Hello CFPB I am having difficulty with Nelnet incorrectly counting the number of payment toward the 25 years till forgiveness under the IBR/ICR programs. 

I contacted Nelnet asking how many payments I have left till forgiveness and was told I have made only 102 payments -- and thus have over 17 years left to go. In actuality, I have made 24 years of payments, and I have made closer to 280 payments. 

I re-contacted Nelnet to ask for clarification and was sent a notice dated XX/XX/XXXX that says Our records indicate you have been enrolled in the Income-Based Repayment ( IBR ) Plan since XX/XX/XXXX. 

However the account history they sent with this notice shows reduced payments under ICR going back to XX/XX/XXXX( this would be at least 192 payments ). Unfortunately, Nelnet did not sent the rest of the record going back to XX/XX/XXXX, which would have shown the rest of the reduced payments under the ICR program. 

I have re-contacted Nelnet twice for an explanation/correction and have not heard back. 

To clarify -- the actual loan has been in ICR and then later the IBR programs since XX/XX/XXXX. I was first placed on the Income Contingent Repayment ( ICR ) plan in the mid XX/XX/XXXXwhen my son had XXXX and I could not work. Under these plans, I made reduced monthly payments under a partial financial hardship. 

Later, when the IBR program became available, I switched from the ICR program to the IBR program. I was told by Nelnet representatives at the time that this switch would not affect the 25 years till forgiveness. When I called a few years ago ( I think it was XX/XX/XXXX) I was told by a Nelnet representatives I should only have about 5 years to go. Now, however, after I have paid on these loans for over 23 years, Nelnet seems to think I have only made 102 payments ( 8 years ) and I still need to pay for another 16 years?? 
Regardless of which program I was using to pay my loans, according to the legal documents I have read ALL of my payments should count toward the 25 years. 

For example -- here is what the it says in the Federal Register ( Vol. 73, No. 206/Thursday, XX/XX/XXXX/Rules and Regulations- Part II )  on page 63259 : 1 ) To qualify for loan forgiveness after 25 years, a borrower must have participated in the income-based repayment plan and satisfied at least one of the following conditions during that period : ( i ) Made reduced monthly payments under a partial financial hardship as provided in paragraph ( b ) ( 1 ) or ( 2 ) of this section, including a monthly payment amount of {$0.00}, as provided under paragraph ( b ) ( 2 ) ( ii ) of this section. [ I meet this qualification! ] The federal register continues and says : ( 3 ) For a borrower who qualifies for the income-based repayment plan, the beginning date for the 25-year period is ( i ) If the borrower made payments under the income contingent repayment plan, the date the borrower made a payment on the loan under that plan at any time after XX/XX/XXXX ; [ < -- Please note XX/XX/XXXX!! This means ALL of my payments on the ICR or IBR made after XX/XX/XXXXshould count!! ] Please look into this and get back to me and let Nelnet know the results as well since I am likely not the only one being impacted by this issue.