Tuesday, September 29, 2015

NY Times Urges "Speedy Help for Victims of College Fraud," but the Times Does Not Go Nearly Far Enough

Let's give the New York Times credit: it is on the right side of the argument regarding the federal student loan program. The Times editorializes repeatedly about the plight of people who cannot pay back their college loans. The newspaper has published several fine news articles about individuals who are overwhelmed by student-loan debt. And again and again, the Times editorial writers demand action by the federal government to bring relief to desperate student-loan borrowers.

Unfortunately, the Times does not grasp this simple fact: True relief for student-loan debtors will require radical action, far more radical than the Times is willing to contemplate.

Last Sunday, a Times editorial addressed the issue of fraud in the for-profit college sector. As the Times pointed out, "The federal government's decades-long failure to curb predatory behavior in the for-profit college industry has left untold numbers of Americans with crushing debt while providing useless degrees--or no degrees at all--in return."

The Times then went on to praise the Obama administration for creating new oversight rules for the  for-profit college industry. And the Times expressed approval of the Department of Education's decision to forgive the student-loan indebtedness of some individuals who attended Corinthian Colleges (about 3,000 people so far).

But, as the Times pointed out, DOE has yet to grant relief  to any of the 4,000 people who claim they were defrauded by Corinthian and have asked to have their student-loans forgiven.

The Times expressed the fear that DOE's "legendary bureaucracy will drag its feet and make it difficult for deserving plaintiffs to get relief." And the Times ended its rather tepid editorial by stating vaguely that "the department needs to do a much better job of reaching out to people who have potential [fraud] claims."

The Times editorial is on the right track; obviously DOE needs to speed up the process of reviewing fraud claims by students who attended for-profit colleges. But I don't think the Times recognizes the enormity of the student-loan problem in the for-profit college sector.

A recent study by the Brookings Institution reported that there are almost 1.2 million people who attended the University of Phoenix who have more than $35 billion in outstanding student loans.  According to the Brookings study, 45 percent of a recent cohort of former University of Phoenix students defaulted on their loans within five years.

More alarmingly, for the for-profit sector as a whole, nearly three quarters of students who attended for-profit schools  (74 percent) owed more than they originally borrowed two years after beginning repayment (for the 2009 cohort).  And nearly half the students who attended for-profit schools (47 percent) defaulted within five years of beginning repayment.

And Brookings default data did not take into account the fact that many former students have obtained economic-hardship deferments and are not making their student-loan payments. Those people are not counted as defaulters even though they are not paying down their loans.

For-profit colleges are encouraging their former students to  sign up for economic-hardship deferments as a strategy for keeping their institutional default rates down. Tragically, most of the people who obtain economic-hardship deferments receive only phantom relief because the interest continues to accrue on their unpaid debt. When those economic-hardship deferments come to an end, the people who held them will find that the principal of their loans went up during the deferment period.

IN SHORT, IT IS INDISPUTABLE THAT HALF OF THE PEOPLE WHO TOOK OUT STUDENT LOANS TO ATTEND FOR-PROFIT COLLEGES WILL DEFAULT AT SOME POINT IN THE LOAN REPAYMENT PERIOD. In other words, about half of the federal student-aid money flowing into for-profit colleges will never  be paid back.

If the Times grasped the magnitude of the student-loan crisis in the for-profit college sector it would surely recommend more aggressive action by the Feds.  What is needed is not a more streamlined fraud review process (as the Times recommended), but something close to blanket amnesty for at least half of the people who borrowed money to attend for-profit colleges.

Put another way, DOE needs to craft a secular version of Pope Francis's "Year of Mercy," whereby millions of people who attended for-profit colleges can have their loans forgiven with little or no red tape.

Obviously some case-by-case review needs to occur to make sure student loans aren't forgiven for students who got good value from attending for-profit colleges and can afford to pay back their loans. But--based on the default rates--a majority of the people who attended for-profit colleges should have their loans forgiven.

What is the best process for sorting through this mess? Bankruptcy. Student-loan defaulters who attended for-profit institutions should have their loans forgiven by bankruptcy courts without the necessity of adversary hearings. If a bankruptcy court concludes that a student-loan debtor is insolvent, that person's loans should be forgiven unless the government can show fraud or bad faith.

But the burden should be on the government to show that an insolvent student-loan debtor who attended a for-profit college is not entitled to bankruptcy relief--not on the debtor.

