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Tuesday, December 16, 2025

Pyrrhic Defeat and the Student Loan Portfolio: How a Managed Meltdown Enables Unauthorized Asset Sales

In classical history, a Pyrrhic victory refers to a win so costly that it undermines the very cause it was meant to advance. Less discussed, but increasingly relevant to modern governance, is the inverse strategy: the Pyrrhic defeat. In this model, short-term failure is tolerated—or even cultivated—because it enables outcomes that would otherwise be politically, legally, or institutionally impossible. When applied to public finance, pyrrhic defeat theory helps explain how the apparent collapse of a system can be leveraged to justify radical restructuring, privatization, or liquidation of public assets.

Nowhere is this framework more relevant than in the management of the federal student loan portfolio.

The federal student loan portfolio, totaling roughly $1.6 to $1.7 trillion, is not merely an accounting entry. It is one of the largest consumer credit systems in the world and functions simultaneously as a public policy tool, a long-term revenue stream, a data infrastructure, and a political liability. It shapes who can access higher education, how risk is distributed across generations, and how the federal government exerts leverage over the postsecondary sector. Precisely because of its scale and visibility, the portfolio is uniquely vulnerable to narrative reframing.

That vulnerability was not accidental. It was constructed over decades through a series of policy decisions that stripped borrowers of normal consumer protections while preserving the financial attractiveness of student debt as an asset. Chief among these decisions was the gradual removal of bankruptcy protections for student loans. By rendering student debt effectively nondischargeable except under the narrow and punitive “undue hardship” standard, lawmakers transformed education loans into a uniquely durable financial instrument. Unlike mortgages, credit cards, or medical debt, student loans could follow borrowers for life, enforced through wage garnishment, tax refund seizure, and Social Security offsets.

This transformation made student loans exceptionally attractive for securitization. Student Loan Asset-Backed Securities, or SLABS, flourished precisely because the underlying loans were shielded from traditional credit risk. Investors could rely not on educational outcomes or borrower prosperity, but on the legal certainty that the debt would remain collectible. Even during economic downturns, SLABS were marketed as relatively stable instruments, insulated from the discharge risks that plagued other forms of consumer credit.

Private banks once dominated this market. Sallie Mae, originally a government-sponsored enterprise, became a central player in both originating and securitizing student loans, while Navient emerged as a major servicer and asset manager. Yet as Higher Education Inquirer documented in early 2025, banks ultimately lost control of student lending. Rising defaults, public outrage, state enforcement actions, and mounting evidence of predatory practices made the sector politically radioactive. The federal government stepped in not as a reformer, but as a backstop, absorbing the portfolio and stabilizing a system private finance could no longer manage without reputational and regulatory risk.

That history reveals a recurring pattern. When student lending fails in private hands, it becomes public. When the public system is allowed to fail, it becomes ripe for re-privatization.

A portfolio does not need to collapse to be declared unmanageable. It only needs to appear dysfunctional enough to justify extraordinary intervention.

The post-pandemic repayment restart, persistent servicing failures, legal challenges to income-driven repayment plans, and widespread borrower confusion have all contributed to a growing narrative of systemic breakdown. Servicers such as Maximus, operating under the Aidvantage brand, MOHELA, and others have struggled to process payments accurately, manage forgiveness programs, and provide reliable customer service. These failures are often framed as bureaucratic incompetence rather than as predictable consequences of outsourcing public functions to private contractors whose incentives are misaligned with borrower welfare.

Navient’s exit from federal servicing did not mark a retreat from the student loan ecosystem so much as a repositioning, as it continued to benefit from private loan portfolios and legacy SLABS exposure. Sallie Mae, rebranded and fully privatized, remains deeply embedded in the private student loan market, which continues to rely on the same nondischargeability framework that props up federal lending.

Crucially, these servicing failures cannot be separated from the earlier elimination of bankruptcy as a safety valve. In normal credit markets, distress is resolved through restructuring or discharge. In student lending, distress accumulates. Borrowers remain trapped, servicers remain paid, and policymakers are confronted with a swelling mass of unresolved debt that can be labeled a crisis at any politically convenient moment.

Under pyrrhic defeat theory, such a crisis is not merely tolerated. It is useful.

Once the federal portfolio is framed as broken beyond repair, the range of acceptable solutions expands. What would be politically impossible in a stable system becomes plausible in an emergency. Asset transfers, securitization of federal loans, expansion of SLABS-like instruments backed by government guarantees, or long-term conveyance of servicing and collection rights can be presented as pragmatic fixes rather than ideological choices.

A Trump administration would be particularly well positioned to exploit this dynamic. Skeptical of debt relief, hostile to administrative governance, and ideologically aligned with privatization, such an administration could recast the portfolio as a failed public experiment inherited from predecessors. In that framing, selling or offloading the portfolio is not an abdication of responsibility but an act of fiscal discipline.

Importantly, this need not take the form of an explicit, congressionally authorized sale. Risk can be shifted through securitization. Revenue streams can be monetized. Servicing authority can be extended indefinitely to private firms. Data control can migrate outside public oversight. Over time, these steps amount to de facto privatization, even if the loans remain nominally federal. The infrastructure, incentives, and profits move outward, while the political blame remains with the state.

This is where earlier McKinsey & Company studies reenter the conversation. Long before the current turmoil, McKinsey analyses identified high servicing costs, fragmented contractor oversight, weak borrower segmentation, and low political returns on administrative complexity. While framed as efficiency critiques, these studies implicitly favored market-oriented restructuring. In a crisis environment, such recommendations become blueprints for divestment.

The danger of a pyrrhic defeat strategy is that it delivers a short-term political win at the cost of long-term public capacity. Selling or functionally privatizing the student loan portfolio may improve fiscal optics, but it permanently weakens democratic control over higher education finance. Borrowers, already stripped of bankruptcy protections, lose what remains of public accountability. Policymakers lose leverage over tuition inflation and institutional behavior. The federal government relinquishes a powerful counter-cyclical tool. What remains is a debt regime optimized for extraction, enforced by servicers, securitized for investors, and detached from educational outcomes.

The defeat is real. It is borne by students, families, and future generations. The victory belongs to those who acquire distressed public assets and those who benefit ideologically from shrinking the public sphere.

Pyrrhic defeat theory reminds us that collapse is not always accidental. In the case of the federal student loan portfolio, what appears to be dysfunction or incompetence may instead be strategic surrender: a willingness to let a public system deteriorate so that it can be sold off, securitized, or outsourced under the banner of necessity. If that happens, it will not be remembered as a policy error, but as a deliberate transfer of public wealth and power—made possible by decades of legal engineering that began when bankruptcy protection was taken away and ended with student debt transformed into a permanent financial asset.


