PASFAA Webinar:
Federal Update
November 26, 2013
Department of Education:
Greg Martin
Agenda
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Federal Updates, Greg Martin
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FAFSA changes
DOMA effect on FAFSA
Verification
150% Subsidized Limitation
Funding and sequestration
Pell LEU
Direct Loan interest rates
Guidance/clarification on assorted topics
Regulatory activity
Discussion of Questions
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attendees
2013-14 CPS/FAFSA Changes
• Income Threshold for Automatic Zero EFC
increased from $23,000 to $24,000
• The PIN signature option will display more
prominently
• “Sign Electronically With My PIN” will be the default
signature option for most applicants
• Students/parents can choose another option for
signing, and when selected, the system will display
options to use PIN, print a signature page, or
submit without signatures, along with definitions for
each
5
2014-15 FAFSA
• Change to collection of parental information
– See GEN 13-12 April 29, 2013
• Applies to dependent students when legal parents
live together
• Legal means biological or adoptive
• Both parents income and other data must be
reported
• Regardless of marital status or gender
• Higher Education Act Section 475 includes the
terms “parent” and “parents” and not genderspecific terms “mother” and “father”
6
2014-15 FAFSA
• New marital status option of “Unmarried and both
parents living together
• Dependent student instructed to provide information about
both legal parents regardless of marital status and gender
• Other parent marital status options: “Never married”,
Married or remarried”, “Divorced or separated” and
“Widowed”.
• Reasoning behind changes:
• Collecting parental information from both legal parents will
result in fair treatment of all families by eliminating
longstanding inequities that were based on the legal
relationships of parents (married or not married) rather
than on the parents’ relationship with their child.
7
2014-15 FAFSA
• Two new fields added that collect the tax
filing status of the student and the parents
of the dependent student
8
Defense of Marriage Act -DOMA
• On June 26, 2013, the Supreme Court struck
down the portion of the Defense of Marriage Act
providing that for the purpose of Federal
programs, a marriage can only be between a man
and a woman
• Impacts the FAFSA/EFC and income driven
repayment plans
• 2014-2015 Draft FAFSA instructions direct samesex couples to report their marital status as
“married”
• If legally married in a state or other jurisdiction that
permits same-sex marriage
9
2014-15 Verification
• Items to verify and acceptable
documentation are published for each year
in an annual Federal Register Notice
• 2014-15 Federal Register Notice
published
June 13, 2013
• Refer to DCL GEN-13-16
10
2014-15 Verification
• 2014-15 verification items are the same as for 2013-14 with
one addition – Other Untaxed Income
– Certain applicants will be required to verify the untaxed income
information they provided
• Question 45 for students and Question 94 for dependent student’s
parents
• If FAA determines that amounts provided and verified from
untaxed income and other sources do not appear sufficient,
applicant and, if appropriate, applicant’s parents or spouse
must explain how the family was financially supported
during 2013
• Verification worksheets will not be provided
• Suggested text for each 2014-15 verification item will be
provided and posted to IFAP
11
2013-2014 Verification
• Electronic Announcement dated October 23, 2013
updates acceptable documentation for the 20132014 award year
• For the remainder of the 2013-2014 award year
alternative documentation is acceptable in
instances where the tax filer recently requested an
IRS Tax Return Transcript but was unsuccessful in
obtaining it
• Must have used the paper or online request process
• No alternative documentation allowed for telephone
request process because IRS does not provide
written documentation of request failure
12
2013-2014 Verification
• Alternative Documentation acceptable per October 23, 2013 Electronic
Announcement
– Signed copy of relevant 2012 IRS tax return; and
– Copy of IRS response to paper request (must be signed by the tax filer)
informing tax filer that the requested transcript could not be provided – if
transcript request was using IRS Form 4506T –EZ or 4506-T; or
– Signed and dated copy of a screen print from the official IRS Web page that
displays a message indicating the transcript request was unsuccessful
– ADDITIONALLY:
– Tax filer must provide the institution with a completed and signed IRS Form
4506T-EZ or 4506-T
• Must include on Line 5 name, address and phone of institution as 3rd party for mailing
transcript
• If no reasonable doubt about accuracy of information on tax return, school simply retains
the form
• If any reason to believe information on tax return to be in accurate, must submit and wait
for IRS to return a transcript
13
2014-15 Verification
• Verification Tracking Groups
• V1, V3,V4and V5 retained
• Group V2 (SNAP) eliminated
• New Group V6 added – Income appears not sufficient
to support family size (V1 + all untaxed FAFSA items
must be verified)
• Payments to tax-deferred pension and savings
• Child support received
• Housing, food and other living allowances paid to members
of the military, clergy and others
• Veterans noneducation benefits
• Other untaxed income
• Money received or paid on the applicant’s behalf
