The U.S. Department of Education (ED) announced another waiver that will bring borrowers closer to forgiveness under income-driven repayment (IDR) plans and that in many ways extend the benefits of the Public Service Loan Forgiveness waiver. These adjustments to borrower accounts include conducting a one-time revision of IDR payment counters to address past inaccuracies (including automatically discharging loans for eligible borrowers) and permanently fixing IDR payment counting by reforming ED’s IDR tracking procedures going forward. These adjustments also allow Parent PLUS borrowers and other federal loan borrowers to obtain credit for normally ineligible periods for the purposes of Public Service Loan Forgiveness! This Feb 2023 webinar reviews this important topic, presented by student loan expert Betsy Mayotte, President of TISLA.
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Please note that this transcript was auto-generated. We apologize for any minor errors in spelling or grammar.
[00:00:00] All right, so welcome everyone. My name is Julie Shields Rina, and I’m the director of college planning education and training at MEFA. And well thank you for joining us for this MEFA webinar that is going to be about the updates on the income driven repayment plan for the federal student loan borrowers and parent plus loan borrowers.
Um, a hot topic. I know a lot of you are interested in this and so we’re so happy to be able to provide this today. I’ll also share that my colleague Sean Morrissey and Stephanie Wells are with me today. Um, and I’m gonna give a few logistics and then I will, um, introduce our, our very much of an expert presenter.
Alright, so a few of the logistics are that I am recording. This so that, uh, tomorrow we will send you a copy of the recording and of the [00:01:00] slides, um, as we go along, if you have questions, especially burning questions. Um, because I know that Betsy will cover so much, um, put your questions in the q and a section, and that way we have, we have people behind the scenes who can help answer as well.
If you need a live transcript, press the closed captioning CC button. And I think, uh, one person at least is already taking advantage of that. Um, and again, if you need to leave the webinar. Then you can do so, and we will be following up with you. Um, I think most of you know, but MEFA is a state authority that was created in 1982, and we help families plan, save, and pay for college.
And we share all kinds of great information about the college going process, and in this case about student loans, uh, for both families and school counselors, and everyone who, um, who works with, with students and [00:02:00] former, former students. So, I don’t want to prolong this anymore because I wanna introduce our, our great presenter today, Betsy Ott, who is the president and founder of the Institute of Student Loan Advisors, tsla.
And let me give a quick, uh, quick introduction, but just to say that, um, we’ll make it quick because I, I know that Betsy has a lot to share. So Betsy, again is the president and founder of tsla. She’s been working in the student loan industry doing compliance and advocacy work for over 20 years, and has helped thousands of borrowers with their student loans.
Betsy has served as a primary negotiator for several federal Title four negotiated rulemaking sessions on topics such as the use of student loans at foreign schools, loan rehabilitation, and borrower defense to repayment. In addition, Betsy frequently [00:03:00] conducts regulatory trainings for the higher education financing in industry, both in this.
Canada, Australia and New Zealand. She’s regularly quoted in the media on student loan issues, including the Washington Post, the New York Times, the Wall Street Journal, and the Boston Globe. And in fact, um, there are so many things going on in the loan industry that those, uh, those quotes have been been more frequent of late.
Uh, and she was recently featured in Money Magazine as one of the top 50 influential change makers in America’s finances. She was born and raised in Lowell and currently lives in Plymouth, Massachusetts. Uh, so with that, Betsy, I’m gonna turn it over to you and I’m sure you can also introduce Pat, um, from your wonderful tsla organization.
I sure can. Uh, thank you for that introduction. Um, I, let me just get the presentation up [00:04:00] there and I have a lot of screens open.
Okay. Um, and I’m gonna shut my camera off because my face will do absolutely nothing to contribute to this.
Okay. So, with me today, I have my senior student loan advisor, pat Torkleson. She’s gonna be working the q and a panel, uh, for you. Um, a word about the q and a. We’ve got an awesomely big group today, which I love to see. Um, but the, the problem with that is sometimes the questions can get a little overwhelming and repetitive.
So a couple I wanna. Put in place a couple ground rules, uh, for the questions. Um, let me just say, first off, we love answering questions. Um, and if you have some, you can post them in the q and a panel on your screen, [00:05:00] and Pat will answer, um, as many of them as she can throughout the presentation. And if there’s any question that she thinks might be really good for the whole group to hear, uh, every once in a while I’m gonna take a breath and she’ll, she’ll feed that to me.
Now to make sure we can’t answer as many questions as possible. First ground rule. Hang off on your, hold off on your question until I’ve covered the topic. If I’m doing my job right, um, I will answer that question for you along the way. So again, um, I know people are really anxious for their personal questions, but please don’t ask it until we cover that topic.
We will be hanging out for a few minutes at the end, uh, to cover any sort of stragglers that might be left over. Um, the second thing is please don’t ask any detailed or personal questions. This isn’t the forum for that. For one thing, it’s public. Um, and you don’t necessarily need everybody on here knowing your business, so to speak.
Um, my organization, TSLA, we’re a [00:06:00] nonprofit who was founded to offer free expert and neutral student loan advice. So if after this presentation is over, you do still have a question and it’s very personal and detailed in nature, I encourage you to go to our website, which is free student loan advice.org.
Um, and we’ll, we’ll throw that up in the chat panel. It’s also on the slides. Check out the, uh, plain language, plain English language, um, information we have about these topics on our website. And then if you still have a question, you can go to our contact page and using the TLA email, uh, send us that detailed question that you want to ask us, and we answer the majority of the questions within a business day and we’re happy to do it.
Um, and I, that’s about it. So again, hold off on your question until we’ve covered the topic. See if I answer it for you along the way and withhold your personal, your personal details because, uh, again, this is a public forum. So with that [00:07:00] said, um. We’re gonna cover sort of a potpourri of things today. What they all have in common is student loans and student loan forgiveness.
I’m gonna start off, even though this wasn’t really in the advertisement of the session, but I feel like it’s an elephant in the room and it’s something we get questions about a lot, which is the Biden Harris debt relief, like what it is, where it’s at, so on and so forth. And then I’m gonna get into the meat of the session, which is about the, um, temporary one time income driven plan waiver, how that works, and especially how it dovetails with the recently ended public service loan forgiveness waiver.
And how it essentially, for the most part, is kind of a backdoor extension to that waiver, which is awesome. Um, and then if we have time, I’m gonna talk about some upcoming permanent changes to the public service loan forgiveness program. Um, that will be effective. One of them’s effective. Now, the rest will be effective on July 1st.[00:08:00]
So, um, I just wanna talk a little bit of background about all these waivers. So, as Julie mentioned in my introduction, I’ve been working in the student loan industry since the earth cooled. Uh, and I gotta tell you, the last three years in the student loan industry has been bananas. I’ve never seen anything like this.