Obviously, I have painted an ugly picture: massive student-loan forgiveness and default on billions and billions of dollars in student-loan debt. But most of the defaulters who attended for-profit colleges will never pay their loans back,  whether or not their loans are forgiven.

It is time to wipe the slate clean. The for-profit college industry should be shut down and the people who were injured by it deserve a fresh start.  We can take action now or we can take action later. But eventually, the federal government will have to face facts: the for-profit colleges are a rogue industry and have ruined the economic prospects of millions of people.


Kelly Field, "U.S. Has Forgiven Loans of More Than 3,000 Ex-Corinthian Students, Chronicle of Higher Education, September 3, 2015. Accessible at: http://chronicle.com/article/US-Has-Forgiven-Loans-of/232855/?cid=pm&utm_source=pm&utm_medium=en

Adam Looney & Constantine Yannelis, A crisis in student loans? How changes in the characteristics of borrowers and in the institutions they attended contributed to rising default rates. Washington, DC: Brookings Institution (2015). Accessible at: http://www.brookings.edu/about/projects/bpea/papers/2015/looney-yannelis-student-loan-defaults

Tamar Lewin, "Government to Forgive Student Loans at Corinthian Colleges," New York Times, June 8, 2015. Accessible at: http://www.nytimes.com/2015/06/09/education/us-to-forgive-federal-loans-of-corinthian-college-students.html?_r=0

Speedy Help for Victims of College Fraud. New York Times, September 27, 2015, Times Review Section, p. 10.

Monday, September 21, 2015

Student Loan Crisis? What Student Loan Crisis? NAFSA Attendees Vote in New Orleans and Conclude That Student Loan Program Is Not In Crisis

The National Association of Student Financial Aid Administrators (NASFA) held its annual conference in New Orleans last July, and members discussed the federal student loan program. According to Inside Higher Education, NAFSA members listened to a panel of experts speak on the topic and then cast their ballots. "A majority of attendees voted to say that student loan debt, while perhaps problematic, was not of crisis proportion" (Stratford, 2015).

And of course for the NAFSA members, the student loan program is not in crisis. After all, they all have jobs, the colleges are getting their tuition money, and the federal government shows no inclination toward shutting off the spigot of student-loan money.  Someday the party will come to an end, but the NAFSA people are hoping the federal student-loan program won't collapse until after they retire.

deluge meaning


Michael Stratford, Student debt protesters crash annual gathering of college financial aid officers. Inside Higher Education, July 21, 2015.

Private Colleges Behave Like Car Salesmen and They Deserve the Same Level of Respect

When I was young, car buying was a very stressful experience. In the old days, car buyers were always at a disadvantage. They didn't actually know the fair price of 1962 Ford Fairlane, and they didn't know how much other people were paying for them. Thus car buying involved tense negotiations, urgent consultations between car salespeople and their supervisors, and sweaty car buyers sitting in showrooms wondering if they were about to pay too much.

And sure enough, right after you drove your shining new Plymouth Fury home and parked it proudly in the driveway, your neighbor came over to tell you that his brother-in-law got the same model for a hundred bucks less and the dealer threw in whitewall tires for free.

How much is this beauty really worth?
Today, car buyers have a lot more information about car prices, thanks to websites like Edmunds.com. But families are much in the same position as car buyers in the 1960s when they shop for a college. They really don't know what the fair price of a college education is, and they don't know what other families are paying. And colleges, just like 1960s car dealers, do all they can to obscure the fair price of a college education.

For example, Utica College in central New York and Rosemont College in Pennsylvania recently slashed their tuition prices drastically. Utica cut its tution from $35,466 to $20,000--a 42 percent price reduction. Rosemont dropped its tuition price from $46,000 ($46,000!) to $30,000--a discount of more than 30 percent.

Wow! Prices Slashed! Everything Must Go! What a lucky break for college students and their families. Just like the end-of-the-year sale at the Chevy dealer.

But wait. According to Inside Higher Education, very few Utica and Rosemont students were actually paying the full cost of tuition. At Utica, only 271 out of 2,300 students were paying the sticker price. And at Rosemont, only 9 out of 1,100 students were paying full tuition--less than 1 percent!

Rosemont and Utica, like most American colleges and universities, are engaging in differential pricing. They set a very high sticker price, hoping a few suckers will pay it; and then they offer steep discounts to the students they really want to attract--minorities, students with high SAT scores, athletes, legacies, etc. In fact, nationwide, the average tuition price at private schools is about half of the posted tuition.

