COD 2026-27 Annual Update · Schema 5.0d · Export Logic Reference · Last updated: 2026-02-18 · Product Manager: Tirath Chhatriwala

InstitutionalLimitApplied Export Logic

Direct Loan Disbursements · Regulatory COD (Web & Legacy) and Automated COD · Award Year 2026-27 and Forward
Section 1 — Export Decision Flow
Key Design Note: The award form field is read-only — inherited from program version configuration (Config → Financial Aid → Program Version → Institutional Loan Limit). The user cannot change the value on the award form. The tag is exported only when the value is True. The tag is never exported when the value is False or blank. No exceptions. No blocking. No COD validation.
Step Decision Point Logic / Check Outcome
Step 1 Award Year Check Is this a 2026-27 or later record for a Direct Loan? Applies to all Direct Loan types: Direct Subsidized, Direct Unsubsidized, Direct Graduate PLUS, Direct Parent PLUS. NoSkip Tag  <InstitutionalLimitApplied> does not apply. Export normally. Done.

Yes → Continue to Step 2.
Step 2 Award Form Check Is InstitutionalLimitApplied = True on the Direct Loan award form?

Applies to all record types: originations, origination changes, and disbursements. Read-only field — inherited from Config → Financial Aid → Program Version → Institutional Loan Limit for this award year and fund source.
Yes — TrueInclude Tag Continue to Step 3.

No — False or blankSkip Tag Do not include tag. Export normally. Done.
Step 3 Include Tag Include <InstitutionalLimitApplied>true</InstitutionalLimitApplied> at disbursement level per Schema 5.0d.

Applies to: originations, origination changes, and disbursement Seq 1. Export disbursement record. No exception. No blocking.
Export Record exported with tag included. COD collects this for FSA analytics only — no enforcement, no audit. Sending on each export will not cause rejects.

Continue to Step 5 (Persist).
Step 4 Adjustments For disbursement sequence 2 and higher (adjustments): do not re-read the award form. Disbursement Seq 1 must exist before adjustments occur.

Use <InstitutionalLimitApplied> value from the most recent accepted disbursement sequence.
Stored = TrueInclude Tag Include tag with stored value. Export record.

Stored = False / blankSkip Tag Do not include tag. Export normally.

No exception under any scenario. No re-query of program version config.
Step 5 Persist Exported Value After export, persist the exported ILA value to the applicable reporting surface. (Column/note pre-created by a prior PBI. This step populates it.) Regulatory COD: Populate Institutional Limit Applied column in Process Results grid (Batch ID → bottom grid). Display True when exported, blank when not exported.

Automated COD: Persist ILA value in Job History note for the export job.
Section 2 — Scenario Matrix
Scenario Award Year Adjustment? ILA on Award Form Tag Exported? Exception? Process Results
1 — Prior award year 2025-26 or prior N/A Any No None Blank
2a — 2026-27, ILA = False 2026-27+ No False / blank No None Blank
2b — 2026-27, ILA = True 2026-27+ No True Yes — True None True
3 — Adjustment (ILA was True at Seq 1) 2026-27+ Yes N/A — use stored Stored → True None True
4 — Adjustment (ILA was False at Seq 1) 2026-27+ Yes N/A — use stored Stored → No None Blank
5 — Program transfer between disbursements 2026-27+ Yes N/A — use stored Per stored value None Per stored value
Program Transfer Note: If a student transfers from Program A (ILA = True) to Program B (ILA = False) between disbursements, adjustments use the ILA value from the most recent accepted disbursement sequence. The system does not retroactively reconcile program changes for paid disbursements.
Section 3 — Key Rules Reference

Export Trigger

  • Only export when ILA = True on the Direct Loan award form
  • Do NOT export the tag when ILA = False or blank
  • Award form field is read-only — user cannot change it
  • Value inherited from program version config (award year + fund source)
  • Can be sent on each export — will not cause COD rejects

Applicable Record Types

  • Originations (DRI = false) — include tag when ILA = True
  • Origination changes — include tag when ILA = True
  • Disbursement releases, DRI = true Seq 1 — include tag when ILA = True
  • Adjustments (disbursement sequence 2 and higher) — use stored value from most recent accepted disbursement sequence; do not re-read award form
  • Applies wherever a DL disbursement block appears in the export file

Fund Sources in Scope

  • Direct Subsidized Loan
  • Direct Unsubsidized Loan
  • Direct Graduate PLUS Loan (not excluded — confirmed ED email Thread 4)
  • Direct Parent PLUS Loan
  • All four Direct Loan fund sources — no exclusions

No Exception Logic

  • No exceptions, no blocking, no validation for this tag
  • COD does not enforce — FSA data collection only
  • No Warning Edits or Reject Edits generated for this tag
  • No dollar amounts — config is Yes/No only
  • If ILA = False: tag is simply omitted. Export proceeds normally.

Award Year Boundary

  • 2026-27 and forward only
  • Do not export for 2025-26 or prior award years
  • Schema 5.0d only — not applicable in 5.0c
  • Reject Edit 996 if tag sent for prior award years
  • Automated COD multi-award-year files: apply tag only to 2026-27+ records

Reporting Surfaces

  • Regulatory COD: Persist exported value to Institutional Limit Applied column in Process Results grid (Batch ID → bottom grid)
  • Show True when exported; blank when tag not exported
  • Automated COD: Persist exported value to Job History note for the export job
  • Column and note pre-created by prior PBI — this PBI populates the data only
PBI Reference
PBI System Description
2693042 Student Core Institutional Loan Limit config at Program Version; read-only display on DL award form
2692794 Regulatory COD — Web & Legacy Export <InstitutionalLimitApplied> for Direct Loan + Process Results persistence
2692945 Automated COD Export <InstitutionalLimitApplied> for Direct Loan + Job History persistence