Course description
New Federal Rules Target Student Bank Accounts - Top 10 Compliance Issues
Make sure you are up to date and in compliance with the new rules governing student bank accounts. Department of Education regulations governing deposit, prepaid and other financial accounts offered to students of higher education institutions took effect on July 1, 2016. The Consumer Financial Protection Bureau has also taken an interest in these requirements and has published a Safe Student Account Toolkit to assist institutions in addressing these rules and otherwise minimizing the risks of CFPB scrutiny. Educational institutions, their third-party servicers, and financial institutions providing the student accounts will all be impacted. In this topic we will explain the rules in detail, with particular focus on the unique operational and compliance issues institutions and their student account partners are likely to face.
Learning Objectives
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Training content
- Introductory Overview of the Department of Education Student Account RulesEffective DatesConsumer Financial Protection Bureau Overlay and Implications
- Broad Enforcement Authority Under the Unfair, Deceptive or Abusive Acts and Practices Law (UDAAP)
- Direct Enforcement Authority Over Larger Banks
- Indirect Enforcement Authority Over Smaller Banks
- The CFPB Safe Student Account Toolkit–Applicable to Colleges, but Impact Banks–Third-Party Due Diligence and Monitoring Requirements–Contractual Term ExpectationsScope
- Who Is Covered
- What College Relationships Trigger Coverage: Tier One and Tier Two ArrangementsTier One Arrangements ExplainedTier Two Arrangements ExplainedRules Applicable to Both Tier One and Tier Two Arrangements (With Some Variations)
- Accounts Must Be in the Best Interests of Students
- Student Choice – Summary of the Requirement for Colleges to Establish a Student Choice Process for Receiving Electronic Deposits of Funds
- Student Consent to Open Account Before Access Device Is Provided
- Limits on Providing Student Information to Third-Party Servicers
- Disclosure of Major Fees and Commonly Assessed Features
- Surcharge-Free ATMs–Applicability–Number and Location of ATMs–Additional Tier One Rules
- No Costs to Open Account or Receive Access Device
- Accounts Cannot Be Marketed or Portrayed as, or Converted Into, Credit Cards
- Public Disclosure of Contracts Governing the T1 or T2 ArrangementUnique Tier One Rules
- No Credit Associated With the Account
- No Point-Of-Purchase Fees
- Overdraft Fees Generally Prohibited
- Convenient Mechanism to Access Title IV Funds in Full Without Charge
Costs
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Lorman Education Services - Live and On-Demand Courses
Lorman Education Services is a leading provider of online professional development and corporate training for organizations and individual professionals. For more than 30 years, Lorman has delivered relevant, high-quality, professional-level courses that cover a broad range of business and technical...