Comment on FR Doc # 2012-10488

For Cost Effective and Student Friendly Title IV Refunds 1. Require Electronic Disbursement: An institution should be able to disburse funds 100% electronically. The provision in 34 CFR Chapter VI that requires paper checks or cash disbursements when a student does not provide information for electronic disbursement is cumbersome, costly, and open to a greater risk of fraud than electronic disbursement. Electronic payments are more efficient and cost-effective. An excellent model is the new Social Security disbursement program. The U.S. Department of Treasury is moving to an all-electronic benefits payments program. By March 1, 2013, all federal benefits must be disbursed electronically. About 83% of federal benefit payments are made by direct deposit today. 2. Restrict Marketing by 3rd Parties: The process for distributing Title IV refunds is between the higher education institution and the student. No third party servicer should be allowed to market its products or services directly to students without each student’s prior consent. 3. Present Unbiased Enrollment Options: Students must be able to choose their preferred disbursement method without undue bias. They should make their choice at the institution’s website or location, not at a third party servicer. Electronic options must be presented equally, with a balance of information that allows the student to make an informed decision. 4. Disclose All Fees Upfront: All fees associated with accounts opened for the purpose of excess Title IV fund disbursement must be disclosed tranparently. The fees will be highlighted in a single table similar to those required for credit card offers. This transparency will enable a student to compare anticipated costs between disbursement options.