I’ve seen multiple, once in a lifetime scenarios, one of those being the Biden Harris debt relief. Another one being the public service Loan Forgiveness waiver. Stuff like this has never, ever happened before, and quite honestly, will almost certainly never, ever happen again. So why are they happening now?
Well, uh, it’s, it’s sort of a perfect alignment of the stars now, as everybody on this call knows. Uh, we don’t have a king. Uh, we have a president, and the president is bound by laws just like the rest of us are. Uh, and, and the sort of the overarching piece of law that we’re, we’re that. Is [00:09:00] relevant to this part of the discussion is the fact that as a general rule, the president of the United States can’t do anything that’s contrary to federal law.
So that’s why we’ve never seen in the past a scenario where a president has said, alright, we’re gonna loosen up on the public service loan and forgiveness rules. Um, because he can’t do that, because the majority of the public service loan forgiveness rules are written into federal law and are set by Congress.
Now, there is a piece of legislation called the Heroes Act. And the Heroes Act when it was enacted. Part of it said that in situations of national emergency, that the president of the United States can do things, uh, and I’m obviously paraphrasing here, can do things, uh, during the national emergency and during the national emergency only, that are contrary to federal law Now.
In short, what I’m saying here is we have Covid to thank for all of these for the most part, because if it wasn’t for the [00:10:00] national emergency that was created by covid, the, the current Department of Education and the president of the United States would not be able to do these temporary waivers, nor would they be able, this is the argument, um, the Heroes Act in the national emergency is the primary argument that the President of the United States is using to justify, uh, the Biden Harris debt Relief.
This also explains why they’re only temporary. There are a couple things that were in the PSLF waiver that are going to be made permanent because they weren’t in law, they were only listed in regulation. And the Department of Ed has been very busy over the past year and a half doing what it needed to do to make changes to those regulations permanent.
But again, for the most part, the PSLF waiver and what we’re gonna talk about with the income driven plan waiver is written into federal law. So only Congress can make those changes permanent. Um, are they at risk for reversal? Well, as, as we’ve seen, the [00:11:00] Biden Harris Debt Relief is being challenged in court and at this point it’s at the Supreme Court level.
Uh, for those reasons, the PSLF waiver. Somebody could have also chosen to challenge that, saying that it was, uh, an overreach of the president’s powers, um, under the Heroes Act and during the national emergency. And they, somebody could also choose to do that for the IDR waiver. Well, nobody that we saw filed any lawsuits against, uh, to challenge the PSLF waiver.
So that’s safe. And I haven’t even heard any chatter or Sabre rattling, so to speak, about the income driven plan waiver. So I feel like the risk for that is also very, very small. But as we’ve seen, um, you know, and as I mentioned, there were multiple lawsuits filed, uh, against the Biden Harris Debt Relief.
And, uh, I’ll talk about, I’m just gonna really quick do a quick overview of, uh, what I’m talking about, the Biden Harris debt relief, the eligibility for it, and then I’ll talk really quick [00:12:00] about where it stands. Uh, as far as the court goes. So the Biden Harris debt Relief is President Biden’s, um, fulfilling his campaign promise to offer student loan forgiveness.
Now, to be fair, he’s done this in many other ways, uh, over the last two years. Public Service loan forgiveness waiver. Um, the IDR waiver that we’re talking about, he’s done a lot to open up discharge for the most vulnerable borrowers to make it easy for them to get loan discharges. I’m talking about borrowers that were defrauded by their schools or borrowers that are considered permanently disabled, but sort of the, the big whammy is.
What they’re calling this Biden Harris Debt Relief. Now, in order to be potentially eligible for this, if this, if this does make it through the court challenges, you do have to have a Department of Education held federal student loan. That’s a Stafford Loan graduate, plus parent Plus or a consolidation.
Um, and it has [00:13:00] to be either a federal direct loan, um, a defaulted loan, um, or a fell or a Perkins loan that was consolidated prior to September 29th, 2022. If you have a Federal Family education loan program loan, or a Perkins loan that was not consolidated before that date, um, and is not held directly by the Department of Education, I’m afraid you’re not eligible for this debt relief.
Although the Department of Ed has expressed, um, the desire to try to find a way to loop those loans in, if you’re not, if you do have a fellow, a Perkins, uh, or if you’re just not sure. What kind of loan you have. Here’s an easy way to figure out whether the loan’s potentially eligible for this. Has this loan been eligible for the covid pause?
Meaning you’ve been enjoying a 0% interest rate since March of 2020 and you’ve enjoyed not having any payments due. You haven’t received a bill on your loan, uh, since March of 2020. If it falls [00:14:00] under that category, it is potentially eligible. Assuming you meet the other requirements for the Biden Harris debt relief.
If you’ve been getting bills or you’ve been getting charged interest, it is not eligible for the Biden Harris Debt relief. Uh, private loans were never eligible. Even private loans that were previously federal loans that had been refinanced into the private loan program. Unfortunately there’s no take backies on that.
Um, and those loans are not eligible. The other, uh, prong to this eligibility is income. Um, if you had an adjusted gross income as a single person of less than 125,000 in either the 2020 or the 2021 tax year, then you are eligible for this debt relief. They are not looking at 2022 and they’re only looking at either or 2020 or 2021.
So if in 2020 your a GI was $45 million, but in 2021 it was 120,000, you [00:15:00] are eligible for this debt relief. Um, for married couples or head of household, that income cap is, uh, adjusted gross income of 250,000. The only, uh, uh. Uh, sort of subset of that is someone who is con, who was in school, enrolled in school, an undergraduate program between July 1st, 2021 and June 30th, 2022.
Um, and you were under 24 years old or otherwise considered a dependent student for financial aid purposes. Tax purposes aren’t relevant. We’re talking financial aid purposes. In that scenario, your, uh, your qualifications will be based on your parents’ income, not on your income. And then the last thing I wanna mention about the eligibility is the loan had to have been, uh, at least have one disbursement sent to the school, uh, by June 30th, 2022.
Any loans that [00:16:00] were dispersed after June 30th, 2022 are not eligible and they cannot be made eligible. I. Now, how much is forgiven? Uh, well, all borrowers are eligible. All borrowers that fit the categories that I described are eligible for up to 10,000, uh, in loan forgiveness. Now, if at any point in your academic career, whether it overlapped you taking out loans or not, you received a Pell Grant, that forgiveness amount goes up to 20,000.
If you’re not sure if you ever received a Pell Grant, you can log on to student aid.gov, which is the Department of Education’s website, and it will tell you as long as you got the Pell Grant after 1994, it’ll be listed on that website. If you got a Pell Grant before 94, it won’t be on the website, but they will have knowledge of it and give you your eligi, your $20,000 eligibility.
You just don’t have a way to look it up. Now, in most cases, if you owe less than the amount of [00:17:00] forgiveness you’re eligible for, you will not get a refund. And I’m gonna give you a couple of examples of that in a minute. The only exception to that is if the reason you owe less than the amount of forgiveness you’re eligible for is because you made payments during COV, in that scenario, you will potentially get a refund.
