BILL ANALYSIS Ó SENATE COMMITTEE ON BANKING AND FINANCIAL INSTITUTIONS Senator Steven Glazer, Chair 2015 - 2016 Regular Bill No: AB 2251 Hearing Date: August 25, 2016 ----------------------------------------------------------------- |Author: |Mark Stone | |-----------+-----------------------------------------------------| |Version: |August 19, 2016 Amended | ----------------------------------------------------------------- ----------------------------------------------------------------- |Urgency: |No |Fiscal: |Yes | ----------------------------------------------------------------- ----------------------------------------------------------------- |Consultant:|Eileen Newhall | | | | ----------------------------------------------------------------- Subject: Student loan servicers: licensing and regulation: Student Loan Servicing Act CHANGES MADE TO THIS BILL AND THIS BILL ANALYSIS SINCE THIS COMMITTEE'S JUNE 29, 2016 HEARING ARE SHOWN IN BOLD TYPE. SUMMARY This bill enacts the Student Loan Servicing Act, operative July 1, 2018, which establishes a new licensing law applicable to student loan servicers, administered by the Department of Business Oversight (DBO), as specified. THIS BILL 1. Contains findings and declarations regarding the magnitude of outstanding student loan debt in the United States, the challenges that this debt places on the state's economy, the lack of consistent federal standards for student loan servicing, and the results of a September, 2015 report issued by the Consumer Financial Protection Bureau (CFPB), which documented several challenges faced by student loan borrowers when attempting to gain answers to questions from their servicers and gain assistance from their servicers in correcting payment processing errors. States the intent of the Legislature to promote meaningful access to federal affordable repayment and loan forgiveness benefits, reliable information about student educational loans and loan repayment options, and quality customer service and fair treatment. AB 2251 (Mark Stone) Page 2 of ? 2. Establishes, on and after July 1, 2018, a new division within the Financial Code, named the Student Loan Servicing Act, administered by DBO, which requires persons engaged in the business of servicing student loans in this state, as defined, to obtain licenses, as specified. a. The following entities are not subject to the provisions of the bill: state- or federally-chartered depository institutions; public postsecondary educational institutions or private nonprofit postsecondary educational institutions servicing student loans they extend to borrowers; specified nonprofit debt settlement and debt management companies; and persons who are licensed in good standing pursuant to the CFLL. b. A student loan is defined as any loan primarily for use to finance a postsecondary education and costs of attendance at a postsecondary institution and includes a loan made to refinance a student loan. A student loan does not include an extension of credit under an open-end consumer credit plan; a loan that is secured by real property or a dwelling; or an extension of credit made by a postsecondary educational institution, if one of the following apply: i. The term of the extension of credit is no longer than the borrower's education program. ii. The remaining, unpaid principal balance of the extension of credit is less than $1,500 at the time of the borrower's graduation or completion of the program. iii. The borrower fails to graduate or successfully complete his or her education program and has a balance due at the time of his or her disenrollment from the postsecondary institution. AB 2251 (Mark Stone) Page 3 of ? c. A private postsecondary educational institution that is subject to the provisions of the bill is not required to comply with the bill with respect to loans that a licensee services on behalf of that private postsecondary educational institution. d. The Commissioner of Business Oversight (commissioner) is given authority to administer the Student Loan Servicing Act and to promulgate rules and regulations and issue orders consistent with that authority; conduct investigations and examinations of applicants and licensees, as specified; grant or deny licenses based on specified criteria; impose and collect license fees and fees related to regulatory examinations, as specified; and pursue enforcement actions against licensees and unlicensed persons who are acting in a manner that requires licensure, as specified. e. Licensees are required to submit to background information checks as a condition of licensure; maintain a minimum $25,000 surety bond on file with the commissioner; maintain a minimum net worth of $250,000 at all times, as documented in audited financial statements; submit an annual financial audit prepared by an independent certified public accountant; obtain approval from the commissioner prior to opening any new branch office; file any report required by regulation or order of the commissioner, including an annual report; refrain from engaging in certain prohibited practices deemed harmful to consumers; and submit to periodic examination by the commissioner. Each licensee is also required to do all of the following: i. Provide, free of charge on its Internet Web site, information or links to information regarding repayment and loan forgiveness options that may be available to borrowers and provide this information or these links to borrowers via written correspondence or email at least once per calendar year. AB 2251 (Mark Stone) Page 