Negotiated Rulemaking – 2/22/24

1

 DEPARTMENT OF EDUCATION

OFFICE OF POSTSECONDARY EDUCATION

NEGOTIATED RULEMAKING 

STUDENT DEBT RELIEF COMMITTEE

SESSION 4, DAY 1, AFTERNOON

FEBRUARY 22, 2024

On the 22nd day of February, 2024, the

following meeting was held virtually, from 1:00 p.m.to

4:00 p.m.
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P R O C E E D I N G S

MR. FRANCZAK: Welcome back, 

everyone. I'm Mike Franczak, FMCS facilitator for this 

afternoon's session. So, in terms of picking back up 

where we left off from this morning's discussion on the 

financial hardship waiver language, I wondered if there 

are any additional comments regarding paragraph C before 

we would switch to presentation and discussion of 

paragraph D? Alright. We okay then to move to paragraph 

D then? Tamy, are you good to go? Can you hear me?

MR. ROBERTS: I think you're muted, 

Tamy. 

MS. ABERNATHY: Yes. My screen went 

black, and I couldn't find the unmute button. So, you 

know, we live in a technological world of fun, don't we? 

I'm ready. If everyone else is, we can go ahead and get 

started with paragraph D. I believe the screen is being 

shared. In paragraph D, the Department would describe 

the factors that could be used to establish a separate 

and additional pathway for relief through an application 

by the borrower or otherwise where the Department has 

some of this information on hand. As we've explained, 

the text would provide for a process by which the 

Secretary may provide automatic or application-based 

relief to borrowers experiencing hardship. We have 
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discussed automatic relief for borrowers who we believe 

are likely to be in default in the next two years, as 

described in paragraph C. Paragraph D provides that for 

automatic or application-based relief, the Secretary may 

use data in the Department's possession as described 

under paragraph B, how a borrower is a Pell Grant 

recipient or the age of the borrower's loans. The 

Secretary may also use an application to acquire 

information for the factors described in paragraph B to 

supplement data that may already be in the Department's 

possession, such as high-cost burdens for essential 

expenses. For an application-based approach developed 

under these regulations, the Department's priority would 

be minimizing the burden on borrowers. We seek your 

feedback on such approaches, as well as through the 

public comment process later today and through the public 

comment process in rulemaking. We'll now turn it over to 

FMCS for discussion and questions on paragraph D. 

MR. FRANCZAK: Thank you, Tamy. 

Discussion and questions on paragraph D? Please raise 

your hand. We'll begin with John Whitelaw. 

MR. WHITELAW: I like the general 

approach here. I'm a little disappointed that the word 

automation isn’t nowhere here to be found. I'm also a 

little disappointed that there's no mention of data 
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sharing, and I just think this is not robust enough and 

does not show enough umph with respect to the 

Department's willingness to think creatively about how to 

automate decision-making. And I'm not I don't mean in 

the context of placing like significant actual 

requirements on the Department to do a particular type of 

data gathering or data sharing, but to reflect what we've 

talked about in many of these sessions before, which is 

why it is so incredibly important to get away from an 

application process where we can. I totally understand 

that you want to have an application process for people 

for whom the Department doesn't have or cannot readily 

get, which I think is something that's missing in this 

section D, information that shows they would be eligible 

for forgiveness based upon meeting the criteria that we 

discussed this morning. We know what happens when there 

are eligible people who have to apply, and the answer is 

they don't apply. And we know we have seen this in lots 

of different contexts. We have specifically seen it with 

TPD in the past, and I commend the Department in the past

for to remind folks what happened there. This was before 

the TPD regs were changed. Step one the Department sent 

a bunch of letters out to thousands, if not tens of 

thousands of people, telling them you're eligible to get 

TPD, you just need to apply for it. John and 50,000 
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other people who were eligible did not apply. So, what 

did the Department do? The Department then switched the 

default to the same people, so the Department knew they 

were eligible, but instead of making them apply, they 

switched the default. What is currently happening in TPD 

in part, is people are getting letters that say, Dear 

John, we know you're eligible unless you tell us you 

don't want to have your loan discharged, it will be. And 

I think I would like to have some language that I'll try 

and drop in a little bit later that would show a more 

robust moral commitment, for a better word, towards 

automation, towards thinking about what data sharing 

agreements you can get with various, especially Federal 

agencies, so that you can gather information that will 

allow you to assess if someone has a hardship without 

making them apply. And again, this is not about the 

substance of who's eligible. It's about how the 

Department goes about finding those people without making 

them apply. And still having at the end of the day, a 

mechanism for people to apply themselves. And so that's 

sort of really what I wanted to say about this. And I'm 

going to break it down to three words: automation, 

automation, automation. I want the Department to make a 

real commitment to be doing that. This language just 

doesn't get me excited about that. 
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MR. FRANCZAK: Thank you, John. 

Jordan Nellums. 

MR. NELLUMS: Yes. Thank you. And I 

just wanted to agree with my colleague John. As a 

current student and representing currently enrolled 

students, I think a lot of the proposals that the 

Department has presented are beneficial for borrowers 

after they leave school. But right now, there's not any 

type of text that really supports currently enrolled 

students. And so, I think automation would allow 

currently enrolled students.

MR. FRANCZAK: Can folks please mute 

their audio if they're not speaking? Thank you. Go 

ahead, Jordan. 

MR. NELLUMS: Yes. So, I just think 

automation would allow currently enrolled students to be 

able to partake in some of the benefits of the text that 

the Department has released, especially if the Department 

knows that there are certain metrics under which a 

borrower is likely to default. I think there are ways 

that the Department can realize whether or not a 

currently enrolled student is likely to default and just 

automatically apply some of the solutions that have been 

identified in the text, so thank you. 

MR. FRANCZAK: Alright. Thank you, 
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Jordan. John, you still have your hand raised. Is that 

from the prior or are you no longer wishing to speak 

again? Okay. Thank you. We have Ashley Pizzuti next. 

MS. PIZZUTI: Hi. I just want to 

bring up the fact that just from past programs where an 

application was required, such as Public Service Loan 

Forgiveness and Borrower Defense, there are so many 

people filling it out, the website tends to go down and 

making it unavailable. There's also a backlog of 

applications. And so, I'm wondering how the Department 

is going to be determining going through these 

applications, do they have the manpower behind them to 

sort of go through these individual applications? So,

I'm just a little concerned with having folks find the 

form, fill out the form when they go to the website, the 

form is actually available and works. You know, there's 

a huge problem in Borrower Defense where people spend 

three hours filling out this form and not saying that 

this form is going to be as robust as Borrower Defense, 

and then they get to the end, and they submit it and they 

can't submit it. The website has timed out and they have 

to start all over again. So, they abandon the form and 

they never get it filled out. So, I feel like there 

might be a lot of hiccups in that area of forcing people 

to file a form and then also making sure that that form 
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is getting into the hands of everybody that's eligible. 

Because I know that I still have people coming to me 

every day who've never even heard of Borrower Defense. 

And asking what it's about and how to file the form and 

yeah, so I just see it as a huge roadblock. 

MR. FRANCZAK: Thank you. Appreciate 

that, Ashley. Alright. I believe Jalil was next. 

DR. BISHOP: Thank you. So, I think 

when we're thinking about the points of my other 

colleagues have made about being kind of the gold 

standard to make sure we get relief to borrowers at a 

broad level, but also a quick and effective level. I 

think we have to also take a step back and maybe reframe 

some of the policies that are often put forth, both in 

this rulemaking but also just in the general discussion 

around student loans. So, for example, the White House 

put out a fact sheet yesterday saying that 4.3 million 

borrowers are unsafe, are at $0 payments per month. I 

think that's an indication of hardship. I think that 

many of those borrowers have probably been at $0 for 

years potentially under other repayment plans. And I 

would encourage the Department to look at that data point 

that they already have to be just one example of how they 

could do automatic relief. I would hate to see a 

situation where a plan like SAVE, which really shouldn't 
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be seen as the gold standard of solutions, but should be 

seen more as a stopgap while we're trying to come up with 

better solutions, I would hate to see the Department make 

a choice where we say, well, someone is under SAVE with a 

$0 payment so they don't need the automatic relief, or 

they don't need to be identified as having hardship. 

When, I think, even if you're under SAVE, even if your 

payment is $0 or $50 or at such a low level that it's not 

tackling that overall principle, that we should look at 

all those indicators as factors of hardship and as ways 

to do automatic relief. So, I just hope that we're going 

to look back at plans like SAVE and other policies that 

have come down so far and don't make the mistake of 

saying, well, because we have SAVE or because we did IDR 

adjustment, we don't need to do something automatically 

here. I think at best we can have kind of multiple ways 

to catch people and doing automatic relief based on those 

programs and the data we have from those programs that to 

me would be the gold standard of how we should approach 

this. Not saying if someone is covered by SAVE, they 

don't need to be covered by this automatic relief or some 

of the harsher factors under section B. 

MR. FRANCZAK: Thank you, Jalil. 

What if we go to Tamy in terms of a response and then 

we'll go to Lane thereafter. Tamy?
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MS. ABERNATHY: Thank you, Mike. So,

I really want to reiterate that paragraph C is about 

automation. The entire paragraph is about automating the 

process to provide relief for borrowers who are 

experiencing hardship. As we mentioned earlier, we 

wanted to have multiple pathways for borrowers to seek 

relief. So, in instances where we do not have data, we 

need to get that information from the borrower. So we 

agree with everything that you're saying, and we are 

committed to automate where and how we can, but we may 

still have to have an application process at this point 

to make sure that we're capturing those borrowers, that 

we simply do not have the information to be able to 

provide this relief for hardship. 

MR. FRANCZAK: Alright. Thank you, 

Tamy. Next, Lane. 

MS. THOMPSON: Yeah. It's funny that 

I was going to commend the Department for including both 

automation and application options. I think it is really 

important to have both of those available. As you 

mentioned, there's some data that's not available to the 

Department. I do also want to kind of reiterate the 

value of data sharing agreements with other Federal 

agencies. I think that's a really big one. Not sure if 

that needs to be included explicitly, but I do want to 
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really stress the value of that. And then the other 

thing I just kind of wanted to include in here is any 

place that the Department is able to include qualitative 

analyses and not just quantitative would be really 

excellent. I mean somebody who is experiencing several 

different types of hardship simultaneously, that maybe 

there's some accounting for that rather than just meeting 

very specific metrics. So, yeah. Thank you. 

MR. FRANCZAK: Thank you, Lane. 

Next, we have Melissa. 

MS. KUNES: Thank you. And I do want 

to agree with the Department's determination that this 

section does attend to both an automated process as well 

as an application process, because we know as much as 

automation, we want to get at the borrowers who need this 

relief. Ultimately, we are going to have those one-offs 

where only an application can get to the root of the 

issue and to help that borrower with some relief. But I 

would state that as the provision is currently stated, I 

don't think we want to be as limiting, even though I am 

very supportive of having open-ended authority here. I 

think we should state that the Secretary may, but will 

rely on data in the Secretary's possession, but also 

expand that thought to say, the Secretary can or will 

obtain. Now, I know that John had put some language 
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recently in the chat that talked about data sharing 

agreements, and perhaps that is to the level of 

specificity that we need to determine here. But I just 

think we need to broaden up that section to say not just 

what's in the Secretary's possession, but which they can 

obtain. And I will put language of that nature in the 

chat. Thank you. 

MR. FRANCZAK: Thank you, Melissa. 

Alright, we'll go next to - I thought Jaleel's hand was 

before Jessica. No, the other way around? Okay. Very 

good. Alright, Jessica then Jalil. 

MS. RANUCCI: Doesn't matter. I'll 

be quick. I agree with everything that everyone had 

said. I would just say I think some of us want to play 

around with this language a little bit. And as we do, it 

makes me a little nervous that this section is intended 

to include both application-based and non-applicationbased waivers, but it only says the word application. It 

doesn't say without an application. So, I think as we're 

thinking about the language I wish that it could be a 

little more explicit. I think that's in some of the 

other Department regulations, like the Department will 

consider without an application from an individual 

borrower, something that just spells that out a little 

more, because I know what you mean. But I think I just 
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want to be a little cautious. 

MR. FRANCZAK: Thank you, Jessica. I 

imagine the Department would welcome your suggested 

language in the chat, so when you're able to do so, that 

would be helpful. Thank you. Jalil. 

DR. BISHOP: Thank you. So, Tamy, 

thank you for the clarification around the Department's 

intention to have multiple pathways to try to automate as 

much as possible. But I think in your opening 

statements, the Department is indicating that one of the 

areas where it will do automatic cancellation is based on 

Pell Grant data. I've already provided regulatory text 

revisions in the chat, but I want to uplift again that if 

we're going to cancel automatically through Pell, that we

should also include Parent PLUS borrowers whose dependent 

receives a Pell Grant. And so I think that's an example 

of why it's not only about what we're going to do 

automatically, but it's also about the technicalities of 

who's included in those categories of hardship. So 

again, implore the Department to really think about how 

to expand these different categories and if default, for 

example, is meant to be done automatically and through 

immediate relief, then it's important for the Department 

to also understand that the likelihood of default is that 

borrower who's been sitting at $0 payments for years.
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And this is particularly important for borrowers of 

color, Black borrowers who disproportionately do not have 

the financial means to afford their student loan 

payments. So, they're often sitting in lifetime debt 

sentences where their payments are $0 or less than enough 

to pay off their student loans. And they're sending 

these student loan repayment plans for what feels like a 

lifetime. So again, this seems like a great framework, 

but the technicality of how these things are going to be 

defined are really going to determine whether or not they 

give the justice that borrowers deserve. So, I just want 

to uplift that point again, that automatic multiple 

pathways is great, but we also have to make sure we're 

defining them to include the borrowers who need relief. 

MR. FRANCZAK: Thank you, Jalil. 

John. 

MR. WHITELAW: If I can take myself 

off mute. I put some language up there. I'm certainly 

not wedded to that language. I'm happy to have other 

people play with it or have the Department do something 

with it. I don't disagree at all with what Melissa said. 

I mean, the further we can push the Department to 

committing to do this, the better. And I agree it would 

be data sharing or other mechanisms of getting it. I do 

think the point she made that I did not make as 
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articulately is it's not just information that the 

Department has, but it's information it can get. And 

again, the example that we have of the big examples is 

TPD is largely being done these days with data sharing 

through Social Security. So, there are definitely ways 

in which data sharing can be accomplished. Thank you. 

MR. FRANCZAK: Thank you, John. Any 

other discussion or questions regarding paragraph D? Oh, 

Lane. Yes. 

MS. THOMPSON: Just real quick with 

this discussion of data sharing is I wanted to throw in 

that maybe including governments other than Federal as 

well. I know the Department is already working with some 

state governments on some data matching. So, if we're 

going to reference data matching, maybe keep it broad as 

much as possible. I think there's maybe tribal 

government information, anything like that that could 

potentially be shared and be really useful in this way. 

MR. FRANCZAK: Thank you, Lane. 

Looks like John found that acceptable as well. Any other 

comments or questions regarding paragraph D? Alright. 

If not, do we need to circle back to any of the previous 

paragraph discussion for purposes of clarification or new 

ideas? I can begin first with paragraph A. Is there 

anything to still clarify or ask questions around 
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paragraph A from this morning? Looks like Jessica has 

her hand raised. Feel free, Jessica. 

