It’s not often that a financial aid professional can ignore an FPS C Flag without having to resolve it.
In preparation to alert schools if a borrower might be considered a Legacy borrower and not subject to the new changes under the Working Families Tax Cuts Act, the Department of Education has published an Electronic Announcement to clear up some confusion.
The new Institutional Student Information Records (ISIRs) generated by the Department on May 25 that set the initial loan limits exception flag, based on 2025-26 disbursement activity, included Comment Code 352, along with an FPS C Flag. Generally, a C Flag signals to the school that an eligibility issue must be resolved before they can award and disburse aid.
Based on feedback from the financial aid community, the Department is updating its logic to no longer set an FPS C Flag for post-screening Reason Code 34/Comment Code 352. According to the announcement, effective immediately schools may disregard the FPS C Flag associated with Comment Code 352 and not delay awarding or disbursing aid.
Starting June 11, the Department will begin reprocessing ISIRs to remove the FPS C Flag associated with Comment Code 352.
The FPS will continue to set Comment Code 352 to provide schools and students with information if eligibility for pre-OBBBA loan limits has potentially changed. Schools are encouraged to check NSLDS to verify for which new loan limits the borrower now qualifies. More guidance is included in the Frequently Asked Questions about loan limits published on the Knowledge Center.
Questions about a student’s transaction should be directed to the FSA Partner and School Relations Center at 1-800-848-0978 or via email at CODSupport@ed.gov.
