(Ep. 234) Navigating the Maze: Insights into Student Loan Forbearance, Recertification & Forgiveness

and myself Megan and we are going to be talking about some interesting situations that we've come across, some client cases, really getting down to business. So how are you Lauren? I am doing wonderful. I am so excited that it is finally the warmer weather time of the year. I think it is great to be able to go outside and exercise and I've been on my workout stuff. I'm trying to get my summer body together right now. The weather is warmer coming up there in Texas. Yeah you know in Texas we get hot hot. Right now it's warm which most people are probably referred to as hot but it's not hot hot yet. We're not in the hundreds yet. Oh gosh yeah I am in Georgia, North Georgia. So it's been getting muggy here. We get real muggy. Does it does that happen in Dallas or is it more dry hot? The humidity comes occasionally but in general we're more of a dry heat. Yeah we're getting the humidity here in May but looking forward to the summer as well. Well let's go ahead and jump on in to some of our topics today. I think one of the first things we wanted to talk about is payments coming up right? You were reading an interesting article lately or recently about student loan payments. Yeah so you know we're always looking for what is the latest and greatest news trying to stay on top of things and even just it was just a general search about student loans to see if there was anything new and exciting versus you know what we had been talking about. And the article was all about the idea that payments are beginning for real this time. That there's many indications that there will not be another extension as per like the Biden administration. So I just thought it was interesting that they're like for real for real. No no no for real because we all know how many times they said for real. And I think some people are actually gonna need to go to therapy when they finally do pick up. Trust issues right? So just in case you haven't heard on a recent podcast what they're doing is that either when the court case is completed or June 30th which we're all pretty sure that's gonna be June 30th now, payments will start 60 days later. So basically that gets rid of all of July all of August and you should be expecting payments to start in September. So if you are not ready you really really really this time should get ready. Megan and I don't know for sure that they're gonna start but I am confident that they're not making this up and that they actually do plan to start them at some point. I know a lot of people when I talk about student loans they're like girl they're gonna forgive them all. Like they're definitely not ever starting this back up again. I will never have to make another payment. They've decided that in their mind but I don't want you to be disappointed if payments begin in September. I know. Protect your future self. Get prepared. Know what your payments going to be. Start factoring that into your budget and we know inflation has been a big factor and a lot of people spending and you know a negative factor and a lot of people spending and their bills. So just be prepared for when that payment comes in. You can also take a look at your studentaid.gov and probably even in login to your servicer and find out what your payment should be when you begin again. And so a lot of people have been able to take advantage of the payment being way way way back to their 2018 payment 2019 payment when income was lower when they were still in school. You know all sorts of different things were happening and they're gonna be picking back up at like you know 75 bucks when their current payment would be $1,000. That was a consultation I did yesterday actually. I was like don't make any changes. So you're definitely gonna want to make sure you know what your payments gonna be so that one like Megan said you can start saving up for it. But two you do not want to recertify your income unless it's absolutely necessary if it's going to benefit you to keep up with that lower payment. So that's what we've been helping people a lot with in consultations lately is understanding when exactly payments will begin what payment they can expect and for how long they can expect it because there's also some some wonky rules about when you will be required to recertify. Yep a lot of people probably won't have to update income until later in 2024. So there's a lot of planning opportunity there for those going towards loan forgiveness to maximize you know their forgiveness overall by keeping those payments really low for as long as possible. One thing to note on checking your servicer portal for your payment I have gotten a lot of reports from folks specifically who are with Mojila and Nelnet for their loan servicers when they sign into their accounts they're seeing what would be the standard 10-year payment as what their next payment is going to be and it says something like you know that payment will kick in in September. Don't let that panic you if that number looks very off to you it probably is and Nelnet and Mojila I know well my assumption why these two companies in particular are showing the standard 10-year payment is likely because you were not at Nelnet or Mojila before COVID started before this COVID forbearance happened. A lot of people are getting moved to Nelnet from Great Lakes because Great Lakes is getting absorbed by Nelnet so you may have had them prior to moving over to Nelnet and same thing with Mojila you may have had FedLoan or a different servicer because maybe you're with PSLF or maybe you're just with Mojila