing and Submitting" portion ofthis section beginning on page 90 for more information on the timeframes associated with erroneous data appeals.

6 34 CFR 682.401(b)(15)


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Based on a last date ofattendance of July 15, 1997, thedate entered repayment shouldbe January 16, 1998 and the loanshould be removed from the

schools FY 1997 cohort defaultrate calculation.

Identify any incorrect new data appearing inthe schools official loan record detail report by:

v comparing the draft loan record detailreport to the official loan record detailreport;

v identifying differences between the draft

and official loan record detail reports.Example: Business Schools FY 1997 draft

loan record detail report indicatesthat Vickie Burleson's Staffordloan was not counted in theschool's FY 1997 cohort defaultrate. However, BusinessSchool's FY 1997 official loanrecord detail report indicates thatVickie's Stafford loan is countedin both the numerator anddenominator of the school's FY1997 cohort default rate.

AND

v determining if the change between thetwo reports results in incorrect data.

When determining if data is incorrect, aschool should determine if:

the date the loan enteredrepayment is correct;

the loan claim paid date/defaultdate is correct;

cancelled loans are correctlyexcluded from the cohort defaultrate calculation;


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uninsured loans are correctlyexcluded from the cohort defaultrate calculation;

loans that were discharged prior

to defaulting are correctlyexcluded from the numerator ofthe cohort default ratecalculation;

any loans that entered repaymentin the cohort year have not beenexcluded from the loan recorddetail report (i.e. are theremissing loans?);

AND

the same loan was not reportedin two different cohort years (i.e.,are there duplicated loans?).

These are some, but not all, ofthe areas in which errors mightoccur.

Example: Vickie Burleson's loan was fullycancelled within 120 days ofreceiving the first disbursementon the loan BUT the loan is listedin the numerator anddenominator of the school's FY1997 official loan record detailreport.

Step 3: If disputed data and/or incorrect new data is identified,within the time frame described in Step 1 (i.e.,within 10 working days of receiving its official cohortdefault rate), a school must

Compile a spreadsheet of disputed andincorrect new data errors by:

v reviewing the sample spreadsheet andinstructions beginning on page 104;

AND


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v recording all disputed and incorrect newdata errors on a spreadsheet(s) similarto the sample Erroneous Data Requestspreadsheet on page 105.

A school should complete a separatespreadsheet for each entity thatcurrently holds or maintains theguaranty on the loan for which an errorhas been identified.

Compile copies of the relevant pages of theloan record detail report;

v Include the page of the loan recorddetail report where the borrowerappears, or where the borrower should

appear. Provide both pages of the loanrecord detail report if the borrowerappears/belongs at the end of one pageor at the beginning of the next page.

v If the borrower is being moved from oneyear to another, include the page of theloan record detail report where theborrower currently appears, and thepage of the loan record detail reportwhere the borrower should appear.

v If the allegation is based on new data,the school should include the draft loanrecord detail report along with the officialloan record detail report to demonstratethat the data is actually new data.

AND

Compile copies of relevant supportingdocumentation that demonstrates that the loanis not being correctly used in the cohort defaultrate calculation:

v Signed and dated copy of a letter to therelevant lender, guaranty agency and/orservicer that timely informs the entity ofthe borrowers last date of attendanceand proof that the guarantyagency/Direct Loan servicer or servicerreceived the documentation;


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v Signed and dated copy of a StudentStatus Confirmation Report (SSCR) sentto a relevant entity that timely confirmsthe borrowers last date of attendanceand proof that the guaranty

agency/Direct Loan servicer or servicerreceived the documentation;

AND/OR

v A screen print from the SSCR functionwithin NSLDS that timely confirms theborrowers last date of attendance wasrecorded within NSLDS and proof thatthe guaranty agency/Direct Loanservicer or servicer received thedocumentation.

These are some, but not all, of thepossible documentation that may beprovided to support a school'sallegation.

Step 4: Within the time frame described in Step 1 (i.e.,within 10 working days of receiving its official cohortdefault rate), a school must

Request verification of the identified errorsfrom each entity that currently holds ormaintains the guaranty on the loan for whichan error has been identified by:

v submitting a request letter using thesample Erroneous Data Request coverletter on page 103;

The addresses for the relevant entitiesto which the request must be submittedcan be found by cross-referencing the

guarantor/servicer code on the loanrecord detail report and locating theguarantor/servicer code in AppendicesA and B.

