Financial Aid Compliance Calendar Washington and Lee University Annual Calendar of Significant Reporting Compliance Activities

Financial Aid

Higher Education Act Disclosure of Foreign Gifts/Contracts1

Yellow Ribbon Participation Renewal2

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Higher Education Act Disclosure of Foreign Gifts/Contracts1

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  • HEOA Code of Conduct and Other Notices3
  • FISAP: Fiscal Operations Report and Application to Participate4
  • NCAA Financial Aid Report5

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1Higher Education Act of 1965 and Higher Education Amendments of 1998
(Disclosure Requirements on Foreign Source Interests)
By January and July 31 of each year, a postsecondary institution must file a disclosure report about ownership or control by, or contracts with or gifts from foreign sources. The institution must make the disclosure by January 31 for the prior year July 1 to December 31, and by July 31 for the immediately preceding January 1 to June 30 period.

Gifts and contracts of $250,000 or more (individual or in combination with other gifts from and/or contracts with the same foreign source) received or contracted within a calendar year must be reported to the Department of Education. This report must also be made available to the public during regular business hours (20 U.S.C. §1011f(e)). This disclosure report should contain the dollar amount of gifts received from and/or contracts entered into with a foreign source other than a foreign government, the amount of gifts received from or contracts entered into with a foreign government, and if the U.S. institution is owned or controlled by a foreign source, the identity of the foreign source, the date the foreign source gained ownership or control, and institutional program or structural changes that took place as a result of the change in ownership or control.

If a restricted or conditional gift and/or contract is received by an institution, the following must also be disclosed: 1) the amount, date, and description of the conditions and restrictions for gifts received from and/or contracts entered into with a foreign source (other than a foreign government) as well as country of citizenship and country of incorporation; and 2) the amount, date, description of conditions and restrictions, name of foreign governments for gifts received from and/or contracts entered into with a foreign government.

A "foreign source" is defined as: 1) a foreign government, or agency of a foreign government; 2) a legal entity, governmental or otherwise, created solely under the laws of a foreign state or states; 3) an individual who is not a citizen or national of the United States or a trust territory or protectorate thereof; and/or 4) an agent, including a subsidiary or affiliate of a foreign legal entity, acting on behalf of a foreign source.

2Yellow Ribbon Participation Renewal
In order to participate in the GI-Bill Yellow Ribbon Program and receive matching funds from Veterans Administration, the institution must submit completed Yellow Ribbon Participation Agreements by February 15 of year for the following academic year. (NOTE: The deadline was extended to May in 2009, 2010, and 2011).

3Higher Education Opportunity Act of 2008
The institution must annually inform all of its employees who have responsibilities with respect to Federal education loans of the provisions of the institution’s Financial Aid Code of Conduct. This annual distribution should include a reminder that funds received from the Federal government under Title IV of the Higher Education Act, as amended, are not to be used to influence any branch of government.

4FISAP: Financial Operations Report and Application to Participate
The institution must report to the Department of Education all Perkins, FWS, and FSEOG funds from the previous fiscal year and apply for funds for the next fiscal year. The FISAP can be filed online at and must be submitted during the fall of each year (the 2009 deadline is October 1).

5NCAA Financial Aid Report
NCAA member institutions are required to submit an annual report that includes data regarding the financial aid packages awarded by the institution to freshmen and incoming transfer student-athletes and to other incoming students. The report is due in the fall; dates vary, but the deadline is September 14th for 2009.