Last week, the CFPB released to the public a memo it had sent to consumers and industry members who participated in its “Know Before You Owe” student loan project reporting on the feedback it received. The project, described as the product of the CFPB’s partnership with the Department of Education (“DOE”), solicited comments on a “financial aid shopping sheet” which was actually a draft model financial aid form. (See our earlier post about the project’s launch in October 2011.)
Although the CFPB says its “thought starter” form was “checked out” by over 20,000 participants, it’s not entirely clear what that means. The CFPB does not say how many substantive comments it received, whether any of the comments were critical, or, although it reminds us that the purpose of the form was to engage students, parents, educators and thought leaders, who the comments came from. The comments do not appear to be accessible electronically and it’s unclear if they are even publicly available, absent a FOIA request.
The CFPB does report “a great deal of excitement for the idea of a standard financial aid shopping sheet,” and it briefly describes certain responses it received to the five questions it asked about the draft. According to the memo, “just about everything” was the answer to the CFPB’s question asking what information was critical. In answer to the CFPB’s question asking what other information would be helpful, it appears commenters wanted more information about work study (and also thought work-study shouldn’t be in the loans section of the form because it doesn’t have to be repaid), more information about default rates, including repayment drivers such as employment data, and more information about repayment options for federal and private loans.
And in response to the CFPB’s request that features be ranked in importance, the feature that was the top choice, “estimated debt at graduation,” was not the most prominent feature of the draft form. One of the two most prominent features of the draft-“what will you pay for one year” – did not make the top five.
What’s next? Even though the DOE’s web site says that the CFPB will develop a second version of the model form (“in January of 2012”), for now, it seems the CFPB is done and the ball is in the DOE’s court. If that’s the case, then the DOE may not be able to issue any revisions if it still intends to meet its announced goal of having a final form available no later than this Spring. Recognizing that the Higher Education Opportunity Act required the DOE to submit its recommendations for a model financial aid offer form by August 14, 2009 (a year after the law was enacted), we’d nonetheless like to see the DOE and CFPB take their time with such an important project. (The DOE has posted information on what it has been doing to develop a model form while the CFPB was taking comments and its web site should be a useful resource for future developments.)