NASFAA yesterday afternoon. NASFAA constructed its comments after soliciting and reviewing comments from members and from working with other higher education groups and the lending community. Final rules from the Higher Education Opportunity Act (HEOA) require covered institutions to provide students — upon request — a private education self-certification form that would contain an applicant’s cost of attendance and estimated financial assistance, as well as other disclosures. Lenders must collect and maintain the self-certification form before disbursing a private student loan.