[Oasfaa] The New NPRM

[Mc Conahay, Pamela K.]

If you attended the OGSLP conference on Thursday (VERY VERY WELL DONE!)
, you heard Brett Lief talk about the new NPRM (Notice of Proposed
Rulemaking) and refer to the kind of people who read the preambles to
NPRMs as 'nerds".  Hi, I'm Nerd.  Nice to meet you.  
 
Notices of Proposed Rulemaking are an important part of the government
regulatory process.  This is our opportunity to say "hey, wait a minute,
I don't like that" or "If you really want to achieve your objective, I
think it should be done THIS way" before regulation gets set in stone.  
 
When I was young in financial aid, back in the last millennia, I was
bored silly by federal updates and people who talked about proposed
regulations.  My attitude was "don't bother me until it actually goes
into effect, not that I'll be all that interested even then".    Then, I
aged...and I learned that comments made in response to NPRMs really CAN
affect the eventual final regulations.  Even if the proposed regulations
don't change when they become final regulations, the comment period
gives you some valuable preparation time depending on how soon these reg
changes will take effect.   
 
What Brett didn't tell you is that all the juicy stuff about arguments
between ED and the negotiated rulemaking participants are talked about
in the preamble.  Preambles are like the People Magazine of NPRMs.  You
can get a pretty good idea of what arguments or suggestions ED has
already refused to budge on by reading the preamble.....and what they
might still be willing to look at during the comment period.   
 
I read through the "invitation to comment" section of  the NPRM, that's
where ED discusses all of the suggestions made by the negotiated
rulemaking group and why ED did or did not take their suggestions.
Although the NPRM is 225 pages long, the 'invitation to comment' is only
about 100 pages (the first 100 pages).  Light reading, huh?   I've
listed below the areas that I pointed out to our administrative
colleagues here at OU.  You might consider doing the same.  
 
Bursar, Student Loan Collections if you have a Perkins Loan Program:
 
Page 11-17  Simplified Deferment Processes for FFEL and Perkins
Page 17-19  Death Certificate Requirement for Discharge FFEL and Perkins
Page 20-28  Total and Permanent Disability Discharges for FFEL and
Perkins
Page 32-38  Electronic Signatures on MPNs for FFEL and Perkins
Page 38-44  Record Retention on MPNs for Loans Assigned to ED. 
Page 50-54  Required Perkins Loan Assignments
Page 54-58  Reasonable Collection Costs for Perkins
Page 58-60  Child/Family Service Cancellation for Perkins
 
Financial Aid Executive Director, Associate VP
 
Page 60        Prohibited Inducements
Page 67        Support for Financial Literacy Efforts Allowed
Page 68        Support for Training,  Meetings, Conferences (meals,
receptions, etc.)
Page 68        Prohibitions for Guarantors
Page 73        Affiliated Groups (Recruiters?  Alumni Association?)
Page 79        Philanthropic Giving  (Might affect Development?)
Page 87        Prohibitions on School Affliated and Social
Groups---might this include fraternities & sororities?
Page 92        Requirements for Preferred Lender lists
Page 100-102  Minimum number on the list, model format for benefits
comparison being developed by ED.
 
Remember, these are just proposed regulations,  the NPRM won't
officially be open for comment until it gets posted in the Federal
Register.  Comments will be accepted for 60 days after the publication
in the Federal Register.  I checked the Friday, June 8 Federal Register
and the NPRM wasn't published yet.  The NPRM is available online at
http://www.ed.gov/policy/highered/reg/hearulemaking/2007/loans.html 
 
There will be analysis and discussion of this NPRM at the highest
levels....and at the lowest----like you and me.  Be a part of the
process.  
Pam McConahay 
Assoc. Dir., Compliance, Training & Lender Relations 
University of Oklahoma Financial Aid Services 
1000 Asp Avenue, Room 216 Norman OK 73019-4078
(405) 325-4617  Fax (405) 325-7608 
pmcconahay at ou.edu 

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