This release is required to support packaging in regards to changes announced under the OBBBA modifications. These changes are focused on Loans and Pell grant processing. The loan modifications are primiarily effecting changes on the limits that students (or parents) can borrow, while the Pell changes place a new maximum SAI edit on Pell awards.
Note: Based on discussions with HETGroup and LSUS, professional students are not within the scope of the required modifications. As a result, all processing that would have affected professional students has been removed from this release.
The identified changes required by FINANCIER will be color coded as follows:
Type of change
Color coding
No change
Green background
Change required
Yellow background
Change identified, but not applicable to the scope of these mods.
Gray background
The loan modifications require new values for the Academic levels as the requirements for Sub, Unsub, Plus, and Grad PLUS have changed.
ACADEMIC LEVELS
FINANCIER previously was delivered with two values for Graduate students, available via the student interface in WWSTDNTD.WW-ST-AC-CLS. These values (included in the dictionary extract in this release) will need to be expanded as a result of the OBBBA changes:
Federal Value
FINANCIER value
Description
8
GN
Graduate Never Professional
9
GP
Graduate Was Professional
10
PN
Professional Never Graduate
11
PG
Professional Was Graduate
12
GC
Graduate Concurrent Enrollment
13
PC
Professional Concurrent Enrollment
Loan Modifications
ANNUAL LOAN LIMITS
Dependent undergraduate students (unless your parent is unable to obtain a Direct PLUS Loan due to adverse credit)
Year
Pre-OBBBA Limit
New Limit
First Year Total
$5,500 (not more than $3,500 can be subsidized)
No change
Second Year Total
$6,500 (not more than $4,500 can be subsidized)
No change
Third Year & Beyond (Total Each Year)
$7,500 (not more than $5,500 can be subsidized)
No change
Independent undergraduate students (and dependent students, if your parent is unable to obtain a Direct PLUS Loan due to adverse credit)
Year
Pre-OBBBA Limit
New Limit
First Year Total
$9,500 (not more than $3,500 can be subsidized)
No change
Second Year Total
$10,500 (not more than $4,500 can be subsidized)
No change
Third Year & Beyond (Total Each Year)
$12,500 (not more than $5,500 can be subsidized)
No change
Graduate students
Pre-OBBBA Limit
New Limit (for those ineligible for the interim exception)
Total Amount (Each Year) for unsubsidized loans
$20,500 (unsubsidized only)
No change
Total Amount (Each Year) for PLUS loans
Cost of attendance minus other aid received (Direct PLUS Loans for graduate or professional borrowers only)
Direct PLUS Loans for graduate borrowers are no longer available.
Professional students*
Pre-OBBBA Limit
New Limit (for those ineligible for the interim exception)
Total Amount (Each Year) for unsubsidized loans
$20,500 (unsubsidized only)
$50,000 (unsubsidized only)
Total Amount (Each Year) for PLUS loans
Cost of attendance minus other aid received (Direct PLUS Loans for graduate or professional borrowers only)
Direct PLUS Loans for professional borrowers are no longer available.
*Students who are enrolled in health profession programs and who previously were eligible for higher annual and aggregate limits can continue to receive loans at those higher limits while they remain eligible for the interim exception. However, once the student takes an action that causes them to lose eligibility for the exception, they’ll become subject to the new borrowing limits listed above.
PLUS loans for parents
Pre-OBBBA Limit
New Limit (for those ineligible for the interim exception)
Total Amount (Each Year) for PLUS loans
Cost of attendance minus other aid received
$20,000 on behalf of each student
AGGREGATE LOAN LIMITS
Dependent undergraduate students (unless your parent is unable to obtain a Direct PLUS Loan due to adverse credit)
Pre-OBBBA Limit
New Limit
Total Amount (includes all subsidized and unsubsidized loans received for undergraduate study)
$31,000 (not more than $23,000 can be subsidized)
No change
Independent undergraduate students (and dependent students, if your parent is unable to obtain a Direct PLUS Loan due to adverse credit)
Pre-OBBBA Limit
New Limit
Total Amount (includes all subsidized and unsubsidized loans received for undergraduate study)
$57,500 (not more than $23,000 can be subsidized)
No change
Graduate students
Pre-OBBBA Limit
New Limit (for those ineligible for the interim exception)
Total Amount (includes all subsidized and unsubsidized loans received for graduate study)
$138,500*
$100,000 (for borrowers who are not and have never been professional students)
*Pre-OBBBA limit includes loans received for undergraduate study.
Professional students*
Pre-OBBBA Limit
New Limit (for those ineligible for the interim exception)
Total Amount (includes all subsidized and unsubsidized loans received for graduate and/or professional study)
$138,500†
$200,000 minus any amount that was received as a graduate student
*Students who are enrolled in health profession programs and who previously were eligible for higher annual and aggregate limits can continue to receive loans at those higher limits while they remain eligible for the interim exception. However, once the student takes an action that causes them to lose eligibility for the exception, they’ll become subject to the new borrowing limits listed above.
