If You Can Dream It, you can achieve It at an HBCU or PBI!

The Honorable Arne Duncan Secretary U.S. Department of Education 400 Maryland Ave., S.W. Washington, D.C. 20202

September 12, 2012

I am writing in my capacity as President & CEO of NAFEO, which you know is the membership association of the nation's public, private, and land-grant, 2- and 4-year HBCUs and PBIs. I am writing to thank you kindly for your affirmative response and that of your team members to the request from the HBCU community for your assistance with our efforts to mitigate the tremendous adverse impact of the Department's new interpretation and implementation of the credit history regulation, 34 CFR § 682.201 (c) (2), and its new practice and method of evaluating eligibility for Parent PLUS loans on enrollment at our campuses. I am informed that you heard, firsthand, from presidents Swinton of Benedict College, Francis of Xavier University, and Ribeau of Howard University. NAFEO's poll of its members has shown that the impact of the shift on these institutions is consistent with the impact on others of our colleges and universities, public and private, large and small. The Benedict, Xavier, and Howard experiences are reflective of the experience at Kentucky State University, South Carolina State University, Southern University Baton Rouge, Texas Southern University, Southwest Christian College, Clark Atlanta University, Tuskegee University, Voorhees College and many others of our institutions. New reports are coming in daily.

Tens of thousands of our students arrived on campus only to learn that their Parent PLUS loan application had been denied or that they are no longer eligible. Students were either sent home or admitted with a short window in which to identify funds to fill the gap created by the denial of the Parent Plus Loan application. This is having a devastating impact on enrollment at our institutions and on their ability to serve their students. It is having an even more devastating impact on the students who have worked hard to get to college and have had to cut short their college careers, as well as on their families who have dreamed of and sacrificed for their sons and daughters going to college. It is having an especially deleterious impact on third and fourth year students in good standing, for whom graduation was well within their grasp. The impact is especially ruinous on low income students attending HBCUs that enroll disproportionate numbers of students of fewer financial means and which have disproportionately fewer dollars to offer to students as gap funds or substitute dollars for those they were denied in Parent Plus funding. And, it is inimical to the goal of President Obama to have roughly 60% of Americans with a 2- or 4-year degree by 2020.

I have discussed with members of your team the appeals process contained in 34 CFR § 682.201. I have been informed that your team is considering ways of receiving and expeditiously processing a large volume of appeals. Mr. Secretary, this case-by-case appeals process cannot satisfactorily meet our need for immediate action. Even an expedited case-by-case review, the process will be costly and time consuming. To satisfy laws and regulations governing campus registration, enrollment, student class hours, processing deadlines and the like, the Department should employ a class-based remedy. DOEd should consider sending a letter to every Parent Plus loan applicant who was denied a Parent Plus loan on the sole basis of the consideration of factors not considered prior to 2012, or on the sole basis of a new interpretation of the existing regulations, noting the