Replacing UK PRIIPs: FCA Consults on Further Proposals for Consumer Composite Investments
The UK Financial Conduct Authority (FCA) has recently published a consultation paper (CP25/9) setting out further proposals on product information for consumer composite investments (CCIs), i.e., investments where the returns are dependent on the performance of or changes in the value of indirect investments.
Background
On 21 November 2024, the UK government enacted the Consumer Composite Investments (Designated Activities) Regulations 2024. This legislation enables the FCA to replace the Packaged Retail and Insurance-based Investment Products (PRIIPs) Regulation and the Undertakings for Collective Investment in Transferable Securities (UCITS) disclosure requirements that were introduced across the EU when the UK was a member state, with a new domestic framework (the Framework).
The FCA’s initial proposals for the Framework were set out in an earlier consultation paper, “A new product information framework for Consumer Composite Investments” (CP24/30), published in December 2024, which sought to create a more transparent, engaging and flexible disclosure framework for retail investors.
Following the closure of the consultation period for CP24/30 in March 2025 and in response to stakeholder feedback, the FCA has now published CP25/9, a second consultation paper focusing on consequential and transitional issues necessary to support the effective implementation of the Framework. The Framework will apply to products currently subject to the PRIIPs regime, as well as to UCITS funds, in each case where the investment is made available for distribution to retail investors. This will include overseas funds that benefit from the FCA’s Overseas Funds Regime (OFR), and other recognised schemes.
Key Proposals under CP25/9
The most notable proposals under CP25/9 are as follows:
Simplification of Transaction Cost Disclosures: The FCA proposes to remove the requirement for firms to calculate and disclose ‘implicit’ transaction costs (such as ‘slippage’ i.e., the difference between the price at which a trade is executed and the arrival price when the order to trade is transmitted to the market), which it views as complex and of limited value to consumers. Instead, firms will only need to disclose ‘explicit’ transaction costs (e.g., broker fees, exchange fees, and stamp duty), which are deemed easier to measure and for consumers to understand and compare.
Alignment and Rationalisation of Cost Disclosure Rules: CP25/9 proposes to align the cost disclosure requirements in the assimilated Markets in Financial Instruments Directive Organisation Regulation (MiFID Org Reg) with the new CCI rules. The FCA states that this will eliminate duplicative or conflicting requirements.
Transitional Provisions: The FCA outlines a transition period, allowing firms to continue using existing disclosure documents (such as PRIIPs key information documents (KIDs) or UCITS key investor information documents (KIIDs)) or to adopt the new CCI product summary at any point during the transition. The transition period is designed to give firms sufficient time to adapt to the new regime without undue complexity or disruption.
Consequential Amendments to the FCA Handbook: The consultation details the necessary changes to various FCA sourcebooks (including the Conduct of Business Sourcebook (COBS), Collective Investment Schemes Sourcebook (COLL), Investment Funds Sourcebook (FUND), and others) to reflect the replacement of the PRIIPs and KIID regimes with the new Framework. This includes updating terminology, cross-references, and removing obsolete provisions.
Complaints Handling for Unauthorised Firms: Unauthorised manufacturers and distributors of CCIs do not fall within the compulsory jurisdiction of the Financial Ombudsman Service (FOS). As a result, the FCA proposes to apply requirements on unauthorised manufacturers of CCIs (other than operators of OFR funds) to implement ‘reasonable and transparent’ complaints-handling procedures, ensuring that complaints raised by retail investors are dealt with without unreasonable delay and in a competent, diligent, and impartial way.
Enforcement and Supervision: The FCA confirms that its investigative and enforcement powers under the Financial Services and Markets Act 2000 (FSMA) (as amended by the FSMA (Designated Activities) (Supervision and Enforcement) Regulations 2024) will apply to both authorised and unauthorised persons carrying out CCI activities, designed to ensure robust oversight of the new regime.
Next Steps
The consultation period for CP25/9 closes on 28 May 2025. The FCA intends to publish a combined policy statement responding to feedback on both CP24/30 and CP25/9, with final rules in late 2025. In addition, the FCA anticipates that the new CCI regime will come into force for all firms at the same time, with the transition period and effective dates to be confirmed in a forthcoming policy statement.
CP24/30 and CP25/9 are available here and here, respectively.
Asia: MAS Consults on Retail Access to Private Market Investment Funds
On 27 March 2025, the Monetary Authority of Singapore (MAS) issued a consultation paper on a proposed regulatory framework to allow retail investors to access private market investments through authorised long-term investment funds (LIFs).
