OTC AskRegs Experts: Understanding Comment Code 352 and Best Practices to Prevent Student Aid Fraud

This week on "Off the Cuff," Jill, Sarah, and Maria discuss questions regarding 2026-27 reprocessed ISIRs, and best practices for institutions to prevent student aid fraud. Jill starts by noting that reprocessed ISIRs recently started arriving in financial aid offices with comment code 352 and a corresponding C-Flag and explains what that means. Jill goes on to detail what NASFAA knows so far about this issue, including which ISIRs are affected. From there, Sarah goes through best practices shared by the Department of Education (ED) on how institutions can help prevent student aid fraud. 

Speakers

Jill Desjean Sarah Austin Jill Desjean
Jill Desjean
Director of Policy Analysis
Sarah Austin
Policy Analyst
Maria Carrasco
Reporter

 

NASFAA Virtual Summit

This episode of Off The Cuff is brought to you by the NASFAA 2026 Virtual Summit.

The NASFAA 2026 Virtual Summit, exclusive to NASFAA members, will take place July 13-16. We have streamlined the programming to bring you the most up-to-date and important information on student financial aid. For a one-time registration fee of only $350, everyone on your NASFAA roster can participate in this cost-effective, online learning opportunity - either live or on-demand. NASFAA Members: learn more and register today at nasfaa.org/virtual.

Resources

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Publication Date: 6/5/2026

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