Student Loan Debtors and the Presidential Race: Hillary still has an opportunity to win over young voteers

Hillary Clinton devastated Bernie Sanders in the South Carolina Democratic Primary election. As Bernie candidly admitted, the Sanders team was "decimated." The only good news, he said, was this: Bernie beat Hillary among voters age 29 and younger.

Hillary talks herself hoarse telling voters how much she has done for them and much more she will do if she is elected President. But young people don't buy it. Essentially, they see her as an elderly political hack who sucks up to the banks.

But Hillary can still make headway with young voters if she would only promise some tangible and substantive reforms to the student-loan program. After all, there are 43 million Americans with outstanding student-loan debt; and most of them are young.

What could she promise? How about this:

1) "If elected president, I will instruct the IRS to draft regulations specifying that forgiven student-loan debt is not taxable."  

Under current law, about 4 million people are in income-based repayment plans, and most of them are seeing their total debt grow larger with each passing month due to accruing interest. When they complete their long-term repayment plans (after 20 or 25 years), their loan balances will be forgiven, but the forgiven amount will considered taxable income by the IRS. This is a real problem for people in income-based repayment plans. Why not just fix that problem with an IRS regulation?

2) "If elected president, my Department of Education will enact regulations that will cut off federal funding to any for-profit college that forces students to sign a promise not to sue the college for fraud or misrepresentation. And I will instruct the Department of Justice to cooperate with State Attorney Generals who are investigating and suing for-profit colleges that exploit students."

This promise demonstrates nothing more than common decency and would be well received by young people.

3) "When I am your president, the government will stop garnishing Social Security checks of elderly student-loan defaulters. And my administration will not oppose bankruptcy relief for elderly student-loan defaulters who are living below the poverty level."

There is nothing radical about this proposition. In fact, last month, in Precht v. U.S. Department of Education, DOE agreed to bankruptcy discharge of an elderly person's student-loan debt and stopped garnishing his Social Security check.

4) "My administration will renegotiate all contracts with student-loan debt collectors like Educational Credit Management Corporation. All these entities will be required to disclose the salaries of their executives and employees. They will also be required to disclose their profits. And I will eliminate the penalties and fees that the collection agencies have been charging distressed student-loan borrowers."

The beauty of these promises is this. All the reforms I listed could be implemented by President Hillary Clinton on the day she takes office. None of them require congressional approval.  And even if they did require statutory changes, what federal legislator would say no to these modest reforms if President Hillary asked for them?

If Hillary made these promises, she would demonstrate that she understands the magnitude of the student-loan crisis and that she  plans to take energetic action to grant some relief.  But my prediction is this: Hillary won't promise any substantive reforms of the student loan program because Goldman Sachs and the banks would disapprove. And that--in a nutshell--is why young people are not voting for Hillary.

References

Natalie Kitroeff. Loan Monitor is Accused of Ruthless Tactics on Student Debt. New York Times, January 1. 2014. Accessible at http://www.nytimes.com/2014/01/02/us/loan-monitor-is-accused-of-ruthless-tactics-on-student-debt.html?_r=0

Stephen Burd. Signing Away Rights. Inside Higher Ed, December 17, 2013. Available at https://www.insidehighered.com/views/2013/12/17/essay-questions-mandatory-arbitration-clauses-students-profit-higher-education

Ashley A. Smith. U.S. Urged to Deny Aid to For-Profits That Force Arbitration. Inside Higher Ed, February 24, 2016. Available at: https://www.insidehighered.com/quicktakes/2016/02/24/us-urged-deny-aid-profits-force-arbitration?utm_source=Inside+Higher+Ed&utm_campaign=183bc9e3a3-DNU20160224&utm_medium=email&utm_term=0_1fcbc04421-183bc9e3a3-198565653

Loan forgiveness for college students defrauded by for-profit colleges: Why not simply allow defrauded students to take bankruptcy?

The Department of Education is revising the regulations for handling student-debtor requests for debt relief. Under present regulations, student-loan borrowers  are eligible for debt relief if they can show they were victims of misrepresentation by the institution they attended.

But the old regulations are cumbersome, and DOE has been swamped by debt relief requests after Corinthian Colleges closed last year. Corinthian had 350,000 students or former students.

