Federal court orders the Department of Education to rule on Everest College student's request for debt cancellation: Sarah Dieffenbacher v. Betsy DeVos

Dieffenbacher v. U.S. Department of Education: A Student Borrower seeks debt relief on grounds of fraud

From 2007 to 2012, Sarah Dieffenbacher attended Everest College-Ontario Metro, a for-profit college located in Ontario, California. She took out $50,000 in federal student loans to fund her studies.

In March 2015, Dieffenbacher filed a "borrower defense" application with the U.S. Department of Education, petitioning to have her loans cancelled on the grounds that Everest had engaged in fraudulent conduct in violation of California law.

In August 2015, Dieffenbacher defaulted on her loans. Educational Credit Management Corporation, her loan servicer, sent her a notice stating that it intended to begin garnishing her wages.

Dieffenbacher filed a timely objection and a request for a hearing. This objection consisted of a 29-page letter accompanied by 254 pages of exhibits. These exhibits included Diefenbacher's sworn statement and records from the California Attorney General's Office showing documented misconduct by Everest and its parent company, Corinthian Colleges.

On January 20, 2017, Dieffenbacher's attorney received a letter from the Department of Education stating that DOE was denying Dieffenbacher's objection to having her wages garnished. DOE said its decision was conclusive and that Dieffenbacher's only recourse was to file a lawsuit in federal court.

This Dieffenbacher did. In her lawsuit, Dieffenbacher claimed that DOE's decision was arbitrary and capricious and violated the Administrative Procedure Act.

Without admitting fault, DOE filed a motion to remand Dieffenbacher's case back to the Department so that its decision could be "reconsidered and re-issued in a way that would not be arbitrary, capricious, or contrary to law."

Judge Virginia Phillips' decision

Last week, Judge Virginia Phillips, a California federal judge, denied DOE's request for a voluntary remand. In Judge Phillips' view, the Department "[had] not established a substantial or legitimate concern guiding its request for a remand."

The judge pointed out that Dieffenbacher's application for loan forgiveness had been pending for more than two years and that the Department had made contradictory arguments about what it intended to do.

Indeed, Judge Phillips' suggested that the Department of Education was attempting to get Dieffenbacher out of court so that it could garnish her wages. "The Department's request for remand appears to be an attempt to evade judicial review so that it can retain the ability to garnish [Dieffenbacher's] wages without a conclusive ruling as to the enforceability of her loans," the judge observed. "Under such circumstances, the remand request appears both frivolous and in bad faith" [emphasis supplied].

Judge Phillips concluded her opinion by ordering DOE to rule on Dieffenbacher's loan cancellation application within 90 days. If the Department fails to comply, the judge added, she would proceed to hear Dieffenbacher's claims on the merits.

The Dieffenbacher case: More Evidence of the Department of Education's Stall Tactics

The Dieffenbacher case is the latest example of the Department of Education's efforts to avoid dealing with student borrowers' legitimate applications for loan forgiveness.

In the Price case, which I wrote about recently, DOE took six years to rule on a University of Phoenix graduate's application for loan forgiveness based on her claim that Phoenix falsely certified that she had a high school diploma when she began her studies. Ultimately, DOE disallowed the claim. A federal court in Texas countermanded DOE's ruling and discharged the debt.

Last January, DOE sent a letter to 23,000 former students at Corinthian Colleges, assuring them that their loans had been approved for cancellation and that the loans would be forgiven within the next 60 to 120 days. Almost six months later, DOE has not kept its promise, which prompted a protest letter from 19 states' attorneys general.

So what's going on?

I think Betsy DeVos's DOE pencil pushers have added up the costs associated with discharging students loans under DOE's own rules and regulations and have found those costs to be enormous. DOE is trying to put the brakes on its administrative loan forgiveness process. The Department announced this week that it is rewriting the "borrow defense" regulations that Dieffenbacher relied on.

BUT IT IS TOO LATE. DeVos's efforts to slow down the loan forgiveness process will not withstand scrutiny in the federal courts, as the Price case and the Dieffenbacher case demonstrate.

The Consumer Financial Protection Bureau said in a recent report that eight million student borrowers are in default, with nearly 1.1 million defaulting in 2016 alone. As CFPB pointed out, people are defaulting at the rate of 2 borrowers every minute!

