101 Dalmatians Consumer Disclosures

10.13.2014Presented by Betsy MayotteMelbourne, Victoria, Australia

2Background

Higher Education Opportunity Act of 2008 (HEOA)

Consumer Finance Protection Bureau

Upcoming Reauthorization

3

Required Notices

4Annual Notice to Enrolled Students

Annually distributed to each student listing and explaining how to obtain info on:

Financial aid available to students at that school

Schools grad/completion rate• Transfer out rate if required

Terms and conditions for Direct Loans

Annual fire safety report• Those with on-campus housing only

Retention rate as reported to ED

Types of grad/professional programs enrolled in by schools 4-year undergraduate completers

5Annual Notice to Enrolled Students con..

Distributed to each student listing:

In separate, clear, notice, the penalties for drug related offenses as they relate to Title IV

Timely notice to students who have lost eligibility due to drug related offenses and explanation as to how to regain

Drug and Alcohol abuse materials (must go to each student and employee)

6Financial Aid Information

Must publish and make available:

Description of all available financial aid programs Eligibility/criteria for selection and award determination

Procedures/forms needed

Terms and conditions of Direct Loans

For awarded financial aid Method and frequency of disbursements

Sample loan repayment schedule

Importance of loan repayment

Student Aid Recipients Satisfactory academic progress policy

Criteria for continued eligibility

Exit counseling information

7School Information

Must make available upon request to enrolled and prospective students:

Completion and graduation rate

Retention rate

Placement rate by graduates

Types of employment

8Textbook Information

Institutions must, as much as practicable, include on its Internet course schedule for required and recommended textbooks and supplemental material:

the International Standard Book Number (ISBN) and retail price;– if the ISBN is not available, the author, title, publisher, and copyright date; or

TBD If applicable, the institution must include on its written course schedule a reference

to internet textbook info listed above

Must provide the following information to its college bookstores upon request:

the institution’s course schedule for the subsequent academic period; and

ISBN or alternative as required above

the number of students enrolled, and

the maximum student enrollment.

9Textbook Information

Also encouraged, but not required, to provide info on renting or purchasing used textbooks;

textbook buy-back programs; and

alternative content delivery programs.

10Peer to Peer File Sharing

Schools must disclose to students: Clear statement that unauthorized distribution of copyrighted material may

subject student to civil and criminal liabilities

Description of the institution’s policies on unauthorized peer-to-peer file sharing, including disciplinary actions

Summary of penalties for violation of country’s federal copyright laws

11Preferred Lender Arrangements

Covered schools or school affiliated organizations must disclose on it’s website and all informational materials:

• Maximum amount of aid under Title IV• Truth in Lending disclosures• Reasons schools chose lenders on list• That student may choose any lender, even if not on list• Information that terms and conditions of federal loans may

be better than private loans• Code of Conduct for education loans

13

Methods and Best Practices

14Policies First… Now Procedures

15Reasonably Accessible

Requirements:

No more than 2 clicks, if electronic

No less than 8 point font

Easily accessible

In a prominent location

Updated yearly at minimum

Designated person must be assigned and be available during normal business hours to all enrolled and prospective students

16Who does what on campus

Best practices:

• Have one office designated to ensure all disclosures are in compliance.

• Keep it Simple

• Document all required disclosures and ensure all are covered

• Review it once a year

17Ways To Communicate Disclosures

• Emails

• Mass and to specific groups

• Alerts

• Websites

• Social Media

• Brochures

18Ways to communicate: Website

19Ways to communicate:Automatic Email

20Resources

Effective award letters

http://www.nasfaa.org/advocacy/award-letter/Improving_Award_Letters_and_Consumer_Information.aspx

Task Force on Consumer Information

http://www.nasfaa.org/consumerinfo.aspx

Net Price Calculator

http://nces.ed.gov/ipeds/netpricecalculator/

21Resources

Textbook Disclosures:

- GEN-10-09 http://ifap.ed.gov/dpcletters/GEN1009FinalTextbookGuidance.html

– GAO report (released June 6, 2013)

http://www.gao.gov/products/GAO-13-368

FSA Assessments on Consumer Info

http://ifap.ed.gov/qahome/qaassessments/consumerinformation.html

22Resources

Comprehensive Consumer Disclosure Resource and Tips

http://counsel.cua.edu/res/docs/npec-heoa-disclosures-revised-11-29-09.pdf

Model FERPA Disclosure• http://

www2.ed.gov/policy/gen/guid/fpco/ferpa/safeschools/modelform2.html

SFA Requirements

Chapter 6, Volume 2 of SFA Handbook

23Thank you

SALT: A Responsible Borrower Program

CONTACT SALT

800.999.9080 bmayotte@asa.org www.saltmoney.org