The higher education associations listed below, write to offer comments on the Notice of Proposed Rulemaking (NPRM) regarding borrower defenses to repayment that was published in the Federal Register on June 16, 2016 (Docket ID ED-2015-OPE-0103). This comment letter addresses recommendations related to the NPRM’s provisions on borrower defenses to repayment. Comments on the NPRM’s changes to current financial responsibility standards will be addressed in a separate letter.
American Association of Community Colleges
American Council on Education
Association of American Universities
Association of Community College Trustees
Association of Governing Boards of Universities and Colleges
Association of Jesuit Colleges and Universities
Association of Public and Land-grant Universities
Council for Christian Colleges and Universities
Council for Higher Education Accreditation
National Association of College and University Business Officers
National Association of Independent Colleges and Universities
National Association of Student Financial Aid Administrators
Thurgood Marshall College Fund
UNCF