This report addresses the trend of for-profit colleges going exclusively online or contracting with nonprofit (mostly public) colleges to run their online programs. Using results from focus groups of for-profit student borrowers, we explore the risks that this rapid shift entails for students already vulnerable to poor outcomes. The Department of Education is seeking to weaken accountability for distance education (online) providers that enroll students across wide geographies. This approach will increase risks for students and the federal student loan program. The Department of Education should increase oversight, and states should also act to protect consumers that are enrolled in online college programs, particularly those that are for-profit, irrespective of the home state of the online program provider.