[author: John L. Culhane, Jr.]
A final model “financial aid shopping sheet,” the result of a collaborative effort by the CFPB and the Department of Education, has recently been issued by the DOE. The shopping sheet is intended to serve as a uniform financial aid disclosure form.
Following the CFPB’s release of feedback it received on a draft of the shopping sheet, the task of finalizing the shopping sheet fell to the DOE (which under the Higher Education Opportunity Act, was required to submit recommendations for a model financial aid offer form by August 14, 2009—a year after the law was enacted.)
The final form has some significant differences from the draft published by the CFPB. Most notably, it does not include any information on a student’s total debt after graduation. In its report on the feedback it received on the draft, the CFPB stated that the two top features thought to be most important by commenters were the student’s estimated debt at graduation and estimated monthly payment after graduation. Neither of those features are in the final form, which only provides cost and financing information for a single school year.
Consistent with the feedback from commenters, the final form does not include “work study” in the loans section (as the draft did). However, contrary to the requests of commenters, the final form does not contain additional information about default rates and repayment options.
Under an Executive Order issued by President Obama in April, institutions that accept federal military and veterans educational benefits are required to provide the shopping sheet to military students. Otherwise, use of the form is not mandatory (the DOE considers it a “best practice”) but institutions will likely feel pressure to use it.
If fact, in his prepared remarks on the final shopping sheet, CFPB Director Richard Cordray stated that the CFPB “fully expect[s]” that “all universities and higher education institutions” will use the shopping sheet. To that end, DOE Secretary Arne Duncan has sent a letter to college and university presidents urging them to use the shopping sheet as part of their financial aid awards starting in the 2013-14 school year. Also, according to Director Cordray, ”universities representing more than a million students” have already committed to using the form.