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On September 29, the Consumer Financial Protection Bureau (CFPB) published a report addressing student loan servicing and private student loans. In it, the CFPB states that “blanket policies to withhold transcripts in connection with an extension of credit are abusive under the Consumer Financial Protection Act.” NACUBO plans to express concerns about the position to the CFPB. 

In the report, the CFPB calls for institutions to discontinue withholding transcripts as a blanket policy and has indicated it will “continue to exercise all of its authorities to ensure that servicers and loan holders make consumers whole.”

The CFPB currently appears to only be targeting schools providing institutional loans to students; however, in addition to in-school loans, the agency is including tuition payment plans, income share agreements, and loans used to refinance existing federal or private loans as “extensions of credit.” It argues that institutions take “unreasonable advantage of the critical importance of official transcripts and institutions’ relationship with consumers” since schools hold the roles of both lenders and educators.

The report follows an announcement earlier this year where the CFPB indicated it was planning to examine college and university in-house lending practices.

In April, NACUBO and the American Association of Collegiate Registrars and Admissions Officers (AACRAO) published a joint statement on the use of holds for registration and transcripts, encouraging higher education leaders to review their policies. NACUBO will respond with a letter outlining concerns with the CFPB's approach to transcript withholding and its interpretation of “private education loans.”


Bryan Dickson

Director, Student Financial Services and Educational Programs


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