The Republican megabill recently passed by Congress and signed into law will have profound impacts on American life, including Americans’ pursuit of higher education.1 Among many other changes to the student loan program, it will eliminate the Grad PLUS loan program, set new annual borrowing limits for Direct Unsubsidized and Parent PLUS loans, and establish lifetime limits on federal student loan borrowing. The so-called savings from those provisions totals $44 billion over the next decade.2 

In other words, federal student loans will be fewer and smaller. Proponents of the new student loan limits argue that the spigot of federal lending for college has made college more expensive.3 But the rub is that colleges cannot reverse years of price increases overnight, and the new loan caps do not come with tuition caps.4 Students will still face high tuition bills and living costs despite the new borrowing limits, and they will shoulder the burden of this change if they want to continue to pursue higher education. 

That’s bad news for students, but tremendous news for the private student loan industry, which is poised to cut into a booming market of students and their families needing liquidity and hitting their federal limits in the coming years.5 As a result of Congress’s reforms, these firms are now set to reap “windfall profits.”6

Unlike the federal government, private student loan companies are not beholden to the American public; they are only beholden to their shareholders. And while the federal government does not discriminate based on a student’s family background, private lenders’ standard operating procedure is to issue more-favorable loans to students from high-income families and less-favorable loans to those from low-income families.

The private loan market will step in to fill some of the void left behind by Congress’s changes, but not all of it: private lenders are picky about who they lend to, and they will not lend to every student. Many students will be shut out completely, forcing an early end to their educational pursuits. Others will face worse terms simply because of their parents’ credit scores—a number that says nothing about a student’s academic potential. In the long-term, more borrowers will struggle in repayment and will languish in debt longer due to private loans’ ineligibility for income-driven repayment and forgiveness programs such as Public Service Loan Forgiveness and Total and Permanent Disability Discharge Loan Forgiveness.

Congress’s reforms will mark the end of an era: one in which families, by and large, have had equitable access to student loan lending for college. Not only will it fundamentally alter how students and families conceive of higher education access and opportunity—and require significant changes to how advisors counsel students about whether and where to go to college—but it will also make upward mobility harder to attain, particularly for people of color and low-income families.

Education is already immensely divided based on financial factors outside a student’s control. The Republican megabill widens the divide further. 

A 4.0 GPA Won’t Prevent a 26 Percent APR

It’s well-documented that private student loans are a worse deal for students than federal student loans.7 To start, the interest rates are higher, reaching as high as 26 percent.8 The repayment terms of private student loans are not as flexible as those of federal loans, seldom offering any income-driven repayment options or pathways to forgiveness.9 Some private loans contain harmful provisions hidden in their terms and conditions, such as pre-dispute arbitration clauses, that cut off the hope of any restitution in the event of fraud or harm. Borrowers often hit “refinancing dead-ends” when they cannot negotiate out of loan terms with their private lender.10 It’s easy to understand why people post questions on the Internet such as, “I need a $10,000 private student loan—who is the least evil?11

The timing of Congress’s changes is especially foreboding given that, under the Trump administration, the Consumer Financial Protection Bureau (CFPB)—a vital private loan watchdog—is being targeted for elimination and, to the extent it is still operating, is “deprioritizing” student loan oversight.12 And the private loan market has evolved rapidly, with new forms of risky financial products entering the market, dubbed “shadow student debt.”13 The existing landscape of lenders would be concerning enough; even still, it’s too soon to say what new actors might be motivated to enter the private lending space as a result of the new law, made worse by the gutting of the CFPB. Reining in private lenders has been like a game of whack-a-mole, but now Player One has been instructed to set down the mallet. 

Reining in private lenders has been like a game of whack-a-mole, but now Player One has been instructed to set down the mallet.

Outside student loan channels, many students engage in a much more banal type of high-risk borrowing: credit card debt. One survey of California college students found that nearly half (46 percent) use a credit card in their name at least once a month for education or living expenses, of whom a quarter (25 percent) carry a rolling balance of at least $5,000 month-to-month.14 The existing problem of over-reliance on credit card debt to pay for education expenses could now worsen when students hit their new student loan limits; absent federal loans, many students could be forced to choose between putting the uncovered expenses on credit cards or dropping out entirely.

