On July 2 NASFAA submitted comments on the Notice of Proposed Rulemaking (NPRM) published on May 18. As previously summarized, the NPRM focused largely on cash management issues. Two other provisions were included, one dealing with repeated coursework and the other with the clock/credit conversion rule. NASFAA supported the changes to both of those provisions.
Several of the cash management provisions generated a great deal of discussion and concern, especially those that affect the form of cash disbursements (checks versus electronic means), sponsored accounts or cards, fees that may be charged by banks that have arrangements with schools to facilitate disbursement of Title IV funds, and new disclosures, among others.
In addition, ED proposes to codify current guidance regarding prior year charges, and to broaden the requirement to make anticipated credit balances available for books and supplies by the seventh day of a payment period to all Title IV recipients with anticipated credit balances (currently applicable only to Pell Grant recipients).
NASFAA also signed on to comments submitted by the American Council on Education (ACE) and those submitted by the National Association of College and University Business Officers (NACUBO).
Publication Date: 7/7/2015