Comment on FR Doc # 2026-07614

Katherine GrowSupportIndividual
Summary: The commenter supports the development of income-driven repayment (IDR) plans but argues that the rules must be more robust to ensure true affordability for low- to middle-income families. They advocate for higher income protection thresholds, a cap on interest accrual, and the preservation of Public Service Loan Forgiveness (PSLF) and other forgiveness pathways.
I am writing to submit comments regarding the above-referenced rulemaking. My primary concern is that any final rule must make student loan repayment genuinely affordable for all borrowers, with particular attention to families and low- to middle-income households. 1. Family size alone is an insufficient measure of affordability. While family size should be considered, it does not capture regional cost-of-living differences, medical expenses, caregiving responsibilities, or other essential costs. The Department should base affordable payments on a more holistic measure—such as a generous income protection amount tied to regional poverty guidelines plus reasonable allowances for dependent care and necessary expenses. 2. Repayment plans must be as affordable as possible. I urge the Department to adopt or preserve income-driven repayment (IDR) plans with: A low monthly percentage of discretionary income (e.g., 5% for undergraduate loans, with a lower or zero payment for very low earners). A high income protection threshold (at least 150-200% of the federal poverty guideline for the borrower’s family size and location). No negative amortization that grows borrowers’ balances over time. Automatic recertification to prevent procedural defaults. 3. Protect Public Service Loan Forgiveness (PSLF) and other forgiveness pathways. Weakening or eliminating PSLF would harm millions of teachers, nurses, firefighters, and other public servants. The Department should maintain PSLF with clear, simple qualifying rules and ensure that all IDR payments (including $0 payments) count toward the 120-payment requirement. Similarly, keep loan forgiveness after 20 or 25 years in IDR without unnecessary tax hurdles at the federal level. 4. Expand affordability in repayment plans. Affordability means more than low payments. It also means: Extending IDR eligibility to all Direct Loan borrowers regardless of loan type or disbursement date. Capping total interest accrual so balances do not balloon for borrowers making good-faith payments. Allowing borrowers to easily switch between repayment plans without penalty or capitalized interest. Providing a straightforward application process accessible to borrowers with disabilities, limited English proficiency, or without reliable internet access. In summary, the Department should design repayment rules that treat true economic hardship as the guiding principle—not just family size. Please keep PSLF intact, preserve multiple forgiveness pathways, and make every repayment plan as affordable as possible for all borrowers.

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