On May 25, 2026, the U.S. Department of Education (ED) generated new Institutional Student Information Records (ISIRs) for 2026–27 Free Application for Federal Student Aid (FAFSA®) forms that set the initial loan limit exception flag (ISIR field 585) based on 2025–26 disbursement activity. This flag was generated to provide institutions with an initial indication of whether a borrower is eligible for the pre-One Big Beautiful Bill Act (OBBBA), also referred to as the Working Families Tax Cuts Act, aggregate loan limits, including maximum lifetime limits and Direct PLUS Loans for parents, as described below and in the “Aggregate Loan Limits” section of the April 24, 2026 Electronic Announcement (LOANS–26–05).
This reprocessing effort set the value of ISIR field 585 to ‘Y = Borrower meets the exception criteria and is eligible for the previous aggregate loan limits for each borrower with existing Direct Subsidized, Unsubsidized, and PLUS Loans with an award end date on or after April 1, 2026, for the 2025–26 award year in the Common Origination and Disbursement (COD) system.’ The value of the loan limit exception flag was set based on disbursement activity in COD, then passed through the National Student Loan Data System (NSLDS®)to the FAFSA Processing System (FPS) as Reason Code 34 on ISIR field 546, via the NSLDS post-screening process. The updated ISIR field 585 was accompanied by Comment Code 352 and an FPS C Flag.
We are aware that the FPS C Flag has caused confusion since FPS C Flags generally signal that an institution must resolve an eligibility issue before awarding and disbursing aid. In response to feedback from the financial aid community, ED is taking steps to update its logic to no longer set an FPS C Flag for post-screening Reason Code 34/Comment Code 352.
Effectively immediately, institutions may disregard the FPS C Flag associated with Comment Code 352. Institutions should not delay awarding or disbursing aid based only on the presence of this FPS C Flag. On June 11, 2026, ED will begin reprocessing ISIRs to remove the FPS C Flag associated with Comment Code 352.
FPS will continue to set Comment Code 352 to provide institutions and students with information if their eligibility for pre-OBBBA loan limits has potentially changed. Any future changes in COD will result in a system-generated ISIR displaying Comment Code 352. Institutions should check NSLDS to verify for which new loan limits the borrower now qualifies. Institutions can also view the borrowers’ aggregate totals and any new warning and/or informational eligibility status icons (such as ‘exceeds,’ ‘close to,’ etc.). This information is available on the aid recipient pages, as well as the Financial Aid History report in NSLDS. For guidance, institutions may refer to Frequently Asked Questions about loan limits published on the Knowledge Center.
We apologize for the confusion and appreciate the community’s patience as we work to resolve this issue.
If you have questions about a student’s transaction, please contact the FSA Partner and School Relations Center at 1-800-848-0978 from 10 a.m. to 6 p.m. Eastern time. You also may email CODSupport@ed.gov.