Legal Alert | Department of Education Expands Interpretation of “Third-Party Servicer” Definition (and Announces Incentive Compensation Review)

UPDATES: On February 28, 2023, the Department updated the Dear Colleague Letter issued February 15, 2023 to establish a future effective date for the guidance, extend the public comment period, and extend the reporting deadline for institutions and third-party services. The new effective date is September 1, 2023. Institutions will be required to report any arrangements with third-party servicers that have not been reported to the Department, and entities meeting the definition of a third-party servicer will be required to submit the Third -Party Servicer Data Form to the Department by September 1, 2023. Additionally, the comment period was extended…
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