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U.S. Department of Education Extends Public Comment Period, Establishes a Future Effective Date, and Extends Reporting Deadline for Third-Party Servicers and Institutions

March 2, 2023

On February 15, 2023, the U.S. Department of Education released updated guidance for institutions that contract with third-party servicers (“TPS”) to administer any aspect of the institution’s participation in student assistance programs authorized under Title IV of the Higher Education Act of 1965. Cullen and Dykman LLP’s Client Alert summarizing the contents of the updated guidance can be found here.

On February 28th, the Department changed the effective date of the guidance from May 1, 2023  to September 1, 2023. Reporting requirements will also go into effect on that date. Institutions will be required to report any arrangements with third-party servicers that have not been reported to the Department and entities meeting the definition of a third-party servicer will be required to submit the Third-Party Servicer Data Form to the Department by that date.

Additionally, the Department adjusted the public comment period so that it closes 30 days from the date of the Department’s February 28th update.

Please note this is a general overview of developments in the law and does not constitute legal advice. Nothing herein creates an attorney-client relationship between the sender and recipient. If you have questions about the impact of this updated guidance on your institution, please contact Dina Vespia ( at (516) 357-3726, Jennifer McLaughlin ( at (516) 357-3889, or Deirdre Mitacek ( at (516) 296-9136.

Thank you to Ciara Villalona, a Law Clerk pending New York bar admission, who assisted in the preparation of this alert.

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