What Happens If Student Loan Rules Change Suddenly?

Congress is considering legislation right now that would completely reshape the federal student loan repayment system. What if it's clear that under IBR or under RAP that you can't afford the payments no matter what? What does your future look like? Not great. You know, I mean, a lot of advocates were telling people, hey, you know, you signed up for this and you made life decisions based on the promise of having lower payments and eventual loan forgiveness. But, you know, we're changing our minds now. Hey, welcome back to this week's episode. I have attorney Adam Minsky with me. He focuses law practice on student loan law and more particularly helping student loan borrowers. He also is a columnist for Forbes and probably the most connected dude I know when it comes to understanding all of this stuff. So I wanted to bring him in here to kind of help have him set the stage for everything that's going on and talk through a lot of questions that I know you have and that I have as well. Now, Adam, I want to go ahead and dive right in. What is actually going on right now with student loan repayment? Yeah. And thanks for having me, Stanley. I mean, so there's a lot going on right now. You have legal challenges right now over the future of income-driven repayment. The SAVE plan is blocked. We have an ongoing legal challenge over the Trump administration's prior suspension of the entire IDR system. And then we also have possible rule changes coming down the pike from the Department of Education with regard to several plans. And then perhaps the biggest news is Congress is considering legislation right now that would completely reshape the federal student loan repayment system and basically impact essentially everyone who is in repayment right now on their student loans. All right. So we have SAVE plan litigation on one hand. We have servicer stuff on the other hand. Then we have like other things kind of floating out there. But then we have this really big kind of big change from Congress proposing things that overhauls potentially how we think about student loan repayment, how it will work moving forward. Talk to me more about that. I want to dive in on that part. So basically we have two different bills. We have a House version of a reconciliation bill and a Senate version. In many ways, they're very similar. There are some important differences, but for the most part, what they both do is they overhaul federal student loan repayment, in particular, income-driven repayment. What they would do is they would effectively repeal most existing income-driven plans, including for current borrowers. This would cover the SAVE plan, the Income Contingent Repayment Plan, or ICR, and pay as you earn as well. Income-based repayment might be preserved for current borrowers. Under the House version of the bill, it would only be the older, more expensive version of IBR. The House version would repeal the newer, more affordable version of IBR. The Senate version would preserve it, but both versions of the bills would do away with all the rest of the plans. They would then create a new plan called the Repayment Assistance Plan, or RAP, which would have some benefits that might be good for borrowers, but also a lot of drawbacks that could be very harmful for borrowers as well. All right. So there's a lot of alphabet soup going on in there, but I think at the core what we're saying is we've had these income-driven repayment plans, which is this category of plans based on income. They use a lot of different initialisms or acronyms. I can never tell which one it is, but they use those for income-based repayment, saving on a valuable education plan, SAVE, Income Contingent Repayment Plan, and then ICR. Now you're saying with that category of income-driven repayment plans, under the Senate and House proposals, those are both going away partially or fully? If these bills ultimately become law in their current form, that is what appears to be happening, which is a big deal for people. And what that essentially means, if we want to kind of take a step back from the alphabet soup of acronyms, I think what this really means for people on the ground is that you might be forced to change repayment plans, and that might result in your monthly payments increasing. That is, I think, sort of the big picture takeaway that I think is getting lost in the minutia of the policy details. Your payments may increase if these bills pass. All right. So on the ground, payments are going to increase for a lot of people. There may be some people who benefit from these changes. For instance, maybe Parent PLUS Loan borrowers who are already in an income-driven repayment plan, like Income Contingent Repayment. They may benefit from it, but there's also some harm there, I'm seeing, with Parent PLUS Loan borrowers specifically under these proposals? Yeah. I think overall, the net result for a lot of Parent PLUS borrowers is pretty bad. Basically, Parent PLUS loans in general already have fairly restricted access to income-driven repayment. Their only way to have payments based on their income is to consolidate their loans, and then they can enroll in a plan called ICR. The bills would eliminate ICR. They would move everyone who's in ICR into IBR, which for many borrowers will be more affordable. But for all other Parent PLUS borrowers who aren't already in that plan, they would essentially be cut off from any income-driven repayment whatsoever. They would be barred from IBR. All the other plans go away, and they would not be able to enroll in WRAP, and that means that Parent PLUS borrowers who experience a reduction in income or retire may not be able to afford their payments. All right. So let me lay this out a little bit more granularly. If you are a Parent PLUS loan borrower and you have not consolidated, under these proposals, would you have access to an income-driven repayment plan moving forward? No. All right. Whether you've consolidated or not. All right. And then if you're a Parent PLUS loan borrower who did consolidate