Consumers Union appreciates the opportunity to comment regarding the Department’s Notice of Proposed Rulemaking to revise the definition of “adverse credit” for the PLUS loan program. We appreciate the Department’s efforts to balance access to funds with consumer protections. However, as we previously stated during the negotiated rulemaking sessions that developed this proposal, we believe that the proposed definition of adverse credit goes too far to loosen underwriting standards for loans that come with high interest rates and no borrowing caps.

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