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2014-15 Verification
• Non tax filers
• If an institution questions a claim that the tax filer is
not required to file, it must require the applicant to
submit a “Verification of Nonfiling”
• Obtained by the tax filer using IRS Form 4506-T and
checking box 7
• Verification of Nonfiling for 2013 tax year not issued
until after
June 15, 2014
• After examining the original Statement of Educational
Purpose for accuracy and completeness, the
institution may convert it to an electronic record
15
2014-2015 Verification
• Verification –Suggested Text EA November 8, 2013
– Provides suggested text for each of the required 2014-2015
verification items (Appendix A)
– Institutions are not required to use the Department’s
text/formats
• Exception – Institutions must use the exact language provided in the
“Statement of Educational Purpose” in Appendix A for students for
students in Verification Tracking Groups V4 or V5
– Use of a comprehensive verification worksheet is discouraged
• Suggests to students that all items on the worksheet need to be
verified
• May delay notifications of awards and disbursements – students and
families struggle to provide documentation for items for which
verification is not needed
16
Extended Foster Care Payments
• Extended foster care payments made under Title IV –
Part E of the Social Security Act directly to foster youth
are excluded from calculation of EFC and not included
on FAFSA - See DCL GEN -13-18
• Payments made under the authority of a state foster youth
program must be reported on FAFSA as untaxed income
• Does not matter if all or any part of the payments is
made from State or other non-federal sources
• Determining factor is whether payments were made under
Part E of Title IV of the Social Security Act
• FAA s may need to become familiar with their state’s
foster youth program
17
FAFSA – Income Earned From Work
• Income Earned from Work field now automatically updated with IRS
value
– Effective September 2013 (see June 25, 2013 EA)
– For students who use IRS DRT and indicate a marital status of Single,
Separated or Divorced or Widowed
– For parents of dependent students who use IRS DRT and indicate a
marital status of Single, Divorced or Separated or Widowed
• If marital status is married/remarried, Income Earned from is displayed viewonly and total amount must be input for each spouse
– Modification of this field will not change IRS Request Flag values
• Dynamic display of tax line numbers
– Student Application and Correction Entry will display applicable IRS tax
line number associated with student/parent AGI, Income Tax Paid and
Exemptions fields
• Based on tax return type and tax filing status indicated by student or parent
18
Direct Subsidized Loan 150% Limitation
• Public Law 112-141, Moving Ahead for Progress in the
21th Century Act, enacted July 6, 2012
• Amended the HEA to set a new limit on Direct Subsidized
Loan eligibility
• Statutory requirement for negotiated rulemaking and
publication of regulations in accordance with master
calendar are waived
• ED published Interim Final Rule
• Regulations effective immediately upon publication
• Revises 34 CFR 685.200, 685.202, and 685.304
• Comment period ended on 7/01/13
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Key Points On 150% Limitation
• Higher Education Act has changed
• Imposes a limit on Direct Subsidized Loan eligibility
• 150% of published length of the educational program
• Makes borrowers who exceed the limit responsible
for accruing interest
• Borrower becomes responsible for accruing interest as of the date
he/she exceeds 150% limit
• ED, not institutions, will be responsible for all
tracking and notification of borrowers
• Institutions will be required to report additional
program and borrower information
• ED will make necessary changes to its financial aid
systems
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150% Loan Limit Reporting
• DCL GEN-13-13 contains guidance and examples
on reporting academic year and loan periods to
COD
• Accurate reporting is critical to proper implementation
of the 150% Direct Subsidized Loan limits
• Many schools are not currently in the practice of
updating loan period and academic year – updating is
imperative
• Follow guidance and examples provided in the DCL
where borrower’s actual attendance during the loan
period is different from the anticipated attendance that
was the basis for the school’s initial reporting to COD
21
COD System Changes
• Phase One changes already made
– New System Field “Subsidized Usage Limit Applies”
• Will be date of first actual disbursement of sub/unsub accepted
by COD
– Identify first-time borrower in COD for 150% Direct Loan
Subsidized Limitation
• New Warning Edit 200 “150% Subsidized Usage Limit Applies
to Borrower”
– Notify school that borrower subject to 150%
Subsidized Limitation
– Will be returned at person level on any award that has SULA
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COD System Changes
• Phase One changes already made
• New System Report
• Weekly web-only report automatically posted to
school’s Reporting Newsbox
• Lists all borrowers subject to 150% Direct
Subsidized Loan limitation
– Borrower will appear only once in processing year
– Borrower will remain on report for 45 days
23
COD/NSLDS System Change
• Upcoming changes –next spring
• Addition of tags to COD schema for borrower’s enrollment status
and payment period begin dates of loan
