Jun 19, 2018, 11:32 AM

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Dear FERPA Professor,

We occasionally have applicants that make claims with their payment card companies that the fees they have paid to our institution are “fraudulent charges.” Typically, these are applicants who are not accepted.  When this occurs, our institution either has to let the payment card company refund the charge to the applicant or try to fight it.  In trying to fight it, we are required to supply proof that the charge is linked to the applicant.  Are we allowed by FERPA to provide the applicants application packet to a payment card company as part of our “compelling evidence showing a link between the person receiving the goods/services and the card holder?” 

Thank you,
Nat Eural
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Dear Nat,

Information submitted by an applicant applying to an institution is not an education record if the applicant does not become a student by attending the institution. Thus, the applicant-furnished records would not be subject to FERPA and FERPA would not prohibit the institution from disclosing them to any party.  You can find the FERPA definition of "attendance" on page 152 of the 2012 AACRAO FERPA Guide and of "student" on page 155.  Keep in mind, however, that State law may limit the institution's ability to disclose applicant records.

I hope this is helpful in answering your question.

The FERPA Professor

AACRAO members can send questions for the FERPA Professor to connect@aacrao.org.

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