This week, the U.S. Department of Education announced changes to the PLUS loan underwriting standards that may help previously denied PLUS loan applicants obtain loans. This will be welcome news to previously approved loan applicants who found themselves unexpectedly denied last year.
But federal PLUS loans can be risky business for graduate students and parents of undergraduates who can use them to borrow up to the full cost of attendance at college. Much more can be done to protect consumers from getting too deeply into debt. The Department of Education recently added PLUS loan underwriting standards to its list of items to potentially consider during negotiated rule-making, the process where students, advocates and colleges work with the federal government to hash out new regulations.
The National Association of Student Financial Aid Administrators offers three recommendations to add vital consumer protections to Federal PLUS loans.
Separate Parent PLUS Loans from Graduate PLUS Loans. Currently, there is one PLUS Loan program available to both parents (Parent PLUS) and graduate/professional students (Grad PLUS). This is a relatively new development: the Grad PLUS program was simply added onto the existing Parent PLUS program in 2005 to help graduate students cover the increasing costs of their programs.
While the borrowing profiles of parents and graduate students differ greatly, the same credit standards are applied to both. Lumping these groups together makes little practical sense. Separating the Grad PLUS and Parent PLUS programs would allow for vital variations in credit standards, loan limits, and interest rates that should be tailored to these two different populations.
Increase Loan Underwriting Standards on Parent Loans for New Students. Appropriate underwriting not only protects the lender (in this case the taxpayer), but also borrowers, by preventing them from getting into unmanageable amounts of debt.
The underwriting criteria for PLUS loans are minimal, resulting in approvals for parents who may not actually be in the best financial position to borrow. In fact, each year colleges field thousands of pleas from parents who have been approved for PLUS loans but believe they should have been denied. These parents know they cannot afford the loan debt on their income or have little experience with any form of significant debt. Yet, in order for dependent undergraduate students to receive additional federal loans in their own name, parents must first apply for -- and be denied -- a PLUS loan.
The sole credit criterion for PLUS loans is that an applicant “not have an adverse credit history,” meaning they cannot be 90 or more days delinquent on any debt or have defaulted or received a bankruptcy discharge in the last five years. Put another way, having no credit is tantamount to having good credit for purposes of a PLUS loan and -- perhaps even more troubling -- approval from the government doesn’t require even a simple debt-to-income analysis.
Using the current definition of adverse credit makes sense for graduate students who haven’t had time to build a credit history. Ignoring debt-to-income ratios also makes sense for graduate students whose earnings will increase based on the very educations they’re financing.
But parental earnings don’t increase because of an educational investment in their children. And unlike graduate borrowers, parents lack access to loan forgiveness programs offered through public service or the government's Pay As You Earn plan. When determining credit worthiness, parent eligibility credit criteria should include some measure of likely ability to repay, such as a debt‐to‐income measure, FICO score, or another test of adequate resources. Allowing parents to assume unmanageable amounts of debt presents a fiscal and moral hazard to both the taxpayer and borrower.
It must be noted that any changes to restrict access to Parent PLUS loans should only impact new students, so as not to disrupt current enrollments. ED learned this the hard way after the agency unexpectedly, and with little fanfare, tweaked underwriting standards last year. The move resulted in harsh criticism from some students, institutions, and lawmakers. Rep. Marcia Fudge (D-Ohio), chair of the Congressional Black Caucus, claimed in an August 1 statement that the change disproportionately impacted students attending historically black institutions and demanded that ED “immediately suspend use of the new ‘adverse credit’ criteria as a determinant for Federal Parent PLUS Loan eligibility.”
In response, ED has begun reconsidering previously denied PLUS loan applicants. Lest anyone believe the lesson here is to never reconsider underwriting standards that ultimately protect parent borrowers, it should be pointed out that the furor would likely have been much less had this not disrupted currently enrolled students who are now depending on these funds to graduate.
More Transparency in Federal PLUS Borrowing. Good public policy must be built on good data, yet the availability of data on federal PLUS borrowing is abysmal. Basic information about PLUS loan approval or denial rates, default and delinquency rates, and repayment plan distributions are difficult if not impossible to obtain. While Congress and the Education Department have significantly increased disclosures requirements placed on colleges regarding graduate earnings, dropout rates, repayment rates, educational costs, and Stafford loan defaults, there is no comparable level of disclosure from the department on Federal Parent or Grad PLUS loan borrowing.
The feds certainly have this information, so why not share it?
Efforts to better target the PLUS programs to the groups they serve, bolster underwriting standards for parent borrowers, and increase transparency would significantly strengthen the programs and help ensure that these federal loan dollars are used to provide access to higher education without crushing current and future borrowers.
Justin Draeger is president of the National Association of Student Financial Aid Administrators.
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