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    Subject Term: "Loan interest rates"

    3 publications with a total of 14 open recommendations including 2 priority recommendations
    Director: William B. Shear
    Phone: (202) 512-8678

    3 open recommendations
    Recommendation: To help business disaster victims and resource partners better access information about the disaster loan process, the Administrator of the Small Business Administration should integrate information resources such as the fact sheet, reference guide, and three-step process flier into its disaster loan assistance web portal and Partner Training Portal in a way that is more accessible to users.

    Agency: Small Business Administration
    Status: Open

    Comments: SBA stated that the disaster loan assistance portal includes links to various loan-related resources and a link to SBA.gov, where users can access the SBA Disaster Loan Program Reference Guide and online learning center. We will continue to follow up with SBA on whether the agency plans to centrally integrate the links to loan-related resources into its disaster loan assistance web portal and Partner Training Portal, so resources can be more accessible to users.
    Recommendation: To help reduce confusion about the disaster loan process and the time frames applicants may experience, the Administrator of the Small Business Administration should ensure the consistency of content across its disaster loan process resources by including in these written and online resources, as appropriate, the following: (1) the three-step process; (2) the types of documentation SBA may request and the general reasons why such information may be requested; and (3) estimates of loan processing time frames applicants might experience and external factors, such as the severity of a disaster, that may affect these time frames using, for example, estimates from its forecasting and related planning tools.

    Agency: Small Business Administration
    Status: Open

    Comments: SBA stated that the agency has provided a consistent messaging about the timeframe for making approval decisions on disaster loan applications: SBA's goal is to make a decision on all home and business disaster loan applications within 2-3 weeks, and this loan approval timeframe also is referenced in other loan-related resources and media interviews. We will continue to follow up with SBA on whether the agency plans to (a) ensure informational content is consistent across written and online resources, (b) also include in written and online resources the types of documentation SBA may request and general reasons for the information requests, and (c) tailor the general 2-3 week loan decision timeframe to the each disaster, including the severity of the disaster and other factors that may affect the timeframe, by using the agency's forecasting and related planning tools.
    Recommendation: To further assist disaster business loan applicants, the Administrator of the Small Business Administration should define technical terminology related to financial statements and other finance terminology on the disaster business loan application forms, in both electronic and paper format. For example, in the online application portal, SBA could incorporate a glossary in the "help" feature. Additionally, SBA could include a glossary in the paper application, so that business applicants who apply by mail can access the definitions as well as the general reasons why such information may be requested.

    Agency: Small Business Administration
    Status: Open

    Comments: SBA stated that the agency is developing a glossary of business financial terms to clearly define terminology used in SBA home and business disaster loan applications and required supporting financial documents. Once completed, SBA stated that it will make the glossary available through the agency's disaster loan assistance portal and the SBA.gov website. We will follow up with SBA once the agency completes the glossary of business financial terms.
    Director: Melissa Emrey-Arras
    Phone: (617) 788-0534

    6 open recommendations
    including 2 priority recommendations
    Recommendation: The Secretary of Education should assess and improve, as necessary, the quality of data and methods used to forecast borrower incomes, and revise the forecasting method to account for inflation in estimates.

    Agency: Department of Education
    Status: Open
    Priority recommendation

    Comments: The Department of Education agreed to assess and improve its borrower income forecasts. The agency reported that it is working with Treasury and other federal partners to obtain the best income data while ensuring that taxpayer privacy is protected to the full extent of the law. Education noted it will establish a timeframe for improvements to the IDR model that allows for adequate and thorough analysis and quality control. It will also consider including an adjustment for inflation in our income estimates and will document the results of our analysis for the next version of the IDR model. The agency wants to guarantee that an inflation adjustment is appropriate for this subpopulation of IDR borrowers, therefore they will conduct further analysis to ensure that any inflation adjustment is appropriately incorporated into the model. The agency anticipates completing these efforts by September 29, 2017. When these efforts are complete, GAO will await documentation that Education has assessed and improved the quality of data quality and methods it uses to forecast borrower incomes, and that it has revised its forecasting methods to account for inflation.
    Recommendation: The Secretary of Education should obtain data needed to assess the impact of income recertification lapses on borrower payment amounts, and adjust estimated borrower repayment patterns as necessary.

    Agency: Department of Education
    Status: Open
    Priority recommendation

    Comments: The Department of Education agreed to attempt to obtain data to assess the impact of income recertification lapses on borrower payment amounts. The agency reported that it started to collect more detailed information on borrowers who fail to recertify their income. It will analyze these data to see if they can be used to adjust borrower repayment patterns in the model. The agency will also consider whether to include behavioral effects to account for targeted borrower outreach to recertify their income. GAO will monitor the progress of these efforts. Education expects to complete these efforts by September 29, 2017. At that time, GAO will await documentation that Education has obtained the necessary data to assess the impact of recertification lapses on borrower repayment patterns and adjusted estimated borrower repayments in its model, as necessary.
    Recommendation: The Secretary of Education should complete efforts to incorporate repayment plan switching into the agency's redesigned student loan model, and conduct testing to help ensure that the model produces estimates that reasonably reflect trends in Income-Driven Repayment plan participation.

