EdLoC Submits Formal Comments on Proposed Federal Regulations to Improve Student Loan Relief Programs
Education Leaders of Color (EdLoC) has weighed in on the proposed federal regulations to improve student loan relief programs. The Biden-Harris Administration is proposing new regulations on various provisions that could benefit student loan borrowers, including students of color who are disproportionately negatively impacted by the student loan debt crisis.
The existing racial wealth gap is significantly exacerbated by the student debt crisis. While approximately 45 million student loan borrowers owe more than $1.7 trillion, longstanding racial and economic inequities disproportionately leave borrowers of color with greater rates and amount of student debt, more difficulty repaying student loans, and greater rates of default. This inequity prohibits their ability to fully thrive and attain the life that higher education was supposed to allow for.
Most of EdLoC’s 800 members work in public service jobs, as defined by the Higher Education Act, and therefore are poised to benefit greatly from the Public Service Loan Forgiveness (PSLF) program. Among the key provisions proposed, EdLoC supports regulatory changes to PSLF that:
remove unnecessary and overly stringent requirements regarding what counts as a qualifying payment;
clarify the definition of “full-time work”;
improve the application process;
eliminate the need to be employed by a qualifying employer at the time of forgiveness; and
create a reconsideration process to allow borrowers to appeal a denied application.
The Department of Education (ED) must also revise the regulations so that forgiveness under PSLF is focused on the public service function rather than the scope of employment, which currently leaves many public service workers ineligible for PSLF.
Given that Black, Latino, and Indigenous borrowers are more likely than white borrowers to seek forbearance, EdLoC strongly supports the department’s proposal to eliminate student loan interest capitalization when a borrower enters repayment, exits forbearance, defaults on a student loan or exits most income-driven repayment plans. Finally, EdLoC supports the various changes to the borrower defense rules that exists to ensure that students who are the victims of fraud, misrepresentation, and illegal conduct by predatory colleges receive the discharge of their debt to which they are entitled under federal law.
EdLoC strives to ensure young people of color have the support they need to thrive, capitalize on opportunities, and build generational wealth. As such, we welcomed the opportunity to comment on the regulatory changes to certain student loan relief programs proposed by the ED. To alleviate the economic burdens facing communities of color, we must provide meaningful relief to the borrowers who are currently struggling under the weight of their student debt.You can read the full comment letter here.
If you are interested in getting involved in federal student loan reform efforts, please contact Angelica Solis-Montero, EdLoC's Chief Policy Officer at asolismontero@edloc.org.
