Acronyms and Terminology 

Basic Loan Awarding: Annual Limits, Cost and Need

The US Department of Education has limits on how much money a student may borrow for Subsidized (Sub) and Unsubsidized (Unsub) Federal Direct loans.

Sub loans are Need-based. Sub calculations must account for the Estimated Family Contribution (EFC). Unsub loans do not depend on Need, but Unsub loans are still constrained by Cost.

Both Sub and Unsub loans can only be awarded up to the remaining Need or Cost amounts, after packaging other Estimated Financial Assistance (EFA). EFA includes all other financial aid awards already packaged before calculating the Sub and Unsub loan amounts.

• Sub is awarded at an amount that is less than or equal to the student's Remaining Need.  (COA - EFC - EFA = Remaining Need)
• Unsub is awarded at an amount that is less than or equal to the student's Remaining Cost.  (COA - EFA = Remaining Cost)

The (Sub + Unsub), taken together, are the Combined amount.

Annual Loan Limits are a separate constraint. In any Academic Year (AY), a student may only borrow up to a limited, maximum amount of total Sub and Unsub loans. Annual Limits are different depending on the student's year in school, dependency status, and type of program (undergraduate or graduate). A list of standard annual limits is in the table at Direct Loan Annual and Aggregate Limits.

Aggregate Limits are an additional constraint.  The Aggregate Lifetime Limits are the maximum allowed amounts a particular student may have for all loans of that type added together, across all schools and all AYs. For example, the maximum Aggregate Sub Lifetime Limit for undergraduates is $23,000.  A student might have two separate Sub loans ($3,500 + $4,500) at a Regent Award school, and the same student might also owe another $5,500 from Sub loans from another, previous school. The student would have a Total Aggregate Sub Lifetime Usage of $13,500 for all the Sub loans added together ($3,500 + $4,500 + $5,500). By ED regulations, the Total Aggregate Sub Maximum Limit is $23,000, so the student would have only $9,500 remaining in Subsidized Aggregate eligibility ($23,000 maximum Aggregate Sub Limit - $13,500 Aggregate Sub used).

Subsidized loan borrowing is also limited by the "150 Percent" or Subsidized Usage Limit Applies (SULA) rules. SULA restrictions are outside the scope of this discussion.  For more details on the SULA rules, please refer to the IFAP SULA FAQ.

Example 1: John - Limited by Need and Annual Limits

John is a first-year, dependent, undergraduate student starting at a university for the very first time. John has no prior student loans. He will be a full-time student for the entire AY. The university packages all funds up to 100% of COA.

John's COA in AY1 is $15,000. John's family EFC is $10,000.  John also has a $2,000 merit scholarship. The scholarship is ranked higher than loans in the university's Packaging Philosophy, meaning the university will award the scholarship to John prior to determining how much loan funding John is eligible for.

John's loan amounts must use the minimum of: the Annual Sub and Combined (Sub + Unsub) limits; the remaining COA or Need; or the remaining Aggregate Lifetime available amounts.

• Look up John's per-AY Annual Loan Limits
  • First-year dependent student 
    • Sub: $3,500 Sub
    • Unsub: $2,000 for $5,500 total (Sub+Unsub) combined annual limit
  • Amounts are from the table on Direct Loan Annual and Aggregate Limits. A first-year dependent student may have up to $5,500 in (Sub + Unsub) loans. However, no more than $3,500 can be Sub loans.
• Calculate John's Remaining Need and Remaining Cost before loans
  • Remaining Need: $15,000 COA - $10,000 EFC - $2,000 Scholarship  = $3,000 Remaining Need
  • Remaining Cost, without EFC: $15,000 COA - $2,000 Scholarship = $13,000 Remaining Cost  
• Check John's Aggregate loan availability
• John has no loans at any school. John's aggregate balances are all $0.
• Aggregate limit amounts are from the last row of the table on Direct Loan Annual and Aggregate Limits. A dependent student may have up to $31,000, including no more than $23,000 in subsidized loans.
• $23,000 Sub - $0 Sub loan aggregates already used = $23,000 Sub aggregate eligibility available
• $31,000 Combined - $0 (Sub + Unsub loans) = $31,000 (Sub + Unsub) Combined aggregate eligibility available

John's Sub loan calculation

Sub loans are need-based. John's remaining Need is only $3,000, and $3,000 is less than both the $3,500 Federal Annual Sub limit, and John's remaining unused Aggregate Total amounts ($23,000 Sub and $31,000 Combined Aggregate limits). Because John's remaining Need is only $3,000, John's Sub loan calculation = $3,000.

