Publication Date: September 2004
DCL ID: GEN-04-10
Requesting and Using an ED-PIN
Posted on 09-27-2004
Subject: Requesting and Using an ED-PIN
Summary: This letter clarifies the requirements for requesting and using an ED-PIN for use in the Federal student aid programs. It also states the actions we will take when we believe that the integrity of an ED-PIN has been compromised.
Starting in 1998, we began issuing an ED-PIN that could be used to conduct a variety of transactions related to the Federal student aid programs. The ED-PIN forms part of an "electronic signature" that can be used to sign a number of student aid documents, including FAFSAs and promissory notes. The ED-PIN also allows on-line access to private and confidential information, including financial data from the application processing system and loan information from NSLDS. For these reasons, maintaining the integrity of the ED-PIN process is critical to the management of the Federal student aid programs and to the protection of privacy rights.
When we developed the ED-PIN process we established several fundamental requirements for the issuance and use of an ED-PIN. First, the person initiating a request for an ED-PIN must be the person identified in the submission who then becomes the owner of the ED-PIN. Second, the person to whom we send the resultant ED-PIN (either by e-mail or regular mail) must be that same person (owner). Third, the person using the ED-PIN, for any purpose, must be the ED-PIN owner. Finally, the owner of the ED-PIN must not share it with any other person nor can the ED-PIN owner transfer any of his or her rights or responsibilities to another person or entity.
We have become aware that there are institutions and other organizations that systematically engage in activity that is inconsistent with the requirements noted above. Specifically, a few institutions, financial advisors, and other organizations routinely ask applicants (and their parents) to provide them with their ED-PIN. While often these requests are well intended, it is inappropriate for anyone to solicit an ED-PIN from another person. And, it is contrary to the requirements of the ED-PIN process for anyone to use another person's ED-PIN, even in an attempt to provide assistance to the PIN owner. This is true regardless of whether the ED-PIN owner has been informed of the activity, or even if he or she voluntarily agrees to provide the PIN to the other party.
We are also aware that there are organizations that have developed processes where they, and not the applicant, submit the request for the applicant's ED-PIN. Some of these organizations also violate our second requirement by designating their postal or e-mail address for receipt of the ED-PIN. Finally, and most seriously, we are aware that there are organizations that use an applicant's ED-PIN to conduct Federal student aid transactions, either because they obtained the ED-PIN from the applicant or because they requested the ED-PIN on behalf of the applicant.
Obtaining or using an ED-PIN by anyone other than the PIN owner is inconsistent with our goal of ensuring that the integrity and viability of the ED-PIN process is not compromised. And, the problems that such actions engender are not mitigated by any disclosure made to the applicant or by any agreement with the applicant.
We have decided to take the following actions when we learn or suspect that there have been violations of the ED-PIN issuance and use requirements, as discussed above. First, if we determine that the person identified as the intended PIN owner did not submit the ED-PIN request, or that the address (regular or e-mail) provided is not that of the applicant we will not issue an ED-PIN. Second, as part of an on-going evaluation of our ED-PIN database, if we believe that an ED-PIN that had previously been issued has been compromised, we will immediately deactivate that ED-PIN. Third, depending upon the nature of the violation, we may invalidate any documents, including applications and promissory notes, signed with PINs we determine to have been compromised.
We hope that you agree with us that we must maintain the integrity of the Federal student aid process by implementing procedures and controls regarding the request for and use of the ED-PIN. If you have any questions on the issues discussed in this letter please contact Jeff Baker of our staff by email at firstname.lastname@example.org.
Theresa S. Shaw
Chief Operating Officer