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, 2021, 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, 2021, other than the revised risk factors included below.
The risks described below and in our Annual Report on Form 10-K are not the only risks facing the Company.
8 unchanged sentences
The legislation requires the Department to conduct a negotiated rulemaking process to modify related Department regulations, which was considered by the Institutional and Programmatic Eligibility negotiated rulemaking.
−Removed: Meetings of this negotiated rulemaking committee occurred January-March 2022.
−Removed: This rulemaking process may result in a definition of “federal education assistance” that will include tuition assistance programs offered by the U.S.
+Added: Meetings of this negotiated rulemaking committee occurred January-March 2022, the Department issued and received public comments on the proposed rule in July-August 2022, and the Department of Education released final 90/10 regulations on October 27, 2022.
+Added: The final regulations may result in a definition of “federal education assistance” that will include tuition assistance programs offered by the U.S.
Department of Defense and U.S.
Department of Veterans Affairs, in addition to the Title IV programs already covered by the 90/10 Rule.
−Removed: Under the legislation, these revisions to the 90/10 Rule would apply to institutional fiscal years beginning on or after January 1, 2023.
+Added: These revisions to the 90/10 Rule will apply to institutional fiscal years beginning on or after January 1, 2023.
Further legislation has been introduced in both chambers of Congress that seek to modify the 90/10 Rule further, including proposals to change the ratio requirement to 85/15 (federal to nonfederal revenue).
30 unchanged sentences
The CFPB subsequently sent a letter on July 8, 2022, indicating that it believed the withholding of transcripts was a violation, and requiring the Company to cease withholding transcripts for those with an outstanding balance and to take other remedial actions.
−Removed: The Company had already discontinued its historical practice prior to the CFPB’s notice, and intends to complete the remedial actions in the allotted thirty days.
+Added: The Company had already discontinued its historical practice prior to the CFPB’s notice, and informed the CFPB that it completed the remedial actions in the allotted thirty days.
On April 26, 2022, the CFPB informed the Company that it intended to conduct an announced education loan exam in June 2022.
−Removed: the examination started on June 13, 2022 and the CFPB has indicated that it is expected to last into August.
+Added: The examination started on June 13, 2022.
+Added: Fieldwork concluded on August 5, 2022, but the examination is ongoing.
+Added: On September 12, 2022, the CFPB informed the Company of a preliminary finding related to a product that is no longer utilized, and invited the Company’s response.
+Added: The Company timely responded to the CFPB’s letter, disagreeing with the preliminary finding and noting that the product to which it related is no longer utilized.
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.
4 unchanged sentences
Title IV requirements are enforced by the Department of Education and, in some instances, by private plaintiffs.
−Removed: If Strayer University and Capella University are found not to be in compliance with these laws, regulations, standards, or policies, they
−Removed: could lose access to Title IV program funds and face related monetary liability, which would have a material adverse effect on the Company.
+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 and face related monetary liability, 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.