Withdrawal and Return of Title IV Funds (R2T4) Policy for Undergraduate Students

Withdrawal and Return of Title IV Funds (R2T4) Policy for Undergraduate Students

We hope you don’t have to leave, but if you do, there may be adjustments to your financial aid. We encourage you to speak with a financial aid counselor  if you are planning to withdraw.


The Return of Title IV policy is to establish the processes for returning federal funds for students who completely withdraw from the institution and/or withdraw from all courses in a given period of enrollment. As defined by the U.S. Department of Education, these students must have a Return of Title IV Funds (R2T4) calculation performed to determine the percentage of aid earned based on the amount of time the student was enrolled at the Institution.

Federal Financial Aid (Title IV aid) is awarded under the assumption that a student will complete attendance for the entire period of enrollment for which aid was awarded. When a student withdraws from all courses, regardless of the reason, the student may no longer be eligible for the full amount of the federal financial aid originally offered. Instead, the student will only be eligible to keep the "earned" portion of the federal financial aid the student received for that term (semester).

Therefore, students who receive federal financial aid and who do not remain in attendance through the end of the term could be responsible for repaying a portion of the financial aid originally received. Federal regulations require a recalculation of financial aid eligibility if a student:

  • Completely withdraws from all classes;
  • Stops attending before the term's end;
  • Does not complete all parts of term (modules) in which the student is enrolled as of the start date of the period of enrollment;
  • Fails to earn a passing grade in any class

Note: UD's institutional tuition refund policy is separate from the federal R2T4 regulations to return unearned aid. Even though a student may receive a tuition/fee refund from UD, unearned financial aid may still need to be returned to the U.S. Department of Education

R2T4 Exemptions

There are 3 exemptions enacted by the Dept of Education that exempt a student from going through the Return of Title IV calculation process. The September 2, 2020 final rule amended the R2T4 regulations at 34 CFR §668.22 in several areas.

A student is not considered to have withdrawn if the student:

• Completed Program of Study (applies to ALL Students)
A student who completes all the requirements for graduation from his program before completing the
scheduled days in the period is not considered to have withdrawn.

• Completed Half-Time Enrollment (applies to students in modules ONLY)
The student must successfully complete Title IV-eligible coursework equal to or greater than what the
school considers to be half-time enrollment.

• Completed Modules Spanning 49% of Countable Days (applies to students in modules ONLY)
A student is not considered to have withdrawn if the student successfully completes one module or a
combination of modules that includes 49% or more of the number of the countable days in the payment
period, excluding scheduled breaks of five or more consecutive days and all days between modules.

If a student meets any of the R2T4 exemptions, the student is considered a “completer “and is not considered
withdrawn for Title IV purposes.

Additionally, the rules amended the requirements for establishing the total number of days in the payment period (denominator) of the R2T4 calculation to only include the days in a module if the student attended the module or the student’s coursework in that module was used to determine the amount of the student’s eligibility for Title IV, HEA funds for the payment period or period of enrollment. Following these new rules, the University of Dallas uses an “R2T4 Freeze Date” (or RFD) to establish the number of days in the denominator of the R2T4 calculation based on the student’s enrollment on a specific date. The RFD was established at UD in Spring 2022, and will fall on the census date for each term (payment period, or fall, spring, or summer). 

This policy is subject to immediate revision based on any changes made to federal laws and regulations. If changes are made, the student will be held to the most current regulations.

The R2T4 Process

The University of Dallas' Responsibility as it relates to R2T4 processing:

  1. To provide each student with the information in this policy;
  2. To identify students affected by this policy and completing the Return of Title IV Funds (R2T4) calculation;
  3. To inform the student of the result of the R2T4 calculation and any balance owed to the UD as a result of a required return of funds;
  4. To return any unearned Title IV aid that is due to the Title IV programs and, if applicable, notifying the borrower's holder of federal loan funds of the student's withdrawal date;
  5. To notify student and/or PLUS loan borrower of eligibility for a Post‐Withdrawal Disbursement (PWD), if applicable.

Student's responsibilities as it relates to R2T4 processing:

  1. Becoming familiar with the R2T4 policy and how withdrawing from all courses affects eligibility for Title IV aid;
  2. Notifying the official UD representative of intent to withdrawal prior to ceasing enrollment;
  3. Resolving any outstanding balance owed to UD resulting from a required return of unearned Title IV aid;
  4. Resolving any repayment to the U.S. Department of Education as a result of an overpayment of Title IV grant funds.

Students who receive federal financial aid must remain in their registered classes to “earn” the aid they originally received. The amount of federal aid earned is based on a prorated formula. Students who withdraw, or do not complete all classes in which they were enrolled, may be required to return some of the aid originally awarded to the student. Institutions, in accordance with federal regulation 34 CFR 668.22, are required to determine the percentage of federal aid “earned” and return the “unearned” portion to the appropriate federal aid programs.

