Higher Ed Insider 2026-17


Higher Ed Insider — Edition 2026-17 
                        
INTELLIGENCE FOR FAMILIES NAVIGATING COLLEGE ADMISSIONS
NH
HIGHER ED INSIDER
Dr. Nathan Hurwitz · Hurwitz Consulting
 
EDITION 2026-17  ·  APRIL 21–25, 2026 © 2026 HURWITZ CONSULTING
nathan@hurwitzadmissions.com  ·  hurwitzadmissions.com  ·  (203) 613-9262
BY THE NUMBERS — EDITION 2026-17
$2.7B
Harvard funding freeze appealed to First Circuit
93
Programs "sunsetted" at Syracuse University
35%
Global F-1 visa denial rate — decade high in 2025
May 20
Deadline to comment on new STATS earnings rule
$133B
Total state higher ed appropriations FY 2026 — slowest growth since COVID
8 weeks
Minimum length for Workforce Pell-eligible programs starting July 2026
EDITOR'S NOTE

Dear Parents and Guidance Counselors,

This week, higher education's financial and legal battles collided with family decision-making in ways you need to understand. The Trump administration filed a sweeping 160-page brief asking the First Circuit to reinstate a $2.7 billion freeze on Harvard's federal funding — a case that will shape not just Harvard's fate, but the rules of engagement between the federal government and every research university your student may be considering. Simultaneously, the new STATS accountability rule dropped, threatening to cut off loan access for any degree program whose graduates don't out-earn high school graduates. That's a map-rewriting policy for families evaluating which majors and institutions carry real long-term value.

We're also tracking an accelerating wave of university program consolidations — Syracuse's elimination of 93 programs is the most prominent, but hardly the only story. Combined with visa denial rates at decade highs and state higher-ed budgets at their slowest growth since the pandemic, the landscape for applicants in the Class of 2030 and beyond is shifting rapidly. My job — and yours — is to turn that volatility into advantage.

— Dr. Nathan Hurwitz
College Admissions Consultant · Hurwitz Consulting · (203) 613-9262

THIS WEEK'S COVERAGE

01  Harvard v. Trump: First Circuit Brief

02  STATS Rule: Earnings or Lose Federal Aid

03  Syracuse's 93-Program Sunset Signal

04  F-1 Visa Denials at Decade High

05  State Budgets and the OBBBA Squeeze

✦   ✦   ✦
TOPIC 01  ·  FEDERAL POLICY & LITIGATION

The Harvard Showdown Reaches the Appeals Court

The government files a 160-page brief to reinstate a $2.7B funding freeze — and the outcome will define the boundaries of federal power over universities.

 

The Trump administration this month filed a sweeping 160-page appellate brief asking the First Circuit Court of Appeals to reverse a September 2025 ruling that found its $2.7 billion freeze on Harvard's federal research grants unconstitutional. Federal lawyers are arguing on three fronts: that Harvard sued in the wrong court, that agencies can revoke grants based on shifting "agency priorities" outside the formal Title VI process, and that the April 2025 demand letter did not violate Harvard's First Amendment rights.

The stakes extend far beyond Cambridge. If the First Circuit reinstates the freeze, it would effectively signal that any university receiving federal research dollars is subject to ideological compliance conditions — a precedent with enormous implications for academic freedom at every institution. Harvard, which has separately faced threats to its tax-exempt status and SEVP certification (the latter already litigated and reversed), continues to self-fund critical research and mount its legal defense while a settlement remains elusive. The administration has publicly demanded at least $500 million as part of any deal; Harvard has not agreed.

Meanwhile, Harvard's endowment tax burden is projected to reach approximately $300 million annually under the One Big Beautiful Bill — costs it must now recognize on its FY 2026 balance sheet even before the first payment is due in FY 2027. The combined financial pressure is already constraining financial aid commitments and research capacity.

 
ELITE SPOTLIGHT — THE SETTLEMENT CALCULUS

Columbia settled for $221 million and policy changes. Brown settled at undisclosed terms. Princeton and Northwestern negotiated resolutions. Harvard alone remains in litigation — and the administration has set a floor of $500 million. The First Circuit ruling, expected by late summer 2026, will determine whether Harvard's legal strategy pays off or whether refusing to settle becomes the most costly Ivy decision of the decade.