Q .Q . How long does aguaranty agency/DirectLoan servicer have torespond to a school'serroneous data request?

A .A . A guarantyagency/Direct Loan servichas 15 working days torespond to a school'serroneous data request.

Please refer to the sectionentitled "Information forGuaranty Agencies onAppeals" on page 243 formore information aboutresponses to a school's

erroneous data request.


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Step 6. Within 5 working days of receiving the last response

to ALL of the schools erroneous data requests(s)],decide how to proceed.

A school should withdraw from the erroneousdata appeal process if it is convinced that thereare not any errors in its cohort default ratecalculation;

OR

A school should continue with the erroneousdata appeal process if:

v it disagrees with the responses receivedto its erroneous data request;

OR

v the responses indicate that a change iswarranted.

Even if the guaranty agency/Direct Loan serviceragrees that a change is warranted, the school muststill submit the change to the Department only theDepartment can decide on and make therecommended changes.

Step 7. Notify the Department whether the school is

withdrawing from the appeal process or continuingwith the appeal process.

If the school wants to withdraw its erroneousdata appeal, within 5 working days of

receiving the last response to ALL of itsrequests for erroneous data, notify theDepartment in writing that the school iswithdrawing its erroneous data appeal.

If the school withdraws its appeal, it is still

liable to pay the Secretary interest, specialallowance, reinsurance, and other related andsimilar payments for FFEL Program and DirectLoan Program loans certified/delivered andoriginated/disbursed beginning 30 calendardays after the school received notification of itscohort default rate until it withdraws its appeal.

Due date forsubmittingthe appeal tothe

Department.


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Please refer to the "Withdrawing an Appeal"section on page 237.

OR

If the school wants to continue with theerroneous data appeal process, it must:

v submit the school's allegations ofdisputed and/or incorrect new data tothe Department within 5 working daysof receiving the last response to ALL ofits erroneous data requests using theaddress on page 101;

OR

v submit the erroneous data appeal withan improper loan servicing andcollection appeal.

If a school is submitting both anerroneous data appeal and an improperloan servicing and collection appeal, itmay submit the two simultaneously bythe latter of:

within 5 working days of receiptof the last response to ALL of theschool's erroneous data requests;

OR

within 30 calendar days ofreceipt of the last response toALL of the school's requests forloan servicing records.

If a school is appealing its three most recent years of

cohort default rates, it should submit all threeerroneous data appeals in a single mailing to theDepartment.

Step 8. Within the time frames described in Step 7,

compile a list of the disputed and/or incorrect newdata using the sample Erroneous DataAppeal

spreadsheet on page 109.

Q .Q . May a school submitits request for adjustmentwith its erroneous dataappeal and/or improperloan servicing andcollection appeal?

A .A . No. A schoolsrequest for adjustment mustbe submitted separatelyand within 30 calendardays of receiving its officialloan record detail report.


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Step 9: Within the time frames described in Step 7, submit

the school's erroneous data appeal to the Departmentusing the address on page 101.

If a school fails to timely submit its erroneous dataappeal to the Department's Default ManagementDivision, the Department will not review the appealand will return all appeal-related material to theschool.

The Department recommends that the school submitan erroneous data appeal in a single, tabbed binder.The recommended tabs and materials are shown onthe next page.

.


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The following material should be sent to the Department's DefaultManagement Division at the address shown on page 101.

The section behind Tab 1 contains:

A letter on the schools letterhead with

the schools OPE ID number; a statement indicating that the school is submitting an erroneous data

appeal;

the fiscal year(s) to which the appeal applies; a certification that indicates that the information provided in the appeal,

under penalty of perjury, is true and correct8;

the signature of the schools President/ CEO/Owner, followed by asignature block providing the signers name and job title;

AND

a notation that a copy of the cover letter will be sent to the relevantguaranty agency and/or Direct Loan Servicer.

Schools only need to send a copy of the cover letter of the appeal to theguaranty agency and/or Direct Loan servicer. It is not necessary to sendthe entire appeal to the guaranty agency and/or Direct Loan servicer.

Schools should refer to the sample Erroneous Data Appeal cover letter,on page 107.


Copies of all relevant correspondence, including:

the responses to the school's request(s) for error;AND/OR

the response(s) to the schools draft data challenge(s).The section behind Tab 3 contains:

A spreadsheet of ALL of the schools alleged data errors in the officialcohort default rate.

Schools should refer to the sample Erroneous Data Appeal spreadsheet onpage 109 and detailed instructions on how to create the spreadsheet on page108.