• Use the minimum of ($3,500 annual Sub limit), OR ($3,000 Remaining Need), OR ($23,000 Remaining Sub Aggregate availability)
• Result: John's $3,000 Remaining Need limits his AY1 Sub loan amount to $3,000 Sub.

John's Unsub loan calculation

Unsub loans are not need-based, but Unsub cannot exceed Cost. Separately, the total Combined (Sub + Unsub) amounts cannot exceed the annual per-AY loan limits.

John's Remaining Cost is $13,000, and $13,000 is more than the $5,500 Federal Combined Annual Limit. John's remaining Sub Aggregate and Combined Aggregate Lifetime Usage are higher. John's Unsub loan calculation is constrained by the $5,500 Combined Annual Limit minus the $3,000 Sub already awarded = $2,500.  

• Because the Sub loan was already awarded, Regent Award will consider the $3,000 Sub loan in the EFA Amount for the Unsub loan.
• Calculate the possible constraints:
  • (Annual Combined limit remaining after awarding Sub loans), OR
  • (remaining Cost after Sub loan), OR
  • (remaining Combined Aggregate availability - any Sub loans already awarded)
• Find the minimum of those amounts:
  • ($5,500 remaining annual Combined limit - $3,000 Sub already awarded = $2,500), OR
  • ($13,000 remaining COA - $3,000 Sub loan = $10,000), OR
  • ($31,000 remaining Combined Aggregate for dependents - $3,000 Sub loan = $28,000) 
• Minimum of ($2,500 remaining annual combined limit) OR ($10,000 remaining cost) OR ($28,000 remaining Aggregate combined eligibility)

• Result: John's $5,500 total Combined Annual limit (including $3,000 Sub) constrains the Unsub loan amount to $2,500 Unsub.

Loan Awarding over Multiple Years

Regent packages loans for the remainder of a student's Academic Plan.  The loan amounts are different depending on a student's grade level and dependency status.  A table is at Direct Loan Annual and Aggregate Limits. 

Example 2: Paul - Limited by Annual Limits

Paul is a first-year, independent, undergraduate student. Paul has no prior student loans. He will be a full-time student for the entire AY. The university packages up to 100% COA for all funds.  

Paul's COA in AY1 is $30,000. Paul's EFC is $0.  Paul has $6,195 in Pell grants, $100 FSEOG, and a $1,500 merit scholarship. All the other funds are awarded prior to loans per the university's Packaging Philosophy.

Paul's loan amounts must use the minimum of: the Annual Sub and Combined limits; the remaining Need (Sub) or COA (Unsub); or the remaining Aggregate Lifetime available amounts.

AY1:

• Annual Limits: $3,500 Sub, $6,000 Unsub or $9,500 Combined - based on first-year, independent limits at Direct Loan Annual and Aggregate Limits.
• Remaining Need before loans: $30,000 COA - $0 EFC - $6,195 Pell - $100 SEOG - $1,500 Scholarship = $22205 Remaining Need  
• Remaining Cost before loans: $30,000 COA - $6,195 Pell - $100 SEOG - $1,500 Scholarship = $22,205 Remaining Cost
• Remaining Aggregate Lifetime availability: $23,000 Sub max - $0 Sub used = $23,000 Sub available; $57,500 Combined max - $0 Sub used - $0 Unsub used = $57,500 Combined available

Paul's remaining Need and remaining Cost are high enough that Paul's main constraints will be the Annual Limits and Grade Level - see Direct Loan Annual and Aggregate Limits.

For AY1-4, Regent Award can estimate future loan amounts based on the annual limits and anticipated grade level (GL) in each AY.

• AY1, GL1
  • $3,500 Sub
  • $6,000 Unsub ($9,500 Combined Annual Limit for First-Year Undergraduate Independent Students minus $3,500 Sub)
• AY2, GL2
  • $4,500 Sub
  • $6,000 Unsub ($10,500 Combined Annual Limit for Second-Year Undergraduate Independent Students minus $4,500 Sub)
• AY3, GL3
  • $5,500 Sub
  • $7,000 Unsub ($12,500 Combined Annual Limit for Third Year and Beyond Undergraduate Independent Students minus $5,500 Sub)
• AY4, GL4
  • $5,500 Sub
  • $7,000 Unsub ($12,500 Combined Annual Limit for Third-Year and Beyond Undergraduate Independent Students minus $5,500 Sub)
• AY5 or later:  see next section!

