Negotiated Rulemaking – 2/23/24

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 DEPARTMENT OF EDUCATION

OFFICE OF POSTSECONDARY EDUCATION

NEGOTIATED RULEMAKING 

STUDENT DEBT RELIEF COMMITTEE

SESSION 4, DAY 2, MORNING

FEBRUARY 23, 2024

On the 23rd day of February, 2024, the

following meeting was held virtually, from 10:00 a.m.

to 12:00 p.m.
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P R O C E E D I N G S

MR. ROBERTS: Good morning, everyone, 

and welcome to this final day of session four and of the 

Student Debt Relief negotiated rulemaking process hosted 

by the Department. My name is Brady Roberts with the 

Federal Mediation and Conciliation Service. And I'd like 

to kick us off with a quick roll call. So representing 

civil rights organizations, we are joined by Wisdom Cole.

MR. COLE: Present.

MR. ROBERTS: Morning, Wisdom. His 

alternate India Heckstall might be a few moments delayed 

in joining us, but she will be joining us. Representing 

currently enrolled borrowers, we have Jordan Nellums.

MR. NELLUMS: Good morning. Here.

MR. ROBERTS: Morning, Jordan. 

Representing FFEL lenders, servicers, and or guaranty 

agencies, we are joined by Scott Buchanan.

MR. BUCHANAN: Good morning.

MR. ROBERTS: Good morning. 

Representing historically Black colleges and 

universities, tribal colleges and universities and 

minority serving institutions, we are joined by Carol 

Peterson.

MS. PETERSON: Morning.

MR. ROBERTS: Morning, Carol. 
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Representing legal assistance organizations for 

borrowers, we are joined by Scott Waterman.

MR. WATERMAN: Present.

MR. ROBERTS: Morning, Scott. 

Representing private, nonprofit institutions, we are 

joined by Angelika Williams.

MS. WILLIAMS: Good morning. I'm here.

MR. ROBERTS: Morning, Angelika. And 

we are joined by her alternate, Susan Teerink.

MS. TEERINK: I'm here. Thank you.

MR. ROBERTS: Morning. Representing 

proprietary institutions, we are joined by Kathleen 

Dwyer.

MS. DWYER: Good morning.

MR. ROBERTS: Good morning, Kathleen. 

And her alternate Belen Gonzalez. I haven't seen her join 

quite yet. Representing public institutions, both two and 

four year, we are joined by Dr. J.D. LaRock. I don't 

think Dr. LaRock has joined us yet either. But we'll let 

you know once they join us. Representing state attorneys 

general, we are joined by Yael Shavit.

MS. SHAVIT: Good morning.

MR. ROBERTS: Good morning. The 

alternate position for state attorneys general is still 

vacant. Representing state officials of higher education, 
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we are joined by Lane Thompson.

MS. THOMPSON: Hello.

MR. ROBERTS: Good morning, Lane. 

Representing student loan borrowers from institutions two 

year or less, we are joined by Ashley Pizzuti.

MS. PIZZUTI: Good morning.

MR. ROBERTS: Good morning, Ashley. 

Representing student loan borrowers of institutions of 

four years, we are joined by Sarah Christa Butts.

MS. BUTTS: Good morning.

MR. ROBERTS: Good morning. 

Representing student loan borrowers from graduate 

institutions, we are joined by Dr. Jalil Bishop.

DR. BISHOP: Good morning.

MR. ROBERTS: Good morning. And 

Richard Haase.

MR. HAASE: Good morning.

MR. ROBERTS: Good morning, Richard. 

Representing veterans or veteran organizations, we are 

joined by Vincent Andrews. I believe he's also going to 

be a few moments delayed. So he's not joined us quite 

yet. We'll let you know when he has. Representing student 

or sorry consumer advocacy organizations, we are joined 

by Jessica Ranucci.

MS. RANUCCI: Good morning.
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MR. ROBERTS: Morning, Jessica. And 

her alternate Ed Boltz.

MR. BOLTZ: Good morning.

MR. ROBERTS: Of our nonfederal 

negotiators, we are lastly, joined by individuals with 

disabilities or organizations representing them, Mr. John 

Whitelaw.

MR. WHITELAW: Good morning.

MR. ROBERTS: Morning, John. From the 

Federal side of things, we are joined by our Chief 

Federal Negotiator, Tamy Abernathy.

MS. ABERNATHY: Good morning.

MR. ROBERTS: Go ahead, Cindy.

MS. JEFFRIES: Brady. I think we 

inadvertently missed Melissa Kunes.

MR. ROBERTS: Oh, I apologize. Sorry. 

Melissa.

MS. JEFFRIES: Thank you.

MR. ROBERTS: Got too excited to dive 

into the regulatory text. But also joining us from the

Department, the Office of General Counsel, we are also 

joined by Soren Lagaard.

MR. LAGAARD: Good morning.

MR. ROBERTS: Good morning, everyone. 

Was there anyone else that I inadvertently skipped? And 
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apologies for that, Melissa.

MR. ROBERTS: Okay. Any old business 

to attend to before we dive into the business of the day? 

Not seeing any hands. Did everyone receive a copy of the 

updated regulatory text last night? Is anyone missing it? 

Alright. Unless there's something else to attend to. 

Tamy, I would turn it over to you and your team to walk 

the committee through the modifications made following 

session one yesterday.

MS. ABERNATHY: Thank you, Brady. 

Welcome back everyone and Happy Friday. As a reminder, 

this is the final negotiated rulemaking session on 

Student Debt Relief. We provided regulatory text. Excuse 

me. We provided revised regulatory text for your 

consideration last evening, and we plan to have the final 

consensus vote on the proposed regulations later today. 

