NAICU Washington Update

Analysis of Cash Management Regulations Completed

December 18, 2015

The National Association of College and University Business Officers (NACUBO) has completed an analysis of the recent program integrity rules dealing with institutional cash management, published by the Department of Education at the end of October. The new rules are effective July 1, 2016.

There are two main focuses to the NACUBO cash management analysis. One part governs institutional management of Title IV funds, and the other describes the rules for relationships between academic institutions and banks or third-party servicers.

According to the Department of Education, these final regulations are intended to ensure that students have convenient access to their Title IV, HEA program funds, do not incur unreasonable and uncommon financial account fees on their Title IV funds, and are not led to believe they must open a particular financial account to receive their Federal student aid.

The cash management portion of the regulations was developed in response to concern about students’ access to their Title IV credit balances, and agreements between financial institutions and third party servicers that were deemed unfair to students. Under those agreements students were sometimes provided with cards linked to other campus services, and involved significant service charges.

NAICU has worked closely with NACUBO staff on the cash management regulations and appreciates their expertise and collaboration.

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