Apparently, the Department of Education is proposing some sort of hearing process where students who claims to be fraud victim can confront the colleges that lured them into enrolling and taking out student loans.

But how will that work? All the for-profit colleges have teams of lawyers, and the defrauded students who confront them at hearings will likely  have no lawyer at all.  That's a crumby idea.

Second, DOE is contemplating some kind of statute of limitation that would bar a student's fraud claim if not filed by some yet-to-be-defined time limit. Another crumby idea. Student-loan creditors can pursue student-loan defaulters any time they want--30 years after a loan was incurred if they choose. That's because there is no statute of limitation on debt collection of a student loan. So why should students be restricted by a time limit to file misrepresentation claims?

Third, the proposed regulations are cumbersome legalese that many students won't understand. Here is a sample of proposal's text:

For loans first disbursed prior to July 1, 2007, the borrower may assert as a defense to repayment, any act or omission of the school attended by the student that relates to the making of the loan or the provision of educational services that would give rise to a cause of action against the school under applicable State law.

Got that?

If the Department of Education were willing to face facts, it would admit that millions of students who enrolled at for-profit colleges have valid misrepresentation claims.  The for-profit industry as a whole has a 5-year default rate of 47 percent--strong evidence that many of the programs the colleges offered did not lead to well-paying jobs.

Rather than construct an elaborate, expensive, and unworkable administrative process for sorting out student fraud claims, the Department of Education should simply allow all students who attended a for-profit college and who are now broke to discharge their student-loan debts in bankruptcy without having to meet the "undue hardship" standard that currently applies to student-loan debtors in the bankruptcy courts. In other words, an insolvent student-loan debtor who attended a for-profit college should be able to discharge student-loan debt in bankruptcy like any other nonsecured debt.

After all, the bankruptcy courts have the expertise and the resources to sort out valid bankruptcy claims from invalid ones.  But DOE won't expedite the loan forgiveness process because it knows that millions of people took out student loans for worthless college experiences. If every student who was huckstered by a for-profit college obtained student-loan debt relief, the cost of loan forgiveness would amount to hundreds of billions of dollars.

References

Michael Stratford. Obama Crackdown on College Fraud. Inside Higher Ed, February 9, 2016. https://www.insidehighered.com/news/2016/02/09/education-department-creates-new-office-crack-down-fraud-colleges?utm_source=Inside+Higher+Ed&utm_campaign=8bca58981a-DNU20160209&utm_medium=email&utm_term=0_1fcbc04421-8bca58981a-198565653

Michael Stratford. New Criteria For Debt Relief. Inside Higher Ed, February 17, 2016. Available at: https://www.insidehighered.com/news/2016/02/17/us-plan-would-cancel-federal-loans-borrowers-misled-their-colleges?utm_source=Inside+Higher+Ed&utm_campaign=60a80c3a41-DNU20160217&utm_medium=email&utm_term=0_1fcbc04421-60a80c3a41-198565653

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

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

Arbitration and For-Profit Colleges: Public Citizen, a consumer group, asks the Department of Education to bar for-profits from forcing students to arbitrate their fraud claims. What a good idea!

Public Citizen, a consumer rights group, formally petitioned the U.S. Department of Education to cut off federal student-aid money to for-profit colleges that force their students to sign arbitration agreements that bar students from suing the colleges for fraud or misrepresentation or from filing class-action lawsuits. Julie Murray, spokesperson for the group, explained Public Citizen's position. "Taxpayers should not have to subsidize predatory schools that deny their students a day in court," Murray said in a press release.

What a good idea! Everyone knows that thousands of low-income and minority students have been lured into enrolling at expensive for-profit colleges by misrepresentations and high-pressure recruiting tactics.  The for-profits have very high student-loan default rates, high dropout rates, and high percentages of students who are seeing their loan debt growing larger because they are forced into economic-hardship deferment programs due to the fact that their post-studies income is not high enough to pay off their student loans.

In fact, as Stephen Burd pointed out in an Inside Higher Ed essay, a for-profit institution's shareholders can sue a for-profit college for misrepresenting job-placement figures while the students themselves cannot.

