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But the younger is not allowed to make a gift in that manner, right?

And you're asserting they aren't allowed because...???

IMO it certainly seems a bit shady - possibly fraudulant about whose money is whose w.r.t. statements made on the FAFSA.
But assuming they are really gifts, and the youngest could do anything he wanted with the money, I don't think there's any reason he couldn't pay part of older sibling's college bill...

JMO - but if it's possible, I'd go with giving the money to the grandparents and they can even pay the college directly (so no gift tax implications for them)
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