Publication Date: January 31, 2014
Subject: Changes to Guidance Concerning the Implementation of the Military Service and Post-Active Duty Student Deferment Request
Summary: This letter provides revised guidance concerning the implementation of the new Military Service and Post-Active Duty Student Deferment Request form for use by lenders and servicers in the Direct Loan, FFEL and Perkins Loan programs.
On November 29, 2013, we published DCL GEN-13-23, which announced the renewal of the Military Service and Post-Active Duty Student Deferment Request form. Since that posting we have received questions concerning the implementation of the revised form. The information in this letter responds to those questions and provides a slightly modified version of the form that we provided in DCL GEN-13-23 (see attachment).
GEN-13-23 explained that the form had been modified to be more accessible to those with visual impairments. One of those modifications was the ability for a borrower to sign the form electronically with a digital facsimile signature. However, in making the signature field one that could be completed with a digital facsimile signature, we did not limit the signature line only to digital facsimile signatures, as was our intent. In a future revision of the form we plan on including this important limitation. In the meantime, and in the interest of having the form implemented as soon as possible, we have dropped the signature line as a fillable field altogether.
GEN-13-23 also requested that lenders and servicers more clearly explain to borrowers any electronic submission processes that may be available to them and the letter provided an example of email as a means of electronic submission. The example of email was not intended to serve as a specific endorsement of email as our preferred method of electronic submission, as we recognize that there are other acceptable methods of electronic submission that have been adopted by lenders and servicers.
Finally, GEN-13-23 provided that, beginning June 1, 2014, lenders and servicers could not accept the prior version of the form. We have determined that, to better serve the affected borrowers, lenders and services may continue to accept the previous version of the form on or after July 1, 2014.
In light of this revised implementation guidance, the deadline by which lenders and servicers must begin distributing the new Military Service and Post-Active Duty Student Deferment Request form has been extended from February 28, 2014 to April 30, 2014.
Any guidance in GEN-13-23 that was not expressly modified by this Dear Colleague Letter remains in effect.
Director, Policy Liaison and Implementation
Federal Student Aid