4 of ? ii. Respond to a qualified written request (QWR), as defined, by acknowledging receipt of the request within five business days, and within 30 business days, provide information relating to the request and, if applicable, the action the licensee will take to correct the account or an explanation for the licensee's position that the account is correct. iii. Refrain from submitting adverse information to any consumer reporting agency for 60 days following receipt of a QWR regarding a dispute on a borrower's student loan payment. iv. Except as provided in federal law or required by a student loan agreement, inquire of each borrower how to apply an overpayment by that borrower on his or her student loan, as specified. v. Accurately report each borrower's payment performance to at least one consumer reporting agency, if the licensee is required to or voluntarily reports to a consumer reporting agency. vi. If the sale, assignment, or other transfer of the servicing of a student loan results in a change in the identity of the party to whom the borrower is required to send payments or direct any communications concerning the student loan, notify that borrower in writing at least 15 days before he or she is required to send a payment to the new servicer. This notification is required to contain specified information identifying and providing contact information for the new servicer, and AB 2251 (Mark Stone) Page 5 of ? specifying the date on which the new servicer will begin accepting payments. The servicer is also required to transfer all information regarding a borrower, a borrower's account, and a borrower's student loan to the new licensee within 45 calendar days of a sale, assignment, or transfer. vii. Retain and maintain its records of servicing a borrower's student loan for a minimum of three years after the student loan has been transferred, assigned, or paid in full, unless prohibited by federal law. f. The commissioner is granted several enforcement tools, including desist and refrain orders; censure, suspension, and bar orders; civil penalties of up to $2,500 per violation; citation and fine authority of up to $2,500 per citation; administrative penalties of up to $100 per day for failure to submit reports; license suspension and revocation, including the ability to immediately revoke a licensee's license if a licensee fails to comply with any order issued by the commissioner; and the ability to petition a court for ancillary relief on behalf of persons injured by the act or practice of a licensee. Licensees are entitled to challenge enforcement actions brought by the commissioner pursuant to procedures specified in the Administrative Procedures Act (Chapter 5 of Part 1 of Division 3 of Title 2 of the Government Code). A licensee wishing to challenge an immediate revocation must secure a court order restraining the enforcement of the commissioner's revocation order. EXISTING LAW grants DBO authority to administer the California Finance Lenders Law (CFLL; Financial Code Section 22000 et seq.) and the California Residential Mortgage Lending Act (Financial Code Section 50000 et seq.), both of which authorize licensees to service loans taken out for personal, family, or household purposes, but neither of which is specific to loans taken out to finance postsecondary educational expenses. AB 2251 (Mark Stone) Page 6 of ? COMMENTS 1. Purpose: This bill is sponsored by Attorney General Kamala Harris to provide increased accountability among student loan servicers and to improve the quality of communications between student loan borrowers and their student loan servicers. According to this bill's author, the licensure program proposed in this bill will be able to protect consumers from errors by student loan servicers and allow servicers to document their adherence to California's rules. 2. Senate Rule 29.10 Hearing: AB 2251 is back before this committee pursuant to Senate Rule 29.10(b), following Senate Floor amendments taken on August 19, 2016. An earlier version of AB 2251 was heard and passed by this committee on a 5-2 vote in June, 2015. Amendments made to the bill on August 19th add language requested by the California Association of Private Postsecondary Schools, California Coalition of Accredited Career Schools, National Foundation for Credit Counseling, and representatives of major credit reporting agencies, as well as language provided as technical assistance by the Department of Business Oversight. This Committee may take only one of the following three actions on AB 2251: a) hold the bill in committee, b) re-refer the bill to the Senate Appropriations Committee, or c) return the bill to the Senate Floor for consideration. The bill cannot be amended. 