Today, Federal Student Aid released a series of updates to the quarterly application, disbursement, and portfolio reports on its FSA Data Center to include data through September 30, 2019. As part of this release, servicer performance allocation metrics for the period beginning September 1, 2019, were also refreshed. Federal Student Aid proactively posts these reports in support of open government initiatives to help ensure consistency, increase transparency, and establish self-service opportunities for stakeholders.
Key Findings in the Quarterly Reports
While not exhaustive, the information below provides a snapshot of key findings in our most recent reporting. Student loans are highly cyclical in nature so figures should be compared year over year whenever possible.
Loan Portfolio Overview
Today, the outstanding federal student loan portfolio is $1.51 trillion. The Direct Loan (DL) portfolio now represents 82 percent of the outstanding loan portfolio while the Federal Family Education Loan (FFEL) portfolio represents 17 percent, and Federal Perkins Loan Program loans comprise less than one-half percent. The federally managed portfolio, which includes DL and FFEL Program loans owned by the Department, is now $1.33 trillion, representing more than 88 percent of the total portfolio. The growth of the portfolio has slowed since 2010 as new disbursements have declined. Year-over-year, the total federal loan portfolio has increased 4.9 percent—about $71 billion—with the FFEL portfolio decreasing by more than seven percent and the DL portfolio increasing by eight percent.
Through September 30, 2019, approximately 16.1 million applications were submitted for the 2019-2020 application cycle, a 3.1 percent decrease from the same time period in the prior year. Application volume has generally declined since 2011-2012, except for the 2017-2018 application cycle, which was when the application cycle extended from 18 to 21 months.
Income-Driven Repayment Enrollment
Enrollment in income-driven repayment (IDR) plans such as Income-Based Repayment (IBR), Pay As You Earn (PAYE), and Revised Pay As You Earn (REPAYE) has continued to increase. As of September 2019, approximately 7.8 million DL borrowers were enrolled in IDR plans, an eight-percent increase from September 2018. Although 1.3 million ED-held FFEL borrowers are enrolled in IBR and Income-Sensitive Repayment (ISR), there is a large overlap of DL and ED-held FFEL IDR borrowers. Combined, 8.1million unique borrowers are enrolled in IDR plans.
New Defaults and Delinquencies
To more accurately measure the flow of defaults, Federal Student Aid began publishing data about new DL defaults in March 2016. Because there are currently no provisions to write off defaulted federal student loans, historically, the cumulative defaulted loan portfolio continues to grow even as delinquencies and new defaults have slowed. During FY2019 Q4, the percentage of new defaulters slightly increased compared to the same time last year while the percentage of dollars entering default remained on par with last year. Approximately 260,000 DL borrowers—or 1.4 percent of recipients who were in repayment last quarter—with outstanding balances totaling $6.3 billion—or 0.9 percent of the total outstanding dollars that were in repayment last quarter. — entered default.
DL delinquency rates have resumed their downward trend following an uptick over the last few quarters as a result of disaster-impacted borrowers exiting forbearance statuses. In fact, more than 83 percent of non-defaulted DL recipients with loans in active repayment are current on their loans (i.e. on time or less than 31 days delinquent), putting the 31-day plus delinquency rate at 16.7 percent by recipient count and 13.2 percent by total dollar balance, representing year-over-over decreases of 10.9 and 10.5 percent, respectively.
Like DL, the ED-held FFEL portfolio’s 31+ delinquency rates also experienced year-over-year decreases in recipients and dollars, now at 16.6 percent by recipient count and 19.6 percent by total dollar balance. These decreases contributed to a similar reduction in delinquency rates across the entire federally managed portfolio (combining Direct Loans and ED-held FFEL), which are now at 16.8 percent by recipient count and 13.5 percent by total dollar balance.
Borrower Defense to Repayment Report
Last year, Federal Student Aid first published the borrower defense to repayment report. Provisions in the Higher Education Act referred to as borrower defense to repayment (borrower defense) allow borrowers to seek loan forgiveness if a college or university misled them or engaged in other misconduct in violation of certain state laws. During the last quarter, Federal Student Aid received approximately 15,000 new borrower defense applications, bringing the total application count to approximately 288,000.
Almost 48,000 applications have been approved, resulting in nearly $535 million in discharges. The total amount discharged and the number of approved and ineligible applications included in the September 30, 2019, report has not changed as a result of ongoing litigation and the prioritization of the implementation of the 2016 final regulations. However, Federal Student Aid has continued to close applications in which the borrowers qualified for other benefits, including automatic closed school discharge.
