Good morning,
Our Student Account Services office has asked if they are permitted to give financial information to 3rd party payers under FERPA. Financial information is not listed as directory information, but I am unsure if it is even covered under FERPA. I read there is no consent required for “financial aid” needs, but I didn’t see anything from a Student Accounts side (i.e. the office where students or 3rd parties may submit tuition payments). Any guidance you may have is appreciated.
Thank you,
Beth Toven
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Dear Beth,
Student account information maintained by the institution would be education records subject to FERPA. This information cannot be "directory information" under FERPA and generally any disclosure would require a signed consent from the student. However, as you noted, one of the exceptions to signed consent is the financial aid exception. See §99.31(a)(4) of the FERPA regulations. You can find this language on page 160 of the 2012 AACRAO FERPA Guide. Whether or not you could disclose under this exception depends on the conditions contained on the application for the aid signed by the student. Such conditions would ordinarily provide for the disclosure of any information necessary for the payment of funds associated with the financial aid. Otherwise, if a third party payer such a family member, for example, wants financial information on the student, this disclosure would generally require a signed consent from the student or to meet one of the other exceptions to signed consent found in §99.31.
I hope this is helpful in responding to your inquiry and hope you had a wonderful holiday season.
Sincerely,
The FERPA Professor
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