Sources

Higher Education Inquirer. “When Banks Lost Control of Student Loan Lending.” January 2025.
https://www.highereducationinquirer.org/2025/01/when-banks-lost-control-of-student-loan.html

U.S. Department of Education, Federal Student Aid. FY 2024 Annual Agency Performance Report. January 13, 2025.

U.S. Department of Education, Federal Student Aid. Federal Student Loan Portfolio Data and Statistics, various years.

Government Accountability Office. Student Loans: Key Weaknesses in Servicing and Oversight, multiple reports.

Congressional Budget Office. The Federal Student Loan Portfolio: Budgetary Costs and Policy Options.

U.S. Congress. Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 and prior amendments affecting student loan dischargeability.

Pardo, Rafael I., and Michelle R. Lacey. “The Real Student-Loan Scandal: Undue Hardship Discharge Litigation.” American Bankruptcy Law Journal.

Financial Crisis Inquiry Commission materials on asset-backed securities and consumer credit markets.

McKinsey & Company. Student Loan Servicing, Portfolio Optimization, and Risk Management Analyses, prepared for federal agencies and financial institutions, 2010s–early 2020s.

Higher Education Inquirer archives on SLABS, servicers, privatization, deregulation, and student loan policy.

Thursday, December 4, 2025

Hyper-Deregulation and the College Meltdown

In March 2025, Studio Enterprise—the online program manager behind South University—published an article titled “A New Era for Higher Education: Embracing Deregulation Amid the DOE’s Transformation.” Written in anticipation of a shifting political landscape, the article framed coming deregulation as an “opportunity” for flexibility and innovation. Studio Enterprise CEO Bryan Newman presented the moment as a chance for institutions and their contractors to do more with fewer federal constraints, implying that regulatory retreat would improve student choice and institutional agility.

What was framed as a strategic easing of oversight has instead arrived as a form of collapse. By late 2025, the U.S. Department of Education has become, in functional terms, a zombie agency—still existing on paper, but stripped of its capacity to regulate, enforce, or even communicate. Consumer protection, accreditation monitoring, program review, financial oversight, and FOIA responses have slowed or stopped entirely. The agency is walking, but no longer awake.

This vacuum has emboldened not only online program managers like Studio Enterprise and giants like 2U, but also a wide array of entities that rely on federal inaction to profit from students. The University of Phoenix—long emblematic of regulatory cat-and-mouse games in the for-profit sector—now faces minimal scrutiny, continuing to recruit aggressively while the federal watchdog sleeps. Elite universities contracting with 2U continue to launch expensive online degrees and certificates whose marketing and outcomes would once have been examined more closely.

Student loan servicers and private lenders have also moved quickly to capitalize on the chaos. Companies like Aidvantage (Maximus), Nelnet, and MOHELA now operate in an environment where enforcement actions, compliance reviews, and borrower complaint investigations have slowed to a near standstill. Servicers once accused of steering borrowers into costly forbearances or mishandling IDR accounts now face fewer barriers and far less public oversight. The dismantling of the Department has also disrupted the small channels borrowers once had for correcting servicing errors or disputing inaccurate records.

Private lenders—including Sallie Mae, Navient, and a growing constellation of fintech-style student loan companies—have seized the opportunity to expand high-interest refinance and private loan products. Without active federal oversight, marketing claims, credit evaluation practices, and default-related consequences have become increasingly opaque. Borrowers with limited financial literacy or unstable incomes are again being targeted with products that resemble the subprime boom of the early 2010s, but with even fewer regulatory guardrails.

Hyper-deregulation has also destabilized the federal loan system itself. Processing backlogs have grown. Borrower defense and closed-school discharge petitions sit in limbo. Decisions are delayed, reversed, or ignored. Automated notices go out while human review has hollowed out entirely. Students struggling with servicer errors find there is no functioning authority to appeal to—not even the already stretched ombudsman’s office, which is now overwhelmed and under-directed.

Across the sector, the same pattern is visible: institutions and corporations functioning without meaningful oversight. OPMs determine academic structures that universities should control. Lead generators push deceptive marketing campaigns with impunity. Universities desperate for enrollment sign long-term revenue-sharing deals without public transparency. Servicers mismanage accounts and communications while borrowers bear the consequences. Private lenders accelerate their expansion into communities least able to withstand financial harm.

Students feel the effect first and most painfully. They face rising costs, misleading claims, aggressive recruitment, and a federal loan system that can no longer assure accuracy or fairness. The collapse of oversight is not theoretical. It manifests in missed payments, lost paperwork, incorrect balances, unresolved appeals, and ballooning debt. For many, there is now no reliable path to recourse.

Studio Enterprise saw deregulation coming. What it left unsaid is that removing federal guardrails does not produce innovation. It produces confusion, predation, and unequal power. Hyper-deregulation rewards those who operate in the shadows—OPMs, for-profit chains, high-fee servicers, and private lenders—while those seeking education and mobility carry the burden.

This moment is not an evolution. It is an abandonment. Higher education is drifting into an environment where profit extraction flourishes while public protection evaporates. Unless new sources of oversight emerge—federal, state, journalistic, or civic—the most vulnerable students will continue to pay the highest price for the disappearance of the referee.


Sources

Studio Enterprise, A New Era for Higher Education: Embracing Deregulation Amid the DOE’s Transformation (March 2025).
HEI archives on OPMs, for-profit colleges, and regulatory capture (2010–2025).
Public reporting and advocacy analyses on student loan servicers, including Navient, MOHELA, Nelnet, Aidvantage/Maximus, and Sallie Mae (2015–2025).
FOIA request logs, non-responses, and stalled borrower relief cases documented by HEI and partner organizations (2024–2025).
Federal higher education enforcement trends, 2023–2025.

Monday, December 1, 2025

Is the Federal Trade Commission FOIA program still in operation?

In light of recent developments at the Federal Trade Commission under the current administration — including staffing reductions and a temporary 2025 government shutdown — many observers and researchers are questioning whether the FTC’s Freedom of Information Act (FOIA) program is still functioning. The answer remains: yes — the FOIA program is still formally operational, but its capacity and responsiveness appear diminished under current conditions.