MS. RANUCCI: Yeah, Tamy, you said at 

the beginning that this would not include HEAL borrowers 

and repayment. Is that just because those are 

commercially held HEAL loans? Is that what you meant?

MS. ABERNATHY: Yes, ma'am. 

MS. RANUCCI: Thanks. 

MR. FRANCZAK: Thank you, Jessica. 

Any other questions or comments for paragraph A? 

Alright, let's go- oh, there's a hand. Jalil, go ahead. 

DR. BISHOP: This is kind of 

connecting back to this question of borrower's ability to 

fully repay or the cost of enforcing. I'm just wondering 

if the Department can speak or explain how they're seeing 

this hardship regulatory text interacting with some of 

the prior discussions, which I believe are often framed 

as we're not touching these areas because we have SAVE or 

we have IDR adjustment, or we already have tackled Public 

Service Loan Forgiveness. I'm just trying to understand 

how SAVE and this regulatory text are kind of going to be 

in conversation with each other, if the Department can 

voice that over because in some earlier conversations, it 

was framed as, you know, we have already addressed this

in SAVE or we have already provided this type of relief 
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in SAVE. And I think some things here may be providing 

another pathway to relief, but I'm just trying to 

understand how those two things will be in conversation 

with each other. 

MR. FRANCZAK: Jalil, could you 

repeat your question, so it's fully digested?

DR. BISHOP: Yeah. So how will the 

borrower's ability to repay or the cost of enforcing andwhen the Department is trying to determine those factors, 

how will that be in conversation with SAVE? Or 

potentially maybe even some tensions or possibilities 

with SAVE. 

MS. ABERNATHY: So right now, in the 

context of costs and benefits of collection, the 

Secretary might determine that a borrower has or 

experiencing hardship, and that the cost of enforcing the 

full amount of debt is not justified by the expected 

benefits of continued collection, which is what you just 

said Jalil. In the regulatory text, we don't prescribe 

costs. We broadly include a number of ways to think 

about cost, and we could consider costs beyond costs to 

the government. Okay? We're not amending any of the 

provisions for PSLF or IDR, and that's still the case. 

This is a new proposed regulatory text that focuses 

completely on borrowers experiencing hardship and the 
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hardship factors that are in paragraph B and other 

information available to the Secretary and looking at 

these borrowers under that lens. And that's the focus of 

hardship for them. Now, that's not to say that a 

borrower under the SAVE plan with a $0 payment might not 

be exhibiting hardship. So, there might be information 

that the Secretary is using information that they have 

available to use for each of these cases of hardship. 

So, the lines could be closely connected. But this is a 

separate provision that the Secretary is choosing to 

exercise the authority to waive debt for borrowers that 

are likely to default within two years for borrowers that 

are experiencing these hardship factors. So, I just want 

to point out that it's kind of separate and apart, even 

though we may glean information from the borrowers and 

from the information that's on our system for these 

respective borrowers. 

DR. BISHOP: Thank you. That 

clarifies. And I think for me, if I'm understanding 

correctly, you will use information from SAVE to better 

provide relief to borrowers. But in assessing if a 

borrower has hardship, you will look at this. You will 

look at a borrower’s situation outside ofMS. ABERNATHY: Yes. 

DR. BISHOP: So that's important in 
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communicating to borrowers and making sure that they're 

not somehow experiencing missed relief because they 

decided to get on to SAVE. 

MS. ABERNATHY: Absolutely. That is 

not our intent at all. We are taking a holistic approach 

where we can and using everything that we can within our 

abilities to look at borrowers for where they are and 

what we can do to help them. And we want to help as many 

borrowers as possible as quickly as we can. And so,

while we talked about the application process and things 

of that nature, our goal here is to really look at our 

borrowers. We've heard you guys, you have given us great 

information. You have provided us with research. We've 

had other Department officials that have done the 

research on this. We understand that this is a very 

passionate topic for this committee, and we are hopeful 

that you can see that our best effort has been put forth 

with the proposed regulatory text. And these discussions 

are super helpful. And we will go back, and we will look 

at some of the suggestions. Again, like I said, we can't 

guarantee that we're going to take everything, but we are 

going to look at everything and we'll circle back to you 

on those. So, thank you for your comments. We really do 

appreciate them. 

MR. FRANCZAK: Alright. Thank you 
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for your clarification and understanding. So, next we 

have Lane. 

MS. THOMPSON: Yeah. After I raised 

my hand, I realized this might fit more nicely under B 

than A, but I'm just going to go ahead and say it anyway. 

MR. FRANCZAK: Okay. 

MS. THOMPSON: This is a little bit 

in the weeds, but as of today, borrowers who have 

balances, original balances that they took out between 

$12,000 and $22,000 and are on the SAVE plan are starting 

to see balances canceled after ten years. The reason I'm 

bringing this up is that there are borrowers who 

originally borrowed between $12,000 and $22,000, who are 

currently not on SAVE, who are not having their balances 

canceled. The reason I wanted to bring this up is that I 

think when we talk about things like the cost of 

collecting on a loan or ability to repay a loan in full, 

we really need to be looking at the time-period in which 

somebody repays that loan as well. You know, the fact 

that some folks will have their balances canceled after 

ten years under SAVE, while others who had the same 

borrowing history, similar repayment histories will not, 

is something that I am concerned about and that I think 

could be covered in cancellation here. 

MS. ABERNATHY: Thank you, Lane. One 
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of the things that I want to mention is in addition to 

what we discussed and what we've proposed in 30. 80 

through 30. 90. So this particular hardship proposed 

regulatory text is in addition to all of what we've 

discussed already, which we're not opening up for 

discussion. But I say that to remind everybody that this 

is in addition to that, and some of what you're saying, 

Lane, with the extensive length of time and repayment, 

some of those things were addressed with our proposed 

final rule related to our last three sessions for student 

debt relief. 

MS. THOMPSON: Yeah, and I understand 

that. The reason I said it's a little in the weeds is 

that I'm specifically talking about borrowers with a

certain amount of debt whose repayment period could be 

shorter than 20 years, but isn't. So, it's really a 

group that is kind of being missed in those previous 

regulations, kind of being missed under the account 

adjustment. So that's why I really just wanted to bring 

attention to this one group. You know, they tend to be 

folks who don't have college degrees, tend to be folks 

who borrowed less to begin with. So just a good group to 

try to hit when automatic inflation goes through. 

MR. FRANCZAK: Alright. Thank you, 

Lane and Tamy, for that exchange. Alright. Anything 
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else on A before we would formally transition to 

paragraph B again? Alright, seeing none. Moving now to 

paragraph B, the categories. Is there any further 

clarification, comments or questions relative to 

paragraph B? And it is my understanding Richard Haase is 

becoming primary in substitution for Jalil. Richard?

MR. HAASE: Hi Mike, thank you. 

Yeah, I just wanted to revisit something that we 

discussed when we were talking about B earlier today. 

There were a number of comments made. We reiterated our 

concern around hardship that's attributable to servicer 

error. And I think in the course of having those 

conversations, we often think of the personal individual 

stories that are contact's experience or that we've 

experienced personally. But I do think it's important 

for the Department to consider cases where we already 

have documented and systemic servicer errors, like in the 

broader scale, transferring of loans from one servicer to 

another, where I think it's already been recognized that, 

you know, there are multiple overlapping issues that 

impacted borrowers. So, I just wanted to add that to the 

record here to make sure that when we discuss hardships 

that are attributable to servicer errors, that we're not 

just looking at these isolated one-off cases that can be 

hard to quantify. But some of the broader ones that I 
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think are already fairly well documented. Thank you. 

MR. FRANCZAK: Thank you, Richard. 

So, I'm not sure who came in first between Wisdom and 

Scott. What if we go with Wisdom, then Scott? So, 

Wisdom, go ahead. 

MR. COLE: Thank you, Michael. Just 

highlighting some amendments that I had shared. I 

believe everyone received an email, but I also put it in 

the chat. In addition to some of the factors that I 

talked about earlier, I want to highlight the educational 

outcomes, disparities and really making sure in this 

sector and level of the institutions attended, along with 

typical student outcomes, the Department should analyze 

how these factors intersect with race and economic 

status, recognizing that disparities in educational 

opportunities contribute to unequal outcomes. We've 

talked about disabilities, but what folks have said there 

as well. I submitted this proposal during the last 

session particularly around the legal system impacts.

But I think in consideration there, we shed the impact of 

legal system and incarceration of borrowers, financial 

circumstances, and the ability to repay the loan with 

particular attention to disproportionate impacts on Black 

and underserved communities. I want to also highlight 

the age and life cycle changes. The Department should 
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also adjust the consideration on age and account for life 

cycle changes that may affect older borrowers differently 

such as retirement or transition to fixed income, 

especially in the light of racial income disparities.

And last but not least, public benefit eligibility. 

Eligibility means testing public benefits will be 

clarified and expanded within the criteria to capture a 

broader range of support programs, ensuring it reflects 

financial hardship and includes programs 

disproportionately serving Black and underserved 

communities. 

MR. FRANCZAK: Wisdom, that's 

captured in the amendment that you posted in the chat?

MR. COLE: Yes, sir. 

MR. FRANCZAK: Okay. Thank you, 

Wisdom. Alright. I believe Jalil is back in for Richard 

as primary. I'll go to Scott next. 

MR. BUCHANAN: Sure. And I just want 

to re-ask the question I think I posed before the 

Department answered, but I'm interested in, you know, all 

of us have to interact with borrowers and explain to them 

who might be eligible for forgiveness and who's not. 

They are going to be a lot of questions about this if the 

Department proceeds with the regulation here. Can the 

Department provide some examples in real-world about how 
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you would interpret this? Because the language would

give the Department the ability to do something, nothing, 

or everything. Some specific examples of what borrowers 

would envision, you know, their characteristics, whether 

it's age, debt balance, things like that, what threshold 

would be for people to be able to get forgiveness under 

the Secretary's asserted authority and then examples of 

people who would not be eligible for forgiveness that are 

below those thresholds, whatever they might be. I think 

that would be very helpful illuminating the conversation 

of who actually is in scope here and who is not rather 

than sort of the language right now, which is vague about 

who may or may not be in. And again, it could be 

everybody, nobody, or somebody. So, I realize that may 

take the Department some time. And certainly, tomorrow 

would be fine for the answer, but I would appreciate 

that. I think it would be useful to the group. 

MR. FRANCZAK: Scott, to clarify, 

were you referencing the categories somehow in B, or was 

that pertaining to paragraph C?

MR. BUCHANAN: Both. It's applicable 

to both. 

MR. FRANCZAK: Alright. Thank you, 

Scott. Jessica is next. 

MS. RANUCCI: Thanks. I just wanted
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Negotiated Rulemaking – 2/22/24

to respond slightly to that on B. I strongly support the 

Department writing regulations that give future 

secretaries of education the discretion to waive some or 

all of student loan debts based on financial hardship and 

these factors. I don't know what the student loan system 

is going to look like in 2030 or 2035 or 2040. But I do 

think that future secretaries of education, having the 

ability to do what's in here is really important. And I 

don't think that the Department should or could really 

give a full answer to that as to section B right now, and 

I don't think that that's a negative. I think that it's 

a positive. I think that we need to build regulations 

that will work across administrations, across points in 

time, and I appreciate the framework the Department has 

put up that will be lasting into the future. 

MR. FRANCZAK: Thank you. Yael. 

MS. SHAVIT: Add a little emphasis to 

that. You know, this particular part of the regulatory 

endeavor that the Department is taking on now is one that 

has been called on for a long time as necessary to ensure 

that regardless of the particular circumstances and 

programs applicable in the student loan system at any 

given moment in time, there is always a process by which 

people who are facing hardship are able to get relief 

that they need, and that taxpayers are spared the burden 
27

Negotiated Rulemaking – 2/22/24

of the expenses that go out to collect the debts that 

shouldn't be collected. So, it's incredibly important 

for these regs to be drafted in a way that will serve 

that purpose, which is the most important purpose that 

these provisions can serve. And it would be a mistake to 

draft them so narrowly that they are only applicable at 

one given moment in time and would necessitate the 

expense of additional regulatory processes like these in 

the future, when there are new programs or changes to the 

student loan system that make a very, very detailed or 

not detailed, but a very, very narrow drafting of them 

inapplicable. That's not the task at issue here. That's 

not the purpose that these are serving. And so, I do 

want to commend the Department for the effort that it's 

put into these and make sure that we are thinking about 

it through the appropriate lens. This is the part of 

this regulatory process that needs to be applicable in 

the future consistently. 

MR. FRANCZAK: Thank you, Yael. Any 

other comments or questions on paragraph B? Alright. If 

not, we can transition to paragraph C and ask if there 

are any comments or questions for paragraph C. Alright 

then, we'll do one last circle back. If there isn't 

anything further on C, we'll do one last circle back on 

B, and then I might make an announcement about the public 
28

Negotiated Rulemaking – 2/22/24

comment in terms of the afternoon. Alright, yes, Yael. 

MS. SHAVIT: I was hoping before we 

move into public comment, this is not intended to stop 

conversation about D, but I didn't want to lose this 

moment. If we could have a very short conference or 

caucus with the Department and with the primary for 

consumer advocates, Jessica. 

MR. FRANCZAK: Okay. So, the request 

is for Yael, Jessica, and who from the Department are you 

requesting?

MS. SHAVIT: It would be great 

MS. ABERNATHY: I can answer that, 

yeah. 

MS. SHAVIT: Thanks. 

MS. ABERNATHY: Me, Soren, Ben, 

Genevieve Torres, Toby Merrill. 

MR. FRANCZAK: Yeah. I just want to 

make sure we have everyone in terms of creating that 

caucus. Thank you, Tamy. Looks like before we do that, 

there is a hand raised. So, what if we take the hand 

raised by Jalil, and then we'll go from there. Sound 

okay? Okay. Jalil?

DR. BISHOP: Thank you. And sorry if 

I sound, I’m repeating myself, but really trying to get 

clarification on this so we can make sure that we're 
29

Negotiated Rulemaking – 2/22/24

doing what's best for borrowers. So I'm really thinking 

about the hardship factor. So, I'm kind of going back to 

B a little bit here. But I'm thinking about the hardship 

factor of age of loans. And I think Lane touched on this 

a little bit. But we have previous regulation that is 

really looking at 25-year periods before relief is being 

provided. And I'm trying to understand how the 

Department is going to factor in the age of the loan 

under this new proposed hardship proposal. Is it the 25-

year period or is that something you going to look at the 

age of loan as it intersects with other hardship factors? 

But just trying to understand, are we still looking at 

this 25-year period or is the age of the loan? Does that 

open up some other timeframe for [inaudible]?

MS. ABERNATHY: I think what we are 

looking at is more of a combined approach, like you're 

going to have factors that have put this borrower in 

hardship, and one of those factors may be the length of 

their loan may be five years, maybe 10 years. That, 

combined with other additional factors and other 

information that the borrower provides to us, that may, 

as we, you know, continue to develop our model, it goes 

into that predictive model and it's going to be able to 

show us certain things about those borrowers. So, for us 

to sit here and say that we know it's going to be X 
30

Negotiated Rulemaking – 2/22/24

number, we can't pinpoint those that length of time. We 

have not written into our regulations if it's X number of 

years in repayment. We're not going to do that because 

we need to look at these borrowers on an individual basis 

with all of the factors that they are experiencing that 

lead them to this hardship in the first place of not 

being able to pay their loans or putting them in an undue 

burden if they pay their loans. And I think we want to 

look at it more holistically. So, we do appreciate your 

question. And please continue to hit us with things so 

that we can think this through thoroughly with you guys. 