The main objective of the proposed LIF framework is to offer retail investors access to private market investments in a way that manages risk, contributing to a diversified investment portfolio. This MAS proposal follows similar initiatives in other jurisdictions, such as the UK and Europe, which have expanded the distribution of LIFs to retail investors.
Under the LIF framework, the MAS has identified two possible structures for a LIF:
(a) Direct Fund
A Direct Fund would offer investors with enhanced transparency regarding the fund’s underlying private market investment assets. Additionally, investors would have the opportunity to evaluate and select the private market investment manager they prefer to invest with.
(b) Long-Term Investment Fund-of-Funds (LIFF)
A LIFF structure would be advantageous for investors who want to leverage the LIFF manager’s expertise in selecting and overseeing the fund’s underlying private market investment funds. Additionally, a LIFF would offer diversification by investing in different underlying fund managers or different investment strategies, sectors, or geographic areas.
The MAS expects the two structures to have distinct regulatory safeguards. The public consultation, which is open until 26 May 2025, seeks comments and views on the regulatory requirements for each structure.
Effective Now: The Maryland Secondary Market Stability Act of 2025 Enacted and Codifies a New Licensure Exemption
The Maryland Secondary Market Stability Act of 2025 (the “Act”) was enacted and became effective as of April 22, 2025. The Act codifies a licensure exemption reversing guidance from the Maryland Office of Financial Regulation (“OFR”), which would have extended mortgage lender and installment lender licensure requirements to persons (including passive trusts) that acquire or are assigned residential mortgage loans or installment loans secured by properties in Maryland. For more background on this topic, see our previous alerts: Even Passive Trusts?!? Maryland Extends Mortgage Lender Licensure Requirements to Holders of Residential Mortgage Loans and Maryland Extends Lender Licensure Enforcement Deadline Amid Industry Pushback.
The Act provides that mortgage lender and installment lender licensure requirements do not apply to a person that acquires or is assigned a mortgage loan or installment loan, so long as that person does not:
otherwise make mortgage loans or installment loans,
act as a mortgage broker,
act as a mortgage servicer, or
directly service or collect on any installment loan.
See, e.g., Md. Code Ann., Fin. Inst. § 11-102(B) (effective Apr. 22, 2025). We note that the language of § 11-102 is only present in the Senate version of the companion legislation, however, both the Senate and House bills were enacted.
The Act also clarifies that the licensure requirements do not apply to a “passive trust.” “Passive trust” means a trust, established under the laws of Maryland or any other state, that: (1) acquires or is assigned mortgage loans in whole or in part, (2) does not make mortgage loans, (3) is not a mortgage broker or a mortgage servicer, and (4) is not engaged in servicing mortgage loans. See Md. Code Ann., Fin. Inst. §§ 11-501(P); 11-502(b)(13) (effective Apr. 22, 2025).
The Act provides a welcomed exemption and regulatory certainty in response to the upheaval following the Estate of Brown decision and subsequent OFR guidance. Secondary market participants should carefully evaluate whether their activities fall within the new exemption and stay informed of further developments in Maryland.
Maryland Enacts Law Exempting Passive Trusts from Mortgage and Installment Loan Licensing Requirements
In January 2025, the Maryland Office of Financial Regulation (the “OFR”) issued a guidance stating that assignees of residential mortgage loans, including certain passive trusts, were required to hold a Maryland mortgage lender license and, in certain circumstances, an installment loan license (previously discussed here). In response to this, the Maryland House and Senate passed separate but identical bills known as the Maryland Secondary Market Stability Act of 2025 (the “Act”). The Act was signed into law by Maryland Governor Wes Moore on April 22, and became effective immediately.
The Act addressed the OFR guidance on licensing for secondary market assignees by enacting an exemption from both the Maryland Mortgage Lender Law and the Maryland Installment Loan Law for “passive trusts.” The Act defines a “passive trust” as a trust that acquires or is assigned a mortgage loan but does not (i) make mortgage loans, (ii) act as a mortgage broker or a mortgage servicer, or (iii) engage in the servicing of mortgage loans. The original bills introduced in response to the OFR guidance would have exempted any assignee of mortgage loans or installment loans from licensing, including a trust, but the final Act more narrowly exempts only passive trusts.
