LEAVE A COMMENT WITH EDUCATION DEPARTMENT ON PROPOSED STUDENT LOAN REGULATIONS!

JUST FOUND OUT MYSELF!  Use the hyperlink below to leave your comments.  Here's one of mine:

 

August 30, 2018

www.regulations.gov

Re:      RIN:                                                   1840-AD26

            Federal Register Number:             2018-15823

            ID:                                                      ED-2018-OPE-0027-0001

"Student Assistance General Provisions, Federal Perkins Loan Program, Federal Family Education Loan Program, and William D. Ford Federal Direct Loan Program"

To the Department of Education:

            This is my second comment letter of today, and this concerns your proposed new language in Section 668.175.

            With respect, you have not complied with applicable law to support your proposed regulation Section 668.175(h)(1), which reads as follows:

(h) Financial protection.  In lieu of submitting a letter of credit for the amount required by the Secretary under this section, the Secretary may permit an institution to--

(1) Provide the amount required in the form of other surety or financial protection that the Secretary specifies in a notice published in the Federal Register;...

            This new language is nothing more than a "proposal to make a future proposal."  This proposed new regulation is not complete.  Instead, it depends on future unspecified action which is presently unknown to the public, to borrowers, to lenders, and perhaps even to the Department at this time.

            Nor is this anything like incorporating other rules or regulations by reference.  There is not attempt here at incorporation by reference of anything.

            These defects render the proposed new regulatory language both legally insufficient and unacceptable as a matter of public policy.

            Further, nothing is specified about the future "form of other surety or financial protection," and the terms, "surety or financial protection" are not themselves defined either.  The proposed new language of Section 688.175(h)(1) is so vague as to render it void.

            For all these reasons, whether taken separately or together, the proposed new language in Section 668.175(h)(1) should be withdrawn and not be officially published.

            Thank you for your consideration of these comments.

Sincerely Yours,

Dennis J. Wall, Esquire

Dennis J. Wall