In a joint comment letter to the Department of Education last week, ABA and other financial trades provided feedback on proposed methodologies for calculating and reporting the mean and median fees students pay on bank accounts offered through partnerships between banks and educational institutions. The information must be provided to DOE and (for “tier 2”arrangements) posted on the bank’s website pursuant to a recently adopted DOE rule.
The associations supported two reporting methodologies proposed by the department, which include a method of obtaining data through a bank’s records of accounts linked to a student ID card, and a participation-based bank review method, which “would allow a financial institution to review and include in the summary of fee data those accounts that the financial institution’s records indicate are opened under the T2 arrangement.” The groups also recommended a third option that would allow for the identification of accounts that are linked to co-branded debit cards.
The groups also supported a two-year look-back period to allow for more representative data on mean and median fees to be reported, and opposed a suggestion to match institution-provided student directory information with banks’ accountholder data, citing concerns over data security and accuracy. For more information, contact ABA’s Anjali Philips or Nessa Feddis.