†Pre-OBBBA limit includes loans received for undergraduate study.
PLUS loans for parents
Pre-OBBBA Limit
New Limit (for those ineligible for the interim exception)
Total Amount (Each Year)
No Limit
$65,000 on behalf of each student from all parents’ combined borrowing*
*For example, if Parent A borrows $50,000 on behalf of their first child and Parent B borrowers $15,000 for that same child, the total is $65,000 borrowed between both parents on behalf of that child. Those parents can’t take out any further loans on behalf of that child for that year, but they can take out up to $65,000 in loans on behalf of a second child (and so on for each of their children).
LIFETIME MAXIMUM LOAN LIMIT FOR STUDENT BORROWERS
Pre-OBBBA Limit
New Limit
Total Amount*
No Limit
$257,500
*Includes the following Direct and FFEL loan types: subsidized loans, unsubsidized loans, and PLUS loans for graduate or professional students (regardless of any amounts paid or discharged).
Pell Modifications
The OBBBA changes have placed a maximum SAI threshold of 14790. A student is ineligible for a Federal Pell Grant if their SAI is twice the maximum Pell Grant amount ($7395) or $14790
×
×
File change notes:
N/A
All file changes were delivered in the previous ISIR focused release, 2605-01.
Functional change notes:
Packaging
The packaging component of FINANCIER has been updated to support the OBBBA loan limit requirements. These modifications include revisions to annual, aggregate, and lifetime loan limit calculations and the implementation of additional conditional processing to accommodate the new exemption rules.
Effective with the 2026-2027 award year, the Packaging Detail Reports have also been enhanced to include two additional student information fields. New packaging reject reasons have been added to identify conditions resulting from the updated loan limit and exemption processing.
NS Lifetime Max: (NSLDS Lifetime Maximum Loan Total, WF-NS-LIFE-MAX-TOT)
New edits/error messages/reject reasons for non awarded funds
Lifetime max reached - when a student borrower (regardless of class level) exceeds the new Lifetime Maximum Loan limit
Grad Loan limit - Exceeded - when attempting to award Unsub loans and the student exceeds the new Lifetime Loan limit for non-undergrad (grad-only) loans
Grad Loan limit - Close or Equal - when attempting to award Unsub loans and the student is equal to or close to the new Lifetime Loan limit for non-undergrad (grad-only) loans
Max SAI Threshold - when a student's SAI exceeds that year's PELL SAI threshold, currently $14,790.
Note: As part of the OBBBA modifications, the guidance for graduate students states:
“Undergraduate subsidized and unsubsidized loans are not included in the calculation of the new graduate or professional aggregate loan limits. However, borrowers who qualify for an exception will continue to have their undergraduate subsidized and unsubsidized loans included in the calculation of the pre-OBBBA graduate/professional aggregate limit of $138,500.”
Implementing this requirement has proven challenging because the 2026-2027 ISIR does not contain TOTALS that distinguishes undergraduate loan totals from graduate loan totals. Our understanding is that this information will first become available in the 2027-2028 ISIR. As a result, FINANCIER has been modified to do our best to accommodate this limitation for the 2026-2027 award year.
Based on guidance from the U.S. Department of Education, FINANCIER now evaluates the NSLDS Graduate Combination Loan Limit Flag (position 4808) on the 2026-2027 ISIR. This field identifies graduate students who are either “Close to or equal to limit” (C) or have “Exceeded limit” (E). These flags DO evaluate against the total of true GRAD-ONLY loans.
For graduate students who do not qualify for the Loan Limit Exception, FINANCIER will reject packaging when either of these values is present in the ISIR. The resulting error will be reported on the detail line for the Unsubsidized fund and will appear on the Packaged Students and/or Not Packaged Students reports, as applicable.
Additionally: The new OBBBA requirements for aggregate limits on graduate students (see $100,000 limit in table above) is intended to be only used for graduate funds, NOT undergraduate. As the 2026-2027 ISIR does not contain data that distinguishes undergraduate loan totals from graduate loan totals, FINANCIER is only able to look at the NSLDS combined total, which includes both sub and unsub (for both undergrad and grad loans). While FINANCIER will not overaward a student, it is possible that a grad student may be under-awarded as the combined total may reflect previously awarded undergrad loans.
NSLDS Display screen
The student’s NSLDS Lifetime Maximum Loan Total has been added to the NSLDS screen. This value is displayed at the bottom of the screen in the Lifetime Max Agg Tot field.
Implementation Notes
To implement the release, complete the following steps:
Unload the SYSOBJH file in the attached zip file
into a temporary library.
SYSMAIN the new and updated modules from your temporary library into your development library.
The updated modules are:
