Title IV

News & Analysis as of

PBGC Publishes Final Regulations on the Phase-In Period for Guarantee of Benefits for an Unpredictable Contingent Event

The Pension Benefit Guarantee Corporation (“PBGC”) recently published final regulations related to the phase-in period for its guarantee of benefits that are contingent upon the occurrence of an “unpredictable contingent...more

Senator Crapo raises concerns with Department of Education campus financial product rulemaking

Republican Senator Mike Crapo, Ranking Member of the Senate Committee on Banking, Housing, and Urban Affairs, sent a letter last week to Department of Education (ED) Secretary Arne Duncan to raise several concerns with the...more

Department of Education proposal on campus financial products expected in July

We recently commented that financial institutions offering financial products to college students, including debit or prepaid cards, under agreements with colleges should be planning now for the possible advent of new...more

DC Circuit Hears Petition Concerning Use Of Phone Call Captioning Technology For Persons With Hearing Impairments

This week, the D.C. Circuit Court of Appeals held oral argument concerning a petition for review of FCC rules regarding the use of phone call captioning technology designed for persons with hearing impairments. Petitioner...more

DOE rulemaking on student aid disbursement reported to be stalled

As we reported last month, the Department of Education (DOE), with active CFPB participation, is currently engaged in a negotiated rulemaking process that is considering, among other things, revisions to the DOE’s Title IV’s...more

The Assault on Sexual Assault Continues – On Both the Federal and State Levels

As reported last week, The White House Task Force To Protect Students From Sexual Assault issued its first report. Simultaneously, OCR issued Q&As on Title IX obligations and related documents to help guide institutions and...more

Congress Members Urge Department of Education to Amend Rules Governing Banking Practices on College Campuses

In a continued effort by federal and state legislators to curb alleged abuse by financial institutions on college campuses, several members of Congress sent a letter to the Department of Education expressing their support for...more

Higher Education Highlights - Winter 2014

In This Issue: - Guidance from the U.S. Department of Education on the Implications of Windsor for Title IV Programs - New law lets students “lawyer up” in student conduct hearings - Service Employee...more

Regulation A+: Proposed Amendments to Regulation A Efforts to Create a Viable Small Issues Exemption

In accordance with its mandate under Title IV of the Jumpstart Our Business Startups Act ("JOBS Act"), on December 18, 2013, the U.S. Securities and Exchange Commission (SEC) proposed new rules modifying Regulation A under...more

SEC Issues Rule Proposals to Amend Regulation A

On December 18, 2013, the U.S. Securities and Exchange Commission (“SEC”) issued rule proposals to amend Regulation A, implementing an important part of Title IV of the Jumpstart Our Business Startups Act of 2012 (the “JOBS...more

SEC Releases Proposed Rules for Regulation A+ under the JOBS Act: A Promising and Innovative Route to Capital Formation for Young...

The SEC has released long-awaited proposed rules to implement Title IV of the JOBS Act, now known as Regulation A+. This regulation could bridge a difficult gap for small companies looking to raise capital. If your company...more

SEC Releases Proposed Rules on Regulation A-Plus

In yet another effort to display Congress' commitment to the "democratization of access to capital," the Securities and Exchange Commission (the "SEC") has proposed rule amendments to Regulation A under the Securities Act of...more

JOBS Act Update: SEC Proposes New Rules to Update Regulation A Offerings

In mid-December, the Securities and Exchange Commission (SEC) voted to propose rules updating the framework to the existing Regulation A offering. The rules would implement new Section 3(b)(2) of the Securities Act of 1933,...more

SEC Proposes Rules to Facilitate Small Business Financing

Introduction - On December 18, 2013, the Securities and Exchange Commission (SEC) proposed rules to enhance access to capital by smaller companies pursuant to its rulemaking mandate under Title IV of the Jumpstart...more

The SEC Revamps Regulation A with Proposed Regulation A+

Introduction - The Securities & Exchange Commission (the “SEC”) proposed significant revisions to Regulation A on December 18, 2013, as mandated by Congress under Title IV of the Jumpstart Our Business Startups Act of...more

A Year End Look at the JOBS Act

2013 has proven to be a strong year for IPOs. According to a recent PWC study, total IPO volume for 2013, as of December 17, reached 237 public company debuts, which is an increase over 2012. The overwhelming majority of...more

Reg A+ Exemption

Today, the SEC released proposed rules to carry out the rulemaking mandate of Title IV of the JOBS Act. The proposed rules preserve and modernize the current framework of current Regulation A. The proposed rules would...more

Protecting The Rich Or The Poor: The SEC Division Of Enforcement

Should the SEC devote more resources to supervising the activities of hedge funds in which sophisticated investors invest, or should it devote more resources to investment advisor fraud, where the victims are less able to...more

First Circuit: Private Equity Fund May Be “Trade or Business” and Subject to Portfolio Company Pension Liabilities

The First Circuit Court of Appeals has recently held in Sun Capital Partners III, LP v. New England Teamsters & Trucking Industry Pension Fund, No. 12-2312 (July 24, 2013), a case of first impression at the Circuit Court...more

First Circuit Finds that a Private Equity Fund Can Be Liable for the Pension Obligations of its Portfolio Company

In Sun Capital Partners III, L.P. et al. v. New England Teamsters & Trucking Industry Pension Fund, No. 12-2312, 2013 WL 3814985 (1st Cir. July 24, 2013), the First Circuit held that a private equity fund could be liable for...more

PBGC Withdraws Two Territorial Coverage Opinion Letters Impacting Puerto Rican Plans

The status of PBGC coverage for Puerto Rico defined benefit plans is one that has been the subject of review and analysis by the PBGC for quite some time. Most recently, on April 19, 2013, the PBGC withdrew two older opinion...more

Deadline Approaches for Gainful Employment Disclosures

Institutions of higher education that receive Title IV funding must properly disclose certain information concerning course offerings that are or may be considered gainful employment programs by the U.S. Department of...more

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