Program Reviews

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Program Reviews Ricardo Davila Assistant Vice
President Char Feist Compliance Officer
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• Auditors come in after the battles been fought
  and bayonet the wounded
• unknown

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OVERVIEW

• Why do Program Reviews?
• Lender/Servicer Reviews
• Review Scope
• Procedures
• Most Common Findings
• New Audit Guide for Lenders

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OVERVIEW (cont.)

• School Reviews
• Review Scope
• Procedures
• Most Common Findings
• Questions

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WHY PERFORMPROGRAM REVIEWS?

• ED mandates guarantors
• Helps protect students
• Helps protect federal fiscal interest
• Helps protect guarantors
• Reduces risk

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TWO BIGGEST UNTRUTHS

• Hi, were Program Review and were here to help
  you
• Welcome, were glad to see you

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Lender/Servicer Reviews
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REVIEW SCOPE

• How are reviews selected?
• What is time period reviewed?
• What are the areas of focus?
• How does Program Review prepare?

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POINTS OF COMMUNICATION

• Entrance conference
• Finding/comment sheets
• Exit conference

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REVIEW PROCEDURESLENDER/SERVICER

• Loan origination
• Loan sales and transfers
• Loan servicing
• Due diligence

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REVIEW PROCEDURESLENDER/SERVICER

• Consolidation loans
• Deferments and forbearances
• ED Form 799
• NSLDS reporting
• Record retention

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REPORT PROCEDURES

• Report is issued
• Response due within 30 days
• Report is closed
• ED gets copies of all reports

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MOST COMMON FINDINGSLENDER/SERVICER

• Improper 799 billing
• Due diligence violations
• Incorrect conversion to repayment
• Unreconciled loan sales
• Cancellations/refunds not differentiated

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MOST COMMON FINDINGSLENDER/SERVICER

• NSLDS error report not processed
• Improper close-out of loans
• Never reported loans not researched
• Consolidation loans not reported
• Original or copy of prom note missing

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• New Lender Audit Guide

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School Reviews
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REVIEW SCOPE

• How are reviews selected?
• What is time period reviewed?
• What are the areas of focus?
• How does Program Review prepare?

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POINTS OF COMMUNICATION

• Entrance conference
• Finding/comment sheets
• Exit conference

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REVIEW PROCEDURESSCHOOL

• Institutional eligibility
• File review (student eligibility)
• Review of internal procedures
• Review of RT4 calculations

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REVIEW PROCEDURESSCHOOL

• Review cash management
• Review financial statements
• Record retention

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REPORT PROCEDURES

• Report is issued
• Response due within 30 days
• Report is closed
• ED gets copies of all reports

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MOST COMMON FINDINGSSCHOOL

• Incorrect return of Title IV funds
• Late return of Title IV funds
• Credit balances not paid
• Overlapping academic years
• Verification not complete

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MOST COMMON FINDINGSSCHOOL

• Late release of proceeds
• Late return of proceeds
• Exit counseling not performed

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SUMMARY

• Any questions?

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Program Review Ricardo Davila Assistant Vice
President ricardo.davila_at_tgslc.org Char
Feist Compliance Officer cfeist_at_state.nd.us