you don't have to be pursuing PSLF to be with Mojila but you likely well you definitely did not have Mojila before 2020 because they're a new company a new servicer so I think that's some of the the rhyme or reason behind why you might be seeing that standard payment it's likely because you just didn't have them before payments were shut off that's not to say that you won't have that payment that you had prior to payments shutting off but it's just not reflecting it currently right now probably because they don't have to be showing it right now payments are not kicking in within 60 days at this point so that I think it'll start to make more sense the closer we get to August and I think your account will start to make more sense and the payment and your portal will start to make more sense but just a note of caution don't panic if you log in and see a really ugly number it's probably not accurate that's probably just their placeholder until they update their systems that makes so much sense to like you said that the people who had to get changed over like hey we just threw you to this default thing and they're working behind the scenes because they do actually have to give you the payment that was your you know 2018 2019 payment and not the standard if you will and they've also been very clear about when people will have to recertify and it's actually ties into a story that I'm going to tell later but as a little bit of a spoiler alert you can call in if you see that standard you know this may just be something extra that you do when like I said to Megan's point it's it's hundreds of people or it was probably thousands of people because we're seeing it on a regular basis with our consult they're going to have to update it so you can do nothing and you know right before payments assuming that it's still looking like this you're like oh my god then you need to do something but it probably makes more sense to just wait it out because we know that a lot of changes are happening in the short term yep and I think that brings us to our next topic point today about how it is pretty clear that the Department of Ed is making some changes to your text files the TXT files that you can download from your student aid gov account those are the raw numbers and data that we use for our planning we run it through our software to figure out an estimate estimated how many months of repayment you've been in how many months you've been in forbearance what the interest rates are what types of loans you had it gives us a lot of detail but it's very clear that the Department of Ed is making some changes to these files or kind of scrubbing them if you will right is that what you're seeing too yeah lots of different changes that are going on with the TXT file and I always like to think of the TXT files like your credit report but we also know that if you you've done any real analysis of your credit report that they can be wrong so while this is a area that you should be depending on to get the accurate information related to your student loan history and what payment plans and like you said it's been the best place for us to be able to do our consultations we've been seeing a lot of weird things one of the things I've been seeing recently is 1-1 so January 1st of 2020 as the period of forbearance that started in general what we've been seeing is is 3-13 because that's the official start of COVID forbearance so yet another thing that's like hmm this doesn't make any sense and the first time you see it you're like oh maybe it was just this person maybe they chose forbearance but you start seeing it two or three different times you're like oh okay this is kind of a theme and they're they're sure that they didn't make any payments during COVID or they didn't choose forbearance you know there's also though some good things that are happening you've seen the portals related to studentaid.gov looking better and all of this is what they're saying is that they're trying to create a payment tracker so the idea is that once all this stuff gets straightened out and you know why all this stuff is crazy stuff is happening to the TXT file is that they're gonna say presto change oh here's the new starting line here's everyone's new payment count based on all these things that we forgive and all these leniencies that we created as per the COVID forbearance now we have a clear starting line you have clear instructions on what you need to do and also we have this cool payment tracker so they said that we should expect that in 2024 and I am super excited for it because what they had but pre-COVID was just not a payment tracker and it was really confusing for people it's not transparent at all yeah I know we are everybody at the student loan planner team I think we are pumped for this tracker and we were super excited about this too when the PS the PSLF tracker came about with started at FedLoan then moved over to MoGila because it's just a way more transparent way of knowing where you stand when it comes to your forgiveness timeline because right now we can make some educated assumptions based on when you graduated and what your text file says your payment history was but it would be nice to see it like on a dashboard it makes sense that you'd be able to see this within your dashboard right because they're tracking it we know that when you get income driven repayment forgiveness like the 20 or 25 year forgiveness it's automatic they're supposed to automatically shut off your payments once you've hit the 20 or 25 years of equivalent payments and so if they're tracking it it would make a lot of sense for them to show us that they're