The FTC continues to administer FOIA through its Office of General Counsel (OGC), which processes all FOIA requests. As of the 2024 fiscal year, the FTC’s FOIA Unit comprised four attorneys, five government-information specialists, and one paralegal, with occasional support from contractors and other staff. In that year, the agency processed 1,919 requests (and 29 appeals), up from 1,812 in 2023. The agency’s publicly available “FOIA Handbook,” last updated in April 2025, continues to outline how requests should be submitted, what records are on the public record, and how exemptions are applied.

The FTC’s website still provides instructions for submitting a FOIA request via its online portal, email, fax, or mail. That means requests remain legally eligible — including those related to for-profit colleges, student loan servicers, institutional behavior, complaints, or decision-making memos.

However, HEI’s own experience in 2025 highlights some of the challenges with the FTC’s current FOIA responsiveness. In January 2025, we submitted a FOIA request asking for a record of complaints against the University of Phoenixbut have no record of a response. In August 2025 we did receive a substantive response related to complaints regarding a student loan company, but the number of complaints appeared lower than we expected. On November 30, 2025, we received an automated response to our FOIA request about AidVantage, a student loan servicer and subsidiary of Maximus. While we did receive a reply, it reflected a stale message stating they would respond after the government reopened — even though the government had reopened on November 13.

These examples illustrate that while FOIA is formally operational, actual responsiveness has deteriorated. For years, HEI had a good relationship with the FTC, obtaining critical information for a number of investigations in a timely manner. It remains to be seen whether that reliability can be restored.

Compounding the issue are broader staffing and operational changes at the FTC. In testimony before Congress in May 2025, FTC Chair Andrew N. Ferguson reported that the agency began FY 2025 with about 1,315 personnel but had reduced to 1,221 full-time staff, with plans to potentially reduce further to around 1,100 — the lowest level in a decade. These staffing reductions coincide with scaled-back discretionary activities, such as rulemaking, public guidance publishing, and outreach. During the October 2025 lapse in government funding, the FTC announced that FOIA requests could still be submitted but would not be processed until appropriations resumed.

For researchers, journalists, and advocates — including those pursuing records related to for-profit colleges, student loan servicers, regulatory decisions, or historical investigations — FOIA remains a legally viable tool. The path is open, though response times are slower, staff resources are constrained, and releases may be more limited, especially for sensitive or exempt material.

Sources

Congressional budget testimony on FTC staffing and budget: https://www.congress.gov/119/meeting/house/118225/witnesses/HHRG-119-AP23-Wstate-FergusonA-20250515.pdf

FTC FOIA Handbook (April 2025): https://www.ftc.gov/system/files/ftc_gov/pdf/FOIA-Handbook-April-2025.pdf

FTC 2024 Chief FOIA Officer Report (staffing, request volume): https://www.ftc.gov/system/files/ftc_gov/pdf/chief-foia-officer-report-fy2024.pdf

FTC website instructions for submitting FOIA requests: https://www.ftc.gov/foia/make-foia-request

FTC 2025 shutdown plan showing FOIA processing paused during funding lapse: https://www.ftc.gov/ftc-is-closed

Reporting on FTC removal of business-guidance blogs in 2025: https://www.wired.com/story/federal-trade-commission-removed-blogs-critical-of-ai-amazon-microsoft/

Thursday, November 13, 2025

The College Meltdown Index: Profiting from the Wreckage of American Higher Education


“Education, once defended as a public good, now functions as a vehicle for private gain.”


From Collapse to Contagion

The College Meltdown never truly ended—it evolved.

After a decade of spectacular for-profit implosions, the higher education sector has reconstituted itself around new instruments of profit: debt servicing, edtech speculation, and corporate “partnerships” that disguise privatization as innovation.

The College Meltdown Index—tracking a mix of education providers, servicers, and learning platforms—reveals a sector in quiet decay.

Legacy for-profits like National American University (NAUH) and Aspen Group (ASPU) trade at penny-stock levels, while Lincoln Educational (LINC) and Perdoceo (PRDO) stumble through cost-cutting cycles.

Even the supposed disruptors—Chegg (CHGG), Udemy (UDMY), and Coursera (COUR)—are faltering as user growth plateaus and AI reshapes their value proposition.

Meanwhile, SoFi (SOFI), Sallie Mae (SLM), and Maximus (MMS) thrive—not through learning, but through the management of debt.


The Meltdown Graveyard

Below lies a sampling of the education sector’s ghost tickers—the silent casualties of a system that turned public trust into private loss.

SymbolInstitutionStatusApprox. Closure/Delisting
CLAS.UClass TechnologiesDefunct2024
INSTInstructure (pre-acquisition)Acquired by Thoma Bravo2020
TWOUQ2U, Inc.Bankrupt2025
CPLACapella UniversityMerged with Strayer (Strategic Ed.)2018
ESI-OLDITT Technical InstituteDefunct2016
EDMCEducation Management CorporationDefunct2018
COCO-OLDCorinthian CollegesDefunct2015
APOLApollo Education Group (U. of Phoenix)Taken Private2017

Each ticker represents not only a failed business model—but a generation of indebted students.


The Phoenix That Shouldn’t Have Risen

No institution better symbolizes this moral decay than the University of Phoenix and Phoenix Education Partners (PXED).

At its height, Phoenix enrolled nearly half a million students. By 2017, following federal investigations and mass defaults, Apollo Education Group—its parent company—collapsed under scrutiny.

But rather than disappearing, Phoenix was quietly resurrected through a private equity buyout led by Apollo Global Management, Vistria Group, and Najafi Companies.

Freed from public oversight, the university continued to enroll vulnerable adult learners, harvesting federal aid while shedding accountability.

In 2023, the University of Idaho’s proposed acquisition of Phoenix provoked national outrage, forcing state officials to confront a basic question: Should a public university absorb a for-profit brand built on exploitation?

The deal collapsed—but the temptation to monetize Phoenix’s infrastructure remains. In 2025, a small portion became publicly traded.  Its call centers and online systems remain models of enrollment efficiency, designed to extract just enough engagement to secure tuition payments.


From Education to Extraction

The sector’s transformation reveals a deeper moral hazard.

If students succeed, investors profit.
If students fail, federal subsidies and servicer contracts ensure the money keeps flowing.

Executives face no downside. Shareholders are protected. The losses fall on students and taxpayers.

In this sense, the “meltdown” is not a market failure—it’s a market design.

“The winners are those who most efficiently extract value from hope.”

Public universities increasingly partner with private Online Program Managers (OPMs), leasing their brands to companies that control marketing, pricing, and student data. The once-clear line between public and for-profit education has blurred beyond recognition.


