July - October 2020

CECU 2020 Virtual Convention



Washington, D.C. partner Jonathan Tarnow led three breakout sessions at the 2020 Virtual Convention for the career education sector, sponsored by Career Education Colleges and Universities (CECU). The virtual convention replaced the association’s usual in-person annual convention with multiple live and prerecorded sessions, which are available online through October 1, 2020. Katherine Armstrong joined Jonathan as a panelist for one of the three breakout sessions.

Cybersecurity and Audit Requirements for Schools

Jonathan served as moderator and presenter alongside Faegre Drinker colleague Katherine Armstrong and an outside auditor to postsecondary institutions. This session provides details about Gramm-Leach-Bliley Act cybersecurity requirements for higher education institutions, how those requirements must now be reviewed as part of annual independent audits, and the federal government’s enforcement practices.

Institutional Accountability Final Rule: Borrow Defense, Financial Responsibility, Leases, and Long-Term Debt

Jonathan Tarnow served as moderator and presenter for this session with two independent auditors to discuss the Department of Education’s “Institutional Accountability” final rule. The rule, which is effective July 1, 2020, reflects significant changes to the Department’s current Borrower Defense to Repayment regulations, and modifies the Department’s financial responsibility standards that assess a higher education institution’s ability to meet its financial obligations and properly administer federal student financial aid.

CARES Act HEERF Grants and Title IV Regulatory Relief

Jonathan served as a moderator and presenter for this session, with the Chief Financial Officer of client Pittsburgh Technical College and an outside audit firm that focuses on the education industry. This session was designed to assist institutions in ensuring that their uses of Higher Education Emergency Relief Fund grants under the CARES Act, and the exercise of certain Title IV student aid program waivers also contained in the CARES Act, comply with the law and related Department of Education guidance.

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