Thank you all so much for the contributions to 

yesterday's productive discussion and your feedback on 

this proposed regulatory text. We appreciate all the 

comments, suggestions, and submitted proposals that we 

received, and we have reviewed and considered each one 

very carefully. Let us walk through those proposed 

changes now and as we go through them, I want to note 

that we are only showing you changes we think are 

appropriate for the regulatory text. There are several 
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other items brought up that we agree with, but we think 

that are not necessary for the actual text, but they 

would be captured in our preamble. And I believe the 

screen sharers are already sharing that amended proposed 

regulatory text. First, we agree with the suggestion to 

change the title of the regulation to refer to waiver 

rather than forgiveness in order to make it consistent 

with the other provisions and subpart (g). We have made 

this change. For paragraph (a), we received a suggestion 

to add language that the provision applies whether or not 

such loan has been reduced to judgment. We appreciate the 

suggestion. However, we do not believe this needs to go 

into the regulatory text, but we will work to include as 

many loans as possible under this provision. For 

paragraph (b), we received several suggestions. First, we 

received the suggestion to be more explicit that the 

provision also applies to parent borrowers, and for 

parent borrowers, the indicators of hardship may be 

related to the parent borrower or the student on whose 

behalf the parent borrowed. As a reminder, this language 

is added to part 30, subpart (g). There are no 

restrictions within that section related to the type of 

loan, which is unlike the regulations related to the 

Income Driven Repayment Plan regulations. So we will 

clarify in the preamble of our negotiated notice of 
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proposed rulemaking that this language also applies to 

Parent PLUS Loans, but we do not feel the need to include 

this in the regulatory text. We also received a 

suggestion to add more factors in paragraph B, such as 

bankruptcy status. We have not made this change because 

the bankruptcy process has certain rules and 

requirements, and we do not think it is appropriate to 

address those through this regulation. We also received 

suggestions about adding service or errors to the factors 

showing hardship. We do not think this change is 

appropriate to make here. As we noted, the Department 

takes action in multiple ways when we discover servicer 

errors. In widespread cases, we provide automatic 

corrections to many borrowers, such as the account 

adjustment or when we place some borrowers into 

forbearance in the first months of the return to 

repayment. We also have processes for individual 

correction of errors, which may be handled through our 

ombudsman's office. We think it is critical that errors 

be caught and identified. However, that is different from 

the other situations we are identifying here that are 

signs of hardship. There were also several suggestions. 

Excuse me. There were also several questions and 

suggestions to add more specificity to how we were using 

certain terms. Overall for the factors in paragraph (b), 
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we do not want to get too specific in the delineation of 

certain terms, because these factors are just examples, 

part of a non-exhaustive list, and the Department wants 

to retain the flexibility to consider these factors 

broadly. For example, the Department does not think it 

appropriate to further define what we mean by household 

in the regulations, because we can describe this in the 

preamble and want to retain breadth and flexibility. The 

same is true for disability. The Department thinks it is 

better to keep the factor broad to maintain flexibility. 

We also received the suggestion to consider high-cost 

burdens such as housing. We would like to point out that 

factor 15 does consider high-cost burdens for essential 

expenses, including housing. As for the suggestion to 

take into account regional housing cost variations, 

nothing precludes the Department from considering housing 

costs based on regional areas. And as before, we think 

it's better to keep the factor broad to maintain 

flexibility. Moving on to factor six. Based on your 

feedback, we removed the term consumer to make it less 

limiting and preserve the Secretary's discretion to 

consider different types of total debt balances. Fear 

factor seven, we received a question with regard to its 

reference to the FAFSA and what we intend to include. We 

have not changed the text but want to clarify our 
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interpretation that this would include information 

submitted by the borrower and their family at the time 

the loan was made. For instance, we can learn things on 

the FAFSA, such as whether a student's parents attended 

college or if they were homeless or foster youth. For 

factor eight, we have changed the term sector to type 

based on your feedback. Factor nine, we've taken the 

suggestion to change the language, so it is clear that 

the Secretary can consider typical student outcomes 

associated with any program or programs attended, rather 

than the last one attended. We agree with making this 

language more flexible and broader. We also received the 

suggestion to add a number of factors such as natural 

disasters, loss of a caregiver, racial and economic 

disparities, historical debt patterns, and Parent PLUS 

borrowers, among other factors. We have not added those 

factors at this time. We think other factors would help 

to capture these borrowers who are experiencing hardship, 

and factor 17 already permits the Secretary to identify 

other indicators of hardship where appropriate. Turning 

to paragraph (c), the Department has accepted the 

suggestion to change the word discharge to wave in 

accordance with the Secretary's authority and other 

provisions in subpart (g). The Department thanks the 

Committee for this feedback. We also received 
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recommendations to remove the Secretary's discretion to 

waive all or part of debt and to change the threshold 

from 80% to a standard of more likely than not. The 

Department has not taken those suggestions at this time, 

but we appreciate the input we received. We want to point 

out one more thing from the end of paragraph (c), the 

version we sent out last night inadvertently excluded the 

final clause of that paragraph. What we shared before 

this session was that this would apply to borrowers 

likely to be in default in the next two years after the 

effective date of this regulation. We are proposing to 

change this from effective date of this regulation to 

publication date. We wanted this change because it helps 

us with the construction of our model. We do not think 

this would appreciably affect the number of discharges. 

Moving to paragraph (d), the Department has added the 

term including automated relief, to clarify the type of 

relief that the Secretary may provide under this 

paragraph. The Department has not taken the other 

suggestions, but we want to restate that the Department 

also likes automatic processes and interagency matches, 

and the Department is committed to pursuing automated 

relief where it makes sense. And the Department can 

specify this in the preamble. We are proud of our work on 

the matches for total Permanent Disability Match and for 
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PSLF. However, we do not think inter-agency data-sharing 

agreements should be written into the regulatory text 

since we cannot regulate other agencies and the provision 

already specifies the Secretary may use data in his 

possession, which could include data obtained through 

such agreements, and as such, future agreements could be 

accomplished without needing to include them in the 

regulation. We also received a request to provide an 

example of a borrower who would receive benefit under 

this proposed regulation and a borrower who would not. We 

think the proposed text sufficiently provides specificity 

about how the Secretary would exercise his discretionary 

authority. We do not think hypothetical examples are 

helpful, because the Secretary's discretionary 

determination would depend on all of the particular facts 

of a situation, which may include the factors described 

and that we have discussed in paragraph (b). We're going 

to turn it back over to FMCS for any questions or 

additional discussion at this time.

MR. ROBERTS: Alright. Thank you, 

Tamy. I did see one question in the chat. Jessica, did 

you want to come off mute and just speak about that?

MS. RANUCCI: I just wanted to point 

out to the Department, unless I'm missing something, I 

think the version of (c) that you showed on the screen 
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with the brackets is not the same one that was emailed to 

us last night. So I doubt that's what you want but I just 

wanted to clarify that there are now three versions, I 

think the original one that you emailed, the one you 

emailed last night, and then the one you showed on 

screen.

MS. ABERNATHY: Right. You're talking 

about the addition of the publication date. Yes, I did 

address that in the remarks that we did send you a 

version last evening that was- and also posted that 

inadvertently left out that clause. So that's why you 

got- we did it on screen so that we could address it with 

you guys this morning.

