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.
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
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.
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.
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.
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.
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
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.
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.
ED’s New Audit Guide Mandates Greater Scrutiny of Compensation Practices under the “Incentive Compensation” Rule
The second post of our Audit Guide series focuses on the incentive compensation rule. The new Audit Guide requirements significantly expand the review required by auditors to assure compliance with the incentive compensation rule.
The new Audit Guide for Title IV compliance audits includes numerous, expanded requirements for accounting firms to use in conducting required annual audits. The Audit Guide applies to Title IV compliance audits for fiscal years ending June 30, 2017 or later for for-profit higher education institutions and for third-party servicers that administer any aspect of the Title IV programs on behalf of any postsecondary institutions.