Comments on Request for Information Regarding Student Loan Borrower Communications

Consumer Financial Protection Bureau Attention: Monica Jackson
Office of the Executive Secretary 1700 G Street NW
Washington, DC 20552

Re: CFPB-2016-0018-0001, Comments on Request for Information Regarding Student Loan Borrower Communications!documentDetail;D=CFPB-2016-0018-0001

Dear Ms. Jackson,

Young Invincibles (YI) thanks the Consumer Financial Protection Bureau (CFPB) for requesting comments on their proposed “Payback Playbook”, a simplified tool to help borrowers understand their student loan repayment options. YI is a non-profit advocacy organization working to advance economic opportunities for young adults ages 18 to 34 in the areas of health care, higher education and economic security.

Over the last several years, Young Invincibles has talked to young adults across the country about their first-hand experiences with loan servicing and has heard time and again from students who are confused or misinformed by their servicers. In 2015, we conducted a survey of over 1200 borrowers that yielded the following results:

  • 54% of borrowers felt that their servicer had made it more difficult to repay their student loans.
  • 37% of borrowers felt that they had not received timely or accurate responses from their servicer.
  • 39% of borrowers who contacted their servicer to change their repayment plan to lower their monthly payments did not reach a positive outcome.
  • 32% of borrowers reported that when their student loan servicer changed, they experienced problems repaying their loans as a result.
  • Almost half of the over 1,200 respondents took the time to write out descriptions of problems they have had with their servicers.

These survey results support the thousands of anecdotal stories YI has heard for years from borrowers about the problems encountered when dealing with servicers. Even more problematic is that the majority of survey respondents had completed college or graduate school and are more likely to have the means to repay their loans. This leads to two conclusions. First, the system is so ineffective and difficult to navigate it stymies borrowers who have the means to repay and may have more experience navigating complex systems. Second, borrowers without a degree who are in the most danger of delinquency and default too often cannot get the help they need to avoid negative outcomes.

We are hopeful that a streamlined tool like the Payback Playbook can be effective in reaching the huge population of borrowers that experience these difficulties. The proposed tool appears to present clear, yet contrasting, repayment options to the borrower. We’ve heard from young people that information that is unique to their situation and contains a limited number of distinct choices is preferable to general information with several choices. In light of that, YI recommends:

  • The Playbook is linked to on the borrower’s home page on their servicer’s website. We hope this would ensure that borrowers are always aware there is a tool to view some of their repayment options in clear language.
  • The Playbook is emailed to borrowers every month during their grace period until they select a repayment plan, as well as appearing unprompted every time the borrower logs on until they select a repayment plan. Preventing delinquency and default is best done before the borrower enters into either situation, and ensuring clear information for borrowers at the beginning of their repayment process should be helpful.
  • The Playbook appears unprompted at regular intervals when a borrower logs into their account, regardless of borrower status.
  • The Playbook is emailed to borrowers annually, timed to coincide when they will be required to re-certify if enrolled in an income-based plan.
  • The Playbook appears unprompted every time a delinquent or defaulted borrower logs into their account, until the delinquency or default is positively resolved. Preventing negative outcomes for borrowers is essential, and every opportunity should be used to get borrowers into plans that work for them.
  • The Playbook page for delinquent and defaulted borrowers offers the plan that will result in the lowest monthly payment.
  • The Playbook page for non-delinquent borrowers clearly states that there are more than the three plans visually represented available, and the information located on the bottom of the page on additional plans is made slightly larger. While simplified choices are a good gateway to the borrower understanding they can change their plan, until the system is further simplified, access to information on all plans should remain available.
  • The Playbook should also be mobile-friendly. Many young people are smartphone- dependent.

We are hopeful these recommendations will be responsive to the needs of borrowers.

Thank you for the opportunity to comment on the proposed Payback Playbook proposal. We hope that the Consumer Financial Protection Bureau finds our input valuable and we look forward to continuing to work together. For more information, please contact Reid Setzer, at or at 609-379-0123.


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Comments on Proposed Department of Education Complaint System

In light of the many challenges and obstacles presented to young people by our current higher education system, the Department of Education has decided to solicit comments on how such a system could be developed and finalized this year. In response to the Department’s request, Young Invincibles filed this comment.

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Young Invincibles Details Priorities in Letter to Congressional Appropriators

On the heels of passing a recent bipartisan budget deal, Congress has the potential to invest in programs that would greatly help young people. Please find a letter to Congressional leaders detailing Young Invincibles’ appropriations priorities here.

