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What are the Tolerances for Under and Overpayments?

UNITED STATES DEPARTMENT OF EDUCATION

OFFICE OF POSTSECONDARY EDUCATION

July 1998

Subject: This letter announces the Department's new business practice for processing underpayments and overpayments during the consolidation of Federal Family Education Loan (FFEL) Program, Federal Perkins Loan Program, William D. Ford Federal Direct Loan (Direct Loan) Program and other eligible loans.

Dear Loan Holder:

I am pleased to announce a new business practice in our Direct Consolidation Loan Program that many of you have suggested we adopt. The practice relates to tolerances for processing overpayments and underpayments and improves the consolidation process for loan holders, borrowers, and the Department.

When consolidating a FFEL, Perkins, Direct Loan or other eligible loans, the payoff amount provided to the underlying loan holder often is not the exact amount owed on the loan on the date the payoff is received. This results in either an underpayment or an overpayment of the underlying loan.

It is costly both to loan holders and to the Department to process these small adjustments, which have only a very slight impact on the borrower's consolidation loan. Many FFEL participants have addressed this issue by establishing the business practice of using tolerance for processing underpayments and overpayments within the Federal Consolidation Loan Program.

In order to promote processing efficiency and cost-effective program administration, we are implementing the following practices for processing underpayments and overpayments:

Underpayment Tolerance Procedures

  • If a loan holder receives a payoff from the Direct Consolidation Loan Program for a borrower's loan(s) that results in a net shortage (underpayment) for the borrower by a loan program type* of less than $25.00, the holder may write off the shortage.
    * Loan program type refers to the individual loan programs such as Perkins, Subsidized, or Unsubsidized Stafford or PLUS loan.

    NOTE: The net underpayment tolerance amount applies to each loan program type being consolidated by the borrower. Thus, a borrower with both Subsidized Stafford and Unsubsidized Stafford loans would have a net underpayment tolerance of $24.99 or less for the Subsidized Stafford loans, and a separate tolerance of $24.99 or less for the Unsubsidized Stafford loans.
  • If a borrower has a net underpayment for one or more loan program types that is $25.00 or greater, the LOC will provide payment upon loan holder request. Please refer to the information that was provided with the initial payment for processing instructions. If the holder has a tolerance level greater than $25.00, it may use that higher amount. All underpayment requests must be reported promptly and adjusted to the correct underlying loan account, by loan program type, and must be identified in the request to the LOC.
  • Whether the LOC is notified of a Direct Consolidation Loan request or not, loan holders are prohibited from billing the borrower for any underpayment and must notify the borrower that the loans are paid in full. See 34 CFR 685.215 (f)(2) and (5).
  • In addition, the Direct Loan Servicing Center will not request an underpayment for less that $25.00 when a FFEL Consolidation of a Direct Loan has been made.

Overpayment Tolerance Procedure

  • If a loan holder receives a payoff from the Direct Consolidation Loan Program for a borrower's loan(s) and there is a net overpayment for an individual borrower by loan program type of less than $10.00, the loan holder may retain the overpayment. The Loan Origination Center will not expect payment from the loan holder.
  • If a borrower has a net overpayment for one or more loan program types that is $10.00 or greater, the loan holder must promptly return the overpayments to the LOC. Please refer to the information that was provided with the initial payment for processing instructions. All overpayment returns must be adjusted to the correct underlying loan account, by loan program type.
  • In addition, the Direct Loan Servicing Center will not return an overpayment of less than $10.00 when a FFEL Consolidation of a Direct Loan has been made.

For Both Underpayments and Overpayments

  • The tolerance policies apply to the aggregate eligible balance of principal, interest, fees and collection costs.

The Department hopes that these changes, which are common practice in the FFEL industry, will simplify accounting procedures, reduce loan holder costs associated with payment processing, and provide for increased efficiencies for borrowers.

Thank you for you cooperation.

Sincerely,
Diane E. Rogers
Acting Deputy Assistant Secretary
Student Financial Assistance Programs

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