tracking it and that way we could check for accuracy so that is something that we're waiting for they're saying that this is going to be well originally they said it was going to be available in summer of 2023 and now they're saying it's going to be available in early 2024 so that's okay as long as it's coming I think that's a good thing and that tracker is is really important too because this account adjustment that's going on right now the IDR waiver it's been said on studentaid.gov that if you are someone who's already made the equivalent of 20 or 25 years of payments or been either in repayment or had extended forbearances or qualifying periods towards that timeline if you've already surpassed the 20 or 25 years then you should be getting your loans forgiven by August before payments restart that is literally said on the studentaid.gov website so if you think you're in that bucket or you think you have had your loans and had repayment history to meet the IDR forgiveness requirements look out for that notice by August and if you don't see it don't panic because I think that there we're going to talk about this here in a little bit but there are some ways that you can dispute inaccuracies in your payment history but all that to say is I think there's going to be some forgiveness coming very soon by August for folks who have been in repayment for a long time and if you feel like that should be you and that hasn't been happening to your file at that time then there are some ways you can go about fixing it so we'll talk about that here coming up. Yeah I think what Megan is saying and what we are saying is it's time to wake up if you have been sleeping for the last three years it is time to open your eyes and see how the various things that are taking place right now might be able to benefit you yes we have all really loved the three years of forbearance but you want to get ahead of seeing what's going on want to understand the process as well as possible so that you can advocate on behalf of yourself if something is not as it should be so understanding how all this works at least in some sort of former fashion is a key piece of the puzzle so that you can make sure that they give you exactly what you deserve or more more is good you know they make a mistake and it benefits you. Well and some quick hitter things just to recap the account adjustment or the IDR waiver it's going under those two kind of blanket names right now but this will a couple facts just to know and you can revisit this all at studentaid.gov as well we've written a couple articles on this account adjustment and IDR waiver on our website but quick hitter things that a lot of people have told me they didn't realize one is that payment history before consolidations is counting towards the forgiveness timeline I literally had a consultation yesterday where they consolidated in 2014 but they had a lot of payment history before 2014 and they were under the assumption that only payments since that consolidation were going to count and that's not not the case anymore not with this IDR waiver so that was exciting to say no we actually have another like eight years we can add so that's a big topic or sorry not topic but that's a big point with this this IDR account adjustment any prior payments doesn't matter if you were on a standard plan the extended plan any payments in the past are going to count towards the forgiveness timeline certain forbearances so 12 months or more of consecutive forbearance will count so if you were in residency for three years you used forbearance for those three years those three years normally would not count towards the forgiveness timeline but they do now with the account adjustment so extended forbearances count you have a lot of forbearance on your account from the past 36 months or more then all of that forbearance will count as well even if it's not consecutive and then let's see what am I missing Oh consolidations if you consolidate loans with different payment counts under the account adjustment the consolidation will be credited with the highest payment count that any one of those underlying loans has so if you went to school during different time periods this is significant to you because you probably have payment history on your undergrad loans for example that you could apply to your graduate loans that were borrowed later and that's I still get a lot of those consultations where we're finding extra payments by looking at how this account adjustment can be applied to your specific situation anything I missed though for quick hitter the only thing I was gonna say is deferment so that's the one other piece of the puzzle not in school deferment unfortunately but we have been seeing some people actually successfully waive in school deferment on loans that they were not taking for their current education so as an example you had some undergraduate loans you're in grad school and you automatically go into in school deferment for all of your loans well those undergrad loans you could have kept paying but you have to first go back and waive deferment which is a bit of a process but it's possible so in school deferment in general is not going to count and a lot of people are not willing to jump through the hoops to to waive their past in school deferment but it can be done but the type of deferment that does count is those deferments related to economic hardship and what the other there's also like residency deferment there's a lot of deferments and also like what the servicers were doing because this whole thing is coming about like these weird like 12 months or 36 months like why those are