Sunday, October 22, 2017

Department of Education forgives student-loan debt owed by a wounded veteran, but the IRS sends him a tax bill for $62,000

At age 40, Will Milzarski, an attorney, took leave from his state government job to return to the U.S. Army. After completing officer training, he served two tours of duty in Afghanistan. where he led more than 200 combat missions.

On his last day in combat, Milzarski was wounded in the face, which left him with a traumatic brain injury, hearing loss, and post-traumatic stress disorder.  He was later determined to be totally disabled.

Milzarski returned to civilian life with $223,000 in student-loan debt, most of it acquired to obtain a law degree from Thomas M. Cooley School of Law. In accordance with its policy, the Department of Education forgave all of that debt due to Milzarski's disability status.

But then this wounded veteran received a surprise. The IRS considers forgiven debt to be taxable income, and thus it sent Milzarski a tax bill for $62,000.

Milzarski summarized his experience well. "One part of our government says, 'We recognized your service, we recognize your inability to work," Milzarski said. "The other branch says 'Give us your blood.' Well, the U.S. Army already took a lot of my blood."

Nearly 400,000 disabled Americans have student-loan debt, and this obscure tax provision impacts nearly all of them. Although they are entitled to have their student loans forgiven due to their disability status, this forgiveness comes with a tax bill.

And disabled student-loan debtors are not the only people affected by the IRS forgiven-loans rule. More than 5 million student-loan debtors are in long-term, income-driven repayment plans (IDRs), and most of them are making monthly payments so low that they are not repaying the accumulated interest.

Under the terms of all IDRs (there are several varieties), college borrowers who successfully complete their 20- or 25-year repayment plans are entitled to have any remaining debt forgiven. But IDR participants, like retired Lieutenant Milzarski, will get a tax bill for the forgiven debt.

Obviously, this state of affairs is insane. President Obama recommended a repeal of the IRS rule when he was in office, but nothing  came of his suggestion.

Surely a bill to repeal the IRS forgiven-debt rule would receive bipartisan support in Congress. Who could decently oppose a repeal? In fact, President Trump can probably reverse the rule that is persecuting Mr. Milzarski simply by signing an executive order.

I predict, however, that  that nothing will be done about this problem--either legislatively or by executive action. Washington DC is in so much partisan turmoil that almost nothing positive is getting done. Under current tax law, millions of student borrowers in income-driven repayment plans will have huge tax bills waiting for them when they complete their repayment obligations and have their remaining student-loan debt forgiven.

And unlike retired Lieutenant Milzarski, who is in his forties, most IDR participants will be in their sixties or seventies when their tax bills arrive in the mail. And if they can't pay their taxes, that will not be the government's problem. The IRS will simply garnish their Social Security checks.


Retired Lieutenant Will Milzarski (photo credit Matthew Dae Smith/Lansing State Journal via AP
References

Associated Press. Wounded Michigan vet gets student loan debt forgiven, but now IRS wants $62,000. Chicago Tribune, October 20, 2017.

Jillian Berman. Why Obama is forgiving the student loans of almost 400,000 peopleMarketwatch.com, April 13, 2016.

Judith Putnam. Student debt forgiven, but wounded vet gets $62,000 tax bill. USA Today, October 20, 2017.

Michael Stratford. Feds May Forgive Loans of Up to 387,000 BorrowersInside Higher Ed, April 13, 2016.


Saturday, October 21, 2017

For-profit colleges are exploiting African Americans. But you already knew that.

The National Center for Education Statistics issued a report in early October on long-term, student-loan repayment patterns, and two independent analyses highlighted the loan repayment patterns for African Americans.  Almost half of all black students who entered postsecondary education in 2003-2004 (49 percent) had defaulted on at least one of their student loans within 12 years.

Think about this statistic for a moment.

The consequences of defaulting on a student loan are catastrophic: a ruined credit rating and a ballooning loan balance due to penalties, collection fees, and accelerating interest.  Individuals who default on their student loans will be crippled in their ability to buy a home, marry, have children, or save for retirement.  And bankruptcy relief, although not impossible, is very rare for student-loan debtors. In short, most people who default on their student loans will be burdened by their debt for the rest of their lives.

Who would construct a student-aid system that ruins the lives of half the African Americans who participate in it?

