BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AJR 11
                                                                  Page  1

          Date of Hearing:   May 6, 2013

                      ASSEMBLY COMMITTEE ON BANKING AND FINANCE
                               Roger Dickinson, Chair
                  AJR 11 (Wieckowski) - As Amended:  April 15, 2013
           
          SUBJECT  :   Bankruptcy

           SUMMARY  :   Urges the President and Congress of the United States  
          to support and pass legislation that would allow the discharge  
          of private student loan debt in bankruptcy.  Specifically,  this  
          bill  :  

          1)Provides for the following findings:

             a)   Existing federal law exempts from discharge in a  
               bankruptcy case filed under Chapter 7 or Chapter 13 of the  
               Bankruptcy Code specified educational loans made, or  
               secured, by a lender other than the federal government,  
               also known as private student loans, unless the debtor  
               convinces a bankruptcy court that repayment would be an  
               undue hardship on the debtor and the debtor's dependents, a  
               sometimes difficult and expensive process not required to  
               discharge other unsecured nonpriority debt; and,

             b)   Californians should have the same ability to discharge  
               their private student loan debt as they do to discharge  
               their unsecured nonpriority debt; and,

             c)   Californians who are not given relief from their burden  
               of private student loan debt, even after a successful  
               completion of a bankruptcy case, are seriously hindered  
               from establishing personal economic stability and  
               contributing to the economic growth of the state; and,

             d)   United States Senator Dick Durban and Representative  
               Steve Cohen have recently introduced the following  
               legislation in their respective congressional houses that  
               would permit private student loan debt to be discharged in  
               bankruptcy and are substantially similar to legislation  
               they each introduced in 2010 and 2011:

               i)     The Fairness for Struggling Students Act of 2013,  
                 supported by eight cosponsors at the time of this  
                 resolution.








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               ii)    The Private Student Loan Bankruptcy Fairness Act of  
                 2013, supported by 24 cosponsors at the time of this  
                 resolution; and

             e)   The inability of Californians to more easily discharge  
               private student loan debt prevents them from gaining the  
               "fresh start" that a successful bankruptcy case is intended  
               to provide

           EXISTING FEDERAL LAW  prohibits the discharge of private student  
          loan debt in bankruptcy.  (11 U.S.C. � 523(a) (8)(b)).

           FISCAL EFFECT  :   None

           COMMENTS  :   

          According to the author this resolution is necessary for the  
          following reasons:

               Student loan debt is growing at an alarming rate in the  
               United States.  At over $1 trillion, it has surpassed  
               personal credit card debt.

               Private loans now comprise about 24% of the nation's total  
               education loan volume.  These private student loans  
               generally have higher interest rates and stricter repayment  
               options than federal loans. Outstanding private student  
               loan debt exceeded $150 billion in 2012, held by more than  
               2.9 million borrowers. More than $8 billion of this debt is  
               in default, according to the Consumer Financial Protection  
               Bureau.

               The inability to discharge private student loan debt  
               through bankruptcy the same way that other private debt is  
               discharged causes debtors to postpone life-cycle events  
               such as buying a home, getting married, or starting a  
               family.   The ability to discharge private student loan  
               debt would release debtors that are unable to pay from  
               their financial obligation. 

               Not only does the inability to discharge private loan debt  
               affect the individual debtor, it negatively impacts the  
               United States and California economy?









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               Dischargeability of private student loan debt may also  
               induce private student loan lenders to improve their  
               interest rates and repayment plans to prevent student loan  
               borrowers from going bankrupt and discharging their private  
               student loan debt.

           Student Loan Debt by the Numbers.
           
          1)Of the 20 million who attend college each year, close to 12  
            million - or 60% - borrow annually to help cover costs.  
            (Source:  Chronicle of Higher Education  ).

          2)There are approximately 37 million student loan borrowers with  
            outstanding student loans today. (Source:  Federal Reserve  
            Board of New York  ).

          3)As of the first Quarter of 2012, the under 30 age group has  
            the most borrowers at 14 million, followed by 10.6 million for  
            the 30-39 group, 5.7 million in the 40-49 category, 4.6  
            million in the 50-59 age group and the over 60 category with  
            the least number of borrowers at 2.2 million for an overall  
            total of 37.1 million. (Source:  FRBNY  ).

          4)There is roughly somewhere between $902 billion and $1  
            trillion in total outstanding student loan debt in the United  
            States today. The  Federal Reserve Bank of New York reports  
            $902B  while the  Consumer Finance Protection Bureau reports  
            $1T  .

