Noncompliance with the DMCA could cause the institution to lose its protection under the DMCA Safe Harbor provision for internet service providers and subject the college to significant monetary fines and potential legal action.


Because the reporting and disclosure requirements of the HEOA are linked to an institution’s participation in the Title IV federal student financial aid programs, the Secretary of Education is authorized to take administrative action, including the imposition of fines, against institutions that do not comply. The most severe penalty the Department of Education could impose for failure to comply, however, is a limitation or termination of the institution’s participation in the Title IV financial aid programs.