Aggregate Lifetime Limits

The Department of Education does not allow students to have unlimited loans. For example, ED restricts undergraduates to $23,000 per-student lifetime maximum in Subsidized loan amounts, and $57,500 lifetime maximum in total combined (Sub + Unsub) loans. The limits only apply to Sub and Unsub loans. Other loans (e.g. PLUS and Perkins) have different rules.

Like Annual Limits, the Aggregate Limits are also different depending on the student's dependency status and type of program (undergraduate or graduate). For more details, see the table at Direct Loan Annual and Aggregate Limits.

Example 3: Paul - Aggregate Limits at a Regent School

Paul is taking all credits for his degree at the Regent school. However, if Paul's undergraduate program is 120 credits, and Paul takes only 24 units per AY, Paul will need exactly 5 years to graduate. Paul's aggregate limits would now limit his aid in his final AY5.  For the examples below, assume that Paul's Remaining Cost is $22,205 and Remaining Need is $22,205 each year for all 5 years of his schooling.

The aggregate limits are the maximum amounts for all loans of that type added together, across all schools and all AYs.

From the table at Direct Loan Annual and Aggregate Limits, the total Lifetime Aggregate Limits for an independent student like Paul are "$57,500 for undergraduates—No more than $23,000 of this amount may be in subsidized loans."

Aggregate Sub Amount Used:  (Sub Loan 1 + Sub Loan 2 + Sub Loan 3 + Sub Loan 4 + all other Sub loans)  <=  Maximum $23,000 Sub 

Aggregate Combined Amount Used = (Sub Loan 1 + Unsub Loan 1 + Sub Loan 2 + Unsub Loan 2 + Sub Loan 3 + Unsub Loan 3 + Sub Loan 4 + Unsub Loan 4 + all other Sub loans + all other Unsub loans) <=  Maximum $57,500 (Sub + Unsub)

For Paul, using the same awarding, the aggregate usage is as follows:

• AY1, GL1
  • $3,500 Sub
    • ($0 Sub Aggregate already used before AY1 + $3,500 AY1 Sub) = $3,500 Sub aggregate used at end of AY1  
  • $6,000 Unsub
    • ($0 Combined Aggregate already used + $3,500 AY1 Sub + $6,000 AY1 Unsub) = $9,500 Combined aggregate used at end of AY1  
• AY2, GL2
  • $4,500 Sub
    • ($3,500 Sub from AY1 + $4,500 AY2 Sub) = $8,000 Sub aggregate used at the end of AY2
  • $6,000 Unsub
    • ($9,500 Combined from AY1 + $4,500 AY2 Sub + $6,000 AY2 Unsub) = $20,000 Combined aggregate used at the end of AY2
• AY3, GL3
  • $5,500 Sub
    • ($8,000 Sub used as of the end of AY2 + $5,500 AY3 Sub) = $13,500 Sub aggregate used at the end of AY3
  • $7,000 Unsub
    • ($20,000 Combined as of the end of AY2 + $5,500 AY3 Sub + $7,000 AY3 Unsub) = $32,500 Combined aggregate used at end of AY3
• AY4, GL4
  • $5,500 Sub
    • ($13,500 Sub as of the end of AY3 + $5,500 AY4 Sub) = $19,000 Sub aggregate used at end of AY4    Getting close to the $23,000 aggregate Sub maximum!
  • $7,000 Unsub
    • ($32,500 Combined as of the end of AY3 + $5,500 AY4 Sub + $7,000 AY4 Unsub) = $45,000 Combined aggregate used at the end of AY4
    • $45,000 Combined used <= $57,500 Combined Aggregate maximum limit  

For AY5, Regent cannot award another $5,500 Sub loan because Paul's total Sub Aggregate usage would go past the $23,000 Sub Aggregate maximum.

• AY5, GL4
  • $5,500 $4,000 Sub  
    • Initial Sub calculation, based on per-AY limits: $5,500
    • Check for aggregate usage: ($19,000 Combined as of the end of AY4 + $5,500 AY5 Sub) = $24,500  Sub aggregate used   Would exceed the $23,000 maximum!
      • Regent Award must calculate the remaining Sub aggregate eligibility, and reduce the Sub loan to that amount
      • $23,000 Sub Aggregate max - $19,000 Sub Aggregate already used = $4,000 remaining Sub aggregate eligibility
    • Regent awards $4,000 Sub for AY5 
  • $8,500 Unsub
    • Initial Unsub calculation, based on per-AY annual limits: $8,500
      • Based on $12,500 per-AY combined (Sub+Unsub) limit - $4,000 AY5 Sub = $8,500 remaining in combined annual limit
    • Check for aggregate usage: ($45,000 Combined as of the end of AY4 + $4,000 AY5 Sub + $8,500 AY5 Unsub) = $57,500 Combined Total Lifetime Aggregate used at end of AY5
      • $57,500 after AY5 = $57,500 max   Unsub amount is OK; not exceeding the Total Aggregate Combined maximum amount.  But Paul is at his max so he cannot receive any additional Unsub.
    • Regent awards $8,500 Unsub for AY5   

