1 Higher Education’s New Bold Sheriff SCCE Higher Education Compliance Conference Austin, TX June 2013 Joel S. Mayer, Esq., CCEP I AM A RECOVERING LITIGATOR THE OPINIONS EXPRESSED HERE ARE PERSONAL TO ME AND DO NOT NECESSARILY REFLECT THOSE OF THE NJ HIGHER EDUCATION STUDENT ASSISTANCE AUTHORITY, ANY PREVIOUS EMPLOYER OR, MORE IMPORTANTLY, MY CHILDREN 2
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Higher Education’s New Bold Sheriff
SCCE Higher Education Compliance ConferenceAustin, TX June 2013
Joel S. Mayer, Esq., CCEP
I AM A RECOVERING LITIGATOR
THE OPINIONS EXPRESSED HERE ARE PERSONAL TO ME AND DO NOT NECESSARILY REFLECT
THOSE OF THE NJ HIGHER EDUCATION STUDENT ASSISTANCE AUTHORITY, ANY
PREVIOUS EMPLOYER OR, MORE IMPORTANTLY, MY CHILDREN
Must capture all complaints – not just those forwarded via the CFPB Portal◦ CFPB Portal◦ Governor’s Office Referrals◦ Legislative Referrals◦ Direct Borrower/Student Complaints (letters, e-mails,
telephone)◦ Includes Co-borrowers and Cosigners
WHAT IS A COMPLAINT?
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All complaints must be quickly investigated, responded to and resolved regardless of type and/or complexity
Portal complaints require timely responses to the CFPB and the borrower
Robust, clear, and consistently applied policies and procedures expected◦ THEY WILL ASK
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http://collegecost.ed.gov/shopping_sheet.pdf
http://www.consumerfinance.gov/paying-for-
college/
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Objective is to promote transparency and allow easier comparisons as between different colleges
Required Elements:1. Cost of Attendance (Tuition/Fees, Housing/Meals,
1. Graduation Rate (Percentage of full-time students who graduate within 6 years)
2. Loan Default Rate (Percentage of borrowers entering repayment and defaulting on their loan)
3. Median Borrowing (Aggregate for typical student and monthly payment on that total for a 10 year Federal loan term)
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Examinations and Enforcement Actions will escalate
Entire landscape of Higher Ed on radar –nonprofit, state affiliation irrelevant
Complaint Portal Data used to target exams Extremely expensive and disruptive◦ Money◦ Resources Systems Staff
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Remain at the edge of the radar by promoting:◦ RESPONSIBLE BORROWING/CHOICES◦ INFORMED BORROWING/CHOICES◦ BETTER CHOICES◦ BORROWER/STUDENT ENGAGEMENT BEFORE , DURING, AND AFTER SCHOOL (LOAN REPAYMENT)
MOBILE AND SOCIAL MEDIA
Remain vigilant in capturing, investigating & resolving complaints
Negative perception generates additional attention and the prospect of a wider inquiry
Avoid negative perception by encouraging transparency and showing that you and the institution have nothing to hideo What they see through is less likely to hurt you
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Don’t confuse respect with intimidationWelcome them with open arms (and open
books) Learn how they take their coffeeMake yourself indispensible Show pride in your work, your integrity, your
program and the work of your staff Beware of lawyers – be very aware of perception
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BENEFITS OF AN INQUIRY OR INVESTIGATION
Presence of regulators, investigators and prosecutors reminds everyone of the importance of compliance efforts
Permits compliance professionals to focus on compliance and improve programs
Encourages investment in compliance related systems, consulting services and third party solutions
Enhances the value of dedicated compliance professionals in the eyes of institutional leadership
Encourages the development of valuable contacts
Can provide a reputational boost to your institution