Proprietary education dates back to the late 19th century, when institutions focused on professional training in teaching, medicine, and law (Breneman, Pusser, & Turner, S., 2000 ). The Higher Education Reauthorization Act of 1972 included for-profit institutions in federal financial aid programs and changed the language of higher education to postsecondary education (2000). This piece of legislation, along with new technologies and increased demand for higher education, spurred the resurgence of for-profit institutions in the second half of the twentieth century (2000). From these changes came a new era of postsecondary education. According to Turner (2006), for-profit institutions are more responsive to changes in the external environment and are able to exploit new opportunities. Growth among for-profit institutions can be attributed to their ability to vary geographically and meet the need for greater access to education by non-traditional students. Geographic variation refers to the inability of nonprofit educational institutions to adapt to changes in state, regional, and local demand due to political and social forces. For-profit organizations' flexibility in their governance structure, sensitivity to market conditions, and ability to generate investment capital through public and private means allow them to establish themselves in new and emerging markets regardless of career and location. Furthermore, for-profit institutions are able to conceptualize the geographic boundaries of education that constrain traditional educational institutions. Therefore, for-profit institutions hold a competitive advantage over non-profit institutions in attracting the expanding market of the aforementioned non-traditional… middle of paper… have adopted a code of conduct entitled Accountability Standards Conduct and transparency with the aim of addressing key concerns (Fain, 2011; The Foundation For Educational Success, 2011). The issues primarily discussed were the ban on incentive pay based on enrollment and the provision of information to students on the “transferability of credit and loan counseling” (The Foundation For Educational Success, 2011). Institutions that fail the annual review will lose their "good reputation" (2011). Fain (2011) stated that there were no public, economic or organizational sanctions associated with non-compliance other than removal from the Foundation's security website. Currently, major for-profit educational groups have not signed the code of conduct, and only 17% of for-profit institutions have agreed to the standards and their enforcement (2011).