# 2026-07827: Student Aid Data System Gets Privacy Act Refresh

2026-07827, Privacy Act of 1974; System of Records, is a Federal Register notice from Education Department published 2026-04-22, effective 2026-04-22; PRIA reads it as touching household money (as of 2026-06-08).

- Canonical: https://policyrisk.com/federal-register/2026-07827
- As of: 2026-06-08
- Plain-text twin of the page above; the HTML and this file carry the same facts.

## Facts
- Document number: 2026-07827
- Title: Privacy Act of 1974; System of Records
- Type: Notice
- Agencies: Education Department
- Citation: 91 FR 21472
- Published: 2026-04-22
- Effective: 2026-04-22
- Comments close: 2026-05-22
- Significant: no
- Touches household money: yes
- Regulation identifier numbers: none
- Last updated: 2026-06-08

## In one line

Student Aid Data System Gets Privacy Act Refresh

## Summary

The Department of Education updated its system that handles student financial aid info to keep things running smoothly and protect your data. This change affects students, schools, and the government, making sure eligibility and aid details are accurate and secure. You’ve got until May 22, 2026, to share your thoughts before the update goes live on April 22, 2026.

## Abstract

In accordance with the Privacy Act of 1974, as amended, the U.S. Department of Education (Department) publishes this notice of a modified system of records entitled "Common Origination and Disbursement (COD) System" (18-11-02). The information contained in this system is maintained for various purposes relating to aid applicants and recipients including determining their eligibility for Federal student financial assistance under the programs authorized by title IV of the Higher Education Act of 1965, as amended (HEA); institutions of higher education participating in and administering title IV, HEA programs; and the Department's oversight of title IV, HEA programs.

## Effects PRIA read

- Legacy Borrower Transitional Rule: mixed, medium. If you were enrolled in a program on June 30, 2026 and borrowed a Direct Loan for that program before July 1, 2026, you are treated as a “legacy” borrower and may remain eligible under pre-2026 rules for the lesser of a transitional period not to exceed three academic years or the difference betwee…
- Enforce New Aggregate Loan Limits: cost, medium. The Department will track and enforce revised aggregate loan limits, including tiered unsubsidized caps for graduate and professional students, an aggregate lifetime limit for Parent PLUS borrowers per dependent, and a non-PLUS lifetime maximum aggregate loan limit. These revised caps will be appli…
- Institutions Can Set Lower Annual Loan Limits: cost, low. The COD System will allow financial aid administrators at institutions to record and apply lower annual loan limits for students or parent borrowers so reduced limits are applied consistently across a specific program of study. That means your school can set a lower yearly borrowing cap and the sys…
- Online Credit Checks for PLUS Loans: cost, low. If you apply for a Federal Direct PLUS Loan, you (or an endorser) can initiate an online credit check through the electronic Direct PLUS Loan application; applicants with adverse credit may still qualify through a qualified endorser or a credit appeal. The COD System will record these credit check…
- PSLF Employer Records and Help Tool: benefit, medium. The system will maintain a qualifying-employer database and employer certification information (including authorizing official name, title, phone, email, and digital signature with time/date) so borrowers can use the PSLF Help Tool to find and select qualifying employers and submit PSLF certificati…

## Related documents

- [2026-17239](https://policyrisk.com/federal-register/2026-17239): Education Department General Administrative Regulations, 2026-08-24
- [2026-17001](https://policyrisk.com/federal-register/2026-17001): Accreditation, Innovation, and Modernization: The Secretary's Recognition of Accrediting Agencies: Institutional Eligibility Under the High…, 2026-08-20
- [2026-15019](https://policyrisk.com/federal-register/2026-15019): Rescinding Portions of the Department of Education Title VI Regulations To Align With the Statutory Text and Conform to Executive Order 142…, 2026-07-24
- [2026-13286](https://policyrisk.com/federal-register/2026-13286): Accountability in Higher Education and Access Through Demand- Driven Workforce Pell: Student Tuition and Transparency System (STATS) and Ea…, 2026-07-01
- [2026-10013](https://policyrisk.com/federal-register/2026-10013): Accountability in Higher Education and Access Through Demand-Driven Workforce Pell: Pell Grant Exclusion Relating to Other Grant Aid; and W…, 2026-05-19
- [2026-08556](https://policyrisk.com/federal-register/2026-08556): Reimagining and Improving Student Education-Federal Student Loan Program Final Regulations, 2026-05-01

## Sources
- [2026-07827 on federalregister.gov](https://www.federalregister.gov/documents/2026/04/22/2026-07827/privacy-act-of-1974-system-of-records)
- [2026-07827 as published (PDF)](https://www.govinfo.gov/content/pkg/FR-2026-04-22/pdf/2026-07827.pdf)

## Related
- [Previous: 2026-07826, Privacy Act of 1974; System of Records](https://policyrisk.com/federal-register/2026-07826)
- [Next: 2026-07828, Christmas Tree Promotion, Research, and Information Order; Continuance Referend…](https://policyrisk.com/federal-register/2026-07828)
- [All Federal Register documents](https://policyrisk.com/federal-register)

Source: PRIA, https://policyrisk.com/federal-register/2026-07827 (as of 2026-06-08).
