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Презентация на тему Contingency Planning: How to Keep Operating During Any Type of Disaster

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Session OverviewA Personal ExperienceContingency PlanningReference InformationGeneral GuidanceDear Colleague Letter GEN-04-04
Contingency Planning: How to Keep Operating During Any Type of DisasterSession 30 Session OverviewA Personal ExperienceContingency PlanningReference InformationGeneral GuidanceDear Colleague Letter GEN-04-04 A Personal ExperienceCathy BrownUniversity of West Florida What’s The Worst That Could Happen?EarthWindFireWaterHumans “Not Just Back, Better”Taking care of faculty and staffImmediate relief for studentsPutting What We LearnedKnow the likely hazards you face and plan accordinglyBack up Contingency PlanningMary HaldaneFederal Student Aid What Are the Different Types of Emergency PlansOccupant Emergency PlanEnsures Safety of What Are the Different Types of Emergency Plans (continued)Disaster Recovery PlanEnsures the Why Develop a Contingency Plan? Ensure the Safety of Students, Faculty, Staff, Why Develop a Contingency Plan? (continued)Minimize Damage and Losses Resulting From an How to Develop a Contingency Plan – A Five Point Plan Contingency How to Develop a Contingency Plan – A Five Point Plan (continued) Important Components of a Contingency Plan Response TeamRoles:Senior Management TeamDamage Assessment TeamContinuity Important Components of a Contingency Plan (continued) TrainingTestingAlternate FacilitiesLocationEquipment Important Components of a Contingency Plan (continued)Notification/Activation ProceduresNotification of Senior Management TeamPerforming Important Components of a Contingency Plan (continued)Continuity ActivitiesActivities to Perform to Keep Important Components of a Contingency Plan (continued)Communication PlanInternal Procedures and TemplatesExternal Procedures Important Components of a Contingency Plan (continued)Vital RecordsLocationMediaAccess Important Components of a Contingency PlanData Backup and Off Site StorageAwareness and Lessons Learned – Contingency PlanningPeople Are the First PriorityPractice – Practice – Lessons Learned – Contingency Planning (continued)KISS PrincipleA Contingency Plan Is a Living Lessons Learned - Occupancy Emergency Planning Establish Building CaptainsEstablish Floor Captains and TeamsEmergency Supplies Reference Information /  General GuidanceAnthony JonesOffice of Postsecondary Education Reference InformationDear Colleague Letters, Federal Registers, and Electronic AnnouncementsGeneral guidance for Title Reference Information (continued)Hurricanes Katrina & Rita:Electronic Announcements (posted on IFAP beginning 09/02/05) Reference Information (continued)Federal Student Aid HandbookRegulationsProfessional JudgmentFFEL and Direct Loans Regulatory GuidanceRegulatory guidance is in 34 CFR 682.211(f)(11) -- allows loan holder Regulatory Guidance (continued)Similar treatment for Federal Direct LoansDCL GEN-04-04 (FP-04-03) clarifies that General Guidance for DisastersUnless otherwise noted, guidance applies to Federally-declared disaster areas General Guidance for Disasters (continued)Guidance applies to all Title IV borrowers, students, General Guidance for Disasters (continued)Guidance also applies to institutions, lenders, and guaranty General Guidance for Disasters (continued)When Federally-declared disaster has impacted a school’s ability General Guidance for Disasters (continued)Always document when deviating from otherwise required actionsMust GEN-04-04: General ProvisionsIf school is unable to continue providing student’s eligible program, GEN-04-04: General Provisions (continued)If, as a direct result of a disaster, an GEN-04-04: General Provisions (continued)Disaster-related assistance received by from the Federal or State GEN-04-04: General Provisions (continued)FAAs are encouraged to use their professional judgment authority GEN-04-04: General Provisions (continued)If student fails to meet satisfactory academic progress standards GEN-04-04: General Provisions (continued)For those applicants selected for verification whose records were GEN-04-04: General Provisions (continued)Schools are strongly encouraged to provide full refund of GEN-04-04: General Provisions (continued)If student withdraws because of a disaster, the institution GEN-04-04: General Provisions (continued)Student directly affected by disaster need not request in GEN-04-04: General Provisions (continued)If Title IV credit balance exists for any reason GEN-04-04: General Provisions (continued)Concerns related to deadlines and timeframes in the following GEN-04-04: General Provisions (continued)Concerns related to deadlines and timeframes in the following GEN-04-04: Federal Pell GrantsIf, due to a disaster, a school is unable GEN-04-04: Campus-Based ProgramsIf an institution is unable to use at least 90% GEN-04-04: Campus-Based Programs (continued)If an institution is having trouble filing its complete GEN-04-04: Federal Work-StudyIf a school is unable, due to a disaster, to GEN-04-04: Federal Work-Study (continued)Affected institutions must make waiver request by contacting Campus-Based GEN-04-04: Federal Work-Study (continued)The Secretary encourages institution to employ their FWS students GEN-04-04: Federal Perkins LoansAny borrower in “in-school” status at time of disaster GEN-04-04: Federal Perkins Loans (continued)For a borrower who is in repayment at GEN-04-04: Federal Perkins Loans (continued)Institutions that have concerns regarding the following issues GEN-04-04: FFEL and Direct LoansAny borrower in “in-school” status at time of GEN-04-04: FFEL and Direct Loans (continued)If institution is unable to complete and GEN-04-04: FFEL LoansLenders are authorized not to disburse loan proceeds to institutions GEN-04-04: Federal Direct LoansIf institution is unable to meet promissory note, loan Contact InformationYour feedback and comments are appreciated!Speaker contact information:cbrown@uwf.eduMary.Haldane @ed.govAnthony.Jones@ed.gov
Слайды презентации

