Product: Student loan

I have been a professor at XXXX XXXX XXXX College since XXXX of XXXX. The PSLF program began in XXXX, XXXX have been enrolled in it since it began, over 130 months ago. 

Like many in the PSLF program, I have had plenty of problems with the Pennsylvania Higher Education Assistance Agency ( PHEAA )  over the years, including some that have required the intervention of the CFPB and my members of XXXX. 

In the first case, I have asked numerous times for copies of the promissory notes the PHEAA holds for the loans the service for me, and any person they may claim has cosigned for any loan under my name. They have never responded to any request I have made on the matter.

Next, PHEAA faults me for its own errors in payment processing  delays and an involuntary " administrative forbearance '' due to its shoddy of records transfers in XXXX, XXXX and XXXX of XXXX. PHEAA has been made aware of this oversight repeatedly and has never corrected it, despite various assurances. This results in three non-qualifying payments, according to PHEAA. 

Further, in XXXX, apropos of nothing, and without warning, PHEAA removed my loans from the IBR program and returned me to the standard repayment plan, which required another " administrative  forbearance '' I had no choice in the matterwhile they reevaluated my suitability for IBR for three months in XXXX, XXXX, and XXXX of XXXX, after I protested the change and made them aware of their error. Despite there being no fault on my part, these months are also counted as non-qualifying, and they have refused to change their records.

You may view this at the attachments labeled Payment Chart PDF and Payments List PDF. NB : I have been on ACH automated debit payment since I have been dealing with PHEAAany delay or late payment recorded by them is, by definition, due to their action ( s ).

Seeing a pattern, I began saving receipts ; e.g., see Payments  XXXX XXXX  and Payments XXXX XXXX  showing 26 and 34 qualifying payments, respectively, even then, with approximate PSLF dates in  XXXX. 

In XXXX, I was forced to seek help from both the CFPB and members of Ohio 's Congressional delegation, the Hons. Mssrs. Rep. XXXX XXXX and Sen. XXXX XXXX when that XXXX, again, for no ascertainable reason, PHEAA recounted my qualifying payments and subtracted a significant number. See XX/XX/XXXX XXXX and XX/XX/XXXX XXXX. 

After repeated attempts to sort out the matter directly with themand receiving either automated, garbled, nonsensical, semi-english, or gibberish repliesI filed the complaint and reply that you will see as CFPB Complaint and Reply XXXX XXXX. 

Replies from my congressmen also contained an analysis from XXXX XXXX, a loan analyst at the Department of Education, whose count, notwithstanding the undercount I describe above resulting from six forced " administrative forbearances '', agreed with the corrected count described in the correction and apology in the PHEAA 's reply to the CFPB.

Notwithstanding the undercount I describe above resulting from six forced " administrative forbearances, '' the PHEAA and I moved forward using this number as the qualified number of payments. I continued to certify my employment on an annual basis and recertify my income for the purposes of IBR status. See, XX/XX/XXXX XXXX, XX/XX/XXXX XXXX, XX/XX/XXXX XXXX, XX/XX/XXXX XXXX. 

The XX/XX/XXXX Qualifying Payment Count shows 123 of 120 necessary qualifying payments, which is obviously 3 in excess of  the statutorily required number. See  XX/XX/XXXX PDF. 

These issues I have described directly relate to the present problem, which is the deliberate miscounting of qualifying payments and what is either incompetence or malfeasance on the part of the PHEAA or the Department of Education, or both and all. 

On XX/XX/XXXX my employer, XXXX XXXX XXXX College, submitted a certified PSLF loan forgiveness application ( See PSLF Application PDF ) to the PHEAA via the proper fax  number. 

I also uploaded that document to the Fedloans website myself, as experience has taught me to duplicate efforts when dealing with the PHEAA. 

On XX/XX/XXXX, I received an acknowledgment email stating the PHEAA had received my PSLF application and would begin processing it. See Acknowledgment XXXX. 

On XX/XX/XXXX, I received a letter from PHEAA alerting me that they had reviewed my work and payment history and that GOOD NEWS! They'd determined I was eligible, and it was TIME TO APPLY FOR PSLF! See Apply XXXX. 

Needless to say, this does not make chronological sense at all, and does not inspire confidence that any human being is actually tending the wheel at PHEAA. In fact, it's clear to any observer that much of what's being done at PHEAA is automated, and poorly so. 

On XX/XX/XXXX, I received an updated qualifying payment count from PHEAA showing 123 qualifying payments. See XX/XX/XXXX XXXX. 

On XX/XX/XXXX, a Friday, at nearly midnight, I received two pieces of electronic correspondence from PHEAA : a new qualifying payment count, and a denial of my PSLF application.

The new qualifying payment count ( See XX/XX/XXXX XXXX  ) was, instead of 123, suddenly 111. My estimated eligibility date for PSLF was fully 12 months from now, in  XXXX of XXXX, despite there being supposedly only nine of these newfound qualifying payments left to be paid. One will notice that the change in the counts table shows a marked decrease in date ranges that include dates outside PHEAA service years, or else may require human adjustment. 

This new " count '' is arbitrary, capricious, absurd, and without any grounding in mathematics that I can understand. Notwithstanding the undercount described in the first section resulting from six forced " administrative forbearances, both PHEAA and I have been using the same numbers for nearly three yearsnow, suddenly, when it's time for PSLF, things are very, very different.

The denial letter is even worse, in terms of nonsensicality. See Denial XXXX. It states that I am NOT ELIGIBLE YET, as I have not made 120 Qualifying Payments. The letter estimates my eligibility as XX/XX/XXXX. 

I can only assume it's estimating the remaining three months of this year, plus 10 months, which is in either ignorance or contempt but certainly in violation of the CARES Act and President Trump 's executive orders on Covid-19 Relief forbearance as relates to PSLF. Should I, or the CFPB have to remind PHEAA of this? Nobut the fact is, it shouldn't matter at all BECAUSE THE COUNT IS WRONG.

Remember, this is the PHEAA, denying an application on XX/XX/XXXX, after having told me on XX/XX/XXXX to apply for PSLF, which I had ALREADY done on XX/XX/XXXX, receipt of which they'd confirmed on XX/XX/XXXX, before they'd confirmed 123 qualifying payments on XX/XX/XXXX. 

The letter also claims to list qualifying employers somewhere, and no matter how hard I look, I can not find them! It's like reading something out of XXXX. 

Furthermore, when trying to make sense of this maddening development it seems the website 's available data has been either altered, or scrubbed, to comport with these inexplicable and unacceptable changes, or to limit the ability to challenge them.

Where previously my 123 qualifying payments were displayed there is now written " 44 unqualified payments, '' none of which are explained or justified. My correspondence with PHEAA has been  eliminated prior to XXXX, and there is no independent way for me to count or evaluate qualifying payments on my own using their tools.

Attempts to communicate, reason, or work with PHEAA are in my experience futile. To date, PHEAA has only responded with any affirmative action when a third party has become involved. PHEAA harms. The borrower begs for redress, is ignored, or lied to, or put off. PHEAA moves on. So, here we are. ( I have included, for further background regarding the Department
of Education 's, and the PHEAA 's, malfeasance, intransigence, and mistreatment of borrowers vis a vis the PSLF program, a complaint for declaratory relief filed by the California Attorney  General against Education Secretary XXXX XXXX. The complaint shows that my experience is quite typical, and provides myriad citation to legal and other well-sourced authorities regarding governing statutes, cases, regulations, and administrative actions. See CAL AG INJ XXXX  )