    Agency: Department of Education
    Status: Open

    Comments: The Department of Education agreed to incorporate repayment plan switching into its redesigned student loan model, and reiterated that efforts to incorporate this capability had begun despite challenges inherent in predicting borrower behavior. GAO will monitor the progress of these efforts.
    Recommendation: The Secretary of Education should, as a part of the agency's ongoing student loan model redesign efforts, add the capability to produce separate cost estimates for each Income-Driven Repayment plan and more accurately reflect likely repayment patterns for each type of loan eligible for these plans.

    Agency: Department of Education
    Status: Open

    Comments: The Department of Education asserted that as they redesign its current cost estimation model, it will consider adding the capability to produce separate cost estimates for each IDR plan and allow for separate, more accurate estimates by loan type.
    Recommendation: The Secretary of Education should more thoroughly test the agency's approach to estimating Income-Driven Repayment plan costs, including by conducting more comprehensive sensitivity analysis on key assumptions and adjusting those assumptions (such as the agency's Public Service Loan Forgiveness participation assumption) to ensure reasonableness.

    Agency: Department of Education
    Status: Open

    Comments: The Department of Education agreed to test its approach to estimating IDR plan costs more thoroughly, including through more comprehensive sensitivity analysis. The agency included in its FY16 Annual Financial Report, sensitivity analyses for Public Service Loan Forgiveness participation and borrower incomes. In the future, the agency will consider conducting additional sensitivity to analyses as well as other kind of analysis to ensure reasonableness. GAO will consider closing this recommendation when the agency has completed these efforts.
    Recommendation: The Secretary of Education should publish more detailed Income Driven Repayment plan cost information-- beyond what is regularly provided through the President's budget--including items such as total estimated costs, sensitivity analysis results, key limitations, and expected forgiveness amounts.

    Agency: Department of Education
    Status: Open

    Comments: The Department of Education agreed to publish more detailed IDR plan cost information and stated that it plans to present sensitivity analysis results and key limitations in upcoming financial reports. GAO will consider closing this requirement when the agency has completed this effort.
    Director: Melissa Emrey-Arras
    Phone: (617) 788-0534

    5 open recommendations
    Recommendation: To help ensure quality information is conveyed to servicemembers about how the Servicemembers Civil Relief Act (SCRA) interest rate cap applies to student loans, the Secretary of Defense should direct the secretaries of each service branch, and work with other secretaries as appropriate, to ensure that all information about the SCRA interest rate cap for student loans is accurate when provided to servicemembers and to those who work with servicemembers to help them obtain SCRA benefits, including information contained in outreach materials.

    Agency: Department of Defense
    Status: Open

    Comments: The Department of Defense (DOD) disagreed with this recommendation believing it to be unnecessary because it is already providing accurate information. Specifically, DOD noted that the information provided in several documents GAO reviewed is accurately based on statute whereas Education's updated requirement to automatically apply the cap is based on policy that could change in the future. Moreover, the automated process applies only to federal and commercial FFEL student loans in contrast to other types of debt. DOD said that providing information based on statute rather than policy would cause less confusion and was a better approach than what we recommend. However, our report noted that Education formalized the automated process through federal regulations, effective July 2016, which legally require servicers to use this process for all federal and commercial FFEL loans. In addition, DOD said it was unable to verify whether DOD's Military OneSource website inaccurately states that the SCRA rate cap does not apply to commercial FFEL loans. However, our searches of the website still turned up this inaccuracy. DOD said it would look into a means of verifying website information but that in the meantime, it is satisfied that its training provides correct information. Given that Military OneSource is a key source of information for servicemembers and that some documents DOD provided state that the SCRA rate cap does not apply to student loans, we continue to believe that servicemembers are not always receiving accurate and up-to-date information.
    Recommendation: To ensure that all eligible servicemembers with student loans receive the SCRA interest rate cap, the Attorney General should direct the Department of Justice to consider modifying its proposed changes to SCRA to require use of the automatic eligibility check for private student loans.

