CBA Comment Letter to Education Department Regarding Collection Activities

Dear Director:
On December 31, 2012 the Department of Education published a notice of information collection activities associated with Preferred Lender Arrangements (Part 601). The regulations require covered educational institutions to provide a variety of new loan disclosures on private student loans. In the notice, the Department noted it is submitting the Private Education Loan Applicant Self-Certification form to the OMB for approval. The notice may be found at:
The deadline for comments was February 28, 2013. Although this deadline is passed, we are submitting comments on the self-certification form in response to the Department’s interest in receiving suggestions on “how might the Department enhance the quality, utility, and clarity of the information to be collected; and how might the Department minimize the burden of this collection on the respondents, including through the use of information technology.

Our comments are as follows:
1. Move school address to a separate line below the school name or create a separate section for school name and address. We are suggesting this change because frequently the address is omitted from the form causing delays.
2. In Section 3, Change “Applicant Name” to “Student Applicant Name.” We believe this clarification will reduce the opportunity for errors.
3. In Section 4, change “Signature of Applicant” to “Signature of Student Applicant”.
4. In Section 4, Change “Date (mm/dd/yyyy)” to “Signature Date (mm/dd/yyyy)”.

To read the full Comment Letter, download the PDF.