PSLF & Digital Signatures: Denials

During the COVID-19 pandemic, there has been an increase in work from home setups where it becomes much easier and safer for HR to electronically sign Employment Certification Forms (ECF’s) for PSLF. Are digital signatures allowed for PSLF ECF’s?

Some borrowers have reported denials because the digital signature is not in the correct format. Specifically, FedLoan Servicing has issued the following denial:

“The signature of the authorized official at your employer is either missing from the form or you submitted the form with an electronic signature of the authorized official that is not an acceptable format. If the authorized official at your employer wishes to provide their signature electronically, please ensure they include an uploaded digital copy of their actual signature.

So it looks like FedLoan Servicing does accept some forms of electronic signatures, but not others. If the signature is an uploaded copy of the signature, this is allowed. If it’s just a font-created or standardized signature from some program like DocuSign, this is not allowed.

Although this is the policy from FedLoan Servicing, we have heard of denials where the signature is in the correct electronic form (uploaded signature)!

So then, if due to the pandemic, you are unable to get wet signatures (pen on paper, signed by hand, original), you can e-mail the ECF to HR, have HR print, sign, e-mail the scanned ECF back, and do the same: print, sign, scan, upload to FedLoan Servicing’s website (top bar on the right of FedLoan’s website has an upload button; see other post).

EDIT 02/17/21: The Department of Education has clarified their position on digital signatures:

A Quick Note About Signatures

While we understand and agree with your desire for electronic signatures, right now we can accept only these types of signatures:

  • A wet signature that was drawn in ink and sent to us in its original format;
  • A wet signature that was drawn in ink and then digitized (for example, drawing your signature and taking a photo of it and placing that photo in the signature block); and
  • A digital signature that was drawn with your hand using a pointing device (like a mouse or trackpad) or a finger (like on a smartphone).

We can’t accept signatures that are font-based, regardless of whether they are made to mimic a signature through the use of a cursive-style font; digital certificate-based signatures; and digital signature services that don’t require you to draw your signature with your hand or pointing device.”

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Posted in blog, COVID-19