FERPA and Reverse Transfer: What can I do (and not do)?

"Its our understanding that some other schools are proceeding with reverse transfer based on the belief that FERPA allows schools to disclose education records for this purpose without the student’s consent, under the following conditions (34 CRF § 99.31):

􏰁  School officials with legitimate educational interest

􏰁  Other schools to which a student is transferring

􏰁  Specified officials for audit or evaluation purposes

􏰁  Organizations conducting certain studies for or on behalf of the school.

Is this permissible under FERPA?” 

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