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Comments to the Dept of Education Urging Expanded Access to Pay As You Earn, Other Student Loan Reforms for Negotiated Rulemaking

November 4, 2014

Wendy Macias

U.S. Department of Education

1990 K St. NW, Room 8017

Washington, DC 20006


Re: Negotiated Rulemaking Committee; Public Hearings (Docket ID: ED-2014-OPE-0124)

Dear. Ms. Macias:

Consumers Union, the policy and advocacy arm of Consumer Reports®, appreciates the opportunity to comment on the Department’s plans to engage in further negotiated rulemaking to expand access to the Pay As You Earn (PAYE) repayment plan for federal student loans, which caps monthly payments at 10% of annual discretionary income over a 20-year repayment period. We appreciate the Department’s willingness to hear suggestions for how to best expand PAYE access, as well as other potential topics for consideration during negotiated rulemaking.

  • We urge the Department to use this rulemaking opportunity to improve access to PAYE in a number of ways discussed below, so that more borrowers have meaningful access to affordable and flexible options for managing their loans.
  • To improve borrowers’ experiences during repayment, we also recommend improvements to loan servicing and collections, to ensure that private companies in contract with the Department are not subjecting borrowers to abusive practices that can steer them toward default and keep them there.
  • Furthermore, we encourage the Department to redouble its efforts to prevent evasion of laws meant to protect students and taxpayers from shoddy career education programs, and to ensure that defrauded students have meaningful access to relief.
  • Finally, we urge the Department to complete its important work on updated rules for cash management, which were debated at the negotiated rulemaking committee convened earlier this year.

To read the full comment, click the link below.