A TOUCHNET LIVE! SPECIAL PRESENTATION SOLVING THE STUDENT REFUND PUZZLE
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1 A TOUCHNET LIVE! SPECIAL PRESENTATION SOLVING THE STUDENT REFUND PUZZLE
2 Subpart K- Cash Management Direct Deposit Student Choice Menu T1, T2 Relationships ATM Access New Account Fees Due Diligence Reporting
3 Components of Change Debit Cards Consumer Protections Social Media
4 The Road to Regulation 2012 ED Hearings & U.S. PIRG Report 2013 Congress / CFPB / Studies 2014 Negotiate Rulemaking 2015 Proposed & Final Rule
5
6 EFT to Existing Financial Account (d)(4)(ii) Direct Deposit Only No change if NO new financial account offered
7 EXAMPLE: erefunds Screen
8 Direct Deposit + New Financial Account (d)(4)(i) Student Choice (A) Implementing: 1. Inform that new account not required 2. Clear, factual, neutral 3. EFT to existing account is as timely and no more onerous than new account 4. Student can change options at anytime 5. No option is preselected/defaulted 6. If no choice selected, refund via check
9 Direct Deposit + New Financial Account (d)(4)(i) Student Choice (B) Describing: 1. Existing account must be listed first 2. List major features and fees of new account (URL for terms and conditions) 3. May provide information for other financial accounts
10 EXAMPLE: Federal Benefits
11 EXAMPLE: Federal Benefits
12 Tier 1 vs Tier 2 Arrangements (e) & (f) Service Provider Tier 1 Financial Institution Tier 2
13 Tier 1 Arrangements Contracts with a third-party servicer Makes payments to one or more new financial accounts Information about account is communicated directly to students by servicer or institution Offered by other affiliated entity
14 Tier 2 Arrangements Financial Accounts marketed directly to students: Institutions communicate directly with students about opening accounts Financial accounts are cobranded and marketed principally to students Card or tool for institutional purpose (when validated)
15 Do I Have a T2 Arrangement?
16 Overview - New Financial Accounts Marketing Account Fees Free Withdrawal ATM Access Disclosures Due Diligence
17 Marketing - New Financial Accounts Must consent to open before sending card or access device, except student ID card No PII except directory info, unique ID, amount, & shared secret identifier T1 T2 T2 (Low) X X X No PII other than directory without consent X X Inform students of T s and C s before opening X X X Can not be converted to credit card X X X X
18 Fees - New Financial Accounts T1 T2 T2 (Low) No cost to open new financial account X X X No point-of-sale fees X No overdraft fees or credit extended X
19 Withdrawals - New Financial Accounts Minimum of one way to withdraw or transfer 100% of credit balance funds without charge for as long as student is enrolled T1 T2 T2 (Low) X *This replaces the 30-day free window that was proposed in the preliminary rule.
20 ATM Access - New Financial Accounts Convenient access to ATM reasonably available to students, including peak times Surcharge-free national or regional network X X No charge for in-network fund withdrawals or balance inquiries T1 T2 T2 (Low) X X X X
21 Disclosure - New Financial Accounts T1 T2 T2 (Low) September Disclose contracts on institution s website and provide ED with URL for publication X X X July Account fee disclosure in new CFPB-driven format September List considerations paid or received by parties under the contract and provide mean and median of actual costs incurred (> 30 financial accounts) X X X X X
22 Due Diligence - New Financial Accounts Terms of accounts in best interest of students and reasonable due diligence every 2 years Contracts terms must allow termination for too many complaints or fees higher than prevailing marketing rates Ensure requirements are being met for T1 and T2 arrangements T1 T2 T2 (Low) X X X X X X X
23 Best Interest of Students Responsibility of the institution Contract termination provision Secretary reserves right to disburse
24 TouchNet + Heartland Software erefunds Direct Services RefundSelect Debit Cards Acceluraid
25 Heartland Full-Service Refunds
26 CPE Credit TouchNet Information Systems Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website,
27 Resources TouchNet Knowledge Center Department of Education NACUBO
28
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