{ "document_id": 15354, "page": 2, "width_pt": 612, "height_pt": 792, "rotation": 270, "pipeline_version": "paddleocr-vl-1.6+paul-48", "engine": "paddleocr_vl", "source_run_id": 15465, "item_count": 6, "counts_by_type": { "footer": 1, "text": 5 }, "build_ms": 2, "items": [ { "id": "p2.1", "order": 1, "type": "text", "bbox": { "l": 79.68, "t": 731.04, "r": 548.16, "b": 673.92 }, "text": "intent of the Department to reverse its denial of the loan after careful consideration of the impact of the new interpretation and/or application of controlling regulations, as well as consideration of the equities of the situation. Such a letter could be used as a letter of credit backed by the full faith and credit of the Department of Education." }, { "id": "p2.2", "order": 2, "type": "text", "bbox": { "l": 80.16, "t": 664.8, "r": 553.2, "b": 354.24 }, "text": "Our institutions, our students and our families need immediate relief from DoED's new interpretation and implementation of the credit history regulation, and its new practice and method of evaluating eligibility for Parent PLUS loans. Please consider one of the following as a fair, equitable, cost efficient manner of redress that will not result in students stopping out for this semester or longer: (1) provide parents who received letters of denial from the Department based solely on the new interpretation or application of the credit history requirement, a letter of reversal noting the intent of the Department to award the parents the loan. Such a letter could be used as a letter of credit to the registrars who may otherwise drop the students from their classes; (2) for future years, more clearly define the \"extenuating circumstances\" provision of the regulations to account for major and sustained economic recessions that cause persons with otherwise good credit histories and standing to experience an anomaly and fall behind as the direct result of the national or regional recession; (3) in an effort to judiciously guard the public dollars, consider withholding some percentage of the loan payment to the institutions to establish a payment reserve for parents/borrowers, while the institutions disburse the entire loan amount to the parent and take the percent withheld as a discount; (4) grandfather-in-students who applied for and were awarded Parent PLUS or FFELP loans prior to September 2012, under the previous interpretation of the regulations, who were awarded the loans and did not default, so that eligibility for the loan is determined based on criteria in use at time of application; (5) provide a grant or a long-term low interest loan to the impacted institutions to offset the loss of Parent PLUS loan funds while a new, more reasonable and fair process for evaluating Parent PLUS loan applications is developed; and (6) join NAFEO in seeking the immediate intervention of a foundation whose portfolio appears to be broad enough to permit them to set up an immediate grant program through which our members might secure funds to fill in the gap between the funds the parents/families were able to amass and what is needed to cover the tuition and fees for this semester. These actions would assist greatly with this human disaster." }, { "id": "p2.3", "order": 3, "type": "text", "bbox": { "l": 80.88, "t": 347.04, "r": 552.48, "b": 147.6 }, "text": "With respect to “extenuating circumstances,” in materials discussing Parent PLUS loans, DoED states, “you may also be able to obtain a PLUS Loan if you document to our satisfaction that there are extenuating circumstances related to your adverse credit history.” See, www.direct.ed.gov/parent.html. There are no more extenuating circumstances than the disproportionately high unemployment rate in the communities from which our students come, the protracted, sustained recession that resulted in the average African American family seeing its wealth fall by 53% as compared with 13% for whites, such that the typical African American household now has just $5,700 in wealth, as compared with $113,000 for White Americans. Other extenuating circumstances must include the bursting of the housing bubble, the subprime mortgage scam, and the disproportionate numbers of African Americans who lost their homes during the credit history review period as a direct result of these human disasters, not their patterns and practices. Finally, extenuating circumstances must also include the failure of the Department to phase in or give notice of the new interpretation and implementation of the regulation regarding evaluating credit history. Parents and families who have demonstrated their ability to overcome these national disasters and to rebound; those who are now on more solid financial ground and appear to pose no immediate credit risk should be granted a Parent PLUS loan." }, { "id": "p2.4", "order": 4, "type": "text", "bbox": { "l": 80.64, "t": 140.64, "r": 549.6, "b": 83.04 }, "text": "Mr. Secretary, given what we believe to be the disproportionately adverse impact of the shift in interpretation of the Parent Plus loans on African American, low-income parents of students attending HBCUs, a summary review and where, appropriate, reversal of its denial might also be warranted by the Department under Title VI of the Civil Rights Act of 1964 in which Congress directed in § 2000d that:" }, { "id": "p2.5", "order": 5, "type": "text", "bbox": { "l": 82.56, "t": 69.84, "r": 524.88, "b": 54.72 }, "text": "\"No person in the United States shall, on the ground of race, color, or national origin, be excluded from" }, { "id": "p2.6", "order": 6, "type": "footer", "bbox": { "l": 13.68, "t": 109.44, "r": 42.48, "b": 81.36 }, "text": "", "attrs": { "block_label": "footer_image" } } ], "excluded_furniture": { "first": [], "last": [] } }