In a joint letter with the Consumer Bankers Association today, ABA offered feedback to the Department of Education on the disclosures for student bank accounts offered through partnerships between banks and educational institutions.
Under a previously adopted regulation, educational institutions are required to provide students the “major features and types of commonly assessed fees” associated with bank accounts offered through partnerships with financial institutions. A current proposal by the DOE would provide a safe harbor to a disclosure model for student bank accounts that mimics the recently adopted disclosures for prepaid cards.
However, the associations noted that such a safe harbor would be unsuited for checking accounts and would not assist students in comparing or selecting checking accounts. As an alternative, the groups urged DOE to provide a safe harbor to the simplified checking account disclosure model that banks partnering with educational institutions already use.
