NACBA and NCLC recently submitted joint comments on the United States Trustee’s Notice of Proposed Rulemaking on Application Procedures for Approval of Providers of a Personal Financial Management Instructional Course.  While commending the UST for requiring mandatory and early disclosure of fee policies, the comments focused on other areas where additional changes or clarification was needed.  These areas included disclosure of fee waivers on websites, language barriers to course completion, mandatory reporting of 111(g)(2) actions, opposition to fees for certificates or replacement certificates and opposition to referral fees.  A copy of the comments is available on the NACBA home page.