The Quiet Winners of Collapse

A few companies continue to prosper by aligning with “practical” or “mission-safe” sectors:

  • Adtalem (ATGE) in nursing and health education,

  • Grand Canyon Education (LOPE) in faith-branded online degrees,

  • Bright Horizons (BFAM) in corporate childcare and workforce training.

Yet all remain heavily dependent on public dollars and tax incentives. The state subsidizes their existence; the market collects the rewards.

Meanwhile, 2U’s bankruptcy leaves elite universities scrambling to explain how a publicly traded OPM, once championed as the future of online learning, could disintegrate overnight—taking with it a network of high-priced “nonprofit” certificate programs.


A Reckoning Deferred

The College Meltdown Index exposes a system that has internalized its own failures.
Fraud has been replaced by financial engineering, transparency by outsourcing, and accountability by spin.

The real collapse is not in the market—but in moral logic. Education, once the cornerstone of social mobility, has become a speculative instrument traded between hedge funds and holding companies.

Until policymakers—and universities themselves—confront the ethics of profit in higher education, the meltdown will persist, slowly consuming what remains of the public good.


“The real question is not whether the system will collapse, but who will rebuild it—and for whom.”


Sources:

  • Higher Education Inquirer, College Meltdown 2.0 Index (Nov. 2025)

  • SEC Filings (2010–2025)

  • U.S. Department of Education, Heightened Cash Monitoring Reports

  • An American Sickness – Elisabeth Rosenthal

  • The Goosestep – Upton Sinclair

  • Medical Apartheid – Harriet A. Washington

  • Body and Soul – Alondra Nelson

  • The Immortal Life of Henrietta Lacks – Rebecca Skloot

Tuesday, November 11, 2025

Divestment from Predatory Education Stocks: A Moral Imperative

Calls for divestment from exploitative industries have long been part of movements for social and economic justice—whether opposing apartheid, fossil fuels, or private prisons. Today, another sector demands moral scrutiny: the network of for-profit education corporations and student loan servicers that have turned higher learning into a site of mass indebtedness and despair. From predatory colleges to the companies that profit from collecting on student debt, the system functions as a pipeline of extraction. For those who believe education should serve the public good, the issue is not merely financial—it is moral.

The Human Cost of Predatory Education

For decades, for-profit college chains such as Corinthian Colleges, ITT Tech, the University of Phoenix, DeVry, and Capella targeted low-income students, veterans, single parents, and people of color with high-pressure marketing and promises of career advancement. These institutions, funded primarily through federal student aid, often charged premium tuition for substandard programs that left graduates worse off than when they began.

When Corinthian and ITT Tech collapsed, they left hundreds of thousands of students with worthless credits and mountains of debt. But the collapse did not end the exploitation—it simply shifted it. The business model has re-emerged in online form through education technology and “online program management” (OPM) firms such as 2U, Coursera, and Academic Partnerships. These firms, in partnership with elite universities like Harvard, Yale, and USC, replicate the same dynamics of inflated costs, opaque contracts, and limited accountability.

The Servicing of Debt as a Business Model

Beyond the schools themselves, student loan servicers and collectors—Maximus, Sallie Mae, and Navient among them—have built immense profits from managing and pursuing student debt. Sallie Mae, once a government-sponsored enterprise, was privatized in the 2000s and evolved into a powerful lender and loan securitizer. Navient, its spinoff, became notorious for deceptive practices and aggressive collections that trapped borrowers in cycles of delinquency.

Maximus, a major federal contractor, now services defaulted student loans on behalf of the U.S. Department of Education. These companies profit directly from the misery of borrowers—many of whom are victims of predatory schools or structural inequality. Their incentive is not to liberate students from debt, but to sustain and expand it.

The Role of Institutional Investors

The complicity of institutional investors cannot be ignored. Pension funds, endowments, and major asset managers have consistently financed both for-profit colleges and loan servicers, even after repeated scandals and lawsuits. Public sector pension funds—ironically funded by educators—have held stock in Navient, Maximus, and large for-profit college operators. Endowments that pride themselves on ethical or ESG investing have too often overlooked education profiteering.

Investment firms like BlackRock, Vanguard, and State Street collectively hold billions of dollars in these companies, stabilizing an industry that thrives on the financial vulnerability of students. To profit from predatory education is to participate, however indirectly, in the commodification of aspiration.

Divestment as a Moral and Educational Act

Divesting from predatory education companies and loan servicers is not just an act of conscience—it is an educational statement in itself. It affirms that learning should be a vehicle for liberation, not a mechanism of debt servitude. When universities, pension boards, and faith-based investors divest from corporations like Maximus, Navient, and 2U, they are reclaiming education’s moral purpose.

The divestment movement offers a broader civic lesson: that profit and progress are not synonymous, and that investment must align with justice. Faith communities, student debt activists, and labor unions have made similar stands before—against apartheid, tobacco, and fossil fuels. The same principle applies here. An enterprise that depends on deception, coercion, and financial harm has no place in a socially responsible portfolio.

A Call to Action

Transparency is essential. Pension boards, university endowments, and foundations must disclose their holdings in for-profit education and student loan servicing companies. Independent investigations should assess the human consequences of these investments, particularly their disproportionate impact on women, veterans, and people of color.

The next step is moral divestment. Educational institutions, public pension systems, and religious organizations should commit to withdrawing investments from predatory education stocks and debt servicers. Funds should be redirected to debt relief, community college programs, and initiatives that restore trust in education as a public good.

The corporate education complex—spanning recruitment, instruction, lending, and collection—has monetized both hope and hardship. The time has come to sever public and institutional complicity in this cycle. Education should empower, not impoverish. Divestment is not merely symbolic—it is a declaration of values, a demand for accountability, and a reaffirmation of education’s original promise: to serve humanity rather than exploit it.


Sources:

  • U.S. Department of Education, Borrower Defense to Repayment Reports

  • Senate HELP Committee, For Profit Higher Education: The Failure to Safeguard the Federal Investment and Ensure Student Success (2012)

  • Consumer Financial Protection Bureau (CFPB) enforcement actions against Navient and Sallie Mae

  • The Century Foundation, Online Program Managers and the Public Interest

  • Student Borrower Protection Center, Profiting from Pain: The Financialization of the Student Debt Crisis

  • Higher Education Inquirer archives

Friday, August 22, 2025

The Right-Wing Roots of EdTech

The modern EdTech industry is often portrayed as a neutral, innovative force, but its origins are deeply political. Its growth has been fueled by a fusion of neoliberal economics, right-wing techno-utopianism, patriarchy, and classism, reinforced by racialized inequality. One of the key intellectual architects of this vision was George Gilder, a conservative supply-side evangelist whose work glorified technology and markets as liberating forces. His influence helped pave the way for the “Gilder Effect”: a reshaping of education into a market where technology, finance, and ideology collide, often at the expense of marginalized students and workers.

