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2nd Annual Conference on Technology & Standards2nd Annual Conference on Technology & Standards
NCHELP’s ESCA History of
Collaborating in Standards Setting
Brian Allison, USA FundsRobert King, Citibank Student Loans
Rhonda Allen, SunGard SCTGary Allen, Oracle/PeopleSoft
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In the Beginning…and then some
Once upon a time…not so long agoTurmoil…disorderAs many different ways of doing business as
there were entities– Forms– Data Structures– Business Rules– Loan delivery
The larger your market, the more difficult it was to keep pace with all the changes and differences
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In the Beginning…and then some
It was inconvenient, but no impetus for change Need community-wide impetus
– A paradigm shift– A change in the landscape
Force competitors to work together– Compromise their own interests– Work cooperatively for the common good
For student loans that impetus was Direct Lending – One entity, one way
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Electronic Standards Committee (ESC)
Hence was born what has become the Electronic Standards Committee
Standing Committee of the National Council of Higher Education Loan Programs (NCHELP)
Broad, representative membership – guarantors, lenders, servicers, secondary markets, schools, software vendors, etc.
Initial task was to develop origination processing standards – Meet the “one way” challenge
The effort began in 1994
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ESC and CommonLine
Developed and now maintains the CommonLine Origination Processing Standards– CommonLine 95, 96, 3.0– CommonLine 4.0 (data exchange basis for most
origination processing in the FFELP community)– Common Record: CommonLine (CRC)
Excellent success at broad implementation of CLR4 – Driven by regulation
Working on adoption of the Common Record: CommonLine XML-based standard
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CommonLineCommonLine standards address all data
exchanges among participants in the FFELP student loan and alternative loan origination processing– Data layouts– Business rules– Error processing
Until CRC the CL standards were internal and not coordinated externally
CRC was fully coordinated with the PESC Core Components and XML standards
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Electronic Standards Committee
Other Standards– Common Account Maintenance (CAM)
• In production among many trading partners (primarily between lenders, servicers, and guarantors)
• General Account Maintenance – Provides standard updates to information between partners
• Common Claim Initiative – Electronic pre-claim reporting, claim filing, and claim payment transmittals
– Imaged Document Transfer Standard• Still being documented
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Electronic Standards Committee
Bottom Line on Standards– Everyone agrees that they are important and valuable– Adoption of standards is driven by self-interest as well
as overall benefit to customers doing business with multiple providers
• How should providers compete– Data and transport protocols?
– Customer service and value added services?
• What is needed to compete effectively• What are the competing priorities
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Committee Structure – How it Works
The standing committee consists of about 50 voting organizations
Fully collaborative work effortsWork, discussion, proposals, votesESC does not make policy, but provides data
standards to facilitate the implementation of policy.
Strength of the committee is the work of its advisory teams
Teams are composed of committee members or other subject matter expert volunteers
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Committee Structure – How it Works
The Advisory Teams are– Origination Standards Advisory Team– Testing and Certification Advisory Team– General Account Maintenance Advisory Team– Default Aversion and Claims Advisory Team– Electronic Exchange Advisory Team– School Advisory Team– Training and Communications Advisory Team
Each team has diverse membership and two co-chairs (generally representing different types of organizations)
This is where the real detailed work is done
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Committee Structure – How it Works
Origination Standards Advisory Team– About 80 members– Develops and maintains all origination processing data
exchange standards– Creates and maintains implementation Guides– Covers all origination processing including changes
and disbursements– Resolves reported issues– Weekly conference calls to address issues and other
needs
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Committee Structure – How it Works
Testing and Certification Advisory Team– About 27 members– Develops and maintains standard test tools available to
all participants– Tools used to perform testing that will reflect the
intended results and interpretations of requirements– Available for CLR5 and for CRC– Sets certification rules for standards compliance
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Committee Structure – How it Works
General Account Maintenance Advisory Team-GAMAT– About 57 members– Develops and maintains the General Account Maintenance
Records in the CAM standard– Coordinates the standard with Program Operations and the
DACAT
Default Aversion and Claims Advisory Team-DACAT– About 53 members– Develops and maintains the Default Aversion and Common Claim
Initiative Records in the CAM standard– Developed the Image Document Transfer Record– Coordinates the standard with the DACS workgroup from the
Program Operations Committee
