Keynote Remarks  of Seth Frotman
at the University of Utah, SJ Quinney College of Law
Utah Law Review Symposium
Financing the Future:
The Law and Politics of Student Debt in American Higher Education


October 20, 2017

Introduction

Ladies and gentlemen, thank you for the opportunity to be here today. My name is Seth Frotman and I have the privilege to serve as Assistant Director and Student Loan Ombudsman at the Consumer Financial Protection Bureau.

These views are my own and do not necessarily represent the views of the CFPB.

I wanted to start first by thanking the Utah Law Review for organizing and hosting this event. I also want to thank Chris Peterson for helping to coordinate this event. Over the past half- decade, I have been lucky enough to get to know Chris, whose comprehensive knowledge of the law is matched only by his tireless efforts to protect consumers. I am honored to call him my colleague, and more importantly, my friend. Thank you, Chris.

We are all here today because we share a commitment to better understand and address our nation’s growing student debt problem. I want to open my remarks with a statement that may seem obvious to those in this room, but remains surprisingly controversial in Washington — student debt has fundamentally changed the lives and livelihoods of tens of millions of people. Further, America’s embrace of a debt-financed higher education model has broken the basic tenets of the social contract between our government and its citizens — the contract that relies on the supposed notion that higher education is our nation’s great equalizer because if you go to college, you will have a clear pathway to the middle class.

In the last session, the panel discussed the political history of student lending. I think that is a good place to pick up because it is important to realize that we did not get here by accident. $1.4 trillion is never an accident.

It is imperative for us to understand the array of decisions that led us to this place for two reasons. First, because the individual people whose lives have been so severely impacted by student debt deserve an accurate accounting of why they have been uniquely asked to bear this burden. And second, so that policymakers and the higher education community — from universities to researchers to foundations — can shape a response that recognizes and effectively addresses the real problems that student loan borrowers face across their financial lives.

But to do this, we first need to look back.

In 2008, the worst economic recession since the Great Depression crippled the nation and destroyed trillions of dollars in household wealth. Millions of Americans stood by, powerless to intervene in their own financial lives. The financial crisis exposed deep-rooted systemic problems across the most basic functions of our credit markets. The economy failed consumers at every turn. Millions of people needlessly lost their homes. The most vulnerable people in our country were hit the hardest. Nearly a decade later, many families and communities have yet to recover.

As is often the case, we engaged in a familiar cycle of study and reaction — diagnosing the causes, learning the lessons, and enacting the right reforms — supposedly.

In response, our elected leaders made three promises. They promised that the public and private spheres would install a framework to stop many of the practices that led to the financial crisis. They also promised that this framework would protect individual consumers as they accessed and repaid the financial products that underpin a 21st century economy. And finally, they promised that by learning from the practices that ignited the last crisis, we could prevent the next one. In effect, our elected officials all across the country promised us that they would never let something like this happen again.

So what about those promises?

This moment in time, and particularly this symposium, should encourage us to step back and take stock of how well they kept those promises. The current student loan market is our first real test of this proposition. In a very tangible and profound way, our actions will determine the financial fate of 44 million people.

I am here today to offer my perspective from the front lines of the federal government’s effort to get a handle on our growing student debt problem. As someone who has focused on student debt in policymaking roles across the government as it supposedly worked to prevent another crisis, I am confident in my assessment — we are too late.

Those promises were broken, and yet again, we find ourselves in a crisis. For millions of American families and their communities, student debt is already a crisis.

Today, over eight million federal student loan borrowers are in default. Another three million borrowers are at least two payments behind. In 2016 alone, 1.2 million federal student loan borrowers defaulted — that is one default every 28 seconds.

To put these numbers into context, last year, three times as many people defaulted on a student loan than lost their homes due to foreclosure. In fact, the number of student loan defaults in 2016 rivaled the number of foreclosures at the peak of the mortgage meltdown. But this is just one part of the crisis. Ballooning, unaffordable student loan debt does not end with the millions of borrowers who are behind or in default on a student loan.

Some people have tried to explain away the student loan crisis by relying on an overly narrow definition of what it means for a borrower to be “struggling.” But when we limit the definition of the student debt problem to those borrowers who are behind or in default, we assume, by process of elimination, that the remaining 31 million borrowers are doing just fine.

This perspective is deeply flawed.

