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The September 23, 2019, Department of Education borrower defense to repayment regulation amended financial responsibility requisites by updating definitions, terminology, and reporting for non-profit and proprietary institutions. Most notably, the new rule added several mandatory reporting requirements that must be addressed either in either general purpose or single audit financial statements.

A recent NACUBO Town Hall explained several ambiguous financial responsibility rules and offered guidance concerning notes to the Uniform Guidance (single audit) financial statement package that comply with the regulation and a recommended format for the mandatory financial responsibility supplemental schedule. The program also covered—

  • Interpreting and completing eZ-Audit templates
  • Non-operating gains and losses including ratios impacted, aggregating spending and net return for funds functioning as endowments, and assessing investment and defined benefit plan gains or losses for inclusion with the appropriate ratio components
  • Understanding the transition election for leases and how to accurately reflect lease information
  • Identifying, disclosing, and reporting pre-and post-implementation debt obtained for long-term purposes
NACUBO Financial Responsibility tutorials provide more detailed explanations and tools to help institutions grasp the concepts and report required information.


Sue Menditto

Senior Director, Accounting Policy


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