UNFAIR PAYMENT PROCESSING : 1. Since XX/XX/XXXX, I attempted to pay my loans by mailing a check through an external bill payment system with my bank ( XXXX XXXX  ) : 2. On XX/XX/XXXX, my bank ( XXXX XXXX ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient, XXXX XXXX XXXX XXXX, PA XXXX.

3. On XX/XX/XXXX, ( XXXX XXXX  ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient, XXXX XXXX XXXX XXXX, PA XXXX.

4. On XX/XX/XXXX XXXX XXXX received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

5. OnXX/XX/XXXX, ( XXXX XXXX ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient, XXXX XXXX XXXX XXXX, PA XXXX

6. On XX/XX/XXXX, XXXX XXXX   received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

7. On XX/XX/XXXX, XXXX XXXX received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

8. OnXX/XX/XXXX, ( XXXX XXXX  ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient, XXXX XXXX XXXX XXXX, PA XXXX.

9. On XX/XX/XXXX, ( XXXX XXXX ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient, XXXX XXXX XXXX XXXX PA XXXX.

10. On XX/XX/XXXX, XXXX XXXX received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

11. OnXX/XX/XXXX, ( XXXX XXXX  ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient, XXXX XXXX XXXX XXXX, PA XXXX.

12. On XX/XX/XXXX, XXXX XXXX  received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

13. OnXX/XX/XXXX, ( XXXX XXXX ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient, XXXX XXXX XXXX, XXXX, PA XXXX

14. On XX/XX/XXXX, XXXX XXXX  received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

15. On XX/XX/XXXX, ( XXXX XXXX ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient, XXXX XXXX XXXX XXXX, PA XXXX.

16. OnXX/XX/XXXX, XXXX XXXX received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

17. On XX/XX/XXXX, ( XXXX XXXX ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient, XXXX XXXX XXXX XXXX, PA XXXX.

18. On XX/XX/XXXX, XXXX XXXX   received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

19. On XX/XX/XXXX, ( XXXX XXXX ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient, XXXX XXXX XXXX XXXX, PA XXXX.

20. On XX/XX/XXXX, ( XXXX XXXX  ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient, XXXX XXXX XXXX XXXX PA XXXX.

21. On XX/XX/XXXX, XXXX XXXX received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

22. On XX/XX/XXXX, XXXX XXXX  received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

23. On XX/XX/XXXX, XXXX XXXX  received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

24. OnXX/XX/XXXX, XXXX XXXX received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

25. On XX/XX/XXXX, ( XXXX XXXX ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient, XXXX XXXX XXXX XXXX PA XXXX.

26. On XX/XX/XXXX, XXXX XXXX received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

27. On XX/XX/XXXX, ( XXXX XXXX ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient, XXXX XXXX XXXX XXXX, PA XXXX.

28. OnXX/XX/XXXX, XXXX XXXX received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

29. On XX/XX/XXXX, ( XXXX XXXX ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient, XXXX XXXX XXXX XXXX, PA XXXX.

30. On XX/XX/XXXX, XXXX XXXX  received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

31. On XX/XX/XXXX, ( XXXX XXXX ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient, XXXX XXXX XXXX XXXX, PA XXXX.

32. On XX/XX/XXXX, XXXX XXXX received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

33. On XX/XX/XXXX, XXXX XXXX received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

34. On XX/XX/XXXX, ( XXXX XXXX ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient, XXXX XXXX XXXX XXXX, PA XXXX.

35. On XX/XX/XXXX, ( XXXX XXXX ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient - XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX XXXX GA XXXX.

36. On XX/XX/XXXX, XXXX XXXX received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

37. On XX/XX/XXXX, ( XXXX XXXX ) executed an electronic payment of {$96.00} to Navient to their payment address at : Navient - XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX XXXX GA XXXX.

38. On XX/XX/XXXX, XXXX XXXX received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

39. On XX/XX/XXXX, ( XXXX XXXX ) executed an electronic payment of {$96.00} to Navient, to their payment address at : Navient - XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, GA XXXX.

40. On XX/XX/XXXX XXXX XXXX received a returned payment from Navient of {$96.00}, and was required to make a credit adjustment and return those funds to my account.