By defining “struggling” as only those in immediate, documented financial distress, we are accepting a status quo in which millions of consumers are failing. We are saying that it is okay to write off the financial futures of 11 million people.

First, this is certainly not okay. Second, the reality is that the legacy of debt-financed higher education is far broader. For every borrower who misses a student loan payment or defaults on a debt, there is another borrower who is struggling to buy a home, start a business, or save for retirement. Student debt has imperiled access to these key pillars of the middle class for far too many Americans.

The recession devastated an entire generation of people, and by breaking the promises we made in the aftermath, we have condemned the next one. We are doomed to repeat history again and again until we get this right.

Our $1.4 trillion problem

In order to address our student debt crisis, we first need to understand how we got here. In all instances, public policy reflects a series of choices. The student debt crisis is no exception.

We can trace the rapid rise of student debt to a series of choices made in state houses across the country, stretching back more than a decade. These choices were laid on a foundation built at the federal level that not only tolerated, but promoted debt-financed higher education.

At the height of the Great Recession, state lawmakers grappled with declines in tax revenue and sought ways to plug holes in their battered budgets. In nearly every state, lawmakers chose to cut public investment in higher education as a way to fill these gaps. This choice directly affected the public colleges and universities that educate nearly three-quarters of all college students in this country.

These state policymakers predicted that, of the tough choices they faced on spending cuts, cuts to higher education would have the least ramifications.

Legislators rightly assumed that if states chose to provide less financial support for public colleges and universities, then these schools could simply raise the cost of college in order to make up any shortfall.

Unfortunately, this same rationale also assumed that individual students and their families could handle a tuition bill of seemingly any size, without any real downside for the state. So when the financial consequences of these policies were passed on to families — but, again, not reflected on state balance sheets — state lawmakers could act as if their choices came at no cost to their state or their citizens. In a budgetary sense, this was undoubtedly true. But in broader social and economic sense, it could not be further from the truth. In fact, the costs would prove to be enormous.

A decade later, we now know that this rationale was rooted in a pyramid of flawed assumptions. First, policymakers incorrectly assumed that families and households would be able to absorb rising college costs without experiencing any long term financial consequences. Second, policymakers relied on the belief that college was always a sound investment. In other words, they believed that as long as they could point to the college wage premium — narrowly defined as the wage gap between college-educated workers and workers without a degree — the long-term economic benefits to families and to society would eventually offset any immediate increase in costs.

Years of evidence has exposed the flaws in both of these assumptions and paints a deeply disturbing picture of the individual and societal costs of student debt.

In the face of this mounting evidence, policymakers and higher education leaders are finally starting to recognize that their choices over the preceding decade set up millions to fail. As Gordon Gee, the former President of Ohio State said in 2012, “I readily admit it. I didn’t think a lot about costs. I do not think we have given significant thought to the impact of college costs on families.”

We are all here today to confront the consequences of these faulty assumptions and to, in Gordon Gee’s words, “give significant thought” to the drivers of and solutions to the student loan crisis. We begin confronting these consequences with an honest assessment of the myriad of ways that student debt is impacting individual borrowers, families, and their communities.

You have heard the numbers before, but I think they are worth repeating — more than 44 million consumers across the country collectively owe over $1.4 trillion in student loan debt. The debt that hangs over these borrowers’ financial lives is larger than the GDP of 180 countries.

Over the last decade, the total volume of outstanding student loan debt has nearly tripled, adding nearly $900 billion on the backs of borrowers. Student loan debt now makes up 11 percent of all household debt, up from only five percent in less than 10 years. The average student loan balance has increased by nearly 300 percent since 2005. These increases translate into very real financial consequences for student loan borrowers.

For a typical borrower, this increase results in higher amounts coming out of monthly paychecks. According to one recent study, in 2015, the average student loan payment for a millennial borrower was $351 per month — a payment amount more than 50 percent higher than it was a decade ago.

And we now see new evidence that declines in household formation and homeownership being driven by student debt — creating barriers to economic mobility for borrowers across the country. Another study found that rising levels of student debt resulted in 360,000 fewer homes purchased by millennials over the previous 15 years, which is greater than the total number of occupied homes in all of Salt Lake County.

For individual families, this struggle is real and immediate. But for policymakers and researchers, the most alarming consequences of the student debt crisis may happen not at the individual level, but where student debt begins to shape our economy and society.