Absent federal loans, many students could be forced to choose between putting the uncovered expenses on credit cards or dropping out entirely.

Congress’s reform bill will push millions of students into the private market in the coming years, but does nothing to protect students from the dangers of that market. Private lenders sometimes deploy deceptive tactics to pressure students into taking risky, expensive loans; by contrast, the U.S. Department of Education does not peddle loans to anybody.15 Colleges don’t have a perfect record of guarding against these companies, either: there is a sordid history of certain for-profit colleges, including Corinthian Colleges and ITT Technical Institute, engaging in abusive practices aimed at pushing students to take on private loans.16 Following the combined actions of Congress and the White House these past six months, there will be a larger role than ever for private lenders, with fewer guardrails in place than ever. 

Who may be impacted the most by Congress’s student loan reforms? The ink has barely dried on the law, but it’s not too soon to assess which students will be the most vulnerable. At the top of the list are graduate students, who already borrow private loans at high rates but will increasingly depend on the private market due to the elimination of the Grad PLUS program and lower lifetime limits on unsubsidized loans for most graduate students. 

  • In 2019–20, 10.0 percent of graduate nonprofessional students and 29.2 percent of graduate professional students borrowed amounts that would exceed the annual cap on unsubsidized loans under the new law.17 That makes for an estimated annual total of about 505,000 students hitting or on pace to hit their annual loan limit (using 2022–23 enrollment totals). Black graduate students and graduate students who had received Pell are over-represented in this group.18
  • According to longitudinal data on graduate students enrolled in the late 2010s, at least 3.4 percent of graduate nonprofessional students would hit the new lifetime limit of $100,000 and at least 11.1 percent of graduate professional students would hit the new lifetime limit of $200,000.19 That makes for an estimated annual total of about 178,000 graduate students hitting or on pace to hit their lifetime caps (using 2022–23 enrollment totals).

Other early analysis suggests that, in many fields, such as occupational therapy and biomedical sciences, more than half of all graduate borrowers will have no choice but to turn to the private market.20 That’s because shorter graduate nonprofessional programs, such as master’s programs, functionally have a lower aggregate cap than $100,000: a student in a two-year program would only be able to borrow $20,500 in federal student loans each of those two years, for a total of $41,000.

Students from families that rely on Parent PLUS loans will also have to switch to the private market once they hit the new caps, which the new law sets at $20,000 per year and $65,000 in the aggregate. 

  • In 2019–20, 29.0 percent of Parent PLUS recipients received more than $20,000. That makes for an estimated annual total of 269,000 hitting their annual limit (using 2022–23 enrollment totals).21
  • In 2019–20, 17.1 percent of Parent PLUS recipients who were in their fourth or fifth undergraduate year had received more than $65,000. That makes for an estimated total of 159,000 hitting or on pace to hit their lifetime limit before earning a bachelor’s (using 2022–23 enrollment totals).22

To be sure, the new loan limits will not be these families’ only problem. Not only will hitting these limits mean they have borrowed significantly in federal student loans, but also, the new law makes those federal loans more expensive. Going forward, families borrowing Parent PLUS loans, for example, can only access the standard repayment plan, with no options to reduce their monthly payments. Any burdens families face due to taking out private loans will accrue on top of the problem of the high cost of federal student loans under the new law.

Once families turn to the private market, what happens then? In the private market, interest rates and fees vary based on credit score, or the credit score of the cosigner.23 In the case of an 18 year-old who has never borrowed a loan in their life, and who likely does not even hold a credit card in their own name, the private lender requires a cosigner and bases the loan terms on the credit history of the cosigner. The same goes for a young person looking to get a graduate degree, such as someone enrolling straight out of undergrad. Those students’ ability to access private lending is linked to their family’s credit score and finances. 

Divvying up educational opportunity on the basis of credit scores will only magnify existing gaps in access.

In the private lending market, it is not enough if the student is an academic prodigy, or if they are the perfect fit for their college. The only question in the private lender’s mind is: How confident are they that the student, or their cosigner, will repay? They answer that question largely by checking credit scores. And divvying up educational opportunity on the basis of credit scores will only magnify existing gaps in access.

