All posts by Cooley

All Institutions Face New Risks Under ED’s Final Borrower Defense Rule

Jonathon Glass, Mike Goldstein and Kate Lee Carey

BDTR is likely to be one of the final major regulatory initiatives under the Obama administration, and one that will be in pre-effective date status on January 20th when Donald Trump becomes President.

What Independent Colleges Need to Know About the Forthcoming BDTR Rules

Kate Lee Carey, Jonathon Glass and Naomi Harralson May

Before the end of this month, the U.S. Department of Education (ED) is expected to issue a new set of regulations to provide students and former students with expanded rights to avoid having to repay their federal loans based on certain acts or omissions of the institutions they attended.

Department of Education to Distribute Earnings Data for GE Programs

Kate Lee Carey, Jonathon Glass and Nancy Anderson

Institutions with gainful employment (GE) programs will receive the first set of earnings data for those programs’ graduates in the coming days according to a new announcement from the Department of Education. This is a prelude to the first set of draft GE rates, which ED intends to distribute later in October.

ED Senior Department Official Terminates Federal Recognition of ACICS

Jay Vaughan and Naomi Harralson May

On September 22, the Senior Department Official (SDO) for the US Department of Education (ED) released a letter announcing the decision to terminate the recognition of the Accrediting Council for Independent Colleges and Schools (ACICS) as a gatekeeper for student financial aid programs authorized by Title IV of the Higher Education Act of 1965, as amended (Title IV programs).

ED Seeks Further Compliance with Third-Party Servicer Rules

Greg Ferenbach

On August 18, 2016, the US Department of Education (ED or the Department) issued a Dear Colleague Letter (DCL) providing additional guidance on issues related to the requirements for third parties that provide financial aid services (Servicers).

CA BPPE Issues Final Regulations on Data Reporting and Disclosure

Kate Lee Carey, Greg Ferenbach, Nancy Anderson, Matt Johnson, Paul Thompson and Jeannie Yockey-Fine

After several rounds of public comment and revisions, the Bureau for Private Postsecondary Education (BPPE or Bureau) has issued final regulations significantly expanding the data reporting and disclosure requirements with respect to an institution’s Annual Report, Performance Fact Sheets, and website.

Seven Steps to Prepare for the New Gainful Employment Rule

Jonathon Glass and Kate Lee Carey

The Gainful Employment Rules became effective on July 1, 2015, and you probably already know that your institution has a deadline to report six years’ worth of institutional, student and financial data to the Department of Education (ED) by July 31.

ED’s Proposed Rules for Online Learning Present New Compliance Challenges

Greg Ferenbach, Nancy Anderson, Matt Johnson and Paul Thompson

On Monday, July 25, the US Department of Education (ED or the Department) formally released a Notice of Proposed Rulemaking (NPRM) to amend its current state authorization regulations, particularly with respect to distance education programs.