Um, and again, I’m gonna show you some examples of that in just one second. Um, the eligibility for this forgiveness is on a borrower basis, um, not a family basis. So, you know, if, let’s say the Duggars, there are 19 kids and counting, um, every single one of them received a student loan, including Michelle and Jim, and every single one of them, uh, met the, the income requirements, then every single one of them would be eligible for the 10 or $20,000 in loan forgiveness, all 21 of them.
Um, so again, it’s per borrower, not per family. I. [00:18:00] So, as I mentioned, as far as refunds go, if you paid during covid, um, and the loan was eligible for the Covid pause, you can always request a refund of those payments, which is any payment made after March 13th, 2020. Now, if you still have a balance and you paid your loan below what you’d get in forgiveness during Covid, I, you’re gonna automatically get that refund.
If you paid your loan off during Covid and it was Covid eligible, you do have to ask for a refund now, so they open the loan back up and therefore, uh, make it eligible for any potential forgiveness that you’re eligible for. If the loans aren’t eligible for covid, they’re not eligible for refunds, they’re also not eligible to be opened back up.
If the reason the loan is paid in full is because you either consolidated or refinanced it, that’s it. No take back, no refunds. You cannot open the loan back up, I’m afraid. Now let’s look at the examples just [00:19:00] to try to hammer this home. ’cause it people do get, we get a lot of questions around the refunds ’cause it can be a little bit confusing.
Let’s talk about George. George has all direct loans, which of course are covid eligible loans. Um, when the po, when the Covid pauses began March 13th, 2020, he owed 23 grand. Now, during the pause, he’s been taking advantage of the 0% interest rate and he’s paid about $6,000 in the last three years. So right now his balance is 17,000.
Excuse me. Now, George did get a Pell Grant during his academic career and he meets the income requirements. So he’s eligible for 20 grand in debt relief. Once they apply that debt relief, he will get an automatic refund of $3,000. And that’s because, um, his balance is lower than the amount of forgiveness he’s eligible for.
And the reason it’s lower is because he made payments. Um, he made payments during covid. Now let’s talk about [00:20:00] Zeke. Zeke and George have pretty similar scenarios except that for a little bit of a difference. Zeke also has direct loans, which again are also eligible for the Covid. Pause. Um, when the pause began on March 13th, Zeke owed only 17,000.
Now, during the pause, he hasn’t made any payments, which is fine. He hasn’t been due for any payments. Zeke also received a Pell Grant during his academic career, and he meets the income requirements, so he’s also eligible for the 20 grand in debt relief. Once that’s applied, assuming it gets through the courts, he will also have a zero balance just like George, but he’s not gonna get a refund.
And the reason he is not gonna get a refund is because he was at 17 grand to start with and didn’t make any payments during CO that brought the balance down below his forgiveness level. Um, now if the. If this, the Biden Honor Debt Relief does get approved by the Supreme Court, uh, they will once again open the [00:21:00] application and the application will be super easy to find on student aid.gov.
Um, if that time comes, it’s just gonna be a pop-up window as soon as you go to the website. In the meantime, you can actually go to that same website and there’s banners at the top of the page that you can click on, and it’ll give you a place to sign up for email alerts. So, um, if you wanna know, as soon as that application opens up, again, you’ll get an email alert for that.
Now, there’s about 8 million borrowers that actually won’t have to apply at all. That’s gonna be a borrower who submitted a FAFSA or maybe submitted, uh, proof of income for an income driven plan in 2020 or 2021. If you were one of those people, you would’ve already received an email giving you the opportunity to opt out of the forgiveness.
Why would you wanna opt out? You might ask. Well, there’s some, uh, there’s a couple states, I believe we’re down to four, that are gonna tax this forgiveness as income. It will not [00:22:00] be taxed on the federal level and it will be not be taxed, um, in the other states other than these four. Uh, but for borrowers in those four states, uh, some of them are either pursuing public service loan forgiveness, which isn’t taxed, or perhaps they’re receiving some sort of income-based benefits such as a housing benefit that this forgiveness would put them over the income threshold and they might lose their housing benefit.
If you didn’t get an email already saying that, um, giving you the opportunity to opt out, you are not one of the people that won’t have to apply. And if and when the application opens back up, you’re gonna wanna make sure that you do apply before, uh, the end of this year. Now, originally before this got tangled up in the courts, uh, when they announced it in August, their intention was for anybody that had applied, uh, by mid-November.
Um, now, back then we thought payments were gonna resume in January, so the goal was to have anybody that applied by [00:23:00] mid-November to have their forgiveness applied by January. Now, obviously, both of those, those thresholds have passed, but it gives us a, a sort of peak into what we can expect the, we might expect the timeline to be if and when this opens back up and it appears like they feel like they’re gonna be able to process the majority of these within six weeks of the time they receive and approve the application for forgiveness.
Now, the application itself could not be easier. You don’t have to log in. You don’t have to submit and upload any documents. You literally just have to put in your name, your social security number, and electronically sign a statement that under penalty of perjury, the information you’re supplying is true, including verifying that you meet the income threshold.
Now, unfortunately. Sometimes the reason we can’t have nice things is there’s always gonna be someone that tries to get around the system, so to speak. And the Department of Education, you know, in addition to [00:24:00] facilitating financial aid and student loan programs and um, you know, sort of all aspects of education in this country, they also are required to be a steward of.
You know, US taxpayer funds and that’s what these are our US taxpayer funds. Uh, so in recognition of that, they have baked in some AI and algorithms into the process for forgiveness to try to identify people that may not have necessarily been telling the truth when they submitted the application. They also are going to randomly require about 5 million borrowers to go through a process that we’re calling verification.
If you’re re, if you get notified after you submit your application that you have been chosen to do income verification, you’ll be required by March 31st, 2024. To submit proof of income either through your, uh, tax return, a tax transcript, or if you weren’t required to file taxes, a letter [00:25:00] from the IRS verifying that you weren’t required to file taxes.
If you are chosen for verification and you choose not to submit it or don’t submit it by March 31st, you can’t get the Biden Harris debt relief, and there’s no appeal to it, and you will never be able to get it.
Another question we get quite often is how they’re gonna apply the, uh, if, you know, do I have a choice of where they apply the money? The answer is no, but that’s okay. Uh, because I think most borrowers will be pleased with how they’re planning on applying it. Uh, the hierarchy is they’re gonna start with any defaulted loans.
Then if you don’t have any loans in default, they’re gonna look for the loan with the highest interest rate. If all your loans have the same interest rate, they’re gonna look for loans that don’t have any type of interest subsidy allowed to them. Um, and if, if all your loans are either subsidized or unsubsidized, they’re gonna go with the most recent loan, and then they go look at balance.
And then once [00:26:00] they apply the forgiveness, they’re going to re amortize your loan, which means that unless you’re on a payment plan, based on your income, your payment will probably go down.
