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  1. Resources & Litigation
  2. Letters/Memos

Letters & Memos


  • Letters & Memos
    May 5, 2023

    Letter to the University of California on Completing the Work of Protecting Students from Predatory Online Programs 

    The SBPC sends a letter applauding the University of California’s recent decision to ban fully online degrees, while urging it to fully protect students from predatory online program managers by also banning fully online non-degree programs.

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  • Letters & Memos
    Apr 21, 2023

    Comments in Response to Proposed Ban on Non-Compete and De Facto Non-Compete Clauses 

    The SBPC submits a comment applauding certain proposed changes aimed at expanding access to the Public Service Loan Forgiveness program and outlining additional needed changes.

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  • Letters & Memos
    Apr 3, 2023

    Letter in Response to the CFPB’s Proposal for a Registry of Supervised Nonbanks that Use Terms & Conditions in Form Contracts to Limit Consumers’ Rights and Protections

    SBPC offers comments on the CFPB’s proposal to create a registry of nonbanks that use restrictive terms in form contracts to block borrowers’ rights. SBPC praises the idea against a backdrop of endemic abuse and offers suggestions for how the CFPB could strengthen it.

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  • Letters & Memos
    Mar 31, 2023

    Letter in Response to the CFPB’s Proposed Rule for a Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders

    In a letter, the SBPC praises and offers additional suggestions to strengthen the CFPB’s proposal to create a registry of covered nonbanks that are subject to certain federal, state, or local agency orders.

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  • Letters & Memos
    Mar 30, 2023

    Letter in Response to the Department of Education’s Dear Colleague Letter Regarding Requirements and Responsibilities for Third-Party Servicers and Institutions

    In a letter, SBPC praises and offers certain recommendations to strengthen ED’s February 2023 letter revising guidance to institutions that contract with third-party servicers to administer any aspect of their participation in the Title IV program.

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  • Letters & Memos
    Mar 16, 2023

    Letter to the Department of Education Regarding the Incentive Compensation Ban and Bundled Services

    In a letter, SBPC outlines the various failures and harms that stem from ED’s “bundled services” loophole, and calls for its immediate recission.

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  • Letters & Memos
    Feb 17, 2023

    Letter in Response to the Department of Education’s Request for Information Regarding Higher Education Act Pooled Evaluation

    SBPC urges ED to conduct long-overdue scrutiny of the student loan system, study the effects of debt on borrowers’ lives, and provide basic but unknown facts about federal student lending.

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  • Letters & Memos
    Feb 10, 2023

    Letter in Response to the Department of Education’s Notice of Proposed Rulemaking on Income-Driven Repayment

    SBPC comments on proposed changes to income-driven repayment, praising certain expansions of the protection while urging ED to go further and eliminate shortcomings likely to hurt those who are already financially vulnerable.

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  • Letters & Memos
    Feb 10, 2023

    Letter to the Department of Education Regarding Low-Financial Value Programs

    SBPC calls on ED to use its existing authorities more robustly to weed out predatory courses of study.

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  • Letters & Memos
    Jan 27, 2023

    Defaulted Borrowers Must Be Included in the Income-Driven Repayment Account Adjustment

    This memo urges the U.S. Department of Education (ED) to reconsider its exclusion of periods of time in default from the one-time Income-Driven Repayment (IDR) Account Adjustment, which ED announced as a remedy for borrowers who have been steered into forbearance or otherwise knocked off course from IDR cancellation.

    More

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