3. Background: Student loan debt is second in size only to mortgage debt, among all types of debt held by U.S. consumers. According to CFPB, more than 41 million Americans collectively owed more than $1.2 trillion in outstanding federal student loan debt as of September, 2015. In less than a decade, the volume of outstanding federal student loan debt has more than doubled, rising from $516 billion in 2007 to over $1.2 trillion in the third quarter of 2015. During the same time period, the average student loan debt burden of individual borrowers grew by nearly 60%, rising from about $18,000 in 2007 to nearly $30,000 in the third quarter of 2015. AB 2251 (Mark Stone) Page 7 of ? Measure One, a consortium of the nation's six largest private student loan lenders, estimated that total outstanding private student loan debt totaled approximately $100 billion in the third quarter of 2015 (http://www.measureone.com/reports). Approximately 92% of outstanding student loan debt is federal, while 8% is private. Types of federal student loans . According to the U.S. Department of Education (USDOE), there are four main types of postsecondary education loans under which borrowers have outstanding balances. Direct Loans are federal loans made directly to borrowers by USDOE through the William D. Ford Federal Direct Loan program. Federal Family Education Loan Program (FFELP) loans were originated by private lenders and guaranteed by the federal government. New FFELP loan originations ended in 2010, pursuant to the Student Aid and Fiscal Responsibility Act, but a significant number of FFELP loans remain outstanding. Federal Perkins Loans, which are co-funded by institutions of higher education and the federal government, are originated and administered by participating educational institutions. Private student loans are made by depository and non-depository financial institutions, states, institutions of higher education, and other entities. Who services student loans? 10 entities are currently authorized to service federal student loans, including CornerStone, FedLoan Servicing, Granite State-GSMR, Great Lakes Educational Loan Services, Inc., HESC/Edfinancial, MOHELA, Navient, Nelnet, OSLA Servicing, and VSAC Federal Loans (https://studentaid.ed.gov/sa/repay-loans/understand/servicer s). A variety of institutions service private student loans, including Citizens Bank, Discover, Navient, PNC Bank, SallieMae, Wells Fargo Bank, AES, ACS, Aspire, Nelnet, and several private educational institutions, among others. A different group of companies, including SoFi, Earnest, CommonBond, CollegeAve, LendKey, U-Fi, and others offer student loan borrowers the opportunity to refinance their outstanding student loans, which can involve additional AB 2251 (Mark Stone) Page 8 of ? servicers beyond those listed above. This bill applies its provisions to entities which service federal or private student loans, or both, "in this state." This bill's definition of "in this state" covers loans that originate in California and are directed outside California, loans that originate outside California and are directed to persons in California, and loans that originate in and are directed to persons in California. The national scope of loans covered by this bill, together with its application to both federal and private student loan servicers, means that the vast majority of student loan servicers operating in the United States will be subject to this bill's provisions. Exemptions provided for depository institutions, public and nonprofit private postsecondary educational institutions, and entities already licensed in good standing under the CFLL may reduce the number of covered entities slightly, but the majority of the entities listed immediately above will be subject to this bill. Concerns about student loan servicing. In May, 2015, the CFPB joined with USDOE and the Department of the Treasury to launch a public inquiry into federal and private student loan servicing practices. That inquiry led to publication of a September, 2015 report by the CFPB titled, "Student Loan Servicing: Analysis of Public Input and Recommendations For Reform" (http://files.consumerfinance.gov/f/201509_cfpb_student-loan- servicing-report.pdf). Analyzing over 30,000 comments, including over 8,000 comments from individual borrowers with outstanding student loans, that report identified a myriad of frustrations and challenges faced by student loan borrowers. Concerns related to five specific areas, including borrower benefits and consumer protections, servicing transfers, customer service and error resolution, payment processing, and practices that affect specific borrower segments, such as military families and older borrowers. AB 2251 includes provisions intended to begin addressing the findings of CFPB's inquiries into student loan servicing practices. New Federal Student Loan Servicing Blueprint. On July 20, 2016, Ted Mitchell, Undersecretary of the USDOE, issued a 56-page memorandum, providing a detailed blueprint for the AB 2251 (Mark Stone) Page 9 of ? future of federal student loan servicing. Within the next two to three years, the USDOE envisions that all federal direct student loans will be serviced from "a single servicing platform on which all borrower accounts held by USDOE will reside, and to which multiple customer service providers will have access...This new ecosystem will function in a manner that will clarify for borrowers that the USDOE is the servicer of their loan." Through a USDOE-branded portal, borrowers will be able to log onto a single website to get information about their federal direct student loans, make payments, apply for benefits, and manage their accounts. Although the actual servicing of loans will continue to be performed by USDOE contractors, borrowers will not know the identities of these contractors, who will operate behind the USDOE curtain. At the present time, the new portal is envisioned as covering all federal direct student loans (which currently total about $1 trillion). FFELP loans, Perkins loans, and private student loans, which together total approximately $300 billion, will not be part of the new portal initially, although some of these loans may be migrated to the portal over time. 4. Remaining Outstanding Issues: a. Interaction with new federal loan servicing platform: The 56-page