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| 15 In Monday's hearing in Washington D.C., a
16 representative from the proprietary school sector noted 17 how the organizations that support the Borrower to 18 Defense and Gainful Employment rules regularly cite ITT 19 Tech and Corinthian, even though those schools are no 20 longer in business. The veterans I have quoted, 21 however, all go to schools that are still in business. 22 Moreover, VES continues to be contacted by 23 plenty of veterans who have had similar issues in 24 schools that still operate. While ITT and Corinthian 25 are, thankfully, no longer around, their business model 
1 lives on. Veterans regularly describe to VES aggressive 2 and misleading marketing techniques that various schools 3 use. They describe misrepresentations that schools make 4 about the cost of their education, whether their credits 5 will transfer to other schools. 6 Some describe bait-and-switch tactics that 7 schools use where schools say one thing about the degree 8 requirements when they enroll students, but tell 9 students something different later on, adding to the 10 debt the students must incur. Many also describe how 11 schools make promises about their job prospects upon 12 graduation, but promises that do not bear out, leaving 13 student veterans with no remaining GI Bill and, in many 14 cases, student loan debt that they have no ability to 15 pay. 16 On top of everything else, typically, 17 because of mandatory arbitration clauses, these students 18 are denied access to justices in the courtroom. 19 Meanwhile, veterans who are currently 20 contemplating going to career colleges have the 21 limited -- have limited ability to adequately compare 22 such schools. As a prospective law student, I was able 23 to compare how graduates from different law schools 24 fared at finding jobs and their average starting 25 salaries. It shouldn't be too much to ask the same for
1 other career-focused schools, particularly when you 2 derive so much of the revenue from American taxpayers. 3 Strong career schools should welcome this 4 requirement, given that it will provide them with a tool 5 to better compete against weaker schools. In turn, this 6 should lead to more students and more revenue for good 7 schools, outweighing any associated administrative 8 expense. 9 Veteran organizations have already 10 expressed many of these concerns in writing to the 11 Department of Education. Earlier this year, VES and 30 12 other military and veteran organizations asked the 13 Department to implement the Borrower to Defense rule and 14 to act on the thousands of Borrower to Defense 15 applications pending before the Department, including 16 many that are from veterans. 17 VES has also asked to meet with this 18 Department concerning patterns of fraud towards student 19 veterans that it has identified at certain schools that 20 still exist. None of these requests have been met, nor 21 has this Department continued the regular meetings that 22 the previous Department held with veteran organizations. 23 This lack of support for veterans is beyond 24 disappointing. Nevertheless, we hope and ask that the 25 Department establish a meaningful dialogue with veteran
1 organizations by including them in defrauding student 2 veterans on both of its negotiating committees. 3 Veterans need a government that will stand up for them, 4 just as they stood up for their country. When they 5 leave the Service and are told that their military 6 experience doesn't translate to the civilian world or 7 simply want to add to their knowledge and skill set, 8 they need schools that see them as more than dollar 9 signs. They need schools that respect their service, 10 recognize their talent and drive and truly prepare for 11 their next phase of their life so they can continue to 12 lead at home, just as they did in the uniform. Thank 13 you. 14 MR. MANNING: Thank you. I might also just 15 add that we have offices at the Department that are 16 willing and ready to work with veterans, and I'll put 17 you in touch with them. 18 MR. MARTIN: Is Adrian Shelley here? 19 MR. SHELLEY: Good morning. Thank you for 20 the opportunity to deliver comments today and welcome to 21 Texas. 22 MR. MANNING: Thank you. 23 MR. SHELLEY: My name is Adrian Shelley. 24 I'm the Director of the Office of Public Citizen in 25 Texas. Public Citizen is a nonprofit consumer
1 organization headquartered in Washington D.C., and we 2 were deeply involved in both the development and legal 3 defense of the Borrower Defense rule and the Gainful 4 Employment rule. We also delivered comments in 5 Washington on Monday, and our comments will be submitted 6 in writing as well. 7 The adoption of both of these rules was an 8 important step in the crackdown on predatory schools, 9 most of those schools being clustered within the 10 for-profit industry. These schools rely on federal 11 student aid and fleece their students with low-value 12 educations. Some of these schools essentially rely on 13 fraud as a business model, to the detriment of their 14 students and to the taxpayers who fund student aid 15 programs. 16 The Department is taking a shameful step 17 backwards here by initiating a new negotiated rulemaking 18 to revisit these rules and by unlawfully delaying key 19 provisions in the meantime. Texas has students who are 20 going to pay the price for these delays, as do other 21 states around the nation. 22 I want to focus, though, in particular, on 23 the continued need for arbitration and class-action 24 waiver provisions in the Borrower Defense rule. I am 25 going to refer to an example from ITT Tech, and although
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