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TG's New Notice of Guarantee/Disclosure Statement
Texas Guaranteed Student Loan Corporation's (TG) Federal Stafford Loan Notice of Guarantee/Disclosure Statement (NOG) is changing in conjunction with implementation of the Master Promissory Note (MPN). AdvanTG version 2.2 will facilitate the printing of the new Stafford NOG.
TG will produce the same NOG for all Stafford loans regardless of whether the common Stafford application or the MPN is used by the borrower. Lenders and servicers can continue to use the NOG to fulfill borrower loan disclosure requirements. It will contain all of the necessary elements lenders are required to disclose to their borrowers prior to or at the time of first disbursement. However, as in the past, TG will provide the cumulative indebtedness for all of the loans the borrower has guaranteed with TG. The Higher Education Act requires lenders to disclose the cumulative amount of loans the borrower has with the lender. Lenders using TG's NOG for disclosure are responsible for correcting or supplementing the disclosure to meet the statutory requirement for this field.
During Negotiated Rulemaking, negotiators have agreed to revise the regulations covering disclosure to clarify which disclosures are covered in the approved common forms, which must be covered in the initial disclosure, and which must be covered in the repayment disclosure. Proposed regulatory language to clarify disclosure responsibilities is forthcoming.
Enhancement Highlights
The following enhancements cover issues related to using the MPN, as well as suggestions from TG customers and items agreed to in Negotiated Rulemaking. Several additions were made based on input the MPN Task Force gathered from the community during MPN development:
- Instructions for canceling or reducing a loan.
- Notification that laws and regulations may have changed since the signing of the Note and that such information will be disclosed to the borrower on the disclosure or separately.
- Request for reference update.
- Message clarifying that the interest rate is the current rate as of the date of guarantee.
- TG's name and guarantor identification number added to Borrower Information.
- Borrower grade level added to Loan Information.
- TG's toll free number.
- Instructions on estimating monthly payments.
Revised and Reprinted (Duplicate) NOGs
Currently lenders and servicers can request revised and reprinted NOGs in various situations. Depending on when the loan was guaranteed and when the lender requests a revision or "reprint," the statutory interest rate and/or interest rate formula may have changed and the total amount guaranteed by TG may have changed since the original guarantee date. Referring to reprinted NOGs as a "duplicate" is not an accurate description of this type of request. Therefore, TG will eliminate the "D" indicator for "duplicate" currently printed directly on the NOG. Instead TG will print "Q" on what was previously referred to as the "duplicate" NOG. The new "Q" indicator stands for NOG "request." "Revised" NOGs will continue to print with the "R" indicator.
New Interest Rate Addendum for Lenders and Servicers
With implementation of the new Stafford NOG, the Interest Rate message will be the same as that printed on a new, revised, and reprinted NOG. To assist lenders and servicers in disclosing accurate interest rate information to their borrowers, TG will offer a new Interest Rate Addendum that can be sent to the borrower by the lender or servicer showing historical interest rates over time. A revised NOG can be sent to the borrower with the Addendum to disclose the correct interest rate message and interest rate formula as of the date of guarantee. The new Interest Rate Addendum will be available in PDF format in the AdvanTG version 2.2 CD and TG's corporate website, TG Online, at www.tgslc.org.
New Federal PLUS Loan Notice of Guarantee on the Horizon
TG is currently enhancing the Federal PLUS Loan Notice of Guarantee/Disclosure (NOG). The new PLUS NOG will be made available sometime this fall. Of special interest to lenders and servicers is the complete replacement of the Messages section. Because of the number and length of required disclosures, TG can no longer continue to include a place for lenders to indicate payment information. This may create the need for lenders to modify programs or to develop new procedures.
Please see samples of the new Stafford and PLUS NOGs included in this Shoptalk to determine how they will fit into your existing processes.
Questions
For questions about the new Stafford or PLUS loan NOGs, contact Kyle Smith, Assistant Vice President, Loan Guarantee Operations, at (800) 252-9743, ext. 4894, or send an message to
kyle.smith@tgslc.org.
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