Mounting evidence shows that the ripple effects of student debt are substantial. We are beginning to see how this debt fuels economic, gender, and racial inequality, inhibits asset accumulation, accelerates wealth gaps, and carves out a generational divide that, even in the best of circumstances, will take decades to erase.

The evidence shows that the burden of student debt is not shared equally, and the impact of this burden is far more severe for certain populations.

Women make up half of all college students, and yet owe two-thirds of outstanding student loan debt. And the gender pay gap only serves to keep women in debt longer.

Over 90 percent of African-American and 72 percent of Latino students leave school with debt, compared to 66 percent of white students. This debt hangs over their financial lives for longer and at a greater rate than their white peers. Data shows that 12 years into repayment, white borrowers have paid down 65 percent of their loan balance, while African American borrowers will owe 113 percent of what they originally borrowed.

We know that one of the most telling factors in whether residents of a zip code will struggle with paying their student debt is not income, but rather the racial composition — zip codes with predominantly African American and Latino populations have higher rates of delinquency and default than predominantly white zip codes with comparable income levels. Disturbingly, at four-year, non-profit schools, African Americans defaulted at four times the rate of their white peers.

But the student debt struggle is not limited by race and gender. We also see that rural areas such as Appalachia and other communities seemingly long-forgotten by policymakers have some of the highest incidences of delinquency and default.

These numbers show that where pursuing a college degree was once marketed as the “great equalizer,” it is now perpetuating the divide between the “haves” and the “have nots.” One recent study projected that a typical household headed by two college-educated adults with average student loan debt balances loses out on more than $200,000 in wealth over a lifetime.

It is increasingly clear that our student debt crisis is much broader than a series of individual student loan defaults. As more Americans pursue higher education, only to be weighed down by unaffordable student debt, this supposed equalizer is quickly turning into, as one researcher notes, one of the greatest forces for economic inequality in this nation.

And so, with a more honest assessment of the full impact of the crisis, we can now look back to the pyramid of assumptions used to justify the public policies that led us here. How well do they hold up?

First, let us revisit the assumption that families could continue to absorb the impact of rising college costs without passing these costs on to students. For much of our recent past, many families have shared the economic burden of paying for college by drawing on a combination of income, savings, home equity, and retirement savings in order to contribute. These family contributions, when combined with a students’ income from part-time work, and paired with a combination of student loans and grants, were sufficient to leave a typical borrower with a modest debt load at graduation. As tuition rose in the years preceding the Great Recession, this equilibrium was tenuous, but it held.

But then the recession hit.

During the recession millions of families suffered a series of continuing economic shocks. Widespread unemployment, combined with drops in home equity, investments, and retirement savings, battered household balance sheets. As wealth declined, particularly for working families, many households could no longer make a major financial contribution to higher education.

To put it another way, rising student debt levels are not just a byproduct of rising college costs, but rather the shift from the state to the household, and then household to the individual. Students were left with the choice to not go to college or to take on debt. And, as we all know, when faced with this choice, millions of people chose debt.

While conventional wisdom often points to the rapid rise in college tuition as the sole driver of increased student indebtedness, that is only part of the story. The other part is the willingness of policymakers to pile college costs onto families at the exact moment these families were trying to stay afloat during the financial fallout of the recession.

Having exposed this first assumption as a flawed one, we should turn to the great catch-all in the higher education funding debate — the proposition that the boost in wages earned by college graduates justifies the explosion of student debt because, over time, college is still “worth it.”

For more than half a century, part of the American dream was built on the implicit understanding, right or wrong, that college is always a sound investment and that taking on debt to get a degree is just a necessary step on a well-worn path to the middle class. Conventional wisdom suggested that the burden on individuals should not be a focus for policymakers because these increased costs were always offset by the broader economic gains that come from getting a higher education.

It is easy to see how this led a generation of policymakers and higher education officials to embrace the myth that a student loan was “good debt.”

But for borrowers — and for the policymakers and researchers that led them there — conventional wisdom around the merits of “good debt” is just as dangerous as the widely held but misguided belief that home values would always rise in perpetuity and an investment in your house always paid off.

To start, wages of those without a degree are dropping rapidly. In effect, the bottom has fallen out of the labor market for non-college educated American workers. This creates a deeply misleading contrast. To put it another way, the college wage premium does not persist across generations because things are getting better for college-educated workers — it persists because things are worse for those without a degree. In fact, when accounting for inflation, wages for college graduates have nearly stagnated for more than a decade.

