Does the transfer of new initial students make DSOs accountable for determinations over which they have no control?
No. After admission into the United States, a new initial student, like every other student (whether U.S. citizen or foreign), can apply for a transfer to another SEVP-certified school. The transfer-out school is not responsible for determining the suitability of the transfer-in school and is in no way required to approve the transfer. The transfer-out school is only responsible for determining that the other SEVP-certified school has accepted the student. Unlike the M-1 class of admission, there is no requirement that F-1 students apply to DHS for permission to transfer (which would involve filing a form with a fee for an adjudicative decision by USCIS).