Credit Scores in America: What the Data Show

Expanding private lenders’ role as gatekeepers to higher education will have profound consequences, particularly because of the role of credit scores in lending decisions. Credit scores are one of the most visible ways in which the effects of discrimination and redlining, past and present, shape opportunity today.24 In 2022, the median white adult had a credit score of 727, significantly above the median values for Hispanic (667), Black (627), and Native American (612) adults.25 And as of this year, the share of consumers with subprime credit scores was above 25 percent in majority Black communities and majority Native American communities, compared to 11 percent for majority white communities.26 (Majority Hispanic communities fell in the middle, at 20 percent.27

Another share of the population has limited credit history—also known as “credit invisibles” or “stale unscored,” meaning they may be denied access to a loan because they lack any recorded credit history or have too little history to receive a score. A recent study by the CFPB estimated this group to comprise around one in eight adults in 2020, and earlier CFPB research found that they are overrepresented in low-income neighborhoods, among Black and Hispanic consumers, and among the young.28

Putting these factors together, Table 1 shows the share of consumers with either limited credit history or credit scores that are graded “poor” or “fair,” neither of which would be likely to earn favorable terms on a private loan.29 Overall, 38.2 percent of consumers would likely struggle to obtain a private loan for themselves as a signer, or for a family member as a cosigner. This share is higher in low- and moderate-income neighborhoods and neighborhoods where a majority of residents are Black, Native American, or Hispanic. 

Table 1

More than half of consumers in low- or moderate-income neighborhoods have limited credit history or poor/fair credit.

Community group Share of consumers with limited credit history or poor/fair credit 
U.S. overall 38.2%

By income

Low/moderate-income neighborhoods 50.9%
Middle/high-income neighborhoods 33.7%

By race/ethnicity 

Majority Black neighborhoods 62.2%
Majority Native American neighborhoods 61.1%
Majority Hispanic neighborhoods 48.1%
Majority white, non-Hispanic neighborhoods  33.8%
Majority Asian or Pacific Islander neighborhoods 25.6%
Majority people of color neighborhoods 46.9%
Source: Federal Reserve Bank of Philadelphia, Consumer Credit Explorer, accessed June 2025. Figures reflect Q1 2025. The Federal Reserve does not define “fair,” but the cutoff is generally between 660 and 669. 

It is hard to overstate the racial implications of allocating higher education financing resources through credit scores. In another study that examined financial health across major American cities, nearly two-thirds of the sixty sampled cities saw a gap of 100 points or more in the median credit scores of predominantly white areas and predominantly non-white areas.30

Virtually every state reflects this dynamic. Maps 1 through 4, below, show how credit scores divide America in two: one America in which people are in a good position to access loans, and one in which people are not—a divide that is closely linked to income and race. Compared to higher-income households, low- or moderate-income households show higher shares with limited credit history or poor/fair credit in every state. And compared to majority white neighborhoods, neighborhoods where a majority of residents are people of color show shares with limited credit history or poor/fair credit in every state with sufficient data for comparison.

Maps 1-4

While Southern states show the highest share of families who would struggle to obtain a private student loan, the percentage-point gaps by income are largest in the Midwest: for example, low- or moderate-income households in Ohio are 22.5 percentage points more likely to have limited credit history or poor/fair credit than upper- or middle-income households.31 In Wisconsin, the divide between neighborhoods where a majority are people of color versus majority white neighborhoods is 30.5 percentage points.32

A minimum credit score of 640 is often required to get any private student loan.33 But even for low-score applicants who get in the door, the interest rate will vary based on credit score. According to one source, average ten-year student loan interest rates are currently roughly 13 percent for those with credit scores under 679, roughly 11 percent for those with credit scores from 680 to 719, and roughly 9 percent for those with credit scores 720 or above.34 And it’s worth remembering that the total cost of a loan increases exponentially with each interest rate increase: for a ten-year, $50,000 loan, a jump from 5 percent interest to 6 percent would cost the borrower an extra $2,973, but the jump from 15 percent interest to 16 percent interest would cost them an extra $3,707. The lower-income a borrower’s family is, the faster things go downhill. 