Of course, all businesses adjust their prices somewhat to attract buyers at various income levels. That's the way business has been done since the beginning of time.

But American colleges have taken differential pricing so far that they've tarnished their integrity. How can a college honestly say that its tuition price is $46,000 when less than one percent of its students actually pays that price?

The hocus pocus about college tuition prices is part of the general confusion about college costs. The FAFSA form for financial aid is unintelligible, tuition varies from student to student, and the student-loan process is so complicated that many students don't know how much money they borrowed, how much they still owe, or whether their loan is a federal loan or the loan from a private lender.

But that's the way the colleges like it. Keep 'em confused. And if a customer asks too many difficult questions, throw in a set of whitewall tires to seal the deal.

My brother-in-law told me you'd give me a really good deal . . . .

Big price cuts, small savings at two private colleges. Inside Higher Education, September 17, 2015. Accessible at: https://www.insidehighered.com/quicktakes/2015/09/17/big-price-cuts-small-savings-2-private-colleges

The deluge is upon us: University of Phoenix students owe the taxpayers $35 billion; and 45 percent default within five years

Earlier this month, the Brookings Institution published a report on student-loan default rates; and some of its findings are truly shocking.  The report ranked institutions based on their students' total accumulated outstanding loans. University of Phoenix, a for-profit college company, ranked number 1; almost 1.2 million University of Phoenix students have racked up more than $35 billion in outstanding student-loan obligations.

And ponder this: 45 percent of the students in the University of Phoenix's 2009 cohort defaulted on their student loans within five years  
(Looney & Yannelis, 2015, table 5).

Image result for "university of phoenix" images

Brookings' researchers also reported that about three quarters of students (74 percent) who attended for-profit schools owed more than they originally borrowed two years after beginning repayment (for the 2009 cohort).  And nearly half of students who attended for-profit schools (47 percent) defaulted within five years of beginning repayment.

These are astonishing figures. And when we consider that a lot of former students who attended for-profit schools are enrolled in economic-hardship deferment programs and are not making loan payments, this sobering fact seems indisputable: more than half of the people who borrow money to attend for-profit colleges eventually default on their loans.

The Brookings Institution argues that the nation's high student-loan default rate can mostly be attributed to students who are "non-traditional borrowers," which it defines as students who attended for-profit colleges or two-year schools. Among all students who began repayment on their loans in 2011 and defaulted by 2013, 70 percent were nontraditional borrowers.

Loaning money for students to attend for-profit schools is irresponsible.

Based on these numbers, even a child can conclude that the federal government should not be loaning money to students who enroll in for-profit programs because taxpayers are going to get less than half of it back.  And--what is far worse--a lot of minority students and students from disadvantaged backgrounds will have student-loan debt hanging around their necks for the rest of their lives.  For these students, attending a for-profit school did not improve their lives; attending a for-profit school made their lives worse. 

Arne Duncan's Department of Education knows that the for-profit college sector is out of control, and it is made some efforts to provide student-loan debtors a little relief. For example, DOE granted loan forgiveness to about 3,000 students who attended one of Corinthian Colleges' campuses after Corinthian went bankrupt earlier this year. But there are more than 300,000 former Corinthian students.

Reasonable bankruptcy relief is the only humane remedy for non-profit students who default on their loans.

I do not think Congress or the Department of Education will ever shut off the federal-loan spigot to the for-profit colleges. This industry has protected itself with lobbyists, attorneys, and strategic campaign contributions.  Year after year, misguided students will continue to enroll at for-profit schools, and at least half will eventually default.

But  in the name of common decency, can't we at least give student-loan defaulters, who are suffering by the millions, some effective relief?  Do we have to make it so difficult for student-loan defaulters to file for bankruptcy and get a fresh start? Do we really want to force them into 25-year repayment plans, basically turning them into economic serfs for the balance of their working lives?


Adam Looney & Constantine Yannelis, A crisis in student loans? How changes in the characteristics of borrowers and in the institutions they attended contributed to rising default rates. Washington, DC: Brookings Institution (2015). Accessible at: http://www.brookings.edu/about/projects/bpea/papers/2015/looney-yannelis-student-loan-defaults

Wednesday, September 9, 2015

You can't win if you don't play: More people should attempt to discharge their student loans in bankruptcy

It's a mess, folks. Seven million people are currently in default on their student loans. Millions more have stopped making payments but aren't counted as defaulters because they obtained economic-hardship deferments, which are given out like candy.  Almost 4 million people are making payments under income-based repayment plans that can last as long as 25 years. Twenty-five years!

