In a comment, Student Borrower Protection Center (SBPC) responds to proposed changes to Income-Driven Repayment (IDR), one of the most important protections available to federal student loan borrowers. SBPC’s letter praises various aspects of the proposed changes while urging the U.S. Department of Education to go further, including by eliminating proposed exclusions that are likely to harm low-income borrowers, borrowers of color, graduate students, and parents.