OTC AskRegs Experts: Working Through Some Professional Judgment Scenarios
This week on “Off the Cuff,” Hugh and David kick off a broader discussion on what is and what isn’t a professional judgment. Last week, David was at the Nebraska State Association conference, where he did a session on professional judgment and, based on some questions that came up, decided to share some important takeaways with the podcast community. During the conversation, David provides definitions for “special circumstances” and “unusual circumstances,” and offers scenarios detailing situations that may or may not allow professional judgment.
Speakers
 |
 |
| Hugh Ferguson Managing Editor |
David Tolman |
Resources
- Listen on Apple Podcasts or Spotify
- Episode Transcript (PDF)
- Regulation on refusing or reducing Direct Loan origination 34 CFR 685.301(a)(8)
- AskRegs: Do We Still Have Professional Judgment Authority to Reduce or Deny a Direct Loan?
- AskRegs: Is a Satisfactory Academic Progress Appeal Determination Considered Professional Judgment?
- AskRegs: Is There a Difference Between a Special Circumstance and an Unusual Circumstance?
Send your thoughts, questions, and comments. We'd love to hear what you think.
Publication Date: 3/27/2026
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