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BPPE seeks committee feedback on catalog disclosure updates and unapproved-activity fines
Summary
BPPE staff asked the advisory committee for feedback on proposed updates to catalog disclosure requirements to improve clarity and student access to records, and outlined proposed regulations to set a $10,000-$100,000 fine range and factors for unapproved activity enforcement.
BPPE staff asked advisory committee members for feedback on potential amendments to catalog disclosure requirements and presented draft regulatory language designed to clarify fines and factors for institutions operating without bureau approval.
Parker Strohmeyer, the bureau's regulations specialist, said catalog disclosure rules (regulatory section 71,810 and Education Code section cited in materials) date largely from 2010 and may require specificity and reorganization so catalogs more clearly explain how students access records, services and visa-related support.
"Subsection b15 requires disclosure of the institution's policies on the retention of student records, but it doesn't require the institutions specify how students may access those records," Strohmeyer said. He invited committee feedback on adding required contact points or procedures in catalogs and on streamlining items that are rarely applicable, such as dormitory information for institutions that do not offer housing.
On unapproved activity, Deputy Bureau Chief Elizabeth Elias said the bureau has cited more than 80 institutions for operating without approval over four fiscal years and that proposed regulations would establish a minimum citation amount and a transparent set of aggravating and mitigating factors for fine calculation. "The proposed regulatory changes provide clearer guidelines for the assessment of fines," Elias said, noting the bureau proposes a minimum fine of $10,000 and a maximum of $100,000 and would list aggravating factors such as harm to students and prior knowledge of the bureau.
The proposed unapproved-activity language conforms citation authority to changes enacted in 2022 (Senate Bill 1433) and further specifies how refunds ordered to students are treated separately from fines. The bureau said both the refund-policies and expired-approval packages have been noticed for public comment and that the unapproved-activity package will be refined with stakeholder input.
Ending: Committee members endorsed the examples Strohmeyer provided, asked a checklist question that staff said would be answered, and requested additional detail on housing disclosures for third-party arrangements; bureau staff said an updated checklist would be published imminently and invited written comments through the public-comment period.