Now where we’re at with the lawsuits is, uh, you know, most of the lawsuit. There was a flurry of lawsuits that were filed when this was first introduced in August of last year. Uh, but most of them didn’t have what we call standing, meaning that the people filing the lawsuits couldn’t prove how they would be harmed by the plan.
And that’s a, a key to a, to a lawsuit. There were a couple. That sort of squeaked by on that. Um, and in the end, you know, long story short, the White House just sort of said enough, we don’t wanna prolong this. We wanna be able to allow our student loan borrowers to move forward. And they actually asked the Supreme Court to take a look at this and they asked the Supreme Court to fast track it.
So I’ve had a lot [00:27:00] of people say, why is this taking so long? Well, in the realm of the Supreme Court, this whole thing is going remarkably fast. Uh, they’re going to be hearing oral arguments, uh, around the 28th of this month. And they’ve stated that they’ll issue, you know, based on that we can expect to get an opinion by the end of June.
So, um, I get asked a lot where I think this is gonna land. Well, I’m a failed pessimist. Um, so from that perspective, um, you know, I’d like to think that I. The Supreme Court will see that A, the plaintiffs likely don’t have standing, uh, and b, whether the plaintiffs have standing or not, that this fits squarely under the intent of the Heroes Act.
Uh, but you know, as I like to tell everybody, we should all be hoping for the best, but preparing for the worst. All right. Any questions about that before I, I, I move on to, uh, the PSLF and IDR waivers, pat. [00:28:00] No, you’re good. Okay. Thank you. All right. So, um, I wish I had seven hours to go over all this stuff with you, but I don’t.
Um, so some of this stuff I’m gonna have to go cover at a high level. I can, I just wanna remind you that we have all the information about these programs in gory detail, and I’d like to think plain English. That includes pretty extensive FAQ documents on our website. If you go, uh, the public service loan forgiveness stuff is under our forgiveness page and the income driven plan stuff is on our repayment plan page.
But just to get everybody on the same page, um, I wanna do a quick overview of the rules for normal public service loan forgiveness rules. Now, PSLF gets. It’s kind of a bad wrap for being the rules being confusing. But if you take a step back and look at it from not [00:29:00] even the 10,000 foot level, but the 5,000 foot level, it’s actually fairly simple.
Um, and so, you know, I always say I use this slide all the time when I talk about PSLF because I think if you remember this slide. You are gonna be able to answer 85% of the questions you’ll ever have about the normal public service loan forgiveness rules. So in order to get the balance of your loans forgiven under PSLF, you’re required to make 120 eligible payments on an eligible loan while working for an eligible employer.
Now, the key, now I’m gonna go over really quickly what all the eligibles mean. Um, and again, the details of all those eligibles are on our website, uh, [email protected]. But the key, the point I’m trying to make with this slide is that in order for a month to count towards PS LF, you have to meet all three of these prongs.
And they all have to happen at exactly the same time for a month to count. So you could be making an eligible payment [00:30:00] on an eligible loan, but if you’re not working for an eligible employer at the time, that month will never count under normal PSLF rules. And you can mix and match that and come up with the same answer.
You could be working eligible employment, have eligible loans, but if you’re not making an eligible payment, that month’s not gonna count Under normal PSLF rules.
Now what, um, you know, just to quickly go over, you know, defining all these eligibles, um, an eligible loan is any federal direct loan. Doesn’t matter when that loan was made. Um, a direct loan can be a Stafford loan, a graduate plus loan, a parent plus loan, or a consolidation loan. An eligible payment under traditional PSLF rules is one that’s made on time, one that’s made under either a 10 year standard plan or any of the income driven repayment plans that’s made on a direct loan while working eligible employment after ten one oh seven.
And while the loan’s [00:31:00] not in default. Also under traditional PSLF rules, if you consolidate, um, they’re not gonna count any payments that you made prior to that consolidation. Now that’s a big piece of these waivers. So sort of put a pin in that in particular for a minute. Eligible employment is working full-time, which as of November 1st is now defined as 30 hours a week.
Even if your employer considers 40 hours full-time as of November 1st, as long as you’re working 30, it counts for PSLF and that you’re working either for a government employer, that’s federal, state, local, or tribal, any 5 0 1 C3 nonprofit. And then there are some other nonprofits that count. But their primary reason for being has to be, um, one of a list about a, of about a dozen functions that include primary, uh, public education, public health, public library services, uh, public legal aid, um, that kind of thing.
[00:32:00] You do have to be a direct employee. Uh, that means that if you’re a contractor, um, unless the. Their, your contracting company that you work for is in and of itself, A-P-S-L-F eligible employer, which most of the time contractors are private employers. Um, it’s not gonna count, um, if you are, um, you know, working for yourself and have an individual contract with the company.
Um, so you get a 10 99 in the mail, uh, that does not count for PSLF purposes. Uh, but so you do have to be working directly for the eligible employer. Now I tell you all of this. So to help you understand why the waivers, what the difference in rules are for the waivers and what exactly the waivers waived.
Uh, one other thing I wanna mention is this Covid period. So since March 13th, 2020, um, on COVID eligible loans, all of these months have [00:33:00] counted towards both PSLF as well as the income driven plan, forgiveness, uh, pieces. Now for PSLF, you did still, you do still have to be working for an eligible employer for the month to count, but you shouldn’t have been paying, if you’re pursuing PSLF, you should not be paying during covid.
It’s literally the same as throwing money and flushing it down the toilet. Um. So if you have been paying during covid and you’ve been working for an eligible employer and you’ve been pursuing PSLF, uh, you should, as soon as you get off this webinar, you should be calling your loan servicer and asking for that money back.
Um, and they will happily send you that money back fairly quickly. Okay, so let’s talk about the waivers. So last October, so October of 2021, I, so I should say two Octobers ago, the Department of Education, um, announced a temporary public service loan forgiveness waiver. And what that waiver did [00:34:00] is it essentially wiped out a lot of the eligible payment rules that we just sort of skimmed over.
So they were essentially counting, um, as long as you submitted, uh, A-P-S-L-F form. So proof of some sort of PSLF eligible employment. By October 31st and assu, if, if you didn’t have direct loans, like if you had fell or Perkins loans, that you consolidated into the direct loan program by 10 31 of 2022, that you could get credit for pretty much any payment, even if that payment had been made on a fell loan.
If it had been late, if it had been, um, not under an income driven repayment plan, uh, if it had been prior to a consolidation, they were counting them all. And we’ve worked with a lot of borrowers that have received a lot of credits that they either thought they’d missed out on or shouldn’t have been able to receive, um, under traditional PSLF rules.[00:35:00]
So that waiver had a hard stop of October 31st. If you didn’t raise your hand, uh, by October 31st, then you weren’t gonna be able to take advantage of that PSLF waiver. However, uh, on October 25th, they, um, made an announcement about giving us more information about something we’d already sort of heard chatter about, which was what they’re calling the income driven plan waiver or income driven plan, one time adjustment Now.