Putting It Into Practice: The OFR’s guidance can now be considered abrogated, at least to the extent that it applied to passive trusts. However, secondary market purchasers of loans that do not use passive trusts to acquire or take assignment of residential mortgage loans in Maryland must become licensed as Maryland mortgage lenders by July 6, 2025. In addition, it is worth noting that the Act does not apply to loans made under the Maryland Consumer Loan Law, which provides that an assignee of a loan made under that law must hold a consumer loan license in order to enforce the loan.
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Fourth Circuit Rejects Rehearing in ACH Fraud Suit Alleging Violations of KYC Rules and NACHA Operating Standards
On April 22, the Fourth Circuit declined to reconsider a panel ruling that found a credit union could not be held liable for a scam in which fraudsters diverted over $560,000 from a metal fabricator through unauthorized ACH transfers. The denial leaves intact a March 2025 decision overturning the district court’s earlier ruling in favor of the plaintiff.
The dispute stems from a 2018 incident in which the company received a spoof email claiming to be from a supplier and directing the company to reroute payments to a new bank account. Relying on the instructions, the company made four ACH transfers to an account at the credit union, identifying the supplier as the beneficiary. However, the funds were deposited into an account belonging to another individual who had also been unknowingly involved in the fraud.
In its original complaint, the plaintiff alleged that the credit union failed to comply with Know Your Customer (KYC) regulations and anti-money laundering (AML) procedures by not verifying the identity or eligibility of the account holder. The complaint also asserted that the credit union violated the NACHA Operating Rules by accepting commercial ACH transfers—coded for business transactions—into a personal account. These claims were framed as failures to implement basic security protocols and to recognize clear mismatches in the payment data.
The panel held that the credit union lacked actual knowledge that the account was being used for fraudulent purposes and therefore could not be held liable under applicable law. In a concurring opinion, however, one judge noted that the record may contain evidence suggesting the credit union obtained actual knowledge of the misdescription before the final two transfers.
Putting It Into Practice: Even though the credit union ultimately avoided liability, the action is a good example of the lengths plaintiffs’ attorneys are going to hold banks liable for fraud related to spoofing. Unfortunately, Regulation E provides no avenue for relief for consumers where they are tricked into transferring money knowingly to another account. And the CFPB’s lawsuit against major banks related to similar conduct, where claims under the CFPA were alleged, was dropped earlier this year.
CFPB Shifts Supervision and Enforcement Priorities; Staff Reduction Stayed by Court
On April 16, the CFPB released an internal memo outlining major shifts in its supervision and enforcement priorities, signaling a retreat from several areas of regulatory activity. The next day, the Bureau issued formal reduction-in-force (RIF) notices to numerous employees, notifying them of termination effective June 16.
The supervision memo directs a significant reallocation of the Bureau’s focus and resources. Examinations are to be reduced by 50%, with an emphasis on collaborative resolutions, consumer remediation, and avoiding duplicative oversight. The CFPB will shift attention back to depository institutions, moving away from nonbanks that have increasingly been subject to Bureau exams in recent years. Enforcement will prioritize matters involving tangible consumer harm, particularly in areas of mortgage servicing, data furnishing under the FCRA, and debt collection under the FDCPA. The memo explicitly deprioritizes supervision of student lending, digital payments, remittances, and peer-to-peer platforms, and restricts the Bureau’s use of statistical evidence to support fair lending cases, limiting such actions to those involving intentional discrimination and identifiable victims.
The RIF notices cite structural realignment and policy shifts as the basis for the cuts and inform employees that the decision does not reflect performance or conduct. Following the issuance of the RIF notices, plaintiffs in ongoing litigation against the CFPB filed an emergency motion, arguing that the RIF appeared to violate an existing preliminary injunction. After an emergency hearing on April 18, Judge Amy Berman Jackson of the D.C. District Court ordered the CFPB to suspend its reduction-in-force and maintain employees’ access to the agency’s systems while legal proceedings continue, raising concerns that allowing the layoffs to move forward could permanently damage the Bureau’s ability to meet its legal obligations. The court set a follow-up hearing for April 28.
Putting It Into Practice: The current administration’s push to downsize the CFPB continues. While paused for the moment, a Bureau of only 200 employees will have a dramatic impact on the enforcement of the country’s federal financial services laws.
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CFPB Drops Suit Against Credit Card Company Alleging TILA Violations and Deceptive Marketing Practices
On April 23, the CFPB voluntarily dismissed with prejudice its lawsuit, filed in September 2024, against a Pennsylvania-based credit card company that had been accused of unlawfully marketing a high-cost, limited-use membership program to subprime consumers.
