Consumer complaint received 2018-06-04
Company: GREAT LAKES
State: PA
Product: Student loan
Sub-product: Federal student loan servicing
Issue: Struggling to repay your loan
Sub-issue: Can't get other flexible options for repaying your loan

Complaint:
I have a Stafford Loan serviced by XXXX XXXX XXXX XXXX,  XXXX XXXX XXXX, XXXX, XXXX XXXX. This is my loan for XXXX school. I am now a XXXX XXXX and XXXX XXXX XXXX who shares a law office with another attorney. Financially, I am essentially XXXX. My income varies drastically based on client payments and contingent cases. For example, in XX/XX/XXXX, my income was roughly in the high 60,000 range. For XX/XX/XXXX, which saw several contingent cases hit successfully, my income was considerably higher at roughly XXXX. 

I have been enrolled in income based repayment for several years now with Great Lakes and never had a problem. I was in the process of buying a house when the time for IBR renewal came up. I applied on or about XX/XX/XXXX. I provided details on my income and how it fluctuates in my application. I started receiving e-mails about additional information being needed. These e-mails were constant and were requesting copious amounts of information. I had never experienced anything like this before in past IBR applications. 

I was in the midst of the house buying process and could not dedicate the necessary time to these requests, and planned on addressing them the following month. I received a phone call on XX/XX/XXXX from a woman with Great Lakes. She did not identify herself when she called and I had to ask who she was with ( this should be on the recording they made ). She was very polite and nice, and asked about my IBR application. I explained the situation as I had before. She said all I needed was my tax return. I specifically asked her if I needed anything else. She said no. I justifiably relied on that, and attempted to fax my return later that day to the number on Great Lakes ' website. It didn't go through. I then uploaded the return on the website and received confirmation it went through. 

Two days later I received another email saying more info was needed. I figured, based on the woman 's representations to me, that it hadn't been processed yet as this wasn't different from past emails. 

On XX/XX/XXXX, I received an e-mail stating I was no longer eligible for a reduced payment. I was very confused and faxed a letter along with a completed form of my income estimates, referencing the phone call, and even more information including my profit and losses from the first three months of this year. Meanwhile, my notifications are saying that my payment is going up toXXXX  per month -- something I can not afford, which I state in my XX/XX/XXXX letter. 

I received no acknowledgement whatsoever of this and continued to received automated e-mails asking for further information. No phone calls. On XX/XX/XXXX I got another form that was identical to the one I already submitted and asked to fill it out. No explanation.

I finally get fed up and on Friday XX/XX/XXXX, sent everything I had provided to them along with additional information in the form of a list of all of my income thus far this year, along with a very stern letter demanding they process my information and again referencing the XX/XX/XXXX conversation with their representative that the tax return was sufficient. I noted that I was a lawyer and was suspicious about how this process had unfolded, and referenced that I intended on contemplating legal action and filing a complaint with your agency if they did not resolve this mater based on the copious information I had given them. 

Less than 48 hours later, on XX/XX/XXXX at XXXX on Sunday afternoon, I received a message that not only was my IBR application denied, I was wholly removed from the IBR program and my interest was capitalized. I had NO notice this could happen. This is in stark contrast to the XX/XX/XXXX email where I wasn't removed from IBR but my payment went up. This is blatant retaliation and a predatory  lending and unfair trade practice as those terms are defined under federal and XXXX law. These practices also fall squarely within the unfair and illegal IBR practices discussed in CFPB 's XX/XX/XXXX supervisory highlights ( spring ) as well as other articles and periodicals and in XXXX  's XX/XX/XXXX lawsuit against Navient which involved in part identical practices as to IBR. 

I can not afford full payments of XXXX every month. My interest has also been capitalized, without notice to me that this could happen, in what is clearly retaliation for my XX/XX/XXXX letter. I am fortunately paid through for another year or so thanks to a large lump sum payment I made earlier this year. However, I was forced to cancel my auto-payments yesterday after receiving this e-mail because I can not afford them, and am terrified of the ramifications this will have on my credit and other consequences such as interest, as I won't be able to make monthly payments for the time being. While canceling my auto-payments, I observed that the chart Great Lakes uses to break down my interest and principal shows the overwhelming majority being principal. This does not strike me as being correct ( I could be wrong ), and I would like an explanation. 

These identical practices have been labeled as unfair and illegal by AG XXXX XXXX in his recent lawsuit and I believe Great Lakes is engaging in similar practices. I am strongly contemplating a lawsuit myself but wish to try to resolve this through the administrative process first. Statutes involved/potentially violated include but are not necessarily limited to Consumer Financial Protection Act, XXXX  's Unfair Trade Practices and Consumer Protection Law, the Fair Debt Collection Practices Act, and the Fair Credit Reporting Act.

Company public response: Company believes it acted appropriately as authorized by contract or law
Company response to consumer: Closed with explanation