The income driven plans have their own forgiveness component baked in. So essentially if you are on an income driven plan for either 20 or 25 years, and that depends on your loan type and or which plan you’re on, and the loan isn’t paid off after being on an income driven plan for the 20 or 25 years, then the government forgives the balance.
Um, now if you remember, you have to be on an income driven [00:36:00] plan under traditional PSLF rules for a month to count for PSLF. So what they’re choosing to do is use this, and this is what they announced on October 25th, is they’re choosing to use the income driven plan waiver. To essentially do a backdoor extension of the public service loan forgiveness waiver.
And then there’s actually even some additional benefits there. So I’m gonna talk about those in a minute. But first, let’s back up and do a little primer about what, um, about the income driven plan and the traditional rules for the income driven plans. Now there’s technically five IDR plans, and they’re all exactly the same except where they’re different.
All of them base the payment on your income and your family size. And by income, I’m talking, we, we call it discretionary income, and all the plans are a little bit different, but essentially they [00:37:00] take their poverty level for your family size and subtract that or subtract in some plans, subtract 150% of that.
From your adjusted gross income, and that’s what they, that’s the income amount that they’re using in the calculation. Um, all the income driven plans require you to reapply on an annual basis. So you’re pay, assuming every time your income, every year, assuming your income changes, your payment’s gonna change and it can go up.
Work can go down depending on, on the change in your income. Um, as I mentioned, if you’re on an income driven plan, um, any of the plans, and you can mix and match. You don’t have to be on the same plan for the whole 20 or 25 years. But if you’re on, uh, a plan for the 20 or 25 years, they do forgive the balance.
Uh, it doesn’t matter what you do for a living or, or even if you’re working for that matter. Uh, and it certainly doesn’t matter who you’re working for or how many hours a week that you work. Your employment [00:38:00] isn’t, um, uh, a factor here. Uh, only your income is a factor. Now under traditional IDR rules, if you consolidate, it does reset your IDR count.
So if you had, say, 12 years of IDR payments under your belt, and then you consolidated outside of these waivers, um, it, your IDR count would go back to zero and you’d still have 20 or 25 years in front of you. Now the plans that we’re talking about are called, uh, we call it old IBR, uh, that’s, uh, has been around since 2009, uh, because we’re not super creative in this industry.
There’s another one called new IBR, which has very different roles than old IBR does. Excuse me. There’s the Pay As You Earn program. There’s the Revised Pay as You Earn program, and there’s the income contingent contingent repayment program. Now, ICRI wanna sort of pull that out for [00:39:00] a minute. Parent Plus Loans, um, which are eligible for PSLF.
Unfortunately, they’re not eligible for any of the IDR plans unless they consolidate. If they consolidate, they then become eligible for the ICR plan. And that plan only. Now we don’t really have time to go into it in, in detail. We do have it described on our website. However, there is a loophole for Parent plus loans that we call the double Super secret consolidation loophole and what that is, and it’s completely legal.
Um, it’s just not talked about. If you could consolidate your parent plus loan twice, um, and we explain how to do that, um, again on our website, then it does open you up to the other income driven plans and that can be important ’cause ICR not all the time, but a lot of the times ICR tends to be the more expensive plan than the others.
Uh, again, [00:40:00] there are some exceptions to that. Um, but if that’s your situation and especially someone who that plan might not be affordable or you’re trying to pay the least amount possible because you’re pursuing public service loan forgiveness, it might be worth looking into the double super secret consolidation method.
Um, now getting back to the income driven plan waiver. So the income driven plan waiver is similar to the PSLF waiver in that they’re going to be giving people credit for every month that they were in repayment, and in fact, some months that they were in, even in deferment or forbearance, um, towards the 20 or 25 years needed for income driven plan forgiveness, even if they weren’t on an income driven plan.
Um, now this applies to the IDR waiver is gonna be applied. You don’t have to, there’s no, I keep using the word apply, but you actually don’t even have to apply [00:41:00] for it. It’s just gonna happen. Um, it’s a one-time adjustment. We’ve never seen it before. We’re never gonna see it again. You don’t have to call.
Calling actually isn’t even gonna do any good. Uh, but if you have an eligible loan, once they do the adjustments, it’s just gonna happen. Um, and it’s gonna apply to any Department of Education held or managed Stafford Loan, graduate plus loan. Parent plus loan, uh, and any, uh, direct that includes consolidations and it includes consolidations, uh, where the consolidation has some fell loans or Perkins loans or other federal loans in it, as long as you consolidate by May 1st, 2023.
Now, if you already have all direct loans, you may not need to consolidate at all, especially if they’ve all been in repayment for the same amount of time. Uh, but if you have fell loans or Perkins loans, you definitely wanna consider consolidating by May 1st in order to get, [00:42:00] uh, the value of this IDR adjustment.
Again, if you’re not sure if your loan is eligible for this, has it been eligible for covid? If it’s been eligible for covid, meaning you’re, you haven’t been billed for the last three years and you’re enjoying a 0% interest rate, that it, your loan is eligible for the IDR waiver, and you likely don’t need to take any action.
Now, here’s where it becomes sort of a backdoor extension for 90% of the the PSLF waiver as well. Now. Under the idea, as I mentioned, under the IDR waiver, they are going to count any payments you made on a fell or a Perkins loan prior to consolidation or any other loan for that matter prior to consolidation as long as you consolidate by May 1st, and they’re gonna apply that to both the income driven plan forgiveness, the 20 or 25 years, [00:43:00] as well as PSLF forgiveness, assuming that you were working, uh, full-time for A-P-S-L-F eligible employer during that month.
Here’s a big difference for no good reason, they excluded Parent Plus loans from the PSLF waiver, however, they recently and pretty quietly announced that they are including Parent plus Loans in this IDR waiver. So here’s the chance for our poor parent plus borrowers who weren’t able to take advantage of the PSLF waiver to actually get PSLF as well as income driven plan credit.
Now they’re also gonna count payments if they had been past due or not, or haven’t paid enough. Doesn’t matter what payment plan you were on, the only thing that won’t count are periods of default. And again, for PSLF purposes, they won’t count towards PSLF any payment made, uh, prior to October of oh seven.
Now, they’re also [00:44:00] gonna count some periods of deferment and forbearance, but they’re not gonna count those until they actually implement the income driven plan. Um. One time adjustment, and I’ll talk about the timing of that in a minute. Now, one thing that was not extended, uh, so again, essentially the entire public service loan forgiveness waiver has been extended because of this IDR uh, waiver.
It. The two things that aren’t, um, under the PSLF waiver, if in the past you’d received teacher loan forgiveness, uh, normally you can’t double dip the time that you used, uh, to qualify for teacher loan forgiveness also towards PSLF, but they were allowing it during the PSLF waiver that that ship has sailed.