your loans, but you're not in the income-driven repayment plan today, would you have access to an income-driven repayment plan under these proposals? You would not. All right. Now, another category. Let's say you are a Parent PLUS loan borrower who did double consolidation, and you're in the SAVE plan right now. Would you then be ported over to income-based repayment under these proposals? That is a question that we don't know the answer to at this time. The versions of the legislation from both the House and the Senate could be read in a narrow way, which would suggest that you specifically have to be in the ICR plan. And that if you're in the SAVE plan or some other plan, you're not going to get moved over to IBR. A broader interpretation could allow, perhaps, for those borrowers to be moved over. But the thing about double consolidation is it never was sort of a sure thing to begin with. And so I think that a lot of those borrowers may be in for some surprises, depending on how this all shakes out. Yeah, that was the thing, like, because I remember us talking about double consolidation probably way back, like, 2014-15, and just kind of the insights of it. But then it gained popularity through Student Loan Plan, and then it really blew up with NPR, and then Massachusetts Attorney General put out their guide to it as well. And then we get the Department of Education. I would say tacitly endorse it. I think you would say something less stronger than that, which is to say they said they were aware of it, and they're letting it slide. Would that be a fair kind of result? I characterize it as a wink and a nod. I think that they basically said, we know about this thing. We're going to shut it down in a year, which sort of was a wink and a nod to, you might be able to get in while there's still some time. But I think it was always on somewhat shaky legal footing, I think. Right. And so, if I have it correct then, if you're someone who has consolidated during double consolidation, which at the time felt like the right thing to do under the rules then, and you're in SAVE or you're in income-based repayment today, or pay as you earn, there is one reading that says, if these bills go forward, you would just be pulled over to IBR. But then there's a second reading, a more narrow reading, that says, no, no, no. If you're not in income contingent repayment specifically, then you will not be pulled over to this new plan. Do I have that correct? Yeah. And I think we just don't know the answer to that. We may not know, unfortunately. Yeah. And so, that leaves parent plus loan borrowers in this tricky situation where they may be incentivized to switch plans today in anticipation of this bill passing, but then they run the risk of A, their payments increasing, and then B, if that bill doesn't pass, they may not be able to get back into the income-based repayment plan or whatever plan they were in that's more favorable for them. That's correct. There's also, I think, a possible C as well, which is that they apply to change into ICR, but because of the ongoing processing delays associated with the IDR system, they're not able to fully switch in by the time the bill passes, and now they're out of SAVE or Pay As You Earn. They're not in ICR, and they've lost access to all income-driven repayment, period. So I think that that's also a real risk for that particular cohort of borrowers. And I know I'm spending a lot of time here, but I recognize that, at least from the way I'm seeing this, that this is one of the more vulnerable populations of a group of borrowers here. I guess, how do you even advise someone here? Or what framework are you using to talk someone through, what do I do here? My approach to advising clients is to ... I see my role as not someone who is supposed to tell people what to do, unless it's very clear that you should do something or not do something. I really view my role as to be sort of a guide and to try to help people make informed decisions. And so I just reached out to some of these exact type of clients this week, and basically gave them the lay of the land and outlined the possible consequences that you and I just discussed and said, if you want to talk it out, let me know, we'll set up a phone call, we can figure out what to do. But when there are no good options and every option carries risk, I think it really comes down to the specific type of risks that the specific borrower is willing to carry and how they order their priorities. Yeah, no, definitely. I think that's where I've landed too, is there isn't an absolute clear decision about what to do, so then we have to map out, okay, what do these different choices look like? And for those of you watching this at home, I promise you, it's really challenging because what we haven't talked yet about too is how your current income status changes things. For instance, if you're someone who's already retired on a fixed income with Social Security, there may not be a real material difference to you under which plan you're in. Potentially you may end up with a minimal payment anyways. And then if you're someone who is closer to retirement and your income is going to go off of a cliff at retirement, then also maybe this isn't that big of a deal depending on which plan you're in. Maybe you just go to ICR and it works out for you. But then there's that category of people who are early parent plus home borrowers, and I say early, they're in their 40s or their 50s and they have 20 working years left. Those are the ones I'm really concerned about because they may have high balances and a lot of working years left and a lot of living years left where they may need to purchase homes and do things. And this is going to be a huge complication for them, at least through this current administration. And that brings me to a part where this Congress are doing these things. I guess, do you have a sense of what's driving these changes? And where I'm actually getting to is what happens if the next administration comes in? We may potentially whipsaw back and have some type of level set