The Bond Market Association (TBMA) provides comments to the U.S. Department of Education (Department) on interim final regulation released by the Department to implement changes based on recent amendments to made to the Higher Education Act of 1965, by the Higher Education Reconciliation Act of 2005 and other new laws, specifically, Sections 682.302 (e) and (f). TBMA is concerned the sections introduce legal uncertainty to the market for municipal bonds backed by Federal Family Education Loan Program loans.

*SIFMA is a product of the merger between the Securities Industry Association (SIA) and the Bond Market Association (TBMA) in 2006.