It sailed away forever. We will never see it on the horizon again. So, uh, unless you took advantage of that prior to 10 31 of 2022, uh, you’re not gonna be able to do that. The other [00:45:00] piece that’s gone forever is public service loan forgiveness requires that you be working for an eligible employer, not only for every one of those 120 months, but also at the time that they process your forgiveness.
Um, unless you hit the one 20 by October 31st and had submitted, uh, your proof of eligible proof of at least some eligible employment by then, um, that that piece is also gone forever. Um, so if you don’t hit one 20 until after October 31st, 2022, make sure you stay at your PSLF eligible job until you actually get that forgiveness letter in the mail and your balance shows a zero
Now. Um. What’s unclear when they do the adjustment? What’s unclear is how far back are they gonna go, uh, towards the income driven plan, forgiveness. [00:46:00] Um, you know, there’s a couple different scenarios they could go back. Um, you know, obviously they’re only gonna go back. The earliest they could go back is.
You know, however old, old your loans are. But let’s say you had loans from the 1980s. Now, the first income driven plan wa that ever existed was income contingent, and that was put into law in 1994. But very, very few people have used it over the years. The first widely used income driven plan came into play in 2009, and that was what we call old IBR.
Um, the Department of Ed is not publicly said how far back they’re gonna go, so they could go back to the beginning of time. So if you have loans from the eighties, uh, assuming that they’re not already direct loans, but you make them a direct loan through consolidation by May 1st, you would get immediate forgiveness, uh, once they do the adjustment on your account.
But again, we don’t know yet how far back they’re gonna go. Um, if you [00:47:00] consolidate by May 1st, it will not reset the count. Now, I’m gonna talk a lot more about this in a second because to say there’s been misinformation, uh, or contradicting information out there about this aspect of the IDR waiver is an understatement, and I’m gonna address that, uh, more fully in a second.
Um, if you have loans that have different counts, so the most common example is, let’s say you went to undergraduate school, you took out loans, you were in repayment on them for a while, and then you went to graduate school and took out more loans. So your undergraduate loans have been in repayment, say for 35 months, and your graduate loans have been in repayment for 12 months under this waiver and under this waiver only.
If you consolidate by May 1st, once they do the income driven plan adjustment, your consolidation will get credit for the higher count. So the example I gave, you’d get the entire consolidation would get credit for the [00:48:00] 35. That includes public service loan forgiveness, and that includes parent plus loans.
Now, let me address the miscommunication that’s been out there about this. We are very aware that some of the servicers have been saying the opposite, that the servicers have been saying that unless you consolidated by the end of the PSLF waiver that uh, your count would reset to zero forever. Uh, sometimes they’re saying that for both the IDR as well as PSLF, sometimes they’re just saying it about PSLF.
Sometimes they’re just saying it about direct loans. Um, we, we are very aware of this. Um, we have spoken to the Department of Education on multiple occasions and have been reassured that that is not the case. Um, our understanding is that they will be coming out with some FAQs. I don’t know when, hopefully sooner rather than later that we’ll further [00:49:00] clarify this.
Now with that said, I under, I also understand how this can, cause, you know, this, getting different messaging can cause a lot of anxiety. So remember, you have until May 1st to consolidate to if you have different counts. Um, if you don’t have different counts, you don’t need to consolidate, you don’t need to worry about it anyway, um, unless you have Feller Perkins loans.
But if you do have different counts and could stand to benefit from consolidation, giving you the higher count, um, and you want something different than some lady on a webinar telling you that it’s okay, um, I just wanna reassure you, you have till May 1st. And Lord, we do hope that those FAQs come out well before May 1st.
I also wanna further clarify. That the consolidation won’t have to be complete by May 1st. You will have just had to have applied for consolidation since submitted a completed application by May 1st in order to get that higher count credit [00:50:00] under this waiver. Now, this is not official and you know, everything, I have, almost everything I’ve told you at this point has been fact other than maybe when we were talking about the Supreme Court stuff, and I was sort of giving some speculation around that.
But everything else I’ve told you here has been fact. Um, the next thing, the next thing that’s about to come outta, outta my mouth falls under rumor, innuendo and speculation. Um, I’ve been hearing some chatter that they’re, they may actually extend that May 1st deadline, but I have nothing even remotely concrete.
So, uh, once you’re comfortable enough with the information, again, if you’re gonna benefit from consolidating, if you’re not gonna benefit, there’s no point in consolidating. Um, I wouldn’t drag your feet any longer ’cause there’s no guarantee they will extend that May 1st. And what, again, what I’ve heard is to call it chatter may even be more substantial than what it is.
Um, but there’s a [00:51:00] chance, um, now for both the IDR waiver and public service loan forgiveness in general. And this applies. Even outside of the waivers. But if it turns out that once they apply your public service loan forgiveness payments, and or once they do the income driven plan adjustment and count the number of years you have under your belt towards income driven repayment, forgiveness, it turns out that not only do you have forgiveness, but that you’ve overpaid, they’ll automatically send you a refund.
The only exception to that. Is if, um, the overpayment happened before consolidation. So for example, let’s say you consolidate tomorrow, uh, based on this webinar, and then once they, and then you don’t make any more payments because you don’t need to, ’cause you already have either the 10 years for PSLF or the 20 or 25 years for the income driven plans and they process it and they figure out, yep, you have forgiveness and you actually technically [00:52:00] overpaid by three years.
In that scenario, you wouldn’t get a refund because all of that overpayment happened prior to the consolidation. But let’s say you consolidated three years ago and you’ve made three years of payment since then and they process all of this and it turns out you’ve overpaid by three years. In that case, you would get a refund.
Um, before I do sort of a quick review and, and move forward, pat is, are there any questions you think I need to address? No, Betsy. Really? Wow. I, I didn’t, I just wanna make sure I didn’t make anybody nervous. I didn’t say you couldn’t ask questions in the beginning. I just asked people to hold off until I covered the thing.
Um, so, you know, let’s put Pat to work there. Betsy. There have been some. Oh, all right. All right. I just wanted to make sure you weren’t just sitting there smoking cigars and, and, uh, I don’t know, playing Tetris or something. [00:53:00] Um. Okay, so I, I understand I’m repeating myself, but this is stuff we get questions about all the time.
So there is a method to my madness. Um, so the following things are temporary exceptions through May 1st, 2023. Consolidation will not reset either the PSLF or the IDR count. Now when I say that, it will initially reset the count, so don’t freak out. Um, when you first apply for consolidation, the first terribly scary thing that’s gonna happen is you’re gonna get a letter from eight Advantage.
Eight Advantage is the servicer that processes all the consolidations. And that letter is gonna say, Hey, are you sure you wanna do this? ’cause if you do it, it’s gonna reset your PSLF and IDR count forever. Um. Ignore it. I know it’s terrifying, but ignore it. That letter is based on the traditional PSLF and IDR rules.