Two things must be done to bring the federal student loan program under control. First, the federal government must stop sending student aid dollars to for-profit colleges, which have shockingly high student-loan default rates.

Second, Congress must amend the Bankruptcy Code to allow distressed student borrowers to discharge their student loans in bankruptcy like any other unsecured consumer debt.

But Betsy DeVos's Department of Education refuses to face reality while it stalls for time. In the end, this approach is going to enrage millions of student borrowers. These borrowers are also voters, and they will vote for any politician who promises real debt relief to the legions of student borrowers who will never pay back their loans.

References

Dieffenbacher v. U.S. Dep't of Educ., ED CV 17-342-VAP (KK) (C.D. Cal. June 9, 2017).

Seth Frotman & Rich Williams. New data documents a disturbing cycle of defaults for struggling student loan borrowers. Consumer Financial Protection Bureau, May 15, 2017.

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

Andrew Kreighbaum. Court Orders Education Department to End Delay in Ruling on Loan Discharge. Inside Higher ED, June 9, 2017.

Andrew Kreighbaum. Education Department to hit pause on two primary Obama regulations aimed at for-profits. Inside Higher ED, June 15, 2017.

Andrew Kreighbaum. State AGs Want Action on Student Loan Discharge. Inside Higher Ed, June 6, 2017.

Lisa Madigan, Illinois Attorney General. Letter to Betsy DeVos, US. Secretary of Education, June 5, 2017.

Price v. U.S. Dep't of Educ., 209 Fed. Supp. 3d 925 (S.D. Tex. 2016). [Link is to U.S. Magistrate's opinion, which was affirmed by a U.S. District Judge.] 

The for-profit college industry is shrinking: It's time to shut this sleazy sector down

We've known for a long time that the for-profit college industry is a cancer infecting the higher education community. Senator Tom Harkin's committee report, published in 2012, told us that.

The cost of attending a for-profit college is far higher than the cost of enrolling at a public college. Completion rates are low, job prospects for attendees are often bleak. Some for-profits spend more on recruiting than they do on instruction.

 And student-loan default rates at the for-profits are quite high. Forty-seven percent of the 2009 cohort of for-profit college borrowers defaulted on their loans within five years.

Here are the 5-year cohort default rates for selected for-profit colleges, as reported by a 2015 Brookings Institute paper:

• University of Phoenix-Phoenix campus: 45 percent
• DeVry University-Illinois: 43 percent
• Ashford University: 47 percent
• Kaplan University-Davenport campus: 53 percent

And of course these figures understate the number of for-profit college students who are not repaying their loans because many non-defaulters have their loans in deferment or forbearance and are not making their monthly loan payments.

But the good news is this: the for-profit college industry is shrinking. When the Harkin report came out five years ago, for-profit colleges enrolled 13 percent of all college and university students. In the spring semester of 2017, that figure had dropped to 5 percent. For the industry as a whole, for-profit enrollments dropped 10 percent between spring 2016 and spring 2017.

Part of this drop can be attributed to aggressive enforcement of consumer protection laws by state attorneys general and better regulation by the U.S. Department of Education. In the last two years alone, Corinthian Colleges and ITT Tech closed and went bankrupt. Together these institutions had a half million former students.

Moreover,  potential students are becoming more wary of aggressive for-profit college recruiters. This may explain why enrollments are plummeting at several well-established for-profit colleges, such as University of Phoenix and DeVry.

Now, while the for-profit college sector is shrinking, is the time to shut this sleazy industry down. I think the for-profits are hoping the Trump administration will be friendly to their interests, allowing them to get back on their feet.

But let's  hope the industry is wrong. If President Trump implements policies that reinvigorate the for-profit college industry, it will be the biggest mistake of his administration--far bigger than his goofy dinner conversation with FBI Director James Comey.

The for-profits are shrinking, shrinking!

References

Associated Press. Enrollment is tanking at University of Phoenix, DeVry, and other for-profit colleges, Los Angeles Times, September 22, 2016.

Paul Fain. Enrollments Continue to Slide at For-Profits and Community Colleges. Inside Higher Ed, May 24, 2017.

Tamar Lewin. Senate Committee Report on For-Profit Colleges Condemns Costs and Practices. New York Times, July 29, 2012.

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).

