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Comment Letters & Statements
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EFC issues comments and letters to regulators, lawmakers, policymakers, and industry stakeholders to promote its members’ positions on key issues. Click on the links below to read the letters.

 

EFC, CBA, NCHER, and SLSA regulatory reform comments to the Education Department, submitted in accordance with Executive Order 13777, Enforcing the Regulatory Reform Agenda, to identify regulations that may be appropriate for repeal, replacement, or modification (September 20, 2017)

 

EFC letter to Sens. Mark Warner (D-VA), John Thune (R-SD), and Angus King (I-ME) endorsing S.796, the Employer Participation in Repayment Act of 2017, which would "allow employers to use pre-tax income to help pay down their employees’ student loan debt by making payments to their employees or directly to their employees’ student loan lender(s)" (August 22, 2017)


EFC letter to Reps. Rodney Davis (R-IL) and Scott Peters (D-CA) endorsing H.R.795, the Employer Participation in Student Loan Assistance Act of 2017, which would "allow employers to use pre-tax income to help pay down their employees’ student loan debt by making payments to their employees or directly to their employees’ student loan lender(s)" (August 22, 2017)

 

EFC letter to Treasury Secretary Steven Mnuchin providing input on Executive Order 13771 and urging Treasury to clarify the application of the identified regulations as “deregulatory actions” (July 28, 2017)

 

EFC letter to Sens. Chuck Grassley (R-IA), Joni Ernst (R-IA), and Al Franken (D-MN) endorsing the Know Before You Owe Act of 2017, which would “strengthen the current loan counseling requirements for institutions of higher education in the Higher Education Act by making the counseling an annual requirement before new loans are disbursed rather than just for first-time borrowers" (July 27, 2017)

 

EFC Statement for the Record, Senate Finance Committee Hearing, "Tax Reform: Prospects & Challenges" (July 18, 2017)

 

EFC letter to Senate Finance Committee Chairman Orrin Hatch (R-UT) outlining EFC's recommendations for comprehensive tax reform (July 11, 2017)

 

EFC letter to Education Secretary Betsy DeVos expressing concern with the growing tendency of state entities to seek to impose state-level laws and regulations on student loan servicers contracted by the federal government to service federal student loans and requesting that the Department make its assertion in favor of federal regulatory preeminence clear to both the public and to state entities that seek to impose their own conflicting regulations on federal student loan servicing contractors (June 29, 2017)

 

EFC letter to Education Secretary Betsy DeVos expressing EFC's concerns with the Education Department’s amended student loan servicing solicitation and requesting that the Department re-evaluate its decision to select one servicer to manage the entire federal loan portfolio (June 8, 2017)

 

MBFA, of which EFC is a member, Statement for the Record on Ways & Means Hearing, "How Tax Reform Will Grow Our Economy and Create Jobs" (May 22, 2017)


EFC Statement for the Record, House Committee on Ways & Means Hearing, "How Tax Reform Will Grow Our Economy and Create Jobs" (May 19, 2017)

 

Bipartisan Senate letter to Treasury Secretary Steven Mnuchin and IRS Commissioner John Koskinen urging the IRS and Treasury Department to lift barriers limiting nonprofit student loan organizations from fully implementing refinancing programs for thousands of education loan borrowers across the country (May 3, 2017)

Bipartisan House letter to Treasury Secretary Steven Mnuchin and IRS Commissioner John Koskinen urging the IRS and Treasury Department to lift barriers limiting nonprofit student loan organizations from fully implementing refinancing programs for thousands of education loan borrowers across the country (May 3, 2017)

EFC letter to House Ways and Means Committee Chairman Kevin Brady (R-TX) outlining the importance of preserving tax-exempt Private Activity Bonds for education loans (April 27, 2017)

 

EFC comment letter in response to the Consumer Financial Protection Bureau’s Student Loan Servicing Market Monitoring proposal (April 24, 2017)

 

EFC letter to Sen. Mike Enzi (R-WY) endorsing his legislation, S.749, the Transparency in Student Lending Act, which would amend the Higher Education Act to require the disclosure of an annual percentage rate (APR) on federal student loans (April 4, 2017)

 

EFC letter to Reps. Peter J. Roskam (R-IL), Ron Kind (D-WI), Ryan Costello (R-PA), and Chellie Pingree (D-ME) endorsing their legislation, H.R.1659, the Stop Taxing Death and Disability Act, which would exempt from income tax federal and private student loans that are discharged due to the death of a child or total and permanent disability and allow a parent whose child develops a total and permanent disability to qualify for student loan discharge (March 22, 2017)