The following explains the formula used to determine the percentage of unearned aid to be returned to the federal government (the number of calendar days completed up to the withdrawal date divided by the total number of calendar days in the enrollment period):

the number of calendar days completed up to the withdrawal date

the total number of calendar days in the period of enrollment

= percent earned 


Note: Breaks of 5 days or more are not included in the count of total days in the period of enrollment (denominator).

This calculation must be performed within 30 days of the date the school determines that a student has completely withdrawn.

The institution must return the unearned funds within 45 days of the calculation.

When calculating the percentage the student completed in the period of enrollment, if a student attended more than 60% of the period of enrollment, the student is considered to have earned 100% of the Title IV funds the student was scheduled to receive during that period.

The institutional charges used in the calculation are the charges initially assessed the student’s account for the period of enrollment. Initial charges may only be adjusted by those changes the institution made prior to the student’s withdrawal. Examples include, but are not limited to:
• Tuition
• Mandatory fees
• Course fees
• Room and board (if contracted within the school)

The charges excluded from institutional charges for the period of enrollment include, but are not limited to:
• Parking permits
• Library fees
• Late payment fees
• Student refunds
• Payment Plan fee
• Emergency Book Loan fee
• Housing damage

For students that may be enrolled in multiple parts of terms, UD combines all courses to form a period of enrollment. The R2T4 is calculated based on the parts of terms within the enrollment period. A student is considered withdrawn if the student does not complete all of the days in the period of enrollment that the student was scheduled to complete.

For example, if a student is enrolled in a Fall I course and a Fall II course, the student’s period of enrollment is from the date Fall I started to the last date of Fall II. If the student completes Fall I and does not attend the Fall II course, the student will be considered a complete withdrawal. UD will track enrollment in each part of term to determine if the student began enrollment in all scheduled courses.

If a student withdraws from a course in a later part of term while still attending a current part of term, the student is not considered as withdrawn based on not attending the later part of term. However, a recalculation of aid based on the change in enrollment status may be required.

Students who provide written confirmation to the Office of Financial Aid  at the time of ceasing attendance in a part of term that they plan to attend another course later in the same payment period are not considered to have withdrawn from the term.

Note: Written confirmation of a later class is required; registration alone does not meet this requirement. If the student does not provide written confirmation of plans to return to school later in the same payment period or term, UD considers the student to have withdrawn and begins the R2T4 process. However, if the student does return to UD in the same term, even if they did not provide written confirmation of plans to do so, the student is not considered to have withdrawn and is eligible to receive the Title IV funds for which the student was eligible before ceasing attendance.

Students who do not begin attendance in their scheduled classes are not eligible for federal financial aid and all aid originally received must be returned. If the student does not pay the funds owed to UD, a financial hold is placed on the student's account by Student Account Services which means he/she will not be permitted to register for classes or receive transcripts until the amount owed to UD is paid in full.

  1. The student submits a completed Withdrawal Form to the Registrar's Office at UD. This is a paper version. Copies of the form also are sent to Deans, Financial Aid, Housing, the library, and Student Account Services.
  2. The Registrar will update Banner to reflect the type of withdrawal (prior to census, after census, administrative withdrawal, military, etc.) and will enter the date of the withdrawal.
  3. The Office of Financial Aid will complete an R2T4 calculation to determine the amount of federal financial aid the student earned.
  4. The Office of Financial Aid will return funds to the federal programs, in the order according to federal regulations, on the student’s behalf.
  5. The Office of Financial Aid will send an e-mail notification to the student’s primary e-mail address indicating the outcome of the R2T4 calculation including additional information regarding repayment, Satisfactory Academic Progress, and exit counseling, as applicable.
  6. The student is responsible for any and all charges resulting from an R2T4 calculation.

The University of Dallas is not required to take attendance. Therefore, if the student has not earned a passing grade in any class and, in conjunction with Registrar's Office, is unable to determine the last date of attendance, the Office Of Financial Aid will use the 50% point of the period of enrollment as the withdrawal date.

At the end of the main part of term (semester) and after grades are officially posted, a audit is run to identify those student’s whom did not earn a passing grade.  

For students who received one or more F grades, a determination must be made with the aid of Deans and professors to identify if the student earned the F grade, if the student stopped attending, or never attended.

• If at least one F grade is determined to have been earned, the Office of Financial Aid will not complete an R2T4 calculation because the faculty member confirmed the student attended until the last day of class to earn the F grade.

• If not one professor can validate that a student completed the course, sat for the final exam, or earned an F, the Office of Financial Aid will consider the student as an unofficial withdrawal because the student did not successfully complete at least one course in the period of enrollment. The 50% point will be utilized as the withdrawal date for these students.