• Used to prorate borrower’s SUP where enrollment for payment period is
< full-time
• NSLDS will allow a new ¾ time enrollment status
• Alternative method for COD to obtain enrollment statuses for
loans made for 2013-2014 year (prior changes)
• Use enrollment status info. currently reported to NSLDS
• SUP for Direct Subsidized Loans will be prorated on the basis of
½ time enrollment – even if borrower is ¾ time
• If, for any portion of the loan period, enrollment status reported to
NSLDS is at least ½ time but less than less than full-time (NSLDS
enrollment status = H)
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COD Calc. of Subsidized Usage Periods
• First COD calculation of Subsidized Usage
periods will occur in March 2014
• COD will only prorate a 2013-2014 SUP of the
school has reported at least ½ time but less
than full-time enrollment status
• COD will recalculate the SUP to account for
enrollment information reported by schools
after initial calculation
• This may result temporarily incorrect SUPs
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Loan Limit Webinars
• DCL ANN-13-08 announces 150% webinar recordings
• “COD Reporting of Academic Year and Loan Period”
• “150% Direct Subsidized Loan Time Limit”
• Recordings, presentation slides and transcripts
available
• Transcripts are especially useful
• How to access:
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Go into ifap.ed.gov
Select “Training & Conferences” – right side of main menu
Select “Training Announcements”
Select 2013
Scroll down to ANN-13-08 and open it –you will see the
appropriate links
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2013-2014 Pell Grant Payment Schedules
• See DCL GEN-13-06
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Maximum Scheduled Award is $5,645
Maximum Eligible EFC is 5081
Minimum Scheduled Award (formula) is $565
Minimum Scheduled Award (schedules) is $582
No LEU Minimum
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2013-14 Funding
• Pell and TEACH Grant are “records first”
– COD must have accepted disbursement record before G5
will allow drawdown of funds
– Schools may report up to 7 calendar days in advance of
actual disbursement date
• Direct Loan
– School with history of “early” disbursements received initial
Direct Loan current funding level in G5 on/about 3/25/13
– All other schools will have current funding level in June 2013
– Update to current funding level in November 2013
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Sequestration
• DCL GEN-13-22 describes FY 2014 sequestration changes to
the Title IV programs
• Federal Pell Grant
• Exempted from the effects of sequester
• 2013-2014 payment schedules posted in DCL GEN-13-06
remain in effect without changes
• Information regarding 2014-2015 award year amounts will not be
available until an appropriation bill is enacted
• Campus-Based programs
• 2013-2014 award year allocations provided in an April 5, 2013
EA and supplemented by a September 25, 2013 EA remain valid
• These amounts were determined under earlier sequestration
requirements
• There is no information regarding sequester’s effect on 2014-2015
allocations
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Sequestration
• Iraq-Afghanistan Service Grants
– Must be reduced by 7.2% from original statutory amount where
the first disbursement is made on or after October 1, 2013
– Must be reduced by 10% from original statutory amount where
the first disbursement was made after March 1, 2013 and prior
to October 1, 2013
• Continue to be covered under the FY 2013 sequester
• TEACH Grants
– Must be reduced by 7.2% from original statutory amount where
the first disbursement is made on or after October 1, 2013
– Must be reduced by 6.0% from original statutory amount where
the first disbursement is made after March 1, 2013 and prior to
October 1, 2013
• Continue to be covered under the FY 2013 sequester
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Sequestration & New Loan Fees
• DL fees where first disbursement is made on or
after December 1, 2013
• 1.072% for DL Subsidized and Unsubsidized Loans
• 4.288% for Direct PLUS Loans
• DL fees where first disbursement was or will be
made on or after July 1, 2013 and prior to
December 1, 2013
• 1.051% for DL Subsidized and DL Unsubsidized
Loans
• 4.204% for Direct PLUS Loans
• Fees are irrespective of when any second or
subsequent disbursements are
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Sequestration & New Loan Fees
• October 18 was earliest date schools could
begin submitting DL records to COD for loans
where the first disbursement will be on or
after December 1, 2013
• If DL records were submitted to COD using last
spring’s sequestration percentages, origination
must be cancelled and a new loan originated
using the correct loan fee percentages
• DCL GEN-13-22 contains an attachment detailing
loan fees and providing examples bases on
maximum loan amounts
32
Change to COD Disbursement Reporting
• Applies to 2012-13 and 2013-14
• Actual disbursements and adjustments to disbursements
made on/after 4/01/13 must be submitted to COD no
later than 15 calendar days after date of disbursement
• Applies to Pell Grant, Iraq and Afghanistan Service Grant,
TEACH Grant and Direct Loan
 An institution's failure to submit disbursement records
within the required timeframe may result in the Secretary
rejecting all or part of the reported disbursement. In
addition, such failure may result in an audit or program
review finding.
