May 28, 2013
Office of the Executive Secretary
Bureau of Consumer Financial Protection
1700 G Street NW, Washington, DC 20552
Re: Comment on Bureau of Consumer Financial Protection proposed rule defining larger participants of a market for student loan servicing (RIN 3170-AA35)
Dear Ms. Jackson:
Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB) proposed rule Defining Large Participants of a Student Loan Market. Young Invincibles is a non-profit, non-partisan organization that works to amplify the voices of young Americans and expand economic opportunities for our generation. Student loan debt is a top issue affecting the economic prosperity of young people today, and borrowers trying to repay their debt face particular struggles. Indeed, student debtors too often report that their servicers give them bad information, that they have problems with loan transfers, and that they cannot access benefits like better repayment plans and forbearances – among numerous other issues.
We applaud that the new provision gives the CFPB regulatory oversight of all student loan servicers with an account volume of more than one million as a positive step toward curbing problems with student loan servicers. This regulation is estimated to cover the seven largest student loan servicers in the U.S. protection. However, we urge the CFPB to extend this important protection. Specifically, we recommend that:
1. When Congress mandates that a servicing contract be given to a student loan servicer,that servicer should be subject to CFPB oversight.
2. The threshold of number of accounts that triggers CFPB oversight should be lower.