Complaint sub-issue: Trouble with how payments are being handled

I would like to file a general complaint regarding the handling of my student loans by FedLoan Servicing. I believe that this is a systemic problem connected to student loan policy more broadly that I would like to flag to the attention of the CFPB, that can not be addressed individually to my specific situation but rather would require further modification to current temporary Public Service Loan Forgiveness rules to resolve. 

Specifically, in the handling of matters pertaining to my federal student loans FedLoan Servicing has both taken inordinately lengthy amounts of time to process my applications for loan consolidation, and income driven repayment plans, and has arbitrarily rejected these applications without first making any effort to contact me or resolve the issue before canceling my applications, thereby repeatedly forcing me to refile again and again from the beginning. For example, after graduating, my loan consolidation application took nearly a year for them to process. My applications for income driven repayment plans have been repeatedly rejected or canceled, after lengthy waiting time for these applications to be processed, without explanation or efforts to email, call, or notify me of any outstanding requirements that need to be met. This in itself has been incredibly frustrating! 

It also seems to have been the standard practice of FedLoan Servicing to automatically place my loans into forbearance during these processing periods. There have been multiple times I have been told that my application was canceled for an arbitrary reason such as failing to pay a {$5.00} fee that I was never notified that I needed to pay, or claiming I had checked the wrong box on my application form, when my PDF records of my application forms indicate clearly I had never checked. 

Furthermore, because my employers during these periods are 501c3 non-profits, had my loans requests been processed more efficiently, I would have been able to earn credit for public service loan forgiveness during the time that FedLoan Servicing took to process my loan requests, as my IDR loan payments have often been determined to be {$0.00} per month. However, because of the extended lengths of time that FedLoan Servicing has taken to process my loan requests and their placement of my loans into forbearance status during those periods of time, I have lost out on YEARS of monthly credits toward earning public service loan forgiveness. 

Since XX/XX/2007, I have completed at least 164 months of full-time employment or combinations of part-time employment exceeding XXXX hours per work for qualified PSLF employers, and continue to work full-time for a PSLF qualifying employer. Yet, because my loans have so frequently been placed into forbearance status by FedLoan Servicing during this time ( primarily due to the time it has taken them to process paperwork on my loans ) to date, my FedLoan Servicing account as it currently shows, says I have only earned 6 months of credits toward PSLF to date!

While I am working to submit the required paperwork to certify all of my qualifying employment for PSLF under the temporary PSLF rules that are currently in effect, to request that the amount of credits I have earned toward PSLF be redetermined under temporary PSLF guidelines, I am concerned that because my loans were so frequently placed into lengthy periods of forbearance due to the inefficiency and failure of FedLoan Servicing to process loan requests in a timely way, and because periods of qualified employment during which loans were in deferment or forbearance status do not count toward loan forgiveness -- even under the temporarily relaxed PSLF guidelines -- that most of the years in which I have worked for qualified PSLF employers more than 30 hours per week, will still not be counted towards loan forgiveness.

Again, I believe that this is systemic problem that I do not necessarily believe can be resolved directly with FedLoan Servicing nor on an individual basis. I am filing this complaint for the purpose of bringing this issue to the attention of the CFPB, in hopes that it might encourage the bureau to raise this concern in its efforts to advocate for student loan borrowers, considering specifically, how temporary guidelines for PSLF count or disqualify periods of qualifying employment. I also hope to bring awareness to the bureau about the tremendously lengthy processing times and arbitrary cancelations of loan requests without prior effort to contact borrowers to resolve outstanding concerns as a problem that I believe have been endemic within the practices and operations of FedLoan Servicing. As the US Department of Education 's only allowable servicer for borrowers who are pursuing PSLF, I believe that these matters should be of particular concern to the Bureau as the federal oversight agency that is responsible for overseeing financial protection and rights for federal student loan borrowers. 

Thank you for your attention and recognition of this matter and any future efforts by the CFPB that might result from consideration of this information. 

Sincerely, XXXX XXXX XXXX