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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.

  • September 19, 2014
    NACUBO requests that the Internal Revenue Service stop issuing penalty notices to colleges and universities related to missing or inaccurate taxpayer identification numbers (TINs) on 2012 Forms 1098-T.
  • April 29, 2014
    NACUBO has asked the Internal Revenue Service to issue guidance that would waive penalties for colleges and universities that file Form 1098-T with incorrect or missing taxpayer identification numbers. The IRS previously announced that penalties for 2011 would be waived.
  • April 16, 2014
    NACUBO submits comments on Notice 2014-4 (December 23, 2013), which requests comments on interim guidance for Type III supporting organizations seeking to qualify as functionally integrated by supporting a governmental supported organization. 
  • June 4, 2013
    NACUBO submits comments on the noticed published in the Federal Register on April 16, 3013, announcing additional topics for consideration by a negotiated rulemaking committee.
  • May 31, 2013
    NACUBO submits comments to OMB on proposed reforms to federal grants management  NACUBO endorses several comments made by the Council on Governmental Relations.
  • 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