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
  • Shannon Krise commented
    22 Jan 17:11

    In terms of placeholders, here are the ones I know we need:

    • Total of tuition (minus financial aid awarded)

    • Balance of tuition after the deposit due with the contract has been paid (amount financed)

    • Number of payments

    • Amount of payments

    • Due date

    • Range of plan tuition months.

    • We also include more obvious things like the student's name, year, and grade.


    There are additional required elements that would not be pulled from the contract (annual percentage rate, finance charge, total of payments including any finance charges.) In our case these are all 0, so we wouldn't need additional placeholders, but some schools may need at least the ability to calculate the tuition balance + finance charges if the form will be automatically produced.

  • Erin Summers commented
    August 31, 2022 01:13

    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!



  • Sarah Bienvenue commented
    August 31, 2022 00:24

    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
    August 30, 2022 13:46

    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

  • Sarah Bienvenue commented
    August 29, 2022 23:09

    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