March 9, 2023, 3-3:30pm ET

Third Party Servicers and Online Program Management

On February 15, 2023, the U.S. Department of Education Office of Federal Student Aid issued a Dear Colleague Letter that greatly expanded the definition of third-party servicers (TPS) to include “entities performing the function of student recruiting and retention, the provision of software products and services involving Title IV administration activities, and the provision of educational content and instruction.” The guidance also prohibits colleges and universities from contracting with third-party servicers located outside of the United States or entities “owned or operated by an individual who is not a U.S. Citizen or national or a lawful U.S. permanent resident.”  The guidance will take effect on September 1, 2023.   On that same day, colleges and universities must report all TPS arrangements to the Department.  Join us for a 30-minute NACUA briefing to learn about the guidance, associated regulatory requirements, and institutional compliance efforts.   

Speaker(s)

Lou Guard

Lou Guard

Lou Guard is General Counsel at Hobard and William Smith Colleges, where he serves as the Colleges’ chief legal officer and represents the Colleges on all legal matters.  He provides legal advice and counsel across institutional areas, assists the president with all major initiatives and projects, and is...

Aaron Lacey

Aaron Lacey is a Partner at Thompson Coburn where he chairs the firm’s Higher Education Practice and assists institutions to navigate a wide range of complex legal and regulatory matters. Aaron has substantive experience in federal, state, and accrediting agency laws and standards that govern...

Recording

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FAQ

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NACUA Briefings

NACUA Briefings are intended for NACUA members only and for their colleagues at member institutions. Members may freely...

NACUA Briefings are intended for NACUA members only and for their colleagues at member institutions. Members may freely share information included as part of a Briefing with their colleagues at member institutions but should not share the information in a manner that could result in broader public distribution. Briefings should not be considered to be or used as legal advice. Legal questions should be directed to institutional legal counsel.