At the same time, cost of living for all Americans has steadily climbed. The cost of health care and housing has outpaced inflation for the last decade. For all but the highest-earning households, these expenses have consumed a steadily rising share of incomes.

It should come as no surprise to researchers or policymakers when a college graduate is not satisfied with her lot in life or when she questions the value of her degree. Yet we continue to tout a tired statistic describing how bachelor’s degree recipients earn an extra million dollars over their lifetimes when compared to non-college educated workers.

This tired statistic does not account for a paycheck already stretched too thin; it does not explain why a college graduate now struggles to accumulate the same assets her parents did after leaving school; nor does it explain the role that student loan debt plays in the widening wealth gap.

The college wage premium may seem pronounced and persuasive to an economist, but it is meaningless to today’s college graduates. The notion that “other people have it worse” offers little solace when far too many of the borrowers who have done everything we have asked of them still struggle to afford a down payment, start a business, or save for retirement. When “other people have it worse” becomes the new foundation for the American Dream, we have failed an entire generation.

Adding insult to injury

It did not have to be this bad.

In 2007, Congress created what is, in effect, an insurance policy for borrowers that assume the risk of an unaffordable higher education. Through income-driven repayment (or “IDR”) borrowers could make payments based on their incomes, not their debt load. With payments as low as zero dollars available to the most financially strapped borrowers, people could avoid persistent economic distress brought on by inescapable student debt.

With IDR, Congress promised that students need not worry about how to pay for college because monthly payments would always be affordable. Having put in place an insurance policy for borrowers who are unemployed or have very low incomes and can make payments based on how much they earn, the IDR framework should also translate to, in the words of former Department of Education Under Secretary Ted Mitchell, a “zero default rate.”

Of course, IDR was not the solution to the most alarming spillovers of student debt, including effects on income inequality, retirement security, and homeownership, but it did hold the promise of serving as a powerful protection against both short-term and long-term financial shocks and promised to serve as a critical bulwark against rising student loan defaults.

This is a great idea — in theory. But as the Bureau has frequently highlighted, our outdated and dysfunctional student loan system was never up to the task of delivering on this promise. When there are eight million defaults a decade after laying out the supposed zero default rate framework, people cannot help but think of this as simply another broken promise. When another 3.5 million people are approaching default and there has been no real action to prevent it, we know they were right. And for every borrower who is struggling to keep up, there are others trying to get ahead but who are knocked off-track with roadblocks and obstacles that can add thousands of dollars in additional debt and years of needless repayment.

When we made the choice to thrust tens of millions of more student loan borrowers into the market, we should have seen this coming. Compared to any other major class of consumer debt, student loans are subject to less government oversight, offer fewer affirmative consumer protections, and rarely hold market participants to account for their most egregious practices. As a result, borrowers routinely fail to benefit from the protections that are in place. And it is more than just IDR protections. It is breakdowns starting from the day a borrower receives her first bill until the day she pays off her loans.

These breakdowns are not mere annoyances that we can greet with a collective shrug. This is not like calling the cable company.

To date, the Bureau has received over 50,000 complaints from student loan borrowers. That is more than one new complaint each hour, 24 hours per day, seven days per week, since we started taking them in 2012.

Driven by these complaints, the Bureau and state law enforcement officials have uncovered rampant illegal practices across the student loan market that are hurting student loan borrowers at every stage of repayment.

What we see is that, too often, on top of the historic debt that we pushed onto an entire generation, the process of repaying a student loan routinely is adding insult to injury. After saddling borrowers with a mountain of student debt, they are subject to harmful or illegal industry practices that drive them to default or lead to thousands of dollars in unnecessary costs. Collectively, this adds billions of dollars of additional student debt to household balance sheets, creating a further drag on the economy and damaging the financial future for millions of people.

Over the last six years, the Bureau has shown a widening disconnect between the protections touted in press releases and the reality 44 million people face on the ground. Widespread, harmful, and illegal practices, misaligned economic incentives, and antiquated or ill-considered public policies coalesce in ways that deny payment relief to struggling student loan borrowers. And when struggling borrowers fall victim to a rigged system, we treat them like tax cheats and dead beat parents by driving them to poverty through garnishment and offsets.

This leads me to two conclusions.

