iAs recently reported, the Washington, D.C. Department of Insurance, Securities, and Banking (DISB) published a Bulletin in late April reminding those who service student education loans in the District of Columbia of their obligation to file an annual report. The DISB has now released the required forms for both the 2018 and 2019 filings.
In an email to servicers, the Commissioner explained that the DISB was waiting to release the 2018 annual report form until Student Loan Servicing Alliance v. District of Columbia, et al. was resolved. Both the DISB and SLSA have now withdrawn their appeals of the decision. The Bulletin also explains that because of the litigation, the 2018 annual report form is now due by June 15, 2019 and no late fees will be assessed based upon the initial statutory deadline of January 30. The letter also informed servicers that the information collected in the annual report will be used to generate the annual assessment that is due on November 15, 2019. The 2019 annual report form is due by January 30, 2020, consistent with Section 3014 of the DISB regulations.
The annual report forms request information regarding the total number of borrowers and dollar amount of loans serviced in the District of Columbia, as well as the total number of borrowers and dollar amount of loans involving: delinquencies of 30 to 90 and 91 to 180 days; collections; modifications; deferments; loans sold, assigned, or transferred to the licensee; and loans sold, assigned, or transferred from the licensee.
