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
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|Author: |Mark Stone |
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|Version: |August 19, 2016 Amended |
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|Urgency: |No |Fiscal: |Yes |
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|Consultant:|Eileen Newhall |
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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.
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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.
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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.
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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
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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.
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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.
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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
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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
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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.
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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
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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:
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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
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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
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(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
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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
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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
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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
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