Does Higher Education have to Participate?
Yes, the following is a summary of the effective date and why Higher Education must participate.
- Effective for Higher Education November 1, 2009
- FTC Red Flag Rules do affect higher education*
- FTC Rules states "any person who defers payment for services rendered, such as an organization that bills at the end of the month for services rendered the previous month";
- and your accounts are "covered". (A covered account is "a consumer account that involves multiple payments or transactions, such as a loan that is billed or payable monthly.)"
- Activities for higher education that cause colleges and universities to be considered creditors include:
- Perkins Loans
- Participation in the Federal Family Education Loan Program
- Institutional loans to students, faculty or staff
- Payment Plan for tuition
- Program Administrator - must be designated for each institution.
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