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;

Enrollment Trending

NSC (National Student Clearinghouse) recently released enrollment trending data you may find useful.  It includes trending data sorted by a variety of components e.g. total, sector, FT students, level of instruction, gender and state.


the full report can be accessed at;