The undersigned negotiators from the 2014 Program Integrity and Improvement Committee, representing the interests of students, legal aid and consumer advocacy organizations, appreciate the opportunity to comment on the Department’s notice regarding the centralized databasing of school-bank contracts, pursuant to its new cash management regulations.

We strongly supported this rulemaking, and believe the new rules will rein in some of the most problematic aspects of school-bank partnerships for marketing financial products to students receiving Title IV credit balances.

To ensure successful implementation of the new rule, we urge the Department to develop a searchable public database, much like the CFPB’s college credit card database, to compare agreements and monitor market trends.   Being able to easily search for agreements by school or financial institution, and review important data about account usage, will ensure that the Department has the information it needs to monitor compliance. It will also ensure that students, other relevant agencies, and the general public have access to important information about campus banking agreements and can compare key terms and conditions.