Return of Title IV (Federal) Funds: Withdrawing from classes or school may result in your owing money that needs to be returned to the appropriate financial aid sources.

Return of Title IV Funds

While the number of students who decide to withdraw from all classes during a term at CUNY Law is low, individual circumstances may lead you to consider this option. Reasons for withdrawal may include illness, a family emergency, or the need to take a break from school. It is important to consider a number of factors before making your decision about withdrawal.


This guideline offers information about the Return of Title IV Aid policies, which apply to students who withdraw from a course, are dismissed, or take a leave of absence from the CUNY Law within a term.

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 awarded. 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

If the calculation determines that you have not qualified for aid, which means you have received a zero percent, you are not eligible for assistance. It indicates a problem with your financial aid eligibility. If there have been any disbursements, you must return all disbursed aid except for any Direct Loan net payments.

The Federal Work-Study (FWS) funds received are not included in the Return of Title IV funds calculation. However, if you withdraw from school, your participation in the Federal Work-Study program will end on your withdrawal date. If you drop below six credits due to settling, starting, or discontinuing attendance, you must immediately stop working under the FWS program. You are responsible for informing your site supervisor of any class schedule or enrollment changes and updating the FWS staff at the Office of Financial Aid. If you have any further questions, please get in touch with the FWS staff at 718-340-4284 or email them at

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.

R2T4 Eligibility Criteria

R2T4 Eligibility Criteria Students are eligible for R2T4 consideration if they fulfill the following conditions:

  • The student withdrew from the term and received grades such as W, WA, WD, WU, WF, or any combination of these across all their courses.
  • The student either anticipated or received Title IV aid or has incurred institutional liability for tuition or allowable fees.

Reasons for Withdrawal and Corresponding Grades

W Student failed to attend class
WA Administrative Withdrawal: Non-punitive grade given to students whose immunization is unverified by the compliance date
WD Withdrew Drop: Student dropped courses after the financial aid certification date during the program adjustment period and they attended at least one class session
WU Unofficial Withdrawal: Student unofficially withdrew but attended at least one class session
WF Withdrew Failing: Student started while failing a class having attended at least one class session

Please note that situations involving “All Drops” or “All WNs” are not considered for R2T4 calculations. When combining WN grades with other withdrawal grades, the WN grades are disregarded, and the calculation is based on the remaining withdrawal grades.

To carry out a Return to Title IV (R2T4) Calculation, the student needs to meet the following requirements:

  • Have attended at least one of their courses.
  • Have been considered for financial aid packaging.
  • They have withdrawn from all of their classes.

Institutional Charges for R2T4 Calculation

Institutional charges for R2T4 calculation contain the educationally related expenses levied on the student for the entire payment period. The costs considered in the R2T4 calculation include:

  • Tuition
  • Room and board
  • Material fee
  • Student activity fee
  • Consolidated service fee
  • Technology fee
  • Change of Program Fee
  • Book voucher amount (excluding book advances)

The institutional charges used in the calculation correspond to the charges initially assessed on the student for the entire payment period or relevant enrollment period.

Official Withdrawals (W Grades)

When a student officially withdraws from the law school, the applicable date for calculating the withdrawal is determined based on when the school is informed. Typically, this is when the Registrar’s Office receives a signed withdrawal form from the student. The Registrar’s Office endorses the received date on the state to establish a clear record, which serves as the withdrawal date entered into the R2T4 system for all calculations. If the law school requires approval from another office before submitting the form to the Registrar’s Office, use the date sanctioned by that office instead. The law school must document the withdrawal process and explicitly state which withdrawal date determines the percentage and sum of earned aid.

Dropped Courses (Refund Period)

If a student drops a course within the first week of the term, it will not be counted toward their enrollment status verification. As a result, any financial aid disbursed to such students will be transmitted to the Department of Education (DOE). Students who officially withdraw during the second and third weeks of classes will receive a Withdrawal Drop (WD) designation. The enrollment status for Financial Aid will be determined at the end of the first week (after the 7th day of classes), which begins the verification process for student enrollment. For students who have WD grades for all their courses, their aid will be calculated based on the most recent withdrawal date.

Unofficial Withdrawals (WU Grades)

Suppose a student makes an unofficial withdrawal from the law school. In that case, the R2T4 calculation will follow the federal 50% rule for determining earned aid as long as the school can prove the student-initiated attendance. This attendance confirmation is crucial to determining a student’s eligibility for Federal financial aid. Faculty must confirm student-initiated attendance through the Verification of Enrollment (VOE) process, enabling students to access Federal financial aid. Suppose the VOE records show that a student has yet to initiate attendance. All support except Direct Loan disbursements issued to ineligible students must be returned (GEN-13-02). When the semester ends and a “WU” grade is recorded on the grade roster, the R2T4 process for the 50% calculation begins. Attendance is optional for the University. The notification of an unofficial withdrawal comes after the semester’s conclusion (usually two to three weeks after finals’ last day) upon grade submission.

As a result, the R2T4 process uses the 21st day after the completion of finals as the determination date, when faculty grades are typically submitted. The law school then has 45 days from this date to execute the R2T4 calculation, return funds, or disburse any post-withdrawal disbursements for grants, as well as 30 days to issue a post-withdrawal/overpayment notice to avoid delays. Loan disbursements made after withdrawal must be completed within 180 days of the determination date. The University assumes a 50% entitlement in such cases.

