White-label programs in higher education, designed and supported by online program management (OPM) firms, pose unique challenges to current policy. In part this is because OPM firms and services are either exempt from policy or fall into a gray area that policy has not yet considered. Policymakers, however, do not need to develop entirely new structures and systems of oversight to capture the significance and mitigate the risk of white-labeling. This brief identifies several existing policies and laws that can be modified or designated to serve as models for regulation.