MS. RANUCCI: Okay. Got it. I just 

thought you were talking about the first one. Anyway. 

There's three. As long as we got it that's fine. Thanks.

MS. ABERNATHY: Sorry for the 

confusion. Thanks for clarifying.

MR. ROBERTS: Thank you. Any other 

questions? Comments? Yeah. Richard, please.

MR. HAASE: Hi. Good morning, 

everyone. First I just want to start by thanking the 

Department and also, you know, recognizing the commitment 

of the Biden-Harris Administration. And really, I think 

tackling this work, I know, I feel like it's been an 
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interesting experience. I've learned a lot. I think 

looking at the proposed regulations that you guys brought 

to the table, based on our recommendations from November 

and December the work we've done around hardship, I 

think, really has the potential to help a lot of people. 

And I just want to applaud the effort at doing that. I 

think all too often there are branches of Government that 

fail to help people when they truly need it. And I think 

that this is work that really has the potential to help a 

lot of people. I do want to kind of bring that back to 

some of the testimony a little bit from yesterday and to 

a question or more of a request as you continue to do 

this work moving forward. One of the things that, you 

know, I found inescapable and common, you know, across 

all of the testimony that we've heard, not just 

yesterday, but moving forward was how tragic so many of 

the stories are that we've heard time and time again 

from, you know, borrowers across the age spectrum, across 

the economic spectrum who've tried to do everything 

right. And again, I'm really grateful that hopefully some 

of what we're doing here will actually be able to help 

them come out from under the crippling student debt that 

they've been dealt. But I think one of the things that 

came up and it's really apparent from a lot of the 

testimony, is how widespread servicer error is in 
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creating the hardship that they experience. Yesterday, a 

number of people who testified cited it directly, but 

even the ones who didn't, you know, when you hear someone 

who's 68 years old who owes four times or five times what 

they borrowed 30 or 40 years ago, it's almost impossible 

not to connect the dots. So I did hear you, Tamy, and I 

do recognize that there are programs in place and that 

there are efforts that are taken to try and address 

servicer error when it's identified. But I have to just 

again, as you move forward from these regulations, I 

can't- I really would be remiss if I didn't say, like, 

anything we can do to expand and improve those efforts 

would be really helpful because clearly, based on the 

testimony, there's a lot of error out there. And it is 

what's often in these cases, more than just a student 

loan in general, like someone borrows a small loan and 

they're paying it back. Those are the tragedies that we 

hear. I think the really compelling stories come from 

people whose loans have been mishandled and compounded in 

ways that make them impossible to climb out from under. 

So again, thank you so much, you know, to the Department, 

to everyone in this room to the Biden Administration for 

really trying to help people who need it. And I would 

just again, as my parting comment here really request 

that anything else we can do to expand our work into 
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tackling servicer error would be really critical. Thank 

you.

MR. ROBERTS: Thank you, Richard. 

There was a bit of a shuffle in the line, but we'll go to 

John next. I have his hand first.

MR. WHITELAW: I have some comments 

that I want to make about the automation later, but I 

just want to echo and make some broader points about 

servicer error. I think I want to take a step back. The 

whole point of hardship as a specific area, my 

understanding, is to capture those circumstances which 

are not captured by some other program or some other 

mechanism of providing waiver. So, for example, the area 

where I have the most knowledge disability. I think 

everyone understands that there is a TPD discharge for 

people who meet the requirements of that, but that 

doesn't necessarily capture people with disabilities who 

are experiencing significant hardship. The same with 

Income Based Repayment. Everyone here understands that we 

have an Income Based Repayment Plan, but my understanding 

of the whole point of having a hardship as a separate 

entity is for people who are suffering hardships that do 

not quite fit within any other mechanism for relief. And 

it seems to me that, notwithstanding the Department's 

best efforts, and notwithstanding everybody's good faith, 
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there are going to be cases where service error occurred. 

There is no remedy for that through looking at the 

service error, but that we would want that to be taken 

into consideration for hardship. And while I think there 

is a strong argument to be made that it could be covered 

in the catchall, which basically says and everything 

else, I do think it is important to include it as a 

specific category, to message to people that they should 

feel free when they are asking for a waiver based upon 

hardship to set out servicer errors that can have 

contributed to the hardship as we heard through the what 

I thought was devastating testimony of a public comment 

yesterday. In ways that, again, notwithstanding the 

Department's good faith to correct errors, not even 

withstanding the servicer's attempt to correct errors. We 

all know when you are working with millions of people and 

lots of agencies to use an overworn frame. Mistakes 

happen and not every mistake is correctable through the 

mistake correcting functions of both the servicers and 

the Department. So I do think that it would be important 

to have the message sent so that folks who are suffering 

hardship as a result of servicer errors know that that 

can be included in their ask for a waiver and that the 

Department may, again may, consider it. So I agree with 

the earlier comment that that is a specific example that 
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should be included. I also want to echo my gratitude for 

the Department for coming back to us this week to talk 

about hardship. Hardship is difficult. It's difficult to 

quantify. It's difficult to set out. And I do want to 

commend the Department for both coming back to us with it 

and for making the changes that were made overnight, even 

though, as always, I think from the advocate side and I 

suspect you all know this, it's never going to be enough. 

Right? We always want more. But I do really urge you to 

reconsider on naming hardship specifically and to add it 

and then I will comment a little bit later on the last 

part about automation. Thank you so much.

MR. ROBERTS: Thank you, John. Lane, 

we'll go to you next.

MS. THOMPSON: Yeah. I just wanted to 

talk about FFEL borrowers for a second. I know that folks 

with commercial FFEL Loans are able to consolidate those 

into a Direct Loan and then get some of the benefits. 

That doesn't always appear to be a sufficient process for 

everyone who has an FFEL Loan. So I wanted to just tell 

y'all a little story. One of my borrowers went to school 

undergraduate degree finished in the 90s and has been 

paying off her debt since then. So she has FFEL Loans 

that she thought would be canceled under the account 

adjustment. Well, going back through the servicing, some 
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of those servicers did not keep records. So when you go 

back, it looks like the first loan she ever had was a 

consolidation in 2010. Well, that's not true. She had 

loans before that, right? They just can't find the 

information on it. So I think that for her, that's a 

perfect example of where a servicer's error did actually 

cause the hardship that she's experiencing. The account 

adjustment should have taken care of that for her. And it 

didn't. People with FFEL Loans didn't decide to get those 

loans. And I just am hearing more and more from folks who 

are very exasperated that they need to take action in 

order to access benefits that are automated for other 

people. And I understand that's not within the 

Department’s control completely. And at the same time, 

these were Federal Loans when they were made. So I think 

it's really important that we don't forget about these 

borrowers and that we don't ignore them just because we 

don't have the same kind of control over those loans. 

