ARTICLE · 08 MARCH 2023

ED Updates Timeline For Third Party Servicer Guidance

Cooley LLP

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The Department of Education has extended the timeline for implementation of its February 15 Dear Colleague Letter, which substantially expanded the "third-party servicer" definition under the Title IV regulations.

United StatesConsumer Protection

Katherine Lee Carey

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The Department of Education has extended the timeline for implementation of its February 15 Dear Colleague Letter, which substantially expanded the "third-party servicer" definition under the Title IV regulations.

As noted in our overview last week, ED's guidance indicated it was immediately effective but, unlike most ED guidance, also included a 30-day comment period. Citing the need for clarity and time to come into compliance with the updated guidance, ED announced on February 28 that the new guidance – including the obligation to report any service providers newly covered by the regulations – will not take effect until September 1, 2023. ED has also reset the 30-day timeline for comments on the Dear Colleague Letter, to begin on February 28.

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