 

EFC letter to Reps. Randy Hultgren (R-IL), Luke Messer (R-IN), and David Scott (D-GA) endorsing their legislation, H.R.1283, the Transparency in Student Lending Act, which would amend the Higher Education Act to require the disclosure of an annual percentage rate (APR) on federal student loans (March 13, 2017)

 

EFC letter to Senators Christopher Coons (D-DE), Angus King (I-ME), and Rob Portman (R-OH) endorsing their legislation, S.405, the Stop Taxing Death and Disability Act, which would exempt from income tax federal and private education loans that are discharged due to the death or total and permanent disability of a student, and allow the parent of a student that becomes totally and permanently disabled to have their federal loan discharged (February 17, 2017)

 

EFC letter to Treasury Secretary Steven Mnuchin recommending that Treasury immediately address three regulatory issues to allow nonprofit and state-based organizations to fully implement valuable refinancing programs (February 16, 2017)

 

EFC letter to Rep. Richard Neal (D-MA), Ranking Member of the House Committee on Ways and Means, outlining EFC's priorities and recommendations for tax reform (February 15, 2017)

 

EFC comments to the Federal Communications Commission in support of the Petition for Reconsideration filed by Great Lakes Higher Education Corp., Navient Corp., Nelnet Inc., Pennsylvania Higher Education Assistance Agency, and the Student Loan Servicing Alliance in the matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (February 1, 2017)

 

EFC letter to Rep. Kevin Brady (R-TX), Chairman of the House Committee on Ways and Means, outlining EFC's priorities and recommendations for tax reform (January 30, 2017)

 

EFC letter to Rep. Bill Flores (R-TX) congratulating him on the introduction of H.R.480, the Student Loan Opportunity Act, which would allow qualified scholarship funding corporations to access tax-exempt financing to fund alternative private student loans for students attending school and provide low-cost refinancing loans to borrowers once they leave school (January 19, 2017)


EFC letter to Consumer Financial Protection Bureau Director Richard Cordray to inform him of the publication of EFC’s “Guiding Principles for Nonprofit, State-Based, and State-Chartered Organizations Who Make Education Loans” (January 9, 2017)

 

EFC letter to Rep. Tom Reed, commending Rep. Reed for the introduction of “Our Vision for Students” and outlining a list of additional opportunities where Congress and federal regulatory agencies can make common sense reforms to immediately improve the higher education financing experience for students and families (January 3, 2017)

 

Letter from Sens. John Boozman, Chris Coons, Roy Blunt, Patty Murray, and Jeanne Shaheen to Education Secretary John King and Treasury Secretary Jacob Lew, urging ED and Treasury to take the necessary steps to streamline the enrollment process for student loan borrowers in income-driven repayment plans (IDR) by “allowing borrowers to give ED advance permission to automatically access their tax information for the limited purpose of determining eligibility and/or monthly payment amounts for IDR plans.” EFC worked with the senators on the letter (December 16, 2016)

 

EFC letter to Senate HELP Committee Chairman Lamar Alexander (R-TN) and Ranking Member Patty Murray (D-WA) to inform the Senate HELP Committee and other lawmakers who represent states with EFC member organizations of the publication of a document outlining guiding principles for nonprofit, state-based, and state-chartered organizations who make education loans. The document serves to affirm the general principles that EFC member organizations have historically embraced to help families in their respective states to plan and pay for college and to outline the principles that all state-based, nonprofit organizations who make education loans should aspire to uphold (December 14, 2016)

 

Industry letter, signed by EFC, to U.S. Department of the Treasury Deputy Secretary Sarah Bloom Raskin, U.S. Department of Education Undersecretary Ted Mitchell, and Internal Revenue Service (IRS) Commissioner John Koshiken to highlight the importance of streamlining and automating the annual reapplication process for borrowers participating in income-driven repayment (IDR) plans. (October 12, 2016)

 

EFC letter to California Governor Jerry Brown, urging him to veto CA Assembly Bill 2251, the Student Loan Servicing Act, in favor of supporting legislation which would effectively protect student loan borrowers — without causing undue hardship for small, state-based entities (September 6, 2016)

 

EFC letter opposing California Assembly Bill 2251, the Student Loan Servicing Act (August 10, 2016)

 

EFC, CBA, NCHER, and SLSA comments in response to the June 16, 2016 Department of Education borrower defense to repayment proposed rules (August 1, 2016)