That's the whole purpose of our conversation. But we 

know what we're doing for the 20 and 25. We've got that 

settled already, right? That is a different paragraph in 

the rules that we did previously. So right now, what I 

think we were going to be doing is looking at this as a 

holistic, all of the factors. There are 17 factors right 

now and we already know that that's a non-inclusive list. 

So, I think it can be both and a combination of a lot of 

different things to look at a borrower's respective 

situation, to determine the kind of hardship this 

borrower is receiving. So, I hope that helps a little 

bit. 

DR. BISHOP: No, thank you. And just 

to clarify, the predictive model is going to be used both 
31

Negotiated Rulemaking – 2/22/24

for part B and for part C?

MS. ABERNATHY: Our intent is to 

provide the borrowers that are likely in default, the 

one-time relief. And then looking at our model to 

provide this as an ongoing effort. So, we're going to 

build that ongoing development of this model to look at 

the predictive factors that put borrowers in hardship 

holistically. 

DR. BISHOP: Thank you. 

MR. FRANCZAK: So, if we go next to 

the idea for the caucus, can I have perhaps estimated 

time from Yael for the need for the caucus? Like, how 

much estimated time should we allocate?

MS. SHAVIT: I think ten minutes is 

adequate. 

MR. FRANCZAK: Ten minutes? Okay. 

So, are we good to set up that caucus now? Alright. 

MS. ABERNATHY: We are Mike, thank 

you. 

MR. FRANCZAK: Okay, good. Alright, 

so what if we shoot for reconvening at 2 p.m. Eastern 

with the larger group, sound okay?

MS. ABERNATHY: That works. Thank 

you. 

MR. FRANCZAK: Alright. Beautiful. 
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Negotiated Rulemaking – 2/22/24

Alright, so let's end our public component here, and 

we'll take our break with the caucus. Brady, can you 

help set up the caucus? 

MR. ROBERTS: You should have just 

receivedMR. FRANCZAK: Welcome back, 

everyone. So before our break there was a caucus called 

and so my first question coming back is if there is any 

report out on the caucus itself. 

MS. SHAVIT: No. 

MR. FRANCZAK: Okay. Alright. So,

my understanding is we may not have as much discussion 

still this afternoon on the text. And if that is the 

case, we may be able to accommodate additional speakers 

who are on the wait list for the public comment section 

that was originally going to start at 3 p.m. Eastern. 

Sorry, Tamy. 

MS. ABERNATHY: Go ahead and finish 

and I'll jump in when you're finished. 

MR. FRANCZAK: Okay. So, what we 

were envisioning was we have a good number of folks that 

are on the waitlist. I believe there are up to 10 on the 

waitlist. So, one idea we could do is to start the 

public commentary at 2:30 p.m. Eastern, allow the folks 

that are on the waitlist to have up to three minutes each 
33

Negotiated Rulemaking – 2/22/24

between the 2:30 and 3:00 p.m. portion, to allow them to 

provide public commentary, and then begin the additional 

public commentary with the folks who are already slotted 

then from 3:00 to 4:00 p.m. Eastern. So that is an 

option and available. So, if there aren't any objections 

to that we could proceed with that format. I guess 

before we go any further on that, I'll go to Tamy if she 

has any comment or question at this time. You're muted, 

Tamy. 

MS. ABERNATHY: Helps if you check 

that little button, doesn't it? What I wanted to do was 

circle back and clarify something that Jalil had asked, 

and I'm not sure that I said it as clearly as I would 

like to say it now. We view the automatic relief tied to 

the likelihood of being in default as a one-time effort 

under paragraph C, the other relief contemplated under 

paragraph D may be ongoing. So, I just want to make sure 

that we clearly understand that C is a one-time and D is 

ongoing. 

MR. FRANCZAK: Alright. Thank you 

for that clarification, Tamy. Looks like there is a hand 

raised with Jalil. 

DR. BISHOP: Okay. Thank you, Tamy, 

for the clarification. So my understanding, if the 

immediate relief for borrowers likely to default is going 
34

Negotiated Rulemaking – 2/22/24

to be one time, I think that again, I would underscore 

the need to really define the likelihood of default based 

on the borrowers variables and based on the borrowers 

hardship, without considering existing relief policies 

will be an important way to approach that, because, 

again, the argument can be made that if a borrower is on 

a $0 repayment, that they may not need relief in that one 

time moment. But I think that what we know about 

hardship, what we know about likelihood to default, what 

we know about borrowers and loan servicing errors, I 

would just encourage the Department to consider the 

likelihood of default based solely on the borrowers 

financial and hardship variables without considering some 

of these other contingent or sometimes even theoretical 

forms, hypothetical forms of relief. So just based on 

default on the borrower for this one-time relief, I think 

would be closer to the gold standard of how to include as 

many distressed borrowers as possible. 

MR. FRANCZAK: Thank you, Jalil. Any 

additional questions or comments on paragraph C or D at 

this time? Yes. Jalil. 

DR. BISHOP: Sorry. I have a lot of 

thoughts today. 

MR. FRANCZAK: No worries. 

DR. BISHOP: So, I think that this is 
35

Negotiated Rulemaking – 2/22/24

not explicit in the regulatory text but I will say for 

the record, and I think it's important for the Department 

to consider how we're going to use predictive models. So 

predictive models are not neutral as I'm sure many 

researchers and data analysts at the Department will be 

able to attest to. So, I would just encourage the 

Department to think about and build out those models. Do 

you have the right equity experts, the right anti-racist 

experts to really unpack and navigate ways that machine 

learning, AI or large data sets can without intentional 

and proactive efforts can reflect racial, gender and 

other biases built into these systems. So just an 

encouragement to make sure that we have the right experts 

at the table and building out these models so that 

they're not reproducing other forms of bias 

discrimination or marginalization that borrowers have 

sometimes experienced in attempts to provide relief. So 

just having the right experts at the table, I think, will 

be key to make sure that model delivers relief in the

intended way. 

MR. FRANCZAK: Thank you, Jalil. 

Lane?

MS. THOMPSON: I just wanted to add 

on to what Jalil was saying to say that whatever the 

model ends up being, whoever it is that's actually 
36

Negotiated Rulemaking – 2/22/24

running it, as much transparency as possible for 

borrowers and for state officials would be really 

helpful. I'm not asking for that now. I know it's 

probably not all made up yet, but I just wanted to ask 

that when we have that tool available that it's clear 

whether a vendor is using it, whether the Department 

employees are using it. And that would just be helpful 

for us to know when we get there. 

MR. FRANCZAK: Thank you, Lane. 

Alright. Any final comments or questions before we sort 

of lay out timing and next steps for this afternoon? 

Alright. So, here's the thought, sort of building on the 

earlier public comment piece to allow folks who were on 

the wait list to have an opportunity to provide 

commentary for up to three minutes per person. What we 

would ask would be for those who were waitlisted, if you 

could begin and the larger group here will take a break. 

I'll ask us to reconvene at 2:25 p.m. Eastern. We'll ask 

folks that are waitlisted in terms of the public 

commentary, to begin to log on 10 minutes prior to 2:30. 

So if folks who were waitlisted, if they could begin to 

log in around 2:20 p.m. Eastern that would be helpful to 

sort of developing a batting order for when we would 

officially begin with the earlier public commentary 

around 2:30 p.m. Eastern. Does that sound like a plan? 
37

Negotiated Rulemaking – 2/22/24

Alright. So, we would take our break now, reconvene 

officially- or if you could get back here on screen by 

2:25, we'll kick back off at 2:30. If you are waitlisted 

and wanting to speak in that earlier section, please do 

so by 2:20 p.m. Eastern. And with that, unless there is 

anything else, we'll take our break and go off our live 

stream. Welcome back, everyone. So, we are going to 

start with the public commentary earlier. I would like 

to provide a couple reminders. If you are on the wait 

list and would like to speak as a part of the public 

commentary now between this 2:30 and 3:00 p.m. Eastern 

timeframe is when we can fit you in definitely, so if you 

please call in, we will work to get you in that way. We 

would ask those who were already slotted for public 

commentary to call in 15 minutes prior to your time slot. 

And then we will go in the order that we have in terms of 

the slotting order. So, we will start the public 

commentary momentarily. Please remember that you'll have 

up to three minutes to provide public commentary. So, 

Brady, I'll turn it over to you in terms of how you want 

to do the order and announcement of folks. 

MR. ROBERTS: Sounds good. Alright. 

I just admitted our first speaker, Dawn Arr, who's 

representing herself. Looks like she's in the meeting, 

but she hasn't turned on audio or video quite yet. 
38

Negotiated Rulemaking – 2/22/24

MR. FRANCZAK: So, Dawn, if you could 

turn your audio and video on, and then we could begin 

with you. 

MR. ROBERTS: Looks like she might 

still be working on it. Do you want me to admit the next 

speaker and I'll work with her? 

MR. FRANCZAK: Yeah, that's fine. 

MR. ROBERTS: Okay. I just admitted 

Sylvia Tapia who's representing herself. Looks like 

she's in the meeting with audio enabled. She's just on 

mute. 

MR. FRANCZAK: Okay. Sylvia, can you 

unmute yourself, please?

MS. TAPIA: Hi. 

MR. FRANCZAK: Hi. How are you?

MS. TAPIA: I'm good, thank you. 

MR. FRANCZAK: Good. If you'd like 

to turn your camera on, that's fine. If not, you know we 

can make do. Please feel free to provide public 

commentary up to three minutes. 

MS. TAPIA: Okay. 

MR. FRANCZAK: Starting now. 

MS. TAPIA: Okay. Hi. I am a 

student loan borrower. I just turned 62 last month and I 

have been making student loan payments for most of my 
39

Negotiated Rulemaking – 2/22/24

life. I have been employed by PSLF-eligible employer for 

almost 20 years. My current position does not require a 

degree. Sadly, my bachelor's degree has not paid off at 

all and, in fact, I am worse off financially than my 

parents who both had less than an elementary school 

education and yet they owned their own home. It was a 

never-ending fixer upper, but they owned their fixer 

upper. I live in a 375 square foot studio apartment that 

I rent for almost $1,700 per month, with rent increases 

every year without fail. Due to the crushing student 

loan debt, I have been unable to buy a home or save for 

retirement. I have no assets. All I have is debt. If 

the Supreme Court had helped loan borrowers with $20,000 

student loan cancellation, that would have been me 

because I received a Pell Grant. Instead, I am back in 

repayment for $220, 36 per month, but only $33. 65 goes 

to principal to pay off the loan, and $186. 71 goes to 

interest. I am here to ask this committee to also 

address this repayment calculation inequity, and how 

student loans are calculated when only a very small 

portion of the payment is applied to the principal, and 

how this has real life implications on many student loan 

borrowers, especially low-income students. I also ask 

the committee to address wage garnishment paid towards 

student loans. Wage garnishments were implemented 
40

Negotiated Rulemaking – 2/22/24

because student loan servicers refused to work out 

manageable student loan payments with borrowers. The 

garnished payments should also be counted as full 

payments at this point in time to ensure that the 

Department rights the wrongs that have been committed by 

unfair and predatory business practices by loan servicers 

contracted to collect on the student loans. I have 

experienced the wage garnishments. I ate white rice for 

weeks because they garnished all of my pay. The loan 

servicers were sharks and predators without an ounce of 

humanity and care for real people that were truly 

struggling to live. Several years ago, before I managed 

to overcome some of this, I became suicidal with a crush 

of the student loan debt and the unethical business 

practices of the predatory student loan servicers. I 

also request that you give employers incentives to help 

their employees pay down their student loan debt. Dear 

Committee, your work is very important, and I thank you 

all for coming together to work on this monumental task. 

Please do your very best to cancel student loans for as 

many student loan borrowers as you can, especially lowincome student loan borrowers who took on a debt for a 

university degree.

MR. WEATHERS: Sylvia, you have 30 

seconds left. 
41

Negotiated Rulemaking – 2/22/24

MS. TAPIA: I want to burn my 

diploma, and I am 62 and I have only a few years to 

retire and I do not want to retire with student loan debt 

fees. Thank you for your time. Have a good afternoon. 

MR. FRANCZAK: Thank you, Sylvia, for 

your public commentary. 

MS. TAPIA: You're welcome. Thank 

you for listening. 

MR. FRANCZAK: Brady, who do we have 

next?

MR. ROBERTS: I believe Dawn Arr is 

in the room and she's got her audio working now. 

MR. FRANCZAK: Hey, Dawn, can you 

hear us?

MS. ARR: Can you hear me?

MR. FRANCZAK: Yes. 

MS. ARR: Okay, great. Thank you 

very much for the opportunity to speak today. I greatly 

appreciate your time. I am 53 years old, and I attended 

a state university. I borrowed a total of $36,000 and 

have been in repayment since 1999. After over 24 years, 

my balance has only dropped to $31,000. That's only a 

$5,000 drop. I've had Pell grants, scholarships, college 

work study program, and I worked in a restaurant at 

night. Despite these efforts, I still needed student 
42

Negotiated Rulemaking – 2/22/24

loans. My loans have been serviced by many groups; Texas 

Guaranteed Student Loan Corporation, Nelnet, Sallie Mae, 

Navient, and now Aidvantage. My payment history is 

filled with errors and there have been no ways to correct 

it and no one to provide a straightforward answer for 

resolution. I was ill advised to immediately consolidate 

my loans in 1999. However, this only locked me into a 

high 7.625% interest rate. While many other borrowers 

were able to benefit from a 1% interest rate many years 

ago, my balance continued to grow because the rules 

stated that once you consolidated, you were locked into 

that higher rate forever. Sallie Mae never explained 

this or provided that information. I had a brief period 

of bankruptcy of 24 months after my husband died, but 

ultimately, I did find a way to pay my debts, so I left 

that program. I did make loan payments during this time 

because the loans were still required, but my file, 

thanks to Navient, shows a bankruptcy status and that 

servicer, Navient, is not available to fix it. This is 

only a long list of errors by Navient over the years. 

Because of these few examples that I've shared, and there 

are many others, I urge you to consider the following for 

hardship. Number one, Pell Grant recipients. Number 

two, bankruptcy status. The very definition of hardship, 

especially because those loans were required, and 
43

Negotiated Rulemaking – 2/22/24

payments being made. Number three, loans serviced by 

Sallie Mae and Navient. The list of mistakes and errors 

by those companies have been detrimental to so many 

people and have caused us to have increasing balances and 

incorrect reporting and payment history that continues to 

plague us to this day. Number four, those people locked 

into high rates because they were ill advised to 

consolidate. All this did was guarantee a never-ending

cycle of payments. 

MR. WEATHERS: Dawn, you have 30 

seconds left. 

MS. ARR: I do not own a house, a car 

or a business. I have been strangled by these loans 

since 1999. These payments mean I cannot afford medical 

care or retirement savings. I implore you to please 

consider hardship cases for loan forgiveness. Thank you 

for your consideration. 

MR. FRANCZAK: Thank you, Dawn. 

MS. ARR: Thank you. 

MR. FRANCZAK: Brady, who will you 

invite next for public commentary?