33
Pell LEU & COD Edits
• HARD REJECT in COD began in summer 2013
• Will prevent Pell disbursements to students with
LEU greater than 600%
• Will apply to 2012-13 and forward
• Modified COD warning edits
• 177 – Pell LEU equal/greater than 450% but
equal/less than 600%
• 178 – Pell LEU exceeds 600%
34
Pell LEU DCL GEN 13-14
• Examples of how to calculate student eligibility
for Pell Grant awards and reduced Pell Grant
awards
• COD calculates eligibility to the 3rd decimal point
– No rounding to three decimals
– Must truncate at cents
• Ex. $1,233.567 truncates to $1,233.56
– If Pell awarded in whole dollars, award must be
truncated to the next whole dollar
• Ex. $1,233.56 truncates to $1,233
• No de minimus award amount
35
Pell LEU Dispute Process
• See EA dated June 27, 2013
• Outlines process for students/schools disputing accuracy of
information resulting in Pell LEU percentage
• Student who believes there to be an inaccuracy must
contact his/her current school
– Must have filed a FAFSA for the current award year
– Must provide all documentation requested by the current
school
• Current school must take active role in resolution using
steps provided in EA attachment
– Former schools expected to cooperate in resolution
• School reporting errors are non-dispute issues – school
must make required corrections
36
Pell LEU Dispute Process
• Escalation
• Occurs once the current school has taken all required
steps and determined the dispute should be
escalated
• Initiated by contacting COD – Case Number assigned
• ED staff review the dispute and documentation then
issue approval or denial notification
• Note : If the disputed amount, were it resolved in
the student’s favor, would not bring LEU to less
than %600, do not escalate the matter
• New: adjusted Pell Grant LEU available on COD
website’s Pell LEU History screen
37
Ability To Benefit (ATB)
Consolidated Appropriations Act, 2012
• Eliminated Title IV aid eligibility for students without
a high school diploma or equivalent (34 CFR
600.2)
• Effective for 2012-13 award year
 DCL GEN-12-01 and GEN-12-09
Exception explained in DCL
• Students who were enrolled in a Title IV eligible
program anytime prior to July 1, 2012, as ATB
student, may continue to qualify under one of the
ATB alternatives
 Approved ATB test
 Completion of six credit or 225 clock hours
38
Cohort Default Rates
• FY 2010 3-year cohort default rate (CDR) distributed
• All schools enrolled in eCDR were sent FY 2010 3-year official
CDR and accompanying documentation via SAIG on September
23, 2013
• 2-year Official CDRs distributed on September 16, 2013
• Last 2-year CDR to be calculated
• 2014 – three 3-year official CDRs will be available with sanctions
based on the 3-year rates beginning
• 3-year Cohort Default rate Sanctions (in effect 2014)
• School’s three most recent CDRs 30% or greater
• Loss of DL and Pell Grant program eligibility for remainder of the fiscal year
in which notified and two following fiscal years
• School’s current CDR is above 40%
• Loss of DL eligibility for remainder of the fiscal year in which notified and
two following fiscal years
39
Cohort Default Rates
• For purposes of 30 day delay and single
disbursement of one-term only loans, you can use a
mix of 2 year and 3 year rates to get three years
below 15%
• FY 2011 2-year rate will be last 2-year rate
calculated
• As of 2014, we will have three 3-year rates
calculated
40
Grace Period Interest Subsidy
Consolidated Appropriations Act, 2012
• Temporarily eliminates interest subsidy on Direct
Subsidized Loans during 6 month grace period
• Effective for new Subsidized Loans first disbursed
on/after July 1, 2012 and before July 1, 2014
• COD will monitor for compliance
• Will only impact students whom you report as out
of school or less than half-time
41
Direct Loan Interest Rates
• Bipartisan Student Loan Certainty Act of 2013 provides new formulas for
determination of Direct Loan interest rates – see August 9, 2013 EA