Слайд 2 Session Overview
A Personal Experience
Contingency Planning
Reference Information
General Guidance
Dear Colleague

Session OverviewA Personal ExperienceContingency PlanningReference InformationGeneral GuidanceDear Colleague Letter GEN-04-04

Letter GEN-04-04


Слайд 3 A Personal Experience
Cathy Brown
University of West Florida

A Personal ExperienceCathy BrownUniversity of West Florida

Слайд 4 What’s The Worst That Could Happen?
Earth
Wind
Fire
Water
Humans

What’s The Worst That Could Happen?EarthWindFireWaterHumans

Слайд 5 "If you fail to plan, then you plan

to fail"
Evacuation Plan
When to close, when to evacuate?
Who’s

in charge?
Who stays, who goes?
Where to go and how?
When to return?
What can you take in 15 minutes and how?

Слайд 6 "If you fail to plan, then you plan

to fail“ (continued)
Security/Safety
Public
Data
Communications


Слайд 7 “Not Just Back, Better”
Taking care of faculty and

“Not Just Back, Better”Taking care of faculty and staffImmediate relief for

staff
Immediate relief for students
Putting the pieces back together; recovering

information
It will be better



Слайд 8 What We Learned
Know the likely hazards you face

What We LearnedKnow the likely hazards you face and plan accordinglyBack

and plan accordingly
Back up your data off-site
Identify building and

floor wardens
Have personal emergency kits at the ready
Training, training, training

People care. Let them help.


Слайд 9 Contingency Planning
Mary Haldane
Federal Student Aid

Contingency PlanningMary HaldaneFederal Student Aid

Слайд 10 What Are the Different Types of Emergency Plans
Occupant

What Are the Different Types of Emergency PlansOccupant Emergency PlanEnsures Safety

Emergency Plan
Ensures Safety of Occupants of a Building
Evacuation
Shelter in

Place (SIP)

Слайд 11 What Are the Different Types of Emergency Plans

What Are the Different Types of Emergency Plans (continued)Disaster Recovery PlanEnsures

(continued)
Disaster Recovery Plan
Ensures the Recovery of IT Systems Contingency

Plan
Ensures the Continuation of Essential Functions Across a Wide Range of Potential Emergencies to Provide For:
Business Process Continuity
Organizational Continuity
IT Continuity

Слайд 12 Why Develop a Contingency Plan?
Ensure the Safety

Why Develop a Contingency Plan? Ensure the Safety of Students, Faculty,

of Students, Faculty, Staff, and Visitors
Prepare Staff and Students

for Any Emergency
Ensure the Continuation of Essential Functions During an Emergency

Слайд 13 Why Develop a Contingency Plan? (continued)
Minimize Damage and

Why Develop a Contingency Plan? (continued)Minimize Damage and Losses Resulting From

Losses Resulting From an Inability to Perform Essential Functions
Facilitate

Decision Making During an Emergency
Achieve a Timely and Orderly Recovery From a Disruption of Services Caused by an Emergency

