LRAP/IBR/PSLF. How does it work? Let's find out!

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Expand view Topic review: LRAP/IBR/PSLF. How does it work? Let's find out!

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Nebby » Mon Oct 19, 2020 7:54 pm

FYI - y'all should call you servicers to see if the extension applies to you. My income based repayment anniversary is on January 1, so I don't qualify. The date is not when your recertification is due, but the anniversary of when you officially entered income based repayment is the reference date for whether the extension applies. My recertification deadline is 11/27, but that apparently isn't the date that matters.

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Johannes » Tue Oct 13, 2020 2:13 pm

Nebby wrote:
Sun Oct 11, 2020 1:27 pm
Does everyone else interpret this to mean we just don't need to recertify this year and our payments next year will be the same as this year?
Correct.

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Nony » Sun Oct 11, 2020 2:19 pm

Yes, that’s my understanding. My recertification is usually in the spring and they’d sent me the reminder to recertify before the first extension, and then nothing more.

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Nebby » Sun Oct 11, 2020 1:27 pm

Does everyone else interpret this to mean we just don't need to recertify this year and our payments next year will be the same as this year?

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Nebby » Sat Oct 10, 2020 12:27 pm

I just got the email
Spoiler:
Image

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Johannes » Fri Oct 09, 2020 11:48 pm

I got an email. I’m on my phone but will post the screen shot when I’m on a computer later this weekend.

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Nony » Fri Oct 09, 2020 8:32 pm

When I last logged on the website said recertification had been deferred till Dec 31. (Not sure if that’s the same as what Johannes saw or if they extended it again.)

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Nebby » Fri Oct 09, 2020 8:06 pm

Johannes wrote:
Fri Oct 09, 2020 4:00 pm
No annual income recertification necessary this year either. Just got message that all annual recerts are extended for at least a year.
Screenshot?

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Johannes » Fri Oct 09, 2020 4:00 pm

No annual income recertification necessary this year either. Just got message that all annual recerts are extended for at least a year.

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Nebby » Wed Sep 23, 2020 12:27 pm

FYI - just did my annual employee recertification for PSLF and it properly counted the months covered by the CARES Act. Sitting at 44 qualifying payments! (lol not even halfway there but at least all months have been properly counted since I started repayment).

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Johannes » Fri Sep 04, 2020 10:34 am

My email is from fed loan servicing, “an office of the US department of education” and also bears the dept of education insignia. I’d consider that from dept of education.

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Nony » Fri Sep 04, 2020 8:23 am

TBF, I’ve never received anything directly from DOE (including about the original forbearance through the CARES act). All communications come through the servicer.

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Guest » Fri Sep 04, 2020 3:49 am

Johannes wrote:
Thu Sep 03, 2020 10:54 pm

Yep just got my email from the dept of Ed confirming each $0 waived payment counts the same. Awesome!
I got an email from Fedloan, but not DOE proper. Was your email from DOE proper?

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Johannes » Fri Sep 04, 2020 12:14 am

Yeah DACA is what I was getting at. I think we’re good regardless. Will opinion in my eyes.

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Nebby » Thu Sep 03, 2020 11:44 pm

Johannes wrote:
Thu Sep 03, 2020 10:55 pm
PSLF for me wrote:
Wed Sep 02, 2020 10:36 am
I work in government, and I’m really hoping to qualify for PSLF after just a few more years.

Is it safe to pay nothing on my loans until January 2021? Can I safely assume that DOE will properly implement Trump’s executive order on student loans?
Yes. Dept of Ed is also an agency. Arbitrary and capricious and they have to follow their own guidance/positions. Can only change positions with a comment period etc.
I don't think Ed is going to go back on it but an agency typically only needs notice and comment if the policy they are changing was implemented following notice and comment. An agency position policy doesn't have the same requirements for amending or rescinding as a regulation does. The exception apparently being If the position policy was in effect for long enough that people detrimentally relied on it (a la DACA).

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Johannes » Thu Sep 03, 2020 10:55 pm

PSLF for me wrote:
Wed Sep 02, 2020 10:36 am
I work in government, and I’m really hoping to qualify for PSLF after just a few more years.

Is it safe to pay nothing on my loans until January 2021? Can I safely assume that DOE will properly implement Trump’s executive order on student loans?
Yes. Dept of Ed is also an agency. Arbitrary and capricious and they have to follow their own guidance/positions. Can only change positions with a comment period etc.

