20 U.S.C. § 1092(f) · 34 CFR § 668.46
Clery Act
Requires institutions participating in federal student aid to collect, classify, and publish campus crime information, warn the community about threats, and maintain the records behind all of it. It is the most procedurally exacting framework we practice in, and the one most often run by someone doing it alongside another job.
What it covers
The annual security report
Published each year, carrying three years of statistics, policy statements, and required disclosures.
Timely warnings and emergency notification
Two distinct obligations with different triggers, different audiences, and different timing.
The daily crime log
Maintained by institutions with a campus police or security department, open for public inspection.
VAWA provisions
Statistics and procedures for dating violence, domestic violence, sexual assault, and stalking, including required prevention programming.
Who it applies to
- Institutions
- Postsecondary institutions participating in Title IV federal student aid programs.
- Enforcement
- The Department of Education, through program reviews, civil penalties per violation, and in serious cases limits on Title IV participation.
- Geography
- Clery geography is a defined concept covering on-campus, non-campus, and public property, and misclassifying it is one of the most common findings.
- Campus security authorities
- A defined group across the institution that must be identified, notified of the role, and trained on reporting.
What has to be in place
The structural obligations, stated plainly. Specifics vary by institution and by state.
An identified CSA population
Reviewed annually rather than inherited, with notification and training documented.
Defined geography
Mapped, dated, and revisited when property changes hands or a program runs somewhere new.
Classification practice
Consistent counting and classification, with decisions recorded so the numbers can be reconstructed later.
Warning protocols
Written criteria for who decides, on what basis, and how fast, so the decision is not being invented during an emergency.
Policy statements
Every disclosure the regulation requires, kept current rather than rolled forward.
Retention
Records supporting the statistics, retained for the required period and organized for a program review.
Where it usually goes wrong
Clery findings are almost never about hiding crime. They are about classification, geography, and missing documentation: a location never mapped, a CSA population that was never identified, statistics that cannot be reconstructed from the underlying records. The obligation is annual, but the work is continuous, and institutions that do it once a year in September are the ones that get findings.
Read the questions we getThis page is a general overview written by compliance practitioners, not legal advice. Fractional Coordinator is a civil rights compliance firm, not a law firm. Regulations change, and how a framework applies depends on your institution and your facts. Confirm with counsel before making an institutional decision.