Слайд 14 How to Develop a Contingency Plan – A

How to Develop a Contingency Plan – A Five Point Plan

Five Point Plan
Contingency Plan Development Team
Resources
Roles and Responsibilities
Business

Impact Analysis
Requirements, Processes, and Interdependencies for Contingency Planning

Слайд 15 How to Develop a Contingency Plan – A

How to Develop a Contingency Plan – A Five Point Plan

Five Point Plan (continued)
Continuity Strategies
Cost, System Sensitivity, and

Recovery Time Objectives
 Plan testing, training, and exercise
 Plan maintenance

Слайд 16 Important Components of a Contingency Plan
Response Team
Roles:
Senior

Important Components of a Contingency Plan Response TeamRoles:Senior Management TeamDamage Assessment

Management Team
Damage Assessment Team
Continuity Activities - Lead and Team

Members
Resumption Activities - Lead and Team Members

Слайд 17 Important Components of a Contingency Plan (continued)
Training
Testing
Alternate

Important Components of a Contingency Plan (continued) TrainingTestingAlternate FacilitiesLocationEquipment

Facilities
Location
Equipment


Слайд 18 Important Components of a Contingency Plan (continued)
Notification/Activation Procedures
Notification

Important Components of a Contingency Plan (continued)Notification/Activation ProceduresNotification of Senior Management

of Senior Management Team
Performing Damage Assessment Procedures
Essential Functions, Their

Priority Order for Recovery, and When They Need to Be Functioning

Слайд 19 Important Components of a Contingency Plan (continued)
Continuity Activities
Activities

Important Components of a Contingency Plan (continued)Continuity ActivitiesActivities to Perform to

to Perform to Keep Essential Functions Working
Resumption of Normal

Activities Procedures
Activities to Return the Institution to Normal Operating Procedures and Processing Capabilities

Слайд 20 Important Components of a Contingency Plan (continued)
Communication Plan
Internal

Important Components of a Contingency Plan (continued)Communication PlanInternal Procedures and TemplatesExternal

Procedures and Templates
External Procedures and Templates
Accounting for Faculty, Staff,

and Students Procedures
Contact information for faculty, staff, students/parents, and internal and external dependencies

Слайд 21 Important Components of a Contingency Plan (continued)
Vital Records
Location
Media
Access

Important Components of a Contingency Plan (continued)Vital RecordsLocationMediaAccess

Слайд 22 Important Components of a Contingency Plan
Data Backup and

Important Components of a Contingency PlanData Backup and Off Site StorageAwareness

Off Site Storage
Awareness and Education Activities
Flyaway Kits
Cell Phones and

Chargers
BlackBerries and Chargers
Identification
Contingency Plan
Occupant Emergency Plan
Disaster Recovery Plan
Vital Records

Слайд 23 Lessons Learned – Contingency Planning
People Are the First

Lessons Learned – Contingency PlanningPeople Are the First PriorityPractice – Practice

Priority
Practice – Practice – Practice
Practice Real Scenarios
Assume No Essential

Services
Make Common Sense Decisions
Be Prepared to Make Decisions Outside of “Rules”
Involve Local Authorities

Слайд 24 Lessons Learned – Contingency Planning (continued)
KISS Principle
A Contingency

Lessons Learned – Contingency Planning (continued)KISS PrincipleA Contingency Plan Is a

Plan Is a Living Document
Keep Plan Current
Confirm Communications Are

Received
Backup
Essential Data
Response Team
Phone Tree Callers
Pre-Position Vital Records at Alternate Site

Слайд 25 Lessons Learned - Occupancy Emergency Planning

Establish Building

Lessons Learned - Occupancy Emergency Planning Establish Building CaptainsEstablish Floor Captains and TeamsEmergency Supplies

Captains

Establish Floor Captains and Teams

Emergency Supplies


Слайд 26 Reference Information / General Guidance
Anthony Jones
Office of Postsecondary

Reference Information / General GuidanceAnthony JonesOffice of Postsecondary Education

Education


Слайд 27 Reference Information
Dear Colleague Letters, Federal Registers, and Electronic

Reference InformationDear Colleague Letters, Federal Registers, and Electronic AnnouncementsGeneral guidance for

Announcements
General guidance for Title IV participants affected by a

disaster: GEN-04-04 (FP-04-03)