– Applicable to all Direct Loans for which the first disbursement is on or after
July1, 2013 and all Direct Consolidation Loans for which the application was
received on or after July 1, 2013
• How rates are determined
– Established each year for which the disbursement is on or after July 1 through
the following June 30 for the life of the loan
– Rate is the sum of the uniform “index rate” plus an add-on depending upon
the loan type and whether grad or undergrad
– Interest rate caps as follows:
• Direct Subsidized and Direct Unsubsidized Loans for undergraduates = 8.25%
• Direct Unsubsidized Loans for graduate/professional students = 9.50%
• Direct PLUS Loans Parent and Grad/Professional = 10.50%
– Interest rate for Direct Consolidation Loans remains weighted average except
the 8.25% interest cap is removed
42
Direct Loan Interest Rates
• Overview of 2013-14 interest rates
– Direct Subsidized Loans
• Undergraduate
3.86%
– Direct Unsubsidized Loans
• Undergraduate
• Graduate/Professional
3.86%
5.41%
– Direct PLUS Loans
• Parent and Grad/Professional
6.41%
– Direct Consolidation Loans
• Weighted average of the interest rates of the loans included in the
consolidation rounded up to the next higher one-eighth of one
percent
43
PLUS Loan Applicant Communications
• Special outreach to PLUS loan applicants denied
because of credit began 6/28/13
– Applicants invited to contact Student Loan Support Center for
more information, encourage to request reconsideration
• COD and Web site modifications (June 25, 2013 EA)
– New PLUS Loan Reconsideration Report (COD Reporting
Newsbox) – IDs applicants who would most likely benefit from
reconsideration
– Modified COD Web site to include a Credit Check
Reconsideration Flag
• Indicates whether applicant has received communication that he/she
may qualify under the reconsideration process (Y=Yes; N=No)
– August 13, 2013 EA – Additional applicants identified as likely to
be approved upon reconsideration
44
Resolving Inadvertent Overborrowing
• Inadvertent student borrowing in excess of annual or
aggregate loan limits
• ISIR reflects flags and comment codes
• Student regains eligibility by
• Repaying excess amount in full
• Making satisfactory payment arrangements
• Involves reaffirmation
• Refer to DCL GEN-13-02
25
Direct Loan & Student Attendance
• Student must begin attendance to be Direct Loan eligible
• Failure to begin attendance in any class
– School must return any DL funds applied to student account
– Immediately notify loan servicer of non-attendance
• Failure to begin attendance on a less than half-time
basis
– No return of funds required by school or student
• No subsequent disbursements until student
resumes at least half-time status
• Refer to DCL GEN-13-02
46
Clarification To Previous Guidance
4/19/13 IFAP E.A. clarifies statement in 11/09/12 IFAP E.A.
“Packaging and Repackaging Title IV Aid”
Example B - Student Eligibility
• Student Enrollment: Student was enrolled in both the fall
and spring terms.
• FAFSA Application Status: Student did not complete FAFSA
until after the end of the fall term.
• Student Eligibility: Student did not meet all eligibility
requirements until the spring term.
47
Clarification To Previous Guidance
• Aid Eligibility: Because, while the student was enrolled in the
fall term, he or she did not meet all of the eligibility
requirements in the fall term, even though the student
applied while enrolled (here, during the spring term), the
student can only receive Pell Grant funding (and campusbased funding) for the spring term – the term when eligibility
was met. However, unless the student was ineligible due to
not making SAP, the student can receive Direct Loan funding
for all periods of the loan period, including the fall term. A
student who is not making SAP regains eligibility only when
the student is in compliance with the school’s SAP
standards, and does not regain eligibility for a prior period
of ineligibility.