Why don't some of these overburdened student-loan debtors file for bankruptcy?  I'll tell you why. Most people believe it is impossible to obtain relief from their student loans in the bankruptcy courts.

But that's not true. Three years ago, Jason Iuliano published an empirical study of student-loan discharges under the Bankruptcy Code's "undue hardship" provision. This is what he found:

  • Nearly forty percent of people who attempted to discharge their student loans in the bankruptcy process obtained relief.
  • People who attempted to discharge their student loans without an attorney were as successful in obtaining bankruptcy relief as people who hired bankruptcy lawyers.
The problem, according to Iuliano, is not that it is impossible to obtain a discharge of student loans in bankruptcy. THE PROBLEM IS THAT MOST PEOPLE DON'T TRY.

In 2007, Iuliano reported, almost a quarter of a million people with student loans filed for bankruptcy (238,446 to be exact). Of that number, less than 300 even attempted to discharge their student loans in bankruptcy. Apparently they assumed that it would be useless to try.

Iuliano constructed a model for predicting which factors were most important in obtaining a student-loan discharge. He estimated that 69,000  student-loan debtors  who filed for bankruptcy in 2007 were good candidates for discharge if they had only applied for relief.

In other words, based on Iuliano's research, more insolvent student-loan debtors should be seeking to discharge their student loans in bankruptcy because a fair percentage are likely to be successful. But you can't win if you don't play. 

Iuliano's article was published in 2012 based on 2007 bankruptcy data. I think the percentage of successful student-loan discharges would be higher today than it was during the period Iuliano studied. Several recent bankruptcy court decisions show that at least some courts are beginning to view student-loan debtors with more compassion than courts once did.

In the Roth case, for example, the Ninth Circuit's Bankruptcy Appellate Panel rejected a loan creditor's argument that Ms. Roth should be put in a 25-year repayment plan. "The law does not require a party to engage in futile acts," the court said.   Roth was a 68-year old woman with chronic health problems living on a Social Security check of less than $800 a month. It would be futile, not to mention callous, to put her on a 25-year income-based repayment plan.

Of course, the Department of Education and its student-loan debt collectors aggressively oppose student-loan discharge efforts in the vast majority of cases, often filing technical motions that make the  discharge process more expensive than necessary. I think  the creditors file these motions to discourage student-loan debtors who file adversary actions without the help of a lawyer. 

Of course, hiring a bankruptcy lawyer to fight the Department of Education can be expensive, and people in bankruptcy generally don't have the money to hire lawyers. Nevertheless, a lot more insolvent debtors should be trying to discharge their student loans in bankruptcy, even if they must do so without a lawyer.

And here are my suggestions for giving overburdened but honest student-loan debtors some bankruptcy relief:

1) Legal Aid clinics should get in the business of representing student-loan debtors. Legal aid clinics, including those that are attached to law schools, should have their attorneys become experts in bankruptcy law--especially the evolving law that relates to student loans; and the clinics should start representing student-loan debtors who seek to discharge their student loans in the bankruptcy courts.

2) Public interest organizations should develop free web sites that would provide useful information to people who are seeking to discharge their student-loans in bankruptcy without lawyers. The site should include sample pleadings and sample discovery motions, recent research on student-loan bankruptcies, recent court decisions, and sample briefs that could be used as models for debtors who are fighting the technical motions that DOE and the debt collectors file. 

Can you imagine the impact if 5,000 people tried to discharge their student loans in the bankruptcy courts rather than the mere 300 who tried in 2007? I think these people would find the bankruptcy courts are much more sympathetic than the debtors might have expected. More and more frequently, the bankruptcy judges are reviewing the details of these pathetic cases and seeing people who borrowed money in good faith to attend college and simply never made enough money to pay it back. Divorce, illness, unemployment, poor choices in deciding on a major, unscrupulous for-profit colleges--all kinds of unexpected things happened to people who simply wanted to get the training they needed to obtain better jobs so they could support their families and have better lives.

As I have said, the bankruptcy courts are becoming more and more sympathetic to these people.  But distressed student-loan debtors have got to ask for bankruptcy relief in order to get it.