At this point, Paul has maxed out his Aggregate Lifetime eligibility for total Sub loan amounts.  Paul cannot be awarded any additional Sub amounts in future years if he needs to extend his undergraduate schooling. Paul also could not be awarded any additional Unsub loans for his undergraduate work. If Paul moves on to a graduate degree, some additional Unsub eligibility would become available to him per the table at Direct Loan Annual and Aggregate Limits. Paul's previous undergraduate loans would still count toward his graduate Aggregate Lifetime total limits.

Loan Awarding with Prior Aggregate Balances

Many students already have loans from prior institutions, as well as loans awarded by Regent.  The National Student Loan Data System (NSLDS) is a central database tracking every student's Federal Loans. NSLDS tracks the amounts of Sub and Unsub loans a student owes from all schools they attended. NSLDS tracks the individual loan data. NSLDS also calculates the student's Total Aggregate usage for the loan types. In the examples on this page, the Total Aggregate amounts include all of the loan amounts the student owes, from every school. When Regent Award packages new loans, the system recalculates awarded amounts based on aggregate usage and loan data from NSLDS.

There are two main ways that Regent Award can receive the aggregate usage amounts reported by NSLDS:

1. In a data file called the Financial Aid History or FAH file, which a school can request and import into Regent Award.  .
2. In the ISIR file, NSLDS information section.

On occasion, a user might need to supply different, override values for the NSLDS aggregate amounts. For example, an updated NSLDS FAH file might not be immediately available. The user may enter Manual override values in the Manual column on the student's History tab, next to the corresponding Aggregate totals. When the Manual values are entered, the system will consider the Manual Entry Date as the date of the Manual data values, unless the user has selected the "Always Use Manual" checkbox. If "Always Use Manual" is selected, the system will ignore any later Aggregate usage values received from the NSLDS FAH or ISIR data. See the History Tab for more details. 

Whenever a student has data from multiple sources (ISIR, FAH, or Manual), Regent Award will use the most recent data source (unless "Always Use Manual" is selected).

Example 4: Mary - Aggregate Limits from a Prior School

Mary is an independent student, transferring into and starting her third year at the Regent Award school.  Mary will be a full-time student for the entire AY. The Regent Award school packages up to 100% of COA for all funds.

Mary already has prior loan Aggregate Lifetime amounts from other, non-Regent schools:

• $13,000 Aggregate Sub Total Lifetime usage
• $15,000 Aggregate Unsub Total Lifetime usage
• $28,000 Aggregate Combined Total Lifetime usage

At the Regent school, Mary's COA in AY1 is $30,000. Mary's EFC is $0.  Mary has $6,195 in Pell grants, $100 SEOG, and a $1,500 merit scholarship, which is awarded prior to loans per the school's Packaging Philosophy.

Mary's loan amounts must use the minimum of: the annual Sub and Combined limits; the remaining Need or COA; or the remaining Aggregate Lifetime available amounts.

AY1:

• Annual Limits: $5,500 Sub, $12,500 Combined - based on third-year, independent limits at Direct Loan Annual and Aggregate Limits.
• Remaining Need before loans: $30,000 COA - $0 EFC - $6,195 Pell - $100 SEOG - $1,500 Scholarship = $22,205 Remaining Need
• Remaining Cost before loans: $30,000 COA - $6,195 Pell - $100 SEOG - $1,500 Scholarship = $22,205 Remaining Cost
• Remaining Aggregate Lifetime availability: 
  • $23,000 Sub max - $13,000 Sub used = $10,000 Sub available for awarding at the Regent school
  • $57,500 Combined max - $28,000 Combined (Sub+Unsub) used = $29,500 Sub+Unsub Combined available for awarding at the Regent school

Like Paul, Mary has a high Remaining Need and Remaining Cost. Her loan amounts will be limited by the annual limits. However, Mary's loan amounts will also be constrained by her aggregate loan usage.

Mary needs 72 units to finish her degree (three full AYs). Regent Award will estimate future loan amounts based on the annual limits and grade level, but also adjust based on the aggregate limits.