memorandum referenced immediately above lays out a detailed blueprint for servicer behavior, which will be enforceable by the USDOE through its agreements with servicing contractors. Some of the provisions of this bill are inconsistent with details of the federal blueprint, which is expected to cover the $1 trillion federal direct student loan servicing portfolio. For example, this bill's requirements for the timing and content of borrower notifications of loan servicing transfers are different than those in the blueprint. This bill's requirement that servicers post information on their websites and provide borrowers with annual notifications about loan repayment and loan forgiveness options is at odds with the USDOE's vision that everything will be USDOE-branded and offered through the USDOE web portal. This bill's requirements for responding to QWRs differ significantly from the blueprint, which envisions a far more robust system for borrower/servicer communication. AB 2251 (Mark Stone) Page 10 of ? It is unclear how the provisions of this bill will work in the context of the new federal loan servicing platform. At present, this bill does not apply its provisions differently to different types of loans. Thus, although the provisions of this bill could be more readily applied to FFELP loans, Perkins loans, and private student loans, all of which will initially be serviced outside the blueprint, this bill fails to make that distinction. b. Impact on small servicers: The August 19, 2016 amendments removed the opposition of the California Association of Private Postsecondary Schools (CAPPS), which had previously opposed the bill, because of the significant financial burden the bill would have imposed on small- to medium-sized trade schools in California. However, amendments taken to address CAPPS' concerns did not change any of the bill's financial requirements; they merely ensured that CAPPS' members would no longer be subject to the bill's provisions. Small loan servicers continue to be impacted by the financial requirements of this legislation. Some of these small servicers are not-for-profit, state-run agencies created by other states to make and service loans to borrowers residing in their states or attending their state schools. Yet, these out-of-state servicers will be covered by this bill, if they service a loan held by a resident of California. To the extent the requirements of this bill prove too costly for smaller servicers, this bill could cause smaller servicers to transfer their California borrowers to larger, wealthier servicers. It is unclear whether this consolidation will work in favor of California borrowers or simply consolidate the servicing of California borrowers' loans into the hands of a few large servicers. c. Ability to alleviate licensing requirements through contracting: The August 19, 2016 amendments to this bill clarify that a private, postsecondary educational institution, which would otherwise be covered by the bill, is not required to comply with the bill, if it contracts out its servicing to an entity that is licensed pursuant to the bill. However, the bill is silent on the extent to which other entities that are subject to its provisions can avoid the requirements of the bill by AB 2251 (Mark Stone) Page 11 of ? contracting with licensed entities. By expressly identifying one group that may avoid the need to be licensed by contracting with other entities, but remaining silent on other groups, the bill is likely to create confusion over its intent in this regard. d. DBO enforcement provisions added on August 19, 2016: Two of the amendments provided as technical assistance by DBO may warrant further discussion, and one of the amendments requires a technical correction. The first amendment gives DBO the ability to immediately revoke a licensee's license, if that licensee fails to comply with an order issued by the department (page 26, lines 17 through 22). Any licensee wishing to challenge the immediate revocation of its license will be required to go to court to seek a restraining order within ten days of the effective date of the revocation order. Although DBO has the authority to suspend or revoke licenses under all of the laws it administers, immediate revocation, combined with a requirement that a licensee wishing to challenge DBO's action go to court within ten days, is quite severe. Although DBO has this authority under the CRMLA, this type of authority is not common among the laws that DBO administers. It is unclear whether this authority is necessary under the Student Loan Servicing Act. The second amendment deletes language, which authorizes sole proprietors and nonpublicly traded persons to elect to have their balance sheets kept private, when DBO releases their annual reports to the public (page 20, lines 17 through 19). The ability to keep one's balance sheet private is commonly used by licensees under other laws, such as the CFLL. It is unclear why this language was deleted. Finally, language added to the bill to provide the department with the authority to censure, suspend, or bar an individual for up to one year contains a confusing typographical error. On page 23, line 33, the word "of" should be deleted and replaced with a comma. 