MR. ROBERTS: I just admitted Jarrod 

Wall, who is representing himself, and I believe he's on 

camera and has audio enabled. He's just muted right now. 

He's unmuted. 
44

Negotiated Rulemaking – 2/22/24

MR. FRANCZAK: Okay, Jarrod, welcome 

to the regulatory negotiations. You have up to three 

minutes for your public commentary. 

MR. WALL: Okay. Hi. I want to 

thank you, first of all, for having the opportunity to 

speak today. I want to kind of speak from a few 

different angles as a formerly incarcerated student debt 

holder. So, first of all, I served 26 years in the state 

of Indiana. And during that time, I ran or administrated 

an on-site college program for over 12 years. During 

this time, I saw many men disqualified from receiving 

Pell and state grants due to defaulted loans. Now, back 

then, if a person didn't have family or friends on the 

outside to help them, it was next to impossible for them 

to discover what company held their debt. Therefore, you 

know the simple process it should be for a six-month 

payment plan to achieve deferment, it was ineffective for 

them because they didn't have outside help at that time. 

True, we have more internet access now, but that still 

remains a problem. People inside simply do not have the 

information, support, or technological access to address 

their student debt issue. Secondly, most incarcerated 

student debt falls under, you know, $10,000 while 

incarceration itself averages $30,000 a year. So, I 

think simple justice reinvestment would be to completely 
45

Negotiated Rulemaking – 2/22/24

absolve all student debt from incarcerated individuals so 

they could have that opportunity there, particularly if 

they've served five years or more. Next, I want to say 

that, you know, upon release, for most of us, when you 

want to talk about wealth, you know, a lot of our wealth, 

realistically, is what we're carrying on our shoulder in 

a trash bag. So, maybe a small gate release check

anywhere from $10 to $200. So, if a person has student 

debt and they also leave with debt, and also with little

wealth as they're trying to start anew, they're starting 

from red, below zero. Lastly, when I was released in 

2015, this was pretty much my situation. And then I ran 

into a 30-year-old criminal legal conviction, which I had 

committed when I was in high school at the age of 17. 

And it was preventing me from realistically gaining 

meaningful employment and even admission for a while into 

universities. But, you know, to increase my 

opportunities, I finally kept pursuing and did get into a 

university. I'm currently a PhD student at Tulane 

University, fifth year, and, you know, but I was wanting 

to increase my life chances and my goal of helping 

others. So, I ended up, you know, into at first, I ended 

into a- excuse me, before the PhD.

MR. WEATHERS: Jarrod, you have 30 

seconds left. 
46

Negotiated Rulemaking – 2/22/24

MR. WALL: Before the PhD program, I 

entered a counseling program and as a result, great 

experience, but I currently have almost $40,000 debt from 

a degree that I'm never going to be able to use. Okay? 

So, I just want to encourage you. I'm going to be 53 

when I graduate, starting with a $40,000 debt. Thank 

you. 

MR. FRANCZAK: Thank you, Jarrod. 

Brady, who do we have next?

MR. ROBERTS: Alright. I just 

submitted Braxton Simpson, who's here representing 

themselves. 

MR. FRANCZAK: Alright. Braxton, can 

you hear us? Can you hear me? There you are. 

MS. SIMPSON: Yes, I can hear you. 

MR. FRANCZAK: Okay, Braxton. So,

you have up to three minutes for your public commentary. 

Please feel free to begin. 

MS. SIMPSON: Greetings everyone! My 

name is Braxton Simpson, and I am honored to address the 

Department Negotiated Rulemaking Committee today as a 

graduate student at North Carolina Central University, a 

student who also attended a historically Black college 

and university for undergraduate and the North Carolina 

state director at Rise. I am deeply committed to 
47

Negotiated Rulemaking – 2/22/24

advocating for equitable and accessible education 

opportunities for all individuals, and I just want to 

express my gratitude to the committee for taking the time 

to listen to my comments. It's crucial that we come 

together to discuss and shape policies that will 

positively impact the education system and ensure that 

every student has the opportunity that they need to 

succeed. I firmly believe that all students should have 

the opportunity to focus directly on their education 

without the burden of having to work tirelessly to fund 

it. Personally, as the oldest of three children, I've 

always had to take on a leadership role in my family. My 

younger brother and I were in undergraduate school at the 

same time, with him having partial scholarships but still 

needing financial support. My brother was also a student 

athlete, which meant he couldn't work a formal job. And 

just knowing the strain on my parents, I took on the 

responsibility of funding my entire education. And this 

meant juggling work, entrepreneurial pursuits, applying 

for scholarships and grants every semester, and 

constantly hustling to stay in school. And while this 

allowed me to graduate, it also resulted in significant 

student loan debt. So just like many Black borrowers 

across the country, student debt is truly a crisis rooted 

in structural and systemic issues faced by Black and 
48

Negotiated Rulemaking – 2/22/24

Brown communities. And we have remained at the center of 

many of these exclusionary policies that have perpetuated 

the racial wealth gap, making it increasingly challenging 

to truly accomplish a high quality of life. And I really 

do believe that investments in the student loan debt 

crisis, like you all are discussing here today, has the 

potential to close this gap and improve the quality of 

life for individuals just like me. So, in conclusion, it 

is imperative for the Department to prioritize the needs 

of student borrowers and take decisive action to create 

an equitable path to loan cancellation. The stories of 

countless individuals like mine, highlight the immense 

challenges and sacrifices made to access higher 

education, only to be burdened by crippling debt 

thereafter. So, by advocating for student borrowers and 

implementing policies that alleviate this financial 

burden, the Department can pave the way for a more 

inclusive and equitable educational system. It's 

essential that we work together to ensure that all 

students have the opportunity to thrive without being 

shackled by the weight of student loans, and the time for 

action is now, and the Department must lead the charge in 

fighting for the future of student borrowers across the 

nation. Thank you so much for your time. 

MR. FRANCZAK: Thank you, Braxton. 
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Brady, who do we have next?

MR. ROBERTS: Alright, I just 

admitted Wesley Watson, who's here representing himself. 

MR. FRANCZAK: Wesley, can you hear 

me?

MR. WATSON: Yes, I can. 

MR. FRANCZAK: Alright, Wesley, you 

have up to three minutes for your public commentary. 

Please feel free to begin. 

MR. WATSON: Good afternoon. My name 

is Wesley Watson. I'm the Michigan State director for 

Rise and a student loan borrower. Thank you for taking 

this time to listen to my comments as you all work towork diligently to establish a rule related towards the 

modification, waiver, and comprehensive of the Federal 

Student Loans. I owe over $200,000 in student loan debt. 

My life number one concern and roadblock is my student 

loan debt. This is impacting my family, this is 

impacting my mother, and this is impacting me. Early on 

in my early grad years, my mother took out a Parent PLUS 

Loan to help me in my first three semesters. After 

college, I wanted to attend law school, but I did not 

pursue it because I feared of collecting more student 

loan debt. I'm currently at the stage where I'm at in 

life where I want to build a family. I want to create a 
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Negotiated Rulemaking – 2/22/24

lasting legacy. I want to purchase my first home. But 

because of my student loan debt, my debt-to-income ratio 

is too high and the only way I will qualify for a home 

mortgage loan is by taking an extreme high interest rate 

loan. This is the new reality for millions of Americans 

and old and young. And this is an unsustainable reality 

and pursuing true equity and opportunity in pursuing the 

American dream. I've seen the impacts of my student loan 

debt impact my ability to be a business owner. I do not 

qualify for business loans, and I face significant 

barriers establishing increasing my business line of 

credit. The debt crisis has disproportionately impacted

Black borrowers and their families across all racial 

groups. Black borrowers hold the most student loan debt 

despite being consistently underserved by postsecondary 

institutions. The Roosevelt Institute brief shows that 

counseling up to $50,000 of student loan debt per 

borrower will immediately increase the wealth of Black 

Americans by 40%. The plan must not leave out borrowers 

who pursue graduate education or support their children, 

like my parents and my mother, and accessing higher 

education to better their lives, to better their future, 

and to better their families. We must ensure and we must 

make sure that we're looking at the hardship. We must 

look at justice and equity and fixing the root cause and 
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Negotiated Rulemaking – 2/22/24

fixing the issue within the- [30 seconds] student loan 

system, including graduate borrowers, including Parent 

PLUS borrowers as well. We fight for equity. We fight 

for justice. Equity benefits all of us, no matter what 

race, skin, color, or creed. Let's fight for equity when 

it comes to student loan debt in crisis. Thank you. 

MR. FRANCZAK: Thank you, Wesley. If 

you are slotted to speak in the first ten minutes between 

3:00 and 3:10, please log in now so we can fit you in. 

Who do we have next, Brady?

MR. ROBERTS: Mike, I just submitted 

Deena Alansky, who's joined but needs to enable audio. 

Let me message her. You should be able to see her on 

screen. 

MR. FRANCZAK: Okay. Deena, can you 

hear us?

MR. ROBERTS: [background noise] 

Could you pause the live broadcast? We're going to get a 

little bit of a feedback otherwise. 

MR. FRANCZAK: Alright, Deena, you 

have up to three minutes for your public commentary. 

Please begin when you are ready. 

MS. ALANSKY: Hi. Thank you for this 

opportunity, I appreciate it. Can you hear me?

MR. FRANCZAK: Yes. 
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Negotiated Rulemaking – 2/22/24

MS. ALANSKY: Awesome. My name is 

Deena Alansky. I'm 62 years old, and I can never retire 

in my lifetime, nor can I afford to buy a house. I work 

full-time in a field unrelated to my degree. I live 

paycheck to paycheck with no safety net, and my job does 

not provide health insurance or a 401K. The American 

dream escapes me because I attended a school that 

defrauded me, The Art Institute of Pittsburgh, which I 

will refer to as AIP. I took out Federal student loans 

to attend AIP from 1999 to 2002. I graduated in '02 with 

a degree in multimedia and web design, but I was never 

able to find a permanent full-time job in my field, and I 

struggled to make payments on these loans, which have 

been a hardship to me for 20 years. Then I discovered a 

few years ago that AIP had committed fraud. They 

fabricated job placement data, which we found out about 

from a whistleblower lawsuit, and they lied to me about 

my future job prospects, potential income, the quality of 

the instructors, the total cost of tuition, and the job 

placement services, which actually ghosted me after I 

graduated. I learned that this was happening at branches 

all across the country. Fortunately, I am a member of 

the Sweet vs Cardona class action lawsuit. I am a full 

class member so I will receive some relief from my debt. 

I was thrilled to get the email from the Department in 
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Negotiated Rulemaking – 2/22/24

February 2022, telling me that my application was 

approved, and my remaining loans will be gone, although 

I'm still waiting for that to happen. I also thought 

that I was going to be reimbursed for all the payments I 

had made during those 20 years, but I was devastated to 

learn that I was ineligible for the refund because my 

Federal student loans were commercially held FFELP loans, 

F-F-E-L-P. I believe it's completely unfair, immoral, 

and unethical the commercially held FFELP loans like mine 

and like thousands of other people like me, are treated 

differently than other Federal student loans. It was not 

my decision to have my Federal student loans financed 

outside of the Federal Government. So why should I be-

[30 seconds] punished for something that was completely 

beyond my control? Why should I be left out of the COVID 

payment pause and why am I ineligible for a 

reimbursement? But still, I'm one of the lucky ones 

because my application was approved. I want to ask the 

Department to please consider a group-wide discharge for 

all former Art Institute students. We were all defrauded 

by the school, and we all deserve to be unburdened from 

the crushing student debt associated with this fraud. 

Please do the right thing. Please issue a group-wide 

discharge for all defrauded borrowers who attended an AI 

school. Thank you for your consideration. 
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Negotiated Rulemaking – 2/22/24

MR. FRANCZAK: Thank you, Deena. 

Brady, who's next?

MR. ROBERTS: Alright. I just 

admitted Ebony Brown, who's here representing herself. 

MR. FRANCZAK: Alright. Ebony.

MR. ROBERTS: She might be stuck in 

the waiting room right now. She just joined. 

MR. FRANCZAK: Ebony, can you hear 

me?

MS. BROWN: Yes, I can, thank you. 

MR. FRANCZAK: Okay. You have up to 

three minutes for public commentary. Feel free to begin. 

MS. BROWN: Okay. Thank you. Give 

me one second please. Computer is moving extremely slow. 

Okay. Well, good afternoon. My name is Ebony Brown. I 

am a first-generation nontraditional college student and 

student loan borrower, and I serve as the state director 

for Rise Georgia, and I appreciate you for the 

opportunity to share my thoughts on this discussion 

today. I was a teenage mother and fresh out of high 

school, I decided to attend college and quickly realized 

that I did not have the financial support to pay for my 

tuition. I did not have reliable transportation, and so 

due to that fact, I had to drop out and after dropping 

out and deciding to choose income over education, the 
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Negotiated Rulemaking – 2/22/24

interest on my student loans grew month after month, 

which eventually led me into default on my loans. And 

the result of defaulting on my loans impacted me in ways 

that I didn't know that it would. And so, I couldn't 

obtain a credit card. I couldn't get a loan for a car. 

And due to the mounting cost of my student loan debt, I 

was not considered credit worthy. And so, when the 

payment pause was rolled out, I was very fortunate enough 

to be able to save enough money towards opening my small 

print on demand service, which in turn gave me the 

ability to contribute to society and benefit my community 

while also giving me a chance to create generational 

wealth. And now I am in a space where I am ready to 

purchase my first home, and with the payment pause 

ending, I am a bit unsure on whether I will be able to 

achieve that goal. And you know, the cost of living is 

higher than it's ever been. Inflation is through the 

roof. Daycare expenses are extremely high, as over 40 

million borrowers are facing student loan debt, and the 

Department must recognize the profound impact student 

debt has on borrowers like me and take decisive action to 

alleviate this burden. And so Black borrowers make up 

under 8% of those with no debt, but over a quarter of 

those who hold over $50,000 in student loan debt. And 

so, I urge the Department to do everything possible to 
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Negotiated Rulemaking – 2/22/24

fight for student loan debt cancellation and for 

borrowers and to create an equitable pathway to 

cancellation becauseMR. WEATHERS: 30 seconds remains. 

MS. BROWN: Yes. It's not about 

alleviating individual financial burdens, but also 

building a fairer and more just society where education 

is truly accessible to all. And thank you for hearing my 

thoughts today. 

MR. FRANCZAK: Thank you, Ebony. I'm 

going to ask anyone who slotted to speak between 3:00 

p.m. and 4:00 p.m. Eastern to log in now so we can fit in 

as many people as possible and keep the- keep our flow 

moving as efficiently and effectively as possible. So 

again, if you are slotted to speak between 3:00 and 4:00, 

please log in now. Brady, who do we have next?

MR. ROBERTS: Alright. I just 

admitted Arin Anderson, who's here representing themself, 

and I believe they are on screen and have audio enabled. 

MR. FRANCZAK: Arin, good to go? You 

have up to- great. You have up to three minutes. Please 

feel free to begin. 