Arbitration clauses always favor the for-profit industry because the for-profits pick the arbitration company, which gives the arbitrators an incentive to rule in favor of the colleges or at least to go easy on them in order to get "repeat business."  Discovery is often limited in arbitration proceedings, and arbitration can be expensive, since the student must bear part of the arbitrator's cost.

I agree with Mr. Burd, who wrote:

Congress should eliminate this injustice by barring colleges that participate in the federal student aid program from including binding arbitration clauses in enrollment agreements, just as Senators Tom Harkin of Iowa and Al Franken of Minnesota proposed . . . . As [the senators] wrote, "Colleges and universities should not be able to insulate themselves from liability by forcing students to preemptively give up their right to be protected by our nation's laws.

Student-loan debtors--and there are 42 million of you--should ask presidential candidates if they are willing to cut off federal student-aid funding to for-profit colleges that force their students to sign arbitration agreements.   What would Hillary's answer be? Donald Trump's? Bernie Sanders?

References

Stephen Burd. Signing Away Rights. Inside Higher Ed, December 17, 2013. Available at https://www.insidehighered.com/views/2013/12/17/essay-questions-mandatory-arbitration-clauses-students-profit-higher-education

Ashley A. Smith. U.S. Urged to Deny Aid to For-Profits That Force Arbitration. Inside Higher Ed, February 24, 2016. Available at: https://www.insidehighered.com/quicktakes/2016/02/24/us-urged-deny-aid-profits-force-arbitration?utm_source=Inside+Higher+Ed&utm_campaign=183bc9e3a3-DNU20160224&utm_medium=email&utm_term=0_1fcbc04421-183bc9e3a3-198565653

Alan Collinge is too pessimistic about bankruptcy relief for student-loan debtors: The Times May Be A-Changin'

Come writers and critics

Who prophesize with your pen

And keep your eyes wide

The chance won't come again

And don't speak too soon

For the wheel's still in spin

And there's no tellin' who

That it's namin'

For the loser now

Will be later to win

For the times they are a-changin'.

Bob Dylan

Alan Collinge wrote an interesting book a few years ago entitled The Student Loan Scam, which I reviewed in the Journal of Law and Education. He is very knowledgeable about the student-loan crisis, and much that he has to say about this problem is useful. Nevertheless, he is far too pessimistic about bankruptcy relief for student-loan debtors.

In an interview with Peter J. Reilly, a Forbes Magazine contributor, Collinge expressed a very bleak view regarding a distressed student-loan debtor's chances in the bankruptcy court. As Reilly summarized Collinge's position, "Alan argued that the chance of bankruptcy relief remains remote, and that the murmurers may be consultants who are engaging in bait and switch." In the interview itself, Collinge said, "Almost no well-versed lawyer will recommend it because of the unlikelihood of winning."

It is true that the Department of Education and its various loan collection agencies have vigorously fought bankruptcy relief for student-loan debtors in almost every case. As Colling observed:

[M]ake no mistake, even for the most destitute borrowers, the Department of Education, ECMC, and the entire lending industry are continuing to pour massive resources into defeating them in bankruptcy court by using shameless fear tactics with the judges, who they pressure ceaselessly--and usually successfully--to make bankruptcy determinations against [ ] these most impoverished individuals rather than for them.

And I think Collinge is also correct to say that so-called "debt coaches" and consultants may be dispensing inaccurate information about bankruptcy relief for the purpose of signing up distressed student-loan debtors in "loan rehabilitation" plans whereby student loans are repackaged into larger loans due to the various fees and penalties that get tacked on to the original principal.

But Collinge is just wrong to disparage the bankruptcy option for discharging student loans. Several bankruptcy courts have ruled with surprising compassion and common sense toward student-loan borrowers in recent years--relieving honest but unfortunate debtors of their student-loan obligations. Remarkably, many student-loan debtors have been successful in the bankruptcy courts even when they went to court without lawyers. Abney v. U.S. Department of Education, Acosta-Conniff v. ECMC, Johnson v. Sallie Mae, and Precht v. U.S. Department of Education--all decided within the last year--are recent victories for student-loan debtors who represented themselves in bankruptcy court.

