Since February 14, 2010 schools have been required to comply with the Truth In Lending Act Regulation Z, commonly known as TILA. TILA covers all private education loans (school loans, *school payment plans, alternative loans, etc.). When a student applies for a Non-Title IV Loan, they are required to submit a self-certification form to their prospective lender. As a result, your school is required to fill in the pertinent information for that student on the form, or provide the student with the form from your school. When a student applies for an “Institutional Loan” from your school (including school loans and some school payment plans), your school must provide and collect the self-certification form from the student.
At the request of an enrolled or admitted student applicant for a private educational loan (or to the parent loan applicant of an enrolled or admitted student), an institution must provide the Self-Certification form to the applicant with the information requested in Section 2 of the form, to the extent that the institution possesses the information. Section 2 of the Self-Certification form requests the following information:
• The student’s Cost of Attendance (COA) for the period of enrollment covered by the loan;
• Any Estimated Financial Assistance (EFA) for the period of enrollment covered by the loan; and
• The difference between the COA and EFA.
The Department has just released the revised “Private Education Loan Applicant Self-Certification” form, with a new expiration date of July 31, 2019. This form replaces all earlier versions and can be used immediately and up until October 31, 2016. The revised form is available here: http://bit.ly/2ahT0cV
Remember, payment or installment plans that do not apply interest or finance charges and which have a term of one year or less, are not covered under TILA Reg Z and are thus exempt, even if the terms require payment in more than four installments.