The Private Market Will See You Now. Bring a Cosigner.

Republicans’ elimination or reduction of federal student lending programs is just another example of how the reform law axes vital economic assistance programs in order to pay for tax cuts for the wealthy. The federal student loan program is essential for many students pursuing higher education; scaling it back means many of these students will have to make other plans, with low-income students and students of color paying the steepest price.

The reforms reflect a belief about who in America is worth taking financial risk on. It has always been true that not all student loans pay off; many students use them to attain higher education and use their increased earnings to settle their debt in full, though others struggle to pay their monthly student loan bills and are not able to become debt-free on their own. No one truly knows from the outset whether the rewards for a particular individual student will outweigh the risk. But the universality of federal student loans, equal access to their below-market interest rates, and the pathways to forgiveness have historically signaled that the federal government is willing to exhibit fairness by shouldering some of that risk for the benefit of virtually any American student. Those qualities are not present in the private market; the private market will not loan to someone unless their calculations tell them it is likely to pay off (or if it provides them with short-term gain, such as improving their balance sheets).35 Furthermore, the more that families must rely on private loans, the more risk is pushed onto them, potentially trapping them in a cycle of debt repayment that strains their finances for years.

Not every student will have to turn to the private market, but over the next several years, millions more will now be pushed into it as a result of the bill. For students who want to enroll despite having fewer family resources, the federal student loan program provides equal access to every student, regardless of their family’s financial circumstances. Parents cosign, but their finances do not affect the terms of the loan. The more a student depends on private lenders, the more that student’s access and loan terms simply reflect who their parents are. Those with more would get more—students whose parents have more resources will be able to access more capital, at more favorable terms.

That dynamic is particularly relevant to the institutions that have been most reliant on Parent PLUS and Grad PLUS, a group that includes many historically Black colleges and universities (HBCUs) and other minority-serving institutions.36 In a foreboding example, a policy change a dozen years ago that made Parent PLUS loans contingent on parents’ credit history caused multi-million dollar losses at several HBCUs in just one year.37 (The U.S. Department of Education subsequently scaled back the credit history check, reducing its impact on family eligibility.38)

Simply put, students’ access to higher education should not depend on their parents’ credit score.

Simply put, students’ access to higher education should not depend on their parents’ credit score. Limiting access to higher education financing based on credit score makes higher education even more exclusive, discouraging young people from aiming high and discouraging working adults from retooling their skill sets.

Going to college is already complicated enough, but it will grow more complicated when the new loan limits take effect July 1, 2026. Every family seeking loans for college needs to know answers to these questions:

  • If I progress with my education at my expected pace, am I likely to hit my federal student loan limit? If so, when?
  • If I expect to hit my federal student loan limit, will my family or I qualify for a private loan? What would be the likely terms of that loan?
  • If I am borrowing Parent PLUS loans, am I sure that I can afford my monthly payment under the standard repayment plan?
  • What wiggle room do I have, if my expenses rise unexpectedly?

States, cities, high schools, and colleges will have to adapt their guidance to suit this new reality. Some states such as California and Illinois already run robust programs to connect high school students with trained support in the college-going process; other states could learn from their example.39

To be clear, loan caps are not an inherently ineffective or unfair policy idea, but to be effective and fair, they must be accompanied by other supports. Recent bipartisan efforts to envision graduate loan reform have emphasized that creating loan caps necessitates additional investments to ensure access for low-income students, as well as strengthened protections against nefarious private lending practices; Congress’s law does not include either of these.40

If the Trump administration is not going to establish guardrails against the private student loan industry, states should take up the mantle by taking the following steps:

While state action to regulate private loans will help, states will also have to allocate resources for enforcing these new laws via state attorneys general offices or other state agencies. The combination of solid state regulations and strong enforcement would help deter lenders who would see the new law as an invitation to prey on students.

