only) 2) Getting rid of all 12 incentive compensation safe harbors .  ED’s proposals for gainful employment standard will determine the appropriate levels of debt allowable for each vocational program/degree offering and thus may effectively result in tuition caps  Eliminating all 12 safe harbors could restrict a school’s ability to utilize 3rd party call centers for qualification & hot transfer and potentially diminish internet generated starts, thus stalling enrollment growth.  Still much speculation and uncertainty…]]>