there? We could. I mean, you just ask, what's driving this particular Congress, this particular administration? If you look at the press releases, at the public statements released by the GOP chairs of these committees that are releasing the bills or the Secretary of Education, they all reference the Biden administration. They all say, the Biden administration did this and it was wrong that they did this. And so we're trying to, we're responding to that. That's basically what they say. The Biden administration was too generous in creating the SAVE plan. So we're going to get rid of it. They were too generous with public service loan forgiveness. So we're going to try to restrict it. They seem to be reacting to the Biden administration. Yes, it's certainly possible that if we get a new Congress and a new administration in a few years, we'll see things swing the other way. It certainly makes for a lot of volatility for borrowers and makes it really difficult for people to plan their lives if things can keep swinging back and forth. But what I'm telling people is, you know, we've got to make the best decisions based on the landscape as it exists today and try to get you through the next few years. But what's happening now does not necessarily mean that this is what it's going to be like forever. Things can change. And if that happens, we'll reevaluate your options in light of those changes. But we've got to get you through the next few years. Yeah. And that part is key. The rest of our debt in our life, I don't imagine we spend much time thinking about mortgage, car note, credit cards. We just pay them on as they come up. But student loans, they don't really come with a set it and forget it option unless you're someone who is on truly a I am paying it off strategy and I am making these fixed payments over time to pay down that balance. But for the vast majority of folk who are on an income type driven repayment plan, part of the deal you're cutting is you are ceding control to the Department of Education and the government whims on how these programs will execute. Now, I guess there is a thing where you say this was a lot more stable environment for like basically 30 years where we knew what the repayment plans are. And now it feels like we are kind of just shaking things up in a way that no one really anticipated or maybe there's someone has, but I didn't really see that. Did you did you have a sense that this was coming? I mean, things have been pretty volatile for several years, even under the Biden administration, between the COVID pauses and the new waiver programs and the new repayment plan options. And I think for several successive administrations, Bush, Obama, Biden, there have been some changes, but usually those changes have been additive. We're giving you a new option where there's a new feature or a new benefit or there's a change, but it's only going to impact people in the future. It's not going to impact anyone now. I think what's different about the era we're in today is that really for the first time, we're seeing benefits and programs and plans be taken away from people. We're telling people, hey, you signed up for this and you made life decisions based on the promise of having lower payments and eventual loan forgiveness. But we're changing our minds now. We as in the U.S. government. And I think that is what makes this era different. I was surprised by both the House and the Senate bills and that they didn't preserve all of the existing repayment options except for SAVE. I expected SAVE to be struck down or repealed one way or another earlier this year. I was surprised that the bills went so far as to take away ICR and Pay As You Earn and the newer version of IBR for current borrowers and for payment. That was surprising to me. I want to ask you about why do you think SAVE had no shot? But I think that's a very obvious question. I thought SAVE had a shot. I think that the reason as a practical matter I think SAVE is doomed now is just because the realities of the situation on the ground. The language and the court's order and that plus the makeup of Congress right now and the current administration. I think that there's no way SAVE survives. I think that if things had been different politically, notwithstanding the Eighth Circuit's ruling, we might see a world in which SAVE survives. But there's no one to save SAVE is what I would say. Right. So we have the courts already striking down. Then we have a Department of Education that has shown no inclination of wanting to preserve that plan, not to use SAVE to save SAVE there. And then we have Congress very narrowly is looking to eliminate repayment plans that have existed for 30 years in some cases. And I guess there is a small contingent of people that say, hey, I cut this deal with the government. They're changing the terms on me. Don't I have some type of contractual right to these or some type of constitutional rights like a property interest here? If someone asked that question, what would you say to those? It's complicated. So I mean, contractual, constitutional, very different things. In terms of contractual, the reality is most or all federal student loan promissory notes, yeah, they do contain provisions describing these programs, but they also contain a provision that says that these programs are based on the Higher Education Act. And if provisions of the Higher Education Act are changed by Congress, it could change some of the terms and conditions of the note. So I don't know that a contractual argument would be enough to have a viable legal claim. But it's very possible that if Congress does go forward with these changes, that there might be legal challenges under other causes of action, including potentially some constitutional claims on the basis that people were given a benefit, they were given a promise, they signed up for it, and now that's being taken away. I'm not a constitutional scholar, so it wouldn't be me bringing those types of suits. But I'm hoping someone will, and I'm hoping that there is some sort of viable claim. It's possible