Product: Student loan

Please see the first Attachment, a XXXX XXXX version of the information below, as the website does not allow formatting or proper spacing. 



This complaint pertains to Navients handling of my application to consolidate my 7 federal student loans. In order to make an informed decision about whether or not it makes financial sense to consolidate my 7 federal student loans, I need to know which repayment plans I would be eligible for if I were to consolidate, and Navient can not /will not give me that information. 

BACKGROUND : I am trying to determine whether or not to consolidate the loans. If I do consolidate them now, ( assuming I am eligible for an Income-Driven Repayment ( IDR ) plan ), I will have a more manageable monthly payment, BUT, I will effectively be throwing away 10 years of payments made under 4 of my loans that were already on an IDR plan. 

( My understanding is that once the loans are consolidated, there are 8 different repayment plan options, which can be broken into 2 categories : Standard repayment plans, and Income-Driven ( IDR ) repayment plans. The Standard repayment plans include Standard, Graduated, Extended Fixed, and Extended Graduated. My estimated payments under the Standard plans would range from a low of $ XXXX/month to a high of $ XXXX/month. The IDR plans include Income-Contingent, Income-Based, PAYE, and REPAYE. The estimated payment under the REPAYE plan ( which is the plan I selected and applied for ) is estimated to be $ XXXX/month ). 

After much research and consideration, I have concluded that I do want to proceed with the consolidation, BUT ONLY IF I AM ELIGIBLE FOR AN IDR PLAN. Therefore, I NEED TO CONFIRMATION OF MY ELIGIBILITY FOR THE DIFFERENT IDR PLANS, AS WELL AS THE ESTIMATED TERMS OF THOSE PLANS, BEFORE I GIVE THE OK TO PROCEED WITH THE CONSOLIDATION. 

My understanding is that Navient ( as the servicer assigned by the US Dept. of Education to process the consolidation application, per Attachment C Email from studentloans.gov ) is supposed to provide me with this information via a Consolidation Loan Summary Statement ( CLSS ). To date, Navient has been unwilling or unable to provide this information the sections of the two CLSSs that I received ( Attachment E and Attachment G ) that address eligibility for the IDR plans are simply blank, and the specific IDR plan that I selected on my application is not even listed on the CLSSs as an available option. 

Lengthy email correspondence with Navient ( Attachment F ) has provided no substantive explanation for why they can not give me this information. However, a Navient representative has, verbally, offered the following explanation : When processing a consolidation loan application, Navient does not provide the IDR plan information if they are not going to be the servicer of the new ( consolidated ) loan. 

In other words, Navient is effectively saying, You have to consolidate the loans first, and then you find out the repayment plans that are available to you. This is not acceptable. The most basic principle of fair lending laws is full disclosure of the terms of a potential loan before the loan is made. I am asking CFPB to step in to help me get the information from Navient I need to make an informed decision. 



SEQUENCE/HISTORY OF THE CONSOLIDATION APPLICATION - XX/XX/19 I submitted my CL application ( Attachment A ) and my IDR Request ( Attachment B ) via the studentloans.gov website. I also received a confirmation email from studentloans.gov on XX/XX/19 ( Attachment C ) stating that XXXX ( the servicer I selected on the application ) would be the servicer of the consolidated loan, but that Navient would be the servicer processing the CL application. The email, Attachment C, stated Once your consolidation servicer receives the application and documentation from you, the servicer will contact you after reviewing your application and your eligibility for the repayment plan you selected. 

- On XX/XX/19 I received an email from Navient ( Attachment D ) confirming receipt of my application. The email further advised that I would receive a Summary Statement ( hereinafter Consolidation Loan Summary Statement, or CLSS Attachment E ), and that I would have 10 business days after receiving the CLSS to request any changes. 

- On XX/XX/19 I received the CLSS, dated XX/XX/19, via email. This meant the deadline to request changes or cancel the consolidation would be XX/XX/19. 
o Page 1 of the CLSS acknowledged that I requested the REPAYE IDR plan. 

o Page 3 of the CLSS, under Section 2, states This [ Section 2 ] allows you to compare the estimated Monthly Payment amount and total repayment amounts under each of the Direct Consolidation Loan repayment plans for which you are eligible ( emphasis supplied ). 

