Prohibition on Unfair and Deceptive Marketing Practices, What You Need to Know
The U.S. Department of Education has updated Borrower Defense to Repayment Regulations that expand actionable circumstances to include substantial misrepresentation, substantial omission of fact, and aggressive recruitment. The Department has also begun the "Use of Secret Shoppers to Evaluate Recruitment and Enrollment Practices." In addition, the FTC has notified institutions that they “are cracking down on any false promises colleges” and recently filed a lawsuit against a large for-profit institution for “deceiving proposed students about cost and course requirements.” During this session, we will help institutions understand their current compliance obligations and practices the FTC, U.S. Department of Education, and other regulators have found unfair and deceptive. In addition, we will discuss ways institutions can design a robust compliance program for their marketing and student recruitment activities to minimize compliance and financial risks. Attendees will also benefit from a discussion on common scenarios. Particular focus will be placed on student outcomes, program disclosures, endorsements, and the use of secret shoppers.