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Committee Structure – How it Works
School Advisory Team– About 35 members– Special advisory team made up of school
representatives– Used by other teams/committees to review ideas and
processing concepts– Brings forward school concerns to be addressed– Works with ED on various policy and practice
questions
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Committee Structure – How it Works
Electronic Exchange Advisory Team (EEAT)– About 30 listserv members– The most purely technical of the teams– Sets data exchange and encryption standards for the FFELP
industry – Has devoted much time and resource to support development of
the DTS
Communication and Training Advisory Team-CAT– About 12 members– Publishes a quarterly newsletter, CommoNews– Looks for agenda opportunities at industry conferences– Performs membership surveys– Maintains standards readiness tracking documents
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Committee Structure – How it Works
Quarterly three-day meetings– Days one and two are set aside for Advisory Team
meetings– Day three is the formal meeting of the ESC voting
members– The meetings are open to NCHELP members
ESC efforts are supplemented by ad hoc work groups– E-sign Standards Workgroup
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Committee Structure – How it Works
Committee co-chairs work across other NCHELP committees to make sure ESC efforts are coordinated at the levels these other committees address– Program Operations– Program Regulations– Debt Management– Legal Affairs– Member Education and Training
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Current Major Efforts
Finalize the Imaged Document Transfer Standard and submit it to PESC
Continue support for all currently published and in production standards
Continue support of movement to the CRC standard– Training– Issue resolution– Development and execution of a controlled beta test– Submit the standard to PESC
Support the development of the DTS
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PESC
FSANCHELP
ESC
Collaboration
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Software ProvidersCommonalityCamaraderieFocus on constituents and their customers
– Administrators– Students, parents– FSA, lenders, etc.
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Software Providers
Challenges– Data format standards– Staggered implementation– Adoption and ongoing support
Technology standards– Constantly emerging technology– Which standard will survive?– Adoption of a standard
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Software Providers
Changing business models– Traditional models
• School to guarantor• Servicer model (ASP)• Department of Education Student Aid Delivery System
– Regulatory and processing changes• Federal• CommonLine• Customer requests
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Software Providers
Define a visionDeliver on defined visionMonitor needs of the market
– Current clients– Prospective clients
Monitor trends in the industryUtilize resources to be the best stewards of
constituents investment dollars
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Software Providers
Scholarships Pell SEOG Perkins loans Work study
– Federal– Non-federal
FFELP loans* Direct loans Alternative loans*
Grants Fee waivers Emergency loans 3rd party contracts Other resources Reporting Communication Self-service products Imaging products, etc.
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Software Providers
XML is the endorsed industry standard of the World Wide Web Consortium
Real-time processingStreamlined processing for schoolsSimplified process for future enhancementsElimination of redundant dataEfficient utilization of resources industry-wideSupport CRC with these in mind
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Software Providers
Other projects underway as result of the Common Record initiative: – XML ISIR– Entrance/Exit counseling – Post-secondary transcript – K-12 transcript– Degree audit
– State grants/scholarships (wishful thinking!)
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Software Providers
Importance of PESC and standards– Streamlines product development timeline – Develops more cohesive, industry-wide business
approach – Develops culture for working together rather than
against each other
– Connects previously unrelated and disparate parties into common vision
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Lessons Learned
Voluntary standards require effective and open collaboration– Collaboration on a large scale requires much work
and coordination– Requires cooperation and a common sense of
purpose among many different constituents– A vision of the future potential...a need to be able to
see the forest in spite of the immediate trees is essential
– Collaboration requires some level of trust among collaborators
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Lessons Learned Continued
– All parties must be willing to compromise on behalf of the greater good
– Compromise must be balanced– Collaboration requires a commitment to the end
product in both its creation and individual company implementations
– There must be realistic expectations about implementation timing and urgency
– There will nearly always be some push back/questioning of voluntary standards. Meet it head on.
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Questions
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Contact Information
Brian Allison, USA Funds– [email protected]
Robert King, Citibank Student Loans– [email protected]
Rhonda Allen, SunGard SCT– [email protected]
Gary Allen, Oracle/PeopleSoft– [email protected]