And the story gets worse.  Three out of four black students who took out student loans to attend a for-profit college defaulted within 12 years. In essence, African Americans who borrow to enroll in a for-profit institution are playing Russian roulette with their financial futures--Russian roulette with four bullets in the revolver.

As an Inside Higher Ed article noted, the Department of Education "has not collected much data on student debt that can be broken out by the race or ethnic background of borrowers." Why not? Because DOE does not want the public to know that African American are getting ripped off by the higher education industry--and the for-profits, in particular.

The historically black colleges and universities (HBCUs) benefit from the status quo, the for-profit industry benefits from the status quo, and Congress benefits from the status quo because our legislators take campaign contributions from entities that depend on federal student-aid dollars--including the private equity funds that own some of the for-profit colleges.

Will these recent reports, which highlight racial exploitation in higher education, bring about change? I seriously doubt it. Everyone who is profiting from the federal student-aid program is playing a short game. The insiders want to make as much money as they can before higher education collapses--and collapse is fast approaching.

Russian roulette with four bullets

References

Paul Fain. Half of black student loan borrowers default, new federal data show. Inside Higher Ed, October 17, 2017.

Robert Kelchen, New Data on Long-Term Student Loan Default Rates. October 6, 2017.

Ben Miller. New Federal Data Show a Student Loan Crisis for African American Borrowers. Center for American Progress, October 16, 2017.


Sunday, October 15, 2017

Harvey Weinstein, the Napa-Sonoma Wildfires, and California's Travel Ban: Greetings from Flyover Country


Awhile back I wrote about California's legislative travel ban, which bars state-funded travel to states that passed so-called unprogessive legislation. Eight states are now on that list, including Texas and North Carolina.

At the time I wrote, I considered California's travel ban to be arrogant, self-righteous, and gratuitous. But that was before the Harvey Weinstein scandal and the Napa-Sonoma wildfires. Now I consider the travel ban to be pathetic.

People who live in flyover country have grown accustomed to being reprimanded by the California entertainment elites--all those beautiful people who are so cool and sensitive. We've endured public scoldings from the California legislature, which passed a law that bars state-funded travel to eight of California's sister states.

And now we find that Hollywood, the capital of coolness, has been enabling a sexual predator and accused rapist for decades. Everyone in the movie business knew Harvey Weinstein was preying on vulnerable women. His own company knew; in fact Harvey's employment contract contained a clause obligating Weinstein to reimburse his employer for future sexual abuse lawsuits (he had already settled with eight accusers) and to pay escalating penalties for future sexual assault complaints.

And then came the Napa-Sonoma wildfires, which have killed at least 40 people and scorched 350 square miles of the California wine country. Firefighters are pouring in from all over the United States to help fight these fires--including firefighters from North Carolina, which is under California's travel ban.

Do you think the California legislature will bar North Carolina fire crews from tackling the blaze in the Napa Valley? No, of course not. California's politicians want all the help the state can get to put out the deadliest wildfire in California history--even help from insensitive North Carolinians.

Do you think Hollywood will ask the folks in flyover country to boycott all the  movies associated with Harvey Weinstein? No. The movie industry depends on the rubes to buy movie tickets and $10 popcorn. Puh-leeze buy a ticket to see all the movies Harvey Weinstein and his cronies vomited into American culture.

Do you think any of Hollywood's supercilious, pompous asses will apologize to middle America for all the judgmental lectures they delivered while they covered up the Weinstein scandal? No, I don't think so.

But it is not my purpose to scold Hollywood or California politicians now that the Golden State's hypocrisy has been exposed. I don't wish to descend to the level of Alex Baldwin.

No, I wish to evoke the spirit of Woody Guthrie, the great folk singer and Dust Bowl refugee who migrated to California during the Great Depression, back in the days when California state troopers turned Okies away at the state border.
"This land is your land," Guthrie sang. "this land is my land.


From the California to the New York island
From the Redwood Forest
To the Gulf Stream watersThis land was made for you and me.



So this is my message to California:

We, the people of flyover country, grieve for you as you battle the Napa-Sonoma wildfires, and fire crews from all over America will come to help. We'll even continue watching the retched movies that Hollywood grinds out ever year.

But here's the thing: This land is not just your land. It's our land. It was a land made for all of us. So let's all be a little more tolerant toward one another.