The for-profit college boom provides the clearest demonstration of how the Gilder Effect operates. John Sperling’s University of Phoenix, later run by executives like Todd Nelson, was engineered as a credential factory, funded by federal student aid and Wall Street. Its model was then exported across the sector, including Risepoint (formerly Academic Partnerships), a company that sold universities on revenue-sharing deals for online programs. These ventures disproportionately targeted working-class women, single mothers, military veterans, and Black and Latino students. The model was not accidental—it was designed to exploit populations with the least generational wealth and the most limited alternatives. Here, patriarchy, classism, and racism intersected: students from marginalized backgrounds were marketed promises of upward mobility but instead left with debt, unstable credentials, and limited job prospects.

Clayton Christensen and Michael Horn of Harvard Business School popularized the concept of “disruption,” providing a respectable academic justification for dismantling public higher education. Their theory of disruptive innovation framed traditional universities as outdated and made way for venture-capital-backed intermediaries. Yet this rhetoric concealed a brutal truth: disruption worked not by empowering the disadvantaged but by extracting value from them, often reinforcing existing inequalities of race, gender, and class.

The rise and collapse of 2U shows how this ideology plays out. Founded in 2008, 2U promised to bring elite universities online, selling the dream of access to graduate degrees for working professionals. Its “flywheel effect” growth strategy relied on massive enrollment expansion and unsustainable spending. Despite raising billions, the company never turned a profit. Its high-profile acquisition of edX from Harvard and MIT only deepened its financial instability. When 2U filed for bankruptcy, it was not simply a corporate failure—it was a symptom of an entire system built on hype and dispossession.

2U also became notorious for its workplace practices. In 2015, it faced a pregnancy discrimination lawsuit after firing an enrollment director who disclosed her pregnancy. Women workers, especially mothers, were treated as expendable, a reflection of patriarchal corporate norms. Meanwhile, many front-line employees—disproportionately women and people of color—faced surveillance, low wages, and impossible sales quotas. Here the intersections of race, gender, and class were not incidental but central to the business model. The company extracted labor from marginalized workers while selling an educational dream to marginalized students, creating a cycle of exploitation at both ends of the pipeline.

Financialization extended these dynamics. Lenders like Sallie Mae and Navient, and servicers like Maximus, turned students into streams of revenue, with Student Loan Asset-Backed Securities (SLABS) trading debt obligations on Wall Street. Universities, including Purdue Global and University of Arizona Global, rebranded failing for-profits as “public” ventures, but their revenue-driven practices remained intact. These arrangements consistently offloaded risk onto working-class students, especially women and students of color, while enriching executives and investors.

The Gilder Effect, then, is not just about technology or efficiency. It is about reshaping higher education into a site of extraction, where the burdens of debt and labor fall hardest on those already disadvantaged by patriarchy, classism, and racism. Intersectionality reveals what the industry’s boosters obscure: EdTech has not democratized education but has deepened inequality. The failure of 2U and the persistence of predatory for-profit models are not accidents—they are the logical outcome of an ideological project rooted in conservative economics and systemic oppression.


Sources

Friday, July 25, 2025

Can Student Loan Debtors Work as Digital Nomads?

In recent years, the concept of working remotely while traveling—becoming a digital nomad—has become an aspirational lifestyle for many young professionals. The freedom to work from Bali, Buenos Aires, or Budapest with nothing more than a laptop and a Wi-Fi connection appeals to a generation burdened with economic precarity, stagnating wages, and dwindling faith in the American Dream.

But for over 40 million Americans burdened with student loan debt, the digital nomad lifestyle is not so simple. Can student loan debtors escape the geographic boundaries of the U.S. and work abroad without financial or legal risk? The answer depends on the type of loans, their repayment status, and how U.S. policy—particularly under presidential administrations—impacts enforcement and forgiveness.

The Debt No Passport Can Escape

Unlike credit card debt or even some tax liabilities, federal student loan debt follows Americans abroad. The U.S. Department of Education, through contracted servicers such as Aidvantage (a Maximus company), can still pursue debtors overseas. Wage garnishment, while difficult to enforce on foreign earnings, can be imposed if the debtor returns to the U.S. or has U.S.-based assets. More critically, failure to make payments can lead to loan acceleration, collection fees, and destruction of credit—regardless of one’s physical location.

Private student loans, meanwhile, can be even more punishing. While they don't have access to federal collection tools like tax refund garnishment, private lenders have fewer forgiveness options and are often aggressive in court.

Income-Driven Repayment and Remote Work

In theory, debtors enrolled in an income-driven repayment (IDR) plan could continue making small or even zero-dollar payments based on low or foreign-earned income. The Biden administration’s SAVE Plan is one such program, but its future is uncertain under political pressure and litigation.

However, reporting foreign income can be complex. Many digital nomads use foreign bank accounts, local clients, or under-the-table gigs, making it hard to verify income and remain compliant. The IRS, via the Foreign Account Tax Compliance Act (FATCA), already monitors foreign financial activity of U.S. citizens. Student loan servicers may increasingly cross-reference this information under future administrations eager to enforce repayment—especially if a second Trump administration pursues cuts to loan forgiveness or implements harsh penalties.

The Visa Question

Living abroad full-time usually requires a visa that allows remote work—a gray area in many countries. Some nations, like Portugal, Estonia, and Costa Rica, offer special digital nomad visas. However, these often require proof of steady income. A heavily indebted American with little in the bank and fluctuating freelance income might not qualify. And overstaying a tourist visa while evading loan collectors could lead to a new form of 21st-century statelessness: not legally grounded in any system, and hunted by both creditors and immigration authorities.

Loopholes and Limitations

Some student loan debtors have used their overseas lifestyle to delay or dodge repayments, either by avoiding wage garnishment or reporting low-to-no income. But this is a short-term tactic that can have long-term consequences. Defaulting on federal loans leads to disqualification from forgiveness programs and adds ballooning interest and penalties.

On the other hand, those determined to pursue Public Service Loan Forgiveness (PSLF) or new cancellation pathways must remain in qualifying U.S.-based work. International remote work doesn’t count, even if the employer is American or the job is virtual.

