Actually, I've read all versions of the HEA (meaning, the original version and the subsequent amendments -- even as far as the info concerning reauthorization) and absolutely NOTHING in the HEA states that GWs can't be made.
It speaks more to reporting defaults (which, since I would assume that since over 270 days late would be considered a "default" so in that case, yes, lates to THAT extent must be reported). In fact, the majority of the passages dealing with reporting to the CRAs deal with mandating that defaults, once rehabbed, must be reported to the CRAs as being rehabbed and out of default status. Which all in all, seems to be more of a concession to the borrower than the lender/servicer/guarantor.
In fact, in re credit reporting, it also stipulates that SLs must be updated once a year, and does not specify that SLs must be updated every month -- which kind of supports (in MY mind) the supposition that a SL servicer/lender does not HAVE to report the lates (unless it becomes a default).
In fact, if we want to get nit-picky, there's more regulations against forgiving lates in the FCRA than in the HEA ... and we all know that banks/lenders are fairly prone to GWs in that area.
And nope, I didn't sleep through Contract Law ... of course, my class was at 9:30 am, so I was wide awake. I loved my Law classes -- but Psychology was just easier!
It speaks more to reporting defaults (which, since I would assume that since over 270 days late would be considered a "default" so in that case, yes, lates to THAT extent must be reported). In fact, the majority of the passages dealing with reporting to the CRAs deal with mandating that defaults, once rehabbed, must be reported to the CRAs as being rehabbed and out of default status. Which all in all, seems to be more of a concession to the borrower than the lender/servicer/guarantor.
In fact, in re credit reporting, it also stipulates that SLs must be updated once a year, and does not specify that SLs must be updated every month -- which kind of supports (in MY mind) the supposition that a SL servicer/lender does not HAVE to report the lates (unless it becomes a default).
In fact, if we want to get nit-picky, there's more regulations against forgiving lates in the FCRA than in the HEA ... and we all know that banks/lenders are fairly prone to GWs in that area.
And nope, I didn't sleep through Contract Law ... of course, my class was at 9:30 am, so I was wide awake. I loved my Law classes -- but Psychology was just easier!