Mr. Arnold's Excellance Beauty Schools, Inc., Dkt. The FPRD is based upon a program review conducted between November 12 and 15, 1991. Respondent has the burden of establishing that the FPRD findings are erroneous.
Respondent points out that in another proceeding, No.
Ed failed to meet its burden of proving that Respondent did not meet the standard of administrative capability and the fiduciary standard of conduct. Respondent did not make timely refunds as required by 34 CFR 668.21. The Respondent did not dispute this violation. However, these findings are not at issue herein. This is a separate proceeding with different issues.