The Future of Debtors Abroad

With growing disillusionment in the U.S. labor market, housing unaffordability, and distrust in higher education, the idea of “exiting the system” is gaining appeal. Online forums like Reddit’s r/studentloandebt and r/digitalnomad are filled with testimonies of people seeking a way out—physically and financially.

But the federal student loan system was never designed with mobility in mind. Instead, it anchors borrowers to domestic obligations. Until policymakers make meaningful reforms—through widespread cancellation, interest elimination, or true debt jubilee—student loan debt will continue to act as a modern tether. For many, even paradise has strings attached.

Final Thoughts

Digital nomadism may offer a temporary reprieve from America’s financial rat race, but it is not a cure for systemic debt. For the student loan debtor, a life abroad might feel freer—but the burden of higher education’s broken promise still weighs heavily, no matter the zip code or time zone.

As the Higher Education Inquirer continues to investigate the exploitative nature of the U.S. credential economy, we invite student loan borrowers abroad or aspiring nomads to share their stories. In this new phase of global capitalism, the educated underclass is learning to move—but cannot yet escape.

Monday, June 30, 2025

Will Maximus and Its Subsidiary AidVantage See Cuts?

Maximus Inc., the parent company of federal student loan servicer Aidvantage, is facing growing financial and existential threats as the Trump administration completes a radical budget proposal that would slash Medicaid by hundreds of billions of dollars and cut the U.S. Department of Education in half. These proposed changes could gut the very federal contracts that have fueled Maximus's revenue and investor confidence over the last two decades. Once seen as a steady player in the outsourcing of public services, Maximus now stands at the edge of a political and technological cliff.

The proposed Trump budget includes a plan to eliminate the Office of Federal Student Aid and transfer the $1.6 trillion federal student loan portfolio to the Small Business Administration. This proposed restructuring would remove Aidvantage and other servicers from their current roles, replacing them with yet-unnamed alternatives. While Maximus has profited enormously from servicing loans through Aidvantage—one of the major federal loan servicers—it is unclear whether the company has any role in this new Trump-led student loan regime. The SBA, which lacks experience managing consumer lending and repayment infrastructure, could subcontract to politically favored firms or simply allow artificial intelligence to replace human collectors altogether.

This possibility is not far-fetched. A 2023 study by Yale Insights explored how AI systems are already outperforming human debt collectors in efficiency, compliance, and scalability. The report examined the growing use of bots to handle borrower communication, account resolution, and payment tracking. These developments could render Maximus’s human-heavy servicing model obsolete. If the federal government shifts toward automated collection, it could bypass Maximus entirely, either through privatized tech-driven firms or through internal platforms that require fewer labor-intensive contracts.

On the health and human services side of the business, Maximus is also exposed. The company has long served as a contractor for Medicaid programs across several states, managing call centers and eligibility support. But with Medicaid facing potentially devastating cuts in the proposed Trump budget, Maximus’s largest and most stable contracts could disappear. The company’s TES-RCM division has already shown signs of unraveling, with anonymous reports suggesting a steep drop-off in clients and the departure of long-time employees. One insider claimed, “Customers are dropping like flies as are longtime employees. Not enough people to do the little work we have.”

Remote Maximus employees are also reporting layoffs and instability, particularly in Iowa, where 34 remote workers were terminated after two decades of contract work on state Medicaid programs. Anxiety is spreading across internal forums and layoff boards, as workers fear they may soon be out of a job in a shrinking and increasingly automated industry. Posts on TheLayoff.com and in investor forums indicate growing unease about the company’s long-term viability, particularly in light of the federal budget priorities now taking shape in Washington.

While Maximus stock (MMS) continues to trade with relative strength and still appears profitable on paper, it is increasingly reliant on government spending that may no longer exist under a Trump administration intent on dismantling large parts of the federal bureaucracy. If student loan servicing is eliminated, transferred, or automated, and Medicaid contracts dry up due to funding cuts, Maximus could lose two of its biggest revenue streams in a matter of months. The company’s contract with the Department of Education, once seen as a long-term asset, may become a political liability in a system being restructured to reward loyalty and reduce regulatory oversight.

The question now is not whether Maximus will be forced to downsize—it already is—but whether it will remain a relevant player in the new federal landscape at all. As artificial intelligence, austerity, and ideological realignment converge, Maximus may be remembered less for its dominance and more for how quickly it became unnecessary.

The Higher Education Inquirer will continue tracking developments affecting federal student loan servicers, government contractors, and the broader collapse of the administrative state.

Monday, April 28, 2025

Maximus AidVantage

[Image of AidVantage operations in Greenville, Texas. Note the barbed wire fence.]

The recent decision to have the Small Business Administration (SBA) take over the federal student loan portfolio has sent shockwaves through the world of education finance. As the SBA — an agency traditionally focused on supporting small businesses — begins to manage a multi-billion dollar portfolio of student loans, borrowers, consumer protection advocates, and financial experts alike are left to question what this transition means for the future of loan servicing, borrower protections, and higher education financing.

At the heart of this shift is the role of Maximus AidVantage, one of the major student loan servicers handling federal loans. Maximus has already come under scrutiny for its inefficiency, poor customer service, and mishandling of crucial borrower programs, such as Public Service Loan Forgiveness (PSLF) and Income-Driven Repayment (IDR) plans. The company’s track record has led to widespread frustration, with many borrowers reporting significant issues, including misinformation, lost paperwork, and mistakes that have placed them at risk of financial hardship.

Yet, despite these concerns, Maximus has maintained its position at the helm of federal student loan servicing. Its CEO, Bruce Caswell, has been compensated handsomely for overseeing the company’s role in this controversial space. According to recent financial reports, Caswell’s total compensation has included a base salary of over $1.3 million, with total compensation often exceeding $8 million when accounting for bonuses, stock options, and other forms of remuneration. This high pay, especially in light of the company’s poor performance in customer service and loan servicing, raises questions about the priorities of both the company and the federal government, which continues to entrust Maximus with managing the finances of millions of borrowers.

The Shift to the SBA: A Lack of Expertise

The most immediate concern surrounding the SBA’s takeover of student loan management is its lack of expertise in this field. The SBA’s core mission has been to assist small businesses, offering loan guarantees and financial support to promote economic growth. While it is well-equipped to manage business loans, the agency has no experience dealing with the unique and complex needs of student loan borrowers. Federal student loans involve intricate repayment plans, borrower protections, and specialized programs like PSLF, all of which require a deep understanding of the educational sector and the financial struggles of students and graduates.