Thank you.

MR. ROBERTS: Thank you, Lane. Yeah, 

Yael.

MS. SHAVIT: Thank you. First I want 

to amplify Lane's point here. I think this is a critical 

point. And the Department, as part of this process, 

should take note of places where there are information 
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gaps as a result of the conduct of past servicers or 

other actors that are not the borrowers themselves and 

ensure that borrowers aren't the ones left bearing the 

burden of that type of information gap. Where it exists, 

it's the servicer that caused it and the borrowers should 

get the benefit of the doubt. But that aside, you know, I 

do also, though, at this point it's been said a lot. I 

think it could be said more, I thank the Department for 

engaging in this process. I'm very enthusiastic about it. 

And I realize that it was a lot of work. The points I 

want to make now are kind of process points going 

forward. I think a lot of the question of how effective 

these regs may be will have to do with how accessible 

borrowers actually find the non-automated provisions or 

parts of these regulations going forward. And there is no 

way around the fact that from the Department's 

perspective, some of this may be complicated, but it 

really needs to be made as simple as humanly possible for 

the borrowers themselves. And that includes not only the 

actual forms to the extent they exist or, you know, are 

they online? Are they paper? How are they submitted? Like 

those types of minute pieces, but also what the 

Department will accept as a demonstration of hardship. 

You know, there were some conversations specifically 

about, you know, forms that doctors need to fill out 
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versus accepting letters from doctors themselves. I think 

that's one good example, but it's not comprehensive. I 

think to the extent that these are the provisions that 

are intended to capture people who are experiencing any, 

you know, many types of hardships who aren't captured by 

other debt relief provisions that exist. It needs to 

really be as broad as possible to allow borrowers who are 

facing some of the worst hardships, who may be the ones 

least able to marshal the specific types of papers that 

would be, you know the most predictable, let's say. It's 

going to be really difficult and I think the Department, 

I'm sure, is approaching this with sensitivity. But I do 

want to encourage the Department to, you know, consult 

with the appropriate communities and the appropriate 

actors who may have a lot of experience thinking about 

how, you know, certain communities may understand 

requests put in paper. I think the more preemptive 

outreach the Department, sorry, the more preemptive 

outreach the Department can do to get the input from 

various communities from a wide breadth of communities, 

the better, including, you know, disability advocates and 

the like, to make sure that the process is as effective 

as I think the regs are going to have the potential to 

be. So thank you.

MR. ROBERTS: Thank you. Jessica, see 
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your hand next.

MS. RANUCCI: Thanks. At a high level, 

I want to echo what others have said. I thank the 

Department for putting out this proposal, for taking our 

suggestions both before the session and in yesterday very 

seriously for taking a swing here to do waiver based on 

financial hardship. I also want to echo what my 

colleagues have said about servicer problems and also 

just to give a couple more examples of what Yael was just 

discussing. You know, in my job, we often see borrowers 

with significant obstacles to obtaining relief. You know, 

we work with, you know, for example, a borrower who's 

unhoused and living in a shelter, who doesn't have a 

stable address, who doesn't have access to the internet, 

is a difficult person to interact with, you know, to help 

get a discharge to which they might be entitled, for 

example, because they need a mailing address to contact 

their servicer. They need everything done on paper. I 

also have had an extensive series of conversations with 

the Department about helping monolingual Spanish 

speakers, for whom many available avenues of relief are 

essentially inaccessible, including all disabilityrelated information, because it's just not available in 

Spanish. Even though there are millions of Spanishspeaking student loan borrowers, not to mention all of 
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Puerto Rico. So I think that really thinking through the 

practical ways that this relief is addressed is really 

important. I'm not sure, Tamy, just from a facilitation 

point, if we're going to go provision by provision, is it 

okay to ask something about (a) now or do you want to 

hold off?

MR. ROBERTS: Tamy, you weigh in if 

you disagree, but I would say go ahead and pose the 

specific questions.

MS. RANUCCI: Thanks. I was heartened 

to hear your answer about judgments, but I just want to 

be very clear that I'm understanding you correctly. So I 

think what I understood you to be saying is that you 

didn't feel the need to include the language that 

specified that this would apply to student loan debt that 

has been reduced to judgment, because the Department's 

interpretation is that the language, as it stands, would 

extend to student loan debt that has been reduced to 

judgment. Again, understanding there may be other legal 

framework that also applies to those debts that have been 

reduced to judgment. Could you just clarify, if I'm 

understanding correctly, that the Department's position 

is that judgments would count here? And also, would you 

be willing to put something to that effect in the 

preamble?
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MS. ABERNATHY: Yes, we are- we don't 

believe we need to specify in the regulations, because 

there are a number of ways we want to be able to leave 

that broader for all of the ways that a borrower could be 

experiencing hardship. I can't really speak to whether or 

not we would officially address that at that level of 

specificity in the NPRM. But what I can say is that we, 

you know, would have an opportunity for public comment on 

that when we do publish that notice of proposed 

rulemaking.

MS. RANUCCI: Thank you. I just want 

to say, you know, I work with a number of borrowers who 

have judgments, as I was explaining, you know, in 

Brooklyn, Queens, and Staten Island, all you needed was a 

$600 Federal student loan debt in order to be sued on a 

judgment in the Eastern District of New York. So we see a 

lot of those judgments here, including for low dollar 

values. And I just think those borrowers have really, 

really limited opportunities for relief. So if the 

Department is, I think it's critical that this framework 

does not exclude those borrowers and anything the 

Department can do that would make it clear that those 

borrowers are not somehow inherently excluded from this 

relief would be really valuable.

MS. ABERNATHY: Well, we certainly 
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agree with you that we'd like for them to be included, 

and we will work toward that. But it is subject to a 

whole line of things coming forward. So thank you, 

Jessica.

MS. RANUCCI: Thanks.

MR. ROBERTS: Thank you both. 

Apologies for not mentioning this sooner, but Jalil is 

coming in on behalf of graduate student borrowers. But 

first, we have Angelika. Your hand, go ahead.

MS. WILLIAMS: Thank you, thank you. 

