Legacy/interim exception provision under OBB3

The Legacy (Interim Exception) Provision allows certain students who were already borrowing federal student loans before July 1, 2026, to temporarily continue borrowing under the previous federal loan rules established before the One Big Beautiful Bill Act (OBBBA).

If you qualify, the Office of Financial Aid and Scholarships will notify you by email.

Who qualifies for the Legacy/Interim Exception Provision?

You may qualify if both of the following are true:

You were enrolled as of June 30th, 2026

You were enrolled as of June 30th, 2026 in a degree-seeking program at the University of Nevada, Reno during either Spring 2026 or Summer 2026.

Students who withdrew from Spring 2026 and were not enrolled during Summer 2026 do not qualify.

You previously borrowed federal loans for the same program you were in

You previously borrowed federal loans for the same program you were in As of June 30th, 2026, either:

  • You borrowed a Federal Direct Loan for your current program of study or
  • Your parent borrowed a Parent PLUS Loan for your undergraduate program.

If both requirements are met, you may qualify for the Legacy Provision.

How long does Legacy status last?

Legacy status is temporary. You may be considered a legacy student for 0-3 academic years. The legacy provision will not exceed three (3) academic years.

Federal regulations limit the amount of time students may remain under the previous loan rules. The length of your Legacy eligibility is based on your Expected Time to Credential (ETTC), which is calculated using:

  • Transfer credit accepted toward your degree
  • Test credit accepted toward your degree
  • Accepted non-degree coursework (e.g., Dual Enrollment and Collegiate Academy)

Federal regulations define ETTC using the expected time for a full-time student to complete the program. This calculation does not change because a student attends part-time or takes longer than expected to graduate.

What loan benefits continue under Legacy?

Undergraduate students

Students who qualify may continue under the previous Parent PLUS Loan rules.

  • No annual or aggregate Parent PLUS loan limit (subject to Cost of Attendance)
  • New Parent PLUS lifetime limit of $65,000 does not apply until Legacy status ends
  • Not subject to the new $257,500 lifetime federal loan limit while Legacy status remains active

All loans borrowed before and during Legacy status will count toward the applicable lifetime limits once Legacy eligibility expires.

Graduate and professional students

Graduate students who qualify may continue receiving:

  • Direct Unsubsidized Loans up to $20,500 annually 
  • Direct Unsubsidized Loan aggregate limit of $138,500
  • Graduate PLUS Loans 
  • Exemption from the new $257,500 lifetime federal loan limit during Legacy eligibility

Once Legacy eligibility ends, all previously borrowed loans will count toward the new federal limits.

Medical professional students

 Eligible medical students may continue receiving:

  • Direct Unsubsidized Loans
  • Additional HEAL Program unsubsidized loan eligibility

Medical School Year Annual Limit

Current annual limits remain.

  • Med 1 - $40,500
  • Med 2 - $40,500
  • Med 3 -  $47,167
  • Med 4 - $42,722

Students may also continue borrowing Graduate PLUS Loans while eligible.

How is Expected Time to Credential calculated?

Federal regulations require schools to determine how much of your program you completed before July 1, 2026. The calculation includes the following:

  • Transfer credit accepted toward your degree
  • Test credit accepted toward your degree
  • Accepted non-degree coursework (e.g., Dual Enrollment and Collegiate Academy)
  • Previous semesters enrolled in your current degree program

FAQ about Legacy (Interim Exception) Provision

Learn how the One Big Beautiful Bill Act affects Legacy (Interim Exception) eligibility, including changes to your major, part-time enrollment and what happens when Legacy status ends.