Transferring such an important and complex responsibility to the SBA without a clear plan for adaptation could lead to mismanagement, inefficiencies, and disruptions for millions of borrowers. The SBA simply isn’t set up to handle issues like loan forgiveness, income-driven repayment plans, and the variety of special accommodations that are necessary for student borrowers. If the SBA isn’t adequately staffed or resourced to take on these new responsibilities, students could be left in the lurch, facing delays, confusion, and even errors in their loan servicing.

A Confusing Transition for Borrowers

For those already dealing with the intricacies of federal student loans, this transition to the SBA is likely to create a significant amount of confusion. Student loan borrowers rely on clear communication, accurate account management, and timely assistance when navigating repayment plans. The Department of Education has long been the agency responsible for ensuring that these programs are managed effectively, but with the SBA taking over, borrowers may face new systems, new contacts, and, potentially, a lack of clarity about their loan status.

One of the biggest risks in this transition is the potential disruption of critical loan repayment programs, such as PSLF, which allows public service workers to have their loans forgiven after ten years of payments. These programs require careful management to ensure that borrowers meet the necessary qualifications. The SBA is not accustomed to handling such programs and may struggle to maintain the same level of efficiency and accuracy, especially if the agency does not prioritize dedicated support for student loan borrowers.

Diminished Consumer Protections

Perhaps the most concerning outcome of the SBA taking over student loans is the potential erosion of consumer protections. The Department of Education has a specific mandate to protect borrowers, which includes holding loan servicers accountable for mishandling accounts and ensuring transparency in loan servicing practices. The SBA, however, has never been tasked with such consumer-focused regulations, and its shift to managing student loans raises concerns that borrower rights might not be adequately enforced.

For example, the SBA may not have the resources or inclination to monitor loan servicers like Maximus closely, allowing them to continue engaging in deceptive practices without fear of regulatory repercussions. The agency might also be less likely to step in when borrowers face issues such as misapplied payments, incorrect information about forgiveness programs, or poorly managed accounts. With the SBA’s focus on business rather than consumer welfare, student loan borrowers may find themselves facing more hurdles without the protections that the Department of Education once provided.

The Impact on Repayment and Forgiveness Programs

Another pressing issue is the potential disruption of repayment and forgiveness programs under SBA oversight. Programs like Income-Driven Repayment (IDR), designed to help borrowers pay off their loans based on their income, require careful management and regular updates. Similarly, the Public Service Loan Forgiveness program is highly specific and requires rigorous tracking of borrowers’ payments and work history to ensure they qualify for forgiveness after ten years.

If the SBA is not adequately equipped to handle these specialized programs, borrowers might find themselves in a precarious position, especially if their loans are mismanaged or if they are denied forgiveness due to administrative errors. The confusion caused by the transition could delay or even derail borrowers’ efforts to achieve loan forgiveness, leaving them stuck with debt for longer than expected.

The Role of Maximus: Financial Incentives Amidst Failure

Amidst the uncertainty of this transition, Maximus continues to play a key role in servicing the federal student loan portfolio. Yet, despite its persistent failures in managing accounts and borrower relations, Maximus has remained highly profitable, with Bruce Caswell’s executive compensation reflecting this success in terms of revenue but not in terms of customer satisfaction.

Maximus’s reported $8 million in total compensation for Caswell, despite the company’s history of customer complaints, raises serious questions about priorities. While Maximus rakes in millions from servicing federal loans, borrowers are left to deal with the consequences of mistakes, misinformation, and poor service. In a system where the stakes are incredibly high for borrowers, this disparity between executive pay and customer service is concerning, especially in light of the SBA’s takeover, which promises more uncertainty.

Adding to the controversy, Maximus has also been involved in labor disputes with the Communications Workers of America (CWA), its workers' union. These disputes, which have centered on issues such as wages, benefits, and working conditions, further complicate the company’s already tarnished reputation. Workers have accused Maximus of engaging in unfair labor practices and failing to adequately support employees who are tasked with assisting borrowers. If these labor disputes continue to affect employee morale and productivity, it could lead to even worse service for borrowers who are already dealing with a complicated and frustrating loan servicing process. The combination of poor customer service, labor unrest, and executive compensation that seems out of sync with the company’s performance paints a troubling picture for the future of student loan management under Maximus.

The Threat of Reduced Loan Forgiveness and IDR Plans

Adding to the turmoil surrounding the future of student loans is the growing effort by the U.S. government to reduce or even eliminate key student loan forgiveness programs like Public Service Loan Forgiveness (PSLF) and Income-Driven Repayment (IDR) plans. These programs were designed to provide crucial relief for borrowers working in public service or those struggling with debt relative to their income. However, recent reports suggest that the government may look to reduce eligibility for these programs, impose stricter requirements, or completely eliminate them altogether as part of broader fiscal policy adjustments.

The removal of or reductions to these programs would leave borrowers with fewer avenues to manage their debt, potentially increasing default rates and extending the time it takes for borrowers to repay their loans. For individuals in public service jobs or those facing financial hardship, these changes would have a devastating impact on their ability to achieve financial stability and pay down their student loans. If the SBA, with its lack of focus on education finance, inherits this responsibility without reinforcing these programs, borrowers might find themselves in a far worse position than ever before.

Furthermore, this reduction in borrower protections and streamlining of repayment options may also be part of a broader strategy to push more borrowers into private loan options, which could further exacerbate financial hardship for those who are already struggling. With private loans often carrying higher interest rates, less favorable repayment terms, and fewer options for deferral or forgiveness, such a shift would mark a significant pivot towards privatization, benefiting financial institutions while leaving borrowers with even fewer protections and much higher costs.

A Plan to Push Consumers Toward Private Loans?

Many experts are beginning to question whether the government’s plans for overhauling student loan servicing are part of a larger agenda to move borrowers toward private loans. By reducing or eliminating federal loan protections, forgiveness programs, and income-driven repayment options, the government may be attempting to create a vacuum in which private lenders can step in and offer alternative (and likely more expensive) financing options.

This push toward privatization could significantly increase profits for private lenders while making it harder for borrowers to repay their loans. With private loans lacking many of the protections and flexible repayment options offered by federal loans, such a shift could result in higher default rates and greater financial instability for borrowers, particularly for those with already high debt levels.

