Comment on FR Doc # E8-26550

Public Comment on Docket No EOUST 104 As currently written, §58.28(b) specifies the deadline by which a provider must apply for approval with the United States Trustee. However, it does not prohibit a time before which a provider should not submit their re-application. Currently, the US Trustee’s office specifies that an application must be received no earlier than 60 days and no less than 45 days prior to the expiration of the provider’s probationary period or its annual period. This gives the provider a 15 day “window” within which to submit its re-application. We respectfully request that the following wording be considered in order to address these concerns: §58.28(b) Such a provider shall apply no earlier than 60 days and no later than 45 days prior to the expiration of its 6-month probationary period or annual period… [the remainder of the wording is unchanged] = = = = = = = = = = As currently written, §58.31(a)(5) prohibits “any changes in the approved provider’s instructional course” without obtaining approval from the United States Trustee. Such a prohibition applies equally to “aesthetic” changes in printed handouts and instructional materials as it does to changes in course content and delivery methods. When it comes to superficial changes such as a PowerPoint’s clip art or the colors used on a handout, submitting a request for approval by the United States Trustee is burdensome on both the provider and the US Trustee. We respectfully request that the following wording be considered in order to address these concerns: §58.31(a)(5) Any changes in the approved provider’s instructional course relating to course content or delivery methods. = = = = = = = = = = As currently written, §58.33(d)(i) specifies appropriate qualifications and experience required by instructors of the debtor education course. However, it does not allow as qualified an instructor who has received certification as a financial educator. We respectfully request that the following wording be considered in order to address these concerns: §58.33(d)(i)(E) Certified as a financial educator or personal finance instructor by an accrediting organization; or = = = = = = = = = = As currently written, §58.33(d)(2)(ii) specifies the instructional experience required to be demonstrated by a provider, particularly for each physical location. As worded, this section will lead to service disruption in many small offices that currently provide individual and personalized instruction. In small offices where the provider employs just one staff member, this section would prohibit any instruction from taking place in this office for an extended period following the resignation or dismissal of that employee. We feel such disruptions can be surmounted with proper instructor certification (as required by these proposed rules) and with proper training and supervision by a supervisor that may be physically based in another location. We respectfully request that the following wording be considered in order to address these concerns: §58.33(d)(2)(ii) Employ at least one supervisor who has met the qualifications in paragraph (d)(2)(i) of this section for no less than 2 of the 5 years preceding the relevant application date; = = = = = = = = = = Thank you for your time and consideration of these concerns and proposed modifications to the proposed final rule “Docket No. EUOST 104.” Sincerely, Todd Christensen Director of Education National Financial Education Center at Debt Reduction Services Inc Boise, Idaho Todd@NationalFinancialEducationCenter.org