relevant is because the Department of Education instructed these servicers in the past that no one could have more than 12 months of consecutive forbearance and no one could have more than 36 months of cumulative forbearance ever so that's three years of forbearance but what the servicers were doing was kind of steering people towards forbearance instead of income driven plans or instead of looking at alternative options which was negatively affecting their their forgiveness timelines because originally forbearances weren't counting towards forgiveness timelines and so this the servicers were kind of taking advantage of forbearance as an easy fix to anybody's problem with payments and just putting people into forbearance instead of looking at alternative options and when they ran out of forbearance because they they hit the 36 month cap they were then using deferments and and kind of classifying them as a different payment pause so that that's why this is all coming about is because there was a lot of misuse and abuse of forbearance and deferment in the past that negatively impacted people's ability to get credit towards forgiveness so that's why they're trying to clean this up that's why those numbers kind of seem arbitrary but they're they're actually not yeah they're kind of not right another point what with forbearance too is that you can request that shorter term forbearances be counted towards forgiveness so let's say you know you were steered into forbearance because another thing that servicers used to do was when you had to update income if they were running behind or whatever the situation was they might push you into forbearance for a couple months so they could process your income recertification form which that is not a good thing you probably were okay with making those payments during that time but since they put you into forbearance those months those couple months there didn't count towards loan forgiveness and if they did that every year that's a lot of months adding up over time that aren't counting so if it wasn't 12 months of consecutive forbearance that you have on on your payment history or if it wasn't quite 36 months total of cumulative forbearance but you do have like 10 months total over the course of five years or 20 months you know randomly over the course of some time go ahead and submit a complaint to studentaid.gov there's an FSA complaint process on the website that you can submit a complaint and just explain that you would have and could have been paying payments during that time and your servicer put you into forbearance so you would like to request that those time periods count that is worth it for especially for someone who's really close to loan forgiveness if they turn around and count those months that can get you a lot closer to your to you being done with loans. A hundred percent and to your point you know you said it's 36 months in aggregate and so if you've got 24 months in aggregate like you said that off and on off and on over the course of years it's highly likely that every time your recertification came up they threw you into forbearance every time you called and asked the question they threw you into forbearance and we actually had a lawyer client reach out to us at one point because sharing is caring so if there's things that are working for you all out there please do share with us because that helps us help other people but what she did was write a letter and she marked down every single time that she was thrown in administrative forbearance and said I should not have been I would I would have been willing to continue to pay during that time and I want my payments counted so it was a pretty long drawn out process we shared that process with some other people a template that she created and it helped a lot of people but now we have this new much quicker much easier way which is filing the complaint but you first once again need to understand what's happening I don't know when I was in or out of you know payment I don't know what's going on you've got to look either at student aid gov or get that TXT file which is it's an ugly file to look at like you said we've got a pretty cool conversion thing we do it a student loan planner so we can help you with that but you first have to have a baseline of like you said what might I be missing out on in order to know whether or not you should be one of those people submitting a complaint and what you're complaining about specifically yeah and that might be a good segue into our complaint process so if you do have a complaint or your payments payment history for either PS left or the longer term forgiveness or this forbearance we're talking about when do you go to student aid gov and when do you go to your loan servicer so let's talk about that because there are some differences here and there's a kind of an order of operation so if you are thinking that there is a discrepancy or an issue with your payment count towards public service loan forgiveness you want to first I would suggest call Mahila to inquire about that time frame see if they're still maybe processing an employment certification form that could clear that up if that's not the case if they're not counting it for a specific reason maybe that reason is not accurate you can submit a reconsideration request form this is done through student aid gov this is specifically for PSLF people though at this time it's a called reconsideration request form you can probably google that in the search bar and student aid gov it's going to ask you if you have an issue with the employer that's being that they're deeming maybe not eligible or if