 
DR. HURWITZ'S TAKE

Harvard's fight is everyone's fight — or at least every serious research university's. What I tell families is this: the legal outcome matters less for admissions than what Harvard is doing right now to adapt. A university that has endured this level of pressure and still expanded financial aid commitments, still maintained its research enterprise, and still attracted top faculty is demonstrating institutional resilience. For students with Harvard-range profiles, don't count them out. And for students considering peer institutions, watch how each responds to federal pressure — that tells you something important about institutional leadership.

 
IF HARVARD PREVAILS
  • Academic freedom precedent protects all universities
  • Research grants restored; financial aid capacity preserved
  • Federal government's leverage over admissions and curriculum curbed
IF GOVERNMENT PREVAILS
  • Federal funding becomes a compliance lever at every university
  • Research partnerships, financial aid, and hiring all subject to political conditions
  • Universities face impossible choice: independence or funding
 
✓ ACTION CHECKLIST

✓ If Harvard is on your list, don't remove it — but do expand your list to 2–3 comparable research universities as backups.

✓ When touring schools, ask admissions officers directly: "How has the university responded to federal funding pressures?"

✓ Monitor the First Circuit docket for a ruling — expected before the end of summer 2026 — before finalizing any EA/ED strategy for fall 2026.

 
KEY SOURCES

The Harvard Crimson — First Circuit Appeal Brief (Apr. 16, 2026)
Harvard Gazette — FY25 Financial Report

✦   ✦   ✦
TOPIC 02  ·  FEDERAL POLICY & FINANCIAL AID

The STATS Rule: Your Degree Must Out-Earn a High School Diploma — or Lose Federal Aid

New proposed regulations would strip Direct Loan access from programs whose graduates don't meet earnings benchmarks. The comment window closes May 20.

 

On April 20, the Department of Education published its third and most consequential piece of Workforce Pell rulemaking: the Student Tuition and Transparency System (STATS) and Earnings Accountability proposed rule. This rule, mandated by the One Big Beautiful Bill Act signed in July 2025, would require every degree program at every institution to demonstrate that its graduates earn meaningfully more than the median wages of high school graduates who skipped college. Fail that test in two out of three years, and the program loses access to federal Direct Loans — cutting off the primary funding mechanism for most students.

The companion Workforce Pell rule, published in March, will allow Pell Grants to cover short-term programs as brief as 8 weeks starting July 2026 — a significant expansion that could redirect federal dollars toward vocational training, community college certificates, and employer-sponsored credentials. The July launch remains technically on schedule, though implementation logistics for institutions are still being resolved.

Critics from the National Education Association and higher education advocacy groups argue the STATS framework lacks adequate state data infrastructure to measure earnings fairly, and that it particularly threatens programs in education, the humanities, and social services — fields where graduates produce enormous public value not captured in wage data. The public comment deadline is May 20, 2026. This is a rule families should understand before selecting a major or institution.

 
WHAT THE STATS RULE MEANS IN PRACTICE
PROGRAM TYPE RISK LEVEL
STEM / CS / Engineering Low — strong earnings outcomes
Business / Economics Low to moderate
Education / Social Work High — public-service wage penalty
Humanities (stand-alone) Very high — median earnings often below benchmark
Graduate Professional (MBA, JD, MD) Low — graduate earnings benchmark different
 
DR. HURWITZ'S TAKE

Here's what the STATS rule actually means for your family's planning today: it's a massive incentive for universities to discontinue low-earning majors rather than risk losing loan eligibility. We're going to see an acceleration of the humanities and fine arts consolidation that's already underway. If your student is passionate about a niche program — think Medieval Studies or Fine Arts at a mid-tier institution — that major may simply cease to exist in four years. My advice: if a specific program is driving your school selection, look hard at enrollment trends and institutional commitment to that field right now, before applying. The STATS rule doesn't take effect immediately, but universities are already responding preemptively.

 
THE CASE FOR ACCOUNTABILITY
  • Students and families deserve earnings outcome data before borrowing tens of thousands
  • Workforce Pell opens grant access for job-focused short programs
  • Federal investment should produce measurable economic returns
THE RISKS
  • Teachers, social workers, and artists produce social value that wages don't capture
  • State data infrastructure can't reliably measure earnings outcomes
  • Accelerates humanities elimination — reducing intellectual breadth of U.S. higher ed
 
✓ ACTION CHECKLIST

✓ Use the College Scorecard at studentaid.gov to check median earnings for specific programs before your student commits to a major.

