An independent English language school in California that enrolls F-1 students answers to three bodies: the Bureau for Private Postsecondary Education for the right to operate, an accreditor (ACCET or CEA) because federal law requires it, and SEVP, which certifies the school to issue I-20s. Each one wants records. Most of what they want is the same record, read three ways. Here is who asks for what, and which one piece of paper all three are really checking.
Written October 2026 · Facts checked against Public Law 111-306, 8 CFR §§ 214.2(f) and 214.3, ice.gov/sevis, studyinthestates.dhs.gov and bppe.ca.gov
The three bodies rarely talk to each other. The school is the only place where their three sets of rules meet, usually in the person of one office manager and one DSO who are sometimes the same person. The practical question is not “what does each agency want”. It is “which records, kept once, satisfy all three”.
What each one wants
- The Bureau wants the business to be straight with the student
Did the student get the catalog and the fact sheet before signing, does the enrollment agreement say what it must, was the refund calculated by the rule, was the STRF disclosure in the agreement, and can you produce the student’s file five years later. Its Annual Report counts enrollments and completions per program. The BPPE guide covers the whole list.
- The accreditor wants the education to be real
A placement test that puts students in the right level, a curriculum with levels and outcomes, an attendance policy that is written down and enforced, completion and progression that you can show, and student files that an on-site team can open at random. ACCET and CEA both publish their standards; the attendance policy and the student-records standard are the two that bite in a visit.
- SEVP wants to know the student is here for school
The DSO certifies on the I-20 that the student will carry a full course of study, then reports in SEVIS that they registered each session, and reports within 21 days when they drop below full time, change address, take leave, finish early or stop attending. The regulation at 8 CFR § 214.3(g) lists what the school must keep per student and make available to DHS on request.
The one piece of paper all three are checking
Attendance. The Bureau’s inspector asks whether the student on the roster was really enrolled and refunded by the rule, and the attendance record is how you show when they started and stopped. The accreditor’s visit asks whether you enforce your attendance policy, and the only proof is the marks. The DSO’s certification of a full course of study is, for a classroom English program, a statement that this student was in class 18 hours a week, and the marks are the only thing behind that statement when SEVP or an immigration officer asks.
Which means the attendance binder for the Monday morning track is a federal record, a state record and an accreditation record at once, kept by a teacher with a pen. Nothing is wrong with the pen. What goes wrong is the gap between the pen and the office: the ticks that never get totalled, the student who moved from Intermediate to Advanced and whose old sheet is in a different binder, the week the substitute did not mark anyone.
Kept once, read three ways
A record that satisfies all three looks like this per student: identity as on the passport; the program and the level, with the date of each level change; the signed enrollment agreement and the fact sheet acknowledgment; every session they were scheduled for and the mark they got; the hours that adds up to per week; the status changes (leave, withdrawal, completion) with dates; the documents the school issued (verification letters, certificates) and the documents it holds (passport page, I-20 copies, proof of funds). The Bureau reads the agreement and the dates. The accreditor reads the levels and the attendance policy. The DSO reads the weekly hours and the status changes, and types them into SEVIS.
What Udooku does about it, and what it doesn’t
Udooku holds that record: one student, every level as its own enrollment, every session marked once by the teacher with a note of who marked it and when, status changes with dates, issued letters numbered and kept, uploads attached to the student. The DSO reads the weekly hours and the dates off one screen. Udooku does not talk to SEVIS, does not issue I-20s, is not an accreditation self-study and is not an LMS. The coursebook platform does the teaching; SEVIS does the reporting; Udooku is the office record in between. How it fits a language school, including what it leaves out.
- Public Law 111-306, Accreditation of English Language Training Programs Act (2010)
- Study in the States, English language training and the full course of study
- 8 CFR § 214.2(f)(6), full course of study and § 214.3(g), school recordkeeping and reporting
- ICE SEVP, DSO requirements
- ACCET and CEA, standards and policies
- Bureau for Private Postsecondary Education