you're having an issue with time frames not being counted correctly towards your qualifying payment count so it's important just like you said Lauren to know what time frames are inaccurate so you can specifically align them out the more specific you can be in this complaint the better the faster they could probably resolve the issue because they know what they're looking for so that's kind of the order of operation for PSLF folks start with Mahila then if we don't get anywhere with Mahila submit a reconsideration request now this is kind of future thinking but if you're someone who is having an issue with your income driven repayment count that you're gonna see in this payment tracker in 2024 there is a complaint process within the studentaid.gov website as well it is separate from that reconsideration request form because that's more specifically towards PSLF folks but it's at studentaid.gov slash feedback dash Center and that's where you can submit a complaint about just about anything so again same same rules be as specific as possible about what your complaint is and the ombudsman group will get back to you on some kind of resolution and usually the requirement before you complete this is that you communicate with your servicer first so I think that should still be the case is always try to communicate with the servicer about it see if there's a resolution if not then you can use these other complaint processes. Yeah no that's excellent information because like I said we've also been seeing with PSLF specifically you know we've done a lot of talking about the IDR and you know TXP files looking wonky in general but even in the Mahila website we've been seeing some things that don't really match up and for the most part they've been getting fixed I was actually just thinking about a client who emailed me recently and said that they got full forgiveness they were you know we had our consultation I was like no you guys should be eligible for a hundred percent forgiveness and they're like are you sure and I looked at the thread it was 62 emails that we exchanged between finishing the consultation and them actually getting forgiveness because so many things went wrong they're like we've got zero payment now we've only got three payments you said they were all going to be forgiven I want my money back like hang tight hang tight we did it right so you know you might be seeing some wonky stuff in Mahila and you know things that first thing is to reach out to them maybe over the phone reach out via the portal you know there is an option to re-upload documents that you've already submitted in the past but to Megan's point that reconsideration request form there they're creating these processes so that they can get to people faster so you don't want to be one of the people clogging up the system by just kind of like going all over the place like the reconsideration request form may be the best place to go because sometimes you re-upload something that they are that you've already submitted and now it's getting labeled duplicate and then they're having to sort through that and it you know just becomes a whole rigmarole if you're not following the various channels that they're creating to be able to get the process done efficiently yes that's a great point so duplicate forms let's talk about that next that has to do with PSLF so this is public service loan forgiveness folks so you could potentially get a employment certification form labeled as a duplicate if just as it sounds you've submitted the same one twice and so this this could be an issue because again it might delay when they're actually able to process your initial form if they're having to filter through like all the ones that you've sent them so when does it make sense to submit a new employment certification form let's kind of talk through that strategize through that right so public service loan forgiveness it has that employment certification form that verifies your employment you may have multiple forms because you've had multiple different eligible employers in the past that's okay when you complete the employment certification form online through the PSLF help tool it's going to help you list out all of your prior employers it's going to have you it used to have you print out each of those individual forms to send off to those corresponding employers and get their signatures and then you would upload that to the portal and they would review it now the process is digital we'll talk a little bit more about that here in a moment but let's say you're someone who did this already like last year you submitted all of your forms for all of your different employers you uploaded that to the mojito portal or you mailed it to the address and let's say you haven't gotten any updates right because I think you said you had a client with this situation yep zero updates she's gotten and it is multiple employers like six and I'm like are you sure where did you send it what did you you know what it happened exactly and she's like no no no I did I have all of that you know she had all the information and so yeah not it's been crickets for her and this is from back in October and we've been hearing like four or five months like first of all they're getting some sort of confirmation like processing yeah we're getting bad information but there's been communication she's got nothing so I'm like something probably didn't go right here I'm gonna say that doesn't sound right so if you've had crickets and you submitted your documentation I'd say two months or more ago then that's probably something you want to just look at a little closer because you