As organizations that represent low-income student loan borrowers, the undersigned organizations comment on the Department of Education’s proposed borrower defense to loan repayment application form. The organizations assist low-income student loan borrowers, many of whom were harmed by unscrupulous schools that engaged in predatory conduct to make a profit off of our clients’ federal student aid dollars. Their comments reflect their experience working directly with low-income borrowers applying for borrower defense and other federal student loan discharges and are intended to help ensure that the proposed borrower defense application form is clear, accessible, and fair to all potentially eligible borrowers. The groups would welcome the opportunity to meet with the Department to discuss ways to make this form more accessible and less burdensome to the borrowers they serve.
The comments first address the estimates the Department has set forth in the supportive statement of the amount of time that will be needed to fill out the individual application form and steps the Department should take to make the form less time-consuming to fill out. The comments then focus in some detail on ways to improve the individual application form. The groups conclude by providing comments regarding the individual borrower reconsideration form and the third party group application forms.