About gathard

Jim Gathard is the owner and principal of National Consulting Services, LLC a New York based consulting firm providing advisory in strategic planning, risk management, and organization management to financial services and higher education organizations Mr. Gathard has expertise and senior executive experience in private sector financial services, legislative and government relations, and higher education management. He has held senior business executive positions at JPMorgan Chase and Bank of America. Prior to his private sector experience Mr. Gathard has nearly twenty years in higher education administration as Deputy Provost/Executive Vice President, Vice President for Student Services and Compliance, Dean of Enrollment Management and Director of Student Financial Services. National Consulting Services, LLC clients include a broad spectrum of publically traded and private financial services firms and not for profit and for-profit organizations including colleges and universities. In the higher education space Mr. Gathard’s primary focus is the student segment including the student financial services, access and enrollment, institutional compliance and; financial literacy and debt management. Mr. Gathard serves on and is advisor to numerous industry and community related boards. Mr. Gathard has been a NYSFAAA member for more than 30 years.

NYS Budget

Find below some 2019 NYS budget proposals*

  • Create/establish NYS licensing standards for student loan servicers; an estimated 28 million borrowers live in New York and are serviced by 30 student loan companies.
  • Create/establish through the For-Profit College Accountability Act oversight of for-profit schools
  • Mandatory regular reporting to the state on funding sources. Limit school funding to 80 percent of its funding from taxpayers, currently ED caps schools’ taxpayer funding at 90 percent.
  • Mandatory regular reporting to the state on expenditures. Each school would be required to spend at least 50 percent of its budget on instruction and learning.
  • Mandatory reporting on salaries and bonuses for school presidents and senior leadership.
  • A prohibition on school leaders serving on boards for accreditation agencies to which they apply.

*from to the 2019 NYS ‘budget book’


PLUS Loan News

Parent PLUS has become a central part of America’s higher-education financing system; parents can borrow freely from the federal government – with no limit – to support their children’s education.

Some recent research* from the Brookings Institution offers illustrations of an out-of-control parental loan program with substantial unintended, negative consequences for parents e.g. rapidly rising parental debt levels, slower repayment rates, increasing delinquency/default rates, all with little benefit from the child’s potential increased earning power.

To add ‘injury to insult’ parent loans actually make money for the government. According to CBO taxpayers net 13 cents for every dollar disbursed, and parent loans are the only category of federal student loans to turn a profit.**   This profitability is because parents pay higher interest rates (currently 7.6 percent) and are ineligible for several loan forgiveness programs that student borrowers can access.

Furthermore, in 2015, 18 percent of families receiving a Parent PLUS loan had an expected family contribution of zero. In other words, the federal government determines that hundreds of thousands of parents can contribute nothing to their children’s college education, and then turns around and gives those same families tens of thousands of dollars in high-interest loans.

In summary:

  • The federal government offers parents unlimited loans, with minimal credit checks and high interest rates, to pay for an asset from which borrowers derive no direct benefit.
  • If parents fall into default, the government has the power to garnish their wages and seize their tax refunds, charging excessive collection fees (up to 20%)
  • Financial aid award letters sometimes do not even make it clear to families that Parent PLUS loans are loans.

If any entity but the federal government were making loans on these terms, it would be labeled a predatory lender and incur the full wrath of regulators at every level of government. But because ED is the lender, supported by Congressional action, these predatory practices get a pass.

As the HEA Reauthorization receives consideration now may be a time for FAAs and others offer a more viable alternative that provides access without burdening parents.

* https://www.brookings.edu/research/parents-are-borrowing-more-and-more-to-send-their-kids-to-college-and-many-are-struggling-to-repay/

** https://www.cbo.gov/system/files?file=2018-06/51310-2018-04-studentloan.pdf

James Gathard, Principal

National Consulting Services, LLC

Proposed Regs

Today ED is expected to release a package of regulatory proposals that if adopted will change, again, accreditation and institutional eligibility rules for financial aid.  It is likely this will be a lengthy process and unlikely to gain Neg Reg negotiators approval.

Find below an advance copy of the proposed regulatory changes.







James Gathard, Principal

National Consulting Services, LLC

Student Loan Data reports

Student Loan Data Reports

FSA (federal loans) and Measure One (private loans) recently reported student loan performance data, as of September 30, 2018.

HIGHLIGHTS: (federal loans)

  • Loan portfolio (outstandings) $1.44Trillion; DL (80%), FFEL (20%)
  • Income-Driven Repayment (IDR) enrollment 7.2M, up 11% from 2017
  • Default

–    About 275,000 borrowers ($5.8B) in repayment defaulted

–    81% of non-defaulted DL recipients with loans in active repayment are current                 on their loans (on time or less than 31 days delinquent) creating a                                   31-day-plus delinquency rate of 18.7% by recipient count and 14.8% by total                   dollar balance

  • Borrower Defense to Repayment Report
  • 48,000 claims have been approved, resulting in nearly $535M in discharges.
  • Public Service Loan Forgiveness Report
  • 41,000 borrowers had submitted almost 50,000 applications for loan forgiveness under this program.
  • Of the approximately 45,000 applications that have been processed
  • 72% have been denied due to not meeting the program requirements*
  • 27% of PSLF applications were denied due to missing or incomplete information on the form.

*The Public Service Loan Forgiveness (PSLF) Program, which was established under the College Cost Reduction and Access Act of 2007, permits Direct Loan (DL) borrowers who make 120 qualifying monthly payments under a qualifying repayment plan, while working full-time for a qualifying employer.

HIGHLIGHTS: (private loans)

  • Loan portfolio (outstandings) $66B; In-repayment 75%; In-school/Deferment 25%
  • 92% of new originations had co-signers
  • 2018 YTD repayment performance better than 2017

Legislative Watch

Senate Finance Committee Ranking Member Ron Wyden, D-Ore., introduced legislation earlier this week to allow employers to make “matching” contributions to 401(k), 403(b) and SIMPLE retirement plans while employees continue to pay their student loans.

Copy of bill can be accessed at;


Description of bill can be accessed at;