Substantive Change FAQs

Frequently Asked Questions about Substantive Change

May I submit a prospectus after the deadline?

Prospectuses reviewed by staff and approved by the Executive Council of the Board of Trustees (most common) can be submitted after the deadline – we won’t reject them for being tardy.  However, we receive a large volume of submissions immediately prior to deadlines and we review in the order received.  Thus, late submissions risk insufficient time for review prior to implementation. Suggestion:  give yourself plenty of lead time between submission and implementation.

Prospectuses referred directly to the full Board of Trustees (mergers/consolidations, acquisitions, etc., and all approvals for institutions on sanction) in June and December must be submitted in their entirety by the published deadlines.

How long does it take to receive a reply?

Current response time is four to six months, depending on the volume of submissions in queue.  We review in the order received.  Prospectuses (requiring approval) are typically given priority over notifications (do not require approval).

I really need my prospectus reviewed. Can you expedite?

Out of fairness to all institutions, we review in the order received only.

How do I know if a change is a substantive change?

In general, if a planned change is not specifically addressed in the substantive change policy, it’s not a substantive change and thus requires no action on your part.  The substantive change policy is your go-to resource.  Several related policies are also helpful for certain types of change.  Also take advantage of the substantive change webinars (live and on-demand), face-to-face workshops, staff-led sessions at the Summer Institute and Annual Meeting.