• AY1, GL3
  • $5,500 Sub
    • ($13,000 + $5,500 AY1 Sub) = $18,500 Sub aggregate used at the end of AY1
    • $18,500 Sub Aggregate used <= $23,000 Sub Aggregate max 
  • $7,000 Unsub
    • ($28,000 Combined Aggregate used + $5,500 AY1 Sub + $7,000 AY1 Unsub) = $40,500 Combined aggregate used at the end of AY1
    • $40,500 Combined Aggregate used <= $57,500 Combined Aggregate max 
• AY2, GL4
  • $5,500 $4,500 Sub
    • Initial Sub calculation: $5,500 Annual Sub limit
      • However, ($18,500 Total Sub Aggregate used + $5,500) = $24,000  Sub aggregate used  Would exceed $23,000 max Sub aggregate limit  
    • Regent Award recalculates the Sub amount to only remaining Aggregate Sub eligibility:
      • $23,000 Total Aggregate Sub max - $18,500 Sub used after AY1 = $4,500 remaining Sub eligibility for AY2
    • Sub is awarded for only $4,500 for AY2 
  • $8,000 Unsub
  • Annual limit calculation: $12,500 Annual limit - $4,500 Sub loan = $8,000 remaining in per-AY limit
  • ($40,500 Combined Aggregate used after AY1 + $4,500 AY2 Sub + $8,000 AY2 Unsub) = $53,000 Combined aggregate used at the end of AY2
  • $53,000 used <= $57,500 Combined aggregate max  

• AY3, GL4
  • $0 Sub 
    • Mary already reached the $23,000 Sub aggregate maximum usage in AY2.
  • $12,500 $4,500 Unsub
  • Initial Unsub calculation: $12,500 Annual limit - $0 Sub loan = $12,500 per-AY
    • However, ($53,000 Combined used after AY2 + $12,500 Unsub) = $65,500  Combined Total Lifetime aggregate used; would exceed $57,500 Combined aggregate maximum
  • Regent Award recalculates the Unsub amount to only the remaining Aggregate Total Lifetime Combined eligibility:
    • $57,500 Agg Combined Max - $53,000 Combined used = $4,500 remaining Total Lifetime Combined eligibility
  • Unsub is awarded for only $4,500 

At the end of AY3, Mary would have exhausted all her Sub and Unsub eligibility for her undergraduate schooling.

Adjusting Aggregate Usage Amounts

The NSLDS Aggregate Usage amounts are based on a point-in-time when the NSLDS data was received. However, Regent Award usually packages and repackages loans daily, and frequently posts loan disbursements to COD. Regent Award needs to adjust the NSLDS data to account for current and future loans. A loan is considered a current, active loan if the loan's Financial Award End Date is on or after the data source's end date. Regent Award automatically adjusts the Aggregate Lifetime amounts for any current loan amounts at the Regent Award school. The system then recalculates and re-awards those loan amounts during packaging. The packaging process also adds on those loan amounts to Regent's internally-calculated Total Lifetime Aggregate Usage amounts.

Adjusting Aggregate Usage for Active, Current Loans

Remember, the NSLDS Total Aggregate usage** is the total of each individual loan amount added together, by type, for all schools the student has ever attended.

• Total Sub Aggregate Lifetime Usage = (Sub loan #1 amount) + (Sub loan #2 amount) + (Sub loan #3 amount) + (all other Sub loan amounts)
• Total Combined Aggregate Lifetime Usage = (Sub loan #1 amount) + (Sub loan #2 amount) + (Sub loan #3 amounts) + (all other Sub loan amounts) + (Unsub loan #1 amount) + (Unsub loan #2 amount) + (Unsub loan #3 amount) + (all other Unsub loan amounts)

NSLDS counts any partially-paid loan amounts as already included in the NSLDS Aggregate Lifetime Total usage amounts. Whenever an individual loan has a disbursement paid at COD, COD posts the disbursement amount to NSLDS. NSLDS adds that disbursement amount to both the individual loan's amount and the relevant Aggregate Lifetime Total Usage amounts.

A student may have one or more active loans that are currently in progress: the individual loan is ending on or after the data source's date. Regent Award adjusts the Total Lifetime Aggregate Usage amounts by subtracting any NSLDS individual loan amounts for those current and future loans. During packaging, Regent Award then recalculates and re-awards the individual loan amounts, adding those recalculated Regent loan amounts to Regent's adjusted Lifetime Aggregate Usage total amounts. The system tracks the running total Lifetime Aggregate Usage and reduces loans as needed to avoid exceeding the statutory Total Lifetime Aggregate Maximum Limits. 

