Consumer complaint received 2019-10-21
Product: Student loan — Federal student loan servicing
Issue: Dealing with your lender or servicer — Trouble with how payments are being handled
Company: AES/PHEAA (PA)

By my count I should have 115 qualifying payments towards my Public Service Loan Forgiveness. I have been enrolled in this since 2009 when my loans were serviced by XXXX XXXX. 
My loans were bought by XXXX XXXX XXXX XXXX XXXX XXXX  ) in XX/XX/XXXX. I re-sent my Employment Certification Form proving I was a federal employee and every year sent in my tax return to have my payment adjusted under the IBR plan. In XXXX I asked XXXX for a count of my qualifying payments. In an email dated XX/XX/XXXX I was told I had made 54 qualifying payments to XXXX and 17 to XXXX. 
In an email dated XX/XX/XXXX XXXX confirmed that I had made 101 payments but also said it would be up to FedLoan to come up with the final number and they transferred my loan to them. Up until I thought I was nearing my forgiveness date I had never heard of FedLoan before. 
I had to re-send all my Employment Certification Forms. I had had 3 different Fed jobs since starting to payback my loans and FedLoan had no record of any of them.

When FedLoan finally calculated my qualifying payments ( XX/XX/XXXX ) they came up with 49 for one loan and 59 for another. Not only are these numbers ridiculous but my loans have been consolidated since my first PSLF/IBR payment so where they get two different numbers is another mystery. 
Writing to complain about their calculations, I got ( in part ) this answer : The months that did not count as qualifying payment months for public service loan forgiveness include XXXX through XXXX XXXX due to an administrative forbearance that was applied to your account, XX/XX/XXXX due to the months full installment amount not being full satisfied, XX/XX/XXXX due to a general forbearance, XX/XX/XXXX due to no bill being generated, XX/XX/XXXX due to an administrative forbearance that was applied to the account, from XX/XX/XXXX through XX/XX/XXXX due to a general forbearance and XX/XX/XXXX due to the full installment amount not being fully satisfied. 

What? What a bunch of excuses and XXXX made up behind the scenes and after the fact. Never ever did XXXX   or XXXX put my loan in administrative forbearance or did I pay during a general forbearance or any of the other stuff I am hearing about the first time ever. 
I reiterate I have never heard of administrative forbearance or general forbearance before and was certainly not told when my loan was in those stages. I was not told that my loan being put in these stages would render my payment invalid towards my PSLF. Never a word of any of this. 
I suspect the answer was uncovered in the XXXX memo that XXXX reported on in XXXX XXXX : " The memo, which was written in XX/XX/XXXX, details XXXX strategy to service federal student loans ... 'Our battle cry remains forbear them, forbear them, make them relinquish the ball. ' While XXXX isnt FedLoan, Ive read too many articles to count now on how awful and even fraudulent FedLoans is.Im positive they work in the same way ; they certainly put me on forbearance over and over again without my knowledge. 

***UPDATE : *** After a complaint to the Consumer Financial Protection Bureau XXXX FedLoan re-calculated my payments. Their letter dated XX/XX/XXXX now states both loans have received 62 qualifying payments with 58  remaining. To recap, the number of payments remaining used to be 71 for one loan and 61 for another. So suddenly they are counting 16 more payments as qualifying. Its an improvement but still completely opaque and far off from my number of FIVE remaining payments. 
How exactly are these payments counted? I have no idea. Does anyone? Looks like its completely arbitrary. The best evidence I have is the evidence from my bank on how many payments I made. No those withdrawals dont show whether my loan was in some sort of made up forbearance at the time but I dont see any paperwork on FedLoans side that shows that either. Their method of counting payments is completely hidden. 
So Im entering this complaint again and sending a copy to the attorney general of my state, which is Pennsylvania, the home of FedLoan. I stated in my earlier complaint that I would be happy with FedLoan counting 110 payments as qualifying since the last communication I had with someone ( before FedLoan became my servicer ) on this subject stated so.