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Debit Cards and Campus Banking Products


ED Guidance

Nacubo Comments

  • NACUBO comments on RFI on disclosures for financial accounts (June 8, 2017)


NACUBO Resources




  • Department of Education's final cash management rules (October 30, 2015)
    • Major changes from the proposed to final rules
    • Provisions that apply to all institutions receiving Title IV funds
    • Summary of provisions for schools with Tier One arrangements (school uses a third-party servicer to process credit balance refunds; the servicer also offers a financial account), Tier Two arrangements (school has an agreement with a bank/financial institution where accounts are offered and directly marketed to students), and Tier Two, Lower Threshold arrangements.
    • Flowchart to assist in determining which type of arrangments schools have with banks and third-party servicers.
    • Matrix broadly explaining the requirements for T1, T2, and T2-L arrangements.
  • Department of Education's proposed cash management rules (May 18, 2015)
    • Summary of proposed rules
    • Flowchart for institutions to determine what type of arrangement they have with third parties and banks
    • NACUBO's concerns with the proposed rules (June 15, 2015)

Consumer Financial Protection Bureau

NACUBO Comments and Resources


Reports and communiqués

  • CFPB Issues Annual Report

CFPB issued its 2014 annual report that lists information submitted to the Bureau concerning agreements between credit card issuers and institutions of higher education or certain organizations affiliated with such institutions. The Credit Card Accountability, Responsibility and Disclosure Act ("CARD Act") requires CFPB to submit to Congress and to make it available to the public.

  • GAO Issues Report on College Debit Cards

The report (GAO-14-91)—College Debit Cards: Actions Needed to Address ATM Access, Student Choice, and Transparency—found that 852 institutions have an agreement to provide some type of college debit card to students.

  • Consumer Reports Issues Report

Consumer Reports issued a publication in late August titled Campus Banking Products: College Students Face Hurdles to Accessing Clear Information and Accounts that Meet Their Needs. Cost comparisons for 16 campus banking options are included.

  • CFPB Weighs In

On February 12, Rohit Chopra, CFPB's assistant director and student loan ombudsman, blogged about relationships between financial institutions and colleges and universities: What Sunshine for Student Financial Products Can Show Us.

  • CFPB Issues Letter to Big Ten

The CFPB sent letters to universities in the Big Ten Conference expressing concern over the failure of their banking partners to post copies of contracts on their websites. A subsequent CFPB blogpost, Alerting Colleges about Secret Banking Contracts, reiterated these complaints.

Rulemaking Negotiations Focus on Cash Management

NACUBO members on the negotiated rulemaking committee included Gloria Kobus, director of student accounts and receivables at Youngstown State University, Joan Piscitello, treasurer at Iowa State University, and Joe Weglarz, executive director of student financial services at Marist College.

Capitol Hill Weighs-In

  • Senate Banking Committee Holds Hearing Examining Campus Banking

A Senate Banking Committee hearing on July 31 included testimony from a U.S. PIRG representative based on the organization's 2012 report on campus debit cards which kicked off the controversy.

  • Legislators Write to ED

Associations representing banks and card providers succeeded in getting members of Congress to weigh in with the Department of Education: Letter 1, Letter 2, and Letter 3. Consumer groups did the same last spring.

  • Bills Would Prohibit Revenue Sharing Tied to Bank Accounts

Two of the most influential Democrats on education issues, Rep. George Miller (D-CA) and Sen. Tom Harkin (D-IA), introduced legislation to regulate agreements between colleges and universities and financial institutions that involve student bank accounts or debit cards.


NACUBO Comments and Resources

  • The 2013 NACUBO comment letter submitted to CFPB in response to the agency's request for information (RFI) on financial products marketed to students, including bank accounts and debit cards.

NACUBO In The News


Huffington Post

Negotiated Rulemaking

On November 20, ED published a request for nominations for negotiators to represent various stakeholders. The Program Integrity and Improvements team is scheduled to hold three three-day meetings in February, March, and April of 2014.


NACUBO Resources

  • NACUBO Survey of Campuses

Student Refunds and Personal Banking at Colleges and Universities (October 2012)
NACUBO conducted a survey about student debit card options on college and university campuses in July 2012 and learned that of the institutions responding, 26 percent reported that they contract with a third‐party vendor to process credit balance refunds; a third of those that do not are considering doing so in the future. Only 12 percent indicated that they have a relationship with a bank, which is not involved in the credit balance refund process, and which allows students to tie bank accounts to the institution's primary campus identification card. NACUBO's survey also found that many schools use a competitive bidding process, and are already making the effort to negotiate good terms for students, be it for processing refunds or arranging campus‐card affiliated personal banking choices.

  • NACUBO Guidance to Campuses

Safeguarding Student Finances: Guidance for Campuses Offering Student Debit Card Options
This is guidance we offered to campuses in December 2012, in response to the growth of campus-based banking options for students in recent years and to growing public interest in student debit card options.

U.S. Public Interest Research Group


Fox Business

Additional Resources


Anne Gross
Vice President, Regulatory Affairs

Bryan Dickson
Senior Policy Analyst

Liz Clark
Senior Director, Federal Affairs