Coalition Comments on Proposed Student Loan Regulations
August 10, 2015 – Comments from TICAS and 22 other organizations representing students, consumers, veterans, and colleges on the Department of Education’s proposed regulations creating a new income-driven repayment plan (REPAYE) and making other changes to federal student loan regulations.
Detailed Comments on Proposed Student Loan Regulations
August 6, 2015 – Detailed comments on the Department of Education’s proposed regulations creating a new income-driven repayment plan (REPAYE) and making other changes to federal student loan regulations.
TICAS Comments on Topics for Negotiated Rulemaking
October 22, 2014 – Comments in response to the September 3, 2014 Federal Register notice soliciting input on topics to be included in the U.S. Department of Education’s upcoming negotiated rulemaking. Key recommendations include: increasing access, targeting, simplicity, and fairness in the Pay as You Earn federal student loan repayment plan; preventing cohort default rate and 90/10 rule manipulation; increasing the efficacy of Participation Rate Index appeals by colleges with low borrowing rates; and ensuring that loans are discharged for defrauded students.
TICAS Comments on the IBR/ICR Plan Request Form
October 9, 2012 – Comments on the draft “Income-Based/Income-Contingent Repayment Plan Request” form, which provides an integrated application process for borrowers seeking loan payments based on their income. Our comments recommend specific improvements to increase the form’s effectiveness.
Coalition Letter to the Department of Education on the Proposed Rules to Improve IBR/ICR/TPD
August 16, 2012 – Letter submitted by a coalition of organizations representing students, teachers, consumers, and civil rights on the proposed rules to improve the Income-Based Repayment (IBR) and Income-Contingent Repayment (ICR) programs, and simplify the process of discharging student loans in cases of total and permanent disability (TPD).
TICAS Technical Comments on the Proposed Rules to Improve IBR/ICR/TPD
August 16, 2012 – Technical comments in response to the Notice of Proposed Rulemaking (NPRM) published in the Federal Register on July 17, 2012, on the proposed rules to improve the Income-Based Repayment (IBR) and Income-Contingent Repayment (ICR) programs, and simplify the process of discharging student loans in cases of total and permanent disability (TPD).
TICAS Comments on the Draft “Alternative Documentation of Income” Form
April 12, 2012 – Comments on the revised “Alternative Documentation of Income” form, which is used by borrowers whose adjusted gross income (AGI) is not available from the IRS or whose most recently reported AGI does not accurately reflect their current income.
Official Comment on Proposed Rules for IBR and Public Service Loan Forgiveness
July 14, 2008
