60D Comment Response

PUBLIC
SUBMISSION

As of: June 04, 2024
Received: April 08, 2024
Status: Posted
Posted: April 09, 2024
Category: Financial Aid Administrator
Tracking No. lur-3197-fnt1
Comments Due: June 03, 2024
Submission Type: Web

Docket: ED-2024-SCC-0054
Reaffirmation Agreement
Comment On: ED-2024-SCC-0054-0001
Agency Information Collection Activities; Comment Request; Reaffirmation
Agreement
Document: ED-2024-SCC-0054-0004
Comment on FR Doc # 2024-07151

Submitter Information
Name: Anonymous Anonymous

General Comment
It is not clear what a reaffirmation is attesting to when it comes to larger
debtors, who disproportionately rely on subsidized IDR plans. When someone
pays through IDR, they are not really paying off what they owe, so any
“Promise to Repay” is a symbolic gesture without any significance.
Therefore, I recommend that for students with more than $31,000 in loans,
smaller overpayments, e.g. less than $500 require actual repayments, and
larger overpayments require return of funds from the school. Reestablishing
eligibility through a reaffirmation should only apply to borrowers with low
debts and low overpayments.
Otherwise, there’s no consequence for going well over a statutory limit.
Anyone can “promise to repay” then qualify for de minimis payments if they
already hold more debt than they can afford.
FSA Response:
Thank you for your comment regarding this information collection. However, the
revisions suggested would require changes to the Higher Education Act of 1965,
as amended, and/or negotiated rulemaking and therefore cannot be incorporated
into this collection.