MS. ANDERSON: Thank you. Good 

afternoon. I am Arin Anderson, an African American

first-generation college student and a student loan 
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Negotiated Rulemaking – 2/22/24

borrower. Thank you all for taking the time to listen to 

my comment as you all work urgently and diligently to 

establish a rule related to modification, waiver, or 

compromise of Federal Student Loans. During my time in 

university, I acquired thousands of dollars in student 

debt simply to have secure housing, basic needs, and 

tuition. Coming from a single-parent, low-income 

household with two girls in college and a middle schooler 

at home, my mom couldn't afford to offer financial 

support while I was in university and eventually needed 

my support when she was diagnosed with breast cancer in 

2020. At the time of her diagnosis, I was already a 

full-time student and working two jobs to cover my cost 

of living and basic necessities while in school, but I 

refused to let the cost of tuition and unfortunate, 

unforeseen circumstances hinder me from pursuing a higher 

education and in turn, creating a better life for myself 

and my family. I took on student loan debt in need of 

support. I knew that this would impact me drastically 

after college, but I had no choice and was unaware to 

what extent. When student loan payments were paused, I 

had the opportunity to create stability in my life; 

secure housing, transportation, and cover basic 

necessities, something I was struggling to do while in 

school working full-time to support myself. Now that the 
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Negotiated Rulemaking – 2/22/24

pause on student loan payments has ended, I am back where 

I started, struggling to make ends meet after paying 

every necessary bill and expense to have safe and healthy 

living conditions, struggling to get ahead, or even 

caught up for that matter, after working so hard and so 

tirelessly to create stability in the midst of chaos. 

Forty-four million Americans hold $1. 6 trillion in 

Federal Student Loan debt. The college affordability 

crisis and the burden of student loan debt can limit 

economic growth for individuals and families. Student 

debt affects everyone. It's an economic issue, an equity 

issue, a housing market issue. And tackling this $1.6 

trillion in Federal Student Loan debt would aid in 

tackling these other issues that are also directly 

impacting our lives. Canceling student debt would bewould significantly support the financial stability of 

young adults, families like- families and student 

borrowers like me can lift the burden of the student debt 

crisis for millions like me. This would give families an 

opportunity to get ahead, buy a house, save money, and in 

turn, change their futures. Thank you. 

MR. FRANCZAK: Thank you, Arin. 

MS. ANDERSON: Thank you. 

MR. FRANCZAK: Brady, do we want to 

just begin with our slotted speakers and then fit in our 
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Negotiated Rulemaking – 2/22/24

last 1 or 2 waitlisted folks as need- as we can?

MR. ROBERTS: Oh, shoot. So, we're 

missing our first two slotted speakers, so I did go ahead 

and admit the final waitlist speakerMR. FRANCZAK: Okay. 

MR. ROBERTS: Who is John Burkey, 

who's representing Burkey Capital, who's in the meeting 

and does have audio enabled. 

MR. FRANCZAK: Okay, John, you have 

up to three minutes. Please feel free to begin. Are you 

ready to start?

MR. BURKEY: Hello. Hello. My name 

is John Burkey. Hello, my name is John Burkey. I'm with 

Burkey Capital. The subject of my comments would include 

the cohort of all student loan debtors. The proposed 

solution I have would be at no cost to taxpayers. Yes, 

can you hear me? 

MR. FRANCZAK: Yes. Please keep 

going. 

MR. WEATHERS: The proposed solution 

I have- theMS. JEFFRIES: Mike, I would suggest 

we bring in the next person. There seems to be a problem 

with his audio. 

MR. FRANCZAK: Yeah. John, in the 
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Negotiated Rulemaking – 2/22/24

future, you could turn off your video, and then we could 

just hear you. That might help with the feed. 

MR. BURKEY: Okay, I canMR. ROBERTS: I can message him while 

we hear fromMR. FRANCZAK: Yeah, let's do that, 

Brady. Thank you. Thank you, Cindy, as well. Alright. 

MR. ROBERTS: I just admitted Guy 

Joseph, who's here representing himself and Guy is in the 

room. 

MR. FRANCZAK: Okay. 

MR. ROBERTS: You're good to go. 

MR. FRANCZAK: Guy, you have up to 

three minutes. Please begin. 

MR. JOSEPH: Good afternoon. My name 

is Guy Joseph, and I am a student loan borrower.

Firstly, I want to express my gratitude to each of you 

for dedicating your time to hear my perspective as you 

work towards establishing rules concerning the 

modification, waiver or compromise of Federal Student 

Loan debt. As a first-generation Haitian American, 

education has always been revered as a fundamental value 

in my family. The sacrifices my grandmother, whose 

education halted at the fourth grade due to familial 

responsibilities, my mother, who tirelessly worked two 
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Negotiated Rulemaking – 2/22/24

jobs to support me and my siblings, highlighted to me the 

importance of familial well-being and education. 

Understanding this, I pursued education passionately, 

driven by the potential it held for my family's future 

success. Graduating college as the first in my family 

was a significant milestone for me. This is followed by 

me becoming the family's first lawyer as my aunt always 

points out every time she gets- every chance she gets. 

Yet these achievements came with a heavy price tag for me 

and my family. Just by receiving the Pell Grant, which 

helped secure my degree and the unwavering support of my 

mother who applied for the Parent Plus Loan, the weight 

of the Federal Student Loan debt has been a persistent 

burden hindering my financial progress. Today day I 

stand before you burdened by student loan debt totaling 

$432,124. 18. It's a staggering sum that threatens to 

overshadow every accomplishment in every dream. The 

recent reinstatement of student loan payments adds 

another layer of complexity to my financial situation. 

Despite my diligent efforts, the looming monthly payments 

threatened to hinder my ability to achieve essential life 

milestones such as home ownership, comfortable family 

life, the creation of generational wealth, often enjoyed 

by my- often enjoyed by my white counterparts. In 

closing, I implore you to consider the broad implications 
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Negotiated Rulemaking – 2/22/24

of student debt on individuals like me to approach your 

deliberations with empathy and compassion, and also to 

work towards leveling the playing field so that all 

Americans have an equal opportunity to thrive. Thank 

you. 

MR. FRANCZAK: Thank you, Guy. 

Brady, who do we have lined up next?

MR. ROBERTS: Alright, I just 

admitted our next scheduled speaker, who is Lisa Salmons, 

who's here representing herself. 

MR. FRANCZAK: Alright. Lisa, can 

you hear me?

MR. ROBERTS: Lisa, you're on mute 

[inaudible]. 

MS. SALMONS: Can you hear me? 

Sorry. 

MR. FRANCZAK: It's okay, Lisa. 

Alright, Lisa, you have up to three minutes for your 

public commentary. Feel free to begin. 

MS. SALMONS: Alright. Thank you. 

Hello. My name is Lisa Salmons, and I have a total 

student loan debt of $172,000 after attending a doctor 

and pharmacy school program that was three years in 

length. I was lucky to not have any other debt when I 

entered my doctorate program. I appreciate the 
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Negotiated Rulemaking – 2/22/24

Department holding this meeting today. With that being 

said, I would like to reiterate that PDP stimulus was 

handed out to businesses, and they did not have to go to 

great lengths to prove they were experiencing hardship 

from COVID-19. COVID-19 sparked this conversation about 

student loan forgiveness, and again, healthcare workers 

who work tirelessly during the pandemic are being 

excluded from this hardship conversation and are mostly 

excluded from receiving benefit from the loan programs 

available. Hardship in this conversation seems to only 

include monetary means and is excluding the emotional 

toll the pandemic took on healthcare workers. I 

submitted red lines in December to include healthcare 

workers in the regulatory text and have yet to see them 

added to the official regulatory text. I would like to 

add the following red lines to 30.91(b)(18) (Student 

loans with more than $100,000 original principal balance, 

combined or not combined, including those not owed to the 

Department, (19)) The loan was disbursed to a student or 

parent on behalf of a student in a graduate student 

healthcare program that provides direct patient care. 

(19)(a), direct patient healthcare graduate programs 

mentioned above include, but is not limited to, 

occupational therapy (ODT), medical doctor (MD), doctor 

of osteopathy (DO), pharmacist (Pharm D), dentists (DMD), 
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Negotiated Rulemaking – 2/22/24

Doctor of Physical Therapy (DPT), physical physician 

associate (PA), masters in nursing (MSN), doctor of 

psychology (PsyD); and (20), student loans that have been 

paid to exceed the original principal balance and have 

satisfied the original principal. Thank you so much for 

your time today and I yield my time. 

MR. FRANCZAK: Alright, so thank you. 

The purpose of this is public commentary. We appreciate 

your public comments. Submission of proposals needs to 

be done through a different vehicle. So, we do 

appreciate your public commentary. I want to encourage 

folks who are slotted to speak now between 3:00 and 4:00 

p.m. Eastern to please log in now. We only have seven 

folks in the waiting room, and I know there's more folks 

who were slotted to speak, so please log in now so we can 

hear your public commentary. Brady, who do we have next?

MR. ROBERTS: I just admitted Mia 

Senechal, who is here representing MoveOn, who is in the 

room, and I believe has audio enabled. You're on mute, 

but I think we're ready to go. 

MS. SENECHAL: Thank you. 

MR. FRANCZAK: Mia, you have up to 

three minutes. Please begin. 

MS. SENECHAL: Okay. Thank you for 

taking the time to hear my public comment. My name is 
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Negotiated Rulemaking – 2/22/24

Mia Senechal and I'm a campaign director with MoveOn 

Political Action Fund. I'm here on behalf of thousands 

of MoveOn members and student loan borrowers who are 

encouraged by the Department’s proposal to relieve 

student debt for borrowers experiencing financial 

hardship. Despite several attempts by far-right

Republicans, their special interest funders and the MAGAled Supreme Court to strip away desperately needed debt 

relief from millions of struggling Americans, this 

administration has remained steadfast in delivering 

student debt relief through legal and established 

processes. Millions of MoveOn members are looking for 

this administration to reaffirm their commitment to 

addressing the student debt crisis. I urge negotiators 

to continue to quickly and fully deliver student debt 

relief to the countless everyday Americans who are 

crushed by the predatory loan system. Thank you. 

MR. FRANCZAK: Thank you, Mia. 

Brady, who do we have next?

MR. ROBERTS: Alright, I just 

admitted Aissa Canchola Banez, who's here representing 

the Student Borrower Protection Center. 

MS. CANCHOLA BANEZ: Great. Thank 

you. Can you hear me?

MR. FRANCZAK: Yes. Aisha, is that 
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Negotiated Rulemaking – 2/22/24

how we pronounce your first name?

MS. CANCHOLA BANEZ: It's Aissa. 

MR. FRANCZAK: Aissa. Thank you. 

You have up to three minutes. Please begin. 

MS. CANCHOLA BANEZ: Great. Good 

afternoon and thank you for the opportunity to speak 

today. Once again, my name is Aissa Canchola Banez, and 

I serve as a senior advisor for policy and strategy with 

the Student Borrower Protection Center. First and 

foremost, I want to thank the Department for heeding the 

calls of borrowers, advocates, policymakers, and even 

some of your own fellow negotiators to come back to the 

table and to present a plan to support borrowers 

experiencing hardship, and, most importantly, for 

proposing a strong and expansive rule that could provide 

the Secretary with the necessary flexibility to address 

the myriad of ways that borrowers could experience 

hardship due to their student loan debt. For the 

millions of working people and families crushed under the 

weight of the student debt crisis, this hardship proposal 

sends a strong message of hope. Hope that the dream of 

finally being debt-free did not die when the Supreme 

Court sided with special interests over the rule of law, 

in hope that the dreams of home ownership, starting a 

small business, saving towards a retirement with dignity, 
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Negotiated Rulemaking – 2/22/24

and even starting or growing a family might finally be in 

reach. For too long, the cost of pursuing a higher 

education has resulted in a lifetime of student debt, 

which has denied an entire generation of borrower’s

higher education's promise of economic mobility. And 

it's- this is why it's critical that the Department's 

rule take into account the millions of current college 

students not yet in repayment, and recent graduates just 

beginning their careers. For an entire generation of 

young people, the promise of an American dream has been 

pushed out of reach by the student loan debt crisis, and 

we can act now to change that. This proposal is a step 

in the- a strong step in the right direction, and we are 

encouraged to see that the proposal grants the Secretary 

the authority to provide immediate and automatic relief 

for those with high likelihood of default. The 

Department should also ensure that the 7 million 

borrowers currently in default, and those who have 

recently taken advantage of the administration's Fresh 

Start initiative, are automatically included in this 

critical relief. We also appreciate that this rule has 

the flexibility to provide further relief automatically 

or via application now and in the future, and in this 

case [inaudible] so where the Department has readily 

available data on a borrower's economic background or 
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Negotiated Rulemaking – 2/22/24

relevant demographic information, such as recipientreceipt of a Pell Grant or other public benefits, the 

Department should work to provide cancellation 

automatically and without an application. Default is not 

the only indicator of hardship and should not be the only 

grounds for automatic relief. For too long, student loan 

policies have been crafted to exclude certain groups of 

borrowers, and so we applaud the Department for including 

Parent Plus borrowers, and strongly urge the Department 

to not allow the 6 million borrowers with commercially 

held FFEL loans to be left behind. We again applaud you 

for proposing a rule that provides an avenue for millions 

of Americans to see the relief that President Biden 

promised them, and we now call on you to ensure that this 

relief is issued as swiftly and as efficiently and as 

broadly as possible. Thank you. 

MR. FRANCZAK: Thank you. Brady, who 

do we have next? 

MR. ROBERTS: Alright, I just 

admitted Val Montefu. [inaudible] It looks like she 

needs to enable audio. We can't hear you, Val. Let me 

see if I can't message her. Here we go. 

MR. FRANCZAK: Val, can you hear us?

MS. MONTEFU: I'm not hearing audio. 

MR. FRANCZAK: You have three minutes 
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Negotiated Rulemaking – 2/22/24

to speak. Up to three minutes. Are you ready?

MR. ROBERTS: I think she maybe has 

the volume on her phone turned down because her audio is 

enabled. 

MS. JEFFRIES: Can we- Mike?

MR. FRANCZAK: Yes. You areMS. JEFFRIES: Mike, can we confirm 

if she's driving because we can't allow people to 

participate if they're driving? 

MR. FRANCZAK: Yeah. 

MR. FRANCZAK: Yeah. Val, are you 

driving or not?

MS. MONTEFU: As high as it goes. Can 

you hear me?

MR. FRANCZAK: Yes. Are you driving 

currently? She can't hear us at all. 

MS. MONTEFU: Can you hear me now?

MR. FRANCZAK: Yes. Go ahead. 