5. Summary of Arguments in Support: AB 2251 (Mark Stone) Page 12 of ? a. Attorney General Kamala Harris believes that many of the issues addressed by the 2012 Homeowner Bill of Rights are similar to those that have surfaced in the student loan servicing industry. "AB 2251 will protect students and provide clarity in a confusing space. By passing this legislation now, California may successfully forestall a crisis like what homeowners experienced at the height of the country's mortgage fraud epidemic. This bill would ensure that bad actors who profit through harmful or deceptive business practices are held accountable, and that students can trust in the state's regulated responsibilities for servicers. AB 2251 will provide clear guidance to borrowers and empower students to pursue their educations with confidence." b. UAW Local 2865 writes that "the bill will provide clarity and give protections to students who are navigating the confusing realm of student loan servicing. It will ensure that student loan borrowers are given reliable information, quality customer service, and meaningful access to repayment and forgiveness programs." c. Next Gen Climate Action strongly supports AB 2251, arguing that "the bill will help student loan borrowers be better informed and provide them with greater protection from bad actors in the industry." 6. Summary of Arguments in Opposition: a. The Education Finance Council (EFC) is a trade association representing nonprofit and state-agency student loan organizations. EFC's members contract as federal direct loan and FFELP servicers and serve as state-based education loan lenders and servicers. "AB 2251 potentially conflicts with numerous federal regulations and guidance that governs student loan servicing; has the potential to create confusion for California student loan borrowers, rather than protecting their interest; and would impose an onerous regulatory burden on state-based education loan lenders and servicers. Therefore, EFC strongly opposes AB 2251 in its current form." EFC is seeking an exemption from the bill for organizations AB 2251 (Mark Stone) Page 13 of ? that are already heavily regulated by the USDOE and the CFPB and that are licensed by other states which have implemented licensing requirements. However, even with such an exemption, EFC is concerned about the potential impact that AB 2251 would have on smaller nonprofit and state-based servicing entities. "These smaller entities would simply be unable to manage the financial requirements of this bill. This may cause additional organizations to terminate their servicing contracts rather than bear these exorbitant costs, resulting in a loss of some of the best servicers - those that already provide most, if not all, of the consumer protections AB 2251 seeks to provide." b. Like EFC, the National Council of Higher Education Resources (NCHER) is a national trade association representing state and nonprofit agencies that have contracts with the USDOE to service federal direct loans, and that service FFELP and private student loans. In its letter of opposition, NCHER identifies six specific elements of AB 2251 that it would like to see amended. First, echoing concerns of other opponents, NCHER observes that the bill's definition of "in this state" is extremely broad and expands the bill's scope far outside California. Many of the entities that will be covered by the bill have to comply with existing regulations, requirements, policies, and practices set by the federal government, many of which conflict with the pending legislation. Second, the bill's definition of servicing includes any interaction with a borrower to assist that borrower in avoiding default. This definition is overly broad and will likely encompass third party servicers that work with institutions of higher education to improve their default prevention efforts; guaranty agencies and their collection agency partners in the FFELP program that assist struggling borrowers in late-stage delinquency; and private collection agencies under contract with USDOE that perform pre-default activities. Third, the bill's language prohibiting the reporting of a borrower's payment dispute conflicts with policies and procedures required under the Fair Credit Reporting Act AB 2251 (Mark Stone) Page 14 of ? (FCRA). The FCRA requires student loan servicers to report the balance and status of a loan; it does not envision parsing out disputed amounts. Fourth, the bill's language on loan transfer notifications is contrary to the federal requirements contained in 34 CFR 682.208(e)(1) governing the transfers of federal student loans. These requirements will be confusing to student and parent borrowers, who will receive two notices with different information and instructions. Fifth, the legislation uses terms and definitions that are inconsistent with those used by USDOE and CFPB, and finally, the bill's use of a pro rata formula to calculate licensee assessments is overly burdensome, because it would involve annual assessment payments instead of a standard, pre-established formula. A pro rata allocation of licensee costs is also unfair, since the nation's federal student loan servicers do not directly or indirectly control the number of loans assigned to them in the state of California. c. The Student Loan Servicing Alliance (SLSA) has approximately 25 servicer members, which service about 95% of all outstanding student loans. "In its current form, AB 2251 conflicts with numerous federal regulations and guidance that govern student loan servicing....We encourage you to work closely with stakeholders to improve the legislation and assure that student loan borrowers are treated consistently with federal policy. Although the bill has a delayed implementation date in order to allow for the possibility of further legislation