Jason Iuliano. An Empirical Assessment of Student Loan Discharge and the Undue Hardship Standard. American Bankruptcy Law Journal 86 (2012), 495. 

Roth v. Educational Credit Management Corporation. 490 B.R. 908 (9th Cir. BAP. 2013

Friday, September 4, 2015

The End of the Beginning: The Corinthian Bankruptcy Case Marks a New Phase in the Meltdown of the Federal Student Loan Program

Winston Churchill, in a speech delivered after the Battle of Egypt, Britain's first major victory in the Second World War, uttered these immortal words: "Now this is not the end. It is not even the beginning of the end. But it is, perhaps, the end of the beginning."

Something similar might be said about the recent bankruptcy filing of Corinthian Colleges, one of the largest chains of for-profit colleges, which once had enrollments totally more than 100,000 students.  Corinthian's collapse does not signal the end of federal funding for the for-profit college industry. The Department of Education will continue pouring money down the rat hole of for-profit higher education at an enormous rate--more than $30 billion per year. And the for-profits will continue to use litigation, lobbying, and strategic campaign contributions to protect their interests.

But the Corinthian bankruptcy does mark a new phase in the downward spiral of the federal student loan program. First of all, Corinthian is one of the largest for-profit college chains in the United States, with 350,000 former students. Under federal law, its closure will require the Department of Education to forgive the student loans of at least some of those students. According to the New York Times, if all 350,000 apply for loan forgiveness and those applications are granted, Corinthian's collapse will cost taxpayers about $3.5 billion.

Thus far, DOE has granted loan forgiveness to 3,000 former Corinthian students, which will cost the taxpayers about $40 million (as reported in Chronicle of Higher Education). But that's only a drop in the bucket.

Let's say half of Corinthians' ex-students are entitled to a loan discharge on the grounds that they were victims of misrepresentations or did not receive fair value for their tuition dollars, which, it seems to me, would be a reasonable estimate of the percentage who are entitled to relief.  Half of all of Corinthian Colleges' former students is about 175,000 people.  And if all those people's loans were forgiven it would cost the American taxpayers well over $2 billion.  And Corinthian is just one of many for-profits who have given students very little of value for the tuition that was paid with federal student loans.

But of course the Department of Education will never grant relief on that scale. It will bustle about the edges of the for-profit scandal, making sympathetic clucking noises while failing to confront this huge crisis. According to the Chronicle of Higher Education, DOE has received just 12,000 applications for some kind of loan relief from former Corinthian students, a small fraction of the total number of people who deserve assistance.  

Meanwhile, as DOE bureaucrats grant loan relief to a handful of  student-loan debtors who attended Corinthian campuses, DOE lawyers go into the federal bankruptcy courts again and again to oppose bankruptcy discharge for the few desperate individuals who have the temerity to seek justice through the bankruptcy process.

Nevertheless, to paraphrase Churchill, the Corinthian debacle is the end of the beginning. Whether DOE wants to admit it or not, the federal student-loan crisis is gathering steam like a locomotive and thundering down the tracks toward a disaster for America's colleges and universities.

Fortunately for President Obama and Secretary of Education Duncan, they have time to get off the tracks before the train arrives. By the time the student-loan program blows up in America's face, they will be out of office and safely ensconced in cushy academic posts at one of the elite universities that made their own contributions to the student-loan catastrophe.

Arne feels your pain--just a little bit of your pain.


Kelly Field, "U.S. Has Forgiven Loans of More Than 3,000 Ex-Corinthian Students, Chronicle of Higher Education, September 3, 2015. Accessible at: http://chronicle.com/article/US-Has-Forgiven-Loans-of/232855/?cid=pm&utm_source=pm&utm_medium=en

Tamar Lewin, "Government to Forgive Student Loans at Corinthian Colleges," New York Times, June 8, 2015. Accessible at: http://www.nytimes.com/2015/06/09/education/us-to-forgive-federal-loans-of-corinthian-college-students.html?_r=0


Wednesday, September 2, 2015

The Beginning of the End: Signs Are Everywhere that the Student Loan Program Is Collapsing

In the spring of 1940, just before the Battle of France, the people of Paris were enjoying themselves. As William Shirer wrote in The Collapse of the Third Republic:
The sands at Auteuil were full for the annual spring racing, and betting was heavy. Crowds flocked to the spring art exhibition at the Grand Palais. The cinemas and theaters played to full houses. The windows of the great jewelry shops in the rue de la Paix sparkled with diamonds and other gems, and inside business was good. (p. 604)
And then the Germans invaded the Low Countries and within a month the Nazis were in Paris.