Regent Award uses each individual loan's detail data from NSLDS data. Regent compares the loan's Financial Award End Date to the NSLDS data source's date (the "Date Received" on the History tab). The most recent data source is used, whether that is the ISIR, the NSLDS FAH file, or a Manually provided value. If any individual loan in the NSLDS data ends on or after the data source's date, and that loan is for a Regent school, Regent will reduce the Total Aggregate Lifetime amount that Regent is using. The reduction matches that individual loan's aggregate usage amount. The reduction (adjustment) lets Regent recalculate the loan amount and re-award the loan.

**The following types of loans may be excluded from Aggregate calculations for certain types of students 

• Graduate-level loans for Undergraduate students
• Additional Unsub awarded in the case of a PLUS denial
• Additional Unsub awarded for Health Professions loans

Example 5: Sarah - Adjusting Aggregate Limits for a current, active, partially paid loan

Sarah is a second-year independent undergraduate. Her AY2 runs from January 13, 2019 to August 31, 2019.

• Sarah's Total Lifetime Aggregate Sub usage was originally $18,000 at the start of AY2.  
• Sarah has a $4,500 Sub loan in her AY2, with three disbursements ($1,500 January + $1,500 April + $1,500 June).
  • Disbursement #1, $1,500 was paid on January 30, 2019,
  • Disbursement #2, $1,500 was paid on April 30, 2019
  • Disbursement #3, $1,500, is unpaid.
• On April 30, 2019, the same day as the second $1,500 disbursement is paid, the school receives an NSLDS FAH file.
  • The new NSLDS FAH file shows Sarah's Total Lifetime Aggregate Sub Usage amount at $19,500.  
    • The $19,500 includes ($18,000 original Total Lifetime Aggregate Sub Usage at the start of AY3 + $1,500 Sub disbursement previously paid in January). 
    • Note, the Total Lifetime Aggregate Sub Usage does not currently include the additional, second $1,500 disbursement, because that additional $1,500 was just paid at COD that day and was not yet recorded at NSLDS.
  • The new NSLDS FAH data also shows the individual AY2 Sub loan as a $4,500 total individual loan amount, with that Sub loan contributing $1,500 toward the student's Total Lifetime Sub Aggregate usage. 
    • In the FAH data, the $4,500 Sub loan has $1,500 in Sub Aggregate Usage and a Financial Award End Date of August 31, 2019. 
    • The loan is a current, active loan, because the loan's Financial Award End Date is later than the FAH data source's date of April 30, 2019. 
    • During packaging, the loan will affect Regent's adjusted Aggregate Total Sub Lifetime Usage, to reduce the total by $1,500 to allow for re-awarding the full loan in AY2. 
    • Note that the loan's second disbursement of $1,500, even though it was just paid at COD that day, has not yet been reported from COD to NSLDS. If the second disbursement had been already included in the NSLDS loan's Sub Aggregate usage, the individual loan's Sub Aggregate Usage would have been $3,000 instead of $1,500, and the NSLDS Total Sub Lifetime Aggregate usage would also have been $1,500 higher ($21,000 Total Sub Aggregate Lifetime usage) in the FAH data file. 
• The system needs to make adjustments to the FAH Total amount. 
  • If Regent Award were to directly apply the new NSLDS FAH $19,500 Lifetime Aggregate Sub Usage amount without any adjustments, the AY2 and future Sub amounts would exceed the maximum Sub lifetime limits. 
  • As a result, if the system awarded current and future years without adjusting the FAH Total Sub Lifetime Aggregate Usage for the current active loan amounts, the system would have calculated a remaining $3,500  for additional, remaining aggregate Total Sub Lifetime usage available beyond the amounts already disbursed.
    • The projected $3,500 remaining Sub would have been based on ($23,000 max Sub lifetime limit - $19,500 unadjusted FAH Total Sub Lifetime Aggregate used). 
    • The unadjusted Sub Total would have resulted in the following awards: 
      • AY2: $4500 Sub ($3,000 already disbursed through Regent and COD + $1,500 additional Sub disbursement, up to the $4,500 Sub Annual limit)
      • AY3: Another $2000 Sub (based on the projected $3,500 remaining Sub eligibility from the unadjusted FAH total - $1,500 additional disbursement awarded in AY2).
    • The student's Total Lifetime Aggregate Subsidized borrowing would then be $23,000 plus an ADDITIONAL $1,500  due to the second AY2 disbursement that was "in transit" from COD at the time the NSLDS FAH file was created.