to fix some of the outstanding issues, once the legislation is enacted, servicers will have to begin implementing the new requirements (regardless of any intention to change them) since there is still no clarity on what the final requirements will ultimately be. And given that changes to servicing systems will be required, we need adequate lead time to program changes that are needed in order to comply with the new mandates in this bill." SLSA's letter of opposition identifies nineteen specific concerns it has with the bill's provisions. Key concerns AB 2251 (Mark Stone) Page 15 of ? include the fiscal burden of the bill on small servicers; the new structure of federal student loan servicing and the challenges of implementing this bill in the context of the new federal regime ("given this new structure, many of the proposals in the legislation simply do not make sense for the vast majority [77%] of all student loans in the nation"); the bill's overly broad definitions of "in this state" and "servicing;" the bill's problematic definition of "overpayment;" onerous and overly prescriptive licensee requirements; conflict with the FCRA; conflict with federal requirements for transferring student loans; conflict with federal recordkeeping requirements; the requirement that balance sheets included in licensees' annual reports be made public; and pro rata allocation of licensee costs. Three of the concerns raised by SLSA, which are not raised by others, and for which SLSA offers suggested amendments, include the bill's definition of and requirements for application of overpayments, requirements around QWRs, and submission of annual audits. For example, SLSA urges the author to amend his bill to delete the provision that requires servicers to honor, over the term of the loan, a borrower's direction regarding how to apply overpayments. The bill's requirement that servicers adhere in the long term to borrower-specific instructions regarding the application of borrower overpayments is not operationally feasible; servicers have no mechanism by which to program their systems to reflect long-term individual borrower preferences. The bill's definition of overpayment also requires amendment to exclude arrearages; as drafted, the bill would treat a payment made by a borrower to bring a delinquent balance current as an overpayment. Another provision of the bill requires servicers to acknowledge receipt of a QWR within five business days. However, there are many instances in which a borrower's problem can be solved quickly during a phone call. Requiring servicers to acknowledge a borrower's QWR, in writing, after the problem has been resolved, will only confuse borrowers. The Real Estate Settlement Procedures AB 2251 (Mark Stone) Page 16 of ? Act, from which this bill's author has borrowed the bill's QWR language, allows servicers to forego the 5-day acknowledgment if the action requested by the borrower is taken by the servicer within that period. SLSA suggests that a similar amendment be made to AB 2251. Furthermore, although AB 2251 does not require servicers to provide substantive responses to QWRs when a borrower sends the same request multiple times, the bill does not absolve servicers from the responsibility to acknowledge receipt of multiple, repetitive requests. SLSA suggests an amendment allowing servicers to stop sending 5-day acknowledgements after a servicer has sent the same borrower three notices informing that borrower that the servicer is not required to respond, because the borrower has repeatedly submitted the same request. Finally, SLSA observes that USDOE requires an annual financial audit, which must be filed with that department within six months of the end of a servicer's fiscal year. AB 2251 requires an annual audit to be filed with the commissioner within 105 days of the end of the servicer's fiscal year. SLSA recommends harmonizing the state requirement with the existing federal requirement. d. The Consumer Bankers Association (CBA) represents nearly 70 members, including private sector lenders that make the majority of private student loans and organizations that are experienced in working with federal student loans. CBA is "concerned about the potentially disruptive consequences that passage of AB 2251 could have on our members' ability to offer loans to students from California or students from other states who wish to study in California. AB 2251 is complex and detailed, and with its application to anyone with a California nexus, would have a national impact. Given recent and continuing major federal initiatives on student loan servicing, AB 2251 would add a complex layer of regulation that will be duplicative of and possibly contradictory to the federal initiatives." CBA is also concerned that, although the measure attempts to exempt banks from its licensing requirements, the bill does require subsidiaries of banks and other exempted AB 2251 (Mark Stone) Page 17 of ? organizations, as well as their contractors, to be licensed. The costs imposed on subsidiaries and contractors that require licensing will be passed on through CBA's member institutions, and ultimately to consumers. LIST OF REGISTERED SUPPORT/OPPOSITION Support Attorney General Kamala Harris (sponsor) California Association of Nonprofits National Association of Social Workers-California Chapter Next Gen Climate Action UAW Local 2865 Opposition Consumer Bankers Association Education Finance Council National Council of Higher Education Resources Student Loan Servicing Alliance -- END --