Federal regulation change leads to DASH policy adjustment

by Pierce Wilson | 2/25/20 2:00am

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Students will no longer be able to spend money on their DASH accounts without preloading money first.

by Naina Bhalla / The Dartmouth Senior Staff

Earlier this month, Campus billing and DartCard services announced via email that as of March 16, students will no longer be able to overdraft their DASH Discretionary accounts. Currently, students are able to overdraw up to $100 on this account without the transaction failing. 

Going forward, all purchases and transactions made using the DASH Discretionary account will have to be made via prefunded deposits, which can be deposited online via the GET website.

According to director of campus billing and DartCard services Kathryn Page, the changes to DASH were made in compliance with a federal policy called Regulation E. Regulation E is a set of rules established by the Federal Trade Commission to carry about the Electronic Funds Transfer Act.

“While the DartCard currently allows students to overdraw their accounts up $100 before declining transactions, Reg E requires financial institutions to obtain affirmative consumer consent if an overdraft is permitted and if there are any fees or costs associated with that overdraft,” Page said. “So, really this is about consumer protection.” 

Page said that Dartmouth falls under a ‘lite’ form of the regulation because it provides an electronic fund transfer service while not holding a consumer’s account. She explained that this ‘Reg E Lite’ refers to the fact that the DASH allows students to access funds by prefunding money onto DartCard through the GET system but does not actually access student’s or parent’s bank accounts. 

Page said that there was recently a change in Regulation E legislation that caused Dartmouth to change the DASH policies. 

“What we can’t allow students to do anymore is use it as kind of like a credit card,” she said. The practice of allowing students to go into the red is, according to Page, is no longer permitted by the federal government. She added that campus billing and DartCard services will begin mailing out disclosure statements to students similar to how a real credit card agency would. 

Page also explained that her office chose March 16 as the effective date for changes in an attempt to be sensitive to student needs and stress. She said she hopes that students who rely on the overdraft feature will be able to complete the term and final exams without worrying about prefunding their accounts or coming up with that money. 

Page also said that although students use their DartCards to make purchases at Collis Market and at vending machines around campus, the changes should not affect food insecurity on campus. 

“Although we have to do this for regulation, it’s not keeping a student from eating on campus, as DDS charging is still possible,” Page said. She said that Regulation E does not apply because DDS charging does not fall under the umbrella of a prefunded card, but under the umbrella of a university meal plan, which is subject to different regulations. 

According to Page, in order to assist with laundry, the Office of Residential Life may be installing machines in laundry rooms around campus that accept debit cards. This way, students will have the choice between quarters, prefunded DASH and their own debit card for the cost. 

Additionally, DartCards will retain the $20 GreenPrint allowance, which is factored into tuition. However, if a student spends more than $20 on printing in one term, the transaction would go DASH and would need to be prefunded. 

According to Page, the current overdraft policy caused much confusion among students and parents, and limited transaction to preloaded funds should make the process clearer.

Page stressed that this policy comes from regulations outside of Dartmouth’s control, and there is not much her office can do in terms of reversing it.

“We had no choice,” she said. “Campus billing heard from Dartmouth’s general counsel exactly what we had to do.” 

The day after the changes to DASH were announced, Student Assembly began circulating a link to a Google Forms survey about the policy via email and GroupMe. The survey asked students to provide feedback on the changes, with the option for respondents to respond anonymously. 

Student Assembly president Luke Cuomo ’20 said that Student Assembly sent out the survey out of concern for how the new policy might impact low-income students. Cuomo hopes to present the responses to the administration. As of press time, Cuomo said that around 350 students had responded to the survey.

“We remain concerned about the perhaps unintentional effects and difficulties the new policy places on students, and we are committed to exploring ways in which perhaps there can be new changes or opportunities made available to students who do need financial flexibility that is not currently provided,” Cuomo said. 

According to Cuomo, a majority of the student responses so far oppose the changes. Cuomo also expressed concern that these changes, which affect the student body, were not run by Student Assembly before being announced. He added that he feels as though the explanation offered in the email from campus billing was less than adequate. 

“I’d also think changes that take effect and changes that affect the student body at large should be well explained to the student body before they take place,” Cuomo said. “I think that is also part of the issue — that many students do not understand the reasoning behind the changes, and that kind of opaque nature of policymaking can sometimes engender a negative personal response.” 

Diego Perez ’23 said that he felt blindsided by the policy when he first received the notice in his inbox. Perez said it was wrong for the College to change a policy that many students rely on for laundry.  

“I feel like it’s going to affect low-income students the most, because they do rely on being able to overcharge it overdraft,” Perez added. “To make purchases either at the Collis Market or for laundry I never think of, ‘No, I’m gonna have to pre-load my DASH account.’ I just know that I can swipe it and then at the end is going to be charged to me once I have all the money for tuition.”

Perez also suggested a potential solution to the financial flexibility problems presented by the new policy.

 “I think that $100 charge at the beginning of the term would be better, instead of just running an overdraft, because we already know that we have $100,” he said. “So instead, if we pay for that $100 upfront, then we still have $100 throughout the term that we can use.”

Cuomo emphasized that the policy is still a major concern for Student Assembly. 

“Regardless of the origin and the reasoning for these changes, the fact is that it is a concern for some students and that is something that we have to address,” he said. “The comments we’ve collected from the student to the administration really sheds a lot of light on the concrete effects of this policy change will have on the daily lives of a lot of students.”