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A review of ED’s new third-party servicer guidance and suggestions for public comment


In February 2023, the U.S. Department of Education issued significant and controversial guidance regarding its oversight of “third-party servicers,” companies and organizations that provide certain services to postsecondary institutions. As discussed in our recent blog post, the Department has proposed to dramatically expand the range of entities that would be deemed third-party servicers under federal law, thereby claiming the authority to directly regulate and investigate these organizations, and to hold them jointly and severally liable for noncompliance. The Department also has maintained its position that organizations located outside the United States, or with foreign ownership, may not serve as a third-party servicer. Institutions and servicers alike have until March 30, 2023, to comment on this proposed guidance. We invite you to join us for a 90-minute webinar on March 27, 2023, during which we will examine the new guidance in detail and offer suggestions for comment.

The live presentation of this webinar was approved for 1.5 hours of general CLE credit in California, Illinois, and Texas; 1.8 hours of general CLE credit in Missouri; and 1.5 hour of professional practice CLE credit in New York. Please visit the CLE Overview page to see how the CLE credit for this recorded webinar can be applied in CA, IL, MO, NY, & TX. 

If you are interested in receiving CA, IL, MO, NY, or TX CLE credit for watching the recorded presentation, you must register for the program by clicking here. If you are not interested in receiving CLE credit, you can watch the presentation by clicking the play button on the video.

Participants will only be emailed a Certificate of Attendance if the webinar is viewed in its entirety. If you were unable to view the webinar in its entirety, please contact webinarinquiries@thompsoncoburn.com to see if you are eligible to receive partial credit. 

If you do not receive your Certificate of Completion, please e-mail webinarinquiries@thompsoncoburn.com

Aaron Lacey
Scott Goldschmidt
Hope Watson


Originally Presented:
March 27, 2023