should get some kind of correspondence so let's think about the order of operation here if this is you so if this situation sounds like what you're going through what I would do first is I would give Mohila a phone call and so if you're you know give them a call and then what you would ask is hey I just want to confirm that you've received my forms my employment certification forms and they'll ask you how you sent it what what method of and they'll they'll let you know if they have it in the queue or not and if they don't see it at all that's probably an issue maybe it got lost in the mail if you mailed it it should be there if you uploaded it to the portal that shouldn't be a question like that's a really easy way for them to track the forms but some folks I know are not at Mohila so they cannot upload their forms to Mohila's portal they have to mail it initially so if that's the case if they can't find your forms what you could do is you could mail so you could do one of two things you can either remail a copy of what you already submitted that you already got signed I would just suggest sending it certified mail to the Mohila's address and confirm the address with them on the phone and send it certified mail that could be one route or you can redo the employment certification forms through the PSLF help tool I know that might be a little annoying but you can reference all the ones that you've already done just plug and chug that information and what's cool about the new PSLF help tool or the updated help tool as you can now send a digital signature request to your employer so it sends them an email I actually acted as a spy today and sent myself an email as if I was an employer so I I put my own email in as the employer to see what would happen to see what the employer would see when they get an employment certification form sent to them for signature and it took probably I'd say like 10 minutes to get to me so it wasn't instant which not totally surprising it didn't go to spam though it went straight to my inbox and it comes from Federal Student Aid it says Federal Student Aid via DocuSign and it comes from a DocuSign.net email and it has just some verbiage that says we're requesting an electronic signature for PSLF for this person this employee is requesting your electronic signature as part of their public service loan forgiveness application prior to signing the employees for a form make sure to confirm your employer identification number and their employment period and it has an envelope access code so I've been getting a lot of emails about this lately because people have been starting to use this form and the employer hasn't been able to find this access code I think this is what they're referencing I guess it's called an envelope access code and there's like a one two three four five five digit number that they have to have to be able to access the form so it's on that initial email it's just called envelope access code but there's a button for me to click that says review document so I'm gonna click that now we're gonna go through this live the thing I love about Megan is that she is the one that's like step-by-step I'm gonna get to the very bottom of this so that we can give people the best information because sometimes we're not able to provide like you said what we can see on our end is limited in comparison to what the borrower can see but now we're able to put a really detailed email together for clients that we work with to say hey this is exactly what's gonna happen here's where here's where you might hit a bump in the road don't be confused by this and here's how you proceed forward I love that about you oh thank you a little detective so the then what it does when I click that button to review the document it says please enter the access code to view the document so this is what the employer the person you sent it to is going to see so I just copied and pasted that access code in there and then I click validate let's see what it does next so now it's taking me to a DocuSign one so the key piece of information is that the access code is in the email so reading is fundamental is what you're saying people have not been able to find it but it is in that initial email it is in that initial email yeah and it does say access code so that is the code and it's kind of small like maybe they should make it bigger or bold or something maybe that's gonna say obscure it's the same like font size is everything else but it's not in bold it's not underlined it's not highlighted nothing like that so just make sure they're looking for that and then it does pull up the full employment certification form it's already filled out it's wanting me to check the box to agree for an electronic signature disclosure and then I'm assuming I'm not going to continue through I'm not an eligible employer let me put that out there I am NOT an eligible employer Megan certifying her own employment right now she's gonna get her forgiveness today nope so that it seems like it'll just take me to a place to sign and then that'll get it submitted straight to the Department of Education and in the Department of Ed's side like your portion of studentaid.gov you can track the progress of this signature under the loan forgiveness tab click on public service loan forgiveness I think you could track it there where it just shows that it was sent you know to the employer that the email was sent to the employer that it was signed and then it was submitted so that's cool I'm glad we were able to go through that live today so people have an idea of what to expect yeah but bringing it back I think we were talking