Recordkeeping

Institutions must be able to document the various actions they take in the administration of the Title IV programs, for both reporting and audit/program review purposes. The time period during which records must be retained, as well as the manner and format, are defined in regulation.

Related topics in this Index: Audit and Program Review; Cash Management

Statutory Authority
- U.S. Code, Title 20—Education Chapter 28—Higher Education Resources and Student Assistance Subchapter IV—Student Assistance > Part G—General Provisions Relating to Student Assistance Programs § 1094(a)(3) Program participation agreements [HEA § 487(a)(3)]
Regulations
- 34 CFR 668.24
ED References
See also Subtopics for more specific references.
NASFAA Publications and Articles
- NASFAA AskRegs Knowledgebase
  Search or browse the Knowledgebase for answers to regulatory and compliance questions submitted by financial aid administrators.
- NASFAA Compliance Engine
  The Compliance Engine is comprised of two modules: the Self-Evaluation Checklists which allows administrators to evaluate their programs in a centralized, shared online space, and the P&P Builder, a tool designed to assist institutions in the creation and maintenance of a policies and procedures manual. Along with an online space to update and maintain policies and procedures, the P&P Builder includes legislation and regulation associated with compliance with Title IV requirements.
- NASFAA U Authorized Events
  NASFAA U Authorized Events are a comprehensive set of instructional materials for teaching financial aid concepts to groups of individuals. Materials include a study guide, instructor guide and accompanying presentation slides.
Subtopics
- Administrative records related to institutional eligibility, educational program eligibility, and Title IV participation
- Closed branch records
  - 2018-19 FSA Handbook, Vol. 2, Ch. 7
  - 2017-18 FSA Handbook, Vol. 2, Ch. 7
- Closed school records
  - 2018-19 FSA Handbook, Vol. 2, Ch. 7
  - 2017-18 FSA Handbook, Vol. 2, Ch. 7
- Completion and graduation rate calculation documentation
  - 668.24(c)(1)(vii)
- Direct Loan Program
  - 2018-19 FSA Handbook, Vol. 2, Ch. 7
  - 2017-18 FSA Handbook, Vol. 2, Ch. 7
- Examination, availability, and sharing of records (cooperation with regulating agencies, loan servicers, and auditors)
  See also top list entry for Administrative Capability
- Federal Trade Commission (FTC) information security requirements (Financial Services Act, Security Provisions; Financial Services Modernization Act)
  - 2018-19 FSA Handbook, Vol. 2, Ch. 7
  - 2017-18 FSA Handbook, Vol. 2, Ch. 7
- FERPA protections, exemptions, right to review records, and documented consent to disclose
- Fiscal records related to receipt and expenditure of Title IV funds—general rule
- FISCOP/FISAP
- FSEOG fiscal records
- FWS payment records
- Job Location and Development
  - 675.36
- Maintenance (format and location)
  - E-Sign Act and electronic processes
    
    GEN-01-06
    
    2018-19 FSA Handbook, Vol. 2, Ch. 7
    
    2017-18 FSA Handbook, Vol. 2, Ch. 7
  - Format
    
    2018-19 FSA Handbook, Vol. 2, Ch. 7
    
    2018-19 FSA Handbook, Vol. 6, Ch. 1
    
    2017-18 FSA Handbook, Vol. 2, Ch. 7
    
    2017-18 FSA Handbook, Vol. 6, Ch. 1
  - General Maintenance Requirements
    
    668.24(d)
  - Location
    
    2018-19 FSA Handbook, Vol. 2, Ch. 7
    
    2017-18 FSA Handbook, Vol. 2, Ch. 7
- Pell Grant
  - 668.24
  - 690.81(a)
  - 690.82
- Perkins Loans
  - General information
    
    2018-19 FSA Handbook, Vol. 6, Ch. 3
    
    2017-18 FSA Handbook, Vol. 6, Ch. 3
  - Collection costs charged to Fund
    
    674.47(f)
  - Fiscal records
    
    674.19(d)(1)
    
    674.19(e)(1)
    
    2018-19 FSA Handbook, Vol. 6, Ch. 1
    
    2017-18 FSA Handbook, Vol. 6, Ch. 1
  - Loan and disbursement records
    
    674.19(e)(2), (3)
    
    2018-19 FSA Handbook, Vol. 6, Ch. 3
    
    2017-18 FSA Handbook, Vol. 6, Ch. 3
  - Promissory note
    
    674.19(e)(4)
    
    2018-19 FSA Handbook, Vol. 6, Ch. 3
    
    2017-18 FSA Handbook, Vol. 6, Ch. 3
- Reports, forms, and underlying data related to Title IV participation
- Retention requirements (timeframes)
- Student-level records
  - Amounts disbursed and/or returned
    
    668.24(c)(1)(iv)
  - Loan counseling
    
    668.24(c)(1)(v)
  - Student (or parent borrower) eligibility and need
    
    668.24(c)(1)(i), (ii), (iii)
    
    GEN-17-08
    
    2018-19 FSA Handbook, Vol. 2, Ch. 7
    
    2017-18 FSA Handbook, Vol. 2, Ch. 7
- TEACH Grant
  - 686.36(a)
  - 686.38
- Written agreements
  - 668.5(d)(3)(ii)

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Recordkeeping

Statutory Authority

Regulations

ED References

NASFAA Publications and Articles

Subtopics

Administrative records related to institutional eligibility, educational program eligibility, and Title IV participation

Closed branch records

Closed school records

Completion and graduation rate calculation documentation

Direct Loan Program

Examination, availability, and sharing of records (cooperation with regulating agencies, loan servicers, and auditors)

Federal Trade Commission (FTC) information security requirements (Financial Services Act, Security Provisions; Financial Services Modernization Act)

FERPA protections, exemptions, right to review records, and documented consent to disclose

Fiscal records related to receipt and expenditure of Title IV funds—general rule

FISCOP/FISAP

FSEOG fiscal records

FWS payment records

Job Location and Development

Maintenance (format and location)

E-Sign Act and electronic processes

Format

General Maintenance Requirements

Location

Pell Grant

Perkins Loans

General information

Collection costs charged to Fund

Fiscal records

Loan and disbursement records

Promissory note

Reports, forms, and underlying data related to Title IV participation

Retention requirements (timeframes)

Student-level records

Amounts disbursed and/or returned

Loan counseling

Student (or parent borrower) eligibility and need

TEACH Grant

Written agreements