41. On or aboutXX/XX/XXXX, I received a letter from Navient that my XXXX XXXX XXXX XXXX loans were past due, and that I was required to make a payment of {$380.00} by XX/XX/XXXX. A copy of that letter is attached as Exhibit A 42. I responded to this letter on XX/XX/XXXX and specifically inquired why my loan accounts were not in good standing. A copy of that letter is attached as Exhibit B 43. OnXX/XX/XXXX, Navient specifically informed me that : 44. I have reviewed your account and our records indicate you're not enrolled in our Auto Pay program. If you set up automatic payments with your bank 's bill payment service, please contact your bank to determine why payments have not been made. You-may need to verify that your bank has all of your student loan account information entered correctly. Please know that your account is currently 82 days past due in the amount of {$1100.00}. The next monthly payment of {$380.00} is due on XX/XX/XXXX. Therefore, the total amount due by XX/XX/XXXX, is {$1500.00}. A copy of that letter is attached as Exhibit C 45. On or about XX/XX/XXXX, I viewed the online records provided by my bank ( XXXX XXXX ) to determine whether my loan payment checks were being forwarded to Navient as instructed, and learned that every one of my weekly loan payments was being returned to the bank by the Navient.

46. At no time during the months that I made my loan payments was I informed by Navient that my payments were objectionable in some manner, nor did they explain the reason for the return of the checks.

47. OnXX/XX/XXXX, I wrote another letter to Navient inquiring why my loan payment checks were being denied, and explaining the financial burden those returns placed on me. A copy of that letter is attached as Exhibit D 48. Based on Navients purposeful refusal to honor any of my loan payments, my student loan account has been defaulted.

49. One of Navients primary responsibilities as a student loan servicer is to process payments made on my student loan account.

50. Navient did not have adequate processes and procedures in place to sufficiently address the errors it made in the processing of payments I made, even after I explained the problem and requested help.

51. I did not submit payments through Navients online portal, but instead submitted my payments by mailing a check or through an external bill payment system operated by my bank ( XXXX XXXX   ) where I had a checking account.

52. The payment of the overdue balance at this time would impose a double payment penalty on the me because of Navients actions in purposely refusing to accept my loan payments caused to unwittingly spend funds each week that I believed were in my account to be spent..

53. Because Navient did not make its payment allocation methodologies clear I had no way of knowing in advance how Navient might reject my payments, or know I would end up in default even if I made regular payments.

54. Navients refusal to accept my payments from my bank has resulted in me incurring improper late fees, increased interest charges, the furnishing of inaccurate negative information to consumer reporting agencies, and the loss of certain benefits.

55. As shown by the evidence attached to this complaint and nearly five ( 5 ) years of being ignored, it is clear that the payment processing errors is not an isolated event, but rather that the same payment processing error occurred time and again, even after I contacted Navient to correct the errors.

INTEREST STACKING THRU FORBEARANCE : 56. At the outset of selecting Navient Loan Servicing as my loan service provider, the defendants had a duty to fairly render their service.

57. Instead of doing so, Navients engaged in a structured act of encouraging me to postpone making payments in lieu of coercing me into Forbearance, and failing to provide information concerning other available options.

58. Navient failed to inform me of repayment plan assignment or selection at any time, when I was experiencing financial hardship or distress.

59. Navient has routinely disregarded its own policies and both Federal and Pennsylvania law and instead coerced me into forbearance by submitting cookie-cutter emails which made the option of forbearance a mechanized option, without adequately exploring income-driven repayment plans with me, without even mentioning income-driven repayment plans at all.

60. I was repeatedly sent emails encouraging me to use my mouse and ready-click a few buttons, and enter in deferment on my loans.

61. Navient discussed my loans on several occasions and only discussed forbearance during those phone and calls and from my recollection did not discuss any other payment option besides forbearance.

62. Every instance that I was entered in forbearance was completed over the phone by Navient agents who stressed how quick and easy the process was compared to other options.

63. On a number of occasions, a Navient representative, when informed of my inability to make a payment, directed me into a voluntary forbearance without advice about available income-driven repayment plans. In no instance was I informed that I may have qualified instead for a {$0.00} payment in an income-driven repayment plan at that time.