✓ If your student is set on a humanities major, prioritize schools with strong pre-professional tracks (pre-law, business minors) built alongside the liberal arts core.

✓ Ask college admissions offices what percentage of each department's graduates are employed in-field within 6 months — institutions tracking this data now are ahead of the curve.

 
KEY SOURCES

Federal Register — STATS NPRM (Apr. 20, 2026)
SBA Office of Advocacy — STATS Impact Analysis

✦   ✦   ✦
TOPIC 03  ·  INSTITUTIONAL STRATEGY

Syracuse Cuts 93 Programs — And It Isn't a Crisis. That's the Point.

When a financially healthy university voluntarily consolidates its academic portfolio, it's sending a signal about where higher education is heading — with or without federal pressure.

 

Syracuse University announced April 1 that it is eliminating 93 academic programs — 41 bachelor's degrees, 33 certificate programs, and 19 graduate degrees — as part of a seven-month academic portfolio review. The university's provost was explicit: this is not a financial emergency. Only 258 students out of roughly 22,000 are enrolled across the affected programs. More than half of the 93 programs had zero students enrolled. No faculty positions are being cut.

The real story is institutional positioning. Syracuse was offering approximately 460 programs — more than double the peer average of roughly 200. The 34% of programs accounting for 80% of enrollment were effectively subsidizing a long tail of ghost programs. As the STATS rule and enrollment cliff put pressure on every institution's resource allocation, proactive consolidation is becoming the strategic response of choice among financially stable universities.

The fields losing programs at Syracuse include French, German, Italian, Middle Eastern studies, digital humanities, and statistics — a list that maps almost perfectly onto the programs most vulnerable under the STATS earnings accountability framework. This is not coincidence. Universities are reading the federal policy signals and acting before compliance becomes mandatory.

 
DR. HURWITZ'S TAKE

Syracuse is doing something genuinely interesting here: the university is proactively streamlining before it has to. Families should see this as a sign of institutional health, not alarm. A university willing to make hard structural choices ahead of an enrollment cliff and federal accountability crackdown is more likely to be thriving when your student graduates than one that keeps zombie programs alive to pad its catalog. What I watch for in portfolio cuts is whether the core majors students actually want are strengthened — and at Syracuse, that appears to be the case. The information sciences, business, and communications programs that drive enrollment are untouched.

 
STRENGTHS OF THE MOVE
  • Proactive — not crisis-driven
  • No faculty eliminations; preserves community cohesion
  • Resources redirect to high-demand programs
  • Students in affected programs can complete their degrees
CONCERNS
  • Humanities and language majors disappearing from another flagship
  • Faculty governance concerns over process transparency
  • Signals broader national trend that narrows the liberal arts experience
 
✓ ACTION CHECKLIST

✓ Before applying, verify that your student's intended major is listed as an active program — not just one that's been "paused" or is under review.

✓ Check IPEDS data for enrollment trends in specific departments — if a major is below 50 enrolled students institution-wide, treat it as at-risk.

✓ For language and humanities-focused students, prioritize flagship liberal arts colleges (Amherst, Williams, Middlebury) where those programs are the core mission — not a side offering.

 
KEY SOURCES

Higher Ed Dive — Syracuse Cuts 93 Programs (Apr. 2, 2026)
Syracuse University Today — Provost Agnew's Campus Letter

✦   ✦   ✦
TOPIC 04  ·  INTERNATIONAL ADMISSIONS

F-1 Visa Denials Hit a Decade High — And the Domestic Applicant Landscape Is Shifting

A new Shorelight report reveals a 35% global visa denial rate in 2025. The retreat of international students creates both competitive risk and opportunity for domestic applicants.

 

A report from Shorelight, an international education analytics firm, reveals that F-1 student visa denial rates reached a decade high of 35% globally in 2025 — exceeding even the pandemic peak of 2020. The disruptions are concentrated in Africa, the Middle East, and South Asia. India, historically the largest source of U.S. international students, saw its refusal rate spike from 36% to 61% between 2023 and 2025. The State Department has separately reported that more than 8,000 student visas have been revoked since the start of the Trump second term, part of a broader enforcement posture that includes social media screening and what critics call a "one-strike" policy for minor infractions.