It is true that some student-loan debtors have lost their cases in the bankruptcy courts. Butler v. ECMC, decided last month, is a particularly heartbreaking case because Brenda Butler's situation was more dire than several student-loan debtors who won their cases. But Roth v. ECMC and Krieger v. ECMC, two appellate-level decisions, are an indication that the federal courts are rethinking their harsh stance toward student-loan debtors.

One thing is certain. Overburdened and insolvent student-loan debtors have nothing to lose by trying to get their student-loan debt discharged in bankruptcy. And it is not helpful or useful to tell people that bankruptcy relief for student-loan debt is nearly impossible.

As Bob Dylan put it,"[D]on't speak too soon for the wheel's still in spin." In other words, the times may be a-changing.

References

Acosta-Conniff v. Educational Credit Corporation, 536 B.R. 326 (M.D. Ala. 2015).

Abney v. U.S. Department of Education, 540 B.R. 681 (W.D. Mo. 2015).

Fossey, R. (2009). Review of The Student Loan Scam: The Most Oppressive Debt in U.S. History—And How We Can Fight Back, by Alan Michael Collinge. Journal of Law and Education, 38, 715-718 (2009). Available at http://www.studentloanjustice.org/fosseybookreview.pdf

Johnson v. Sallie Mae, ., No. 11-23108, Adv. No. 11-6250,  2015 WL 795830 (Bankr. D Kan. Feb. 19, 2015).

Krieger v. Educational Credit Management Corporation, 713 F.3d 882 (7th Cir. 2013).

Precht v. United States Department of Education, AD PRO 15-01167-RGM (Bankr. E.D. Va. Feb. 11, 2016 (Consent Order).

Peter J. Reilly. Interview With Student Loan Activist Alan Collinge On Bankruptcy Protection, Forbes, October 28, 2015. Available at http://www.forbes.com/sites/peterjreilly/2015/10/28/interview-with-student-loan-activist-alan-collinge-on-bankruptcy-protection/#64fa9b7a6438

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

Daniel Arbess, Writing In The Wall Street Journal, Says Bernie Sanders Supporters Are Clueless: But It Is the Wall Street Journal That Is Clueless

Daniel J. Arbess, writing in the Wall Street Journal, maintains that American young people who support Bernie Sanders are economically clueless. They blame Wall Street for the nation's financial malaise, Arbess argues, which is misguided. "Don't they realize," he asks plaintively, "that the financial markets are the lubricant of the entire economy--that Wall Street's capacity to provide liquidity and to broker capital is the lifeblood of American companies?"

Actually, Mr. Arbess, America's young people do understand that Wall Street is a lubricant. They've figured out that the global financial industry is a lubricant for raping the middle class.

Arbess seems to believe that young Americans should put their faith in unrestrained capitalism, which will eventually bring us all economic prosperity. But Arbess's own words belie his argument. As he himself says, the underemployment rate for young adults--that is, the percentage of people who are underpaid or working in jobs for which they are overqualified--is 60 percent! And 20 million Americans are burdened by student loans they can't pay back
The political elites, the financial industry, and the mainstream media seem to think Sanders' economic platform is nothing but a pipe dream; but two planks of that platform--universal health care and a free college education--resonate deeply with the young.

Young people know they must obtain useful postsecondary training to get middle-class jobs; and they also know they are being forced to pay far too much to attend a college or a graduate school. And they are coming to grips with the fact that borrowing money to pay for college can sometimes be an economic death sentence since it so difficult to discharge student-loan debt in bankruptcy.  Free college tuition to attend a state institution makes perfect sense to them, and Bernie's plan would actually be cheaper than the Byzantine student-loan program the government is now running.

And young people know that health care costs are eroding their take-home pay. Everyone I know who was forced into Obamacare is unhappy about it. Virtually all of them saw their health insurance costs went up and the quality of their coverage deteriorated. They understand that the United States could offer universal health care on a European model that would be more efficient and far cheaper than the cobbled-together scheme we now have in place that benefits no one but the medical industry and the insurance companies.