 

EFC, SLSA, and Consumer Bankers Association (CBA) comments to the Common Manual Policy Committee on Proposal #1312 in Batch 205 (increasing the Minimum Claim Payment Amount) (July 22, 2016)

 

EFC letter to House Speaker Paul Ryan (R-WI) and House Committee on Ways and Means Chairman Kevin Brady (R-TX) urging them to retain the tax exemption on municipal bond interest as they work to reform the tax system (July 20, 2016)

 

EFC letter to the Federal Communications Commission bringing to the Commission’s attention additional information that supports many of the points that EFC and other commenters have made regarding the Commission’s Notice of Proposed Rulemaking (NPRM) revising rules under the Telephone Consumer Protection Act (TCPA). In addition to the findings outlined in the Fiscal report, the letter provides the Commission with the results of an informal poll that EFC recently conducted of its members to determine the effectiveness of borrower live contact on reducing delinquencies. The findings of the informal survey overwhelmingly support Fiscal’s findings, and bolster EFC’s claim that, in a majority of cases, if a borrower can be contacted, that borrower can be helped (July 18, 2016)

 

EFC and NCHER letter to Representatives Kevin Brady (R-TX) and Sander Levin (D-MI), the Chairman and Ranking Member, respectively, of the House Committee on Ways & Means, urging them to support H.R. 3822, the Student Loan Opportunity Act of 2015, which will increase the availability of low-cost alternative loans to student and parent borrowers, allow these students and their families to refinance existing higher interest rate student loans, and expand opportunities and resources for students, families, and borrowers nationwide (June 27, 2016)

 

EFC comments to the Consumer Financial Protection Bureau in response to their Request for Information Regarding Student Loan Borrower Communications (June 9, 2016)

 

EFC comment letter to the Federal Communications Commission (FCC) regarding their recent Notice of Proposed Rulemaking (NPRM) revising rules under the Telephone Consumer Protection Act (TCPA) to implement a provision of the Bipartisan Budget Act of 2015 that excepts from TCPA’s prior-express-consent requirement autodialed and prerecorded calls "made solely to collect debt owed to or guaranteed by the United States" (June 6, 2016)

 

EFC, NCHER, and SLSA comments for the record for the Senate Committee on Commerce, Science, and Transportation hearing, “The Telephone Consumer Protection Act at 25: Effects on Consumers and Business” (May 17, 2016)

 

EFC letter to Senators Christopher Coons (D-DE), Angus King (I-ME), and Rob Portman (R-OH) endorsing their legislation, S.2800, the Stop Taxing Death and Disability Act, which would exempt from income tax federal and private education loans that are discharged due to the death or total and permanent disability of a student, and allow the parent of a student that becomes totally and permanently disabled to have their federal loan discharged (April 14, 2016)

 

EFC letter to Senator Debbie Stabenow (D-MI) endorsing her legislation, S.1128, the Early Pell Promise Act, which would authorize an Early Federal Pell Grant Commitment Program, in which eighth grade students who are eligible for free or reduced price lunch would receive a commitment to receive a Federal Pell Grant (March 24, 2016)

 

EFC letter to Representative Brenda Lawrence (D-MI) endorsing her legislation,H.R.4415, the Early Pell Promise Act, which would authorize an Early Federal Pell Grant Commitment Program, in which eighth grade students who are eligible for free or reduced price lunch would receive a commitment to receive a Federal Pell Grant (March 24, 2016)

 

MBFA, of which EFC is a member, letter to Representative Kevin Brady (R-TX), Chairman of the House Committee on Ways and Means, reaffirming the Municipal Bonds for America Coalition’s opposition to legislative proposals targeting municipal bonds, including private activity bonds (March 23, 2016)

 

EFC, NCHER, and SLSA letter to Representatives Fred Upton (R-MI) and Frank Pallone (D-NJ), the Chairman and Ranking Member, respectively, of the House Committee on Energy and Commerce, urging them to oppose H.R.4682, the HANGUP Act (March 7, 2016)

 

MBFA, of which EFC is a member, letter to Representatives Randy Hultgren (R-IL) and C.A. Dutch Ruppersberger (D-MD) thanking them for forming the Congressional Municipal Finance Caucus (March 4, 2016)

 

EFC, NCHER, and SLSA letter to Senators John Thune (R-SD) and Bill Nelson (D-FL), the Chairman and Ranking Member, respectively, of the Senate Committee on Commerce, Science, and Transportation, urging them to oppose S.2235, the HANGUP Act (February 22, 2016)

