New Federal Rules Target Student Bank Accounts - Top 10 Compliance Issues

Webinar: ID# 1023221
Recorded CD
About This Course:
Department of Education regulations governing deposit, prepaid and other financial accounts offered to students of higher education institutions took effect on July 1, 2016.

The Consumer Financial Protection Bureau has also taken an interest in these requirements and has published a Safe Student Account Toolkit to assist institutions in addressing these rules and otherwise minimizing the risks of CFPB scrutiny. Educational institutions, their third-party servicers, and financial institutions providing the student accounts will all be impacted.

In this webinar we will explain the rules in detail, with particular focus on the unique operational and compliance issues institutions and their student account partners are likely to face.


Introductory Overview of the Department of Education Student Account Rules
Effective Dates
Consumer Financial Protection Bureau Overlay and Implications
  • Broad Enforcement Authority Under the Unfair, Deceptive or Abusive Acts and Practices Law (UDAAP)
  • Direct Enforcement Authority Over Larger Banks
  • Indirect Enforcement Authority Over Smaller Banks
  • The CFPB Safe Student Account Toolkit
  • Applicable to Colleges, but Impact Banks
  • ThirdParty Due Diligence and Monitoring Requirements
  • Contractual Term Expectations
  • Who Is Covered
  • What College Relationships Trigger Coverage: Tier One and Tier Two Arrangements
Tier One Arrangements Explained
Tier Two Arrangements Explained
Rules Applicable to Both Tier One and Tier Two Arrangements (With Some Variations)
  • Accounts Must Be in the Best Interests of Students
  • Student Choice – Summary of the Requirement for Colleges to Establish a Student Choice Process for Receiving Electronic Deposits of Funds
  • Student Consent to Open Account Before Access Device Is Provided
  • Limits on Providing Student Information to Third-Party Servicers
  • Disclosure of Major Fees and Commonly Assessed Features
  • Surcharge-Free ATMs
  • Applicability
  • Number and Location of ATMs
  • Additional Tier One Rules
  • No Costs to Open Account or Receive Access Device
  • Accounts Cannot Be Marketed or Portrayed as, or Converted Into, Credit Cards
  • Public Disclosure of Contracts Governing the T1 or T2 Arrangement
Unique Tier One Rules
  • No Credit Associated With the Account
  • No Point-Of-Purchase Fees
  • Overdraft Fees Generally Prohibited
  • Convenient Mechanism to Access Title IV Funds in Full Without Charge
About The Presenter

John ReVeal
  • Financial Institutions Group’s lead regulatory and compliance lawyer in Bryan Cave’s Washington, D.C. office, where he leads the firm’s Retail Banking Team and Payments Team
  • Advises banks and other financial services providers on consumer compliance, including issues arising under the following federal laws (and state law equivalents, where applicable): Truth in Lending Act, Equal Credit Opportunity Act, Real Estate Settlement Procedures Act, Electronic Fund Transfers Act, Truth in Savings Act, Fair Credit Reporting Act, Fair Debt Collection Practices Act, Federal Trade Commission Act Section 5 (Unfair or Deceptive Acts or Practices) and the CFPB Unfair, Deceptive or Abusive Acts or Practices law, Gramm-Leach-Bliley Act Title V (consumer privacy), and the Automated Clearing House rules and guidelines
  • Also assists financial institutions in the review and development of Bank Secrecy Act and Anti-Money Laundering programs, and provides BSA/AML training to directors, officers and other employees of banks and other financial institutions
  • Advises financial institutions regarding bank and thrift powers, federal preemption, exportation of rates and charges, and financial institution licensing
New Federal Rules Target Student Bank Accounts - Top 10 Compliance Issues
Available on CD format
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