Thursday, October 12, 2017

Louisiana State University: $30 water bottles, an official personal-injury law firm, and a student's death from alcohol poisoning

I live a couple of blocks from Louisiana State University, and I occasionally visit the campus book store. Or I should say I visit the Barnes & Noble book store that operates on the LSU campus.

As I walked in a few days ago, I noticed a large stack of plastic water bottles, all bearing the LSU logo. How much does such a water bottle cost, I asked myself? I discovered there are two versions. The basic plastic water bottle is priced at $25 and the premium bottle costs 27 bucks.  Actually, the premium bottle costs almost $30 because the buyer also pays a 10 percent sales tax.

Thirty dollars for a plastic water bottle!

The campus bookstore also has a coffee bar that sells Starbucks coffee for about four bucks a pop. Incidentally, the coffee bar is not owned by Starbucks so you can't use your Starbucks gift card there to buy your Starbucks coffee.

But that's OK because most students have debit cards, which they whip out to pay for everything. And how are students paying for $30 water bottles and four-buck exotic coffee? With student loans, of course.

But the expensive items at the Barnes & Noble bookstore are small beer. LSU recently completed a $85 million leisure project that includes a a 645-foot "lazy river" water feature shaped in the letters LSU.

Mercilessly ridiculed for constructing this monstrosity, LSU officials solemnly defended the project. "I will put it up against any other collegiate recreational facility in the country when we are done because we will be the benchmark for the next level,"Laurie Braden,  LSU's recreation director, said in 2015. I have no idea what that means.

LSU's world-class spa is conveniently located near LSU's fraternity houses, but the frat boys apparently are not visiting it enough. Nine members of Phi Delta Theta were indicted this week on charges of hazing after Maxwell Gruver, a freshman from Georgia, died of "acute alcohol intoxication" while at a drinking party.

Hazing is a crime in Louisiana, but the frat boys' lawyers insist that the drinking incident was not hazing. As a matter of fact, a fraternity member lured Gruver to the drinking site by directing him to report for "Bible study." And perhaps that is the proper description of an incident that left Gruver's system pickled with five times the legal amount of alcohol in his system.

In any event, what's the big deal? According to experts, Gruver "probably slipped out of consciousness and died without pain . . ., as if under anesthesia." And no one was charged with murder because, hey, college boys will be college boys.

Mr. Gruver's death will soon be forgotten.  All that matters at LSU is football. LSU's stadium was expanded to seat 103,000 fans, including the high rollers who sit in air-conditioned executive suites and drink premium liquor while the plebeians sweat it out in the cheap seats.

Everyone wants to be associated with the LSU Tigers. In fact, the Tigers have an official personal-injury law firm by the name of Dudley DeBosier. What does it mean to be the LSU Tigers' official injury law firm? Dudley DeBosier explains it to us on its web site:

"Being the Official Injury lawyers of LSU Athletics means more to us than just a simple sponsorship," the firm assures us:
It means hot boudin, jambalaya, fried catfish, and more gumbo than you can eat. It’s thousands of smiling faces walking in between stately oaks and broad magnolias on a Saturday morning. It’s the sound of Tiger Stadium as you cheer on your team with 100,000 of your closest friends. It’s the traditions, tailgates, and everything else we love about Louisiana.
 Got it. So if I get maimed on Interstate 10 by an 18-wheeler, I'm going to hire Dudley DeBosier to sue the trucking company because--well, Dudley DeBosier is LSU's official injury law firm.

Meanwhile, LSU is tearing down an old dorm and constructing new, more luxurious student housing. Some LSU officials feel that the students should live in at least as much splendor as Mike the Tiger--LSU's mascot, who resides in a "habitat" that looks like Club Med.

LSU officials say they are only providing all these amenities because this is what today's students demand. And indeed, the student body voted to pay for the lazy river with student fees.  From the students' perspective, I suppose, the cost of going to college is immaterial. After all, everything is paid for with student loans; and if the costs go up, Uncle Sam and Wells Fargo are always there to loan students more money.




Maxwell Gruver probably "died without pain" from alcohol poisoning


Meanwhile, Mike the Tiger has his own private swimming pool.

References


Rebekah Allen, Grace Toohey, and Emma Discher. 10 booked in LSU fraternity hazing death case. The (Baton Rouge) Advocate, October 12, 2017, p. 1.

