Did You Know…
The U.S. Department of Education (ED) requires a “wet” signature on the statement of educational purpose for students who are placed in verification tracking groups V4 and V5. The clarification requiring “wet” signatures was published in the Application and Verification Guide (AVG) of the Federal Student Aid Handbook beginning with the 2019/2020 award year and beyond.
ED released the Electronic Announcement (EA) that was published on April 3, 2020 “UPDATED Guidance for interruptions of study related to Coronavirus (COVID-19)”. On that EA, ED announced that for:
“borrowers in verification groups V4 or V5, … We suspend the in-person submission and notary requirements for V4 and V5 verification. The institution may allow an applicant or student to submit copies of the required verification documents electronically to the institution. This may occur by uploading a photo of the documents (including from a smartphone), PDF, or other similar electronic document through a secure school portal, by email, etc.”
FAME submitted questions to ED requesting further clarification as it relates to the “wet” signature requirement for the statement of educational purpose for tracking groups V4 and V5. The response received from ED was:
“In lieu of a wet signature on the Statement of Educational Purpose (SOEP) for applicants selected in V4 or V5, an institution may accept an electronic signature that meets the E-Sign requirements only during the COVID-19 emergency.”
While electronic signatures may be collected for verification document purposes, it is important to understand that the process for obtaining the electronic signature must include “assurances that the person providing the electronic signature is the person whose signature is being collected. Often, this is accomplished through a PIN or password process where the PIN or password has been assigned only after authentication of the identity of the person to whom the PIN or password is assigned.” [Guidance issued 06/21/2012 on the program integrity questions and answers – verification DOC-Q12 and DOC-A12]
As a reminder, it is recommended that schools maintain records of the date Coronavirus was declared a National Emergency through the end date of the Federally–declared emergency related to COVID-19, along with the effective dates of flexibilities afforded because of COVID-19.
If you have any questions regarding the aforementioned article, please contact our Client Solution Center.
Wet signatures have served us through the years but today we need solutions to be aligned with our digital world such as electronic signatures.