Supporting documentation to support the schools list of alleged errors.

Schools should refer to page 94 and 95 for information on supportingdocumentation.

Schools do NOT need to submit copies of their loan record detail reports to

the Department.

The Department will review only the information submitted with theerroneous data appeal and will not consider information submitted afterthe regulatory deadlines. The Department will send the school and eachinvolved entity written notification of its decision. The Departmentsdecision is final and no further administrative review is provided.

8 34 CFR 668.17(c)(6)

Tab 1

Tab 2

Tab 3

Tab 4


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Sample Erroneous Data Request Cover Letter

October 6, 1999

State Guaranty Agency OPE ID#: 111222

Guarantor/Servicer Code 111ATTN: Compliance Officer1010 Maple Lane, Suite 200Woodston, Michigan 98765-4321

Dear Mr. Bowen:

School of Business, OPE ID# 111222, is submitting an erroneous datarequest of the attached errors in its official loan record detail report forFY 1997.


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Sample Erroneous Data Request Spreadsheet

10/06/1999

[sendtoth

erelevantentity

Page

1of1

attheadd

resslocatedin

AppendicesAandB.]

9.Effect

onCDR

calc.

(N,D,

orB)

-D+D

-B

8.FY(s)

appl.

FY1997

FY1998

FY1997

7.CPD

DD,ICRD,

orN/A

(MM/DD/CCYY)

or(MM/CCYY)

N/A

cancelled

6.Dat

e

enter

ed

repaym

ent

(DER)

(MM/DD/CCYY)

01/16/1998

cancelled

5.Earlier

ofLDA

orLTH

(MM/DD/CCYY)

07/15/1997

cancelled

4.

Typeof

loan

(U

secodes

oninstructions)

SF

SF

3.Basisof

allegederror

(DisputedorNew)

Disputed

New

2.Borrower's

Name

T

om

Tucker

Vic

kieBurleson

1.Borrower's

SSN

121-21-2121

232-23-2323

FY1997

Er

roneousDataRequest

SchoolofBusiness

OPEIDNumber111222

Guarantor/ServicerC

ode111

ABCGuarantyAgency

Note:Thisisasample

spreadsheet.Seeinstructions

onthepreviouspage.


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Sample Erroneous Data Appeal Cover Letter

January 4, 1999

U.S. Department of Education OPE ID#: 111222Default Management DivisionATTN: Erroneous Data AppealPortals Building, Room 6300

400 Maryland Avenue, S.W.Washington, D.C. 20202-5353

Dear Default Management Division:

School of Business, OPE ID# 111222, is submitting the attachedappeal based on allegations of erroneous data in its FY 1997 officialcohort default rate.

Please see the enclosed correspondence, spreadsheet, andsupporting documentation.

I, the undersigned, certify under penalty of perjury, that all informationsubmitted in support of the erroneous data appeal is true and correct.

Sincerely,

R obert Y oungR ober t Y oungRobert Young, President

Enclosures

cc: State Guaranty AgencyDirect Loan Servicer

Subject: FY 1997 Erroneous Data Appeal

School of Business1212 Wedgewood LaneLeonardtown, Wisconsin 12345-6789

123-456-7890

Sample Letter


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Sample Erroneous Data Appeal Spreadsheet

10.Effect

onCDR

calc.

(N,D,

orB)

-D+D-B

9.FY(s)

appl.

FY1997

FY1998

FY1997

8.Entity

Code

from

LRDR

111

111

7.CPD

DD,ICRD,

orN/A

(MM/DD/CCYY)

or(MM/CCYY)

N/A

Cancelled

6.Date

entered

repayment

(DER)

(MM/DD/CCYY)

01/16/1998

Cancelled

5.Earlier

ofLDA

orLTH

(MM/DD/CCYY)

07/15/1997

Cancelled

4.Type

of

loan

(Usecod

es

oninstruct

ions)

SF

SF

3.Basisof

allegederror

(DisputedorNew)

Disputed

New

2

.Borrower's

Name

TomTucker

VickieBurleson

1.Borrower's

SSN

121-21-2121

232-23-2323

FY1997

ErroneousDataAppeal

SchoolofBusiness

OPEIDNumber111222

Note:Thisisasample

spreadsheet.Seeinstructions

onthepreviouspage.

01/04/2000

[sendtoU.S.Depa

rtmentofEducation'sDefault

Page

1of1page

ManagementDivisionattheaddresslocatedonpage101.]


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