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FACT SHEET: FAFSA Simplification

The unnecessarily complicated application for Federal Student Aid is preventing some students from accessing the financial aid they are entitled to or in some cases from going to college all together. Students tell us all the time that the application process can be quite difficult to complete and can put a strain on their families. It doesn’t have to be this way. Click here to read Young Invincibles’ fact sheet on FAFSA simplification.

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Comments on Proposed Workforce Innovation and Opportunity Act Rules

The United States’ Millennial unemployment rate is roughly 40 percent higher than the national average, despite the fact that many jobs remain unfilled. By helping narrow the skills gap, the Workforce Innovation and Opportunity Act (WIOA) is a big step towards ensuring young people have the training they need to fill the jobs of the 21st century. In response to the law’s proposed rules, Young Invincibles filed these comments.

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Comments on U.S. Senate HELP Committee’s Risk Sharing White Paper

In response to Senate Health, Education, Labor, and Pensions Committee Chairman Lamar Alexander’s request for input on his Committee staff’s white paper on risk sharing in higher education, Young Invincibles submitted the following comments. We support the goal of aligning and improving federal incentives to elevate institutions’ interest in reducing the burden of student debt and improving access and success.

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Comments Regarding Proposed College Ratings Framework

February 17, 2015

U.S. Department of Education
Attention: National Center for Education Statistics
1990 K Street NW, 8th Floor
Washington, DC 20006

Re: For Public Feedback: A College Ratings Framework

Dear Sir or Madam:

Thank you for the opportunity to provide feedback on the College Ratings Framework as published on December 19, 2014. As a non-profit research and advocacy organization working toward expanding economic opportunity for young adults, we applaud the Department of Education’s (hereafter “the Department”) work to make institutions of higher learning more accountable to students and families, better able to improve, and more transparent for taxpayers.

We understand and appreciate the difficulty of achieving an ambitious project such as the one that the Department lays out in its framework. Systems within higher education are extremely complex, often to the detriment of students and families. How the Department will assign value to its activities and outcomes speaks to our values and priorities as a nation. We hope that our comments are beneficial to your work and will result in a usable system that benefits students and families, with an emphasis on students from underrepresented communities.

Click here to download our full Comments.

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Comments Regarding the Administration’s Intent to Expand Pay As You Earn (PAYE)

November 4, 2014

Ms. Wendy Macias
U.S. Department of Education
1990 K Street NW, Room 8017
Washington, DC 20006

Re: Docket ID ED-2014-OPE-0124 – Intent to Establish Negotiated Rulemaking Committee

Dear Ms. Macias:

We write in response to the September 3, 2014 Federal Register notice soliciting input on the U.S. Department of Education’s upcoming negotiated rulemaking. Young Invincibles is a national nonprofit dedicated to creating economic opportunity for young adults and amplifying the voices of 18 to 34 year olds on issues like health care, higher education, and jobs. Thank you for giving us the opportunity to submit comments on the administration’s intent to expand Pay As You Earn (PAYE).

To download our full Comment, please click here.

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Investing In Young America: What’s In the President’s 2016 Budget?

Click the fact sheet to read, “Investing in Young America: What’s In the President’s Budget?


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A Millennial Agenda for Illinois

Click here to download the full report: A Millennial Agenda for Illinois.

The NextGen Illinois project is an initiative of Young Invincibles and the Roosevelt Institute | Campus Network, in collaboration with dozens of other Illinois organizations, designed to activate young people to shape a unique policy agenda for the state of Illinois. Young adult voices are frequently overlooked in state-level political conversations, and the NextGen project aims to strengthen the youth voice by elevating shared political priorities.

From June to September of 2014, we met with young people from across Illinois and hosted discussions and town halls on campuses, in classrooms, and in bars to gather policy ideas. Over 700 young people, ages 14 to 34, participated in discussions about Illinois’ biggest policy challenges such as education, jobs, and health care. Participants also tackled important reform questions around political corruption, money in politics, and fair elections.

On September 27, hundreds of NextGen Illinois participants came together at a state convention to vote on some of the best ideas that young people contributed throughout the process and created a cohesive 10-item agenda for Illinois.

Here you will find the resulting agenda, containing the top 10 ideas supported by young people from all over the state. We have included a brief analysis of each policy and information on how you can help move these policies forward.

Next Gen IL

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