NASFAA Submits Comments on Cash Management
By Joan Berkes, Policy & Federal Relations Staff
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
Comments Disclaimer: NASFAA welcomes and encourages readers to comment and engage in respectful conversation about the content posted here. We value thoughtful, polite, and concise comments that reflect a variety of views. Comments are not moderated by NASFAA but are reviewed periodically by staff. Users should not expect real-time responses from NASFAA. To learn more, please view NASFAA’s complete Comments Policy.
Related Content
When Is the Earliest We Can Originate and Disburse Title IV Funds For 2026-27? (Award Year: 2026-27)
Can We Reinstate Aid That Our System Reversed Due To a Subsequent ISIR Transaction?
Can the School Refund a Title IV Credit Balance To the Student's Or Parent's Credit Card?
If a Student Or Parent Cancels an Authorization, When Is the Cancellation Effective?
Must Title IV Credit Balance Be Returned To ED If the Student or Parent Has Died?
Do We Use Half Weeks In Determining When a Student Completes Weeks Of Instructional Time?
Third Day of Neg Reg Session Focuses on Cash Management, Accreditation
Can a School Hold Or Delay Disbursements Until Later In the Term Or Payment Period?
Can Individuals Enrolled In Prison Education Programs Receive Title IV Credit Balances?
Do Schools Need an Authorization To Disburse Funds For Books and Supplies To Title IV Recipients?
Can We Round Clock Hours Up When Determining If the Student Completed the Payment Period?
Can We Use Email To Communicate With and Collect Documents From Students and Parents?
Can We Use the Student's Preferred Name On the College Financing Plan?
NASFAA Mention: Millennial Money: You Lost Your Job. Now What?
Can Students Placed On SAP Suspension Keep Their Early Disbursements For the Following Term?
Can We Hold Disbursements For a Student Who Meets SAP But Is Struggling Academically?
How Is the 30-Day Delayed Disbursement Rule Applied When a Student Attends Modules?
Is a School Required To Confirm VAWA Eligibility Before Each Disbursement?
Can We Pay Title IV Funds Directly To a Study Abroad Provider?
Can An Incoming Student Earn FWS Prior To Starting Classes?
Is Charging Books At The Bookstore Considered Student Authorization?
Do We Need the Student's Authorization To Pay For Housing the School Contracts To a Third Party?
Can You Disburse a Direct Loan If You Accidentally Canceled the Loan After the Student Withdraws?
How Long Can We Pay Students Who Are Conditionally Or Provisionally Admitted?
Previously Unreleased CFPB Report Raises Concerns Over Payment Vehicle Pilot
How Does the Use Of Electronic Books and Access Codes Impact Title IV Aid?
Can We Re-Issue Title IV Aid If an Unofficial Withdrawal Later Proves Attendance In the Term?
Are There Resources To Assist With Our Biennial T1 Or T2 Arrangement Due Diligence Review?
Do New Academic Transcripts Retroactively Change a Previous SAP Determination?
Advertisement
You must be logged in to comment on this page.