U.S. Senate Committee on Health, Education, Labor and Pensions. For Profit Higher Education: The Failure to Safeguard the Federal Investment and Ensure Student Success. 112 Congress, 2d Session, July 30, 2012.

"Meet The Three Headed Debt Monster That's Going to Ravage the Economy," writes MN Gordon

A three-headed consumer debt monster is about to ravage our economy, writes MN Gordon in an Acting-Man essay that was republished on zerohedge.com. And what are the three heads?  Auto loans, credit card debt, and student loans.

As Gordon points out, all this massive debt is backed by essentially no collateral. Regarding credit-card debt, Gordon says this:

[C]redit card debt has been run-up purchasing 72-inch flat screen televisions, avocado toast, and combination platters at Applebee's. How does a creditor recover the cost of a meal that was consumed 2 years ago?

Of course, auto loans are secured by the cars that are purchased on credit. But, as Gordon put it, new cars lose value "nearly as fast as fresh tomatoes turn to rot." Thus, a repossessed car is rarely worth as much as the debt it was  meant to secure.

And of course student loans form the third and most vicious head of the three-headed consumer debt monster. As has been often reported, student loans have now outstripped credit card debt and auto loans as the biggest sector of consumer debt (excluding home mortgages).

The federal government issues more than $100 billion in student loans every year, and student loans are backed by absolutely no collateral.  How do you repossess a law degree from Thomas Jefferson Law School or a liberal arts degree from Vassar?

The entire postsecondary education industry--from Harvard University to Bob's Barber College--subsists on federal student-aid money. The for-profit colleges get almost 90 percent of their revenues from the federal government. Most for-profit colleges could not last a month without regular infusions of federal cash.

And although no one wants to admit it, at least half of the outstanding student-loan debt--totally $1.4 trillion--will never be paid back. The Department of Education is hiding the true default rate by putting borrowers into economic hardship deferments, forbearance programs, or long-term income-driven repayment plans. But the reality is this: most of the people in these shell-game programs will never repay their loans.

One might think that all this federal cash is adequate to sustain America's colleges and universities, but they are continually searching for more money. Nationwide, tuition rates have gone up nearly every year for the past 25 years. Tuition costs for graduate programs have reached insane levels because the federal government put no limit on the amount a student can borrow to get an MBA or law degree.

And where has all this student loan money gone? As Gordon observed, "it has been dispersed into oversized professor salaries, oversized lecture auditoriums, and oversized sports complexes."

Most of us would feel better about the runaway cost of higher education if our universities and colleges were providing real value for students' tuition dollars--if a college degree or graduate degree led to a good job and a better life.

But average wages in real terms have gone down over the past 30 years. Although the higher education industry repeatedly points out that the wage differential between high school graduates and college graduates is increasing, most of this growing gap is explained by declining wages for non-college graduates.

Of course, higher education's defenders like to point out the intrinsic value of a university degree--a better appreciation for culture, an enhanced ability for civic involvement, greater tolerance for people with opposing points of view.  The late John Kenneth Gailbraith, some old white guy from Harvard, expressed the intrinsic value of education as follows:

Education is, most of all, for the enlargement and the enjoyment of life. It is education that opens the window for the individual on the pleasures of language, literature, art, music, the diversities and idiosyncrasies of the world scene. The well-educated over the years and centuries have never doubted their superior reward; it  greater educational opportunity that makes general and widespread this reward.

But this is bullshit. It was bullshit when Galbraith wrote it, and it is overripe bullshit today. Our colleges and universities--our elite universities in particular--have become cesspools of racial and sexual-identity politics, Brownshirt-style intolerance for diverse political ideas, and Orwellian breeding grounds for groupthink.

In short, over a period of less than 50 years, our nation has constructed a higher education system that forces millions of Americans to take out student loans they cannot pay back in return for overpriced educational experiences that do not lead to better jobs or to better lives.

References

MN Gordon. Meet the Three-headed Debt Monster That's Going to Ravage Our Economy. Acting-Man.com. Republished at  zerohedge.com, June 10, 2017.

If Trump Will Let CFPB Survive Their Work Will Protect Small Business Loans and Student Loans--essay by Steve Rhode

I can’t imagine a measure of the the amount of effort that has been invested into making sure the Consumer Financial Protection Bureau is wiped off the face of the earth.

