By Sally Samuels, Director of Compliance, Fame

If your school participates in Title IV federal student aid, you’re required to give students, families, and staff accurate, timely, and accessible information about your programs, costs, and policies. This isn’t a “nice to have”, it’s a legal obligation rooted in the Higher Education Act of 1965, and the penalties for getting it wrong are steep: up to $67,544 per incident for missed general disclosures, security reports, athletic program data, or FERPA notices.

The good news? Consumer information compliance is entirely within your control. It just requires the right structure, the right people, and a regular review cycle.

Here’s a look at what career schools need to have covered, and why it matters more than ever.

 

Why Consumer Information Compliance Matters

Beyond avoiding fines, strong consumer information practices build trust. When prospective students can easily find your costs, outcomes, and policies, they make better-informed decisions and they’re more confident choosing your school.

When current students know exactly where to go for financial aid rights, campus safety information, or grievance procedures, your staff spends less time fielding preventable questions and complaints.

In short: clear disclosure isn’t just about compliance. It’s good business.

 

What Your Website Needs

The Department of Education requires that consumer information be prominently displayed and accessible without a password and pass the “three click” rule, i.e. a person must find the content within three clicks. That means your site needs clearly labeled, easy-to-find sections covering:

• General institutional information: your net price calculator, accreditation status, state approvals, and academic programs
• Cost transparency: every time you mention a program, you’re required to mention its cost
• Financial aid information: eligibility, application procedures, disbursement methods, loan terms, and repayment options
• Professional judgment availability: schools must now proactively advertise that professional judgment exists for unusual or special circumstances — and can no longer have a blanket policy against it

 

Campus Safety, Title IX, and Athletics

If your school hasn’t reviewed its Annual Security Report (Clery Act) lately, now is the time. It’s due no later than October 1st— not the next business day if that date falls on a weekend, but no later than October 1st, period — and it must reach every student, faculty member, and staff member, not just financial aid staff. The report includes crime statistics, emergency response procedures, and (if you have campus housing) fire safety and missing person policies.

Schools with athletic programs also need an Equity in Athletics Disclosure (EADA) report, and every institution needs a clearly stated Title IX non-discrimination policy, grievance procedure, and coordinator contact information.

 

The Financial Aid Landscape Just Changed

This is the area where schools are most likely to have outdated information sitting on their website or in their catalog. With loan changes effective July 1, 2026, schools need to update disclosures to reflect:

• Reduced loan amounts for certain programs
• Parent PLUS loan reductions, capped at $20,000 per student per year
• Elimination of Grad PLUS loans
• New loan intensity rules for credit-based, term-based programs
• New, simplified loan repayment options
• – Workforce Pell requirements, for schools moving into that space

If your financial aid information still reflects last year’s numbers, it’s time for a refresh.

 

Beyond the Basics: FERPA, AI, and Accessibility

A few other areas deserve attention:

FERPA notices must go out to students annually, and if your materials still reference the “Buckley Act,” it’s time to update that language; it hasn’t been called that in decades.

AI policies are quickly becoming a compliance essential. Schools should have clear guidance on how AI can and can’t be used by students and staff.

Accessibility information must be accurate and specific. Vague or inaccurate claims about accessibility can create real legal exposure. Schools are expected to clearly state what accommodations are and aren’t available.

 

Making Compliance Manageable

The schools that stay compliant year after year tend to do a few things consistently:

1. Maintain a centralized consumer information webpage with clear headings and links
2. Coordinate an annual review across financial aid, the registrar, institutional research, and student services
3. Delegate ownership of updates to a specific person, with a deadline
4. Use version control so you can show what changed and when
5. Document notification methods so you can prove students received required disclosures

None of this requires reinventing your process, it simply requires consistency and the right internal ownership.

 

Where This Leaves You

Consumer information compliance touches nearly every department at your school: financial aid, admissions, the registrar, and institutional leadership all have a role to play. Getting it right protects your school from costly penalties, but just as importantly, it builds the kind of transparency that earns student trust.

In the next post in this series, we’ll walk through a compliance checklist you can use as a starting point for your own internal review.

Have questions about how your school’s consumer information practices stack up? Fame’s consulting team can help you identify gaps before they become findings.

The content provided on this page is for general informational purposes only and is not intended to be legal advice. You should consult a licensed attorney for advice regarding your specific situation.