          5)Roughly $864 billion is outstanding federal student loan debt  
            while the remaining $150 billion is in private student loans  
            (Source:  Consumer Finance Protection Bureau  ). Private student  
            loans are not made or backed by the federal government.

          6)As of Quarter 1 in 2012, the average student loan balance for  
            all age groups is $24,301.  About one-quarter of borrowers owe  
            more than $28,000; 10% of borrowers owe more than $54,000; 3%  
            owe more than $100,000; and less than 1%, or 167,000 people,  
            owe more than $200,000. (Source:  FRBNY  ).

          7)Among all bachelor's degree recipients, median debt was about  
            $7,960 at public four-year institutions, $17,040 at private  
            not-for-profit four-year institutions, and $31,190 at  
            for-profit institutions. (Source:  College Board  ).









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          8)As of October 2012, the average amount of student loan debt  
            for the Class of 2011 was $26,600, a 5% increase from  
            approximately $25,350 in 2010. (Source:  The Project on Student  
            Debt  ).

          9)The majority of borrowers still paying back their loans are in  
            their 30s or older. 

          10)Of the 37 million Americans with outstanding student loan  
            debt: Almost 40% of these borrowers are under the age of 30.   
            Nearly 42% are between the ages of 30 and 50. 17% are older  
            than 50.

          11)Borrowers age 30-39 carry $307 billion in student loans,  
            followed by those under 30 at $292 billion, $154 billion in  
            the 40-49 age group, 50-59 at $106 billion and the over 60  
            category carrying $43 billion, for a total outstanding debt of  
            $902 billion.
          (Source:  FRBNY ).

          12)Of the 37 million borrowers who have outstanding student loan  
            balances, 14%, or about 5.4 million borrowers, have at least  
            one past due student loan account.  Of the $870B-$1T in  
            outstanding student loan debt, approximately $85 billion is  
            past due.
          (Source:  FRBNY  ).

          13)The official FY 2010 two-year national student loan cohort  
            default rate rose to 9.1%, up from 8.8% in FY 2009, while the  
            three-year rate declined slightly from 13.8% to 13.4%.   
            (Source:  U.S. Department of Education  ).

          14)Only about 37% of federal student loan borrowers between 2004  
            and 2009 managed to make timely payments without postponing  
            payments or becoming delinquent.

          15)For every student loan borrower who defaults, at least two  
            more borrowers become delinquent without default.  Two out of  
            five student loan borrowers - or 41%- are delinquent at some  
            point in the first five years after entering repayment.   
            (Source:  Institute for Higher Education Policy  ).

          16)As of 2012, there are now more than $8 billion in defaulted  
            private student loans, or 850,000 distinct loans in default.  
            (Source:  CFPB  ).








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          17)As of early 2012, borrowers in their 30s have a delinquency  
            rate (more than 90 days past due) of about 6%, while borrowers  
            in their 40s have a delinquency rate double that, at about  
            12%. 

          18)Borrowers in their 50s have a delinquency rate of 9.4% and  
            those over 60 have a delinquency rate of 9.5%. (Source:  
             Federal Reserve Bank of New York Consumer Credit Panel  ).

          19)From 2004 to 2009, 33% of undergraduate federal student loan  
            borrowers who left without a credential became delinquent  
            without defaulting and 26 % defaulted, vs. 21% with a  
            credential who became delinquent without defaulting and 16%  
            who defaulted.(Source:  IHEP  ). 

          20)From 2004-09, a third or less of federal student loan  
            borrowers at four-year, public or private nonprofit  
            institutions became delinquent or defaulted on their loans,  
            while nearly half or more (45% and 53%, respectively) of their  
            borrowers were making timely payments on their loans.)   
            One-quarter to one-third of borrowers at for-profit and public  
            two-year institutions were making timely payments on their  
            loans, and more than half of all borrowers in these sectors  
            were delinquent or had already defaulted.
          (Source:  IHEP  ).

           Expanding market  . 

