In comments submitted to ED yesterday, NASFAA supported fair, reasonable, and well-targeted regulations that ensure Title IV funding for programs that lead to gainful employment.
Among other issues, NASFAA commented that the proposed rules:
- Provide insufficient regulatory accommodation for those GE programs that are considered low-risk, i.e, programs where the total number of borrowers or amount of debt is relatively low.
- Include an extensive, complicated, and overwhelming list of 16 possible disclosure items, representing in total 36 possible data items due to possible disaggregations.
- Lack a meaningful front-end approval process that would serve to protect students from risky programs before they assume unmanageable debt, rather than after.