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Business and Policy Areas
Business and Policy Areas

Student Financial Services

FINAL DUE DATES FOR Title IV Cash Management Rules Are COMING

On October 30, 2015, the Department of Education published the final version of its Program Integrity and Improvement regulations, which include revisions to the agency's cash management rules.Most of the rules took effect in July 2016, but a few provisions had a longer lead time.

In early July, ED provided guidance, including suggested formats, to schools that offer Tier 1 or Tier 2 financial accounts to students on disclosing the fee schedules for such accounts--and delayed the effective date of the requirement until January 1, 2018.

In addition, institutions with Tier 1 arrangements or Tier 2 arrangements that meet certain thresholds must publicly provide additional data about their contracts including the mean and median of fees paid by students with the accounts annually by September 1, 2017. Schools must follow the formatting requirements laid out in ED's notice.

NACUBO has prepared a summary of the requirements for schools with Tier One arrangements (school uses a third-party servicer to process credit balance refunds; the servicer also offers a financial account) and Tier Two arrangements (school has an agreement with a bank/financial institution where accounts are offered and directly marketed to students).



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Anne Gross
Vice President, Regulatory Affairs