- In order to comply with the 90/10 rule, Corinthian made sure that the cost
of attending its schools was high enough that students would not be able to pay solely
through using Title IV aid.
- In September 2011, Corinthian’s CEO distributed a presentation to his
executive team, describing efforts by Corinthian to meet the requirements of the 90/10
rule by instituting “above market price increases to create ‘funding gaps.’” By increasing
tuition, Corinthian caused students, who otherwise would have been able to pay for the
entire cost of tuition through Title IV aid, to take out private student loans in order to
maintain 90/10 compliance. Regardless of whether students were able to repay the
private student loans, Corinthian would profit from the increased availability of Title IV
monies.
- In or about Spring 2011, for example, Corinthian increased tuition at
Heald College by 14% to ensure that the school received additional non-Title IV funds in
order to meet 90/10 requirements.