Tag: Financial Aid
Just in Time for Halloween: The Return of the Borrower Defense Rule of 2016
Kate Lee Carey, Jonathon Glass, Mike Goldstein and Vince Sampson
The Borrower Defense to Repayment Rule is back, thanks to a September 17 federal court order that overturned Secretary DeVos’ action suspending implementation of the existing rule, followed by the October 16 final order denying CAPPS’ request for injunctive relief.
Borrower Defense to Repayment: The Saga Continues
Jonathon Glass and Kate Lee Carey
The Department of Education has published a new notice of proposed rulemaking for the BDTR law. Comments on the proposed new rule are due August 30.
Cooley Team at NASFAA 2018
Marjorie Arrington, Pat Dickerson and Rebecca Flake
The 2018 NASFAA National Conference is June 24-27 in Austin, TX. The annual NASFAA conference brings together 2,500+ student aid professionals from across the nation. Members of the Cooley team will be presenting throughout the conference.
Another Disclosure Requirement for California Higher Education Institutions Signals an Accelerating State Role in Student Disclosure
Kate Lee Carey and Mike Goldstein
Beginning with the 2018-19 academic year, all higher education institutions in California, except the California Community College system, will have to provide their students an annual summary of their total borrowing to pursue their education and an estimate of their future monthly payments.
Cooley Team at FSA Training Conference
Marjorie Arrington, Lisa Bureau, Pat Dickerson and Rebecca Flake
The 2017 FSA Training Conference is November 28-December 1, 2017 in Orlando, Florida. The FSA Conference is the largest training program in the US for school and institution financial aid professionals. Cooley team members will be attending the Conference.
Department of Education Pushes Back Effective Date of Borrower Defense Rule – Again
Mike Goldstein and Kate Lee Carey
The drama surrounding the US Department of Education’s Borrower Defense to Repayment Rule continues, with the date the rule would come into effect now delayed to July 1, 2019.
ED’s New Audit Guide – 90/10 Compliance
Jonathon Glass, Naomi Harralson May and Rebecca Flake
Financial statement audits prepared under the Department of Education’s new Audit Guide will involve more detailed 90/10 testing and note disclosures. Read more in the seventh post of our Audit Guide series.
New ED Audit Guide Updates Requirements Concerning Third-Party Servicers
Nancy Anderson and Rebecca Flake
The sixth post in our Audit Guide series focuses on the new requirements for third-party servicers. Institutions of all types that use any third-party servicers should become familiar with these new Audit Guide requirements.
Increased Student Samples, Student Confirmations and Site Visits Mean Expanded Audits Under ED’s New Audit Guide
Blain Butner and Rebecca Flake
In the fourth post of our Audit Guide series, we focus on three significant process expansions: the size and composition of the required student sample, the student confirmations auditors are required to perform and how site visits are conducted.
New ED Audit Guide Now Requires Extensive Gainful Employment Compliance Testing
Kate Lee Carey, Jonathon Glass and Joseph Mensah
Gainful Employment data reporting is the topic for the third post in our Audit Guide series. For the first time ED is requiring that independent audit firms conduct extensive testing relating to Gainful Employment data reporting and mandated disclosures as part of their annual Title IV compliance audits.
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