Слайд 28 Reference Information (continued)
Hurricanes Katrina & Rita:
Electronic Announcements (posted

Reference Information (continued)Hurricanes Katrina & Rita:Electronic Announcements (posted on IFAP beginning

on IFAP beginning 09/02/05) on topics including transfer students,

deadline extensions, adding federal school codes, CPS and COD technical support, etc.
Federal Register (09/09/05) announcing deadline extensions
IFAP links to additional information
09/11 Terrorist Attacks: GEN-01-11, GEN-01-12, GEN-01-13, all posted on IFAP 09/2001
Disaster Letter 99-28, posted on IFAP on August 5, 1999

Слайд 29 Reference Information (continued)
Federal Student Aid Handbook
Regulations
Professional Judgment
FFEL and

Reference Information (continued)Federal Student Aid HandbookRegulationsProfessional JudgmentFFEL and Direct Loans

Direct Loans


Слайд 30 Regulatory Guidance
Regulatory guidance is in 34 CFR 682.211(f)(11)

Regulatory GuidanceRegulatory guidance is in 34 CFR 682.211(f)(11) -- allows loan

-- allows loan holder to grant administrative forbearance for

up to 3 months if lender determines borrower’s ability to make payments has been adversely affected by:
Natural disaster;
Local or national emergency (as declared by appropriate government agency); or
Military mobilization

Слайд 31 Regulatory Guidance (continued)
Similar treatment for Federal Direct Loans
DCL

Regulatory Guidance (continued)Similar treatment for Federal Direct LoansDCL GEN-04-04 (FP-04-03) clarifies

GEN-04-04 (FP-04-03) clarifies that this applies to Federally-declared disasters

as well

Слайд 32 General Guidance for Disasters
Unless otherwise noted, guidance applies

General Guidance for DisastersUnless otherwise noted, guidance applies to Federally-declared disaster

to Federally-declared disaster areas (individual or household assistance)
FEMA website

is official source (www.fema.gov)

Слайд 33 General Guidance for Disasters (continued)
Guidance applies to all

General Guidance for Disasters (continued)Guidance applies to all Title IV borrowers,

Title IV borrowers, students, and families who, at the

time of the disaster, were:
Residing;
Employed; or
Attending eligible postsecondary institution, in Federally-declared disaster area.

Слайд 34 General Guidance for Disasters (continued)
Guidance also applies to

General Guidance for Disasters (continued)Guidance also applies to institutions, lenders, and

institutions, lenders, and guaranty agencies impacted by a disaster
Additional

guidance may be issued that supplements or supercedes GEN-04-04 (usually through posts to IFAP)

Слайд 35 General Guidance for Disasters (continued)
When Federally-declared disaster has

General Guidance for Disasters (continued)When Federally-declared disaster has impacted a school’s

impacted a school’s ability to administer Title IV programs,

DCL GEN-04-04 provides relief or specific guidance on how a school should proceed.
In many cases in which ED could not provide standard or across-the-board relief, we direct the school to contact their Case Management team for a case-by-case analysis of the school’s situation.

Слайд 36 General Guidance for Disasters (continued)
Always document when deviating

General Guidance for Disasters (continued)Always document when deviating from otherwise required

from otherwise required actions
Must document when invoking GEN-04-04 guidance
Note

that specific future statutory authority may change or enhance the guidance in GEN-04-04
For example, Hurricanes Katrina and Rita special exceptions and allocations, and R2T4 student grant overpayments
ED will most likely issue some form of guidance or statement when this authority is granted

Слайд 37 GEN-04-04: General Provisions
If school is unable to continue

GEN-04-04: General ProvisionsIf school is unable to continue providing student’s eligible

providing student’s eligible program, we encourage establishing written agreement

with another institution
See 34 CFR 668.5 for applicable regulations
Attempt to reconstruct any records lost, destroyed, or rendered illegible due to a disaster, but if unable to do so, document in the student’s file that records were lost/destroyed/damaged due to disaster

Слайд 38 GEN-04-04: General Provisions (continued)
If, as a direct result

GEN-04-04: General Provisions (continued)If, as a direct result of a disaster,

of a disaster, an institution is temporarily closed for

a period of time that impacts the length of the academic year, the institution should contact the appropriate Case Management team
Case Management will determine, on a case-by-case basis, continued program eligibility and students’ continued eligibility for Title IV assistance

Слайд 39 GEN-04-04: General Provisions (continued)
Disaster-related assistance received by from

GEN-04-04: General Provisions (continued)Disaster-related assistance received by from the Federal or

the Federal or State government by disaster victims for

the purpose of financial relief, shall not be counted as income for the purpose of calculating a family’s EFC. Also, this assistance shall not be counted as a resource or estimated financial assistance.