For universities that have long relied on international tuition revenue to subsidize financial aid for domestic students, the collapse in international enrollment is a financial emergency. Virginia's public higher education system has already reported millions of dollars in lost tuition and fee revenue. Graduate programs — especially in STEM fields, where international students often represent 40–60% of enrollment — face the most acute disruption, with one analysis suggesting a potential $6.2 billion in lost postgraduate revenue nationally by fall 2026.

The replacement question is stark: there is no obvious pipeline of domestic students to fill these seats. Programs built around international enrollment — particularly in engineering, computer science, and economics at research universities — face a structural revenue gap that will take years to address.

 
THE DOMESTIC APPLICANT WINDOW

Some admissions experts argue the pullback in international enrollment creates modest opportunity for highly qualified domestic applicants at research universities that have historically reserved spots for revenue-generating international students. This is most visible in STEM graduate programs — but may filter into undergraduate engineering and economics admits as well. The counterpoint: many schools are responding by expanding international scholarships to maintain enrollment rather than admitting more domestic students.

 
DR. HURWITZ'S TAKE

I've been cautioning families not to count on a "visa vacuum" boosting domestic admit rates — the data doesn't clearly support that narrative at the undergraduate level. Where I do see real signal is in graduate programs, especially at state flagships in engineering and the sciences, where international enrollment collapses are severe and domestic candidates with strong profiles are suddenly more competitive. For families with a student headed into those pipelines, this is worth understanding. For everyone else, stay focused on building the strongest possible application — not on gaming demographic shifts.

 
FOR DOMESTIC APPLICANTS
  • Potential marginal improvement in odds at research-intensive schools
  • Graduate STEM programs at flagships may see domestic admits increase
  • Some universities increasing domestic merit aid to compensate
THE BROADER RISKS
  • Lost tuition revenue strains financial aid for all students
  • STEM research capacity diminishes without international graduate students
  • U.S. loses global standing as top destination for talented students
 
✓ ACTION CHECKLIST

✓ When evaluating financial aid packages, ask schools directly whether their offers are contingent on international enrollment staying at current levels — a school with heavy international dependency is carrying more financial risk.

✓ For students targeting graduate STEM programs at research universities, apply broadly this cycle — acceptance rates in these programs may be modestly better than historical norms.

✓ International families currently in the U.S. with students approaching college age should begin visa and legal status planning at least 18 months out, not 6.

 
KEY SOURCES

Inside Higher Ed — F-1 Visa Refusals Surged in 2025 (Apr. 11, 2026)
Mayer Brown — Immigration Reality for Academic Institutions (Feb. 2026)

✦   ✦   ✦
TOPIC 05  ·  STATE FUNDING & AFFORDABILITY

The OBBBA Squeeze: How Medicaid and SNAP Cuts Are Moving Toward Higher Ed Tuition

State higher-ed appropriations saw their slowest growth since the COVID pandemic in FY 2026 — and the worst may be ahead as federal health and nutrition cuts force state budget choices.

 

A new Inside Higher Ed analysis, citing a Center for American Progress report released this week, lays out the cascade: the One Big Beautiful Bill Act's cuts to Medicaid and SNAP will force states to fill enormous holes in health and nutrition budgets. History says they will raid higher education to do it. In FY 2026, state appropriations for public higher ed reached $133.1 billion — a 1% nominal increase that amounts to a real-dollar decline after inflation. It's the slowest growth in the sector since the pandemic year of FY 2021, when states froze spending as revenue collapsed.

The precedent from the Great Recession is alarming: state higher-ed funding dropped more than 23% during that downturn, while tuition rose roughly 18%. The OBBBA's Medicaid cuts alone are projected at $840 billion over 10 years, and many states have already seen tax revenue decline before any federal shifts have fully materialized. Several states — including Nevada, California, and Washington — are already reducing public university appropriations or raising tuition in anticipation.

The downstream effects for families are concrete: public university tuition is likely to rise, financial aid pools will shrink, and low- and middle-income students who rely on both Pell Grants and state need-based aid will feel the double squeeze. For community colleges, where state and local appropriations account for nearly half of all revenue, the vulnerability is especially acute.