When the party's over, it's over.
American  higher education, it seems to me, is behaving much as the Parisians did on the eve of their World War II disaster. Tuition goes up every year, even though the colleges offer steeper and steeper discounts just to lure students in the door. The average freshman now pays just 50 percent of a college's sticker price.

Meanwhile, the major public institutions of the South and Midwest pay their varsity football coaches $4 million and even $5 million a year to producing winning teams; and the assistant coaches often make a million dollars a year or more.

The campus book stores sell fewer and fewer books but make a profit selling junk.  Fewer books means more space to sell college-branded  t-shirts, sunglasses, and coffee mugs at outrageous prices. Most campuses now have a Starbuck, where students can buy elaborate coffee drinks for $5 a pop.

More and more, colleges and universities are outsourcing their student services. University employees no longer cook the meals.  Let them eat at Taco Bell, conveniently located in the Student Union. As a percentage of  total college enrollment, fewer and fewer undergraduates live in college dorms. Instead they flock to expensive, privately developed coed student-housing ghettos that provide undergraduates with swimming pools, game rooms, and plenty of space to park their late-model cars.

And why not? Student loans will pay for just about everything. And if the kids need more money than they can borrow on their own account, mom and pop will be glad to co-sign student loans at private banks. Total outstanding student-loan debt is now $1.3 trillion.

But it can't go on forever.

Almost 7 million people are currently in default on their loans, which means they haven't made a student-loan payment for more than a year. Millions more have obtained economic hardship deferments and aren't making student-loan payments.

More and more people have signed up for income-based repayment payment plans that stretch out the loan repayment period to as long as 25 years--3.9 million people, according to the Department of Education. That's a 56 percent surge in just one year.

DOE describes the uptick in long-term repayment plans as a victory because students' monthly payments go down. But many people in these plans are making payments so low they will never pay off their loans. And anyway, who wants to pay a percentage of their income for a quarter of a century just for the privilege of getting a crummy college education?

Nor is it clear that most people will stick with a long-term payment plan for 25 years. Not long ago, DOE reported that more than half of the people in those plans failed to report their annual income, a prerequisite for continuing in an income-based repayment program.

This house of cards is about to come tumbling down. Already, private liberal arts colleges are folding or on the verge of folding as students realize that it makes no sense to pay $40,000 or $50,000 a year to attend a nondescript private liberal arts college in nowheresville. Sweetbriar's debacle is just the first of many more college closings to come.

And the bloom is off the rose for the for-profits, which have been insanely profitable for the private equity groups and wealthy investors who own them. Corinthian Colleges' bankruptcy is but the harbinger of a major shakeup in the for-profit college industry.  And what happens to Corinthians's 300,000 former students, most of whom used student-loan money to pay their tuition? How many Corinthian alums will pay back their student loans?

There's only one solution to this giant economic disaster--reasonable access to bankruptcy for overburdened student-loan debtors. But DOE and its loan-collection agencies fight student-loan bankruptcies tooth-and-nail. DOE even opposed bankruptcy relief for a quadriplegic debtor who was working full time but couldn't make enough money to compensate his full-time caregiver and and still pay his fundamental living expenses (Myhre v. U.S. Department of Education, 2013).

DOE knows that if bankruptcy relief becomes an option for people who are swamped by their student loans that a flood of debtors will flow into the bankruptcy courts. If that ever happens, this enormous fraud on American young people will be exposed.

So colleges and universities waddle long, academic year after academic year, jacking up their tuition and hiring more and more bureaucrats and administrators.  College presidents hob nob with wealthy donors and watch the football games in executive sky boxes.  Tenured professors teach less and less, and low-paid adjuncts teach more and more of the college curriculum.

But the metaphorical equivalent of German panzer tanks are hiding in the shrubbery of our well-groomed college campuses. And some day soon, American higher education--the envy of the world our college leaders tirelessly assure us--will collapse.


Mitchell, Josh. School-Loan Reckoning. 7 Million Are In Default. Wall Street Journal, August 21, 2015.

Myhre v. U.S. Department of Education, 503 B.R. 698 (Bankr. W.D. Wis. 2013).

Shirer, William. The Collapse of the Third Republic. New York: Simon and Schuster, 1969.