The fact that the Wall Street Journal thinks it is appropriate for a hedge fund manager to lecture Americans about the presidential campaign shows us just how clueless that newspaper is.
As for Mr. Arbess himself, I found a recent news story about his financial acumen. According to a 2014 online story in Bloomberg Business, "Perella Weinberg Partners LP is shutting its Xerion hedge fund, after its manager, Daniel Arbess, failed to recoup a 21 percent loss dating from 2011."

So maybe American young people are smarter than Mr. Arbess when it comes to making political decisions that affect their own economic well being.

Mr. Arbess thinks young Bernie supporters are clueless.

References


Daniel J. Arbess. The Young and the Economically Clueless. Wall Street Journal, February 19, 2016. Available at http://www.wsj.com/articles/the-young-and-the-economically-clueless-1455924699


Kelly Bit and Katherine Burton. Peralla Weinberg's Xerion Fund To Close, Return Money. Bloomberg Business News, November 24, 2014. Available at http://www.bloomberg.com/news/articles/2014-11-14/perella-weinberg-s-xerion-fund-to-close-return-money-to-clientshttp://www.bloomberg.com/news/articles/2014-11-14/perella-weinberg-s-xerion-fund-to-close-return-money-to-clients

Let Justice Roll On Like A River: Richard Precht, A Virginia Man Living on $1200 a Month, Won Bankruptcy Discharge of Nearly $100,000 in Student-Loan Debt

But let justice roll on like a river, righteousness like a never-failing stream!

Amos 5:24

On July 7 2015, the Department of Education issued a letter outlining guidelines for determining when the Department and its student-loan collection agencies would not oppose bankruptcy relief for distressed student-loan debtors. DOE listed 11 factors that it would consider, including these:

1) "Whether a debtor is approaching retirement, taking into account the debtor's age at the time student loans were incurred and resources likely to be available to the debtor in retirement to repay a student loan . . ."

2) "Whether a debtor's health has materially changed since the student loan debt was incurred . . . ."

Frankly, I thought DOE's letter was insincere and that DOE would continue to oppose bankruptcy relief for nearly everyone and that it would persist in insisting that virtually every distressed student-loan debtor must be placed in a long-term income-based repayment plan. But perhaps I was wrong. 

In October 2015, Richard Precht, age 68, filed for bankruptcy and asked to have his student-loan debt discharged.  Mr. Precht as it turned out was the perfect person to test whether DOE meant what it said in its  July 2015 letter.  He was living in retirement and was in ill health and was burdened with almost $100,000 in student-loan debt.

In fact, his circumstances were desperate. Mr. Precht was living on a small pension and a small Social Security check, but both were being garnished by the federal government. His total income was only $1,200 a month and he was forced to live with his adult daughter because his income was not sufficient for him to afford housing.

Precht filed for bankruptcy in Virginia, and the federal court system quickly issued a scheduling order that put his case on track for a trial before a bankruptcy judge. Fortunately, Mr. Precht was ready to proceed with his case without delay. He had prepared nearly a thousand pages of exhibits outlining his financial circumstances, his health status, and his loan payment history over the years.

Initially, DOE opposed Precht's petition for relief. DOE's lawyer filed a motion to strike, asking the bankruptcy judge to order Precht to refile his complaint on technical grounds. But fortunately for Mr. Precht, the bankruptcy judge had read DOE's July 2015 letter. 

At the hearing, the judge pointedly asked DOE's attorney what DOE planned to do about that letter. The attorney's candid reply was, "We don't know."

But apparently, the policy makers at DOE considered the matter and decided to do the right thing. A few days after the hearing on DOE's motion to strike, the DOE attorney called Mr. Precht and said the Department would not oppose bankruptcy relief. DOE prepared an order for the bankruptcy judge to sign that relieved Mr. Precht of all his bankruptcy debt--a miracle of almost biblical proportions.

As the prophet Amos said: "Let justice roll on like a river." Mr. Precht won a life-altering victory for himself, and his case points the way for hundreds of thousands of people similarly situated. More than 150,000 elderly student-loan debtors are having their Social Security checks garnished, and millions of people are now in long-term income repayment plans that obligate them to pay on their student-loans until they are in their 70s, their 80s, and even their 90s!

