Outstanding student loan debt now totals more than $1.2 trillion in the U.S., and it’s only going to grow as college tuitions continue to outpace inflation. Meanwhile, student loan servicers aren’t exactly making it easy for borrowers to pay down that debt with confusing and inconsistent policies and an apparent reluctance to work with troubled borrowers. In an effort to see if the repayment process can be made less byzantine, the Consumer Financial Protection Bureau is asking for you to share your thoughts on the state of student loan servicing.

Loan servicers are the companies that process loan payments and manage borrowers’ accounts. In most cases, it’s a third party that had nothing to do with issuing the loan but is now responsible for making sure it gets repaid.

One might assume that loan servicing is a reasonably simple process: collect payments, post them to the account, adjust the balance accordingly, work with customers who are having trouble making payments.

But many student loan borrowers have reported a wide variety of problems with their loan servicers. A 2013 report from Consumers Union included anecdotal claims of servicer incompetence, like the borrower who was being charged more than twice the interest rate he was supposed to pay.

Even borrowers who took it upon themselves to try to get ahead by paying more than they owed on their monthly invoices sometimes found that their good intentions were pointless. In 2013, the CFPB reported that servicers were inconsistent and opaque about how these additional payments were posted, especially in cases where a servicer managed multiple loans for the same borrower.

More recently, the CFPB found that some student loan servicers took part in several illegal and shady practices, including inflating borrowers’ minimum payments, making illegal collection calls and charging unlawful late fees.

Borrowers rarely have any say in the servicer handling their loan, or whether that loan gets sold to another servicer. Between 2010 and 2013, 10 million federal loan borrowers had their loan servicing company changed on them. The CFPB says it’s heard repeated complaints from borrowers who experienced servicing and billing interruptions during the transition from one servicer to another.

With eight million student loan borrowers in default, representing a total of $110 billion in debt, it would seem to be in everyone’s best interest for servicers to work with troubled borrowers to get them back on the repayment track. However, borrowers have complained that their servicers were unable or unwilling to present alternative payment options.

In order to better address these concerns the CFPB is asking the public for feedback on the following issues:

• Industry practices that create repayment challenges:
Are consumers harmed by billing error dispute processes? Are servicers applying payments in ways that maximize fees or increase the amount of interest paid? How are accounts handled when transferred from one servicer to another?

• Hurdles for distressed borrowers:
Are servicers’ policies and procedures resulting in struggling borrowers paying more fees or prolonging repayment? Are these policies and procedures driving borrowers to default on their loans?

• Economic incentives affecting the quality of service:
Most servicers receive the same fee from lenders regardless of how much the borrower pays in a month. Does this model incentivize servicers to push borrowers to only make the minimum payment? Is there a way to provide incentives for servicers to take the time to enroll borrowers in flexible repayment options or help them avoid going into default?

• Application of consumer protections in other markets:
Can consumer protections in other credit markets — like credit cars and mortgages — inform any effort to improve the quality of student loan servicing?

• Availability of information about the student loan market:
Is the general lack of transparency in the student loan market contributing to consumer harm?

The CFPB is accepting comments on these issues from the public between now and July 13, 2015.

There are multiple ways to submit your feedback. All comments must reference Docket No. CFPB-2015-0021:

• Online: http://www.regulations.gov. Follow the instructions for submitting comments.
• E-mail: Send a message to FederalRegisterComments@cfpb.gov with “Docket No. CFPB-2015-0021” in the subject line of the message.
• Mail: Send written comments to Monica Jackson, Office of the Executive Secretary, Consumer Financial Protection Bureau, 1700 G Street, NW, Washington, DC 20552.
• Hand Delivery/Courier: Written comments can also be hand-delivered to Monica Jackson, Office of the Executive Secretary, Consumer Financial Protection Bureau, 1275 First Street NE, Washington, DC 20002.

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