And thank you, Tamy, and the Department for the revised 

text. I was the individual that brought up natural 

disasters. And I want to expand on a little bit of why I 

mentioned the need for that particular item to be 

explicitly stated because I feel like it's a common 

factor. So I'm looking at the factors that are listed and 

the factors that are common and impact many borrowers. 

We're talking about past and current borrowers. So we're 

talking about victims of Hurricane Katrina, Hurricane 

Rita, and Hurricane Harvey in addition to multiple issues 

with the California wildfires. And so I do understand 

that when we have regulatory text in this realm, a lot of 

this text is copied and pasted into the application. And 

then going back to the previous note of the Department 

asking, why aren't borrowers applying for relief? 
26

Negotiated Rulemaking – 2/23/24

Sometimes it's easier to make a lot of things more 

explicit in the communication and make it more clear in 

the communication. There are options for applying for 

relief or waivers. And so that's why I wholeheartedly 

mentioned about explicitly mentioning natural disasters 

because it does impact many borrowers. My last note is 

more so of a question, because I brought up yesterday 

about the text to number 7, and I just want to get 

clarification when it says- or as its stated about other 

information from the FAFSA. Are we talking about the 

information on the FAFSA or the information as a result 

of the FAFSA? And that's just the question or 

clarification of what is that particular item. Because 

one, Pell Grant is a result of the FAFSA is derived from 

the FAFSA. It's not on the FAFSA. So I just want to make 

sure what do we mean by other information from the FAFSA?

MS. ABERNATHY: So as I mentioned in 

my opening remarks, a couple of those examples are 

looking at first generation like is a student a firstgeneration student? And gleaning some information if 

perhaps they are foster youth or homeless. Those pieces 

of information at the time that the borrower completed 

that FAFSA. That would be some information. So just some 

examples of what we're looking for. So Pell Grant 

recipient we have that information in our database. Like 
27

Negotiated Rulemaking – 2/23/24

we know who our Pell Grant recipients. But there is 

always some other information that we think that is 

pertinent to the data that remains on our system from the 

time that the borrower applied, that we could glean and 

try to further establish whether or not this borrower is 

experiencing hardship.

MS. WILLIAMS: Okay. Because from a 

financial aid administrator point of view, it's our 

understanding that the FAFSA data that's on the FAFSA is 

not available once the award year is closed. So not even 

a student can see in some cases or obtain that 

information after the fact. So how would this information 

be gathered from a previous borrower?

MS. ABERNATHY: So we have data 

available on our systems. So we would be able- so the 

whole purpose of that respective section is to look at 

when we're talking about both and process where the 

information that is available to the Secretary that 

information on our systems that we are able to see, we 

can get that information. It's also a process of 

application. So I don't think we're expecting a borrower 

to prove to us something that they completed on their 

FAFSA ten years ago or five years ago. That would not be 

our intent Angelika. Our intent is to streamline the 

application process, to make it as easy as possible for 
28

Negotiated Rulemaking – 2/23/24

borrowers to identify to us that they are experiencing 

some form of hardship. We certainly do not want to 

exacerbate the problem of hardship by creating a process 

that would be too cumbersome for a borrower to even 

tackle and requesting us to look at their respective 

situations for hardship. So I think as we can do it from 

the Department standpoint, we're going to glean as much 

information about a borrower as we can from their 

previous FAFSA forms that they've completed. Where they 

Pell Grant recipients? What were other indicators of data 

that we have on our system that could help us look and 

evaluate a student borrower's claim of hardship?

MS. WILLIAMS: Okay, Tamy, I 

appreciate that clarification. That helps out a lot.

MR. ROBERTS: Alright. Thank you, 

both. Jalil, go ahead.

DR. BISHOP: Thank you. I wanted to 

circle back to Tamy's opening remarks that I appreciate 

the acknowledgment to include Parent PLUS borrowers in 

the preamble and making sure that borrowers understand 

that this hardship regulation is targeted and meant for 

them, I think will be important. But I also, you know, 

have learned [inaudible] for advocacy work I've learned 

and, you know, being a student loan borrower, being a 

Black person navigating higher Ed policy, student loan 
29

Negotiated Rulemaking – 2/23/24

policy, is that it's really important to put your trust 

not just in what people say, but really in what they do. 

And I think for the Department, the question I have is 

how can Parent PLUS borrowers or borrowers who have had 

hardship where they've been on $0 payment year after 

year. How can they trust what you're going to do based on 

kind of what you have done in the past? So when I think 

about Parent PLUS borrowers, when we look at some of the 

last commentary released and previous rulemaking, it was 

a suggestion that parents and student borrowers are 

different because parents have more stable earnings, that 

parents giving them some type of relief could create some 

type of moral hazard where they may borrow more, I think 

is the suggestion there. It also was argued that giving 

parent borrowers relief would not be and this is a quote 

it would not accomplish our goal of focusing on the loans 

at the greatest risk of delinquency and default, which 

again, suggests that parent borrowers are not a group 

that needs that type of support. And that really goes 

against the data where we know, particularly for Black 

and Brown Parent PLUS borrowers, that they often have a 

$0 expected family contribution, they're one of the 

fastest growing groups in the Parent PLUS Loan portfolio, 

especially since 2000. So I'm just trying to understand 

if we have all this messaging that continues to say 
30

Negotiated Rulemaking – 2/23/24

Parent PLUS borrowers and borrowers who have $0 payments 

aren't necessarily, again, the quote is a part of 

accomplishing the goal of targeting relief for those who 

experience the most at-risk outcomes. How can a borrower 

trust that this time they will be included if in past 

commentary you have said they're now a part of your goal 

of applying relief? So just trying to again, how can we 

send that message and make it clear in these regulations 

that Parent PLUS borrowers are included since they've 

been excluded from relief multiple times?

MS. ABERNATHY: So one of the ways 

Jalil, thank you for your comments, we really appreciate 

hearing your insight on this. One of the ways that I 

think this particular proposed regulatory text is a 

little bit different is because it specifically is for 

the type of borrowers that you're mentioning. It does not 

exclude them. It's not an Income Driven Repayment Plan. 

It is a very- it's a specificity around the Secretary 

exercising his authority over specific instances of 

borrower hardship. And the loans that are included are 

Department held loans of which are Parent PLUS Loans. So 

I believe our messaging in good faith when we craft our 

notice of proposed rulemaking, and we put this 

information out to the public, we can be very clear, as 

we mentioned in the opening remarks, we can say these are 
31

Negotiated Rulemaking – 2/23/24

the types of loans that are included. And give our very 

best effort for the information that's on our websites 

related to the specific information that you're 

detailing. There are ways that we can get the message and 

present a good faith effort to our borrowers. And we 

would employ all of those mechanisms across the 

Department to reach these borrowers that are experiencing 

hardship.