 

EFC letter to Senators Chuck Grassley (R-IA) and Kelly Ayotte (R-NH) congratulating them on the introduction of S.2043, the Know Before You Owe Federal Student Loan Act of 2015. EFC strongly supports the legislation and the Senators' efforts to strengthen the current student loan counseling requirements to promote smart borrowing and give more students the resources they need to make conscious, informed decisions on how to successfully finance their higher education (February 19, 2016)

 

EFC, NCHER, and SLSA letter to the Federal Communications Commission (FCC) providing background on federal student loan programs and related debt collection efforts as the FCC considers whether to adopt regulations that “limit the number and duration of calls made to a telephone number assigned to a cellular telephone service to collect a debt owed to or guaranteed by the United States,” as authorized under Section 227(b)(2)(H) of the Communications Act of 1934, as recently amended by Section 301 of the Bipartisan Budget Act of 2015 (January 26, 2016)

 

EFC, NCHER, and SLSA comment letter to the Department of Education on their proposed rules for the Revised Pay As You Earn repayment plan (REPAYE) and the required use of the Department of Defense database in granting the Servicemembers Civil Relief Act interest rate limit (August 10, 2015)

 

EFC and Multi-Association comment letter to the Board of Governors of the Federal Reserve System on the Board’s May 21 proposal to classify some municipal securities as High Quality Liquid Assets (July 24, 2015)

 

EFC comments to the Federal Communications Commission in response to their call for comments regarding a petition filed by Blackboard, Inc. calling for a reasonable and practical relaxation on the requirements of the Telephone Consumer Protection Act (TCPA) for educational organizations (May 6, 2015)

 

EFC and NCHER letter to the Internal Revenue Service in response to the invitation by the U.S. Department of Treasury and the IRS for public comment on recommendations on items for inclusion in the 2015‐2016 Priority Guidance Plan (April 30, 2015)

 

EFC letter to the Senate Committee on Health, Education, Labor, and Pensions in response to Chairman Lamar Alexander’s (R-TN) call for comment on his “Risk Sharing: Concepts and Proposals” white paper as it relates to the reauthorization of the Higher Education Act (April 23, 2015)

 

EFC letter to the Senate Committee on Health, Education, Labor, and Pensions in response to Chairman Lamar Alexander’s (R-TN) call for comment on his Consumer Information: Concepts and Proposals white paper as it relates to the reauthorization of the Higher Education Act (April 23, 2015)

 

EFC and NCHER letter on the Senate Finance Committee’s solicitation for ideas and input on comprehensive tax reform (April 14, 2015)

 

MBFA, of which EFC is a member, comments to the Senate Committee on Finance in response to their request for ideas and input on comprehensive tax reform (April 14, 2015)

 

EFC, Airport Councils International, and American Association of Port Authorities letter to preserve Private Activity Bonds and not limit it by the existing Alternative Minimum Tax in response to the Senate Committee on Finance request for input on comprehensive tax reform (April 13, 2015)

 

Letter to House Leadership urging retention of the tax-exempt status for municipal bonds, circulated by Representatives Randy Hultgren (R-IL) and C.A. Dutch Ruppersberger (D-MD) (April 13, 2015)

 

MBFA, of which EFC is a member, letter to President Barack Obama advocating for the retention of current law tax exemption for municipal bonds (March 27, 2015)

 

MBFA, of which EFC is a member, letter to Senate leadership advocating for the retention of current law tax-exemption for municipal bonds (March 27, 2015)

 

MBFA, of which EFC is a member, letter to House leadership advocating for the retention of current law tax-exemption for municipal bonds (March 27, 2015)

 

EFC letter to Senators Angus King (I-ME) and Richard Burr (R-NC) in Support of S.85, the Repay Act of 2015 (March 24, 2015)

 

MBFA, of which EFC is a member, letter to the Senate Committee on Finance tax reform working group expressing support of the current law tax-treatment of municipal bonds (February 26, 2015)

 

EFC and NCHER letter to Treasury requesting clarification regarding an interpretation of the IRC as it relates to refinancing student loans and making loans to parents using Qualified Student Loan Bonds (February 10, 2015)

 

EFC and Multi-Association letter to the Federal Communications Commission (FCC) requesting regulatory clarification of the Telephone Consumer Protection Act (TCPA) to help curb abusive lawsuits that likely harm consumers overall (February 2, 2015)