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Additionally, Title IX is a affliction of receipt
of Federal economic assistance, whilst the Clery Act is
a ailment of receipt of Federal student monetary help for pupils at establishments
of higher education. These commenters noted that the Clery Act polices require institutions to have a policy statement outlining the approach and course of action for disclosures of sexual assault (and a
few other crimes) and asserted that the assertion would utilize regardless of whether the offense happened
on or off campus. One commenter asserted that Congress precisely defined what due course of action legal rights it requires for campus adjudications of sexual assault in the Clery Act and nowhere did Congress manifest an intent that the Department need to take
into account the elevated thanks process protections for
respondents outlined in the proposed rule. Another commenter mentioned
that the Department enacted the Clery Act laws next a negotiated rulemaking process developed to implement Congress's intent.
The commenter argued that the Department's interpretation of Title IX in the proposed procedures
is incompatible with its Clery Act laws and
the suitable Clery Act rulemaking process, which demonstrates that the Department's Title
IX rulemaking is arbitrary and capricious and an try by the
Department to circumvent its individual polices and the very clear intent of Congress with respect to procedural owing approach in campus sexual assault proceedings.