Scott Z. Goldschmidt and Kyle B. Venit
September 30, 2026
The U.S. Department of Education’s (“ED”) September 10, 2026 Dear Colleague Letter (ANN-26-23), announced the planned move of Borrower Defense to Repayment (“BDR”) case management into FSA Partner Connect and announced webinars held on September 23 and 24, 2026 to provide an overview of the new processes and features.
If you missed those sessions, this post distills ED’s guidance—including access permissions, notification contacts, response deadlines, and evidence-submission requirements—ahead of the expected October 2026 rollout. This post will not unpack the full complexity of the BDR frameworks, but institutions responding to BDR claims, now or in the future, may wish to review our Suggested Protocols for Responding to Individual Borrower Defense to Repayment Claims or past webinars explaining the rule, including: ED’s Proposed Borrower Defense to Repayment Rule: A Detailed Examination.
Borrower Defense Moves to FSA Partner Connect
Currently, the Common Origination and Disbursement (COD) system is used to provide school notifications and processing for BDR claims. Starting in October 2026, that process will move to FSA Partner Connect.