August 21, 2017
Betsy DeVos, Secretary
U.S. Department of Education
400 Maryland Ave. SW, Room 6E231
Washington, DC 20202
RE: Evaluation of Existing Regulations [Docket ID: ED-2017-OS-0074]
Dear Secretary DeVos:
Consumers Union, the policy and mobilization arm of Consumer Reports, appreciates the opportunity to comment on existing Department regulations that may be subject to review, repeal, or modification.
We urge the Department to preserve two rules developed by the 2014 negotiated rulemaking committee on Program Integrity and Improvement: (1) the cash management rule, pertaining to student financial accounts; and (2) the state authorization rule, pertaining to distance education programs. Both rules were carefully crafted through a negotiated rulemaking process that included educational and financial institutions, accreditors, financial aid administrators, and groups representing students before proceeding to public comment. The final rules balance diverse interests and ensure commonsense protections for students. They should be fully implemented and vigorously enforced.
We also urge the Department to preserve and support continued borrower enrollment in the REPAYE plan, which was developed by negotiated rulemaking in 2015 and received consensus support from a committee that included schools, financial aid administrators, loan servicers and groups representing students before proceeding to public comment. The REPAYE plan ensures that anyone with a Direct loan, regardless of when they borrowed, has access to an affordable repayment plan that ties monthly payments to their income.