608 Record Retention (source: Audits of Federal Student Financial Aid Programs Handbook)

Except for audit or related questions (see below), the institution must keep records for a minimum three-year (formerly five-year; see Note below) period. The beginning of the three-year period, however, depends on the type of record involved, as indicated by the following:

Most records relating to the institution’s administration of the Campus-based and Pell programs must be kept for at least three years after the end of the award year for which these funds were awarded and disbursed.

The FISAP report, and any records supporting data in the report (including "income grid" information), must be kept for at least three years after the end of the award year in which the FISAP is submitted.

Perkins Loan repayment records, including those relating to cancellation and deferment, must be kept at least three years after the date on which the loan is repaid, canceled, or assigned to ED; furthermore, original promissory notes and repayment schedules must be kept in a locked fireproof container until the loans are satisfied or the originals are needed to enforce the loan obligation).

FFEL and FDL records relating to a student or parent borrower’s eligibility and participation must be kept for at least three years after the end of the award year in which the student last attended.

All other FFEL and FDL records relating to the institutions participation, including records of any other reports or forms, must be kept for at least three years after the end of the award year in which the records are submitted.

All records involved in any loan, claim, or expenditure questioned by a Title IV audit, program review, investigation, etc. must be retained until the later of (1) the resolution of that questioned item, or (2) the end of the normal retention period applicable to the record.

Note: The change in retention from a minimum of five years to a minimum of three years results from the Improving America’s Schools Act of 1994, which became effective on October 20, 1994, and which amended the General Education Provisions Act. Final regulations from ED to implement this amendment were published on November 27, 1996 (effective July 1, 1997).