First, policymakers, regulators, and law enforcement officials neglect the student loan market at borrowers’ peril. Simply because the word “student” comes before “loan,” policymakers routinely treat these consumers like second class citizens. When compared to other markets like credit cards or mortgages, the companies paid to manage the student loan repayment process are subject to less oversight and the consumers are entitled to fewer protections. Student loan borrowers routinely face breakdowns and harmful practices that we would simply never permit in other markets.

Second, if we are going to accomplish any meaningful and lasting reform, we must overcome the misguided notion that one of the nation’s largest creditors, the Department of Education, should be relied upon to self-regulate. Too many people are too comfortable only looking to the Department of Education to fix the consumer debt market it dominates. The Department of Education is responsible for contracting with private companies to originate and service the more than $1 trillion in consumer debt it owns. In no other market and with no other creditor would we permit self-policing or reform via contract, rather than imposing independent statutory and regulatory requirements that are transparent and enforceable.

As recent events have illustrated, self-regulation by the Department of Education leaves student loan borrowers exposed and vulnerable to the political priorities of each new administration. Where sympathetic administrations prioritized consumer protection, reform that was implemented through guidance and contracts fail to endure. And where one administration may prioritize consumer protection, the next may seek to advance a different goal. But what ties nearly all administrations together is the desire to manage a one trillion dollar portfolio at the lowest cost possible in order to invest in “other priorities” — pitting other higher education programs against the investment necessary to deliver on the baseline protections promised to borrowers.

Industry takes its lead from these priorities. Nascent efforts to deprioritize or deflect rigorous oversight by independent federal and state agencies risks leaving a trillion-dollar blind spot in the heart of our nation’s financial sector. Student loan borrowers deserve better.

If we continue down this path, we leave the future of 44 million people subject to the political winds and special interest groups who view the student debt crisis as an avenue to enrich themselves, openly touting that they have no responsibility to help student loan borrowers.

The road ahead

We are now at the point you have all been waiting for — where do we go from here?

The task before us, in some ways, is more difficult than what we have faced in past. Our present problem is a quiet crisis. It is not driven by storefronts springing up on corners in vulnerable communities and peddling financial products that strip wealth from those least able to afford it. It does not feature families forced from their homes because they fell behind on a mortgage they couldn’t afford. There are no abandoned houses to point to.

We now know that a foreclosure harms more than just the individual family. The ripple effect of a foreclosure extends across the community.

To a casual observer, the signs of a family’s own internal student debt crisis are less visible than the empty house at the end of the block that used to belong to a neighbor and now belongs to a bank. But just because a family’s crisis is not as readily apparent, does not mean that the effects on our communities are any less significant or severe. The burden of student debt can ravage communities in a myriad of ways.

For example, consider a borrower devoting so much of his paycheck to his monthly student loan payment that he never puts enough away to save for a home. He is then pushed into an often punishing rental market that further limits the options available to him and his family, such as the school district in which they can live, thus perpetuating a cycle of economic and geographic segregation.

Or consider one of the several towns in rural America where residents lost their jobs after a lumber mill closed. These residents go back to school to learn new skills, take on debt, fall behind on their debt despite protections that should prevent this, and now the town is doubly harmed.

Or what about the thousands of borrowers who depend on their credit to get or keep a job? In many states, a credit check can still be used as a precondition for nearly any job. These borrowers took on debt so they could go to school to learn the skills necessary for vital professions. Thousands of nurses, teachers, EMTs, and other public servants rely on their credit to maintain their professional licenses. And yet, all across the country, we have seen how these borrowers fall behind on a student loan and become unable to get or keep the job that keeps a roof over their head.

A growing body of evidence suggests that millions of Americans are experiencing crises just like this. Individual lives are disrupted. Families become buried under the financial consequences of unmanageable student debt. And this devastation ripples across their communities.

The stakes are high and the consequences are enormous to neighborhoods, communities, states, and the nation, all driven by a cycle dependent on the debt that flows through this broken system and spurred by the tired assumptions that set us down this path.

So what can we do?

Our national conversation has begun incorporating exciting and far reaching proposals for how we can help new borrowers avoid the consequences of student debt. This is a laudable and necessary endeavor, but it is wholly inadequate to address the crisis borrowers are facing today. We could make college free for everyone tomorrow, but it would do nothing to help the millions of Americans struggling today.