about just troubleshooting like if we needed to submit another form so I think we got that down if you're someone who hasn't heard anything about your employment certification forms that you've submitted it's probably a good idea to either resend the ones that you already completed or redo the forms with the new electronic signature process and that should get it submitted now if you're someone who is pursuing PSLF you've submitted all your forms but there's either certain time periods missing or certain employer employers missing from your your tracker I think the first order of operation there to fix any issues is to first communicate with Mokila so I'd give them a call say hey I submitted all my employment certification forms for XYZ employers the dates you know some of those dates have qualifying payments others don't can you explain to me why I'm missing some dates and that usually can be I've from what I've heard and you tell me if you've heard the same thing the PSLF folks now are doing a lot better at being able to articulate why your tracker isn't looking correct now that might not be the case for everybody so don't send me spam or email but from the clients that I've worked with I've heard that they've gotten better that may not mean they're awesome but maybe they're better so they should be able to help you identify what's going on if you need to take action or not or if it's just a waiting game because a lot of this is a waiting game for them to just update and process your prior forms which might take like we said two to four I've been saying two to six months but all the while you should be getting communication to some extent that they've received the forms that you'll get a one payment count update that might not look like it makes sense maybe the payment count looks really low but you should be getting more as time goes on anything you'd like to add to that I think you covered it he said hopefully if you're a PSLF person out there this is giving you some solace because I know people are losing sleep they said I mentioned the client that I exchanged 62 emails with you and you can imagine it's super duper stressful for people you're like there's a lot riding on this you know I've put in my time I either am eligible for full forgiveness or I think that I'm getting really close and I don't want to make 50 more payments that I didn't mean to make or 20 more payments or even five more payments that are unnecessary I just want to know like where I am so that I can I can be done with this and so you know someone if you think you have a hundred payments and you get a document that says you get but you have five like it freaks you out reasonably so so understandably yes for sure so definitely not trying to shame the folks that like have been getting panicky about their payment counts we can absolutely understand but we just want to reinforce that trust the process it will be getting a lot of communication you haven't we talked about how to fix that so hopefully this helps some folks out there with any problems with the PSLF payment count and then of course that there are legitimate problems where they're not counting periods that they should be you can go through that complaint process that we talked about with the reconsideration form reconsideration request form yeah I think that with with that you know as you mentioned the word panicky I was thinking about like kind of the last kind of point that we said we were going to talk about and it's the you know who are the other people that are really panicky right now parent plus people because they're worried about the the double consolidation loophole closing the window closing and the opportunity you know there's a lot of change happening in the student loan system right now among the federal government it seems like most of it is actually it doesn't seem most all of it there's a lot of change happening in the federal system right now as it pertains to student loans and all of it has been really really lenient or you know in favor of borrowers so you know a lot of times we get counsel consultations where people are like what if they pull the rug from underneath me what if this goes you know poorly what if you know how are they gonna screw me over is the the sentiment that's been had but everything that's happened during kovat has been really really helpful for borrowers but one thing they don't seem to be even in the least bit aware of is this double consolidation loophole that exists right now and the new ID our adjustment was something that kind of pointed it out to me they didn't they didn't say anything they addressed all these kind of other little nuances but they didn't address this particular one and so that lets me know that they still it's not on their radar yet but at any point they could figure it out and they could change rules and so you know we always put like an asterisk when we help people with the double consolidation is like hey this is important you need to do this sooner rather than later and also it could close in the midst of you doing this loophole but there's been some changes as well you know since Kovat are things that are relevant so you want to talk a little bit about that Megan and what parent plus borrowers should be thinking about yep so the process is still working there's no like word or concern at this point that the loophole will be closing soon but like you said there's a lot of changes so who knows so if you're someone who needs to be exploring this sooner the better that's all we can say there just for a peace of mind but the folks that have been going through it and if you plan on going