    Agency: Department of Justice: Office of the Attorney General
    Status: Open

    Comments: The Department of Justice (DOJ) stated that its current package of proposed legislative changes provides benefits to servicemembers with all kinds of loans, including private student loans. Rather than requiring servicemembers to submit written notice and a copy of military orders, they need only give oral or written notice of eligibility for the cap to their creditors. Creditors would then have to search the Department of Defense's records to verify the servicemembers' military service and apply the SCRA interest rate cap, when applicable. DOJ believes that these changes would significantly benefit all servicemembers with loans while providing a uniform standard for all types of creditors. The department added that it will consider its proposed changes to SCRA in future legislative proposals and plans to obtain feedback from stakeholders on how to improve SCRA's protections for servicemembers. However, as stated in our report, servicemembers with private student loans would still need to be aware of the rate cap in order to give notice, whether written or oral. Therefore, we encourage DOJ to consider updating its current proposal to require use of the automatic eligibility check by all student loan lenders and servicers. Not only would this ensure that servicemembers with private student loans receive a benefit for which they are eligible, but also that the interest rate cap is applied consistently across all types of student loans. The agency said that it would consider these changes to the SCRA in future legislative proposals and plans to obtain feedback from stakeholders on how the agency can propose to improve the SCRA's protections for servicemembers. However, as stated in our report, servicemembers with private student loans would still need to be aware of the rate cap in order to give notice, whether written or oral. Therefore, we encourage DOJ to consider updating its current proposal to require use of the automatic eligibility check by all student loan lenders and servicers. Not only would this ensure that servicemembers with private student loans receive a benefit for which they are eligible, but also that the interest rate cap is applied consistently across all types of student loans.
    Recommendation: To enhance customer service, the Secretary of Education should direct the Office of Federal Student Aid to identify ways to modify the data collected in its unified borrower complaint system to allow the agency to more precisely identify and analyze complaints specifically about the SCRA interest rate cap.

    Agency: Department of Education
    Status: Open

    Comments: The Department of Education said it is committed to accurately tracking the types of complaints it receives and will create a complainant subcategory for SCRA under the "Military and Veterans Benefit" category. In addition, it will continue to run periodic key word searches to identify other complaints that may have been miscategorized by the complainant, related to the requirements of the SCRA, and ensure that they are considered appropriately. GAO will consider closing this recommendation when the department has provided evidence that it has completed these efforts.
    Recommendation: To better ensure that servicemembers with private student loans benefit from the SCRA interest rate cap, the Director of the Consumer Financial Protection Bureau and the Attorney General of the Department of Justice should coordinate with each other, and with the four federal financial regulators, as appropriate, to determine the best way to ensure routine oversight of SCRA compliance for all nonbank private student loan lenders and servicers. If CFPB and DOJ determine that additional statutory authority is needed to facilitate such oversight, CFPB and DOJ should develop a legislative proposal for Congress.

    Agency: Consumer Financial Protection Bureau
    Status: Open

    Comments: The Consumer Financial Protection Bureau (CFPB) stated that it is committed to working with the Department of Justice (DOJ) and federal financial regulators, when possible, to facilitate oversight of SCRA compliance and that it will support all relevant federal agencies in using their respective authorities to identify and address SCRA violations as efficiently and effectively as possible. While CFPB coordinates with DOJ and other federal regulators in general, there is still no single agency authorized to enforce SCRA compliance among nonbank private student loan lenders and servicers, and no entity is conducting onsite supervisory reviews of these lenders and servicers. In addition, while CFPB may refer complaints from servicemembers about the SCRA rate cap for private student loans to DOJ and other financial regulators, we believe this does not constitute routine, proactive oversight and also presumes servicemembers are aware of the SCRA rate cap. GAO will consider closing this recommendation when the bureau has provided evidence of actions it has taken to facilitate routine oversight of SCRA compliance for all nonbank private student loan lenders and servicers.
    Recommendation: To better ensure that servicemembers with private student loans benefit from the SCRA interest rate cap, the Director of the Consumer Financial Protection Bureau and the Attorney General of the Department of Justice should coordinate with each other, and with the four federal financial regulators, as appropriate, to determine the best way to ensure routine oversight of SCRA compliance for all nonbank private student loan lenders and servicers. If CFPB and DOJ determine that additional statutory authority is needed to facilitate such oversight, CFPB and DOJ should develop a legislative proposal for Congress.

    Agency: Department of Justice: Office of the Attorney General
    Status: Open

    Comments: The Department of Justice (DOJ) believes that it is in full compliance with this recommendation and that the four federal financial regulators do not have statutory authority to examine nonbank private student loan lenders and servicers unaffiliated with a depository institution. DOJ stated that it already coordinates extensively with the Consumer Financial Protection Bureau (CFPB) and the financial regulators concerning SCRA compliance through such mechanisms as referrals from CFPB for any SCRA-related violations and access to its consumer complaint database, and regular meetings with CFPB, and that it will continue to be built upon these efforts. While these mechanisms are commendable, GAO believes they do not constitute exercising routine oversight of nonbank private student loan lenders and servicers who are not affiliated with a depository institution. We believe that additional interagency coordination, including working with CFPB to seek additional statutory authority, as needed, is necessary to ensure routine SCRA compliance.