Personally, I don't think Mr. Precht's victory signals a change of attitude at the Department of Education. I think he was able to prevail because he was prepared to go to trial and his case was so strong.  As of this writing, DOE still opposes bankruptcy relief for almost all student borrowers.

Nevertheless, Mr. Precht's victory is significant. His case demonstrates that truly deserving student-loan debtors who prepare good cases can prevail in bankruptcy court, even if they are not represented by an attorney.

References

Lynn Mahaffie, Undue Hardship Discharge of Title IV Loans in Bankruptcy Adversary Proceedings.  U.S. Dep’t of Educ., July 7, 2015, DCL ID: GEN-15-13.

Precht v. United States Department of Education, AD PRO 15-01167-RGM (Bankr. E.D. Va. Feb. 11, 2016 (Consent Order).

Dear distressed student loan debtors: You should vote for Bernie Sanders because Hillary won't do anything for you unless Goldman Sachs approves

Dear distressed student-loan debtor:

You are not alone. There are about 20 million of you all across America--people in default, in delinquency, in forbearance and deferment plans, or making income-based payments that stretch out over 20 or 25 years.  You need help, and you deserve help.

You will not find help from Congress. The for-profit college industry owns Congress.

You will not find help from the U.S. Department of Education, which makes soothing noises, but has done very little to help overburdened student-loan debtors.

And you will not find help from most of the presidential candidates. Hillary Clinton's so-called student-loan reform plan is basically a scheme to funnel more money to the higher education industry with only token efforts to keep tuition costs down.

But Bernie Sanders' proposal for a free college education at a public institution offers real change. If his plan is enacted and people could get a college education for free, the for-profit industry would shut down and the private nonprofits would be forced to cut their tuition.

I know Bernie's run for the presidency is a long shot. And even if he is elected, his very sensible plan to offer free postsecondary education would never be approved by Congress, which is beholden to the for-profits and the elite private schools that benefit from the status quo.

But if--by some miracle--Bernie is elected President--he could do a lot for distressed student-loan borrowers even without help from Congress.  Here are some things Bernie could do, and I think would do:

1) Direct the Department of Education to adopt regulations prohibiting the for-profit colleges from forcing students to sign "covenants not to sue" as a condition of enrollment.
2) Order the Department of Justice to cooperate with state attorney generals who are suing the for-profit colleges under state consumer-protection laws.
3) Issue an executive order stopping the Internal Revenue Service from garnishing elderly student-loan defaulters' Social Security checks.
4) Direct government attorneys and the DOE's collection agencies to stop opposing bankruptcy relief for deserving student-loan debtors.

Certainly, I don't think Bernie would allow the Department of Education to oppose bankruptcy relief for a quadriplegic debtor whose expenses exceeded his salary, as the Department did recently in Myhre v. U.S. Department of Education.

I don't think President Sanders would permit the government to oppose a bankruptcy discharge for a 40-year old man who is living on $1200 a month and is so broke he has to ride a bicycle to work, as DOE did in the Abney case.

And surely, Bernie's DOE would order debtor collectors like Educational Credit Management Corporation to stop harassing elderly women living on less than $800 a month as ECMC did in the Roth case.

Nor would a Bernie presidency force millions of overwhelmed debtors into long-term repayment plans, as the Obama administration--cheered on by the New York Times and such elite college presidents as Vassar's Catherine Hill--is doing now.

So if you are swamped by your student-loan debt, you better register to vote, and you better vote for Bernie in your state's primary. And you need to find out whether your state has an open primary or whether you have to be a registered Democrat to vote for Bernie.  If you have to be a Democrat to vote in the Democratic primary, change your registeration. That's what I did.

In short, do what you have to do to vote for Bernie Sanders, because Bernie is your only hope of student-debt relief in the political arena.

And remember this: Hillary Clinton has her hands in Goldman Sachs' pocket, and Goldman Sachs has an ownership interest in a company that operates several for-profit institutions--Argosy University, Brown Mackie College and South University.

References

Stephanie Saul. For-Profit College Operator EDMC Will Forgive Student Loans. New York Times, November 16, 2015. http://www.nytimes.com/2015/11/17/us/for-profit-college-operator-edmc-will-forgive-student-loans.html?_r=0