      • ($19,500 unadjusted FAH Total Sub Lifetime Aggregate amount + $1,500 paid but not-yet-posted AY2 Sub April disbursement + $1,500 AY2 additional unpaid Sub disbursement + $2,000 AY3 Sub) = $24,500  
• To recalculate Sarah's adjusted Total Sub Aggregate Lifetime usage, Regent Award adjusts the Total Sub Lifetime Aggregate usage by looping through Sarah's NSLDS individual loan detail data.
  • The system goes through the FAH individual loan detail data to identify any current, active loans ending on or after the data source's date.
    • Regent compares each individual loan's Financial Award End Date to the data source's date.
    • The system determines Sarah's individual Sub loan for AY2 is a current active loan.
      • That Sub loan has a Financial Award End Date (August 31, 2019) that is greater than or equal to the data source's date (April 30, 2019).
    • Regent Award will need to subtract that individual loan's NSLDS Sub aggregate usage from the data source's reported NSLDS Total Sub Lifetime Aggregate Usage.
  • Regent Award subtracts the individual AY2 Sub loan's NSLDS Aggregate usage amount ($1,500) from the student's NSLDS overall Total Sub Lifetime Aggregate Usage ($19,500) from the NSLDS FAH data.
    • Regent's internal adjusted Total Lifetime Aggregate Sub Usage is $18,000.
      • ($19,500 original FAH Total Sub Aggregate usage - $1,500 current individual Sub loan's Aggregate usage in FAH loan data) = $18,000 adjusted Total Sub Aggregate Usage.
• The resulting adjusted Total Sub, $18,000, is used for packaging loans in AY2 and later. 
• When repackaging the AY2 Sub loan, using the adjusted Total, Regent Award awards $4500 Sub.
  • Initial AY2 Sub calculation: $4,500 Sub based on second-year Sub annual limits.
  • Check for aggregate usage in AY2: ($18,000 adjusted Total Sub Aggregate at start of AY2 + $4,500 AY2 Sub loan = $22,500 Total Sub Aggregate usage)
  • $22,500 < $23,000 maximum Total Sub Aggregate Lifetime Limit 
  • AY2 Sub Loan is awarded for $4,500
• When Regent Award packages the AY3 Sub loans, the system awards only $500 Sub.
  • Initial AY3 Sub loan calculation: $5500 for third-year Sub annual limits
  • The system checks for the Total Sub Lifetime Aggregate Usage by comparing the adjusted Total Lifetime Sub loan usage, plus the AY2 Sub loans.
    • Check for aggregate usage at end of AY3: ($18,000 adjusted Total Sub Lifetime Aggregate Usage) + ($4,500 AY2 Sub) + ($5,500 proposed AY3 Sub) = $28,000  Total Lifetime Sub Aggregate usage  Exceeds the $23,000 maximum Total Lifetime Sub Aggregate Maximum!
  • Calculate the remaining Total Sub Lifetime Aggregate Eligibility for AY3:
    • $23,000 Total Sub Lifetime Maximum - $18,000 adjusted Lifetime Aggregate Used at start of AY2 - $4,500 AY2 Sub = $500 remaining Sub Lifetime Aggregate Usage for AY3
  • Reduce the AY3 Sub amount to the remaining $500 Sub Lifetime Aggregate eligibility
  • Check for aggregate usage: ($18,000 adjusted Total Sub Lifetime Aggregate usage + $4,500 AY2 Sub + $500 AY3 Sub) = $23,000  Equals the $23,000 Total Lifetime Aggregate Sub Maximum.
  • AY3 Sub Loan is awarded for only $500 

Example 6: George - Adjusting Aggregate Limits for Multiple Individual Current, Active Loans 

George is a fourth-year independent undergraduate. His AY4 runs from January 13, 2019 to August 31, 2019. 

The school imports a NSLDS FAH file dated July 1, 2019.  The NSLDS FAH data shows that George has the following NSLDS Total Outstanding Principal Balance amounts:

• $20,250 Subsidized Total Aggregate Lifetime in FAH file
• $32,750 Combined Total Aggregate Lifetime in FAH file

In the same FAH file, George's NSLDS Loan Detail shows the following individual loans and their amounts, with each loan's amount that counts toward George's Total Lifetime Aggregate usage:

• Loan #1:  $5,500 Sub loan with $2,750 Aggregate usage; Financial Award end date 8/31/2019  
• Loan #2:  $7,000 Unsub Loan with $3,500 Aggregate usage; Financial Award end date 8/31/2019
• Loan #3:  $5,500 Sub Loan with $5,500 Aggregate usage; Financial Award end date 6/15/2019
• Loan #4:  $7,000 Sub Loan with $7,000 Aggregate usage; Financial Award end date 6/15/2019
• Loan #5:  $5,500 Sub Loan with $5,500 Aggregate usage; Financial Award end date 12/31/2017, and the loan is for a different (non-Regent) school code

Regent would compare each individual loan's dates to the data source's date of July 1, 2019.

