FAFSA Comment Code Guide

Have Comment code on your FASFA? Find general information and instructions for resolutions of comment codes below.


What is a FAFSA comment code?

A comment code is generated by the Department of Education when a Free Application for Federal Student Aid (FAFSA) is submitted. These codes are meant to resolve discrepancies in information reported on your FAFSA. There may be additional steps for a student who has a comment code on their FAFSA. The University of Pennsylvania may request necessary documentation to resolve these discrepancies. This is a separate process from Federal verification.

How do I know if I have a Comment Code?

You will be notified on your Path@ Penn account via the “My Financial Aid “section. This information can also be found in your FAFSA Submission Summary.

How do I submit documentation for my comment code?

To submit documentation for a comment code, use the Secure Document Submission Portal here https://srfs.upenn.edu/DocumentSubmit.

What Documents are required?


A student must be a U.S. citizen, a citizen of the Freely Associated States, or an eligible noncitizen to be potentially eligible for federal student aid. The Department of Education matches all applications with the Social Security Administration (SSA) on U.S. citizenship status. If the status cannot be confirmed, the student must provide documents proving citizenship. Below is a list of documents that may fulfill the citizenship requirement.

Status Identity Eligibility

U.S. citizenship

Any government-issued photo ID, such as:

  • Driver's License

  • U.S. Passport

  • U.S. Passport (excluding temporary passports) 

  • U.S. passport card

  • Certificate of Citizenship

  • Certificate of Naturalization

U.S. permanent resident

Any government-issued photoID, such as:

  • Driver's License

  • U.S. Passport

  • I-94 Arrival-Departure Record that states your status and is currently valid.

  • Machine Readable Immigrant Visa (MRIV)

  • Alien Resident Card

Visa holder

Any government-issued photo ID, such as:

  • Driver's license

  • U.S. passport

  • Arrival-Departure Record (I-94) from the Department of Homeland Security showing any one of the following designations: “Refugee,” “Asylum Granted,” “Parolee T-Visa holder (T-1, T-2, T-3, etc.) or “Cuban-Haitian Entrant.

  • Certification letter from U.S. Dept. of Health and Human Services showing a designation of victim of human trafficking.

Students can submit citizenship documentation one of two ways. The first option is to submit in person in our student service center.  You can find our student service center location and hours here: https://srfs.upenn.edu/contact.

For students unable to come in to the Student Service Center Office in person, citizenship documents must be submitted with a notarized affidavit. This affidavit can be found here https://srfs.upenn.edu/financial-aid/forms under the Citizenship Confirmation Affidavit section. Please make sure to choose the correct corresponding aid year before completing and submitting the form. Students must submit the Citizenship Confirmation Affidavit form along with U.S Citizenship or Eligible Non-citizenship.

Unusual Enrollment 

An Unusual Enrollment History flag occurs when a student receives federal aid funding from multiple institutions. The Department of Education will review federal aid disbursement information for the past four award years for all FAFSA filers. The University may request academic transcripts from all Universities attended in the past four years. Your student portal will reflect if you must submit academic transcripts.

National Student Loan Database Systems (NSLDS) Related Comment Codes

Over Aggregate Limit

You may have exceeded your annual or aggregate Federal Direct Loan borrowing limit and may be ineligible for additional federal funding. Your financial aid award cannot be processed until the review is complete. Penn' s Student Financial Aid is working to resolve the issue and will contact you if further documentation is required and or when the review is complete.


For a loan made under the William D. Ford Federal Direct Loan Program or the Federal Family Education Loan Program, you're considered to be in default if you don't make your scheduled student loan payments for at least 270 days. On April 6, 2022, the U.S. Department of Education (ED) announced an initiative—called “Fresh Start”—to help eligible borrowers in default. Fresh Start will continue through at least September 2024. Please contact UPenn’s Student Financial Aid office or visit https://studentaid.gov/announcements-events/default-fresh-start for more information.


The National Student Loan Data System (NSLDS) database indicates that you have one or more student loans in an active bankruptcy status. Before you can receive additional federal student loans, you must provide proof that your bankruptcy has been discharged.

Total and Permanent Disability

The National Student Loan Data System (NSLDS) indicates that one or more of your federal student loans have been discharged. You must reaffirm your student loan debt and provide a letter from your physician confirming you can take on gainful employment.

If you do not see the comment code listed on your FAFSA named here, please use the following resources to determine what if any action is needed on your part.