Public Service Loan Forgiveness
The Public Service Loan Forgiveness (PSLF) Program, which was established under the College Cost Reduction and Access Act of 2007, permits DL borrowers who make 120 qualifying monthly payments under a qualifying repayment plan, while working full-time for a qualifying employer, to have the remainder of their balance forgiven. As of Sept. 30, 2019, approximately 110,000 borrowers had submitted more than 136,000 applications for loan forgiveness under this program. Of the approximately 125,000 applications that have been processed, more than 74 percent of them were ineligible due to not meeting the program requirements (such as making 120 qualifying payments or having eligible loans or qualifying employment). Another 24 percent of PSLF applications were ineligible due to missing or incomplete information on the form. These borrowers have been advised to submit a complete application so a determination of their eligibility can be made. As of September 30, 2019, 1,561 applications have been approved by the PSLF loan servicer as meeting all program requirements, resulting in $71.9 million in discharges for 1,139 unique borrowers.
More than one-thousand borrowers have also received approximately $43.7 million in discharges under the Temporary Expanded PSLF (TEPSLF) opportunity. Of the approximately 20,000 borrowers who have been deemed ineligible for TEPSLF, one-third have not been in repayment for 10 years; one-fifth do not meet the TEPSLF payment requirements for payments during the last 12 months; and one-tenth have no loans eligible to receive TEPSLF.
Servicer Performance Results and Allocations
As part of this release, FSA posted all federal loan servicer performance metric and allocation data, in addition to its accompanying explanation, on the FSA Data Center. This includes the customer performance results for the Quarter Ending March 31, 2019, customer performance results for the Quarter Ending June 30, 2019, and allocations in effect September 1, 2019 through February 29, 2020.
Key Items to Note While Reviewing These Reports
To accurately interpret the data, please note the following items:
In the portfolio reports, recipient counts are based at the loan level. For that reason, recipients may be counted multiple times across varying loan statuses. For example, a recipient with one loan in deferment and one loan in forbearance would be counted once in each category. A recipient with two loans in the same status would be counted once in that category.
In the portfolio reports by servicer, please note the differences in portfolio composition between the Title IV Additional Servicers (TIVAS) and the Not-For-Profit Servicers (NFPs). The NFP portfolio was originally made up of accounts received from the Direct Loan Servicing Center in 2011–12. These loans already were in repayment and current at the time they were transferred. As a result, the loans were more stable and mature than the TIVAS portfolios. In addition to new accounts, the TIVAS service FFEL Program loans purchased through the Ensuring Continued Access to Student Loans Act and loans of all statuses received from the Direct Loan Servicing Center in 2011–12. Although the NFPs first started receiving new borrowers in January 2015, many of those loans still are in an in-school status.
The Consolidated Appropriations Act of 2016 required the Department to allocate new student loan borrower accounts to eligible student loan servicers based on their performance compared to all loan servicers utilizing established common metrics, and based on the capacity of each servicer to process new and existing accounts no later than March 1, 2016. Prior to the passage of the Consolidated Appropriation Act, the Department established common performance metrics across all servicing contracts but maintained separate allocation pools to reflect differences in portfolio composition.
Given this requirement, beginning on March 1, 2016, new allocation percentages were based on performance under the established common metrics compared across all loan servicers. Since March 2016, the Department has developed a revised methodology, that it continues to implement today, that better reflects differences across servicer portfolios while maintaining the established common metrics.
Active repayment includes all current and delinquent borrowers whose accounts are currently serviced by federal servicers. Borrowers with loans in grace, in school, in deferment, in forbearance, or in bankruptcy or disability status are not expected to make payments and are not included in this calculation.
The Portfolio by Delinquency Status reports should not be directly compared with the quarterly performance metrics for federal student loan servicers. These reports define current repayment as less than 31 days delinquent while the most recent contracts with the servicers define current repayment as five or less days delinquent. The servicer contract performance metrics are at the borrower level while the FSA Data Center reports are based at the loan level. As a result, there may be duplication across the FSA Data Center reports in the event a borrower has loans in varying delinquency statuses.
In the loan and grant reports, the first worksheet shows the number of recipients and disbursements for the specified quarter while the second tab shows the cumulative, award-year-to-date activity. The second worksheet of an award year’s fourth quarter report will show data for the full award year. As the information is reported by specific loan type or grant program, a total unique grant or loan recipient count is not available by school. Please note that because loan and grant reports generally are run shortly after the quarter’s end, initial runs often under-report activity as a result of reporting delays and activity that occurs for the award year after the run date (for example, summer disbursements).
The FSA Data Center was launched in 2009 to increase government transparency by proactively posting information useful to businesses, institutions, the media, and individuals. In addition to the reports listed above, Federal Student Aid regularly posts strategic plans, copies of executed contracts, and school compliance reports, such as Clery Act reports and financial composite scores, on the FSA Data Center. Federal Student Aid is committed to continuing to expand the data sets available on the FSA Data Center in alignment with customer needs.