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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.
- 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
- May 21, 2004
NACUBO comments on proposed changes to student FICA regulations
- December 1, 2003
NACUBO comments on an NCES proposal to add an expenditure calculation
- August 26, 2003
NACUBO comments on eZ-Audit
- October 11, 2002
NACUBO's comments to OMB on Circular A-21 on F&A rates
- October 11, 2002
NACUBO's comments to OMB on Circular A-133 on single audits
- October 7, 2002
NACUBO's comments to ED on institutional eligibility notice of proposed rulemaking
- October 7, 2002
NACUBO's comments to ED on notice of proposed rulemaking on the Title IV student loan programs
- July 29, 2002
NACUBO's comment letter to the IRS on the notice of proposed rulemaking published April 29 on information reporting related to the Hope and Lifetime Learning credits
- June 17, 2002
NACUBO's comment letter to GAO in response to proposed changes to the Government Auditing Standards
- June 17, 2002
NACUBO's comment letter to INS on SEVIS
- November 19, 2001
NACUBO's comment letter to OMB on the proposed new Federal Perkins/NDSL Loan assignment form (ED Form 553)
- November 1, 2001
NACUBO joined ACE in a letter to campus presidents encouraging them to take "extra care" to ensure that their campus is in compliance with federal laws regulating the use, storage, and security of biohazardous materials.
- October 26, 2001
NACUBO recently joined the ACE and other members of the Washington Higher Education Secretariat in testimony before the House Education and Workforce Committee, presented by ACE President David Ward, outlining the higher education community’s specific recommendations for changes to the visa policy.
- April 17, 2001
American Council on Education comments, joined by NACUBO and others, on temporary and proposed regulations on excess benefits transactions issued by the IRS
- February 16, 2001
Higher education community concerns in response to IRS Announcement 2000-84 on the Internet activities of exempt organizations
- February 12, 2001
Independent Sector's comments to the IRS in response to Announcement 2000-84, concerning nonprofits’ usage of the Internet. These comments represent the concerns of the higher education and non-profit communities.
- February 6, 2001
Community comments draft on Competitive Networks before the Federal Communications Commission.
- September 14, 2000
NACUBO’s comments on the notice of proposed rulemaking published on June 16 on information reporting requirements for colleges and universities under IRS Code section 6050S for the Hope and Lifetime Learning tax credits
- April 10, 2000
NACUBO's comments on an advance notice of proposed rulemaking on insurance requirements for the FEMA Public Assistance Program.
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