• Loan #1:  $5,500 Sub loan with $2,750 Aggregate usage, Financial Award end date 8/31/2019 
  • Loan #1 will adjust Regent's Aggregate Total Lifetime Usage: Reduce by $2,750
  • The reduction will allow re-awarding because the loan's end date is on or after the data source date of July 1, 2019.
• Loan #2:  $7,000 Unsub Loan with $3,500 Aggregate usage; Financial Award end date 8/31/2019
  • Loan #2 will adjust Regent's Aggregate Total Lifetime Usage: Reduce by $3,500
  • The reduction will allow re-awarding because the loan's end date is on or after the data source date of July 1, 2019.
• Loan #3:  $5,500 Sub Loan with $5,500 Aggregate usage; Financial Award end date 6/15/2019  ← Do not need to adjust, because the loan ended before the data source date
• Loan #4:  $7,000 Sub Loan with $7,000 Aggregate usage; Financial Award end date 6/15/2019 ← Do not need to adjust, because the loan ended before the data source date.

• Loan #5:  $5,500 Sub Loan with $5,500 Aggregate usage; Financial Award end date 12/31/2014, and the loan is for a different (non-Regent) school code

  • Because loan #5 is for a different school code, Regent would not adjust the Lifetime Aggregate Usage. Regent will not repackage and re-award the non-Regent loan, so Regent Award does not need to remove the loan amount from Regent's adjusted Total Aggregate Lifetime Usage amounts.  See below for a description of the user notification task for this scenario.

Adjusting the Sub Total Aggregate Lifetime amounts for the individual, current active Sub loan #1:

• ($20,250 Total Aggregate Sub Lifetime Usage from NSLDS) - ($2,750 loan #1 Sub Aggregate usage) = $17,500 Adjusted Total Aggregate Sub Lifetime Usage

Adjusting the Combined (Sub+Unsub) Total Aggregate Lifetime amounts for the individual, current active Sub loan #1 Aggregate usage and the current, active Unsub loan #2's Aggregate usage:

• ($32,750 Total Aggregate Combined Lifetime Usage from NSLDS) - ($2,750 loan #1 Sub Aggregate usage) - ($3,500 loan #2 Unsub Aggregate usage) = $26,500 Adjusted Total Lifetime Aggregate Combined Usage

Repackaging George's loans:  

• AY4, GL4
  • $5,500 Sub
    • Initial Sub calculation: $5,500 Sub Annual limit
    • ($17,500 adjusted Total Sub Lifetime Aggregate Usage + $5,500 AY4 Sub) = $23,000 Total Sub Lifetime Aggregate Usage at the end of AY4
      • $23,000 Total Sub Lifetime used = $23,000 Sub max Aggregate Lifetime limit 
  • $7,000 Unsub
    • Initial Unsub calculation: ($12,500 Combined Annual Limit - $5,500 AY4 Sub) = $7,000 Unsub in AY4
    • ($26,500 adjusted Total Combined Lifetime Aggregate used + $5,500 AY4 Sub + $7,000 AY4 Unsub) = $39,000 Combined Aggregate Lifetime used as of the end of AY4
    • $39,000 used <= $57,500 Combined max Aggregate Lifetime limit   

Loans from Other Schools 

Occasionally, a student will transfer to a Regent school while still having potential additional loan money earned from their previous institution. Regent Award does not adjust the Total Aggregate Usage for loans at other schools. However, those loans might potentially affect the student's Total Aggregate Usage amounts. 

A school may configure a Task, "Review Unpaid Loan from Another School." Whenever Regent Award receives NSLDS loan detail data, the system triggers the Task if any recent loan at another school might potentially change the student's Aggregate totals. The Regent school may contact the other school to confirm when (or whether) the student's unpaid disbursement will be reported to COD and NSLDS, and available in FAH data. In the meantime, the Regent user may manually adjust the student's loans, block packaging, or enter manual Aggregate values on the History tab. More information is at Regent Award Task Triggers.