COD 039 Rejects for Direct Loans Originated w/o Enrollment Status Effective Date

It has come to our attention that schools who originated 2026-27 loans before SFP supported the COD Enrollment Status Effective Date may have submitted initial origination records without that date. For those records, COD automatically returned LLE = N, which SFP receives as the ED LLE value and uses to package the student at the higher non-exception loan amounts.

Now that SFP can send the Enrollment Status Effective Date, COD’s validation identifies some of these students as LLE = Y and rejects the higher award amounts with Reject Code 039 before it returns an updated LLE result. SFP therefore continues to hold the prior ED value of LLE = N, while COD is validating the corrected origination as though the student is LLE = Y. This in turn creates a circular process where SFP needs the updated ED LLE value of Y to repackage the student at the applicable exception limits, but COD requires an accepted transaction at those