Big business and companies wanting consumers to have less power in the financial world are not excited about the CFPB that has been fighting hard to protect consumers from scams and schemes to rip them off.

In the coming years, if the CFPB survives, they are planning on targeting mortgage loan servicing, student loan servicing, and small business lending to make sure consumers are not getting to get screwed by these entities.

Some people want government out of our lives at nearly all costs. But for all those who politically want the CFPB to go away there is one simple issue that should change your mind. Let’s be honest. big business has more money to fight back against consumers and people just do have the resources to make much of a difference when they get screwed over by their financial company.

Sure, there have been some hit and miss victories by the lone consumer but for the most part, the deep pockets win.

Take private student loans for example. Consumers could discharge a lot of private student loan debt in bankruptcy or invalidate it. But people don’t have the resources to wage these battles and fight back against the lenders. So guess what, lives are ruined.

The CFPB represents at least one entity that works hard to fight for consumers. It creates leverage against deceptive and abusive financial practices that take advantage of consumers. But in this atmosphere of America First – Consumers Last, the Trump Administration wants the CFPB to go away. According to USA Today, “the Department of Justice argued in an amicus brief that the structure of the Consumer Financial Protection Bureau (CFPB), the watchdog created after the financial crisis during the Obama administration, is unconstitutional.” Even the federal government wants consumer protections to vanish.

Wanting to make the CFPB go away from defending consumers does not make the underlying problems go away or increase the defense of people just like you when you get scammed and ripped off.

The CFPB has been fighting back to protect consumers by filing suit against Navient for not providing advice to help consumers. Navients response is they don’t have to provide good advice, just collect on loans. And Navient even knew they were peddling loans that were not affordable when they pushed them on students.

So let’s let the CFPB fight back to protect people with student loan issues and small business loans. The only thing you have to lose is a better financial future and more protections for those you love.
Steve Rhode

Get Out of Debt Guy – Twitter, G+, Facebook

If you have a credit or debt question you’d like to ask, just click here and ask away.
This article by Steve Rhode first appeared on Get Out of Debt Guy and was distributed by the Personal Finance Syndication Network.

******

I am in total agreement with Mr. Rhode regarding the value of the Consumer Financial Protection Bureau. The the Trump administration should  support the CFPB its mission, including the protection of student borrowers from unscrupulous for-profit college and ruthless student-loan debt collectors.

Richard Fossey

Snapshot of the student loan crisis from a recent New York Federal Reserve Bank report: Surprise, surprise! Debt levels Are rising

Researchers at the New York Federal Reserve Bank issued a press release on April 3 that reported on household borrowing and student debt.  Here are some excerpts from that press release. I have highlighted particularly interesting passages:

Student Loan Update 

Aggregate student loan balances have continued to increase and stood at about $1.3 trillion at the end of 2016, an increase of about 170 percent from 2006. Aggregate student debt is increasing because more students are taking out loans, the loans are for larger amounts, and the speed with which borrowers repay their debts has slowed down. New debt originations continue to increase: 2015 graduates with student loans left school with about $34,000, up from only $20,000 just ten years before. 

While about 36 percent of student debt holders owed less than $10,000, and 65 percent owed less than $25,000, only about 5 percent of student debt holders owed more than $100,000 in debt in 2016. Yet these big-balance borrowers account for nearly 30 percent of the total balances outstanding, so their outcomes and repayment success have a disproportionate influence on the overall picture.

Student loan default and delinquency rates appear to have leveled off, albeit at a relatively high level. Defaults peaked in 2012, and have stabilized since 2013; the 2009-11 cohorts saw the highest default rates, with some improvement among more recent cohorts.

We have noted in the past that delinquency and default rates are lower among higher-balance borrowers; however, the default rates among higher-balance borrowers have worsened notably in recent years. Further, payment progress is slower among those who borrowed more. Ten years later, over 70 percent of the original balance has been repaid among those who had borrowed less than $5,000 when they left college in 2006, compared to a reduction of only 25 percent among students who borrowed more than $100,000.

Higher balances, increasing participation in student loan programs, and slower repayment are pushing up aggregate student loan balances. Although defaults are improving, the pay down progress of recent cohorts continues to decline.

