No, according to the relevant regulations and conversations with the U.S. Department of Education, Populi is not a third-party financial aid servicer (TPS). Rather, it is considered a software vendor.
According to this Dear Colleague letter updated on February 28, 2023, here is the definition of a TPS:
A TPS is any entity or individual that administers, any aspect of an institution’s participation in the Title IV programs. 34 C.F.R. § 668.2 (definition of a third-party servicer). In general, a TPS performs functions or services necessary—
- For the institution to remain eligible to participate in the Title IV programs;
- To determine a student’s eligibility for Title IV funds;
- To provide Title IV-eligible educational programs;
- To account for Title IV funds;
- To deliver Title IV funds to students; or
- To perform any other aspect of the administration of the Title IV programs or comply with the statutory and regulatory requirements associated with those programs.
Populi does none of the above; we do not contract with you to perform any of the work listed above. What we do instead is provide the software you need to manage your financial aid in-house.