Any male required to register with Selective Service at any time must have done so to receive federal student aid. The Central Processing System (CPS) performs a match with Selective Service to confirm a student’s registration status. In this chapter we discuss that match and the registration requirement.
Males (any person assigned the sex of male at birth) aged 18–25 are required to register with the Selective Service System (SSS). This requirement covers males residing in the United States who are U.S. citizens or noncitizens, except that a male who is in the U.S. as a lawful nonimmigrant isn’t required to register as long as he maintains that status (see the exceptions to the registration requirement under “Exemptions” below). Students who are required to register with the Selective Service must do so to be eligible for FSA funds, but parents who want to borrow a PLUS loan aren’t required to have registered.
Only persons assigned the sex of male at birth are required to register. If a student’s gender identity is now female but she was assigned the sex of male at birth, the student must register with the SSS, unless one of the exemptions described in this chapter applies, regardless of subsequent sexual reassignment surgery or any other gender transition process. If a student’s gender identity is now male but he was assigned the sex of female at birth, the student is not required to register with the SSS, regardless of subsequent sexual reassignment surgery or any other gender transition process.
The student can be registered with Selective Service as early as 30 days before his 18th birthday. If the student is too young, Selective Service will hold the registration until the student is within 30 days of his 18th birthday. Students 26 and older can’t be registered.
The student has several ways to register, which include using the FAFSA; there is a question that asks if the student wants Selective Service to register him. If he indicates that he wants to be registered, we will submit his registration information to the Selective Service. If he doesn’t answer this question, he can do so later on the student aid report (SAR) and submit the correction (the answer to the question “Are you male?” must be answered “yes”). The student may also register online at the Selective Service website (https://www.sss.gov) or by filling out a form available at the post office.
Generally, a male student who is 18–25 and who has not registered previously may register using the FAFSA or SAR. Students who have questions about Selective Service registration may contact the Selective Service at 1-(847)-688-6888 or at www.sss.gov.
Status information letter codes
The Selective Service has different status information letters, which include a code that appears in the lower left-hand corner. Determination of aid eligibility for a male who failed to register with Selective Service should not be based solely on these codes. Financial aid administrators are obliged to review all evidence presented by a student to determine if he has shown “by a preponderance of evidence” that his failure to register was neither willful nor knowing. The codes are:
E1–E8: These codes indicate that the student was not required to register or was exempt the entire time he could have registered (ages 18–25).
NM: The student did not register although he was on active duty in the armed forces only for a portion of the time when he could have registered (between ages 18–25) and was, therefore, required to register.
NR: The student was born before 1960 and is therefore not required to register.
RD: The student gave a reason for not registering or documentation to show he was exempt from the requirement, but the Selective Service determined the reason or documentation to be invalid. Therefore, the student was required to register but did not. No requests to comply with the registration requirement were sent.
RH: The student was sent one or more letters requesting that he register during the required period, but all letters were returned by the post office as undeliverable.
RL: The student was required to register, but the Selective Service has no record of his registration, and their records show he was sent one or more letters requesting that he register.
RR: The student said he attempted to register, but Selective Service has no proof of the attempt.
Out of concern for privacy, the SSS only displays the last four digits of the Social Security Number on correspondence.
Selective Service requirement
- Selective Service requirement
- General Provisions
- 34 CFR 668.32(j), 668.37
- PLUS exemption 682.201(b)(1)(v)
Males exempted from the requirement to register include:
Males currently in the armed services and on active duty (this exception does not apply to members of the Reserve and National Guard who are not on active duty);
Males who are not yet 18 at the time that they complete their applications (an update is not required during the year, even if a student turns 18 after completing the application);
Males born before 1960;
Citizens of the Republic of Palau, the Republic of the Marshall Islands, or the Federated States of Micronesia*;
Noncitizens who first entered the U.S. after they turned 26;
Noncitizens who entered the U.S. as lawful nonimmigrants on a valid visa and remained in the U.S. under the terms of that visa until after they turned 26;
Transgender males who were assigned the sex of female at birth.