          The yearly growth of private loans has outpaced federal loans.   
          In 2005-06, federal loan volume equaled nearly $69 billion while  
          private loan volume was a little over $16 billion.  The  
          Institute for Higher Education predicts that federal Stafford  
          loan volume will grow by 8% while private loans will grow by  
          25%.  In terms of recent (December 31, 2011) offerings, the CFPB  
          reported low-end variable rates of 2.98% to 3.55% and high end  
          rates (those paid by those with the worst credits) of 9.50% to  
          19.00%, with an average rate of 7.8%. These are initial rates in  
          a very low rate environment and could increase substantially if  
          interest rates rise generally. Fixed-rate risk-based pricing  
          ranges from 3.4% to 13.99%.  The financial institution private  
          loan market grew rapidly over the last decade and just as  
          rapidly receded. According to the College Board, the financial  
          institution market grew from less than $5 billion in 2001 to  
          over $20 billion in 2008, and then rapidly contracted to less  








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          than $6 billion in 2011.  A large portion of student loan volume  
          during the boom was funded by asset-backed securities (ABS). In  
          this respect, the private student loan market resembled the  
          subprime mortgage market. During the boom, high investor demand  
          for student loan ABS which allowed student loan ABS issuers to  
          create structures with very low collateralization ratios. As a  
          result of these factors, $100 in student loans could generate  
          immediate cash proceeds from securitization of $105 or more.  
          Generally speaking, the buyer assumed all of the risk that the  
          borrower would fail to repay the loan after such a transaction.  
          Therefore, a PSL lender had an incentive to increase loan  
          volumes made for such a sale, with less incentive to assure the  
          creditworthiness of those loans. 

          As developments in the asset backed securities market in mid to  
          late 2007 negatively impacted investor demand for student loan  
          ABS, private loan originations slowed dramatically.  

          During the lending boom, private loan lenders sought to increase  
          volume through a new
          marketing channel and processing protocol: Direct-to-Consumer  
          (DTC). DTC lending circumvented the school's financial aid  
          office, marketing instead through mass media, online  
          advertising, and direct media.  Funds were generally disbursed  
          directly to the student, instead of to the school. The school  
          did not certify the borrower's financial need, and the lender  
          instead imposed a cap of the lesser of total cost of attendance  
          or a fixed amount, such as $30,000. This new technique could  
          simultaneously increase the number of borrowers and the amount  
          each one borrowed. It also created an opportunity for the  
          student to borrow more than the actual costs of education. 

           
          Borrower challenges  .

          The private student loan market is structured in the same way as  
          the mortgage market, where loans are held by investors and  
          serviced by intermediaries, often other financial institutions.   
          Not surprising the challenges faced by student loan borrowers  
          often reflect the issue faced by mortgage borrowers.  CFPB has  
          highlighted the following borrower issues:

          1)Inability to speak with personnel empowered to negotiate a  
            repayment plan.









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          2)Inability to refinance.

          3)Inability to access repayment plans previously advertised.

          4)"Good faith" partial payments leading to default.

          5)Bankruptcy -triggered defaults.

          6)Unexpected checking account transactions.

          7)Handling of payments.

          8)Confusion when loans and servicing rights are bought and sold.

          9)Crediting of overpayments.

          10)Limited access to account information.

          11)Loss of benefits due to servicer personnel-suggested action.

          12)Debt collection practices.

           Student loans and bankruptcy.
           
          Student loans are among the few types of debts that generally  
          are not dischargeable in bankruptcy. In contrast to student  
          loans, most other debts are dischargeable in either a Chapter 7  
          liquidation process or Chapter 13 debt adjustment plan. Other  
          debts singled out as nondischargeable include child support,  
          alimony, court restitution orders, criminal fines and some  
          taxes. 

          Prior to 1976, all student loan debt was dischargeable in  
          bankruptcy. That year, Congress added an exception to the  
          bankruptcy discharge by prohibiting the discharge of education  
          loans made by the government or a non-profit college or  
          university, unless those loans had been in repayment for five  
          years. That exception was continued in the 1978 Bankruptcy Act,  
          but debtors who completed a chapter 13 plan, paying all they  
          could afford over three to five years, were not subject to the  
          five year waiting period. Since 1978, there have been three  
          significant legislative changes in the treatment of student  
          loans in bankruptcy. 

          In 1990, the five year repayment period was extended to seven  








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          years and the differential treatment of chapter 13 was  
          eliminated. In 1998, the temporal ground (the seven years) for  
          discharge was eliminated. And finally, in 2005, Congress  
          included most private student loans in the nondischargeability  
          category as part of a comprehensive rewrite of the bankruptcy  
          code.

