The following is an example of a bulletin put out by ASA for hurricane charley.
American Student Assistance
e.clips Story
Hurricane Charley Compliance Alert
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Brendan Furey
Regulatory Analyst Partnerships
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Lenders, servicers and guarantors dealing with student loan borrowers in Florida should be aware of the following regulatory relief as a result of Hurricane Charley:
Disbursements to schools:
• Lenders, guarantors and other disbursing agents are authorized not to disburse loan proceeds to schools in areas declared Federal Disaster areas if they are informed the school has a delayed opening or has ceased operations for an undetermined period of time.
• A notation should be made in the school’s profile.
Borrowers currently in school:
• Borrowers are kept in “in-school” status regardless of their attendance until such time as the borrower withdraws or re-enrolls during the next regular enrollment period. If a regular enrollment period’s begin date passes and the borrower does not enroll, then the borrower is put into repayment (which begins with a grace period if still available for the borrower) as of the date of the next enrollment period.
• If an institution’s normal operations are interrupted while a borrower is in an “in-school” deferment status, then the borrower stays in an “in-school” deferment status until the borrower withdraws or re-enrolls in the school.
Borrowers in repayment:
• Florida student loan borrowers affected by Hurricane Charley may be eligible for administrative forbearance for up to three months. All borrowers must call to request relief due to Hurricane Charley
• Defaulted borrowers who have been adversely affected by Hurricane Charley may, upon request, have their loans put in administrative forbearance for up to three months without being required to submit supporting documentation or sign a written agreement.
• Administrative forbearances applied to defaulted borrowers accounts should not affect their rehabilitation eligibility.
• Borrowers not in default are also eligible for the above referenced administrative forbearance. If these borrowers should contact ASA rather than their loan holder, they will be assisted in their request for relief by facilitating their contact to their loan holder.
• Lenders may use additional administrative forbearance to resolve any delinquencies that existed on the borrower’s account prior to the disaster forbearance.
Generally, borrowers (who live and/or work in) and institutions in the following counties should qualify: Brevard, Charlotte, Collier, DeSoto, Dixie, Duval, Glades, Hardee, Hendry, Highlands, Indian River, Lake, Lee, Levy, Manatee, Monroe, Okeechobee, Orange, Osceola, Pasco, Polk, St. Johns, Sarasota, Seminole, and Volusia Counties
Updates on the affected counties can be found at
http://www.fema.gov/news/eventcounties.fema?id=3455. Borrowers not residing or working in the above counties that call requesting relief should be handled on a case by case basis by the department’s supervisor. All requests must be thoroughly documented on the borrowers’ accounts including date, time and reason for request.
For more guidance on this or any other regulatory relief, contact your ASA client manager.