64. Indeed, only after research forced by Navients refusal to accept my loan payments, did I realize that I may have met the eligibility criteria for income-driven repayment plans, and qualified for a $ 0 monthly payment.

65. My loan balance was also subject to the negative consequences of forbearance, including the addition of interest to the principal balance of the loan, which raised my total loan balance from ( {$43000.00} to {$59000.00} = {$16000.00} [ additional principal ] ), which I could have avoided had I been enrolled in the income-driven repayment plan from the start. A copy of the Loan Documents are attached as Exhibit E 66. Navient also enrolled me in multiple consecutive forbearances, even though I had demonstrated a long-term inability to repay my loans during two periods of unemployment and specifically requested information and assistance.

67. I was enrolled in two or more consecutive forbearances totaling twelve months or longer, and on every occasion it was done via emails or over the phone in minutes.

68. Enrollment in multiple consecutive forbearances imposed a staggering financial cost on me by adding over {$16000.00} dollars of unpaid interest to the principal balance of my loans. If I would have been enrolled in an income-driven repayment plan, I would have avoided these additional charges because the government would have paid the unpaid interest on my subsidized loans in full during the first three years of my consecutive enrollments.

69. If I would have realized that every one of my many loans would take a principle increase when I entered into forbearance, I would have simply paid the loan balance on that particular loan, which could have managed. Below is a copy of the letter sent by Navient after they rejected a number of my payments : Dear XXXX  : This is a very important matter regarding your federal student loan account with the U.S. Department of Education.

You're eligible to resolve your past due payments through forbearance and you may qualify for a new repayment plan.

Income Driven Repayment ( IDR ) plans may reduce your monthly payment and give you more time to pay. Over 50 % of approved IDR plans result in a {$0.00} monthly payment.

Forbearance is a short term solution that will allow you to avoid default and resolve your past due status without having to pay your past due balance immediately.

We have a few options for you to consider : Option 1 : For a long term solution, simply call us toll free at XXXX to discuss all available federal repayment options. You may be eligible for an IDR plan or another plan that may reduce your monthly payment.

Option 2 : Request a Forbearance to bring your account current and postpone your payments for two ( 2 ) months. There is no fee for this forbearance. Read the terms below and, if you want to accept this offer, simply reply " Yes '' to this message. This is a short term repayment solution.

Forbearance terms : By replying " yes '' to this email you agree to the following : You request forbearance because you're temporarily unable to make payments due to hardship.

The forbearance will bring your loan ( s ) current and cover your next two ( 2 ) monthly payments.

You promise to repay your loan ( s ) following forbearance according to the terms of your promissory note ( s ).

Unpaid interest will be added to the principal balance of your loan ( s ) at the end of the forbearance, which will increase your total loan cost.

This forbearance does not remove any information previously reported to the consumer reporting agencies.

If you have other federal loans serviced by Navient, forbearance will be applied to all eligible federal loans to bring them current and cover your next two monthly payments. You'll receive a separate notification of the forbearance for each eligible loan.

A notice will be sent to you to confirm your selection and provide you with more detailed information. You will also be sent information regarding additional options such as IDR that provide a long term solution.

70. A copy of this letter is attached as Exhibit F 71. I generally received no response from the letters seeking assistance and information during the course of my loan servicing with Navient.

72. Navients engaged in a structured act of encouraging me to postpone making payments in lieu of Forbearance, and failing to provide information concerning other available options.

73. Long-term enrollment in forbearance dramatically increased the total amount due each month after the forbearance period ended over the repayment term for my federal loans.

74. On a number of occasions, I chose to simply reply Yes to this message., because without information or instruction, I used the most readily suggested ; time-efficient ; and financially feasible method presented.

75. The bank documents from my XXXX XXXX   account show that I submitted the payments and that Navient rejected them because the account was closed or the number was invalid ; however, my account number with Navient is the same as it has been.

76. Moreover, all of the account numbers listed on my payments to Navient correspond with my Navient account number, and therefore there was no basis for them to reject the payments and cause me to spend those funds unknowingly. A copy of the XXXX XXXX payment to Navient is attached as Exhibit G 77. Even after I discovered the matter and asked for help with the matter, Navient rejected several payments and sent emails suggesting that I consider forbearance as an option instead of suggesting some form of assistance with the problem they created.