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Johannes » Thu Sep 03, 2020 10:54 pm

Yep just got my email from the dept of Ed confirming each $0 waived payment counts the same. Awesome!

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Nony » Wed Sep 02, 2020 11:03 am

All the student loan sites are saying that this is the case, so while they’re obviously not DOE and I can’t say for certain what DOE will ultimately do, I think borrowers would have really good arguments for detrimental reliance if DOE changes course (although I cannot believe I’m citing detrimental reliance with a straight face).

Personally I’m going to go with it, on the theory that it’s worth the risk that I might have to pay 3 months longer.

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by PSLF for me » Wed Sep 02, 2020 10:36 am

I work in government, and I’m really hoping to qualify for PSLF after just a few more years.

Is it safe to pay nothing on my loans until January 2021? Can I safely assume that DOE will properly implement Trump’s executive order on student loans?

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Nebby » Sun Aug 23, 2020 11:20 am

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Johannes » Sun Aug 09, 2020 11:10 pm

Worst case scenario you don’t make 3 payments right now and they don’t count. I don’t see why you’d make 3 payments where a $0 payment might count.

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Johannes » Sun Aug 09, 2020 11:09 pm

No I hadn’t gotten there yet. I disagree and think they will count. Trump is literally telling the agency how to do it.

It’s an APA question and there’s no clear law on this specific issue but I think forgiveness or not (or counting the payment) if done by the agency would be an agency action.

The statute CARES ACT made clear the agency had to count them as payments. They didn’t have any authority on the issue to fill the gap. Here there is a gap because there’s no law. It’s likely the agency can fill it however it chooses.

And I think they’ll fill it how the previous deferral worked.

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Nony » Sun Aug 09, 2020 10:59 pm

Johannes wrote:
Sun Aug 09, 2020 10:53 pm
BeatricESQ wrote:
Mon Aug 03, 2020 2:06 pm
Nony wrote:
Tue Jul 28, 2020 7:41 am
In what sense? Other than making sure that someone fills out the appropriate form so you can certify it was a qualifying job, there isn’t anything to do.
I mean when you leave it for good. I was 2.5 years in and left for private practice during the pandemic. I normally would be doing my annual certification pretty soon, my deadline is sometime in October.
Well don’t get off government repayment REPAYE/PAYE/whatever income contingent plan you’re on for anytime in the future. Trump exec order means no payments through end of the year and each payment count/. Election will be big time too now that there’s an exec order blueprint out for student loan payment forgiveness. I would recertify but now you gotta have 240 instead of 120 pay’ents. What’s debt load?
Did you read Nebby's post immediately above yours?

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Johannes » Sun Aug 09, 2020 10:53 pm

BeatricESQ wrote:
Mon Aug 03, 2020 2:06 pm
Nony wrote:
Tue Jul 28, 2020 7:41 am
In what sense? Other than making sure that someone fills out the appropriate form so you can certify it was a qualifying job, there isn’t anything to do.
I mean when you leave it for good. I was 2.5 years in and left for private practice during the pandemic. I normally would be doing my annual certification pretty soon, my deadline is sometime in October.
Well don’t get off government repayment REPAYE/PAYE/whatever income contingent plan you’re on for anytime in the future. Trump exec order means no payments through end of the year and each payment count/. Election will be big time too now that there’s an exec order blueprint out for student loan payment forgiveness. I would recertify but now you gotta have 240 instead of 120 pay’ents. What’s debt load?

Re: LRAP/IBR/PSLF. How does it work? Let's find out!

by Nebby » Sun Aug 09, 2020 4:27 pm

While not completely clear, it's likely that Trump's EO won't provide qualifying payment status for those months being deferred after Sept. 30. PSLF is governed by statute and implemented through Dept. of Ed. regulations that were adopted via notice and comment, including what types of payments are "qualifying" for PSLF purposes. Ordinarily, suspension of payments (deferment or forbearance) do not count as "qualifying," unless some other legal authority defines them as such. The CARES Act smartly suspended payments and defined them as qualifying for PSLF purposes. Trump's EO doesn't mention PSLF or qualifying payments. Here's the text: https://www.whitehouse.gov/presidential ... -pandemic/

The EO only references deferring loans, which would make those months deferred not qualifying for PSLF. It sucks but for those on PSLF, I'd start making payments due after September 30th because they're likely not qualifying. Hopefully Congress is able to enact legislation that extends the CARES Act to make the months suspended count for PSLF. The Dept of Ed could also promulgate regulations to define deferred payments as qualifying, but that's unlikely to happen.

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