Negotiated Rulemaking Committees - Summary of 2nd Session of Borrower Defenses & Financial Responsibility
In an effort to consolidate the four days of deliberations into a "brief" summation, we have chosen to share the Department’s "Summary of Change" and highlights of the topics and takeaways for each of the eight Issue Papers.
We also focus on a key issue of importance regarding lease liability contained in the Financial Responsibility Subcommittee’s recommendations to the Committee. AACS will be seeking additional information from many within our membership in order to help us formulate a response and additional recommendations prior to the Subcommittee’s final meeting in just a few weeks.
- Issue Paper 1 – Federal Standard
- Issue Paper 2 – Regulatory Framework
- Issue Paper 3 – Financial Responsibility and Administrative Capability
- Issue Paper 4 – Pre-dispute Arbitration Agreements, Class Action Waivers, & Internal Dispute Process
- Issue Paper 5 – Closed School Discharge
- Issue Paper 6 – False Certification
- Issue Paper 7 – Guaranty Agency Collection Fees
- Issue Paper 8 – Recalculation of Borrower’s Subsidized Usage Period and Interest Accrual
Financial Responsibility Subcommittee:
- Issue Paper 2 – Financial Accounting Standards Board (FASB) Accounting Standards Update, ASU 2016-2, Leases (Topic 842), and the Department’s Financial Responsibility Standards
Click here to read the full summary of the Borrower Defenses & Financial Responsibility sessions.