DCL GEN-14-02 provides revised guidance concerning the implementation of the new Military Service and Post-Active Duty Student Deferment Request form as well as a slightly modified version of the form.
The form that was originally released in DCL GEN-12-23 had been modified to allow a borrower with visual impairments to sign the form electronically with a facsimile signature. However, the signature line was not limited only to digital facsimile signatures as intended. In a future revision of the form USDE plans on including this important limitation. In the meantime, and in the interest of having the form implemented as soon as possible, the signature line as a fillable field has been dropped.
GEN-13-23 also requested that lenders and servicers more clearly explain to borrowers any electronic submission processes that may be available to them and the letter provided an example of email as a means of electronic submission. The example of email was not intended to serve as a specific endorsement of email as the preferred method of electronic submission. There are other acceptable methods of electronic submission that have been adopted by lenders and servicers.
GEN-13-23 also provided that, beginning June 1, 2014, lenders and servicers could not accept the prior version of the form. USDE has determined that, to better serve the affected borrowers, lenders and servicers may continue to accept the previous version of the form on or after July 1, 2014.
In light of this revised implementation guidance, the deadline by which lenders and servicers must begin distributing the new Military Service and Post-Active Duty Student Deferment Request form has been extended from February 28, 2014 to April 30, 2014.
Any guidance in GEN-13-23 that was not expressly modified by this Dear Colleague Letter remains in effect.