In July, the Federal Reserve Board approved final rules on Regulation Z (Truth in Lending) that revise the disclosure requirements for private education loans. Compliance with the final rules has been optional since September, but will be required starting Feb. 14, 2010.

Truth in Lending Act (TILA) regulations were updated in accordance with changes from the Higher Education Opportunity Act (HEOA). Title X of the HEOA amends TILA by adding disclosure and timing requirements that apply to creditors - including institutions - making private education loans.

Recently, NASFAA convened a conference call with multiple stakeholders who have a role in either developing or carrying out new student loan disclosure requirements. The conference call focused on how schools would implement new TILA requirements when dealing with institutional loans and federal Title VII and Title VIII loans under the Public Service Health Act, which are not been exempt from TILA requirements. Participants in the call included representatives from NASFAA, NACUBO, ED, HHS, and the Federal Reserve Board.

The Federal Reserve has provided the following model disclosure forms and samples that schools can use in implementing the TILA requirements:

1. H-18 Private Education Loan Application and Solicitation Model Form
2. H-19 Private Education Loan Approval Model Form
3. H-20 Private Education Loan Final Model Form
4. H-21 Private Education Loan Application and Solicitation Sample
5. H-22 Private Education Loan Approval Sample
6. H-23 Private Education Loan Final Sample

The Department of Education plans to make the self-certification form available by Feb. 14. The Department will announce when the form is available on the Information for Financial Aid Professionals (IFAP) Web site and NASFAA will post the announcement in Today's News.

Posted 02/03/10 to www.NASFAA.org. Redistribution to non-NASFAA institutions is prohibited. Please submit Web site questions or comments to Web@NASFAA.org.