DR. BISHOP: So, Tamy, just a quick 

clarification. So are you saying that the Department now 

has a shift in language where before has said we do not 

believe extending the benefits to Parent PLUS borrowers 

would accomplish our goals. Are you saying now under this 

regulation, it would be made explicit that Parent PLUS 

borrowers would be a part of the benefits?

MS. ABERNATHY: This particular 

regulation is different. So this particular regulation 

talks about the Department-held loans and the Secretary's 

specificity around these particular regulations and 

different statutory goals. Right? So this is about 

offering borrowers of which in this particular instance, 

Department-held loans including a Parent PLUS Loan would 

be considered as loan borrowers that are experiencing 

hardship. So it's different in the sense that this 

particular very narrow provision of subpart (g) speaks 
32

Negotiated Rulemaking – 2/23/24

specifically to borrower hardship or Department-held 

loans. It's not about Income Driven Repayment Loans or 

Parent PLUS Loans, excuse me, PSLF or any of those types 

of things. This is a very narrow specific subpart. 

Another component to subpart (g).

DR. BISHOP: Okay. Thank you for the 

clarification. And what I'm hearing is also an agreement 

to make sure that borrowers, particularly Parent PLUS 

borrowers, are aware and made explicit that they're 

included in this regulatory text.

MS. ABERNATHY: Yes, we want any 

borrower who is experiencing hardship within the 

parameters of what this regulation is to feel that they 

can seek this benefit.

MR. ROBERTS: Alright. Thank you, 

both. Ashley, I have your hand next.

MS. PIZZUTI: Hi. Thank you. I also 

want to, you know, circle back and say thank you again 

for including the text for- on number eight, the type of 

school we heard yesterday from several for-profit 

borrowers who have been incredibly harmed by choosing the 

school that they went to yesterday, including myself. I 

want to circle back to servicer error a little bit and 

something that I've experienced, just speaking with a lot 

of the Sweet v Cardona members is that for many of these 
33

Negotiated Rulemaking – 2/23/24

loan holders, their servicers have changed either due 

through their own consolidation or the company has gone 

out of business and, you know, sold off the loans to 

somebody else. And for Sweet v Cardona members those who 

have paid on a Direct Loan are due a refund. So what we 

are finding now is that a lot of these servicers that 

have obtained the loans over many, many years do not 

actually have the payment history. And so a lot of these 

full class members that are due refunds are not getting 

the either correct amount of refund or they're not 

getting refunds at all because they don't have the 

payment history. Now, so I guess my question would be, is 

it going to be on the student to prove they were harmed 

in the servicer harm? Or how is that going to play out in 

fixing this issue? I'm just wondering if the burden of 

proof is going to be put onto the borrower to show that 

they had made, you know, 20 years of payments when they 

don't actually have a payment history. Now, I have a 

second question to that. And that is the errors that are 

popping up actually on the student aid website, if you 

download your data, you can kind of see the history of 

your loans there. Now, there's been several instances 

where that is actually not accurate. For example, my 

husband's loans originated in 1901 on his history which 

is pretty interesting because he's not that old. I don't 
34

Negotiated Rulemaking – 2/23/24

even think student loans were around back in the early 

1900's. Yeah, that's all I have to say. Really, the 

question is, is the servicer error going to be the burden 

of proof onto the borrower?

MR. ROBERTS: I'm not seeing an 

immediate response to your question, Ashley. We can 

capture that and then I have John's hand next. John, do 

you want to go ahead?

MR. WHITELAW: Please. It's going to 

be two parts. One, I want to talk about subsection (d), 

and then I also want to talk and expand upon what both 

Jessica and Yael have said. I understand- I appreciate 

the adding the words including automated relief in 

section (d), and I think that's helpful. And I also 

understand that the Department doesn't want to put data 

sharing into the regulation. What I think an alternative 

thing to do, which I think is consistent with the 

Department's stated goals and their stated commitment 

that they believe in automation is to include, and we're 

going to fill something in the preamble that is where it 

says the Secretary may rely upon data in the Secretary's 

possession to talk about, in some level that, you know, 

that that also includes the Secretary will, you know, may 

take various efforts to gather data from appropriate 

sources, even if they don't currently have it in their 
35

Negotiated Rulemaking – 2/23/24

possession. So some language there that talks about it. 

So again, I really would like to see something that data 

sharing, which the Department has done in the past is 

just something that is in their arsenal and that they 

acknowledge that that's something that they do have done. 

And, you know, it's in the game. More generally, I cannot 

stress enough how important what both Jessica and Yael 

said about the application process. I have been doing 

client service work for more than 35 years, and the bulk 

of my job has been helping people applying for various 

benefits from a Governmental system, and the actual 

application process itself defeats multitudes of eligible 

individuals because they cannot master it. Depending on 

what agency it is and depending on where you are, many of 

us think that that is frequently intentional. And that it 

is designed to weed people out. We know that that is not 

the Department's intent, and I cannot tell you how 

important it is for the Department to consult with 

various advocates at the sub regulatory level to make the 

application process the least disruptive it can. Thank 

you.

MR. ROBERTS: Thank you, John. Tamy, 

you briefly came off mute, but then you- did you want to 

respond or would you like to take Jessica's comment as 

well?
36

Negotiated Rulemaking – 2/23/24

MS. ABERNATHY: Oh, no. Please, let's 

listen to Jessica.

MR. ROBERTS: I also recognized you 

were mid-cough. So Jessica, go ahead.

MS. RANUCCI: Thanks. I want to echo 

what John said. I also just as a drafting matter, I 

really would encourage the Department to put the words or 

without an application in this provision, if you intend 

to do debt relief without an application, which my 

understanding is that that is your intent. I really 

appreciate you adding the words automated relief. I think 

that that goes a step towards clarifying. I just think 

that automated relief and without an application are 

actually slightly different things and that you can 

imagine debt relief that requires an application and then 

upon application is automated. I'll put a different kind 

of language in the chat. I'm not wedded to how that goes. 

I just think I support what you're doing here. I just 

think it would be prudent to be really crystal clear that 

if you're saying you can rely on an application, you also 

do not need to rely on an application just so it's not 

misunderstood.

MS. ABERNATHY: Thank you, Jessica. 