The complaint alleged that the company violated the Consumer Financial Protection Act (CFPA) and the Truth in Lending Act (TILA) and its implementing Regulation Z. The Agency asserted the following violations:
Misleading marketing of a “general-purpose” credit card. The company allegedly represented that it offered a standard credit card when the product could only be used at the company’s own online store.
Excessive fees in violation of TILA and Regulation Z. The card carried annual charges amounting to roughly 60% of the card’s credit limit, exceeding the 25% cap permitted during the first year of account opening.
Limited consumer use and value. Despite charging substantial fees, the program offered minimal utility—only 6% of customers used the card and just 1–3% used any ancillary benefits.
Deceptive cancellation and refund process. The company claimed cancellations could be completed in under a minute but instead subjected consumers to extended calls and repeated sales pitches before granting partial refunds.
Unreasonable barriers to exit constituted abusive conduct. The CFPB alleged the company exploited consumers’ inability to easily exit the program or secure refunds, thereby taking unreasonable advantage of financially vulnerable individuals.
Putting It Into Practice: The dismissal is the latest in a series of reversals by the CFPB under its current leadership (previously discussed here and here). While the agency appears to be retreating from certain nonbank UDAAP cases, the statutory obligations under the CFPA and TILA remain unchanged. Companies marketing credit products to subprime consumers should closely review how their offerings are presented, how fees are structured, and how cancellation processes are administered.
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White House Executive Order Eliminates Disparate-Impact Liability Enforcement
On April 23, the White House issued an Executive Order entitled Restoring Equality of Opportunity and Meritocracy, directing federal agencies to “eliminate the use of disparate-impact liability in all contexts to the maximum degree possible.” The Executive Order marks a potential shift in how federal fair lending laws will be enforced across the financial services sector.
Federal agencies have historically used disparate-impact liability to evaluate facially neutral policies that may result in unequal outcomes for protected classes. The Executive Order now instructs agencies to reassess their enforcement strategies and deprioritize claims rooted in disparate impact, including under the Equal Credit Opportunity Act, the Fair Housing Act, and other fair lending statutes.
Specifically, the Executive Order directs the Attorney General to identify and initiate repeal or amendment of regulations, guidance, or rules that impose disparate-impact liability. It also calls on federal agencies, including the CFPB, to review all pending investigations, litigation, and consent orders based on disparate-impact claims. Additionally, the Attorney General must evaluate whether federal law preempts state-level disparate-impact regimes and recommend further action where such state laws may conflict with federal policy.
Putting It Into Practice: The Executive Order reflects a broader policy shift on how discriminatory conduct is litigated. (previously discussed here). The Executive Order will certainly impact federal fair lending and anti-discrimination oversight, particularly in areas where enforcement has traditionally relied on statistical disparities rather than explicit intent. Market participants should also prepare for potential divergence between federal and state priorities in some jurisdictions.
CFPB to Revoke Medical Debt Collection Advisory Opinion
On April 11, the CFPB filed a joint motion in the U.S. District Court for the District of Columbia indicating its intent to revoke an advisory opinion on medical debt collection. The Bureau requested a stay of litigation while it moves to formally withdraw the opinion and committed to providing a status update by July 14 and every 30 days thereafter.
The October 2024 advisory opinion interpreted the Fair Debt Collection Practices Act (FDCPA) and Regulation F to restrict certain medical debt collection practices, including those involving allegedly deceptive or unfair statements about the validity or scope of consumer obligations. The opinion’s issuance triggered multiple lawsuits challenging the CFPB’s statutory authority and legal basis, arguing that the Bureau exceeded its rulemaking powers by issuing substantive policy through an advisory opinion without following the Administrative Procedure Act’s notice-and-comment requirements.
The parties explained that revoking the advisory opinion would resolve the plaintiff’s legal claims, eliminating the need for further litigation. The CFPB stated that it was actively evaluating next steps and that maintaining the litigation would be inefficient and unnecessary.
Putting It Into Practice: The CFPB’s decision to revoke its medical debt advisory opinion continues a broader rollback of policies issued under prior leadership (previously discussed here and here). As the Bureau reconsiders its approach, states may increasingly step in to fill the regulatory gap—particularly those active in applying and enforcing UDAAP laws.
North Dakota Expands Data Security Requirements and Issues New Licensing Requirements for Brokers
On April 11, North Dakota enacted HB 1127, overhauling its regulatory framework for financial institutions and nonbank financial service providers. The law amends multiple chapters of the North Dakota Century Code and creates a new data security mandate for financial corporations—a category that includes non-depository entities regulated by the Department of Financial Institutions (DFI). It also expands the licensing requirement for brokers to include “alternative financing products,” potentially impacting a broad array of fintech providers.
