NACUBO Comment Letters

NACUBO provides comments in response to regulatory developments or notices of proposed rulemaking issued by federal agencies. (NACUBO position letters on legislative issues may be found in the Legislation section.) NACUBO staff rely heavily on comments, advice, and concerns from members in developing the association's position on agency proposals. Members are always encouraged to review proposed rules and contact appropriate staff members in the Advocacy and Issue Analysis (AIA) department to share their concerns.

December 21, 2012
NACUBO signs on to ACE's comments on Health Insurance Market Rules; Rate Review Relating to Student Health Insurance Coverage under the Affordable Care Act.
November 15, 2012
NACUBO Comments to FCC on Auto dialer Definition.
August 6, 2012
NACUBO signs on to EDUCAUSE's comment regarding the proposed reform of the Universal Service Fund (USF) contribution methodology.
June 22, 2012
NACUBO, ACE, and 11 other associations comments to ED, VA, DoD, and CFPB on Executive Order 13607 and associated Principles of Excellence
April 30, 2012
NACUBO comments on OMB ANPG on reforming policies related to grants and cooperative agreements, cost principles and administrative requirements (including Single Audit Act)
November 21, 2011
NACUBO signs on to ACE's comments regarding the Department of Defense's Memorandum of Understanding for the Military Tuition Assistance Program
August 1, 2011
NACUBO submits comments in response to Announcement 2011-36.
September 29, 2010
NACUBO Comments to IRS on Expanded Form 1099 Reporting Requirements.
September 9, 2010
Comments on Notice of Proposed Rulemaking posted in the Federal Register on July 26, 2010, Docket ID-2010-OPE-0012.
August 19, 2010
NACUBO and the undersigned organizations are pleased to submit the following comments on the Environmental Protection Agency's Advance Notice of Proposed Rulemaking regarding the reassessment of PCB use authorizations.
August 2, 2010
NACUBO provides comments on the notice of proposed rulemaking addressing program integrity issues.
May 21, 2010
NACUBO with COHEO and NASFAA provide comments on the on the notice of proposed rulemaking that would amend the rules implementing the Telephone Consumer Protection Act
October 6, 2009
NACUBO with ACE, AAU, and NAICU provide comments on reporting requirements under the Bank Secrecy Act by Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR)
September 21, 2009
NACUBO submits comments on the notice of proposed rulemaking on General and Non-Loan Programmatic Issues.
September 8, 2009
NACUBO submits comments on the notice of proposed rulemaking that makes amendments to the rules governing money market funds.
August 21, 2009
NACUBO with ACUTA, ACE, AAU, APLU, and EDUCAUSE submits comments on employer-provided cellular telephones.
May 26, 2009
NACUBO, with NASFAA, ACE, CHEAO and NAICU comments on the Federal Reserve's proposed amendments to Regulation Z (Truth in Lending).
January 22, 2009
NACUBO, with NASFAA and AAU, comments on proposed regulations implementing the new GI Bill
August 18, 2008
Associations Comment on proposed ADA changes
April, 24, 2008
NACUBO submits comments to IRS on 3% withholding requirement
September 14, 2007
NACUBO comments on IRS Draft Redesign Form 990.
August 13, 2007
NACUBO comments on Department of Education Proposed Loan Programs: NPRM
May 9, 2007
NACUBO and ACE comments on DHS Interim Final Rule: Chemical Facility Anti-Terrorism Standards
August 18, 2006
NACUBO and ACE comments on EPA Proposed Rule: Subpart K--Standards Applicable to Academic Laboratories