Believe it or not, it takes the government [00:54:00] forever to change the language on an official letter. And, um, this, all this stuff was supposed to be for a very short window of time, not three years. So that’s why they never got around to changing that letter. So that’s the first terrifying thing that’s gonna happen.
The second terrifying thing that’s gonna happen is once the consolidation’s complete, if you, you know, hum along and log into your account to check your PSLF count and your income driven plan count, it’s gonna say zero and you’re gonna go. That Betsy, she gave us bad information. Um, well no, I gave you the correct information because initially it’s gonna be zero ’cause it’s a fresh new loan.
It’s not until they process the income driven plan one time adjustment will you see those counts reappear. And what’s gonna make that even more nail, more of a nailbiter is that adjustment’s not gonna happen for a wicked long time. And I know I’m showing my Boston when I put it that [00:55:00] way. Uh, but you know what they, if you look at the Department of Education’s income driven plan, one time adjustment page, they intimate that for most people, they won’t see that adjustment till the summer of this, this summer.
Um, I have heard. When I, I’m gonna say chatter again, but this is more substantial than the chatter I’m hearing about the potential extension of the May 1st date. That at best we’re not gonna see the adjustments done until this fall. Now there are a couple lucky borrowers that they are doing the IDR adjustment for as we speak, but that’s only borrowers where doing the adjustment would give them PSLF forgiveness immediately.
And it’s not even all of those. Um, so again, it’s gonna be scary because first you’re gonna get the letter saying, Hey, this is gonna reset the count, and then you’re gonna see your consolidation and your account’s gonna be reset, and then you’re gonna wait and wait, and wait, and wait and wait. But it will happen.[00:56:00]
Um, if, again, if you have loans that have different counts, it will get assigned to the higher count, assuming you consolidate by May 1st. Um, and if you consolidated more than once, they’re gonna do a look back on all of those consolidations. So, you know, I have borrowers, especially with older loan, older fell loans that have consolidated more than once, and they’re gonna, again, look back before, uh, um, they’re gonna look back Prior to all of those consolidations, uh, I already talked about the timing.
Um, we get a lot of questions about, well, should I pursue PSLF or the Biden Harris Debt Relief, or the IDR waiver? And I say, why not? All three? Um, for the most part, one, pursuing one does not exclude you or, or make you ineligible for the other. The only exception to that is my poor fell borrowers. If you have FFEL loans and your service, if, if you took your loans out prior to [00:57:00] 2010, um, and you haven’t consolidated since 2010, there’s a chance you do have these FFEL loans.
Um, and again, these are loans that would not have been eligible for the COVID waiver, so you would’ve been getting billed and accruing interest over the last three years. Um, you have to consolidate by May 1st in order to get credit for the IDR waiver or this sort of backdoor extension to the PSLF waiver.
But doing so will exclude you from the Biden RIS debt relief, and you can blame, uh, the lawsuit filed by the, what was, it had six states. Missouri, Indiana, whoever else. Um, it’s because of them that, that unfortunate and silly rules in place. So if that, if that describes your situation, you’re gonna have to figure out, um, if you’re gonna get more bang from your buck for the Biden Harris debt relief, if it even gets through scotus, uh, or the IDR or PSLF [00:58:00] waiver.
Okay. Cup, just really, really quick, I know we’re on our, at the end of our time. Uh, as I mentioned, there have been some permanent changes made to public service loan forgiveness. The vast majority of them will not be, um, in place until July 1st of this year. Uh. One of those is they’re getting rid of the, the piece of PSLF that says that if the payment’s late, they don’t count it.
Um, you can be late on a payment as long as you make the payment up later, they will still count it. And assuming you meet all the other PSLF eligible rules, uh, lump sums payments that’s been in place for a while, but they actually finally put it into the regulations, lump sum payments will count in a limited way up to no more than 12 payments.
Um, no matter what, just to be clear, you can never get credit for more than one month at a time. But if your payment’s a hundred dollars a month, um, and [00:59:00] in January you pay $1,200 and then don’t pay again for the next 12 months. That used to not count for PSLF, but now it will count, uh, for the most part.
For PSLF, as I mentioned, and this is already in place as of November 1st, full-time now means 30 hours a week regardless of what your employer considers to be full-time, they also are. Uh, you may not have been aware of this, but for the most part, our poor adjunct professors have been sort of, uh, edged out of PSLF, uh, because of the way the regulatory language read and because of the fact that most colleges and universities don’t consider adjunct professors full time.
While they have put, um, a caveat in place in the regulations. So effective July 1st, there will be a way for adjuncts to qualify, assuming that they’re teaching enough credits regardless of, of whether their college or university considers them full-time or not. Going forward. They’re also gonna count periods of economic [01:00:00] hardship, deferment, military and cancer treatment deferment towards PSLF, assuming you are also working full-time, you know, at least 30 hours a week for an eligible employer during those deferment periods.
Um, one thing I forgot to mention about the IDR waiver and shame on me. I mean, I think I mentioned it, but I think I sort of glossed over it. Um, they are going to count periods of deferment, um, other than in-school deferment towards IDR forgiveness. Um, for the most part, uh, any deferment other than an in-school deferment prior to 2013 will be counted under the one-time adjustment.
Um, and for deferments after 2013, they’re gonna count economic hardship, uh, military. Uh, cancer treatment deferment. And also if you’ve used, uh, what they consider to be an excessive amount of forbearance over the years, which means either 12 consecutive months or [01:01:00] more than 36 cumulative months, uh, for this one time adjustment only, they’re gonna count that towards the income driven plan waiver as well, which means it’ll also count for PSLF.
But again, that’s just under these waivers. What else did I have? Betsy? Are you gonna mention the new IDR plan? I was not going to, but if we have time afterwards I could talk about it. And I just wanna be, in case we don’t end up talking about it, I wanna make it super clear this is a proposed plan. This is not a done deal by any means at this point.
Uh, but if we have time, then somebody was interested in that. Okay. Um. A couple other changes that are coming up July 1st. Most periods of interest capitalization are going away forever, which is awesome. Um, and then they made some other changes [01:02:00] that are particularly helpful to some of our most vulnerable borrowers, such as those pursuing discharge because of permanent disability, if their school closed while they were attending or if they were defrauded by their school.
And we will once those rules are in place. So, you know, after July 1st, we will be updating our website with that language as well. Now, um, here’s some resources for you. Student aid.gov, the Department of Ed’s website, our website of course, which is free student loan advice.org. And then I’ve posted the links to the announcements about these waivers in particular, so you can read it for yourself.
Um. I’m gonna see if there’s any more questions about our content today, and then if Julie says, okay, um, I will spend 37 seconds talking about the proposed, uh, revised repaid plan and I am fine with that. I think we all are fine with that. Let me just see, I don’t see any current [01:03:00] questions. So, uh, pat, is there anything you think I need to reiterate or say in a clearer way?
Um, don’t think so. Okay. I mean, frankly, I mean, I know some people are confused, but, um, those people, I really encourage you to go to our website and you, there’s a contact us button where you can send us questions directly and that’s often the best way to walk you through these. They’re very complicated.