Let us go back and try to massage the language a little 

bit. And we appreciate that suggestion, so thank you.
37

Negotiated Rulemaking – 2/23/24

MS. RANUCCI: Sure. I just put another 

version in the chat or a version I put yesterday. I'm not 

wedded to any version. I think you understand the 

concept.

MS. ABERNATHY: Yes. Thanks so much. 

We appreciate that.

MR. ROBERTS: Any other questions, 

specific or general comments, or anything at all for the 

committee's consideration? Yeah. We'll go to Jessica 

first.

MS. RANUCCI: Thinks I just, you know, 

we haven't spoken about (c) and I think there was a 

pretty strong push from the negotiators yesterday to 

really critically think about that 80% number in section 

(c)C, and consider whether language such as more likely 

than not, which I think was proposed both by Lane and 

separately by me and maybe others would be a better 

formulation of the idea that the Department is intending 

to do immediate waiver of borrowers with significant 

default risk. I understand in your intro Tamy, you said 

something along the lines of like, we thought about it 

and we've declined, and I was just wondering if the 

Department might be able to expound a little bit on its 

reasoning. In my view, that language would really provide 

the Department flexibility to take this action to extend 
38

Negotiated Rulemaking – 2/23/24

relief to the borrowers that it really thought warranted 

that relief. And, you know, we discussed about how high 

of a threshold default is, you know, 270 days without a 

payment is a long time. And that we thought, you know, 

both that it would be more appropriate to include more 

borrowers, but also that, you know, language that 

provided the Department flexibility in its model would be 

good, you know, sort of in the vein of the Department's 

approach to this rulemaking.

MR. ROBERTS: Might need to wait if 

you don't have a response for that, Jessica. But Jalil go 

ahead.

DR. BISHOP: I'm going to- Jessica 

kind of is touching on the same point. I think what I 

heard the Department say yesterday and today is that when 

it comes to the 80% and how it's trying to move through 

the regulations internally, is that it still needs time 

to look at the data, to look at the best way to create a 

model that allows them to answer this question of likely 

default or likely to experience hardship. And if that is 

the case, it seems like if more research and time is 

needed to build to explore how to provide relief and how 

to understand the data. The 80% seems- it could feel that 

without us understanding how you got to the 80% it could 

feel like we need a little bit more clarification. So I 
39

Negotiated Rulemaking – 2/23/24

think the more likely to default over the 80% first 

honors what the Department is saying is that it needs 

more time to look at its data to understand what's 

happening with borrowers, but also gives us regulation 

that really accomplishes the goal of making sure that 

we're not doing something that would narrowly focus the 

regulation before we have all the information, or before 

the Department has had time to really evaluate the 

student loan portfolio and understand what it means by 

default. I think by putting 80% to me, it suggests that 

you then need to tell us how you reach the 80% so that we 

can know whether that is going to really get to the 

borrowers who we know are in default, and if they're in 

default, it means that they have already experienced 

close to almost a year of hardship if not more. So I just 

think if the Department could talk a little bit more 

around why the 80% versus the proposed revised text of 

more likely, I think would help us just understand a 

little bit more that number and you know, and then make 

us also feel a little bit better about whether or not 

it's going to get to the target, which is helping 

borrowers who are in default experiencing some of the 

worst outcomes of student loan debt.

MS. ABERNATHY: So Jalil. Thank you 

and thank you, Jessica, for bringing this back up to us. 
40

Negotiated Rulemaking – 2/23/24

At this point, the Department is not able to speak to 

this question. Perhaps the team can look at this and get 

back to you later today.

MR. ROBERTS: Thank you, both. Any 

additional comments? If there are none. What I might 

suggest is like a 15-minute break. And then we come back 

if there's more from the Department in terms of some of 

the questions, if there's more in terms of what you'd 

like to cover today, we can get to that. But if there's 

not I would ask that we consider a consensus check before 

the lunch hour. So does anyone have an issue with that if 

we take a 15-minute break? Okay seeing none. Why don't we 

pick back up at ten after the hour? So I have 11:10 

Eastern and we'll go from there. We can pause the live 

broadcast. Welcome back, everyone. Hope you enjoyed that 

short break. Tamy, if it's okay, I'll turn it right back 

over to you. I know we left with a few questions that the 

Department might have some additional consideration on so 

I'll turn it over to you and your team.

MS. ABERNATHY: Thank you, Brady. We 

would like to respond to the questions and the concerns 

regarding the 80%. We really appreciate your input, your 

feedback, your rationale. We will take all of that under 

consideration. However, we think 80% is appropriate. And 

that is the percentage at this point that the Department 
41

Negotiated Rulemaking – 2/23/24

will propose in this regulatory text.

MR. ROBERTS: Alright. Oh, go ahead, 

Tamy. Yeah.

MS. ABERNATHY: The other thing well, 

we'll talk about revising the regulatory text after all 

of the questions.

MR. ROBERTS: Okay. Yeah. Jalil, 

please.

DR. BISHOP: Thank you. If the 

Department and other negotiators are open to it I would 

love to go into a caucus with the Department to not so 

much talk about the 80% in part (c), but to have a little 

bit more of a conversation around the how and some of the 

context. And if we could have some time to go into a 

caucus to discuss that, that would be helpful.

MR. ROBERTS: Sure, just for the 

record's sake, would you mind just saying the names of 

the constituent groups of folks you'd like to invite?

DR. BISHOP: Well, I'm open to other 

negotiators who want to come in, please let me know. But 

I will say Wisdom, and Jessica as the two. But if other 

folks would like to enter please just speak up.

MR. ROBERTS: Anyone else?

MS. ABERNATHY: Do you need the Ed 

team?
42

Negotiated Rulemaking – 2/23/24

MR. ROBERTS: I would, yeah, I would 

say Tamy, Soren, and then do you also want Ben, Genzie, 

and Toby?

MS. ABERNATHY: Yes. And Brian Siegel.

MR. ROBERTS: And Brian. Gotcha.

MS. SHAVIT: I'm happy to join Jalil, 

butDR. BISHOP: Yeah. You're invited.

MR. ROBERTS: So that was Yael Shavit 

for state attorneys general. Anyone else?

MR. WHITELAW: Yeah, I'd like to join 

too.

MR. ROBERTS: John Whitelaw. Jalil, 

about how much time do you predict this caucus to last?

DR. BISHOP: Maybe ten minutes.

MR. ROBERTS: Ten minutes?

MR. WATERMAN: I would like to join 

too.

MR. ROBERTS: Scott Waterman for legal 

aid. Alright. We'll check in in about ten minutes. And 

then if you've concluded the caucus at that time, we'll 

come back to the main session, we'll ask for a report 

out, and then we'll go from there. Does that sound okay?