Alla Shaheed. LSU's 'lazy river' leisure project rolls on, despite school's budge woesFox News, May 17, 2015.

Lela Skene. LSU fraternity pledge Maxwell Gruver's 'off the charts' blood-alcohol level shocks experts. The (Baton Rouge) Advocate, October 11, 2017.

Wednesday, October 11, 2017

Bloomberg reports that student-loan delinquencies have ticked upward: Another sign of growing misery among student debtors

Shahien Nasiripour, writing for Bloomberg.com, wrote an article last month about rising student-loan delinquency rates. As of June 30th, 18.8 percent of student borrowers were at least one month late on their loan payments.  That's about 3.3 million college borrowers.

The Department of Education's June report showed a slight uptick from the delinquency rate one year earlier, when 18.6 percent of student debtors were a month late on their loan payments.

What does this mean?

Yelena Shulyatyeva, a senior economist for Bloomberg Intelligence, professed to be mystified. "There's no fundamental reason for that to be happening," Shulyatyeva said.

James Kvaal, who was President Obama's Deputy Director of White House Domestic Policy, also seemed stumped by rising delinquency rates. "That the trend has stalled," Kvaal said, "is not yet a warning sign, but it is a question mark."

Nasiripour, who has done some fine reporting on the student loan crisis, summarized why this development is puzzling to many policy experts. "After all," she wrote, "the U.S. economy has improved since June of last year, with lower unemployment, higher household incomes and increased wealth, federal data show." Moreover, Nasiripour pointed out "Consumers are more confident about the economy, and their own personal finances, too, according to Bloomberg Consumer Comfort data."

But rising delinquency rates are just one more sign that the student loan program is in meltdown. Let's tick off some more disaster indicators:
  • Last year, 1.2 million Americans defaulted on their student loans at an average rate of 3,000 defaults a day.
  • A recent report released by the National Center for Education Statics revealed that almost 6 people in ten who first enrolled for postsecondary education in 1995-96 had not paid off their student loans 20 years later.
  • As reported by the Wall Street Journal, more than half the students at a thousand colleges and schools had not reduced their student-loan debt by one penny seven years into repayment.
  • According to a 2016 report from the Government Accounting Office, half the people who entered income-driven repayment plans to lower their monthly loan payments were removed from their IDRs for failing to recertify their income.
  • Brookings Institution report noted that more than one out of four people (28 percent) in a recent cohort of student borrowers defaulted on their loans within five years of beginning repayment. The default rate among students who attended for-profit colleges was 47 percent.
Congress, the Department of Education, and the higher education industry refuse to face reality. I suppose all the people who should be addressing this crisis are hoping they will be retired and playing golf in Florida when the student-loan program collapses.

And collapse it will. In the meantime, millions of student-loan debtors are buried under a mountain of debt.

I believe the federal bankruptcy courts are slowly awakening to this crisis and that they are increasingly willing to rule compassionately toward distressed student debtors who seek bankruptcy relief.  The Murray decision out of Kansas, which was affirmed on appeal last month, is a heartening sign.

The Murrays were fortunate enough to have been represented by an able attorney, and they also received assistance in the form of an amicus brief filed by the National Consumer Law Center and the National Association of Consumer Bankruptcy Attorneys.

Unfortunately, few insolvent student debtors are able to find attorneys to take their cases. If American lawyers understood the student-loan crisis for what it is--a human rights issue, they might take up some of these cases as volunteers, much as the civil rights lawyers did in the 1960s, when attorneys from across the United States came South at the risk of their lives to represent civil rights activists.

I am convinced that the solution to the student-loan catastrophe lies with the federal bankruptcy courts. Congress does not have the collective courage to address this problem legislatively, and the higher education industry--like a cocaine addict--survives from day to day on regular infusions of federal student-aid money.

American colleges, like drug addicts, survive from day to day on regular infusions of federal student-aid money.


References

Andrea Fuller. Student Debt Payback Far Worse Than BelievedWall Street Journal, January 18, 2017.


Shahien Nasiripour. More Americans Are Falling Behind on Student Loans, and Nobody Quite Knows Why. Bloomberg.com, September 28, 2017.

The Wrong Move on Student LoansNew York Times, April 6, 2017.

US. Government Accounting Office. Federal Student Loans: Education Needs to Improve Its Income-Driven Repayment Plan Budget Estimates. Washington, DC: U.S. Government Accounting Office, November, 2016.

