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| 9 it. And, thus, that's the way it was. Plus, they
10 didn't know how and what kind of job to get. 11 So this whole effort to undo what we have 12 already paid to have done, that is a rules -- rules that 13 level the playing fields for our children and our young 14 students so that they don't spend a lifetime in debt, 15 it's ridiculous. I'm not trying to be rude to you all, 16 but it is ridiculous. And if you are in a position 17 that's not new to the Department, you've already been 18 through this, so it must feel like déjà vu. 19 Also, the use of arbitration as a 20 requirement in these education loans is so ridiculous 21 and expensive and requiring a certain expertise that you 22 have to hire a particular attorney with that training. 23 Also, the arbitrator, who is the judge -- 24 MR. MARTIN: Time. 25 MS. McGOVERN: -- is hired by the parties. 
1 The people who use arbitration frequently are in 2 arbitration all the time, so who's paying the judge? 3 The person you're going against, if you are a student. 4 Thank you for your com -- thank you for 5 your courtesy, and I would urge you to not continue with 6 this proposed negotiated rulemaking. 7 MR. MANNING: Thank you for your comments. 8 MR. MARTIN: Our next speaker is Jerry 9 Valdez. 10 MR. VALDEZ: It's like following the 11 preacher on Sunday morning. Good morning. My name is 12 Jerry Valdez. I serve as the executive director of 13 Career Colleges and Schools of Texas, which is the 14 largest organization and association representing the 15 nearly 150,000 students enrolled in private-sector 16 colleges and universities in the great state of Texas. 17 We appreciate this opportunity. First and perhaps 18 foremost, we appreciate the opportunity of your coming 19 to Texas. It is a gesture that we don't take for 20 granted and very much appreciate, and we appreciate the 21 opportunity to provide commentary. 22 Our organization represents, as I 23 mentioned, approximately 150,000 students enrolled, and 24 we provide both degree-granting and non-degree-granting 25 training and education for our graduates, and we employ
1 more than 250 occupation fields in Texas and beyond. We 2 have a significant impact on the Texas economy, and, in 3 many cases, our graduates are first generation in their 4 families to cross the stage and graduate and that 5 become very proud and accomplished Texans with a first 6 taste of academic success. 7 We commend the Department for accommodating 8 the request in providing input. In past years, CTST has 9 struggled with a rather politically driven and 10 retaliatory approach to regulations by the Department. 11 Such outreach efforts, including your trip to the Lone 12 Star State, is very welcomed and an incredible gesture. 13 Ultimately, we seek regulations that are 14 fair and balanced to everyone. I will speak 15 predominantly on Borrower to Defense -- Borrower to 16 Defense Repayment issue and let last -- or, I guess, 10 17 days ago, the delay by the department on the 18 implementation of Gainful Employment speak for itself 19 with regards to the issues that occurred there. 20 So, specifically, with Borrower Defense to 21 Repayment, we seek a concise definition and applicable 22 instances that are very clear. Such regulations should 23 have a clear process for students and not have barriers 24 for students being able to make claims, also, while 25 containing a clear process for the institution to
1 respond and seek an immediate resolution that isn't 2 drawn out for months, if not years. A quick resolution 3 is very important to our universities and colleges, 4 owners, and operators. 5 Additionally, previous consideration has 6 been given to accept claims by groups and not by 7 individuals. This is a very significant concern on our 8 behalf and one that we would stand strongly in 9 discouraging the Department from considering. Claims 10 should not be stacked or widely and aggressively 11 solicited with promises of favorable outcome. It's very 12 important that the regulations are limited to their 13 intended purpose and not so broad that they lose meaning 14 or could be scrupulously taken advantage of by 15 plaintiff's attorneys. There has been a regrettable 16 history of this occurring, not only in our state but 17 across the nation. 18 Thank you again, gentlemen, for the 19 opportunity to share our views on the proposed 20 regulation and thank you for your outreach, again, in 21 your visit to Texas. Look forward to working with you 22 to achieve common goals for the regulations that are 23 being considered and, again, seek them in a way that is 24 fair and balanced to both the student and to the 25 institution. Thank you very much.
1 MR. MANNING: Thank you. 2 MR. MARTIN: Our next speaker is Adrian 3 Shelley. Adrian Shelley. 4 I will point out that we do have a few 5 unscheduled blocks here, so Ms. Shelley -- Mr. Shelley, 6 rather, is not scheduled to speak until 10:00. So what 7 I would do -- I'm going to ask if -- is Nicole 8 Hochsprung, did she arrive? 9 Okay. We do have some people that we know 10 are here who are scheduled to speak for the -- in the 11 afternoon. I'm not trying to put any pressure on you. 12 If you want to keep your afternoon slot, that's just 13 fine. We're absolutely fine with that. The 14 afternoon -- the situation we're in here is that we have 15 no further speakers scheduled until 1:00, and at 1:00, 16 we have a fairly full agenda, so I'll ask -- I'll 17 start -- and I hate to put people on the spot like this. 18 Actually, I don't. I enjoy it. Let's start with 19 Mr. John White. Is he here? 20 MR. WHITE: Yes, sir. Directory: policy -> highered -> reg -> hearulemaking policy -> American bar association adopted by the house of delegates policy -> The Threats of policy -> 2nd Quarter 2010 policy -> Nato unclassified north atlantic treaty organisation policy -> Department of the Navy Office of the Assistant Secretary (Research, Development and Acquisition) Washington, dc 20350-1000 navy marine corps acquisition regulation supplement policy -> Policy Manual June 2015 policy -> Executive summary Download 5.96 Mb. Share with your friends:
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