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Comments to Department of Education on Proposed Borrower Defense Rule

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Comments to Department of Education on Proposed Borrower Defense Rule

August 30, 2018

​ACE, along with 20 other higher education associations, submitted this community comment letter on the Department of Education’s proposed Borrower Defense rule. 

The letter states that the associations strongly support regulatory measures that are targeted, effective, and provide a necessary balance between protecting students and ensuring appropriate responsibility on the part of institutions. However, the proposed rule moves far too much in one direction, and if implemented as drafted, would further penalize borrowers for the actions of certain institutions operating in a manner contrary to the public interest, the associations write.

In addition to ACE, the organizations that signed on to the letter are:

  • ACPA-College Student Educators International 
  • American Association of Collegiate Registrars and Admissions Officers 
  • American Association of Community Colleges 
  • American Association of State Colleges and Universities 
  • American Dental Education Association 
  • Association of American Colleges and Universities  
  • Association of American Universities 
  • Association of Catholic Colleges and 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 of Graduate Schools
  • Council of Independent Colleges 
  • EDUCAUSE 
  • NASPA - Student Affairs Administrators in Higher Education 
  • National Association for College Admission Counseling 
  • National Association of College and University Business Officers 
  • National Association of Independent Colleges and Universities 
  • The Common Application

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