2 unchanged sentences
There have been no material changes to the risk factors previously described in Part I, "Item 1A.
−Removed: Risk Factors" included in our Annual Report on Form 10-K for the year ended December 31, 2020, other than the revised risk factor included below.
+Added: Risk Factors" included in our Annual Report on Form 10-K for the year ended December 31, 2020, other than the revised risk factors included below.
The risks described in our Annual Report on Form 10-K are not the only risks facing the Company.
17 unchanged sentences
If such legislation were to be enacted, and the Universities were unable to meet the threshold, loss of eligibility to enroll students in certain states would have a material adverse effect on our business.
+Added: If Strayer University and Capella University fail to comply with the extensive legal and regulatory requirements for higher education institutions, they could face significant monetary or other liabilities and penalties, including loss of access to federal student loans and grants for their students.
+Added: As providers of higher education, Strayer University and Capella University are subject to extensive laws and regulation on both the federal and state levels and by accrediting agencies.
+Added: In particular, the Higher Education Act and related regulations subject Strayer University, Capella University, and all other higher education institutions that participate in the various Title IV programs to significant regulatory scrutiny.
+Added: The Higher Education Act mandates specific regulatory responsibilities for each of the following components of the higher education regulatory triad:
+Added: (1) the federal government through the Department of Education;
+Added: (2) the accrediting agencies recognized by the Secretary of Education;
+Added: and (3) state education regulatory bodies.
+Added: In addition, other federal agencies such as the Consumer Financial Protection Bureau, Federal Trade Commission (“FTC”), and Federal Communications Commission and various state agencies and state attorneys general enforce consumer protection, calling and texting, marketing, privacy and data security, and other laws applicable to post-secondary educational institutions.
+Added: Findings of noncompliance could result in monetary damages, fines, penalties, injunctions, or restrictions or obligations that could have a material adverse effect on our business.
+Added: Some of these laws also include private rights of action.
+Added: On October 6, 2021 the FTC announced that it is resurrecting Penalty Offense Authority under Section 5(m) of the FTC Act (the “Act”).
+Added: Under the Act, the FTC may secure penalties against entities not a party to an original proceeding if the FTC can show that the entity had actual knowledge that the conduct in question was found to be unfair or deceptive.
+Added: Also on October 6, 2021, in an effort to establish actual knowledge and create a pathway for penalties in the event of post-notice acts or practices, the FTC issued notice to the 70 largest for-profit schools, based on enrollment and revenues.
+Added: The notice included a list of acts and practices that the FTC has determined are unfair or deceptive, including but not limited to acts relating to misrepresentation of employment opportunities and other benefits, together with citation to various prior determinations from cases previously litigated by the FTC.
+Added: Strayer and Capella University received the FTC’s notice on October 7, 2021, although the FTC made clear that receipt of the notice itself does not reflect any assessment as to whether Capella or Strayer has engaged in deceptive or unfair conduct.
+Added: The laws, regulations, standards, and policies applicable to our business frequently change, and changes in, or new interpretations of, applicable laws, regulations, standards, or policies could have a material adverse effect on our accreditation, authorization to operate in various states, permissible activities, ability to communicate with prospective students, receipt of funds under Title IV programs, or costs of doing business.
+Added: The Department of Education periodically engages in negotiated rulemaking sessions to revise regulations that govern the federal Title IV student financial aid programs.
+Added: As discussed above in “Current Negotiated Rulemaking” the Department of Education has convened negotiated rulemaking committees to address issues such as borrower defense to repayment, mandatory arbitration agreements, gainful employment rules, and federal government oversight into changes in ownership for institutions of higher education.
+Added: Certain proposals related to these issues could raise the cost of compliance for Strayer University or Capella University.
+Added: We cannot predict whether the Department of Education will promulgate any regulations that would negatively affect Strayer University or Capella University.
+Added: Title IV requirements are enforced by the Department of Education and, in some instances, by private plaintiffs.
+Added: If Strayer University and Capella University are found not to be in compliance with these laws, regulations, standards, or policies, they could lose access to Title IV program funds, which would have a material adverse effect on the Company.
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.