For those borrowers with student debt, solutions that help the next guy not only miss the mark, but reinforce the notion that we are okay writing off this entire generation of borrowers. We cannot forget 44 million people.

First, we need to recognize that strengthening consumer protections in this market, while not a cure-all, is a critical step. At a bare minimum, we must ensure that we fix the severely broken repayment system that fails more student loan borrowers each day. When we ask people to take a risk and go to college, we must make sure that at the very least, they do not spend the next two decades of their lives navigating a minefield of illegal practices.

We can achieve this through robust oversight at the state and federal level. For a generation, state and federal regulators have overseen banks, credit unions, debt collectors, and other companies that provide financial products or services to consumers. This oversight has been a key component of the post-recession strategy to ensure consumers are protected when things go wrong. However, tellingly, until 2014, a student loan servicing industry responsible for handling over a trillion dollars in consumer debt was not subject to the same accountability. Today, only a handful of states have expanded their oversight to include these companies despite the central role they play in many consumers’ economic lives.

How do you explain to student loan borrowers all across the country that if they rent out a spare room on Air BnB, they likely need to obtain a license, but the trillion dollar student loan system that is essential to their financial futures lies with companies that too often operate in the shadows? Student loan borrowers deserve a government that focuses on their problems by building out the critical framework necessary to ensure these companies are complying with the law.

Additionally, to ensure this oversight is effective, the student loan market also needs clear rules of the road, just like those in other consumer debt markets. When setting standards in this market, individual borrowers, law enforcement, and regulators must be given the tools to hold servicers accountable for meeting these standards.

Second, we must think of innovative ways to help borrowers and their families reduce the financial burden caused by student debt. We have seen states implement a range of creative solutions that help borrowers in repayment, from programs like New York’s “Get on Your Feet,” to Maryland’s “SmartBuy.” Programs like these are not only critical for student loan borrowers’ financial futures, but must be viewed as an extension of our national effort and obligation to continue righting the wrongs of the Great Recession.

There is no silver bullet to fix a problem of this scale, but innovative policymaking, diligent oversight, and a government-wide crack-down on illegal student loan industry practices offer us a necessary first step.

Conclusion

But that is clearly only a start. We cannot succumb to the wishes of those who have not only resigned themselves to this broken system, but have also asked us to accept this as the new normal. We must find ways to end the cycle of debt-fueled higher education.

I have traveled the country talking to individual borrowers and organizations that have taken notice of how student debt affects their members. Just this year, we have seen organizations ranging from the AARP and the National Association of Realtors, to the NAACP and the American Federation of Teachers, up their efforts to fix the student debt crisis. This is promising, but every conversation reinforces my sense of how much work still needs to be done and reflects how many more people we need doing this work.

This is not simply a “college student” issue. This is not only a “consumer protection” issue. Nor is it solely an economic justice issue, or a civil rights issue, or an elder justice issue. Our student loan crisis is all of these and more.

I know that we all crave answers or the magic solution that can solve the issues I laid out here today. Unfortunately, that is not what I am going to do — not because I do not think there are good ideas or policy proposals that could make a real difference, but rather, because I want to focus on the necessary work like research, advocacy, and organizing, that must be put in place to build a foundation for these reforms. It is the foundation that is necessary for these policies to be successful, but does not yet exist. And so instead of answers, I would like to conclude with a series of additional questions that I hope you will each consider:

  • If you care about income disparities and economic justice, what have you done to demonstrate how student debt entrenches inequality?
  • If you care about civil rights and racial justice, what have you done to alleviate the uniquely burdensome role of student debt in communities of color?
  • If you remain committed to the American ideal of college as a gateway to the middle class, what have you done to show how the debt-financed higher education model impedes this ideal?
  • If you care about college access and affordability, what have you done to ensure that the definition of success does not end the day students walk across the stage?
  • If you care about protecting American consumers, what have you done to lay out a 21stcentury consumer protection framework for the student loan market?

Perhaps most importantly, have we collectively done the work to cast aside the tired and faulty assumptions that got us into this mess and demonstrate to policymakers across the country that public disinvestment in higher education merely shifts these costs onto those less able to bear them? Have we shown them that it merely places it onto the backs of the students, families, communities, they represent?

The only answer I am confident in is that we have much more work to do.

We need to do better for this generation, and for the next. We need to renew our promise to never let this happen again. And this time, we need to keep that promise.