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.
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-actions/memorandum-continued-student-loan-payment-relief-covid-19-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.