          The only exception to the nondischargeability of student loan  
          debt is if the debtor can persuade the bankruptcy court that  
          repayment of the loan would result in "undue hardship." There is  
          no statutory definition of "undue hardship." This is a  
          court-defined term, usually satisfied only if the debtor can  
          meet the three-pronged test set forth in Brunner v. New York  
          State Higher Education Services Corp. under which the debtor  
          must demonstrate: (1) they cannot maintain a minimal standard of  
          living for themself or their dependents if forced to repay the  
          loan, (2) circumstances exist indicating this state of affairs  
          is likely to persist for a significant portion of the repayment  
          period, and (3) the debtor has made a good faith effort to repay  
          the loan. In certain courts, a somewhat more flexible "totality  
          of the circumstances" test has been applied. 

          These statutory changes to the bankruptcy discharge for student  
          loans were made despite the lack of any hard evidence that there  
          were abuses of the system. In fact, in 1977, after the original  
          bankruptcy amendments had been adopted but before they went into  
          effect, the House Judiciary 
          Committee issued a report concluding that the  
          nondischargeability provision should be repealed. 

          The House Judiciary Committee found that there was no real  
          problem and that fewer than 1% of all federally insured and  
          guaranteed educational loans were discharged in bankruptcy.  An  
          unidentified lawmaker slipped in a provision making private  
          student loans non-dischargable. There is no evidence that this  
          policy change was discussed or otherwise analyzed.

          A study in the  American Bankruptcy Law Journal  , An Empirical  
          Assessment of Student Loan Discharges and the Undue Hardship  
          Standard, by Jason Iuliano analyzed the result of bankruptcy  
          cases and the interaction of the hardship standards in Brunner.   
          That study concluded:

               For years, commentators have derided the undue hardship  
               requirement as too burdensome and attacked courts for  








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               applying the standard in an inconsistent manner. The real  
               problem, it turns out, is that debtors simply are not  
               pursuing student loan discharges. So few discharges are  
               granted, not because judges set the bar too high, but  
               rather, because so few people request relief.  This study  
               showed that only 0.1 % of student loan debtors in  
               bankruptcy file an adversary proceeding in an attempt to  
               discharge their educational debts. This statistic is  
               surprising for three main reasons.  First, many debtors who  
               do not try to discharge their loans are in dire financial  
               positions. Second, courts grant discharges to nearly forty  
               % of discharge seekers. Third, many debtors are successful  
               without the aid of an attorney.

               This study also showed that courts are not granting relief  
               in an indiscriminate manner. People who received discharges  
               differed from people who were denied discharges in three  
               respects: successful debtors (1) were more likely to have a  
               medical hardship, (2) were less likely to be employed, and  
               (3) had lower annual incomes the year before they filed  
               bankruptcy.  Rather than condemn the undue hardship  
               requirement, members of the bankruptcy community should  
               encourage debtors with legitimate need to file adversary  
               proceedings even if they cannot hire an attorney. Courts  
               are willing to grant discharges. The problem is that few  
               people are asking for them.

          Staff notes that in spite of the evidence that student loan debt  
          does get discharged in bankruptcy in some cases, the standards  
          that the debtor must meet in order to receive discharge of  
          student loan are far more onerous that the standards for other  
          types of debt.  Instead student loan debt is held on par with  
          other debts that cannot be discharged, such as taxes and tax  
          liens, alimony and child support, debts obtained through fraud,  
          false pretenses or false representation, debts for fraud while  
          you were acting in a fiduciary capacity, or for embezzlement or  
          larceny, debts for willful and malicious injury, debts for fines  
          or penalties to governmental units, debts for judgments in  
          wrongful death or personal injury lawsuits resulting from motor  
          vehicle, vessel or aircraft accidents while you were intoxicated  
          and condominium or cooperative association fees or assessments.   
          Furthermore, the fact that a debtor lacks knowledge about their  
          rights during bankruptcy that could otherwise change the outcome  
          of their cases should not prevent placing student loan debt on  
          the same level as other types of debt that is discharged.  








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           Technical amendments.
           
          1)Page 1, line 3, strike "excepts" and insert "exempts"

          2)Page 2, line 7, Strike "their."

          3)Page 2, lines 15-16 strike, "supported by eight cosponsors at  
            the time of this resolution."

          4)Page 2, line 18, strike, "supported by 24 cosponsors at the  
            time of this resolution;"

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Council on Economic Education (CCEE)
          California State Student Association (CSSA)
          Children's Advocacy Institute at the University of San Diego  
          School of Law


           Opposition 
           
          None on file.
           
          Analysis Prepared by  :    Mark Farouk / B. & F. / (916) 319-3081