48
GE Disclosure Template
• Gainful Employment Electronic
Announcement #46
• November 22, 2013
• GE Disclosure Template released
• Institutions must use by January 14, 2014
• Use output document from the Template to meet
currently effective disclosure requirements
• EA provides a link to the disclosure template
application
49
StudentLoans.gov For 2013-14
• All FSA loan counseling tools together on this site
• Entrance Counseling
• Subsidized, Unsubsidized, and Graduate/Professional PLUS
• Exit Counseling
• NSLDS will continue to provide detailed exit counseling reports
• Financial Awareness Counseling
• New Repayment Estimator on “My Preferences” screen
50
StudentLoans.gov for 2013-2014
New features for signed-in students
• New landing page with guidance to help the student
select the right type of counseling
• Select schools to notify from a list of associated
schools
• Add new schools to notify
• Select preferred repayment plan in Exit Counseling
• Send notifications of previously completed
counseling sessions
 Entrance Counseling
 Financial Awareness Counseling
51
StudentLoans.gov for 2013-2014
52
StudentLoans.gov for 2013-2014
53
Counseling Reports
• Posted to your School NewsBox on COD site
• New counseling type indicators
“S” for Subsidized & Unsubsidized Entrance
Counseling
“P: for Subsidized, Unsubsidized, and PLUS
Entrance Counseling
“L” for Financial Awareness Counseling
“X” for Exit Counseling
54
College Scorecard
College Scorecard
An online tool that will
make it easier for
students and families
to compare colleges
by comparing
information such as:
net price; graduation
rates; default rates;
student loan debt; and
earnings potential
55
Regulatory Activity
• Loans 1
• NPRM issued July 17, 2012
• Final Rules issued November 1, 2012 with
July 1, 2013 eff. Date
• Pay as you earn
• Total and Permanent Disability
• 150% Direct Subsidized Loan Limit –
Interim Final Rule
• Published May 16, 2013
• Comment period ended on July 1, 2013
56
Regulatory Activity
• Loans 2 – Final Rule published November 1, 2013
• Repeals redundant FFEL regulations
• Updates Direct Loan regulations
• Defines “satisfactory repayment arrangement” more consistently
across all Title IV programs
• Borrower who makes six payments when rehabilitating a loan, but does
not seek additional Title IV aid, will not be considered to have used the
one-time only opportunity to regain Title IV eligibility by making
satisfactory repayment arrangements
• Amends closed school discharge provisions
• Borrower may qualify for a loan discharge if the borrower withdrew from
school not more than 120 days before the school closed and ED has
ability to extend the time frame due to exceptional circumstances
57
Regulatory Activity
• Loans 2
• Minimum loan period exception applicable to transfers in
clock-hour/non-term and some non-standard term
programs modified
• Allows origination of a loan for a period of less than an
academic year, regardless of whether transfer hours re
accepted
• FFEL and DL enrollment status reporting requirements
updated to reflect current processes
• Adds comparable enrollment status reporting provisions for
Perkins
• Forbearance adjustments
• Loan Rehabilitation – reasonable and affordable payment
standards
• Federal Perkins Loan – deferment and cancellation
adjustments
• FFEL – repayment disclosures and AWG
58
Program Integrity Regulations Q&A Web Site
http://www2.ed.gov/policy/highered/reg/hearulemaking/2009
/integrity-qa.html
• Includes•
•
•
•
•
•
State authorization
Repeating coursework
Credit hour definition
Ability-to-benefit
Incentive compensation
Misrepresentation
• R2T4
• Satisfactory academic progress
• Gainful employment
59
FSA Conference
• December 3-6, 2013 at the Mandalay Bay
Hotel in Las Vegas, Nevada
• 45 sessions over the course of four days
• Upgraded Resource Center
• More robust Ask-a Fed
• COD, NSLDS, G5, FAFSA on the Web
stations and more
• Refer to September 30, 2013 EA with link
to Conference Web site
60
I would appreciate if you would take the time
to submit an evaluation of this presentation.
Please use this link. Thanks much! Greg
http://s.zoomerang.com/s/Gregory.Martin
61
Webinar Recording will be available on the
PASFAA website next week!