 
STATE HIGHER-ED FUNDING: SELECTED PRESSURES
STATE ACTION TAKEN
Maryland 7% system budget cut; 2nd consecutive year
Washington 1.5% cut to all 4-year public institutions
Virginia $600M in infrastructure funding paused
Nevada / California Tuition increases enacted or under consideration
 
DR. HURWITZ'S TAKE

The public university value proposition — excellent education at a reasonable cost — is under direct threat from this cascade. If your student is considering a flagship state school in a state with budget pressure, you need to factor in likely tuition increases of 5–15% over the next three years. That can dramatically change the sticker price calculation. My strong advice right now: run the 4-year cost of attendance at any public school you're considering with a conservative 8% annual tuition increase, not the current rate. And for lower-income families, the risk of state need-based aid shrinking right when you need it is real — this is precisely why I advise families to look hard at private colleges with strong financial aid endowments alongside public options.

 
SILVER LININGS
  • States like Massachusetts with dedicated higher-ed tax revenue are more insulated
  • Years of prior growth give some systems cushion before deep cuts
  • Strong enrollment demand gives universities some tuition-setting flexibility
THE RISKS
  • Community colleges — highest risk — serve the most cost-sensitive students
  • Tuition increases will compound annually, not just hit once
  • Low-income students face reduced aid exactly when costs rise
 
✓ ACTION CHECKLIST

✓ When comparing public vs. private college costs, model 4-year totals with a projected 7–10% annual tuition increase at public schools — not today's flat rate.

✓ Check whether your state has protected higher-ed funding through dedicated revenue streams (like Massachusetts' Fair Share Amendment) — those states carry lower tuition-spike risk.

✓ For families with demonstrated financial need, weight private colleges' guaranteed financial aid commitments heavily — a private school that meets 100% of need may end up cheaper than a public flagship facing budget pressure.

 
KEY SOURCES

Inside Higher Ed — States Grapple With OBBBA Cuts (Apr. 21, 2026)
Center for American Progress — State Funding Stability Report (Apr. 2026)
Pew Charitable Trusts — Higher Education's Uncertain Fiscal Future

GUIDANCE COUNSELOR CORNER

Notes for Counselors: Navigating Structural Uncertainty With Your Students

 

On Harvard and Federal Funding Battles: Students and families are asking whether elite research universities are safe choices given the ongoing funding wars. Your most useful framing: institutional resilience matters more than headline risk. Harvard, despite its extraordinary challenges, has maintained its financial aid commitments and research capacity. Help students understand that the legal battles are about governance and academic freedom — not about whether these schools will continue to serve undergraduates well. The outcome of the First Circuit case will be worth watching, but it should not drive list-building decisions this fall.

 

On Program Cuts and the STATS Rule: Students committed to niche humanities or language programs need your active guidance right now. The wave of program consolidations — from Syracuse's 93 to UNT's 70 to Ohio State's closures — reflects a national trend that is accelerating under federal policy pressure. For students whose college choice is driven by a specific major, conduct a program health check: enrollment numbers, faculty lines, and any administrative communications about reviews. A great major at a school where it's a strategic priority beats the same major at a school where it's on the chopping block.

 

On Cost Planning With Public Universities: The state budget squeeze is here. When advising families comparing public and private options, introduce the 4-year projected cost model with tuition inflation built in — not just today's sticker price. A private college meeting 100% of demonstrated need with a guaranteed multi-year aid package may carry less financial risk than a public flagship facing annual budget pressure. This is counterintuitive for many families, but the numbers increasingly support it.

 

Forward this edition freely to colleagues with attribution. Subscribe at nhurwitz.kit.com/2303368ea2.

FOR FAMILIES

Your Action Guide — Edition 2026-17

Dr. Hurwitz's Analysis · April 21–25, 2026

 

1. Watch the First Circuit Docket

The Trump administration's appeal of the Harvard funding ruling will be decided by the First Circuit, likely before fall 2026. This decision will define federal leverage over every research university. If your student is applying early action or early decision in fall 2026 to a research university, track this ruling as a material factor.

2. Verify Your Student's Intended Major Is Secure

Use IPEDS enrollment data and each school's academic program catalog to confirm the specific major your student wants is actively enrolling students and has a full faculty complement. Program cuts are accelerating nationally — verify before committing.