Jennie H. Woo, Alexander H. Bentz, Stephen Lew, Erin Dunlop Velez, Nichole Smith, RTI International,  (2017, October). Repayment  of Student Loans as of 2015 Among 1995-96 and 2003-04 First-Time Beginning StudentsFirst Look (NCES 2018-410). U.S. Department of Education. Washington DC; National Center for Education Statistics. [Sean A Simone, Project Officer]


Saturday, October 7, 2017

Alan and Catherine Murray discharged more than $200,000 in student loans in a Kansas bankruptcy court and their victory was affirmed on appeal: Good news for middle-income college borrowers

In a previous essay, I wrote about Alan and Catherine Murray, a married couple in their late forties who defeated Educational Credit Management Corporation in a Kansas bankruptcy court.  ECMC appealed, and the Murrays prevailed again--a victory that has important implications for middle-income student-loan debtors.

The Murrays took out student loans in the 1990s to obtain undergraduate degrees and master's degrees. Their total indebtedness was $77,000, which they consolidated in 1996 at an interest rate of 9 percent.

Over the years, the Murrays paid $54,000 toward paying off these loans--70 percent of the amount they borrowed. But they obtained economic hardship deferments during periods of financial stress, which allowed them to skip some loan payments.  And they entered into an income-based repayment plan to lower their monthly payments to a manageable level.

Although the Murrays handled their student loans in good faith, interest on their debt continued to accrue; and they made no progress toward paying off their debt. In fact, when they filed for bankruptcy in 2014, their loan balance had ballooned to $311,000--four times what they borrowed!

Judge Dale L. Somers, a Kansas bankruptcy judge, gave the Murrays a partial bankruptcy charge. It was clear, Judge Somers ruled, that the Murrays could not pay off their total student-loan indebtedness and maintain a minimal standard of living. And it was also clear that their financial situation was not likely to change. Finally, Judge Somers concluded, the Murrays had handled their student loans in good faith--an essential requirement for discharging student loans in bankruptcy.

On the other hand, Judge Somers determined, the Murrays could pay off the original amount they borrowed ($77,000) and still maintain a minimal standard of living. Thus, Judge Somers discharged the accumulated interest on the Murrays' debt, but required them to pay back the original amount they borrowed.

ECMC, the Murrays' ruthless creditor, appealed Judge Somers' decision. ECMC argued, as it always does, that the Murrays should be put in a long-term income-based repayment plan (IBR) that would last from 20 or 25 years.

But U.S. District Court Judge Carlos Murguia, sitting as an appellate court for the appeal, affirmed Judge Somers' decision. "The court agrees with Judge Somers' findings and conclusions that [the Murrays] made a good faith effort to repay their loans," Judge Murguia wrote.

Significantly, Judge Murguia, ruling in the capacity of an appellate judge, explicitly rejected ECMC's argument that the Murrays should be placed in an IBR and that none of the Murrays' $311,000 debt should be forgiven.

"The court disagrees," Judge Murguia wrote. "Under the circumstances of this case, debtors' payments under an IBR plan are insufficient even to stop the accrual of additional interest, and such payments directly contravene the purpose of bankruptcy."  Judge Murguia noted that Judge Somers had not discharged all of the Murrays' indebtedness--only the accumulated interest. "He discharged that portion--the interest--that had become an undue hardship on debtors, denying them a fresh start."

ECMC v. Murray is an important case for two reasons: First, this is one of the few student-loan bankruptcy court decisions that have granted relief to middle-income student borrowers. The Murrays' combined income was about $95,000.

Second, the key ruling by both Judge Somers and Judge Murguia was their finding that the interest on the original debt would constitute an undue hardship for the Murrays if they were forced to pay it back. Furthermore, this would be true even if the Murrays were placed in an IBR because the monthly payments under such a repayment plan were insufficient to stop the accrual of interest.

There are hundreds of thousands of people in circumstances very similar to the Murrays. Their loan balances have doubled, tripled or even quadrupled due to accumulating interest. People in this situation will never pay off their total indebtedness. But most of these people, like the Murrays, can pay off the amount they originally borrowed if only the accumulated interest were wiped out.

