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Key Facts
- Federal level: Sen. Charles Grassley framed ABA law school accreditation oversight around concerns for students using taxpayer-backed loans and the risk of defaults.
- Federal level: Grassley said he cited a June article reporting that the ABA was “out of compliance with 17 regulations,” including the need to consider student loan default rates.
- Federal level: The ABA Section memorandum dated July 20, 2011 stated it was submitted in response to Grassley’s July 11, 2011 letter to ABA President Stephen N. Zack.
- National overview: The U.S. Department of Education describes U.S. accreditation as a Triad involving non-government accrediting organizations plus federal and state government agencies.
- Federal level: The ABA memo stated the ABA Section of Legal Education and Admissions to the Bar was responsible for the ABA Accreditation Project and that its Council is recognized by the Department of Education as the accreditor for J.D. leading programs and institutions.
- Federal level: The ABA memo described a separate and independent requirement for the Section regarding accreditation decision-making, governance, and budgeting.
- Federal level: The ABA memo discussed Standards 510 and 511 focused on minimizing student loan defaults and providing student support services, using scholarship and student loan default rate figures as ABA-stated data.
Last reviewed: May 2026. Legal rules, forms, deadlines, and procedures can change by jurisdiction, agency, and court system.
- Why this archive exchange matters to modern readers
- The Senate timeline and Grassley’s framing of accreditation oversight
- The “17 regulations” allegation was attributed to a cited June article
- What the ABA memo said and how it positioned its response
- Roles, governance separation, and the memo’s internal accountability theme
- Standards 510 and 511 as the memo’s answer to student loan default concerns
- Scholarship assistance and default rate figures were presented as ABA stated data
- How the Department of Education describes the federal accreditation recognition framework
- What Grassley reported after the ABA response and the role of period specific estimates
- Sources
Why this archive exchange matters to modern readers
This archive recovery focuses on a 2011 back-and-forth in which Sen. Charles Grassley pressed the American Bar Association (ABA) about the quality of ABA-related law school accreditation and how that oversight connected to concerns about student loan repayment and defaults. The core materials in the record are Senate releases describing the inquiry and an ABA response memorandum dated July 20, 2011, which together show how lawmakers and a professional accreditation organization discussed accountability, standards, and data in that period. For additional archive context on legal education policy debates involving the ABA, see ABA coverage of legal education issues in 2008 and the related ABA legal education award archive coverage.
The Senate timeline and Grassley’s framing of accreditation oversight
Grassley’s August 2011 release described his continuing request for answers after he sent an initial letter to the ABA and received what he characterized as an inadequate response. In that release, Grassley stated that the ABA had “tremendous power” because it accredits law schools, and he tied the oversight to “taxpayer backed student loans” and the concern that defaults would create taxpayer exposure. The release also described a theme about the ABA’s position on repayment while acknowledging uncertain job prospects for lawyers, and Grassley presented that as a point he wanted to reconcile.
The “17 regulations” allegation was attributed to a cited June article
Another Grassley release in the record describes an additional concern: Grassley said that he cited a June article reporting that the ABA was “out of compliance with 17 regulations,” and that the report included a need to consider student loan default rates when assessing programs. The archive record treats that “out of compliance with 17 regulations” point as information attributed to a June article cited by Grassley, not as a directly confirmed government finding about the ABA.
What the ABA memo said and how it positioned its response
The ABA response memo dated July 20, 2011 identified itself as a memorandum from the “Section of Legal Education and Admissions to the Bar” to Senator Charles Grassley, and it stated that the memorandum was submitted in response to Grassley’s July 11, 2011 letter to ABA President Stephen N. Zack. The memo’s timeline and framing matter because the archive record describes a legislative oversight exchange; it is not a federal court decision or an agency enforcement action. The memo also provided background on the ABA’s Accreditation Project, consistent with responding to the questions raised by the Senate releases.
Roles, governance separation, and the memo’s internal accountability theme
In describing its structure, the ABA memo stated that the Section of Legal Education and Admissions to the Bar is the ABA entity responsible for the law school Accreditation Project. The memo also stated that “the Council of the Section is recognized by the Department of Education as the accreditor for programs and institutions leading to the award of the J.D. degree.” Finally, the memo described an internal accountability/governance separation concept: “pursuant to Department regulations,” the Section was required to be “separate and independent” from the ABA for accreditation decision-making, governance, and budgeting.
Standards 510 and 511 as the memo’s answer to student loan default concerns
The ABA memo used specific accreditation standards to address themes raised in the Senate releases. It quoted “Standard 510- STUDENT LOAN PROGRAMS” describing requirements for reasonable steps to minimize student loan defaults, including debt counseling at the inception of a student’s loan obligations and prior to graduation. The memo also quoted “Standard 511- STUDENT SUPPORT SERVICES” describing basic student services, including financial aid counseling and an active career counseling service.
Scholarship assistance and default rate figures were presented as ABA stated data
The memo further discussed student outcome related information in two categories: scholarship assistance and student loan default rates. It described scholarship assistance comparing 2005 to 2010 and stated that total scholarship assistance increased from $536 million to $899 million, and that nearly 47% of law students enrolled in ABA-approved schools in 2010 received scholarship assistance through their law schools. It also described a student loan default rate range for independent ABA-approved law schools, stating that defaults were “very low,” ranging from 0% to 7.4%, and noting that the 7.4% statistic was based on a very small cohort. Those figures reflect the ABA memo’s presentation of its own materials and summaries within the archive record.
How the Department of Education describes the federal accreditation recognition framework
A common point of confusion in accreditation discussions is whether accreditation standards are federal law or whether federal agencies “accredit” schools directly. In the record here, the U.S. Department of Education provides a general framework explaining that U.S. accreditation involves a “Triad” including non-government accrediting organizations plus federal and state government agencies. The Department also explains that, under the Higher Education Act (HEA), the Department “recognizes” accrediting agencies, and that recognition involves reviews by Department Accreditation Group (AG) staff and the National Advisory Committee on Institutional Quality and Integrity (NACIQI) (see Overview of Accreditation in the United States).
Federal recognition versus private accreditation standards in one snapshot
| Accreditation related topic | What the 2011 exchange shows | What the Department overview describes generally |
|---|---|---|
| Standards and requirements used by a professional accreditation body | The ABA memo cites Standards 510 and 511 to describe how student loan defaults and student support are addressed | The Department overview does not supply those specific standards, but it places accreditation within a larger oversight system |
| Federal recognition and review participants | The ABA memo states the Section Council is recognized by the Department as the accreditor for J.D.-leading programs and institutions | The Department overview describes recognition as involving Accreditation Group staff and NACIQI |
What Grassley reported after the ABA response and the role of period specific estimates
The Senate follow-up release in the record states that Grassley wrote to the ABA on July 11, the ABA responded on July 20, and Grassley sent a second letter after finding the response inadequate. The release also includes a Senate reported federal estimate for higher education student loan volume that uses period-specific language: it stated that the federal government would make 24.3 million loans totaling $116.4 billion “this year alone” for higher education including graduate studies. As an archive item, the legal significance of the exchange lies in the historical framing and the standards and figures the ABA emphasized in response to the Senate inquiry, not in any claim that the 2011 exchange changed current accreditation rules.