3. Model 4-Year Public University Costs With Inflation

Don't use today's tuition rate as your 4-year projection for public schools. Apply a conservative 7–10% annual increase to account for state budget pressures. In many cases, a well-endowed private college with a strong financial aid commitment will be the better financial choice.

4. Comment on the STATS Rule Before May 20

The proposed STATS earnings accountability rule has a public comment window closing May 20, 2026. If your family has views on how this would affect humanities, education, or social-service majors, submitting a comment directly to the Federal Register is the appropriate channel. Your voice is part of the record.

5. Prioritize Institutionally Stable Colleges on Your List

With financial pressures building across the sector, institutional financial health matters more than it did five years ago. In your research, look for strong endowments relative to enrollment, healthy enrollment trends, and explicit financial aid guarantees. Weak balance sheets lead to cuts in exactly the services — tutoring, advising, career centers — your student needs.

6. For Graduate-Bound Students: Broaden Your STEM School List

The collapse in international graduate student enrollment at state flagship STEM programs is a real opening for qualified domestic applicants. If your student is heading into a master's or PhD program in engineering, CS, or the sciences, expand your application list to include flagship programs where you might previously have considered yourself a long shot.

 
DR. HURWITZ'S BOTTOM LINE

The higher education landscape is being restructured at a pace we haven't seen in a generation. Federal funding rules, visa policy, state budget pressure, and programmatic consolidation are all moving simultaneously. The families who navigate this best will be the ones who research deeply, model costs honestly, and build genuinely strategic college lists — not the ones who guess or follow outdated conventional wisdom. That's what I'm here to help you do.

Know a family navigating college decisions?

Forward this edition. Higher Ed Insider is free, independent, and published weekly.
Every subscriber gets the same intelligence I give my private clients.

SUBSCRIBE FREE →

HIGHER ED INSIDER · Published by Hurwitz Consulting
hurwitzadmissions.com · nathan@hurwitzadmissions.com · (203) 613-9262

© 2026 Hurwitz Consulting · All rights reserved · Edition 2026-17

You are receiving this because you subscribed to Higher Ed Insider.
Unsubscribe · View online

 

Dr. Nathan Hurwitz, College Admissions Consultant

Tenured professor, college admissions consultant, and editor of "Higher Ed Insider," helping families navigate elite college admissions with clarity, strategy, and calm. For students applying to Top 100, Ivy-adjacent, honors, STEM, business, and performing arts programs.

Read more from Dr. Nathan Hurwitz, College Admissions Consultant
Higher Ed Insider

Higher Ed Insider — Edition 2026-15 Intelligence for Families Navigating College Admissions NH HIGHER ED INSIDER By Dr. Nathan Hurwitz · Hurwitz Consulting EDITION 2026-15 · APRIL 7–11, 2026 · © 2026 HURWITZ CONSULTING www.hurwitzadmissions.com | nathan@hurwitzadmissions.com | (203) 613-9262 By the Numbers — Edition 2026-15 $2.6B DOJ seeks Harvard repayment 17% Drop in new intl. enrollment 93 Programs cut at Syracuse 17 States block admissions data demand $7B Estimated econ. loss from intl....

Higher Ed Insider

Higher Ed Insider — Edition 2026-15 Intelligence for Families Navigating College Admissions NH HIGHER ED INSIDER By Dr. Nathan Hurwitz · Hurwitz Consulting EDITION 2026-15 · APRIL 7–11, 2026 · © 2026 HURWITZ CONSULTING www.hurwitzadmissions.com | nathan@hurwitzadmissions.com | (203) 613-9262 By the Numbers — Edition 2026-15 $2.6B DOJ seeks Harvard repayment 17% Drop in new intl. enrollment 93 Programs cut at Syracuse 17 States block admissions data demand $7B Estimated econ. loss from intl....

Higher Ed Insider — Edition 2026-14 Vol. I, Issue 14 · Edition 2026-14 March 30 – April 3, 2026 College Admissions Intelligence Higher Ed Insider Curated higher education intelligence for families navigating college today NH Dr. NathanHurwitz Editor-in-Chief Edition 2026-14 · March 30 – April 3, 2026 © 2026 Hurwitz Consulting ✉ nathan@hurwitzadmissions.com · 🌐 hurwitzadmissions.com · (203) 613-9262 This Week By the Numbers Apr. 25 Deadline for federal agencies to insert anti-DEI clauses in...