Слайд 40 GEN-04-04: General Provisions (continued)
FAAs are encouraged to use

GEN-04-04: General Provisions (continued)FAAs are encouraged to use their professional judgment

their professional judgment authority (granted under HEA §479A) to

reflect more accurately the financial need of students and families affected by a disaster
Must still make adjustments on a case-by-case basis and clearly document the student’s file with the reasons

Слайд 41 GEN-04-04: General Provisions (continued)
If student fails to meet

GEN-04-04: General Provisions (continued)If student fails to meet satisfactory academic progress

satisfactory academic progress standards due to a disaster, the

institution may apply the exception provision of “other special circumstances” contained in 34 CFR 668.34(c)(3)
must document student’s file that student’s failure to maintain SAP was due to disaster

Слайд 42 GEN-04-04: General Provisions (continued)
For those applicants selected for

GEN-04-04: General Provisions (continued)For those applicants selected for verification whose records

verification whose records were lost or destroyed because of

a disaster, the verification requirements during the award year will not be enforced
Must document when verification is not performed for this reason
When reporting Federal Pell Grant disbursement, use verification status code “S”

Слайд 43 GEN-04-04: General Provisions (continued)
Schools are strongly encouraged to

GEN-04-04: General Provisions (continued)Schools are strongly encouraged to provide full refund

provide full refund of tuition, fees, and other institutional

charges (or to provide comparable amount against future charges) if student withdraws as a direct result of a disaster

Слайд 44 GEN-04-04: General Provisions (continued)
If student withdraws because of

GEN-04-04: General Provisions (continued)If student withdraws because of a disaster, the

a disaster, the institution must perform the return of

Title IV funds calculations in accordance with 34 CFR 668.22, as it must for any student who withdraws
If institution makes refund of institutional charges, R2T4 calculations must must be based upon originally-assessed charges

Слайд 45 GEN-04-04: General Provisions (continued)
Student directly affected by disaster

GEN-04-04: General Provisions (continued)Student directly affected by disaster need not request

need not request in writing a leave of absence
Documentation

of LOA must include reason for LOA and reason for waiving written request requirement
LOA definition generally applies only to clock hour or non-term programs

Слайд 46 GEN-04-04: General Provisions (continued)
If Title IV credit balance

GEN-04-04: General Provisions (continued)If Title IV credit balance exists for any

exists for any reason when a student withdraws, it

must first be applied to any Title IV grant overpayment that exists as a result of the student’s withdrawal

Слайд 47 GEN-04-04: General Provisions (continued)
Concerns related to deadlines and

GEN-04-04: General Provisions (continued)Concerns related to deadlines and timeframes in the

timeframes in the following areas should be addressed through

the appropriate Case Management team:
Cash management requirements (includes credit balances; notices and authorizations; borrower request for loan cancellation; excess cash; FFELP funds; and institutional eligibility, financial responsibility, and administrative capability)

Слайд 48 GEN-04-04: General Provisions (continued)
Concerns related to deadlines and

GEN-04-04: General Provisions (continued)Concerns related to deadlines and timeframes in the

timeframes in the following areas should be addressed through

the appropriate Case Management team: (continued)
Return of Title IV funds (includes post-withdrawal disbursements)
Campus Security Reporting and Equity in Athletics Disclosures

Слайд 49 GEN-04-04: Federal Pell Grants
If, due to a disaster,

GEN-04-04: Federal Pell GrantsIf, due to a disaster, a school is

a school is unable to meet the deadlines for:
reporting

disbursement records, contact Case Management for a case-by-case analysis
final Pell Grant reporting, request extension by calling Pell Grant Customer Service (800-474-7268), or submit request via COD website (on “Request Post Deadline Processing” screen located on left hand side of menu under the School tab)


Слайд 50 GEN-04-04: Campus-Based Programs
If an institution is unable to

GEN-04-04: Campus-Based ProgramsIf an institution is unable to use at least

use at least 90% of each of its Campus-Based

allocations because of a disaster, the Secretary will consider the failure of an institution to expend funds solely due to a disaster as an appropriate criterion for a waiver of the underutilization penalty
Affected institutions must make waiver request by contacting Campus-Based Call Center (877-801-7168) for waiver submission guidelines