The Fed researchers also commented on the relationship between student-loan indebtedness and homeownership:

Homeownership 

The final portion of the press briefing was on educational attainment, student loans, and homeownership, using education records from the National Student Clearinghouse that were newly matched with credit records from the Consumer Credit Panel. These findings are presented in greater detail in a separate post. New analysis shows that college education is associated with markedly higher homeownership rates regardless of debt status, which increases at each additional level of college attainment. However, having student loans dampens homeownership rates at every level of education, and higher debt balances are associated with even lower homeownership rates.

Takeaways from the Fed researchers' findings

In essence, the Federal Reserve Bank researchers are telling us this:

Loan balances are going up, more people are taking out student loans, and repayment rates are slowing, particularly for borrowers with high loan balances. I imagine a lot of these slow paying borrowers are in the Public Service Loan Forgiveness (PSLF) program or an income-driven (IDR) plan.  

The vast majority of people making payments under  PSLF and IDR are not making payments large enough to pay down their loan balances. And, as the Fed researchers noted, among people who borrowed $100,000 or more, only 25 percent were able to pay off their student loans within 10 years.

Regarding student loans and home buying, the Fed researchers had this to say: Homeownership increases with people's education level, but student loans hamper the ability of people to buy a house, regardless of income level.

References

Rajashri Chakrabarti, Andrew Haughwout, Donghoon Lee, Joelle Scally, & Wilbert van der Klaauw. At the N.Y. Fed: Press Briefing on Household Borrowing with Close-Up on Student Debt. April 3, 2017. 

I’m Screwing Myself Out of Retirement With My Wells Fargo Private Student Loans: Letter to Steve Rhode, The Get Out of Debt Guy

Steve Rhode

Steve Rhode, the Get Out of Debt Guy, received a letter from an individual who is swamped by private student loans taken out with Wells Fargo. The letter and Steve Rhode's response are well worth reading. This post originally appeared on Mr. Rhode's web site, The Get Out of Debt Guy. It was also posted on the Personal Finance Syndication Network.

*****

Question:

Dear Steve,

I took out both federal and private student loans to pay for college, and was approved by Wells Fargo for more than I can pay back in reasonable increments each month with my current salary (roughly $565/month).

The federal loan payments I have each month are quite manageable, but the private loan payments through Wells Fargo are at a much higher interest rate, and also make up the bulk of my loan balance, currently at over $47k with interest rates hovering around 8%.

I attempted to consolidate the Wells Fargo loans to lower my monthly payment and hopefully reduce the interest rate as well, but do not have access to a co-signer and my debt-to-income ratio is too high (mainly because of my student loans), so I haven’t had the option to consolidate.

I make a decent salary at approximately $41k per year and hope to see an increase in the next year or so, but with living expenses at a bare minimum I am still living paycheck-to-paycheck in order to do the responsible thing and follow through on my loan payments.
Although I try to be as financially responsible as I can, I am now in my early thirties and am unable to put any money towards savings for retirement or emergencies. I have heard of graduates abandoning their private loan payments, and I am starting to feel that may be my only option if I want to save for my future.

In fact, I read your article on the Huffington Post about this very topic, but am so scared of the repercussions that I just continue to make my payments and regret my willingness to sign my life away to loans. I’m curious to find out if you think the risk would be worth the reward? What would you recommend to a person in my situation? Thanks so much in advance for the help!

Paige

Answer:

Dear Paige,

I can completely empathize with your situation and plight. As you’ve painfully learned, just because a lender will give you a loan it does not mean you can afford it.

Your worry about the future and the inability to save for retirement is a logical concern. Each day you can’t stash away money now is a bit hit on your retirement later.

As an example. If you invested $300 a month starting now and didn’t retire for 40 years you’d have about $1,897,223 in retirement. That doesn’t even include the additional benefit of employer matching or tax benefits.

So the real question now is how much pain you are willing to deal with in the short run to deal with the private student loans versus how much you will throw away by not doing something.
I think you might have read my article Top 10 Reasons You Should Stop Paying Your Unaffordable Private Student Loan. In that article the discussion is about the pain you will have to face when you default on your student loans and the options it gives you.

Look, I’m not suggesting the defaulting is either easy or doesn’t have consequences. It’s a frightening strategy that is not for the ill advised or faint of heart. If you did decide to investigate this path I would strongly urge you to talk to a competent debt coach like Damon Day to evaluate your entire situation and provide a plan based on your specific situation and goals. You need someone you can bounce these ideas off of and have regular conversations.
However, the idea of a strategic default of your private student loans is not entirely without merit. It does carry risks and will damage your credit from the defaulted payments.

