Abstract
EDUCAUSE joined with the Association of Research Libraries (ARL) to submit comments to the U.S. Department of Education regarding its February 2023 guidance on third-party servicers (TPSs). The EDUCAUSE and ARL submission provided examples from colleges, universities, and research libraries of the problems created by the TPS guidance, as well as the negative effects likely to arise from those problems if the department declined to rescind and revise its guidance. Areas discussed include the ban on foreign owned and/or located TPSs, instructional content, student retention, and general compliance burdens.