The law introduces sweeping data protection obligations for nonbank financial corporations through new requirements created in Chapter 13-01.2. Specifically, covered entities must:
Implement an information security program. This includes administrative, technical, and physical safeguards, based on a written risk assessment.
Designate a qualified individual. Each financial corporation must designate a qualified individual responsible for overseeing the security program and report annually to its board or a senior officer.
Conduct regular testing. Annual penetration tests and biannual vulnerability assessments are mandatory unless continuous monitoring is in place.
Secure consumer data. Encryption of data in transit and at rest is required unless a compensating control is approved. Multifactor authentication is also mandatory.
Notify regulators of breaches. A data breach involving 500 or more consumers must be reported to the Commissioner within 45 days.
The bill also amends North Dakota’s broker licensing laws to authorize the DFI to classify certain alternative financing arrangements as “loans.”
Putting It Into Practice: Of the many amendments here, North Dakota’s expansion of licensing requirements for brokers of alternative financing products may have the biggest impact for institutions, especially fintechs.
Pushback of Deadline for SNFs to Submit Significantly More Detailed Ownership and Control Information in New “SNF Attachment” to CMS Form 855A
With newly confirmed Dr. Mehemet Oz at its helm, the Centers for Medicare & Medicaid Services (CMS) maintained but delayed the deadline for its requirement that Skilled Nursing Facilities (SNFs) to report significantly expanded information to CMS about the ownership, management and relationships with private equity (PE) and real estate investment trusts (REIT), and newly defined “additional reportable parties” (ADPs).
Scheduled to take effect on May 1, 2025, CMS recently announced a three-month reprieve, pushing the deadline back to August 1, 2025. This comes at the same time that CMS is seeking suggestions on lowering the Medicare regulatory burden and simplifying Medicare reporting requirements.
The delay announcement came as a surprise since, as recently as Friday, April 11, CMS reminded SNFs about the May 1 deadline that was fast-approaching for the Off-cycle SNF Revalidation of all Medicare-enrolled SNFs. Originally issued on October 1, 2024, every SNF was required to complete the new Form 855A that was designed to improve transparency and accuracy in SNF enrollment data under new reporting rules that were finalized by CMS in the Medicare and Medicaid Programs; Disclosures of Ownership and Additional Disclosable Parties Information for Skilled Nursing Facilities and Nursing Facilities; Medicare Providers’ and Suppliers’ Disclosure of Private Equity Companies and Real Estate Investment Trusts, on November 17, 2023.
Effective October 1, 2024, CMS added the new “SNF Attachment” to Form 855A, the Medicare Enrollment Application for Institutional Providers. All SNFs must now revalidate CMS enrollment by submitting the updated form by August 1, 2025. Medicare-enrolled SNFs should have received a revalidation notice by the end of the calendar year 2024. Even if the letter got lost in the mail, CMS expects every Medicare enrolled SNF to contact their Medicare Administrative Contractor (MAC) to ensure they revalidate their enrollment before August 1, 2025, or risk what will be serious consequences.
CMS set the bar for disclosures high, and the consequences will be swift and painful for SNFs that fail to report enrollment information fully and accurately. Penalties may include notice of dis-enrollment or revocation of Medicare enrollment, which could result in a lapse in enrollment, leaving a non-compliant SNF unable to submit claims or receive reimbursements.
The updated 855A requires SNFs to disclose all ownership interest and managing control information on the new SNF Attachment, rather than in Sections 5 and 6 as previously required. SNFs will no longer fill out Sections 5 and 6 and instead must check a box in each section which states “Check here if you are a Skilled Nursing Facility and skip this section.”
The new SNF Attachment requires far more information and detail than previously required by Sections 5 and 6. While some of the disclosures previously required in these sections have carried over to the new SNF Attachment, there are several additional requirements. SNFs must now disclose:
All members of their governing body irrespective of business type;
If the SNF is an LLC, all owners must be reported regardless of ownership percentage;
If the SNF is a trust, all trustees;
All Additional Disclosable Parties (ADPs); and
Certain additional information about each ADP.
An Additional Disclosable Party (ADP) is defined broadly to include any person or entity that:
Exercises operational, financial, or managerial control over any part of the SNF,
Provides policies or procedures for any of the SNF’s operations,
Provides financial or cash management services to the SNF,
Leases or subleases real property to the SNF or owns a whole or part interest equal to at least 5% of the total value of property leased by the SNF,
Provides management or administrative services to the SNF,
Provides clinical consulting services to the SNF, and/or
Provides accounting or financial services to the SNF.