The best strategy would be if Wells Fargo worked with you to create a repayment plan that allowed you to meet your obligations and begin to build an emergency savings account and save for retirement.

Alternatively, if you won the lottery and could pay off your student loans at once, that would be a lucky option as well.

Given that both a reasonable Wells Fargo payment and lottery win are not likely then you have to think carefully about the advice I’ve given you here.

Sometimes in the face of no good solution you just have to choose from the least objectionable and stick to it.

Steve Rhode

Department of Education is slow to forgive loans of student borrowers defrauded by Corinthian Colleges: State Attorneys General urge DOE to move more quickly

Yesterday, nineteen state attorneys general and the Director of the Hawaii Office of Consumer Protection delivered a letter to Betsy DeVos, U.S. Education Secretary, urging the Department of Education to quickly process fraud claims brought by former students of Corinthian Colleges.

The state AGs asked DeVos to approve "swift automatic group discharge" to students in Corinthian cohorts where fraud has been found. Alternatively, the AGs asked DeVos to process individual fraud claims faster.

Corinthian Colleges closed and filed for bankruptcy in 2015, leaving behind more than 350,000 former students who took out loans to pay Corinthian's tuition. Many of these student borrowers were induced to attend Corinthian through fraud, and the nineteen AGs claim there are defrauded Corinthian students in all 50 states.

So far, DOE has discharged 27,000 borrowers from their federal loan debt, but that number is a small fraction of the former students who are entitled to debt relief. Thousands have filed "borrower defense" claims, asking DOE for loan forgiveness, but DOE is not processing these claims quickly. Meanwhile, many Corinthians students are still paying on their loans or defaulted and are subject to having their wages garnished and their credit ruined.

According to the state AGs, DOE notified 23,000 Corinthian student borrowers in January that their loan forgiveness applications had been approved and that "forgiveness should be completed within the next 60-120 days." It's been nearly 180 days since that announcement, and these loans have still not been discharged.

What's going on?

I think the Department of Education is simply overwhelmed by the meltdown of the student loan program. Almost half the people in a recent cohort of students who attended for-profit colleges defaulted within five years. According to a recent article in the Wall Street Journal, half the students who attended more than 1,000 colleges and schools have not paid down one dime of their student loans seven years after their repayment obligations began.

In addition, the first beneficiaries of the Public Service Loan Forgiveness Program will be eligible for debt relief before the end of this year, and DOE has no idea how many people are eligible to have their loans discharged under that program.

Personally, I think Secretary DeVos should adopt the AGs' suggestion and grant swift automatic group discharges to all Corinthian students who were in DOE's "Designated Fraud Cohorts." Or better yet, I think DOE should forgive the loans of all 350,000 former students.

Admittedly, there are probably some people who completed a Corinthian program and actually got a good job, but I'll bet there aren't many. Undoubtedly, the default rate for Corinthian students is extraordinarily high largely due to the fact that Corinthian's students did not get well-paying jobs at the conclusion of their studies.

I recognize there are risks associated with a mass loan forgiveness program. If all 300,000 of Corinthian's former students are granted a discharge, then ITT Tech's former students will ask for blanket loan forgiveness. ITT Tech also closed and filed for bankruptcy, and it has 200,000 former students.

It is shocking to contemplate, but millions of Americans will never pay back their student loans. In addition to the for-profit college students, there are the law graduates who accumulated mountains of debt and can't find law jobs. And then there are the poor saps who got liberal arts degrees from expensive liberal arts colleges; many of them will never pay back their loans.

The 19 state AGs are right to urge Secretary DeVos to grant automatic group discharges for thousands of former Corinthian students. But Corinthian Colleges is the tip of the iceberg. Millions of student borrowers will never pay back their loans, and the ultimate loss to taxpayers will be in the billions.

References

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

Tamar Lewin. Government to Forgive Student Loans at Corinthian. New York Times, June 9, 2015, p. A11.

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).

Andrew Kreighbaum. State AGs Want Action on Student Loan Discharge. Inside Higher Ed, June 6, 2017.

Lisa Madigan, Illinois Attorney General. Letter to Betsy DeVos, US. Secretary of Education, June 5, 2017.