UC Comment Letters

This comment letter responds to the U.S. Department of Education's proposed information collection requirements for implementing Section 117 of the Higher Education Act (HEA) regarding disclosure of foreign gifts and contracts. The University of California (UC) supports transparency in foreign relationships but expresses concern that the proposed requirements substantially exceed the statutory requirements of Section 117, impose significant administrative and compliance burdens, raise privacy and confidentiality concerns, and introduce unclear reporting obligations. UC recommends scaling back the proposal, clarifying key definitions, protecting confidential information, maintaining the existing reporting threshold, and pursuing implementation through a more robust rulemaking and stakeholder engagement process.