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Updated Financial Responsibility Reporting Guide 2024

July 8, 2024

The U.S. Department of Education's new financial responsibility rules took effect July 1, 2024 (the “2024 Rule”). These rules are part of a sweeping set of regulations that cover financial value transparency and gainful employment, professional licensure programs, the bare minimum rule, transcript withholding, and diploma verification, among many other topics.

Part of this rule relates to the set of events or circumstances called “triggers,” which must be reported by the department and could result in institutions being required to provide financial protection. Thompson Coburn’s Higher Education practice published a guide for institutions of higher education with respect to these reporting obligations in May.

On June 27, 2024, the Department published an Electronic Announcement with technical information concerning the form and content of submissions. The Electronic Announcement states that triggers should be reported to the Department through the Document Center, available on the Common Origination and Disbursement (COD) website, and by emailing the FSA Financial Analysis Division at FSAFinancialAnalysisDivision@ed.gov.

Thompson Coburn has updated our Financial Responsibility Guide to reflect this new reporting information. Click here to view the updated guide.