ED Provides Guidance on How to Submit Contracts for Banking, Processing Relationships
7/08/2016
Part of the recently revised cash management regulations establish rules for institutions that have arrangements with third-party servicers processing Title IV credit balance refunds (T1 arrangements) and banks (T2 arrangements). The regulations require colleges and universities to disclose on their website-by September 1-the contract establishing a T1 or T2 arrangement. Additionally, institutions need to provide the Department of Education with the URL of the contract so the department can include it in a centralized public database.
On July 1, ED posted an Electronic Announcement with instructions for submitting those contracts. Schools will also be able to use the website to submit future updated/amended contracts. Institutions are allowed to redact portions of the agreement that would compromise "personal privacy, proprietary information technology, or the security of information technology or of physical facilities."
NACUBO has a web page with extensive cash management resources for institutions.
UPDATE (September 30, 2016): ED published a "Dear Colleague Letter" reminding institutions to post contracts and arrangements online and to submit copies to the Department to post in the database. The guidance also included a link to access the database.