There are certain less common situations in which registration isn’t necessary. Students who weren’t required to register prior to meeting one of these criteria and who meet a criterion for the entire time through the age of 25 qualify for the waiver if:
They are unable to register due to being hospitalized, incarcerated, or institutionalized;
They are enrolled in any officer procurement program at The Citadel, North Georgia College and State University, Norwich University, Virginia Military Institute, Texas A&M University, or Virginia Polytechnic and State University; or
They are commissioned Public Health Service officers on active duty or members of the Reserve of the Public Health Service on specified active duty.
If the student is clearly not required to register, you must document this, but do not have him request a status information letter from the Selective Service. You should only ask the student to provide such a letter to document an exemption from the requirement to register if it is not clear that he is exempt. For example, noncitizens who first enter the U.S. after the age of 26 aren’t required to register. Only those immigrant males who enter and live in the U.S. between the ages of 18 and 25 are required to be registered. If a male immigrant can show proof that he first entered the U.S. when he was past registration age, he is clearly not required to be registered, and no status information letter is needed. The student’s entry documentation is enough to show whether he was required to register.
Documentation for exempt noncitizens includes: proof of birth date on a passport, birth certificate, or U.S. driver’s license or state ID; proof of immigration date into the U.S. from an entry date stamp on the I-94 form or in the passport, or a letter from the DHS/USCIS indicating the entry date; and, for those here on a valid visa who were between 18 and 26 years old, a student visa form (I-20) or other valid U.S. passport visa stamp on a foreign passport with an expiration date (the dates must be from entry until after the male turned 26).
Exception if SSS does not respond in 30 days
As of this writing, the Selective Service System does not have a delay in responding to requests for status information letters. However, you may award aid while waiting for the letter from the SSS if their response time is longer than 30 days and if you have no evidence that a student intentionally failed to register. If the SSS response or other subsequent information causes you to conclude the student did knowingly and willfully fail to register, then he becomes ineligible for federal student aid and he, not your school, is responsible for returning the aid he received.
Jorge has been on active duty in the Army from the time he was 18 and didn’t register with Selective Service before he joined the Army. He’s now 24, is planning to leave the Army, and wants to receive financial aid. If he applies while he’s still on active duty, he doesn’t need to be registered with Selective Service. Once he leaves, he must be registered, or else he won’t be able to receive aid in later years. In most cases, when someone completes an enlistment contract, he is automatically registered, so Jorge is probably already registered even though he didn’t complete a separate registration form.
Kyle was enrolled in an officer procurement program at the Virginia Military Institute, which he started a month before he turned 18. When he was 22, he had a serious accident and was hospitalized; he officially dropped out of school a month after he was hospitalized. Due to his injuries, he was hospitalized for four years. Because he qualified for a waiver for the entire time he was 18–25, he was not required to register with Selective Service.
Veteran status match
See the Application and Verification Guide for information on the veteran match and dependency status.
34 CFR 668.37(a)(2)
Selective Service Match
The CPS performs a match with the SSS to determine if relevant students are registered. The output document(s) display the match result(s) in the FAA Information section, and include any relevant comments about the result(s).
If the match shows that the student is registered or exempt, a comment confirming this fact will be on the student’s output document. The student is then eligible for aid.
The student is also eligible for aid if the match shows that the student is still too young to register. If the student asks to be registered, Selective Service will hold onto that registration request until 30 days before the student’s 18th birthday and will then register the student.
Finally, the student is also eligible if the CPS successfully forwards the student’s name to Selective Service for registration.
If the match doesn’t confirm the student’s registration or the student can’t be registered, the output document will have a comment about the problem. A “C” code will also be printed next to the student’s EFC. Until the student resolves the registration problem, you can’t pay FSA funds to the student or certify or originate a loan.
Registration not confirmed. If the match shows that the student isn’t registered, he must either register or provide evidence that he is registered or is exempt from registration. His Selective Service Registration Acknowledgement or letter of registration shows that he is registered. You can also go to the Selective Service System web page at www.sss.gov and check on the student’s status—a printout of the web page is acceptable documentation that the student is registered. If he doesn’t have an acknowledgement or letter of registration and the web page doesn’t confirm his registration, he’ll have to contact Selective Service to resolve the problem. If the conflict is resolved in his favor, he’ll receive a letter from the Selective Service documenting that he is registered or is exempt from registering.