MS. MONTEFU: Oh, good. Okay. I 

don't know what that was about. I'm sorry. Okay. My 

name is Valerie Montefu. I'd like to tell you about the 

hardships these loans have created in our family. Our 

son attended Brooks Institute of Photography from 2003 to 

2007, anticipating a bright future in a career he had 

dreamed of since he was a child. He worked hard, 
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Negotiated Rulemaking – 2/22/24

graduated with a bachelor's degree and the bachelor's 

degree turned out to be completely worthless. The career 

counseling and promise leads never happened. The 

accreditation they claimed would lead to great jobs 

turned out to be non-existent. There were no jobs in his 

field. The loans we were told would be easily paid off 

by his guaranteed high income, are still lingering and 

growing like a cancer 20 years later, due to the 

predatory and deceptive pressure put on us by Brooks 

Institute and CEC. This loan amount has more than 

tripled, according to our loan servicer, Nelnet, from 

about $100,000 to over $337,000. Brooks Institute and 

CEC are a known bad actor duo for decades, and even 

though Brooks has shut down forever, CEC is still in the 

business of deceiving people that are still trying to 

build a better future for themselves or for their 

children. My husband and I and our son are Sweet class 

members, and the victory of this lawsuit was the first 

ray of hope we've had in many years. Unfortunately, the 

DOE and Nelnet failed to meet the January deadline. Both 

have terrible customer service and are nearly impossible 

to reach. We're currently living in fear that something 

will happen to allow them to permanently avoid complying 

with those court orders. My husband is 70 years old and 

I'm 68. We no longer own a home, nor can we get a loan 
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Negotiated Rulemaking – 2/22/24

to buy one with this amount of debt. In fact, our amount 

of predatory loan debt is more than the price of a nice 

middle-class home in many parts of our country. I'm 

still working full time with no view of retirement in 

sight, probably for the rest of my life. We will die 

with these loans hanging over our heads, unless the DOE 

and Nelnet are made to comply with the terms of the lawof the Sweet lawsuit. Due to all these deceptive 

practices of Brooks Institute and CEC, I believe all 

Brooks students and their parents should get immediate 

loan cancellation and refunds so that we can begin to 

live our lives again with freedom from this crushing 

burden. The loans from predatory companies like this 

create huge undue hardships and extreme stress on 

borrowers and their families. They're devastating in 

ways that go well beyond mere finances They go so deeply 

into family relationships and dynamics for success. 

MR. WEATHERS: 30 seconds remains. 

MS. MONTEFU: Really personal things 

I don't want to talk about right now. My husband and I, 

as well as all the other borrowers suffering under this 

hardship, deserve to be able to move on with renewed hope 

for what's left of our future. Thank you for allowing me 

to speak. 

MR. FRANCZAK: So, for the safety of 
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our commentators, we just want to make sure that people 

are not driving. We couldn't tell if she was driving or 

not, but we do want folks to be safe while they're 

providing their public commentary. So, let's make sure 

that we are in a safe place and safe space to provide our 

public commentary. Alright. Brady?

MR. ROBERTS: Alright. I just 

admitted Candace Milner, who is here representing Public 

Citizen. And they are in the room, and I believe ready 

to go. 

MR. FRANCZAK: Candace, can you hear? 

Can you hear me?

MS. MILNER: Yes. Can you hear me?

MR. FRANCZAK: Yes. You have up to 

three minutes. Please begin. 

MS. MILNER: Thank you. My name is 

Candace Milner. I'm the racial equity policy associate 

at Public Citizen, a national nonprofit organization that 

represents consumer interests and has more than 500,000 

members and supporters. Thank you all for taking the 

time to listen to my comment and your work to establish a 

rule related to the modification and waiver of Federal 

Student Loans. I am a first-generation college graduate, 

a Pell Grant recipient, and a student loan borrower.

During the payment pause, I graduated from law school and 
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began working in a public interest role that is not PSLF 

eligible. The payment pause enabled me to pay down 

additional debts I incurred while in grad school and 

preparing for the bar. I was also able to build a 

savings and plan for my future. Returning to payment 

without substantial debt relief has halted my progress in 

reaching saving goals and makes the idea of reaching 

financial milestones like home ownership and expanding my 

family out of reach. It is not a secret that Black women 

are the most likely group to have student loan debt, and 

Black and Latinx students borrow at higher rates than 

their white peers. For me, pursuing higher education was 

a pathway for upward mobility and to build wealth for 

myself and my family. Unfortunately, student loan debt 

incurred from earning my degrees has stifled my ability 

to save, build wealth, and acquire true mobility in ways 

that I was promised. This is hardship. I urge 

negotiators to do everything possible to fight for 

borrowers and create widespread and accessible pathways 

to cancellation. Canceling $50,000 in student loan debt 

would significantly reduce the racial wealth gap and lift 

the burden of the student loan debt crisis for millions.

It will also guarantee that borrowers like me, and an 

entire generation of borrowers, are not left out to dry. 

The Department must not leave out borrowers who pursued 
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graduate education or supported their children in 

accessing higher education by ensuring any proposals for 

waivers include graduate borrowers and Parent PLUS 

borrowers. I would stress the importance of the hardship 

portion for this proposal and thank the Department for 

bringing the negotiators back to the table. I support 

making this relief as automated as possible and would 

like to specifically support it, including Pell Grant 

recipients, borrowers impacted by loan service errors, 

and borrowers with high housing costs. Like many 

borrowers, I am happy to do my part in paying down debt 

and strengthening our economy. Student loan debt relief 

and the flexibility for hardship that was proposed today 

are a great start to ensure [30 seconds]. Thank you- are 

a great start to ensure that borrowers like me can 

contribute to our economy and strengthen our communities 

without the burden of a crippling student loan debt. 

Thank you so much. 

MR. FRANCZAK: Thank you, Candace. 

Alright, so we have six speakers left. And up to 38 

minutes remaining for the public commentary. So, if you 

haven't logged in as a slotted speaker, please do so now. 

Brady, who do we have next?

MR. ROBERTS: Alright. I just 

submitted Timothy Babulski, who is here representing 
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himself. And I believe he is all set to go. 

MR. FRANCZAK: Alright, Timothy, all 

set?

MR. BABULSKI: Yes, indeed. 

MR. FRANCZAK: Alright. You have up 

to three minutes. 

MR. BABULSKI: Thank you. Thank you 

for taking the time to listen to my comments today. I am 

Timothy Babulski. Although I'm here representing myself 

as a student loan borrower, I am the art education 

coordinator for the University of Maine and adjunct 

professor at the University of Southern Maine, Southern 

Maine Community College, and the University of North 

Carolina at Charlotte. The reason why I have so many 

titles is because higher education right now is in an 

adjunct [inaudible] crisis, and the Public Service Loan 

Forgiveness changes, although important made some 

necessary improvements, have still made it impossible for 

those of us with large amounts of student loans to be 

able to successfully return to payment without taking on 

multiple positions, traveling extensively and working 70, 

80, 90 hours a week. The Department needs to understand 

that their failure to previously include graduate 

borrowers and to make significant changes to the Public 

Service Loan Forgiveness program, although they are not 
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topics for today, has indeed created hardships that we 

all suffer with. My personal loan story is that I have 

$229,756.41 in student loan debt. A small portion of 

that is from undergraduate loans, most of it from my 

master's and my doctorate program. But at a point of 

career transition in 2009, there was really no choice, no 

other option left before me. It is what we have all been 

told to do as good American students and citizens, that 

when times are down, we dig deep, we go far. We make the 

Hail Mary pass. We try for the end zone. And that meant 

going back into higher education. Doing so allowed me to 

live. I have no doubt that without going back into

higher education, I would not have survived a period of 

being unhoused. However, having this burden of student 

loan debts hanging over the top means that not much has 

significantly changed. I still do not have access to 

home ownership. I have only recently regained access to 

medical care, still have not had access to dental care in 

over 20 years. I have never been able to start a 

business or raise a family. That lack of security as I 

am entering middle age, means that I am looking at a 

position where I have no retirement, no real access to 

benefits, and hearing the stories of people who are 10, 

20 years my senior really brings it home how deep and big 

this crisis is I encourage the Department [30 seconds] 
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to seriously consider how their 17 factors relate to 

hardship, because the hardship of student loan debt is 

that it denies all of us full participation in society 

and derails the possibility of our social mobility. It 

cannot just be for borrowers on the verge of default or 

for the purpose of making payments. Thank you. 

MR. FRANCZAK: Thank you. Brady, who 

do we have next?

MR. ROBERTS: Alright. We just got 

confirmation that Pam Patterson is our next speaker. 

She's here representing herself. I believe she's in the 

room, and she's enabled audio. 

MR. FRANCZAK: Alright, Pam, can you 

hear us? 

MS. PATTERSON: Yes. Can you hear 

me?

MR. FRANCZAK: Yes. You have up to 

three minutes. Please begin. 

MS. PATTERSON: Okay. I'm very 

appreciative to the panel's efforts to hear the 

borrower's stories. My husband's student loan struggles 

have been an issue since he left school in 1986. I've 

been following the discussions and even reached out to 

Jessica Ranucci, one of the negotiators who's been 

helping navigate collection issues for HEAL borrowers. 
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Thank you, Jessica. I would like to bring attention to 

our experience with the HEAL Loan Program, discontinued 

in '98, and ask the Department to include HEAL Loan 

borrowers in any debt relief. When these loans were made 

at Life University in 1982, my husband was told, sign 

here and get a loan. No counseling or warning this could 

ruin your life. So, he borrowed $50,000 and as of 

October 23, his balance was $562,000. Unfortunately, his 

first wife deserted him and two young boys at four and 

five while being a full-time student. When the judge 

awarded him full custody, he was told to get full-time 

employment and was not able to finish school and

defaulted. His boys took priority over the letters 

demanding loan payment in full. Times were tough. He 

was unable to provide insurance for himself or the boys, 

afford health, dental care, braces, assistance with 

education, auto insurance, cell phones, etc. The boys 

started working at an early age to cover expenses that 

most parents can afford. Because of damaged credit, he 

never qualified for a car loan and still been a joint 

owner on a home mortgage, nor contributed to any type of 

retirement saving plan. Even after Mark and I married, 

we were unable to escape the stress of this monster loan. 

As with most borrowers who have gone into default, it is 

often for hardship reasons. A payment agreement was only 
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offered after years of being in default, since he had 

honored this agreement and faithfully paid the $200 per 

month for over 23 years. Prior to COVID, his monthly 

statements showed interest penalties, late fees at $3,000 

or more. At 64 years old, if he lives to be 80, this 

debt will likely be 1.5 million. He has paid back 

$60,000 with no credit applied to the $50K principal. 

For decades, borrowers have likely been paying on similar 

payment plans unknowingly, still in default with no 

forgiveness in sight. Since HEAL loans are still in 

collection through HHS program support, they are not 

monitored by the Department. When Mark's payments 

resumed [30 seconds]- He did not receive a monthly 

statement, just a collection letter wanting payment in 

full $562,000 in principal. Yet we will still be 

garnishing tax refunds, Social Security, and benefits.

The current balance is unknown since HHS no longer 

provides monthly statements. This is like a home buyer 

still owing ten times more the principal amount after 

paying off a 30-year mortgage. In summary, I understand 

protecting taxpayer money, but struggling student loan 

borrowers are also taxpayers and deserve protection. I 

think that borrowers with defaults, judgments, and 

borrowers with HEAL loans deserve to be included in debt 

relief. 
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MR. FRANCZAK: Thank you, Pam. 

Alright Brady, who do we have next?

MR. ROBERTS: Alright. I just 

admitted Christian Solomon who is the Nevada State 

Director of Rise. And I think he's on screen and off 

mute. 

MR. FRANCZAK: Okay. Christian, can 

you hear me?

MR. SOLOMON: Yes, sir. 

MR. FRANCZAK: Alright. You have up 

to three minutes. Please begin. 

MR. SOLOMON: Thank you. Hello 

everyone. My name is Christian Solomon and I'm the state 

director for Rise Nevada, and someone who's suffered 

under the financial burden of student loan debt. I would 

like to thank the Department Negotiated Rulemaking 

Committee for taking the time to hear my story, among 

others, as you work with the purpose to establish a rule 

related to the modification, waiver or compromise in 

loans. 

MR. FRANCZAK: Thank you. Go ahead. 

Christian. 

MR. SOLOMON: Because of student loan 

debt, 2020 was the worst year of my life. In that year, 

I could not afford to continue pursuing my bachelor's 
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degree and decided that I was going to work and take care 

of my mother, who had been diagnosed with renal failure. 

Because of a delinquent balance at New Mexico State 

University, my transcripts were withheld from me, and I 

was ineligible for many job opportunities after dropping 

out in 2020. It was during the payment pause that my 

financial and career situation was made a lot clearer for 

me. As someone who then served an AmeriCorps term in the 

fall of 2020, I was able to establish a plan, pay off my 

delinquent balance, became empowered to do more and aim 

higher, and recognize that my ambitions, passions and 

interests were in my hands all along. But I needed that 

hand up in the form of a payment pause to help me get 

here. Without any form of student loan debt relief, my 

life would drastically change, because I would then have 

to reacquire the costly burden of simply being born in 

the wrong time, striving for an education in an economic 

system that was created without my generation's 

ambitions, passions, and interests in mind. As a Gen 

Zer, I can assure you that we are a generation that 

watched our parents struggle during the recession of the 

late 2000 and on the verge of adulthood, were set back 

with similar effects during the pandemic, secure economic 

mobility for our generation and for communities that have 

been historically marginalized should not just be a goal, 
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it should be an automatic built in necessity. As young 

people, we are often told that we are the leadership, 

professional, workforce and backbone of the future, but 

get paid lip service far too often for it. The DOE 

should establish a pathway through student loan debt 

cancellation to ensure that we can meet our needs and 

thrive as societal stakeholders. We are not just the 

foundation of our country's success; we are the 

reinforcing pillars that will let you know about this 

immense pressure that could lead to a dark future for 

young people. Our students deserve to live with the 

dignity of being able to live and learn. It is their 

energy that can be focused on solving huge systemic 

problems in all fields instead of having them squander 

their talent on survival, hardship, and struggle. More 

avenues for student loan debt relief will empower 

students. Thank you for your time. 

MR. FRANCZAK: Thank you, Christian. 

Brady, who's lined up for us next?

MR. ROBERTS: I just admitted Zaniya 

Lewis, who is the executive director of 

YesSheCanCampaign. 

MR. FRANCZAK: Alrighty. Zaniya, can 

you hear me?

MS. LEWIS: Yes, I can hear you. 
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MR. FRANCZAK: Great. You have up to 

three minutes. Please begin. 

MS. LEWIS: Okay. Thank you for 

allowing me to speak today. My name is Zaniya Lewis, and 

I am a financial aid recipient, a law student, and the 

founder of the nonprofit called the YesSheCanCampaign. 

We run a program and platform called Disscholared that is 

working to dismantle scholarship award displacement 

nationwide. I have over $60,000 in student loan debt, 

and many of my loans came from earning a scholarship. 

100% of postsecondary institutions across this nation are 

penalizing students like me who earn outside scholarships 

and grants, including, but not limited to, Federal 

grants, Federal scholarships, state grants, state 

scholarships, military benefits, outside scholarships, 

external scholarships, private scholarships, and any 

outside aid. During my senior year of undergrad, my 

institution eliminated my work study. They eliminated 

about half of my university need-based scholarship, and 

they increased my Federal loans because I won a 

scholarship, and I was left to pay over $15,000 out of 

pocket. And I ended up going into over $20,000 in 

student loan debt, both Federal and private loans that 

year, and almost had to drop out of my postsecondary 

institution. Higher institutions are also eliminating a 
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student's Pell Grant after receipt of an outside 

scholarship grant or aid, and therefore a student who is 

eligible for a Pell Grant are not able to- or any other 

type of financial aid, do not receive it because of their 

postsecondary institutions outside aid policies. And 

students who receive outside aid and grants are 

disadvantaged by being penalized for earning these 

scholarships and grants, leading them to take on 

additional loans which include Federal loans. 

Institutions, state student loan lenders, and scholarship 

websites and programs are also working together to force 

students into additional student loan debt, including 

Sallie Mae, who recently inquired the scholarship site, 

Scholarly. And I hope that this committee will take into 

consideration on how postsecondary institutions are using 

scholarships and grants as a tactic to force students 

into student loan debt. Scholarships and grants should 

be used to decrease debt, not increase debt. Thank you. 