To be sure, students from affluent families will continue to be able to pay for college just fine. Colleges will compete for them even more, particularly with Grad PLUS off the table and Parent PLUS newly capped. It’s the less fortunate that we should worry about. The net effect will be fewer people enrolled in college—and a weaker economy as a result—while private lenders make off with record profits. 

Notes

  1. Julie Margetta Morgan, “Senate Republicans: ‘Food Banks Squeezed, Big Banks Unleashed,’” The Century Foundation, July 1, 2025, https://tcf.org/content/about-tcf/senate-republicans-food-banks-squeezed-big-banks-unleashed/; text of the law can be found at H.R.1—One Big Beautiful Bill Act, 119th Congress (2025–2026), https://www.congress.gov/bill/119th-congress/house-bill/1.
  2. “Estimated Budgetary Effects of an Amendment in the Nature of a Substitute to H.R. 1, the One Big Beautiful Bill Act, Relative to the Budget Enforcement Baseline for Consideration in the Senate,” Congressional Budget Office, June 28, 2025, https://www.cbo.gov/publication/61533.
  3. Matthew Arrojas, “Republicans Propose Limiting Graduate School Borrowing, Expanding Loan Transparency,” Best Colleges, June 23, 2023, https://www.bestcolleges.com/news/republicans-propose-limiting-graduate-school-borrowing/.
  4. Carolyn Fast, Robert Shireman, and Alex Edwards, “College Tuition Is Out of Control. Voters Want Government to Do Something,” The Century Foundation, July 26, 2023, https://tcf.org/content/commentary/college-tuition-is-out-of-control-voters-want-government-to-do-something/.
  5. Carolyn Fast and Ella Azoulay, “Private Lenders Would Cash In on Congress’s Student Loan Changes,” The Century Foundation, May 20, 2025, https://tcf.org/content/commentary/private-lenders-would-cash-in-on-congresss-student-loan-changes/.
  6. Jennifer Zhang, “Deep Dive: House Reconciliation Bill Makes Paying for College More Expensive and Risky for Students and Working Families,” Student Borrower Protection Center, May 6, 2025, https://protectborrowers.org/deep-dive-house-reconciliation-bill-makes-paying-for-college-more-expensive-risky/.
  7. “Private Student Lending,” Student Borrower Protection Center, April 2020, https://protectborrowers.org/wp-content/uploads/2020/04/PSL-Report_042020.pdf.
  8. Denny Ceizyk, “Student loan interest rates in July 2025,” Bankrate, June 19, 2025, https://www.bankrate.com/loans/student-loans/current-interest-rates/.
  9. “What are the different ways to pay for college or graduate school?,” Consumer Financial Protection Bureau, May 14, 2024, https://www.consumerfinance.gov/ask-cfpb/what-are-the-different-ways-to-pay-for-college-or-graduate-school-en-545//.
  10. “Consumer Financial Protection Bureau Report Finds Private Student Loan Borrowers Face Roadblocks to Repayment,” Consumer Financial Protection Bureau, October 16, 2012, https://www.consumerfinance.gov/about-us/newsroom/consumer-financial-protection-bureau-report-finds-private-student-loan-borrowers-face-roadblocks-to-repayment/.
  11. Via Reddit, r/StudentLoans, May 21, 2025, https://www.reddit.com/r/StudentLoans/comments/1ks4qxn/i_need_a_10000_private_student_loanwho_is_the/.
  12. Hugh Son, “Trump administration, Musk’s DOGE plan to fire nearly all CFPB staff and wind down agency, employees say,” CNBC, February 28, 2025, https://www.cnbc.com/2025/02/28/cfpb-leaders-and-elon-musk-doge-planned-to-fire-nearly-all-staff.html; Jordan Weissman, “The CFPB says it will ‘deprioritize’ protecting student borrowers, people with medical debt,” Yahoo Finance, April 19, 2025, https://finance.yahoo.com/news/the-cfpb-says-it-will-deprioritize-protecting-student-borrowers-people-with-medical-debt-151021551.html.
  13. “Shadow Student Debt,” Student Borrower Protection Center, July 2020, https://protectborrowers.org/wp-content/uploads/2020/12/Shadow-Student-Debt.pdf.