through this in the future one note just on I guess the feedback we've been getting from people who are getting to that last step so we when we do the double consolidation it's technically three consolidations for most cases that's not always the case but for most cases we're doing three because we have to consolidate groups of parent plus loans by themselves first separately so then we can consolidate the two consolidation loans together to wipe out that parent plus loan code okay so let me just say that in layman's terms so you got six loans you get three loans together that's group a three loans together that's group B you know you consolidate group a you consolidate group B you wait and then their final consolidation is group a and group B getting consolidated together and now you have that third one and then what what our instructions have been is on that last consolidation go ahead and apply for the income driven plan that you want to go on because that's mostly why people are doing this double consolidation is they need to get on a cheaper income driven plan what we've been finding especially with mohila is the income driven application has been getting approved before the consolidation is done and so what happens is the when they process that income driven application before the consolidate the last consolidations are done they're looking at eligibility and they're saying no these consolidated parent plus loans so you only have access to that ICR plan and so that panics people we've had lots of panicked emails about mohila folks just doing this prematurely they'll get a rejection notice that says hey you're actually not eligible for pay or for repay we put you on ICR and then you know that of course is really scary because it seems like the process failed that's not actually the case it it seems like mohila is processing the income driven application before the consolidation is settled so our new instructions are that you know it probably makes sense just to apply for the standard plan again just that fixed amortized plan for the last process it also makes that last consolidation a little quicker so you don't have to gather your income information quite yet and then once that consolidation is completely done and you've been approved for the standard plan then go ahead and apply for the income driven plan that should solve most of those problems there have been some small cases where a representative is still looking at the loan file and saying no there were parent plus loans at some point this isn't eligible for ICR and it just takes a phone call or two maybe you have to get a different representative to look at the file to say no you know this is a consolidation of two consolidated loans it's not a consolidation of parent plus loans once they see that once they understand what the order of operation was for your consolidations then you will be approved for the lower income driven plan so that that's just some notes to those who are maybe going through that double consolidation process or who might be in the future some recent problems we've been running into mainly with mohila but probably be safe and do that those are those newer instructions for anybody that you're ending up with and I think this speaks to the way that the computer may be saying or looking a little bit different with all these changes that are happening that it keeps coming up over there and so this may be the first little inclination that they're getting of like oh people are doing this strategy like what is this let's look into this more so hopefully they're not you know overdoing their job to the point where they would have like whistleblower and say hey we got this consolidation thing happening over here let's stop it I don't think I don't think they would like I know that could be a concern I don't think these people over there care that much about this they're probably just like what what is this weird process that people are doing I don't get it I don't care but I don't think there's gonna be anybody over there like pounding the the the steps of the courthouse saying hey we need to change this we need to block I don't think so don't worry yeah I don't think that that would be the case either you said you were just trying to get their job done and move on and even then it's something that's really helpful and so to that point like you said the government is doing a lot of things that are super helpful so maybe you know they would point out that this is a another strategy and this is the additional steps you have to take at some point when they find out about it and or maybe they'll just get rid of all the stinky rules related to parent plus loans in the first place yeah so then there's no double consolidation necessary like that's what they really need to do so yeah man then what am I gonna be a specialist in that's my micro specialty I'm just kidding I'm sure that would be something else I get nerd out on well this has been a wonderful episode I really love podcasting with you because it's just a conversation of all the things that are coming up and I mean gosh you're so intelligent about everything that is happening in the student loan world that I think we do a good job of like breaking this down for clients helping them better understand what needs to happen and yeah these mailbags are the best ones I think I think they're really fun and you've been flattering in this whole podcast I love doing podcasts with you thanks for for joining and thanks everybody for listening in shoot us an email if you have any interesting situations happening so don't be afraid to take action have a good day everybody