Making Sense of the Latest Changes to Title IV Financial Responsibility and Change in Ownership Regulations

Education law partner Jonathan Tarnow spoke at the California Association of Private Postsecondary Schools (CAPPS) 40th Annual Conference. His session provided attendees with a detailed understanding of certain significant changes to U.S. Department of Education regulations that apply to all postsecondary institutions that participate in the Title IV federal student financial aid programs (Title IV).

On July 1, 2024, the latest revisions to the Department ’s Title IV financial responsibility regulations took effect, including significant changes to mandatory and discretionary triggers for institutions to provide the Department with letters of credit or other financial protection. The updated financial responsibility regulations also codify and expand previous sub-regulatory policies on changes in ownership, and specific financial requirements related to such transactions. This newest set of regulations also intersects in many important respects with other Title IV regulatory changes that took effect in 2023.