Even when schools do not officially rank, when GC & teachers submit the LOR he/she will check off what is the student’s percentile ranking for Academic Achievement (below average, average…top 10%, top 5%, top 1%). I would have a discussion with the GC on which box he/sh would be checking off for the student. I think the GC may have some leeway and it may not need to tie strictly to GPA. I had such a discussing with D2’s GC.