TICAS Comments on Student Loan Servicing Market Monitoring

October 6, 2017
The Institute for College Access & Success

Comments on the Consumer Financial Protection Bureau’s (CFPB’s) proposed “Student Loan Servicing Market Monitoring” initiative to collect information from both private and federal student loan servicers on their loan portfolios and borrower outcomes. We strongly support this information collection, however, the new proposed adjustment to the data collection would substantially limit the comprehensiveness and usefulness of the information on student loan servicing. According to the Supporting Statement Part A for this comment period, the CFPB is “not requesting data requiring manual investigative work or interactions with third parties to compile data points not captured on the current system.” Only requiring servicers to report data they already track would lead to uneven reporting, and reward servicers that don’t analyze certain data elements or claim not to. We strongly recommend requiring student loan servicers to report all the data included in this collection.