MR. FRANCZAK: Thank you. Next, 

Brady. 

MR. ROBERTS: Alright. I just 

admitted Joann Mercedes, who is here representing 

herself. 

MR. FRANCZAK: Alright. Joann, can 

you hear me?
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MR. ROBERTS: She has audio enabled. 

MR. FRANCZAK: Yep. Joanne, you're 

currently muted. There you go. Alright. You have up to 

three minutes for your commentary. Please begin. Still 

can't hear her. 

MR. ROBERTS: Yeah. Joann, if you 

can hear us, your off mute but we can't hear you for some 

reason. Do you have like a- maybe an external mic hooked 

up? Do you want- here, I can work with you offline if 

you want me to admit the next speaker. 

MR. FRANCZAK: Okay. 

MR. ROBERTS: Alright, I just 

admitted Tyler Knapp, who's here representing himself. 

And Joann, I'll send you a message. 

MR. FRANCZAK: Alright. Tyler, can 

you hear me? Tyler? Can you hear me? Tyler Knapp. 

MR. WEATHERS: Yep. 

MR. FRANCZAK: Alright, Tyler, you 

have up to three minutes for your public commentary. 

Please begin. 

MR. KNAPP: Hi. Hello. First and 

foremost, I'd like to thank the committee for allowing me 

time to speak. I'm a 32-year-old male who works as a 

software engineer. I have $48,000 in student loans. I 

have a chronic medical condition called ankylosing 
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spondylitis, which slowly fuses my spine into one bone 

over time. I'd like the committee to consider adding a 

category for people that have chronic health conditions, 

and the significant gap in how much people with chronic 

health conditions pay. Last year alone, between medical 

and dental expenses, I spent $11,456.16. Last year was 

not a good year. I had two surgeries. An average 

healthy individual will spend a few hundred dollars a 

year on out-of-pocket medical expenses. According to 

Huang, et al, in 2001, two percent of families with 

members having two or more chronic health conditions 

spent 10% or more of their income on healthcare, as 

compared to only four. Three percent of families 

spending 10% or more of their income on healthcare. For 

my condition alone, on a monthly basis, I am spending 

$450.53. I do have private insurance for my employer, 

but even with the private insurance, I'm still spending 

hundreds of dollars a month on specialists such as pain 

management, rheumatology and psychiatry. One of the 

specialty medications I take, my co-pay is $250 a month. 

My insurance company's responsibility is around $5,500. 

Another one, my co-pay is $80. My insurance company pays 

around $1,200 a month for that. So, I'm asking the 2024 

Negotiated Rulemaking Student Debt Relief Committee to 

please consider these facts when deciding on the rules 
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and incorporate some type of program that offers relief 

for individuals with chronic health conditions. Every 

paycheck I pay combined $862.42 in Federal, State, 

Medicare, and Social Security taxes, which means that 

last year I had withheld from my paycheck a total amount 

line taxes of $22,061.28. I am on no welfare programs or 

any type of state aid. By allowing a program to allow 

complete or partial forgiveness for individuals with 

chronic health conditions, I would actually see my tax 

dollars going toward something that is benefiting me. As 

a taxpayer that pays so much in tax dollars, I think we 

should have a say in how our tax dollars are spent. I do 

not have children, nor do I qualify for food stamps, 

medical or other welfare programs. I personally, in my 

lifetime, have met at least ten people that deliberately 

do not work more than a certain number of hours a week, 

so that they are able to still qualify for Medicaid and 

food stamps. And it is people like that that my hardearned tax dollars are benefiting. While they are fully 

capable of working more, they choose not to because they 

don't want to lose the benefits of the hard-working

people's tax dollars are paying for. Thank you. 

MR. FRANCZAK: Thank you, Tyler. 

Brady, who do we have next?

MR. ROBERTS: Alright. Joann dropped 
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off to work on her audio issues. So, we are going to 

admit Derrick Johnson, who is the president and CEO of 

the NAACP. 

MR. JOHNSON: Hello, everyone. 

MR. FRANCZAK: Hi, Derrick. You have 

up to three minutes. Please begin. 

MR. JOHNSON: Sure. For over a 

decade, NAACP, particularly our youth and college 

division, has fought for economic liberation through the 

cancellation of student debt. Make no mistake, this is a 

racial justice issue. Black borrowers consistently 

struggle with loan repayments, and over 50% of Black 

borrowers likely- are likely to default as a result of 

the payment resumption last fall. This burden weighs 

particularly heavily on Black women, who are one of the 

most educated and debt-burdened groups in this country. 

While we appreciate all that this administration has done 

to move the needle, the gravity of this issue warrants 

immediate substantive relief that is not possible without 

a clear definition of hardship. Let's be clear. Taking 

out student loans is the hardship. Students do not 

aspire to enter their early 20s with deliberating debt. 

They aspire to uplift themselves, their families, and 

their communities, and have been taught that education is 

the best path towards economic stability and upward 
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mobility. These students have been promised an American 

dream, and those unable to afford- to be afforded the 

education that will open doorways for them are encouraged 

to take out- take on debt with the promise of a future 

where that debt can be repaid as they flourish in their 

careers. The reality is, for many, that dream has become 

a nightmare. Americans, particularly Black Americans, 

are saddled with debt, facing insurmountable obstacles 

and navigating a systemically racist job market while 

predatory lenders rack up interest fees, creating a 

perfect storm that for many is near impossible weatherto weather through. We must do better. The relief that 

we've seen, and the rules that have been proposed thus 

far are pivotal first steps. Despite this process, Black 

Americans, particularly young Black Americans who have 

been at the forefront of this fight, are being left 

behind. As you engage in this crucial additional 

session, I encourage the Department to approach the issue 

of hardship and the factors considered to define such 

hardship through a racial equity lens. A failure to 

consider the unique factors that disproportionately 

impact borrowers of color will be a failure of the duties 

that have been bestowed upon this administration through 

the promise made on the campaign trail. Black America 

has and will continue to show up for America from 
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fulfilling our civic duties to fueling the economy time 

and time again is at the forefront and we thank you for 

this opportunity.

MR. WEATHERS: 30 seconds remains. 

MR. FRANCZAK: Thank you. Brady, 

who's next?

MR. ROBERTS: Hey, I re-admitted 

Joann. I think her audio issues should be solved. 

MR. FRANCZAK: Okay. 

MS. MERCEDES: Can you hear me? 

MR. FRANCZAK: Joann? Yes. You have 

up to three minutes. Please begin. 

MS. MERCEDES: Thank you. Thank you 

to the Department and the negotiators for dedicating 

their time to improve the student loan system. My hope 

is new ways to discharge these loans are found in order 

to release borrowers from this death sentence. Defaulted 

and chapter 13 borrowers were left out from all the 

waivers and no mentions of forgiveness. Borrowers that 

were most in need currently or at a period of the student 

loan history. With the waivers, actual no payments or 

new loans with no payments at all if consolidated with O1s were forgiven where those with default or chapter 13 

history with actual high payments were left behind. Real 

money sent to our loans not being acknowledged in my 
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personal case after a life event, I defaulted in 2017 and 

my taxes were garnished a total of over $8,000, which was 

comparable to my Income Based Repayment Plan at the time. 

I hope those defaulted payments were accounted, or at 

least [inaudible] on rehabilitation forbearance, which 

were over $500 a month for ten months. The reason why we 

have [inaudible] forbearance payments are not counted is 

beyond my comprehension, since this loan is in good 

faith, being rehabilitated and should not have a default 

status in the history. You can help many, many of us 

right now by counting our payments that were processed 

via default or chapter 13 in our IDR or PSLF journey. It 

is unacceptable that is not counting for us that have 

struggled with the student loan system for a long time. 

Due to this status existing in our loans, we can't even 

use the time to buy back these periods. It feels like a 

punishment. Please don't leave us behind. Many 

deserving people that due to temporary financial crisis, 

can get their loans discharged despite having the time of 

IDR or working in public service. Fresh Start is not the 

answer for us because it's not counting the time that has 

passed or that we paid. Before implementing new 

solutions, please help us with the [inaudible 02:48:43] 

forgiveness programs that are still plagued by many 

issues and can be the answer for many of us. That can 
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potentially help many of the borrowers experiencing 

hardship today and in the past. Thank you. 

MR. FRANCZAK: Thank you. Next, 

Brady. 

MR. ROBERTS: Alright, I just 

admitted Peter Granville, who is here representing the 

Century Foundation. 

MR. FRANCZAK: Alright. Peter, can 

you hear me? Great. You have up to three minutes. 

Please begin. 

MR. GRANVILLE: Thank you. Good 

afternoon. My name is Peter Granville. I'm a fellow at 

the Century Foundation. During public comments in July, 

I urged the Department to include Parent PLUS Loan 

borrowers in student debt relief. Today, I applaud the 

Department for crafting regulatory text that has the 

potential to deliver much needed debt relief to Parent 

PLUS borrowers on the basis of hardship. Nearly four

million borrowers and their families carry Parent Plus 

loans, which have proven to be especially difficult for 

families with low income and wealth, to repay, and which 

can exacerbate the racial wealth disparities. Due to 

restrictions on Parent PLUS borrowers IDR eligibility, 

debt relief through Department action is likely their 

best chance to get out from under unmanageable debt that 
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they may have carried for decades. The categories of 

hardship identified in part B capture many dimensions of 

the financial challenges facing Parent PLUS borrowers. 

I'd like to use my time to highlight a few groups of 

Parent PLUS borrowers, who may be especially likely to 

qualify for relief if this text were put into regulation. 

The first group is parents who carry both Parent PLUS 

debt for a child's education, plus loans for their own 

education. By my estimates, 1 in 6 parent borrowers 

carry this unique cross-generational burden. Survey data 

from the Federal Reserve suggests these borrowers with 

Parent loans and their own education loans have less 

savings, are more likely to receive public benefits, are 

more likely to carry unpaid credit card debt, and are 

more likely to report being behind on student loan 

payments versus comparison groups. A substantial number 

of these borrowers would likely qualify under the 

hardship provisions. The next group I want to highlight 

is Parent PLUS borrowers whose loan supported enrollment 

at an HBCU. Due to more than a century of chronic 

underfunding, HBCUs lack the ability of predominantly 

white peer institutions to close affordability gaps 

through institutional aid that leads to a high 

concentration of Parent PLUS loan debt among HBCU 

families. This debt can prove unmanageable, as HBCUs 
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Negotiated Rulemaking – 2/22/24

comprise many of the institutions with the highest Parent 

PLUS default rates. Under the Department's plan, and 

outsized number of Parent PLUS borrowers whose loans 

supported an HBCU education would likely qualify for 

hardship-based relief. Finally, relief based on hardship 

may reduce the incidence of older Parent PLUS borrowers 

seeing their Social Security payments withheld due to 

student loan default. According to the GIO, 40,000 

disabled or retired Parent PLUS borrowers saw portions of 

their Social Security benefits withheld from them in 2015 

due to student loan default, which can plunge a person 

below the poverty line. The undeniable and lasting 

hardship experienced by these borrowers would likely meet 

the standard for loans whose cost of collection exceed 

the value of keeping that debt on the books. While more 

information would be needed to make projections of Parent 

PLUS borrowers’ relief under this plan, I am encouraged 

by the text released by the Department, and I thank the 

Department and negotiators for their work. 

MR. FRANCZAK: Thank you. 

MR. GRANVILLE: That's all for me. 

Thank you. 

MR. FRANCZAK: Brady, next?

MR. ROBERTS: Alright. I just 

admitted Lisa Harle, who's here representing herself. 
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Negotiated Rulemaking – 2/22/24

MR. FRANCZAK: Lisa, can you hear me?

MR. ROBERTS: But she isMR. FRANCZAK: She's listed under 

River Run Condo? 

MR. ROBERTS: She is, yes. 

MR. FRANCZAK: Okay. Lisa, can you 

hear me now?

MS. HARLE: Yes, I can. 

MR. FRANCZAK: Okay, great. You have 

up to three minutes. Please begin. 

MS. HARLE: Okay, so my name is Lisa 

Harle, and I represent students that filed a BTR 

application against Kaplan University. I want to thank 

everyone for canceling debt for students due to financial 

hardship. This will definitely help many, many students. 

I am, however, very disappointed in the Department has 

yet to cancel debt for students who attended Kaplan 

University, now known as Purdue Global. As for the 

Kaplan students, we do not have much time. I am 

requesting that the DOE please cancel student debt for 

Kaplan students. It was accomplished for Corinthian 

College and ITT, and our time is running out. And that's 

basically what I have to say. I wanted to thank you, 

though, for the- for really the canceling of debt for 

people with financial hardship. I think that's a move in 
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the right direction. 

MR. FRANCZAK: Is that the end of 

your public commentary, Lisa?

MS. HARLE: Yes, it is. 

MR. FRANCZAK: Alright, thank you. 

Appreciate it. 

MS. HARLE: Thank you. 

MR. FRANCZAK: Okay. Brady, who's 

next?

MR. ROBERTS: Alright. Next, we have 

Bob Carey, who's here on behalf of the National Defense 

Committee. 

MR. FRANCZAK: Alright, Bob. 

MR. CAREY: Thank you very much. I'm 

Bob Carey. The National Defense Committee started in 

2003, in order to advocate for the civil and legal rights 

of military and veterans. We've recently put together a 

report about the nature of military and veteran 

educational benefits, and what we basically consider to

be a war against veterans and military personnel to be 

able to use their earned educational benefits. And this 

seems to be another one of those examples. The fact of 

the matter is that this regulation is going to establish 

a very dangerous moral hazard. Everyone signed these 

loan agreements to which they knowingly agreed. And 
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these loan agreements are not based upon any promise of 

future income or future financial position except to 

allow for deferments and refinancing. Now, where there's 

been fraud or other criminal activities in that loan 

process, or in the educational process that makes that 

loan agreement broken, then yes, we agree there should be 

a loan discharge for a reasonable position, but this 

regulation gives every loan holder every incentive to go 

into greater debt, get into worse financial position, and 

to be in the greatest possible position for a default, 

because then they'll get their loan discharged. Now, 

from a military and veteran perspective, this looks like 

a pretty bad deal. The fact of the matter is I'm a 62-

year-old veteran. I had to sign on for an additional six 

years in order to be able to get the GI Bill benefits and 

that was part of the deal. I knew it, I made the deal. 

But now it looks to me that I was a sucker because I 

could have just gotten a loan and then got it into 

deferred. This looks to be much more about how we make

higher education free than about how do we look at 

deferment or discharge of loans. The last question is we 

look at the military and veteran- the military recruiting 

crisis and retention crisis. And, you know, these 

veterans and these potential military personnel, they're 

rational. They know whether something is a good deal or 
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not. And the problem is, is that with this regulation 

that, you know, that military service is no longer a good 

deal. Now, look, if Congress wants to make higher 

education free, then they need to pass a law to do it. 

But as one of your participants today talked about, I 

don't see where Congress has given the Department this 

grand expansive of legislative authority in order to be 

able to essentially forgive each and every loan as a 

matter of policy. And I think that is a really bad moral 

hazard that we are setting up for our student financial 

market. This is how banks fail. And I think we're 

setting ourselves up. 

MR. WEATHERS: 30 seconds remains. 

MR. CAREY: I'm good. Thank you very 

much. Appreciate your time. 