Слайд 51 GEN-04-04: Campus-Based Programs (continued)
If an institution is having

GEN-04-04: Campus-Based Programs (continued)If an institution is having trouble filing its

trouble filing its complete FISAP by the published deadline

because of a disaster, the institution should request assistance from the Campus-Based Call Center (877-801-7168)

Слайд 52 GEN-04-04: Federal Work-Study
If a school is unable, due

GEN-04-04: Federal Work-StudyIf a school is unable, due to a disaster,

to a disaster, to expend at least 7% of

its FWS allocation to compensate students employed in community services, the Secretary will consider the failure of an institution to expend these funds solely due to a disaster as an appropriate criterion for a waiver of this expenditure requirement

Слайд 53 GEN-04-04: Federal Work-Study (continued)
Affected institutions must make waiver

GEN-04-04: Federal Work-Study (continued)Affected institutions must make waiver request by contacting

request by contacting Campus-Based Call Center (877-801-7168) or following

annually-published waiver submission guidelines

Слайд 54 GEN-04-04: Federal Work-Study (continued)
The Secretary encourages institution to

GEN-04-04: Federal Work-Study (continued)The Secretary encourages institution to employ their FWS

employ their FWS students in the cleanup and relief

efforts for the communities affected by a disaster. These efforts would be considered part of the institution’s community services activities under the FWS Program.

Слайд 55 GEN-04-04: Federal Perkins Loans
Any borrower in “in-school” status

GEN-04-04: Federal Perkins LoansAny borrower in “in-school” status at time of

at time of disaster should continue to be in

“in-school” status during period of disaster-related nonattendance until such time as borrower withdraws or re-enrolls in next regular enrollment period (whichever is earlier)
Period of disaster-related nonattendance should not impact grace period
Document student’s file

Слайд 56 GEN-04-04: Federal Perkins Loans (continued)
For a borrower who

GEN-04-04: Federal Perkins Loans (continued)For a borrower who is in repayment

is in repayment at the time of a disaster,

but is unable to continue to repay the loan due to the disaster, the Secretary authorizes the institution to grant a forbearance for a period not to exceed three months
Borrower may request forbearance orally or in writing without submitting documentation (beyond 3 months requires written request and documentation)
Institution must document student’s file

Слайд 57 GEN-04-04: Federal Perkins Loans (continued)
Institutions that have concerns

GEN-04-04: Federal Perkins Loans (continued)Institutions that have concerns regarding the following

regarding the following issues should contact the appropriate Case

Management team for a case-by-case analysis:
Billing and collection activities required by Part 674, Subpart C – Due Diligence
Borrowers in initial or post-deferment grace periods

Слайд 58 GEN-04-04: FFEL and Direct Loans
Any borrower in “in-school”

GEN-04-04: FFEL and Direct LoansAny borrower in “in-school” status at time

status at time of disaster should continue to be

in “in-school” status during period of disaster-related nonattendance until such time as borrower withdraws or re-enrolls in next regular enrollment period (whichever is earlier)
Period of disaster-related nonattendance should not impact grace period
Doesn’t affect how institution reports borrower’s enrollment status on SSCR

Слайд 59 GEN-04-04: FFEL and Direct Loans (continued)
If institution is

GEN-04-04: FFEL and Direct Loans (continued)If institution is unable to complete

unable to complete and return SSCR to NSLDS according

to established schedule due to disaster, contact NSLDS Customer Service (800-999-8219) to modify reporting schedule
If using Nat’l Student Clearinghouse, contact Clearinghouse

Слайд 60 GEN-04-04: FFEL Loans
Lenders are authorized not to disburse

GEN-04-04: FFEL LoansLenders are authorized not to disburse loan proceeds to

loan proceeds to institutions affected by a disaster if

institution’s operations have ceased or opening delayed.
Revised disbursement schedules, loan periods, completion dates, etc. may be necessary.

Слайд 61 GEN-04-04: Federal Direct Loans
If institution is unable to

GEN-04-04: Federal Direct LoansIf institution is unable to meet promissory note,

meet promissory note, loan origination record, and initial and

subsequent disbursement record submission requirements due to a disaster, contact appropriate Case Management team for case-by-case analysis

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