GLOS has lack of respect for Neg Reg procedures by issuing Dear Colleague Letter prior to Neg Reg. PBO can't decide policy on direct lending and FFEL and be fair to both. ED's interpretation of the Prompt Payment Act. Lack of customer service approach on forms development. Seems to always be a legal approach vs. customer service.
Lawyers control forms development process.
Forms expire before new forms developed and ED doesn't provide any guidance on what to do in the interim. Forms development without involving FFEL users. Policy development without gaining the FFEL perspective. Interest and special allowance payments too many edits too many kickbacks .not fully automated. Payments not expedited.