  14. “SEARS Spotlight: Credit Cards & Student Debt,” California Student Aid Commission, n.d., accessed July 2025, https://www.csac.ca.gov/sites/default/files/file-attachments/credit_cards_and_students_debt.pdf.
  15. “CFPB Takes Action Against Student Lender for Misleading Borrowers about Income Share Agreements,” Consumer Financial Protection Bureau, September 7, 2021, https://www.consumerfinance.gov/about-us/newsroom/cfpb-takes-action-against-student-lender-for-misleading-borrowers-about-income-share-agreements/.
  16. “CFPB Secures $480 Million in Debt Relief for Current and Former Corinthian Students,” Consumer Financial Protection Bureau, February 3, 2015, https://www.consumerfinance.gov/about-us/newsroom/cfpb-secures-480-million-in-debt-relief-for-current-and-former-corinthian-students/; “Consumer Financial Protection Bureau and Multiple States Enter Into Settlement with Owner of ITT Private Loans for Substantially Assisting ITT in Unfair Practices,” Consumer Financial Protection Bureau, September 15, 2020, https://www.consumerfinance.gov/about-us/newsroom/cfpb-multiple-states-enter-settlement-itt-private-loans-owner-assisting-itt-unfair-practices/.
  17. Author’s analysis of data from the National Postsecondary Student Aid Study: 2019–20 via NCES Datalab, table retrieval codes tcwhtu, mqbxvc, and puvjrk.
  18. Ibid.
  19. Author’s analysis of data from the Baccalaureate & Beyond Study: 2016/2020 via NCES Datalab, table retrieval code qdmpku, and muaraz.
  20. Jordan Matsudaira via BlueSky, July 2, 2025, https://bsky.app/profile/jdmatsudaira.bsky.social/post/3lsyjjr4tes2u.
  21. Author’s analysis of data from the National Postsecondary Student Aid Study: 2019–20 via NCES Datalab, table retrieval codes qeppgq and fmooyz. Due to inflation, the share borrowing more than $20,000 may have risen since 2019–20, which would make these figures underestimates.
  22. Ibid. Due to inflation, the share borrowing more than $65,000 may have risen since 2019–20, which would make these figures underestimate.
  23. “What are private student loans?” Consumer Financial Protection Bureau, May 14, 2024, https://www.consumerfinance.gov/ask-cfpb/what-are-private-student-loans-en-2136/.
  24. “Past Imperfect: How Credit Scores ‘Bake In’ and Perpetuate Past Discrimination,” National Consumer Law Center, February 2024, https://www.nclc.org/wp-content/uploads/2016/05/20240227_Issue-Brief_Past-Imperfect.pdf.
  25. Sabrina Karl, “Average Credit Scores by Race,” Investopedia, July 2, 2024, https://www.investopedia.com/average-credit-scores-by-race-5214521.
  26. “Consumer Credit Explorer,” Federal Reserve Bank of Philadelphia, n.d., accessed June 2025, https://www.philadelphiafed.org/surveys-and-data/community-development-data/consumer-credit-explorer.
  27. Ibid.
  28.  “Technical correction and update to the CFPB’s credit invisibles estimate,” Consumer Financial Protection Bureau, June 2025, https://files.consumerfinance.gov/f/documents/cfpb_update-credit-invisibles-estimate_2025-06.pdf; “Who are the credit invisibles?,” Consumer Financial Protection Bureau, December 2016, https://files.consumerfinance.gov/f/documents/201612_cfpb_credit_invisible_policy_report.pdf.
  29. “Consumer Credit Explorer,” Federal Reserve Bank of Philadelphia, n.d., accessed June 2025, https://www.philadelphiafed.org/surveys-and-data/community-development-data/consumer-credit-explorer.
  30. Caroline Ratcliffe and Steven Brown, “Credit scores perpetuate racial disparities, even in America’s most prosperous cities,” Urban Institute, November 20, 2017, https://www.urban.org/urban-wire/credit-scores-perpetuate-racial-disparities-even-americas-most-prosperous-cities.