Let us hope student loan debtors situated like the Murrays will learn about ECMC v. Murray and find the courage to file bankruptcy and seek a discharge of their student loans--or at least the accumulated interest.  After all, it is the accumulated interest, penalties and fees that have put millions of student borrowers in a hopeless situation. The Murray decision offers a fair and reasonable solution for these people and gives them a fresh start. A fresh start, after all, is the core reason that  bankruptcy courts exist.


References

Murray v. Educational Credit Management Corporation (Bankr. D. Kan. 2016), aff'd, No. 16-2838 (D. Kan. Sept. 22, 2017).


Friday, October 6, 2017

Why won't Congress do a few things to ease the student debt crisis like stop the government from garnishing Social Security checks of elderly student-loan defaulters?

James Howard Kunstler posted a blog last week in which he challenged Congressional Democrats to introduce legislation to counteract the effect of Citizens United v. Federal Election Commission, 558 U.S. 310 (2010). In that case, you may recall, the Supreme Court ruled that corporations can give as much money as they like to political campaigns. 

All sensible people agree that Citizens United triggered a new level of corruption in national politics as corporations pump millions of dollars into Congressional campaign coffers in order to protect their venal interests.

President Obama complained publicly about Citizens United while he was in office.  But he didn't do anything about it, even though he could have ameliorated its effect through legislation when the Democrats controlled the Senate and the House of Representatives.

Democrats can still put a Citizens United override on their legislative agenda as Kunstler challenged them to do:
That’s your assignment Chuck Schumer, Nancy Pelosi, and the rest of the Democratic Party leadership. Get serious. Show a little initiative. Do something useful. Draw up some legislation. Get behind something real that might make a difference in this decrepitating country. Or get out of the way and let a new party do the job.
And of course there are plenty of other things the Democrats can do to promote fairness and justice in our society. As Gretchen Morgenson pointed out in a New York Times article last year, hedge fund managers get a special tax break allowing them to pay lower taxes on their income than most Americans.  That's right: a hedge fund manager is taxed at a lower rate than a New York school teacher.  President Obama could have closed that loophole in the tax law by executive action, but he didn't.

And then there's corporal punishment in the schools. Researchers are unanimous that beating children with boards is not good for them, and the United Nations has identified corporal punishment as a human rights abuse.

In the waning days of the Obama administration, Secretary of Education John King, Jr. condemned corporal punishment in an open letter to the nation's school leaders. But why didn't King speak up sooner? Corporal punishment in schools is a wrong that Obama's Department of Education could have stopped with an administrative regulation. Why didn't it? 

And then there's the student-loan program, which has brought suffering to millions.  According to the Government Accountability Office, the Department of Education garnished the Social Security checks of 173,000  student-loan defaulters in 2015, a practice that Senator Elizabeth Warren bitterly condemned. The amount the government collects each year is a pittance--about one eighth the amount Hillary Clinton spent during the 2016 election season. And most of the money the Feds collect goes to paying interest and penalties without reducing the debtors' loan balances at all.

Senator Warren and Claire McCaskill filed a bill to stop the garnishment of student debtors' Social Security checks, but the measure never made it out of committee. Why won't Senator Schumer and Representative Pelosi get behind that bill? Who could decently oppose it?

In fact, there are numerous noncontroversial things our Congressional representatives could do to ease widespread suffering among the nation's poorest Americans. But  our Congressional representatives are not doing these things. 

Why? Two reasons.

 First, they don't want to do noncontroversial good things because that would mean sharing the credit with their political enemies.

And second, Nancy Pelosi, Chuck Schumer, John McCain, Mitch McConnell and all our other bozo representatives don't work for us. They work for the lobbyists, their campaign contributors, and the global financial institutions; and that keeps them pretty busy.




References

Secretary of Education John B. King, Jr. Letter to Governors and State School Officers, November 22, 2016.

James Howard Kunstler. Homework AssignmentClusterfuck Nation, September 29, 2017.

Gretchen Morgenson. Ending Tax Break for Ultrawealthy May Not Take Act of CongressNew York Times, May 6, 2016.


Senator Elizabeth Warren Press Release, December 20, 2016. McCaskill-Warren GAO Report Shows Shocking Increase in Student Loan Debt Among Seniors

United States Government Accountability Office. Social Security Offsets: Improvement to Program Design Could Better Assist Older Student Borrowers with Obtaining Permitted Relief. Washington DC: Author, December 2016).