News & Analysis as of

Recruitment Policies Title IV

Husch Blackwell LLP

Update: U.S. Department of Education Third-Party Servicer Guidance

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UPDATE: On February 28, 2023, the Department updated the Dear Colleague Letter issued February 15, 2023 to establish a future effective date for the guidance, extend the public comment period, and extend the reporting...more

Husch Blackwell LLP

Department of Education Expands Interpretation of "Third-Party Servicer" Definition (and Announces Incentive Compensation Review)

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Wednesday’s U.S. Department of Education Dear Colleague Letter announces an expanded Department interpretation of the definition of Third-Party Servicer to include a new array of vendors providing student recruiting and...more

Ballard Spahr LLP

Student Loan Advocacy Group Pushes Department of Education to Increase Oversight of For-Profit Colleges and Contractors

Ballard Spahr LLP on

The Student Borrower Protection Center (SBPC)—an organization established by former CFPB Student Loan Ombudsman Seth Frotman—recently published an article examining the Department of Education’s oversight of “lead...more

Cooley LLP

Blog: ED’s New Audit Guide Mandates Greater Scrutiny of Compensation Practices under the “Incentive Compensation” Rule

Cooley LLP on

As discussed in last week’s post, Title IV compliance audits for entities’ fiscal years ending June 30, 2017 and later must be completed using the revised Audit Guide recently issued by the US Department of Education’s Office...more

Hogan Lovells

Regional Accrediting Agency Proposes Ban on Paying Recruiters of International Students

Hogan Lovells on

On March 27, the Middle States Commission on Higher Education (“Middle States”) released for public comment a draft policy on its expectations for honesty and truthfulness in published information and in student recruitment...more

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