On behalf of our low-income clients, the National Consumer Law Center submits these comments in response to the U.S. Department of Education’s request for comments on the proposed income-driven repayment (IDR) plan request form. Our comments reflect our expertise in the applicable IDR regulations as well as our experience working directly with low-income borrowers applying for IDR plans and feedback from other legal aid attorneys who provide IDR application assistance. All of our comments are intended to help ensure that the process of enrolling and remaining in IDR plans is smooth and accessible to all student loan borrowers, and to low-income and otherwise vulnerable borrowers in particular.
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