The U.S. Department of Education (ED) has announced an important update regarding 2026–27 ISIRs that were reprocessed on May 25, 2026, and assigned Comment Code 352 along with an FPS C Flag.
Why Were These ISIRs Reprocessed?
ED generated new ISIR transactions to identify borrowers who may qualify for the pre-One Big Beautiful Bill Act (OBBBA) aggregate federal loan limits. The reprocessing added a new loan limit exception indicator (ISIR Field 585) for students with qualifying 2025–26 loan disbursement activity.
What Caused the Confusion?
The updated ISIRs included Comment Code 352 and an FPS C Flag. Because financial aid administrators typically associate an FPS C Flag with an eligibility issue requiring resolution before aid can be disbursed, many institutions interpreted the flag as a processing hold.
ED’s Guidance
Effectively immediately, institutions may disregard the FPS C Flag associated with Comment Code 352. Institutions should not delay awarding or disbursing aid based only on the presence of this FPS C Flag.
ED is taking steps to update its logic to no longer set an FPS C Flag for post-screening Reason Code 34/Comment Code 352. To eliminate further confusion, ED will begin reprocessing affected ISIRs on June 11, 2026, to remove the FPS C Flag while retaining Comment Code 352.
What Schools Should Do
Comment Code 352 will continue to serve as an informational alert that a borrower’s eligibility for pre-OBBBA loan limits may have changed. Schools should:
- Ignore the associated FPS C Flag.
- Review NSLDS to determine which loan limits the borrower may now qualify for.
- Use NSLDS to view the borrowers’ aggregate totals and any new warning and/or informational eligibility status icons (such as ‘exceeds,’ ‘close to,’ etc.). For guidance on loan limits, institutions should refer to Frequently Asked Questions published on the Knowledge Center.
SOURCE: (APP-26-07) Update on ISIR Reprocessing Related to Comment Code 352 and FPS C Flags