There is no minimum threshold for how long the ADP must have furnished the services, the extent of involvement with the SNF’s operations, or the volume of furnished services. If a person or entity performed any of the above-listed services, for any period of time, they must be disclosed as an ADP.
Furthermore, CMS has made it abundantly clear that SNFs should err on the side of disclosure if they are uncertain as to whether a party qualifies as an ADP. Additional information can be found in CMS Guidance for SNF Attachment on Form CMS-855A.
At approximately the same time SNFs were expected to be gathering the information to complete the new disclosures, CMS posted an appeal for regulatory relief titled “Unleashing Prosperity Through Deregulation of the Medicare Program Request for Information” (Medicare Deregulation RFI). Through this RFI, CMS asks for input “on approaches and opportunities to streamline regulations and reduce administrative burdens on providers, suppliers, beneficiaries, Medicare Advantage and Part D plans, and other stakeholders participating in the Medicare program . . . [in an] effort[ ] to reduce unnecessary administrative burdens and costs, and create a more efficient healthcare system. . .” Commenters are asked to identify “specific Medicare administrative processes, quality, or data reporting requirements, that could be automated or simplified to reduce the administrative burden on facilities and providers,” “changes [that could] be made to simplify Medicare reporting and documentation requirements without affecting program integrity,” and “documentation or reporting requirements within the Medicare program that are overly complex or redundant.” Some SNF industry stakeholders are looking at the RFI as an opportunity to get the Trump Administration to at least decrease the complexity of the increased SNF reporting requirements, if not eliminate as a redundant, duplicative and unnecessary administrative burden that will create financial strain on SNFs.
New Executive Order on HBCUs Establishes Initiative to ‘Promote Excellence And Innovation’
On April 23, 2025, President Donald Trump issued an executive order (EO) that moved a long-standing presidential initiative focused on supporting Historically Black Colleges and Universities (HBCUs) from the U.S. Department of Education to the White House.
Quick Hits
On April 23, President Trump issued a new EO designed to “elevate the value and impact of our nation’s HBCUs as beacons of educational excellence and economic opportunity that serve as some of the best cultivators of tomorrow’s leaders in business, government, academia, and the military.”
The EO establishes an initiative—“the White House Initiative on Historically Black Colleges and Universities”—“housed in the Executive Office of the President and led by an Executive Director designated by the President.”
There are approximately one hundred HBCUs in the United States. Although HBCUs were originally founded to educate Black students, they now enroll students who are not Black.
The executive order establishes the White House Initiative on Historically Black Colleges and Universities under the executive office of the president, to be led by an executive director designated by the president. The executive order outlines two primary missions for the initiative: (1) increasing the private-sector role, including the role of private foundations, in strengthening and further supporting HBCUs; and (2) enhancing HBCUs’ capabilities to serve the country’s young adults. Specifically, the executive order calls for increasing the private-sector role in:
assisting HBCUs with “institutional planning and development, fiscal stability, and financial management”;
“upgrading institutional infrastructure, including the use of technology”; and
“providing professional development opportunities for HBCU students to help build America’s workforce in technology, healthcare, manufacturing, finance, and other high-growth industries.”
In addition, the executive order calls for enhancing HBCUs’ capabilities to serve the country’s young adults by:
“fostering private-sector initiatives and public-private and philanthropic partnerships to promote centers of academic research and program excellence at HBCUs”;
“partnering with private entities and [K-12] education stakeholders to build a pipeline of students that may be interested in attending HBCUs”;
“addressing efforts to promote student success and retention at HBCUs, including college affordability, degree attainment, campus modernization, and infrastructure improvements.”
The executive order establishes, within the U.S. Department of Education, a board, referred to as “the President’s Board of Advisors on Historically Black Colleges and Universities.” The board is to be comprised of current HBCU presidents and representatives in philanthropy, education, business, finance, entrepreneurship, innovation, and private foundations. The board is tasked with advising the president on matters pertaining to the HBCU PARTNERS Act, which became law in 2020.
Furthermore, the initiative will organize an annual White House summit on HBCUs “to discuss matters related to the [i]nitiative’s missions and functions.”
While the executive order does not specifically identify or otherwise promise funding for the initiative, the White House also released a fact sheet that references HBCU-related funding secured during President Trump’s first term.