• If it is determined that one or more F grades listed are for courses the student never attended, the Office of Financial Aid will recalculate the student’s financial aid prior to completing the R2T4 calculation. Likewise, if it cannot be determined that the student began a single course, 100% of aid will be returned since the student never began classes.

If a student stopped attending but completed more than 50% of the period of enrollment, the student may submit to the Office of Financial Aid, within 30 calendar days from the date the student was notified of the R2T4 calculation, dated documentation pertaining to an academically related activity to use as the withdrawal date. An academically related activity may include, but is not limited to, taking a test or exam, attending a class lecture; completing an academic assignment, paper, or project; or participating in an online discussion. Any academically related activity must be signed off by the instructor prior to submitting the documentation to the Office of Financial Aid in order to be accepted.
Documentation that is not acceptable as proof of participation include, but is not limited to, the student's self‐certification of attendance that is not supported by school documentation, living in campus housing, participating in the school's meal plan, participating in a club or extracurricular activity, or participating in academic counseling or advising.

UD must return Title IV funds to the financial aid programs from which the student received aid during the payment period or period of enrollment, in the following order, up to the net amount disbursed from each source:

1. Federal Direct Unsubsidized Loan *
2. Federal Direct Subsidized Loan *
3. Federal Direct PLUS Loan *
4. Federal Pell Grant *
5. Iraq and Afghanistan Service Grants
6. Federal Supplemental Educational Opportunity Grant (FSEOG) *
7.Teacher Education Assistance for College and Higher Education (TEACH) Grant

* Funds ungraduate students at the University of Dallas can receive.

The loan grace period begins on the withdrawal date from the school or when a student ceases to be enrolled at least half-time. If the student does not re-enroll as a half-time student within 6 months of withdrawal or less than half-time enrollment, the loan(s) enters repayment. The promissory note signed by the borrower outlines the repayment obligations. The student should contact his/her loan servicer to make repayment arrangements.

A post-withdrawal disbursement (PWD) may be required if the total amount of the Title IV aid earned as of the withdrawal date is more than the amount that was disbursed to the student (e.g. in the case where a student withdraws prior to the first disbursement date of the term).

To be eligible to receive a PWD, students must have a complete financial aid file (verification completed and all tracking requirements satisfied) and meet all eligibility requirements.

  • Grants from a PWD may be credited to the student’s school account without obtaining student permission. However, it may only be credited for tuition, fees, and housing and food (if the student contracts with the school) or disbursed directly to the student. UD must obtain the student’s authorization to credit a student’s school account for charges other than current charges.
  • The University must obtain confirmation from the student, or from a parent for a Direct Parent PLUS Loan, before making any disbursement of loan funds. Also, for a Direct Loan, the institution must have originated the loan prior to the withdrawal. All terms of repayment apply as outlined in the Master Promissory Note.

Students who owe the U.S. Department of Education for an overpayment of Title IV funds are not eligible for any additional federal financial aid until the overpayment is paid in full or payment arrangements have been made with the U.S. Department of Education.

Students who owe UD because of an R2T4 calculation will be placed on a financial hold by Student Account Services. Students will not be allowed to register for subsequent semesters or receive academic transcripts until the balance is paid in full, or until payment arrangements have been made with Student Account Services. In addition, at the time the R2T4 calculation is completed, if the student received Federal Direct Loans, the Office of Financial Aid will notify students of the federal Loan Exit Counseling requirements.

A withdrawal may affect a student’s completion rate. Please refer to UD's Satisfactory Academic Progress (SAP) policies for additional information.

  1. Withdrawal date of determination without notification: 30 days after the end of the term
  2. Return of unearned Title IV funds: No later than 45 days after the date UD determines the student withdrew
  3. Post-withdrawal disbursement for outstanding current allowable charges: No later than 180 days after the date UD determines the student withdrew
  4. Written notification to students to accept PWD for loans: Within 30 days of the school’s determination that the student withdrew
  5. Post-withdrawal disbursement to the student, from the date school determined student withdrew:
    • Loans - No later than 180 days, and
    • Grants - No later than 45 days


As long as a student is not receiving a refund of un-funded institutional aid (e.g. merit scholarships or UD need-based grants), UD will not adjust institutional aid. 

After the R2T4 is complete, and all tuition adjustments have been made, if the student has a credit balance remaining that consists of unfunded aid, further adjustments must be made.  

E.g. a student and family have paid $10,000 towards their balance. Upon withdrawal, after the R2T4 has been completed, a credit balance remains of $8,000, the student may have that refunded back to her.

Alternatively, if after the R2T4 has taken place, an $8,000 credit balance on a student account exists due to a Trustee Scholarship and $5,000 in payments from the family, then UD will adjust the award down to ensure the Trustee award (unfunded) is not paid to the student.

A student who withdraws before prior to census does not earn any percentage of the TEG award.  Withdrawal after census date earns 100% TEG.