Combination of Withdrawal Grades

When official withdrawal grades (WD, W, WF, or WA) are combined with an unofficial withdrawal grade (WU), the “WU” grade or unofficial withdrawal takes precedence within the R2T4 calculation. Consequently, the regulations governing unofficial withdrawals come into effect. In such instances, upon the Registrar’s Office at the law school receiving notification of the “WU” grade (typically on the 21st day following the conclusion of finals), this date serves as the determination date for the R2T4 calculation. The law school must document the commencement of attendance to apply the 50% rule, enabling students to receive 50% of their Federal aid.

If the official withdrawal date falls between 50% and 60%, the R2T4 entitlement will be calculated using the actual percentage for that range, which benefits the students more. Similarly, any official withdrawal after the 60% point will make a student eligible to receive 100% of their Federal aid.

Never Attended Grades (WN Grades)

Students who do not initiate attendance in their registered courses (WN) are not eligible for Title IV funds. In these cases, the withdrawal date is automatically set as the day preceding the first day of classes. The funds deemed ineligible (all aid, excluding any Direct Loan disbursements directly issued to the student, as outlined in GEN-13-02) must be reimbursed within 30 days from the moment the institution becomes aware that the student will not or has not started attending.

Grade Changes

Any earned grades, including “F” grades, changed to total withdrawal grades (“W”) are not subject to the R2T4 regulations. Unofficial withdrawal grades (“WU”) converted to complete withdrawal grades (“W”) after an R2T4 calculation was made do not require the college to perform an R2T4 recalculation. The original calculation for “WU” grades utilizing the 50% rule for determining Federal aid earned does not change.
Incomplete (“INC”) grades changed to “F” grades following the guidance above.
It should be noted that in the case of canceled registration (no grades on an academic transcript), all aid is to be returned.

Reviewing every R2T4 calculation carefully and documenting all the dates used to ensure consistency is essential. The changes discussed aim to bring more uniformity to the R2T4 process and avoid problems caused by inconsistent dates.

Medical Withdrawals

If a student needs to withdraw from college due to medical reasons and the withdrawal is approved by a committee, an official last date of attendance must be determined. This date should be based on documentation provided by the student or school records that confirm the medical condition. This date will be considered the official withdrawal date for calculating necessary adjustments or refunds instead of the date of the withdrawal decision or when the Registrar’s Office received the request. Alternatively, the date of the accident or event that caused the medical condition, as indicated in the documentation, could also be considered.

Administrative Withdrawals (WA Grades)

Students who fail to fulfill mandatory immunization requirements may receive an Administrative Withdrawal (WA grade). Local students have 30 days to complete outstanding vaccine doses, while out-of-state students have 45 days. Students will be administratively withdrawn if they fail to meet these requirements.

Usually, students can resolve this issue by providing proof of completing the immunization process. However, the system treats WA withdrawal similarly to an official exit. The withdrawal date is set as the 31st day of the term (46th day for out-of-state students if manually adjusted). If the record remains incomplete 21 days from the determination date, the system will automatically finalize the document, potentially triggering R2T4 returns processing.

What Does Title IV Aid Encompass?

Title IV aid, delineated by the Higher Education Act of 1965, comprises the subsequent programs:

  1. Federal Unsubsidized Student Loan
  2. Federal Grad PLUS Loan

Instructions for returning funds are in this order:

  1. Direct Unsubsidized Loan
  2. Direct Grad PLUS Loan

Determining Accrued Financial Aid

Accrued aid is calculated by dividing the total number of days attended, including weekends, by the total number of days in the term, starting from the first day of classes and ending on the last day of finals.

If you withdraw after completing over 60% of the term, there will be no unearned funds. The Return of Title IV aid calculation only applies to students who withdraw before completing 60% of the period. Any withdrawals after this point will not affect your financial aid for the semester.

Determining Unused Financial Aid

Unused aid is defined by subtracting the earned percentage from 100 percent.

Disbursement After Withdrawal

If the amount of Title IV grants or loans earned before withdrawing is greater than the disbursed amount, it will be considered a post-withdrawal disbursement. The school must ask for your permission before paying if this involves loan funds. If you decline, we will give the funds to you. However, allowing the school to keep the funds could be beneficial in reducing any remaining debts owed to the institution.

Disbursement of Loan Funds Following Withdrawal

If you choose to withdraw, you can still receive loan funds after your withdrawal through a post-withdrawal disbursement. After your departure date is confirmed, you will receive a notification giving you the option to accept the total allocation or a portion within 30 days. If you respond within 14 days of receiving the information, the school will disburse the loan funds within 180 days of your withdrawal determination. These funds will pay off any charges still on your account for that semester, such as tuition and fees. If there is any money left over, it will be disbursed directly to you as the student (or to the parent, if applicable).

CUNY Law must calculate the Return of Title IV Funds within a 30-day timeframe and return the Title IV funds within 45 days. The comprehensive formula for ascertaining the earned portion of Title IV federal aid and the procedure for returning unearned shares to the federal programs is described in CFR 668.22.