Truth in Lending Act Disclosure Statements (TILs)

This is a legal compliance issue for any school entering into enrollment contracts where payments occur more than a month after the contract is signed or in terms such as monthly or two-pay, with or without deferred payment fees.- Admin edit- This idea is specifically to show the TIL for Tuition Management customers. There is a separate (but very similar idea) to show the truth in lending disclosure for enrollment management customers if you'd like to vote for that. K12OB-I-2426

  • Erin Summers
  • Aug 26 2022
  • Under consideration
  • Attach files
  • Erin Summers commented
    31 Aug 01:13am

    Hi Sarah,

    We need to be able to report on net tuition - so financial aid is also important - and the payment plan terms must be represented. Right now we are downloading all of these elements and running macros into a template in Excel to produce TILs and emailing them to families. What we are looking for is a formatted, legally-compliant TIL report from Tuition Management that is auto-generated and sent to families once the contract is accepted and integrated into the system. I believe that a TIL can currently be generated by the system, but it does not take into account the proper elements for a fully compliant TIL. The ability to add our own clarifying language to the format (as shown on the second page of the attachment) is also needed.


    Thank you!



  • Admin
    Sarah Bienvenue commented
    31 Aug 12:24am

    Hi Erin, while we strive to offer the correct tools for our schools to be able to make their contracts legally compliant, and we do check in with our legal team, it is still up to our schools to check with their own lawyers to make sure that the legal language and inclusions that they're adding to their contracts passes their own state and local legal requirements.

    What we're hoping to provide you, is the ability for you to provide your own required legal language that would have placeholders that would allow you to tailor the specifics for each of your students. Based on what you're saying here I can see the need for: tuition amount, cost of tuition refund insurance, and fees. If there are others that I am missing, please let me know.

    Thank you,

    Sarah

  • Erin Summers commented
    30 Aug 01:46pm

    Hi Sarah,

    Hopefully Blackbaud's legal/compliance department can provide the required parameters for development of the TIL. I'm not a lawyer nor would I want to opine on all requirements to be legally accurate. We've been manually creating TILs since Tuition Management cannot produce these. Attached is an example of a generic TIL we provide as an overview prior to contract signing, but we then have to tailor this to the specifics of each student to include financial aid and adjustments for cost of tuition refund insurance and deferred payment fees.


    Thanks,

    Erin

  • Admin
    Sarah Bienvenue commented
    29 Aug 11:09pm

    Hi Erin, can you tell me more what what specifically you would want to see/need for a TIL disclosure to be legally accurate? I'm assuming that you'd need specific placeholders?

    Thank you,

    Sarah