Mandatory Assignment of Perkins Loans

November 10, 2021 · by COHEAO · Spark Notes

As you know, COHEAO has been actively engaged and reviewing the Department’s August 27th notice regarding the mandatory assignment of Perkins loans that are more than 2 years in default.  Our previous Sparks indicated that COHEAO would be taking action.


This week, a letter was sent to Under Secretary James Kvaal asking him to rescind the August 27th guidance.  The request for rescission was based on three main points:

  • Recovery data does not support 2 years
  • The guidance letter contradicts current binding regulation
  • The Department’s interpretation is not consistent with Congressional intent


COHEAO will continue to engage on this subject with the Department and will keep you informed of that engagement.  In addition, we will share any response from the letter once it is received. 


In the meantime, COHEAO urges institutions to follow good management practices as outlined in previous Sparks and webinars.  Should you have any questions, please feel free to contact Robert Moran, Executive Director, with any questions at 202-539-6488 or by email at


You can view the letter here.

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