Award Decisions

The Director of Financial Aid will be responsible for making determinations regarding the amount of funds a student borrower will require. The Financial Aid Office will process the applications in accordance with Federal regulations.

Disbursements

Because of the small number of federal loan applications, all disbursement of Federal loan funds between the lender bank and the Union will be conducted through the issuance of checks rather than electronic funds transfer. Once the disbursement checks are received, the Business Office will be responsible for contacting the student borrower and for releasing the loan funds. Such notification and release is to be completed not later than 15 days after receipt of the disbursement check from the lender.

Loan checks made payable to the student borrower and the Union will be processed by the Business Office so that payment of outstanding tuition and fee amounts receive priority and then the residual amounts be made available to the student borrower by Union check for purposes of financial accountability.

The student borrower will be required to sign a form with the Business Office acknowledging receipt of the lender’s loan check; this document to be retained on file by the Business Office. The Business Office will provide a copy of the check receipt form to the Director of Financial Aid to finalize action on disbursements against applications.

Counseling

Students will be required to participate in both entrance and exit counseling regarding their participation in the program. This may be accomplished electronically through the internet. Students will be required to submit evidence that counseling was accomplished to the Director of Financial Aid; this will be retained in their financial file, as required.

Record Administration

The Director of Financial Aid will be responsible for maintaining all necessary electronic and paper documentation associated with loan applications such as loan worksheets, certifications and other significant loan information. The Director will be the point of contact for resolving any discrepancies regarding information about loan applications, loan status, disbursements and related matters. The Director of Financial Aid will obtain information from the Business Office when necessary to resolve discrepancies of information involving that office. All historical financial records will be maintained appropriately in the Financial Aid and Business Offices for a period of three (3) years after the student graduates or withdraws.

Academic Progress

The Director of Financial Aid will be responsible for determining that all students receiving federal loans comply with the standards of academic progress. The Director of Financial Aid shall establish in cooperation with the Admissions and Scholarship Committee the required standards of academic progress a student borrower must satisfy to be in compliance with Federal regulations. At the conclusion of the academic year, the Director will determine the academic progress of each student borrower and notify any student that falls below the required standard of academic progress and the impact of such a delinquency on future loan applications.

Audit

An independent auditor is to conduct a compliance audit of the Federal financial aid program in conjunction with the annual financial audit of the Union.

Annual Financial Statement

The Business Office is responsible for submitting the Union’s annual financial statement to the appropriate Federal office, as required. The statement is to be sent no later than six (6) months after the end of the Union’s fiscal year. To substantiate the need for submission of the statement, the Business Office will determine the annual total of all Federal loans completed during the academic year.

Electronic Processes

The Director of Financial Aid is required to use those electronic processes provided by federal and associated agencies necessary to administer the significant activities and functions required for administering the Federal Stafford Loan program.

Authorization Documentation

The Director of Financial Aid is responsible for obtaining and submitting to the proper federal authorities any changes in institutional control, programs and other related information. Such notification is to occur within ten (10) days of the particular change. The Director will consult with the Union President and or staff, as needed, to ensure the currency and accuracy of the information required to meet federal regulations. The Director is responsible for ensuring the currency of the required program certification, as required.

Reference Document

The Federal Student Aid Handbook, published annually by the US Department of Education, is maintained on file by the Director of Financial Aid and is the principal authority for guidance on the program.

Return of Funds Based on Withdrawal

Students who withdraw from all classes during a given semester are subject to the Federal policy on Title IV return of funds. Such funds must be returned in accordance with Title IV instructions. The Title IV instructions to be used by the school are detailed in the attached guidance and worksheet published by the US Department of Education. The Director of Financial Aid is responsible for the required computation and the Business Office for the actual return of funds. The following is a verbatim extract from pages 2-43 to 45 of the “Blue Book” for Student Financial Assistance published in June 2001 by the US Department of Education for determining the return of Title IV funds.

Step 1 – Student’s Title IV Aid Information: This step collects information about the student’s Title IV grant and loan assistance. It consists of two columns: amount disbursed and net amount that could have been disbursed (for loans, the net amount of the disbursement issued). The calculation requires the school to separately determine the totals of the Title IV aid disbursed plus the Title IV aid that could have been disbursed for the payment period or enrollment period.

Step 2 - Percentage of Title IV Aid Earned: Using the student’s withdrawal date, the school calculates the percentage of the payment period or period of enrollment that the student completed (which is the same as the percentage of Title IV aid earned). Note: This calculation varies based on whether the program is a clock or credit hour program. For a program that is measured in clock hours, the percentage of Title IV aid is determined based on completed clock hours or, in some cases, scheduled clock hours at the time the student withdrew. For a program that is measured in credit hours, the percentage of Title IV aid is based on completed calendar days. For credit hour programs, scheduled breaks of at least five consecutive days and days on which the student is on an approved leave of absence are excluded from the calculation.

Step 3 - Amount of Title IV Aid Earned by the Student: The school multiplies the percentage of the payment period or period of enrollment completed by the student (Step 2) by the total amount of aid that was disbursed or that could have been disbursed (Step 1).

Step 4 - Total Title IV Aid to be Disbursed or Returned: This step is used to determine whether the school must disburse additional aid to the student (called a post-withdrawal disbursement) or whether Title IV aid must be returned. If the student has earned less than he or she received, the Title IV aid must be returned to the appropriate program(s). If the opposite is true, the school completes the post-withdrawal disbursement worksheet to determine how much the student receives.

Step 5 - Amount of Unearned Title IV Aid Due from the SCHOOL: Using the percentage of unearned Title IV aid, the school multiplies this percentage by the total amount of qualified institutional charges. The lesser of this amount or the total Title IV aid to be returned (Step 4) is entered here.

Step 6 - Return of Funds by the SCHOOL: A school must return the unearned aid for which the school is responsible (Step 5). The funds must be returned to the appropriate Title IV programs from which the student received aid in the following order: 1) Unsubsidized Federal Stafford Loans; 2) Subsidized Federal Stafford Loans; 3) Unsubsidized Federal Direct Stafford Loans; 4) Subsidized Federal Direct Stafford Loans; 5) Federal Perkins Loans; 6) Federal PLUS loans; 7) Direct PLUS loans; 8) Federal Pell Grants; 9) Federal Supplemental Educational Opportunity Grant Program; 10) Other grant or loan assistance authorized by Title IV of the HEA

Step 7 - Initial Amount of Unearned Title IV Aid Due from the STUDENT: The school subtracts the amount of unearned aid the school is responsible for (Step 5) from the amount of Title IV aid to be returned (Step 4). If the amount is $0, the student has nothing to repay.

Step 8 - Return of Funds by the STUDENT: The school determines the amount to be returned by the student to each Title IV program from which he or she received funds. If the student is to return loan funds, he or she repays the amount according to the terms of the promissory note he or she signed. If the student is to return grant funds, the school must follow the procedures for handling any grant overpayments due from the student, including notifying the student of overpayment.

[Note: Since the Union is qualified to participate only in Federal Stafford loans, the foregoing steps are used only as they apply to Federal Stafford Loans and for credit hour computations. The Department of Education worksheet is used for calculating and recording the determination.]