electronic signatures in the sfa loan programs electronic p-notes presented by jeff baker & kay...
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Electronic Signatures in the SFA Loan Programs
Electronic P-Notes
Presented byJeff Baker
&Kay Jacks
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Electronic Electronic SignaturesSignatures
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What Are the Laws That Affect What Are the Laws That Affect e-Transactions?e-Transactions?
Government Paperwork Elimination Act (GPEA)
&Electronic Signatures in Global and
National Commerce Act (E-SIGN)
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GPEAGPEA
To promote e-commerce by the Federal Government
Electronic records have legal effect, validity, and enforceability
Agencies to allow electronic transactions and maintenance of electronic records, when practicable
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E-Sign LegislationE-Sign Legislation
To promote e-commerce in the private sector Legal equivalence between paper and electronic
documents for binding transactions Applies to private sector transactions regulated
by Federal and State Government to specify standards to ensure accuracy, integrity, and accessibility of records
Requires consent and protection of consumer [student] in electronic context
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E-SignE-Sign
A contract does not lose enforceability solely because it was signed electronically
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Implications and StandardsImplications and Standards
Other Implications:
FFEL Program P-Note Lender Choice Standards PIN Options
Perkins Program P-Note School Choice Standards PIN Options Note
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Implications and StandardsImplications and Standards
Other Implications:
All Three Loan Programs Disclosures Due Diligence Bill Presentment and Payment Others
Other Title IV Transactions Application Verification Authorizations Others
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What Have We Done?What Have We Done?What Needs to be Done?What Needs to be Done?
Discussions with financial aid community Electronic Access Conferences Direct Loan FAA Focus Groups FFEL Community
Advanced Notice of Proposed Rulemaking
Notice of Proposed Rulemaking on Record Retention – Cancelled
Development of Standards on Electronic Signatures for Title IV Loans Released on April 30 See IFAP or SFA-CIO Site
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Standards on Electronic Standards on Electronic Signatures for Title IV LoansSignatures for Title IV Loans
Developed in Cooperation with FFEL Lenders/GA’s and Schools
Provides “Safe Harbor” for FFEL and Perkins Lenders
ED’s Standards for Direct Loans
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Summary of Standards:
Definitions Borrower Consent Disclosures Knowledge-Based Authentication (PIN) Intent to Sign an Electronic Record Required Display of Terms and Conditions
Standards on Electronic Standards on Electronic Signatures for Title IV LoansSignatures for Title IV Loans
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Section 4: Format of Electronically-Signed Records4.1: Printing and Viewing Electronically-Signed Records4.2: Self-Contained Records
Section 5: Integrity of Electronic Records5.1: Authoritative Copies5.2: Associating Electronic Records5.3: Tracking Changes and Updates to Electronic Records
Section 6: Managing and Maintaining Electronic Records6.1: Hybrid Transactions
Section 7: Accessing Electronic Records7.1: Access Rights and Restrictions 7.2: Providing Access7.3: Timeframe for Providing Access
Section 8: Holder CertificationsPIN
Standards on Electronic Standards on Electronic Signatures for Title IV LoansSignatures for Title IV Loans
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Standards on Electronic Standards on Electronic Signatures for Title IV LoansSignatures for Title IV Loans
Continued-Summary of Standards:
Format of Electronic Records Printing/Viewing Electronic Records Integrity of Electronic Records Managing and Maintaining Electronic
Records Accessing Electronic Records Holder Certifications
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E-MPN EnforceabilityE-MPN Enforceability
DatabaseMatches
FAFSA
DigitalDocument
Origination/ Certification
School Data
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+
** Events below are date/time stamped and stored by the lender.
1 Student enters an eNote website and reads notices.
2 Student clicks statement that s/he has read consumer consent disclosure & agrees to an eNote process.
3 Student enters identification credential (PIN).
4 An authentication authority verifies identity.
5 Student clicks acknowledgement of certifications, authorizations, disclosures, and rights.
6 Student adds/modifies information on the eNote (references, driver’s license number, e-mail address, etc.)
7 Student reviews completed eNote and clicks agreement.
8 Student signs eNote.9 Student prints or saves eNote.
Digital Document
Lender
Originate a Student Loan
School
Borrower
1. School sends student notification of loan amount, type and right to cancel to student
2. Student accepts loan according to school procedures
3. School verifies student enrollment4. School confirms eligibility criteria5. Lender disburses loan to school to
distribute to student 6. School credits student’s account and
forwards balance to student 7. School maintains records on enrollment,
grades, charges, etc.
School/Student Affirmation & Disbursement
Disburse a Student Loan
LenderSchool
Borrower
+Identification & Application
Process
Borrower
Apply for Federal Aid
School
1. Student completes a FAFSA.2. Student is instructed on how to obtain
an identification credential (PIN).3. Student data is verified by an
authentication authority.4. An identification credential (PIN) is
issued to the student.5. SFA sends notice to the school (ISIR)
and the student (SAR)6. School resolves any exceptions to data
matches.7. The school determines student to be
eligible and certifies/originates the loan (type, amount, date of disbursement, etc.)
Creating An Enforceable eMPNCreating An Enforceable eMPN
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How To Obtain SFA PINHow To Obtain SFA PIN
Sent to Every Paper FAFSA Filer
Can Be Requested at Time of Electronic FAFSA on the WEB or Renewal FAFSA on the WEB filing
Pre-Application Request ED PIN Registration Web Site Parent or Student (High School Seniors)
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Use of SFA PINUse of SFA PIN
Sign FAFSA on the Web or Renewal FAFSA on the Web
Sign Corrections on the Web Sign Title IV Loan e-P Note Access NSLDS Access Direct Loan Servicing
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Student AuthenticationStudent AuthenticationService (STAN)Service (STAN)
Allows borrowers to sign e-PromissoryNotes electronically using SFA PIN
Eliminates need for borrower to printout signature page and mail it in
Can be integrated seamlessly into anyelectronic student loan website
Contact [email protected] to start a service agreement, or get more information
about STAN
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FFELLenders
PerkinsSchools
SFA PIN Database
STAN Authentication STAN Authentication Services ModelServices Model
DLO/DLC STAN
Site
•Audit history•Billing•Customer support•Data storage/access
NCS Pearson SFA
SFA PINSite
DLO
DLS
NSLDS
DigDoc
FAFSA
DigDoc
DigDoc
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STAN SCREENSHOT
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Using an E-Signature:Using an E-Signature:
The ProcessThe Process
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141111111
BO
10/11/1972
****
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