WINK

As you know, AACS has been participating in three rounds of Federal Negotiated Rulemaking on the subject of Borrower Defense to Repayment.  Our own Chris DeLuca represented us most ably as an Alternate Negotiator. Attached is a detailed summary prepared by Chris, in conjunction with Tom Netting, of the key issues deliberated during these negotiations. As noted in the past two day's Listserve notices, the U.S. Department of Education and the group of non-federal negotiators failed to reach consensus on these vitally important issues — leaving open the ability of the Department to now craft regulations which may or may not adhere to the draft proposals. AACS is in the process of finalizing a comprehensive plan to continue to address these regulations — and will be sharing much more information on the proposal and our plan with you in the very near future.

With the addition of the latest Federal Negotiated Rulemaking, and the proposals related to Borrower Defense to Repayment, your GRC determined that it may be appropriate to color code information regarding various legislative and regulatory issues in order to help you easily identify them as you are reviewing our various forms of communication, the websites, and other forms of information sharing including AACS webinars.