Dept. of Ed close to releasing proposal that would facilitate income share agreement programs at selected Title IV schools – JD Supra
Written b: Ballard Spahr LLP
My colleagues and I have the privilege of advising numerous clients on income share agreements (ISAs), including universities, service providers, and institutional investors. So we were excited by reports that the U.S. Department of Education (ED) plans to publish a Federal Register notice for an Experimental Sites Initiative (ESI) that would facilitate ISA programs at Title IV schools.
Under an ESI, ED seeks to test out new approaches to financial aid by waiving certain Higher Education Act requirements. This forthcoming ESI—called “Institutional Investment in Student Success”—would permit a small number of selected schools to limit their students’ federal borrowing, repay federal student loans on behalf of students, or both.
Specifically, ED’s intention is that participating schools would:
- Limit federal loan borrowing, including at the program level (based on expected earnings data reported by the College Scorecard), credential level, or year in the program;