Income-Based Repayment, LRAP, and PSLF

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Hello LSL friends,

This is a longish post about LRAP/IBR/PSLF. I will expand on the post as people have questions and comments, but the baseline is a simple explanation of these programs, what these acronyms mean, and why you should pay attention to them.

Basics of Income Driven Repayment

Law school is expensive - like, unreasonably so. Georgetown Law's tuition costs alone are now just under $60,000/year at sticker price. With an additional $20,000/year in housing costs, law textbook costs, commuter costs, interest on loans during school, etc., it is entirely possible for a law grad to have accumulated $250k in student loans by the time they graduate. On a ten-year standard repayment plan, this comes out to about $2900/month just in student loan payments.

Federal direct loans (common loans for law school education funding) offer a unique benefit over private educational loans; and that is access to "Income Driven Repayment Programs" (IDR). In an income driven repayment program, you do not make payments based on your loan amount, you make payments based on your income. Therefore, someone that earns $40,000/year will pay significantly less than someone who earns $190,000/year.

This presents a problem, however - it is possible/very likely that someone paying a loan based on their income will not pay off the entirety of the loan in ten years. In fact, the borrower may not even be able to make payments covering the interest on their loan, leading to negative amortization. That's a scary thought; you make regular payments on your loan only to see the balance increasing every month!

Fortunately, there is an exit: Depending on the program, if a borrower on an IDR continuously makes payments for 20 years, the borrower's remaining balance will be "forgiven."

Let's take a hypothetical borrower who makes 50,000/year after graduating law school (looks like he didn't get biglaw!). He took out $250,000 in loans that average at 7%/year. Let's also assume he receives a 5% raise every year for the next 20 years.

  • His initial monthly payment will be either $2,903/mo on a standard repayment plan, or $266/month based on REPAYE, an IDR plan.
  • His last payment (after 10 years) will be $2,903/mo, or (after 20 years on REPAYE) $1,078/mo
  • If he opts on standard, he will pay a total of $348,325 over ten years. If he opts into REPAYE, he will pay $177,748 over 20 years, with $358,729 forgiven.

Sounds great, right? There's a catch:

The downside of IDRs

The biggest noticeable downsides of IDR is that, at year 20, the IRS will consider you to have "earned" the forgiven balance, which means you are taxed in a single year as if you had made $358,729 (plus your actual income!) in our hypothetical above. This problem is called the "tax bomb." So while you might not owe a lot of money to the Department of Education, you will owe a lot of money (albeit less) to the IRS. The bad news is, there's no way around this problem right now. Most people save for "tax bomb day" for the 20 years they are in the IDR program.

In some situations, the borrower has no choice but to enroll in an IDR. If your choices are between defaulting on your student loan because you can't make payments of $2,900/mo and enrolling in an IDR, well, that's not really much of a choice.

IDRs will generally kick in at 10% (or 15%/20% on some programs) of your income exceeding the HHS poverty threshold. In our hypothetical above, someone making $50k/year would pay about $266/mo. Someone making $90k/year would pay about $600/mo. Someone making $16k/year would pay $0/mo, because they would not be above the federal poverty threshold. You get the idea.


PSLF to the rescue!

PSLF, or "Public Service Loan Forgiveness" is the trusty sidekick to IDR that changes the program from a decent safety net to a clear path to repayment. PSLF became available in 2007 as a way for "public servants" to qualify for early loan forgiveness. How? Let's take our hypothetical above.

  • Our borrower makes 50k/year, but he makes 50k/year at a 1) federal/state/military employer, 2) 501(c)(3) employer, or 3) qualified organization falling under a special exception (i.e., Americorps).
  • Although our borrower would have to make payments of $266/mo which would increase with his raises, he only has to do so for 10 years, rather than 20.
  • Furthermore, when his loans are forgiven in year 10, he will not have to pay the "tax bomb" associated with a sudden loan forgiveness.
  • In this hypothetical, our borrower would only pay $42,746 on the entirety of his $250k/loan.

Therefore, if you make regular payments under an IDR while employed by a qualifying organization you could drastically reduce your overall payment and suffer no tax repercussions.

Okay, then what's LRAP?

Before PSLF, top law schools operated a "Loan Repayment Assistance Program" in which they would provide monetary assistance to borrowers who opted into public sector work. However, after PSLF, this school-provided safety net proved to be redundant, because the federal safety net in place was so much better. In taking advantage of the federal programs, law schools began making their reformed LRAP programs contingent on participation on IDR/PSLF. How?

Let's take Georgetown law for instance. Normally, a graduate that makes 75k/year would be required to pay $474/mo on an IDR program. However, if you make 75k/year or less and graduated from GULC, GULC will pick up those monthly payments, leaving the borrower paying nothing out of pocket.

Some schools are more generous with this cap, some (most) schools are less. Columbia Law, for instance, has a cap of $100k/year. If you make less than that, you owe nothing out of pocket to the Department of Education. It is entirely possible for a lawyer working in the public sector to never make more than this amount for the first ten years of their career, which means you could technically go to law school at sticker price, take out 250k in loans, and pay absolutely nothing on them.

Wow this seems too good to be true?!

Yeah, so, that's the problem. PSLF is becoming less and less popular as Congress/the non-law population footing the bill begins to understand this issue. As more people qualify for PSLF, the more of a burden it will become. It is almost certain, politically, that PSLF will eventually be terminated. What will happen to the folks currently making payments under an IDR schedule with the expectation of PSLF forgiveness is unclear. Most interpretations (read: speculations) of current events lead the hivemind to believe Congress will continue allowing current borrowers access to PSLF, but not future borrowers.

Aside from the political uncertainty, what's the catch?

First, you have to basically commit to making 120 payments (don't have to be consecutive) under an IDR program while employed by a public service organization. If your plan is to be a federal employee lifer, this is probably a good plan. If you get fired on month 119 from your non-profit and you can't find another non-profit job? Tough to be you. There's no partial forgiveness - either you go find another public service job, or you have another 11 years to go on the regular IDR track.


-----

Some resources!

https://studentloans.gov/myDirectLoan/mobile/repayment/repaymentEstimator.action <- Federal student loan repayment calculator. Mess around with some numbers, figure out what makes the most sense for you.

https://www.law.georgetown.edu/admissions-financial-aid/office-of-financial-aid/lrap/LRAP-III.cfm <- Georgetown's LRAP is very similar to other top schools' LRAP programs. The amount will likely vary, but the explanation of how it works is pretty ubiquitous. Check each individual school for details.

https://studentaid.ed.gov/sa/repay-loans/forgiveness-cancellation/public-service <- Read this thoroughly! This is a PSLF FAQ section on the DoEd's website.

 

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