  31. “Consumer Credit Explorer,” Federal Reserve Bank of Philadelphia, n.d., accessed June 2025, https://www.philadelphiafed.org/surveys-and-data/community-development-data/consumer-credit-explorer.
  32. Ibid.
  33. Denny Ceizyk, “What credit score is needed for a student loan?,” Bankrate, April 14, 2025, https://www.bankrate.com/loans/student-loans/credit-score-for-student-loans/.
  34. Lisa Davis, “Average Student Loan Interest Rates Today,” Credible, June 23, 2025, https://www.credible.com/student-loans/student-loan-interest-rates.
  35. “Consumer Financial Protection Bureau and Multiple States Enter Into Settlement with Owner of ITT Private Loans for Substantially Assisting ITT in Unfair Practices,” Consumer Financial Protection Bureau, September 15, 2020, https://www.consumerfinance.gov/about-us/newsroom/cfpb-multiple-states-enter-settlement-itt-private-loans-owner-assisting-itt-unfair-practices/.
  36. Denise A. Smith and Jordan Nellums, “GOP Reconciliation Bill Would Be Harmful to HBCUs, MSIs, and Their Students,” The Century Foundation, February 18, 2025, https://tcf.org/content/commentary/the-college-cost-reduction-act-would-be-harmful-to-hbcus-msis-and-their-students/
  37. Dianne Hayes, “Obama Administration Plans Changes to Parent PLUS Loans,” Diverse Issues in Higher Education, August 15, 2013, https://www.diverseeducation.com/demographics/african-american/article/15093542/obama-administration-plans-changes-to-parent-plus-loans.
  38. “Parent PLUS loans,” Office of Federal Student Aid, n.d., https://studentaid.gov/understand-aid/types/loans/plus/parent#adverse-credit.
  39. See section “State Models for Student and School Support” in Peter Granville, Jaime Ramirez-Mendoza, and Jaden Mikoulinskii, “Mandatory FAFSA Policies Have Had Immediate Impact,” The Century Foundation, February 19, 2025, https://tcf.org/content/report/mandatory-fafsa-policies-have-had-immediate-impact/#c5.
  40. Beth Akers, Nathan Arnold, Zakiya Smith Ellis, Jasmine Jett, Bethany Little, Tiara Moultrie, and Robert Shireman, “Financing Graduate Education: Next Steps for Federal Policy,” American Enterprise Institute, August 2024, https://production-tcf.imgix.net/app/uploads/2024/07/31140029/Financing-Graduate-Education.pdf.
  41. “Student Loan Borrower Bill of Rights,” Student Borrower Protection Center, n.d., accessed July 2025, https://protectborrowers.org/sls-oversight/.
  42. Scott Jaschik, “Education Department Clarifies Rules on Income-Share Agreements,” Inside Higher Ed, March 3, 2022, https://www.insidehighered.com/news/2022/03/04/education-department-clarifies-rules-income-share-agreements; Steven Yoder, “Twilight of income-share agreements to pay for college?,” Hechinger Report, August 12, 2022, https://hechingerreport.org/twilight-of-income-share-agreements-to-pay-for-college/.
  43. Andrew Smalley, “Student Loan Oversight: Private Lending & Student Information,” National Conference of State Legislatures, November 07, 2023, https://www.ncsl.org/education/student-loan-oversight-private-lending-student-information; “Know Before You Owe Private Education Loan Act,” Illinois General Assembly, n.d., accessed July 2025, https://www.ilga.gov/Legislation/ILCS/Articles?ActID=4211&ChapterID=18/
  44. Andrew Smalley, “Student Loan Oversight: Private Lending & Student Information,” National Conference of State Legislatures, November 07, 2023, https://www.ncsl.org/education/student-loan-oversight-private-lending-student-information; “2021 CO S 57,” Statenet, n.d, accessed July 2025, https://custom.statenet.com/public/resources.cgi?id=ID:bill:CO2021000S57&ciq=ncsl27&client_md=c26ad73f73d99ba456cd21a705dddf07&mode=current_text.
  45. “State-Based Student Loan Ombudsmen,” Student Borrower Protection Center, n.d., accessed July 2025, https://protectborrowers.org/state-based-student-loan-ombudsmen/.