MR. FRANCZAK: Thank you. Next, 

Brady?

MR. ROBERTS: Alright. I just 

admitted Dorien Rogers, who's here representing himself. 

MR. FRANCZAK: Alright, Dorien, can 

you hear me? Dorian?

MR. ROBERTS: He's in the room but he 

hasn't enabled audio quite yet. And he's our last 

scheduled speaker, so I want to give him [inaudible]. 

MR. FRANCZAK: Okay. John Burke, who 
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is in the waiting room, he had already spoke, did he not?

MR. ROBERTS: He had some audio 

issues, and so he left about 45 seconds into his comment. 

So, I was going to admit him again to see if his audio 

issues had resolved. 

MR. ROBERTS: Okay. While I work 

with Dorien, do you want me to admit, John?

MR. FRANCZAK: Sure. 

MR. ROBERTS: Okay. Just as a 

reminder, this is John Burkey, speaking on behalf of John 

Berkey Capital LLC. 

MR. FRANCZAK: John, can you hear me?

MR. ROBERTS: [inaudible] There we 

go. 

MR. FRANCZAK: How about now? John, 

can you hear me?

MR. ROGERS: Yes, I can hear you. 

MR. FRANCZAK: Alright. Yes. You 

have up to three minutes. Please begin. 

MR. BURKEY: Hello. My name is John 

Burkey. I'm with Burkey Capital. The subject of my 

comments would include - let me turn off myMR. FRANCZAK: Yeah, the public feed. 

MR. BURKEY: The subject of my 

comments would include the cohort of all student loan 
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debtors. The proposed solution will be at no cost to 

taxpayers. It would have the opportunity to fix many of 

the hardship conditions right now. And additionally, for 

students that are in school it would provide an 

opportunity for them to resolve their student loans when 

they graduate. As we know, a significant consequence of 

student loan debt has been the delay in home ownership 

and the opportunity for wealth creation via home 

ownership. The problem is often the burden of paying 

down or paying off student debt. And how that impairs 

saving for a down payment. The delays result in an 

endless treadmill of never getting ahead, raising rents, 

rising home prices and then compounding the issue, albeit 

temporary rising interest rates. Accordingly, an 

impending structural paradigm shift to mortgage lending 

may provide an opportunity to enable home ownership. 

More specifically, traditional mortgage lenders are 

usually limited to 99 to 100% the house as collateral. 

However, considering advances of data processing 

technology, behavioral credit analysis, etc. together 

with the average growth rate in the price, the value of 

homes of about four-point three percent that there is an 

opportunity to comb pine student loan payments with the 

purchase of a home. Given that historical growth of 

four, three precent four-point three percent in the 
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period as short as five years, a student loan borrower 

could basically be out of debt. The value of their home 

would exceed the price of their mortgage and effectively, 

they're out of student loan debt, didn't cost the 

taxpayers a dime. It was fair to the student and had 

equity for the student, had equity for the taxpayers, 

especially the ones that didn't go to college or those 

that did and were able to pay off their student loans. 

The bottom line is the mortgage industry would ask the 

Department to do one thing. The reality is student debt 

is already on the table. They've already wrote the 

check. The money's already there. So, when a lender-

[30 seconds] pays off the loan, the Department would 

agree that during this five-year period or the next five 

years, if the student defaulted to the point it became a 

foreclosure, and there's a little bit of legalese. But 

basically, if the house ever foreclosed and had to be 

sold, if there was a what's called deficiency balance or 

meaning the mortgage balance was greater than the house 

value, the student loan would be reinstated up to its 

original amount. So, if somebody bought a houseMR. FRANCZAK: John, that's the end 

of the three-minute time period. 

MR. BURKEY: -dollars was paid off in 

student debt-
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MR. FRANCZAK: John. 

MR. BURKEY: -for some reason, that 

house foreclosedMR. FRANCZAK: I'm sorry, John. That 

was the end of the three-minute period. So, we have our 

last speaker. I believe it's Dorien Rogers. Dorien, can 

you hear me?

MR. ROGERS: Yes, I can. How's 

everybody doing?

MR. FRANCZAK: Yep. Dorien, you have 

up to three minutes. Please begin. 

MR. ROGERS: Absolutely. Thank you. 

Greetings, everybody. I hope all is well with everyone. 

My name is Dorien Rogers, resident of Clarksburg, 

Maryland. And as a student, as a borrower, as a teacher, 

as a Door Dash delivery driver, and most importantly, as 

an American, education has been a bridge that has 

interconnected me to the intersections of the American 

Dream. However, with over $50,000 in student debt 

undergraduate and graduate, the American Dream feels more

like the American nightmare. This comes as the job that 

I possess barely enables me to sustain my finances, the 

very finances I wish to use to purchase a home, start a 

family, take care of my parents who have proudly served 

this country in uniform alongside their endless sacrifice 
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for me and my brother, and my ambitions to run for public 

office to serve the people as well. Are my parents 

worthy of relief from me as the supported child to put 

through school, through their Parent PLUS loans through 

undergraduate? Am I worthy as a student going through 

student loan forgiveness as I advance my degree within my 

master's program? Though I recognize we all have to work 

hard for our journey to uplift a better America, I find 

contradictions in having to work so hard to truly utilize 

the true power of education, when this life investment 

has become a life sentence. This comes as I struggle to 

even put gas in my car, knowing if I do not make it 

through the end of the week from my night's Door Dashing, 

that I may not be able to put money in my pocket for the 

week. This comes as I pay out through the week as a 

whole. This comes as I pay out of my pocket to ensure I 

can reward my students as I am an educator, so that I can 

continue to embrace and uplift as they continue to shine 

their light in their schools through their academics, 

their civic engagement, and most importantly, in their 

leadership to make this nation better through their 

involvement in leadership as middle schoolers, the very 

education that has driven this nation to make the 

impossible possible when obstacles and crises have tested 

our very humanity, which is the $1.7 trillion crisis on 
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student debt. Thank you. 

MR. FRANCZAK: Thank you. Alright. 

That was our last speaker during the public commentary. 

Before we would break for today, I wanted to check in and 

see if we have any wrap-up for today or preparation 

comments for tomorrow. Scott, you have your hand raised. 

Go ahead. 

MR. BUCHANAN: Well, yeah, I guess 

for tomorrow, then, is the Department planning to provide 

revised text based upon feedback today and suggestions 

that others had or what's sort of the process you 

envision going forward is- since as you've highlighted, 

we only have one more day here of discussion?

MS. ABERNATHY: Thank you, Scott. We 

will be looking at the suggestions that the negotiatorsthat the nonfederal negotiators have made to us today and 

put in the chats, and we will be circulating and 

discussing those changes that we are able to consider, 

and we will be presenting amendatory- an amended proposed 

regulatory text to the negotiators as soon as we're able 

to either get it to you guys sometime this evening or 

first thing in the morning. 

MR. FRANCZAK: And we begin at 10:00 

a. m. Eastern Standard tomorrow for our official second 

day of session four. 
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MR. FRANCZAK: Brady, Cindy, John, 

any other wrap-up facilitation wise? Okay. And Tamy, 

anything final otherwise from the Department?

MS. ABERNATHY: I would simply like 

to thank everybody, on behalf of the Department for all 

of the formative conversation, suggestions, support 

and/or discussion not in support of this proposed rule. 

It certainly is our privilege to work with you and work 

alongside you. We look forward to our last day tomorrow 

and finalizing the negotiations on student debt relief. 

So, thank you again and have a good evening. 

MR. FRANCZAK: Thank you, Tamy. 

Thank you to the Department. On behalf of the FMCS 

Facilitation Team, thank you today for all your efforts. 

We look forward to rejoining you tomorrow for the 

conclusion of session four. Thank you. 
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Zoom Chat Transcript 

Student Loan Debt Relief Committee - Session 4, Day 1, Afternoon, February 22, 2024

*Chat was copied as presented, as a result minor typos or grammatical errors may be present.

From P - Lane Thompson, state officials to Everyone:

+1 to including current students in potential default analysis

From A-Richard Haase (Graduate Borrowers) to Everyone:

Definitely recognize the value and importance of allowing for application based forgiveness, 

but also agree that the more that can be automated, the better.

From P- Jessica Ranucci (Consumer Advocates) to Everyone:

Reacted to "Definitely recognize..." with ���

From P - Lane Thompson, state officials to Everyone:

Reacted to "Definitely recognize..." with ���

From A- Susan Teerink 4 year - Private Not for Profit Colleges to Everyone:

Reacted to "Definitely recognize..." with ���

From Sarah Butts, P-4-year Borrowers to Everyone:

Reacted to "Definitely recognize..." with ���

From John S. Whitelaw, (he/him) (CLASI) P-Students with Disabilities to Everyone:

Suggested language

In exercising its authority to grant forgiveness under section 30.91, the Department will endeavor 

to provide relief to eligible borrowers automatically without the need for an application and may 

explore data sharing agreements with other governmental agencies where the Department 

determines that such data sharing is reasonable and will assist the Department is determining 

eligibility

From P-Melissa Kunes-Public 2&4 Yr to Everyone:

In exercising the authority described in paragraph (a) of this section, the Secretary may will 

rely on data in the Secretary’s possession and data which the Secretary can or will obtain or 

acquired through an application to provide relief based on criteria demonstrating the conditions 

described in paragraph (a).
107

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From P-Melissa Kunes-Public 2&4 Yr to Everyone:

Sorry that did not translate well, try again:

From A-Richard Haase (Graduate Borrowers) to Everyone:

+1 again on including Parent Plus borrowers whose dependents received Pell Grants

From P-Melissa Kunes-Public 2&4 Yr to Everyone:

In exercising the authority described in paragraph (a) of this section, the Secretary may will 

rely on data in the Secretary’s possession and data which the Secretary can or will obtain or 

acquired through an application to provide relief based on criteria demonstrating the conditions 

described in paragraph (a).

From (P)-Angelika Williams: Private, Nonprofit Institutions to Everyone:

In paragraph b, could we include explicit language mentioning "Natural Disasters," 

especially considering the numerous victims of wildfires in California who have faced significant 

losses, ensuring that hardship resulting from such events is duly acknowledged?

From P- Jessica Ranucci (Consumer Advocates) to Everyone:

(d) Process for additional relief. In exercising the authority described in paragraph (a) of this 

section, the Secretary may rely on data in the Secretary’s possession to provide relief without an 

application from the borrower or may rely on information acquired through an application, or 

both, to provide relief based on criteria demonstrating the conditions described in paragraph (a).

From Sarah Butts, P-4-year Borrowers to Everyone:

+1 on Jalil's comments, re: expanding the way the Department considers Pell borrowers. 

We should also consider borrowers with Parent Plus loans who were themselves Pell grant 

recipients.

From P- Jalil Mustaffa Bishop - Graduate Student Borrower to Everyone:

Reacted to "+1 on Jalil's commen..." with ���

From A-Richard Haase (Graduate Borrowers) to Everyone:

Reacted to "+1 on Jalil's commen..." with ���

From Sarah Butts, P-4-year Borrowers to Everyone:

+1 on Lane's comments regarding qualitive data and accounting for multiple hardship 

factors of a borrower and/or their parent borrowers/family.
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From A-Richard Haase (Graduate Borrowers) to Everyone:

Stepping in for grad borrowers

From Sarah Butts, P-4-year Borrowers to Everyone:

*correction to my comment above. I meant to type qualitative

From P - Lane Thompson, state officials to Everyone:

+1 to Richard on servicer error - complaint data from ED, CFPB, states, can be used to show 

where there is larger groups of borrowers whose loan records may be incomplete or incorrect

From A-Richard Haase (Graduate Borrowers) to Everyone:

Jalil back in as primary for graduate borrowers

From A-Richard Haase (Graduate Borrowers) to Everyone:

Reacted to "+1 to Richard on ser..." with ���

From P- Jalil Mustaffa Bishop - Graduate Student Borrower to Everyone:

I would encourage the Dept to assess a borrower’s hardship, without factoring in their 

enrollment in SAVE. In other words, the future default-predictive-model should predict likelihood of 

default without considering SAVE factors (e.g. monthly payment, interest cap, 20-25 yr cancellation 

clause). 

Predict default based on borrowers’ hardship factors only and not based on existing relief policies 

like SAVE, fresh start, ICR, etc.

From P- Jalil Mustaffa Bishop - Graduate Student Borrower to Everyone:

Reacted to "Amendments to Subsection (b) – Consideration of Hardship Factors for Waiving 

Federal Student Loans.docx" with ���

From P-Yael Shavit-State AGs to Everyone:

+1 to the critical need to be focused on ensuring equity and preventing bias in the 

development of predictive models

From P- Jessica Ranucci (Consumer Advocates) to Everyone:

+1, agree with Jalil and Yael

From A-Richard Haase (Graduate Borrowers) to Everyone:
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Negotiated Rulemaking – 2/22/24

Reacted to "+1 to the critical n..." with ���

From P-Carol Peterson-HBCU to Everyone:

+1 agree with Jalil and Yael

From Edward Boltz to Everyone:

+1 to Dawn for Bankruptcy as hardship factor

From Ashley Pizzuti - P - 2YR Borrowers to Everyone:

Reacted to "+1 to Dawn for Bankr..." with ���

From P - Lane Thompson, state officials to Everyone:

+1 to using current or previous incarceration as a hardship factor

From Sarah Butts, P-4-year Borrowers to Everyone:

Reacted to "+1 to using current ..." with ���

From Edward Boltz to Everyone:

Reacted to "+1 to using current ..." with ���

From P - Lane Thompson, state officials to Everyone:

Reacted to "+1 to Dawn for Bankr..." with ���

From John S. Whitelaw, (he/him) (CLASI) P-Students with Disabilities to Everyone:

These public comments are devastating and compellingly demonstrate the need for action 

on hardship

From A- Susan Teerink 4 year - Private Not for Profit Colleges to Everyone:

Reacted to "These public comment..." with ���

From Sarah Butts, P-4-year Borrowers to Everyone:

Replying to "These public comment..."

Yes, very much so.

From Ashley Pizzuti - P - 2YR Borrowers to Everyone:

Yes
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Negotiated Rulemaking – 2/22/24

From A-Richard Haase (Graduate Borrowers) to Everyone:

Replying to "These public comment..."

It’s amazing how every story is tragic in its own unique way, and yet, they’re all too similar to each 

other

From Sarah Butts, P-4-year Borrowers to Everyone:

Replying to "These public comment..."

���

From Ashley Pizzuti - P - 2YR Borrowers to Everyone:

Yes, schools that have a bad track record shouldn’t have to have borrowers jump through 

hoops to prove they were misled

From A-Richard Haase (Graduate Borrowers) to Everyone:

+1 to creating a more fair and equitable society where education is available to all

From Sarah Butts, P-4-year Borrowers to Everyone:

Reacted to "+1 to creating a mor..." with ���

From Edward Boltz to Everyone:

Reacted to "It’s amazing how eve..." with ���

From Sarah Butts, P-4-year Borrowers to Everyone:

+1 on public service workers experiencing hardship, including essential frontline healthcare 

workers.

From John S. Whitelaw, (he/him) (CLASI) P-Students with Disabilities to Everyone:

My apologies but I have to drop for another obligation. See you all tomorrow.

(ED Note: Documents shares in chat are available on the Department of Education’s 2023-2024 Neg 

Reg website)