o Page 5 of the CLSS is titled Direct Consolidation Loan Summary Sheet ( Summary Sheet ) and Section 2 Estimates of your Direct Consolidation Loan Repayment Options The Summary Sheet sets for the estimates under the different Standard repayment plans ( which I am not interested in, nor did I request ). 
However, the Summary Sheet does not provide any of the information about either the estimated terms of, and/or my eligibility to participate in, 3 of the 4 IDR plansFurther, the specific IDR plan that I did select ( REPAYE ) is not even listed as an available option on the Summary Sheet. 
Given the language on page 3 of the CLSS ( This [ Section 2 ] allows you to compare the estimated Monthly Payment amount and total repayment amounts under each of the Direct Consolidation Loan repayment plans for which you are eligible ), this makes me question whether or not I would be eligible for an IDR plan ( specifically, REPAYE ) after consolidation. 

o Since, as stated above, I only want to consolidate the loans if I am eligible for an IDR plan, I need confirmation, in writing, about my eligibility for IDR before the consolidation goes through. Thus, I have been trying to get Navient to give me that written confirmation in the form of an updated/corrected CLSS since I first received the XX/XX/19 CLSS. Their responses to my request have been all over the place, but ultimately they have not given me this confirmation that I need to make an informed decision about whether to proceed with the consolidation. 

CORRESPONDENCE WITH NAVIENT AFTER RECEIPT OF THE XX/XX/19 CLSS. 
o XX/XX/19 Email to Navient requesting an email copy of the CLSS once available. 
o XX/XX/19 Email from Navient advising CLSS would be available on XX/XX/19. 
o XX/XX/19 Email from Navient with the XX/XX/19 CLSS o XX/XX/19 Email to Navient explaining the CLSS does not contain the info I need regarding my IDR plan eligibility, or the estimated terms. 
o XX/XX/19 Email from Navient confirming that I did provide the documentation necessary for them to process my IDR request, and advising that the IDR info should be listed in the letter. 
o XX/XX/19 Email to Navient with a more detailed explanation of my position and need for confirmation of my eligibility for IDR. 
o XX/XX/19 Email from Navient discussing IDR eligibility generally, but confirming that Navient is not able to actually confirm my eligibility for IDR. This email also advised me to call Navient Customer Service, suggesting that their agents could verbally confirm my eligibility for IDR ( but for some reason, it could not be confirmed via the new CLSS I was requesting ). 


o XX/XX/19 Phone call to Navient re status of my request for the new CLSS. The agent advised that she saw no pending request for a new CLSS in their system, but stated she would re-initiate the request, and that it should be available to me via Navients website within 48 business hoursthis would be XX/XX/19, which was the deadline to change/cancel the consolidation. The agent also explained the process for pausing or temporarily canceling the consolidation request, if I did not get the info I needed in time. 

o XX/XX/19 Phone call to Navient to check status of the new CLSS. The agent stated he saw notes regarding the XX/XX/19 call, but did not see any pending request for a generation of a new CLSS. This agent also stated he would re-initiate the request for a new CLSS. 

o XX/XX/19 Email to Navient instructing them to temporarily cancel the consolidation, as I still had not received the new CLSS that had been promised numerous times. 
o XX/XX/19 Email from Navient confirming temporary cancelation of my consolidation application. This email also stated, for the first time, that any new CLSS will NOT include IDR plan information, because [ t ] hat information comes from the Servicing Department. 
o XX/XX/19 Email to Navient explaining that I can not proceed with consolidation without getting confirmation of the IDR information. Also advised of my intention to file this CFPB complaint. 

o XX/XX/19 Email from XXXX XXXX, Supervisor in Naviets Consolidation Dept,  advising a supervisor in another area would contact me to address my issue. 
o XX/XX/19 Follow-up email to XXXX, as I had not heard from anyone. 
o XX/XX/19 Response from XXXX stating she would follow up with the other supervisor, and also advising she can not create you an updated Loan Summary Statement. 

o XX/XX/19 Received call from XXXX XXXX, a supervisor in the Customer Service Department. She explained Navients process and advised I could look up my eligibility for IDR using a number of different resources, but I again explained I needed confirmation in writing. XXXX advised she would look into it and get back to me, particularly re the issue of why the REPAYE plan was not even listed as an available option on the XX/XX/19 CLSS. I advised I would wait to hear from her until Monday, XX/XX/19 before filing the complaint with CFPB. 

o XX/XX/19 & XX/XX/19 Phone calls with Ms. XXXX, where she explained that it appears that the problem is that Navient does not have a process/procedure for providing the IDR info when they are not going to be the servicer of the loan once the ( potential ) consolidation is complete. 
o XX/XX/19 Recd 2nd CLSS dated XXXX ( Attachment G ), again without any of the IDR information. 
o XX/XX/19 Recd letter from Navient dated XX/XX/19 ( Attachment H ) confirming my consolidation loan application was not processed due to the fact that I cancelled/postponed it.