Unsuccessful registration. The CPS won’t be able to forward the student for registration if certain information—first and last name and date of birth—is missing. The student should submit a correction with the required information, and you can check the match results from this correction to see if the student is eligible.
If the student is 26 or older, the CPS cannot register the student but will send his record through the data match. If the student is not registered, he can no longer do so, but may qualify for a status information letter from the SSS. You will have to determine if he is eligible for aid despite having not registered.
As an example, on his FAFSA, Andre asks the CPS to forward his information to the Selective Service for registration. However, he’s over 26, so the Selective Service can’t register him. His output document comes back with a blank match flag and comment 33. Andre didn’t enter the U.S. until after his 26th birthday, so he doesn’t have to be registered. Guerrero University already has information about his citizenship status, including the date he arrived in the U.S., so it has documentation that he is exempt from registration. The aid administrator explains to Andre why he wasn’t required to register.
Failure To Register
Some students have been denied aid because they failed to register with the Selective Service before their 26th birthday. The Selective Service will register only males aged 18–25, leaving older students with no way to remedy their situation if they failed to register. However, the student may still be eligible to receive aid if he can demonstrate that he did not knowingly and willfully fail to register.
A student who served on active duty in the armed forces but who did not register before turning 26 is still eligible to receive FSA funds because it’s reasonable to conclude that he was not trying to avoid registering for the Selective Service. Ask the student to provide a copy of his DD Form 214, “Certificate of Release or Discharge from Active Duty,” showing military service in the armed forces—other than the reserve forces, the Delayed Entry pool, and the National Guard.
Students without military service who knew of the registration requirement but chose not to register are considered to have knowingly and willfully failed to register and are therefore ineligible for FSA funds. Your school’s decision in this case is final and cannot be appealed to the Department except as noted in the “Appeals” subsection below.
Determining if non-registration was knowing and willful
Unless you can document that the student meets one of the registration exemptions or that he served on active duty in the armed forces (with a character of service other than dishonorable), he must write to the Selective Service to get a status information letter addressing his failure to register. He may also download a request form from https://www.sss.gov to print out, complete, and mail. The student should provide as complete a description about his situation as possible: where he was living during the period when he should have registered, whether he was incarcerated or institutionalized, his citizenship status during the period, if applicable, and so on.
If the student receives a “general exemption letter” (codes E1-E8) or a “DOB before 1960” letter (code NR), he is exempt from registration and may receive FSA funds. If he receives any other type of letter, you must determine based on all relevant evidence whether he knowingly and willfully failed to register. The letter from Selective Service may provide information that is crucial to your decision. For example, if the student received a letter indicating a compliance letter had been sent (code RL), this would be a negative factor when you make the determination. If the student received a “Military Service: Noncontinuous” letter (code NM), you might reasonably determine that the student did not knowingly and willfully avoid registration.
Most of the status information letters state that the final decision regarding the student’s eligibility rests with the agency awarding funds. For the purposes of the FSA Programs, the decision is made by your school, which represents the Department of Education. If you determine that the student’s failure to register was knowing and willful, the student loses FSA eligibility.
When deciding whether the student had knowingly and willfully failed to register, you should consider the following factors:
Where the student lived when he was aged 18–25. For example, if a student was living abroad, it is more plausible that he would not come into contact with the requirement for registration.
Whether the student claims that he thought he was registered. Mistakes in recordkeeping can occur. Correspondence indicating an attempt to register could form a basis for determining that the student did not knowingly and willfully fail to register. On the other hand, a letter from Selective Service stating that it received no response to correspondence sent to the student at a correct address would be a negative factor.
Why the student claims he was not aware of the widely publicized requirement to register when he was aged 18–25.
The school’s decision is final and cannot be appealed to the Department except in one limited instance. The regulations state that the Department will hear appeals from students who have provided their schools with proof that they are in compliance (i.e., that they are registered or exempt from registration) but who are still being denied federal student aid based on the registration requirement. For more detail, see 34 CFR 668.37(f).
Failure to register
34 CFR 668.37(d), (e)