The Department reiterates that any application that is rejected under this new identify confirmation process has a high risk of being fraudulent. Although a small number of legitimate students are likely to be flagged for in-person verification by institutions, the Department’s expectation is that FAAs will not need to take any action on the significant majority of rejected applications.
That said, in cases where a legitimate student is impacted, starting on May 3, 2026, schools will be able to assist applicants in resolving their application’s rejected status. To complete the process, FAAs must follow the guidelines for information to be verified and acceptable documentation for resolving identity verification (similar to the V4 Verification Tracking Group), as published in the Nov. 26, 2025 Federal Register notice.
If an FAA successfully confirms the identity of a student whose…
MANAGEMENT & CULTURE (THE “TONE AT THE TOP”)
Fraud thrives in “sloppy” environments where leadership ignores the rules.
- The Fraud Triangle: For fraud to occur, three elements must be present: Pressure (the need for money), Rationalization (thinking “I deserve this”), and Opportunity (weak controls). You can only control the Opportunity.
- Whistleblower Hotline: Provide an anonymous way for staff to report “odd behavior.” Most internal frauds are caught via tips, not audits.
- Background Checks: Conduct credit and criminal record checks for all employees in financial or data-sensitive roles.
- Annual Ethics Training: Make sure every staff member knows that the company has a Zero Tolerance policy toward “borrowing” from petty cash or fudging overtime.