[Part 2/3] From Subprime to Subagents: HE's Compliance Reckoning

The Pattern Is Forming

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Universities face unprecedented scrutiny. Financial management questions are mounting. Governance concerns are making headlines. International student recruitment, once a growth engine, is now under the microscope.

Immigration integrity issues have prompted governments to tighten visa settings. Reports of subagent misconduct and student welfare concerns are drawing media attention. Regulators are raising standards. Government inquiries are multiplying.

These aren't isolated incidents. They represent a pattern of growing public and political concern about how the sector operates.

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The Infrastructure Gap

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Many institutions currently manage agent relationships through systems designed for a different era. Contracts exist across multiple departments. Commission structures live in spreadsheets. Due diligence processes vary by individual staff member. Subagent networks lack central visibility.

During growth periods, these gaps seem manageable. They become critical vulnerabilities when regulators intensify oversight.

In financial markets before 2008, we had similar gaps. The question governments asked then is the same one being asked about higher education now: how did we allow these risks to develop?

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What Regulatory Enforcement Actually Demands

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When compliance requirements tighten, the expectations are specific and unforgiving.

Agent contracts need centralised management with clear audit trails. Subagent authorisation requires documented oversight. Commission payments need transparent justification. Due diligence must be demonstrable, not simply claimed.

Individual accountability follows. Vice-Chancellors, Chief Financial Officers, and Directors become personally responsible for compliance in their domains. The defence of "I didn't know" loses its protective power.

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Why Manual Systems Fail

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When regulators arrive requesting complete agent contract histories, "we think we have that somewhere" isn't acceptable. When they want evidence of due diligence on a particular agent, delayed responses create liability. When they ask who authorised specific decisions, uncertainty has consequences.

Digital contracting platforms provide what regulators demand: centralised repositories, complete audit trails, version histories, automated due diligence tracking, subagent visibility, and immediate reporting capability.

This isn't primarily about operational convenience. It's about having defensible answers when questions become difficult.

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The Costs of Waiting

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We're already seeing preliminary consequences: recruitment restrictions in certain markets; increased regulatory scrutiny; reputational damage impacting enrollment; financial penalties or losses that exceed the cost of proper systems many times over.

In financial markets, the institutions that waited to implement compliance systems paid far more than those who acted early. They paid in direct fines and in lost market access, restricted operations, and damaged reputations. There is no benefit to being a laggard in this space.

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The Proactive Choice

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University & college leaders today have an advantage financial services didn't in 2008: visibility of what's approaching.

Acting now means implementing systems whilst you can establish standards that work for your institution. You train teams properly. You maintain control over your compliance framework.

What surprised many in financial services was that early movers gained competitive advantages. They attracted professional partners who valued transparent relationships. They built trust with regulators. They positioned themselves as industry leaders whilst competitors scrambled to catch up.

The same opportunity exists in higher education now.

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The Time Is Now

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Financial markets, as a whole, underestimated how quickly the industry would transform. Higher education's regulatory environment is tightening now. The institutions that prepare thoughtfully today will navigate this transition successfully. Those caught unprepared will face restrictions that limit their ability to operate.

Digital contracting isn't simply about compliance. It's about protecting your institution's reputation, maintaining international recruitment capabilities, and managing the personal liability exposure that increasingly accompanies leadership roles.

When regulatory requirements intensify, the time for preparation has passed.

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Trent Tighe is Chief Commercial Officer at HEComply's parent company, Feezy Pty Ltd. He worked in financial services for 20 years across Singapore, Sydney, and Hong Kong.