Some of them are very complicated issues. Okay. And make sure you use the Tesla email, not the Betsy email. Uh, the Betsy email can get lost in the day-to-day stuff. Um, so, you know, borrow questions should go directly to the Tesla email. If you have questions about Tesla as a organization, do, you can use the Betsy email.
Um, all right, so the revised repay plan. So, um, [01:04:00] about a little over a month ago, the Department of Education finally issued draft regulations, which is essentially a proposal to change the existing repay plan to a much more generous plan now. Uh, we, the con the public comment period for those proposed rules just ended last Friday.
Um, and they received th tens of thousands of comments on it. Uh, where it stands now is that they are required to read all those comments and then at some point they’re gonna issue what’s called the final rule, and they may very well, uh, make changes based on those comments. They’re also getting a lot of negative pressure from, um, members of Congress about the cost of this plan, which is why I’m emphasizing so much that this is just a draft.
But if, and this is a big, if the plan was to be [01:05:00] issued final rules the way it was written in the draft, what it would do is it would. Significantly lower the payment for a lot of borrowers by doing two things. Um, number one, instead of using a hundred or 150% of the poverty level for the borrower’s family size to be, uh, subtracted from their adjusted gross income, it would be 225%.
So you’d be starting from a much smaller, um, income level to begin with. The other thing it does is right now all the income driven plans, once they’ve determined what your discretionary income is, they take either 10 or 15 or 20% of that depending on the plan. And that’s how they figure out what your monthly payment’s gonna be.
Well, under this, for some borrowers it would be 5% and uh, that’s borrowers with undergraduate loans. And for borrowers with graduate loans, it would be 10%. And for borrowers with a mix, it would [01:06:00] be, um, 7.5%. So it also not only lowers the income amount they’re starting with from the fir in the first place, they’re also lowering the amount that they’re gonna take from that income amount to be your payment.
The other thing this revised repay plan would do is if, if you only ever borrowed in the first place, less than $12,000. And you’ve been on the revised repay plan, which doesn’t exist yet, but you get on the revised repay plan and you’re on it for 10 years and you still have a balance after the 10 years, then they’re gonna forgive it after 10 instead of after 20 or 25.
But that’s only if you only ever borrowed 12 grand to begin with. So if you borrowed 50, but now you’ve paid it down to 12, this wouldn’t apply to you. The way this draft rule is written, um, it does exclude Parent Plus, um, from my read, uh, parent Plus Loans would still be [01:07:00] able to do the double super secret consolidation and be able to get into this plan.
But again, that’s based on where the draft rules read. And this plan could change significantly or it might not change at all. By the time we get the draft rules to come out. Now, the next question becomes, well, when are the final rules gonna come out? I don’t know. Um, I would su so if I was a betting woman, I would say we are not gonna see the, the final rules until at least this fall.
And then it’s gonna be some time after that, before people are gonna have access to it, because this would require a significant programming change on the servicer side and significant, um, disclosure and other type of written information. And that stuff takes a long time. Now the Department of Ed really wants it out.
Uh, if you talk to the Department of Ed, you’ll, you might hear them say, well, we wanna have it available by this summer. We wanna have it available by the time payments resume this [01:08:00] fall. Um, and if they do it, more power to them. But I, as I said before, I, and I’m not being a Debbie Downer here, I’m just being pragmatic.
Um. The Department of Education has a lot of really big projects, and Congress has denied them additional funding to fulfill those projects. So I will be personally surprised, delighted, but surprised if this thing is in place by this fall, I would be, I will be delighted if we even see the final rules by this fall.
So, I, I’m, again, not trying to be a Debbie Downer, just trying to set expectations.
Alright. Um,
let’s see.
I see, uh.
Any other questions? I see. I do see people saying they [01:09:00] were confused and that means I didn’t do my job very well. I mean, this stuff is pretty confusing. Um, but if you wanna post another question I could take of something you’d like me to go over again, I’m happy to take a shot at it. You did your job.
It’s there. There’s just such a level of detail here that of course there are just so many confusing parts. I know. The only, the only other thing I’ll add is, you know, I, I do wanna thank MEFA again for, for hosting this and for all the webinars they host. Um, I will say in Pat and I’s experience, the borrowers that do get some sort of proactive education about these programs are much, much more successful.
And I’d like, you know, especially for public service loan forgiveness eligible employers, I mean, this is a real free benefit that they can offer to their employees. And, and Pat can verify for me, we work with a lot of borrowers that specifically look for jobs or looking to stay at [01:10:00] jobs because they are PSLF eligible jobs.
So. If you are a working for A-P-S-L-F eligible employer, I encourage you to encourage them to offer some sort of proactive education to their constituents. And it doesn’t even have to cost them anything. It could be as simple as providing a link to either the Department of Ed or our PSLF page. Uh, but it could be a real game changer.
And again, it’s a, it’s a free benefit that these employers can offer and it really makes a difference. So thank you Julie, and the rest of the MEFA team for recognizing that and offering this to your audience. Well, thank you and we will continue to do that as things evolve as well. Um, and thanks to you Betsy, I will just, I see two questions, uh, both about taxation.
Do you think the taxing IDR forgiveness will go away forever? And, and what are the four states that say now they will tax the debt relief if we get it? So, uh, I don’t remember. The four [01:11:00] states that are are, are left, um, the IDR forgiveness. So just as a recap for those that might not be aware, IDR forgiveness used to be taxable at the federal level.
Um, but Congress put a temporary moratorium on that through 2025. The fact that Congress even put a temporary moratorium on it GI make, gives me hope that they will extend it, uh, that they will extend it permanently. So again, remember, I’m a failed pessimist, but if I was a betting woman, I would say there is a 65% chance that Congress will make that permanent.
Now, as far as the four states that are still taxing, um, the Biden Harris debt relief, uh, I honestly don’t remember. Um, pat, do you remember, I think Indiana is one. Pennsylvania might be. One of the Carolinas, MA Massachusetts is not one. Correct?
Um, I will say that, [01:12:00] uh, our, oh, somebody Googled it. I love the Google machine. I think was, yeah, California do. So on this list is Arkansas, California, Indiana, Minnesota, Mississippi, North Carolina, and Wisconsin. I know for a fact, California, like, like Biden announced it on August 24th and California started moving things on the 25th to get rid of it.
Um, I think Indiana, North Carolina, I think Wisconsin might still be in place. And I don’t remember the fourth one.
So. All right. Well, things have gone quiet. Thank you, Betsy. Thank you, pat. And, uh, thank you Stephanie and Sean for being here as well. And, uh, thank you to everyone who participated and yes, we will continue to, we’ll have you back, Betsy, and we’ll continue to, uh, educate us as things evolve. So, [01:13:00] all right, well have a good afternoon everybody.
Thanks everyone. Thanks. Thanks Pat.