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Memorandum on Legal Authority for Cash Management Rule

February 23, 2015
Student Loans

The letter states...

On August 20, 2014, the Department received a joint memorandum from the American Bankers Association (ABA) and Consumer Bankers Association (CBA),1 arguing that the Department did not have authority under Title IV of the Higher Education Act (HEA) to promulgate rules on campus banking products of the scope proposed during negotiated rulemaking in spring 2014. The ABA's analysis is incomplete, superficial, and incorrect. It should not disturb the Department's rulemaking efforts.

Download the entire letter. (PDF)