MS. ABERNATHY: Thank you, Brady.

MR. ROBERTS: You can now we can pause 
43

Negotiated Rulemaking – 2/23/24

the live stream now. Welcome back, everyone. From that 

caucus break. First and foremost, Jalil, you had called 

the caucus. Do you want to do a brief report out to the 

committee and the viewing public?

DR. BISHOP: Yeah. So we had a caucus 

to discuss part (c). The main point for the negotiators 

were ensuring that as part (c) is being designed and 

implemented, that borrowers who have indicators of 

likelihood around default, both past and present, are 

being considered, making sure that borrowers who have 

used relief plans like Fresh Start or SAVE are not 

somehow penalized for using what was available to them at 

that time. And now that a new opportunity, a new relief 

plan is becoming available we just really insisted that 

that doesn't somehow penalize borrowers who use Fresh 

Start or other options prior to. The Department made 

clear that their 80% threshold is something that they 

feel confident around but still welcome proposals around 

what parameters, evidence, or other criteria should be 

considered as they think about the design of part (c).

MR. ROBERTS: Thank you, all. Tamy, I 

think I'll turn it back over to you. Did you want to- did 

you have anything else for the committee?

MS. ABERNATHY: I do. I think we have 

heard some really good suggestions related to some of the 
44

Negotiated Rulemaking – 2/23/24

amendatory text, and we're going to need a few minutes to 

go through that and finalize that language for you guys 

and present that to you. So I think we're just going to 

need some time so that we can circulate and get that 

right and then present it to you guys. So, Brady, I don't 

know if you have a suggestion as to how we should handle 

that. We're open to suggestions.

MR. ROBERTS: If I can suggest it. If 

no one's opposed, we could just take lunch about 25 

minutes early to give the committee about an hour and 20-

ish minutes to do that work. And then you'd want to pick 

up at 1 Eastern with presenting any modifications made 

and then any further discussion.

MS. ABERNATHY: That works for us.

MR. ROBERTS: Is anyone opposed to 

that suggestion? I'm seeing an emphatic no from John 

Whitelaw. What I would say to the public at this time is, 

A, as usual, there is a different viewing link for the 

afternoon session. So there's a secondary link that 

should have been provided in the registration emails. 

This first link that you're currently viewing on will not 

be live in the afternoon. That second link will be and 

then we will pick up at 1:00 pm Eastern for the 

resumption and conclusion of session four of this 

negotiated rulemaking. With that, I think we are okay to 
45

Negotiated Rulemaking – 2/23/24

take our lunch 25 minutes short and pick up as I said at 

1:00 Eastern. So thank you all.

MS. ABERNATHY: Thank you, Brady. 
46

Negotiated Rulemaking – 2/23/24

Zoom Chat Transcript 

Student Loan Debt Relief Committee - Session 4, Day 2, Morning, February 23, 2024

*Chat was copied as presented, as a result minor typos or grammatical errors may be present.

From P- Jessica Ranucci (Consumer Advocates) to Everyone:

To ED- the end of paragraph (c) that Tamy just showed on screen is not the same that was 

circulated to us last night

From A-Jalil Mustaffa Bishop-Graduate Student Borrower to Everyone:

Coming in for graduate borrowers

From Edward Boltz (A: Consumer Advocates)(he/him) to Everyone:

+1 Jessica about broad inclusion of borrower (including those in bankruptcy)

From P - Lane Thompson, state officials to Everyone:

+1 to including natural disaster as a hardship factor (maybe an "other potential factors" 

section that lists this and other possible hardships)

From P-Yael Shavit-State AGs to Everyone:

Reacted to "+1 to including natu..." with ���

From Sarah Butts, P-4-year Borrowers to Everyone:

Reacted to "+1 to including natu..." with ���

From Sarah Butts, P-4-year Borrowers to Everyone:

Reacted to "+1 Jessica about br..." with ���

From P - Kathleen Dwyer - Proprietary Institutions to Everyone:

Reacted to "+1 to including natu..." with ���

From A-Jalil Mustaffa Bishop-Graduate Student Borrower to Everyone:

The Department in the SAVE regulations said this about Parent Plus: 

“The Department considered suggestions by commenters to provide payments equal to 5 

percent of discretionary income on all loan types. However, we believe that doing so would not 

address the Department's goals of targeting benefits on the types of loans that are most likely to 

experience delinquency and default. The result would be expending additional transfers to loans 

that have a higher likelihood of being successfully repaid.”
47

Negotiated Rulemaking – 2/23/24

My understanding is the Dept is agreeing to not make these type of statements that could 

exclude borrowers under hardship

From A-Jalil Mustaffa Bishop-Graduate Student Borrower to Everyone:

Replying to "The Department in th..."

“However, we do not believe that extending benefits to these borrowers would accomplish 

our goal of focusing on the loans at the greatest risk of delinquency and default. Moreover, we are 

concerned that extending such benefits could create a high risk of moral hazard for borrowers who 

are close to retirement age. Instead, we think broader reforms of the Parent PLUS loan program 

would be a better solution.”

I ask that the Department does not use statements like this to shape their model or public 

facing documents.

From Sarah Butts, P-4-year Borrowers to Everyone:

+1 on making the application user friendly

From A-Jordan Nellums-Currently Enrolled Students to Everyone:

Reacted to "+1 to including natu..." with ���

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 or acquired through an 

application to provide relief, including automated relief without an application from the borrower, 

based on criteria demonstrating the conditions described in paragraph (a).

From John S. Whitelaw, (he/him) (CLASI) P-Students with Disabilities to Everyone:

Plus one to Jessica’s comments

From Sarah Butts, P-4-year Borrowers to Everyone:

Reacted to "Plus one to Jessica’..." with ���

From P - Lane Thompson, state officials to Everyone:

Reacted to "Plus one to Jessica’..." with ���

From P-Richard Haase (Graduate Borrowers) to Everyone:

+1 to reconsidering 80% threshold for part (c)
48

Negotiated Rulemaking – 2/23/24

From P - Lane Thompson, state officials to Everyone:

+1 to Jessica - 80% likely to default within two years is a complicated metric

From Sarah Butts, P-4-year Borrowers to Everyone:

Reacted to "+1 to Jessica - 80% ..." with ���

From A - India Heckstall, Civil Rights Orgs to Everyone:

+1 to Jessica - 80% likely to default within two years is a complicated metric