Conclusion: A New Era of Uncertainty

The transition of student loan servicing to the Small Business Administration represents a significant shift in the federal student loan system, one that could lead to inefficiencies, confusion, and a reduction in protections for borrowers. With agencies like Maximus AidVantage continuing to profit from loan servicing despite failing borrowers, ongoing labor disputes, and a focus on executive compensation over customer service, and the SBA stepping into a complex arena with limited experience, the future of student loan servicing seems fraught with challenges.

The push to reduce or eliminate key student loan forgiveness programs like PSLF and IDR only adds to the uncertainty, leaving millions of borrowers facing a potentially more difficult future. Moreover, the possibility of moving consumers toward private loans with fewer protections and harsher terms would deepen the financial struggles of many borrowers. This move underscores the importance of effective oversight and the need for federal agencies to prioritize the well-being of borrowers over financial interests. The student loan system should be about more than just revenue generation — it should be about supporting borrowers and ensuring that they can achieve financial freedom, not be left trapped in a cycle of debt and frustration. Without proper management, this new era of student loan servicing risks deepening the crisis for millions of Americans who are already struggling to keep up with their education-related debts.

Tuesday, March 4, 2025

The Future of Federal Student Loans

The U.S. student loan system, now exceeding $1.7 trillion in debt and affecting over 40 million borrowers, is facing significant challenges. As political pressures rise, the management of student loans could be significantly altered. A combination of potential privatization, the elimination of the U.S. Department of Education (ED), and a new role for the Department of the Treasury raises critical questions about the future of the system.

U.S. Department of Education: Strained Resources and Outsourcing

The U.S. Department of Education (ED) is responsible for managing federal student loan servicing, loan forgiveness programs, and borrower defense to repayment (BDR) claims. However, ED has faced ongoing issues with understaffing and inefficiency, particularly as many functions have been outsourced to contractors. Companies like Maximus (including subsidiaries like AidVantage) manage much of the administrative burden for loan servicing. This has raised concerns about accountability and the impact on borrowers, especially those seeking loan relief.

In recent years, ED has also experienced staff reductions and funding cuts, making it difficult to process claims or maintain high-quality service. The potential for further cuts or even the elimination of the department could exacerbate these problems. If ED’s role is diminished, other entities, such as the Department of the Treasury, could assume responsibility for managing the student loan portfolio, though this would present its own set of challenges.

Potential for Privatization of the Student Loan Portfolio

One of the most discussed options for addressing the student loan crisis is the privatization of the federal student loan portfolio. Under previous administration discussions, including those during President Trump’s tenure, there were talks about selling off parts of the student loan portfolio to private companies. This would be done with the aim of reducing the federal deficit.

In 2019, McKinsey & Company was hired by the Trump administration to analyze the value of the student loan portfolio, considering factors such as default rates and economic conditions. While the report's findings were never made public, the idea of transferring the loans to private companies—such as banks or investment firms—remains a possibility.

The consequences of privatizing federal student loans could be significant. Private companies would likely focus on profitability, which could result in stricter repayment terms or less flexibility for borrowers seeking loan forgiveness or other relief options. This shift may reduce borrower protections, making it harder for students to challenge repayment terms or pursue loan discharges.

The Department of the Treasury and its Potential Role

If the U.S. Department of Education is restructured or eliminated, there is a possibility that the Department of the Treasury could step in to manage some aspects of the student loan portfolio. The Treasury is responsible for the country’s financial systems and debt management, so it could, in theory, handle the federal student loan portfolio from a financial oversight perspective.

However, while the Treasury has experience in financial management, it lacks the specialized knowledge of student loans and borrower protections that the Department of Education currently provides. For example, the Treasury would need to find ways to process complex Borrower Defense to Repayment claims, a responsibility ED currently manages. In 2023, over 750,000 Borrower Defense claims were pending, with thousands of claims related to predatory practices at for-profit colleges such as University of Phoenix, ITT Tech, and Kaplan University (now known as Purdue Global). Additionally, some of these for-profit schools were able to reorganize and continue operating under different names, further complicating the situation.

The Treasury could also contract out loan servicing, but this could increase reliance on profit-driven companies, possibly compromising the interests of borrowers in favor of financial performance.

Borrower Defense Claims and the Impact of For-Profit Schools

A large portion of the Borrower Defense to Repayment claims comes from students who attended for-profit colleges with a history of deceptive practices. These institutions, often referred to as subprime colleges, misled students about job prospects, program outcomes, and accreditation, leaving many with significant student debt but poor employment outcomes.

Data from 2023 revealed that over 750,000 Borrower Defense claims were filed with the Department of Education, many of them against for-profit institutions. The Sweet v. Cardona case showed that more than 200,000 borrowers were expected to receive debt relief after years of waiting. However, the process was slow, with an estimated 16,000 new claims being filed each month, and only 35 ED workers handling these claims. These delays, combined with the uncertainty around the future of ED, leave borrowers vulnerable to prolonged financial hardship. 

Lack of Transparency and Accountability in the System

While the U.S. Department of Education tracks Borrower Defense claims, it does not publish institutional-level data, making it difficult to identify which schools are responsible for the most fraudulent activity. 

In response to this, FOIA requests have been filed by organizations like the National Student Legal Defense Network and the Higher Education Inquirer to obtain detailed information about which institutions are disproportionately affecting borrowers. 

In one such request, the Higher Education Inquirer asked for information regarding claims filed against the University of Phoenix, a school with a significant number of Borrower Defense claims.

The lack of transparency in the system makes it harder for borrowers to make informed decisions about which institutions to attend and limits accountability for schools that have harmed students. If the Treasury or private companies take over management of the loan portfolio, these transparency issues could worsen, as private entities are less likely to prioritize public accountability.

Conclusion

The future of the U.S. student loan system is uncertain, particularly as the Department of Education faces the potential of funding cuts, staff reductions, or even complete dissolution. If ED’s role diminishes or disappears, the Department of the Treasury could take over some functions, but this would raise questions about the fairness and transparency of the system.

The possibility of privatizing the student loan portfolio also looms large, which could shift the focus away from borrower protections and toward financial gain for private companies. For-profit schools, many of which have a history of predatory practices, are responsible for a disproportionate number of Borrower Defense claims, and any move to privatize the loan portfolio could exacerbate the challenges faced by borrowers seeking relief from these institutions.

Ultimately, there is a need for greater transparency and accountability in how the student loan system operates. Whether managed by the Department of Education, the Treasury, or private companies, protecting borrowers and ensuring fairness should remain central to any future reforms. If these issues are not addressed, millions of borrowers will continue to face significant financial hardship.