that there might be. Yeah. The only thing I know about constitutional law is that I got a B plus in it in law school, and Erwin Cherminowski's, I always say his last name, book saved me on trying to understand con law. All right. So there is this thing that may be coming, and it looks like it will be coming through this Reconciliation Act, unless it's killed probably by some other reason, because it appears that both the House and the Senate are aligned, for the most part, broad strokes on what to do with student loan repayment. But there's a chance it goes away because of some other thing. Yeah, I think that's accurate. I was pretty struck by how similar the House and the Senate versions of the bill were with respect to student loan issues. There are some changes, some differences, but they're relatively small, and most things are the same. I think that if it doesn't go through, it'll be because of some debate about Medicaid or about the state and local tax issue that is causing a wedge. They have very narrow majorities, especially in the House, and so they really got to get everyone on the Republican side on board for the bill to pass. That might be difficult, but it's definitely not impossible. And so I think there's a real possibility that this passes. And then what are you kind of anticipating timeline-wise for passage and becoming law? I mean, there's apparently a goal of getting this passed to the Senate in early July. Is that possible? Yeah, it is. But then it has to go back to the House, where they have to approve the changes that the Senate made or reject those changes. Passing the Senate is the next step. That could happen in a few weeks, but I think if there are some significant differences in other aspects of the bill compared to the House version, you could see a prolonged fight over that. But if I were a betting person, I would bet on this being signed into law before the end of the year. I wouldn't necessarily bet a lot of money, but that would be my guess. It may not be final in a couple of months, but I think it will likely be final if it passes within the next five months or so. All right. So you're kind of thinking, at least today, is that this is not something that's happening tomorrow, that it's at least several weeks out, if not a handful of months or more before it actually becomes law. Obviously, we don't know for sure, but that's kind of just your best guess there. Let's say it does pass in the way it looks today. What will my repayment options look like as a general borrower without Parent PLUS loans? Let's imagine I owe $100,000 and I have a family size of two. What does my repayment options look like moving forward? What am I choosing between? Well, if you're looking to pay based on your income, your choices will essentially be either income-based repayment, IBR, or this new WRAP plan. For those who were already in the older version of IBR, there may be no change, but for people who were in Save or Pay As You Earn, you might see an increase in your payments if you're moved over to the IBR plan. Borrowers can opt into this new WRAP plan, which depending on where you are in the income spectrum, I think for most borrowers will probably have a payment somewhere between what they would have been under Save versus what they would be under IBR. So, a little better than IBR, but not quite as good as what you might have had if Save were allowed to exist. But WRAP also has a 30-year term rather than 20 or 25 years for the other IBR plans, and if you opt into WRAP, you're locked in. You can't change plans again after that. So, I think it's really going to be a tough choice for people if they're going to have difficulty affording the IBR payments. Do you take the risk of switching into WRAP where you might be stuck in WRAP for 30 years if you do that? Yeah, that's a challenging thing. And I do want to get back to the payment, but I do want to kind of hone in on this extra five years of forgiveness timeline and just kind of break down for me what are the current forgiveness timelines a borrower could have and then how much of a difference does this extra five years make here? So, currently, when can I have my loans forgiven? At what intervals? Yeah, so it's either 20 or 25 years depending on the plan. So, for Pay As You Earn and new IBR, it's the 20-year term. For old IBR, it's 25 years. For ICR, it's 25 years. For SAVE, it's kind of all over the place depending on when you took out your loans and some other details. But really, it's 20 or 25 years. And for the most affordable plans, it's 20. WRAP would have a 30-year term. Now, payments made under the other plans would still count under WRAP, so you wouldn't be starting at zero. But paying an extra five or 10 years could be pretty expensive. You know, if you have, say, a $300 payment and you're paying for an extra five years, that would be $18,000 in additional cost to switch over to WRAP. If you're increasing the term by 10 years, we're talking about $36,000, and that assumes your payment is around $300 a month. Obviously, that's just one example. But that has really meaningful cost for people if you're going to be tacking on an additional five to 10 years in repayment. Now, so that's one of the big kind of headline drawbacks of this WRAP plan is that it tacks on another five years. Or 10. Or 10 years. Yeah, or 10 years. And to be fair, from the way I look at it, if you think about student loan forgiveness programs globally in other countries that have them, 30 years is not unheard of. England has a 30-year timeline. I think Australia has something similar as well. It's not without consideration, but it is a really long time to be strapped to a debt. But also, the government is giving this program that says, hey, we'll give you the money you need for school, but we expect to recoup those funds, and we'd like to recoup them during your higher years of earning, potentially, down the road, which is one way to look at this and say this is fair. But that is a con. I guess, what are some of the benefits of WRAP, though? I don't think it's all bad for borrowers. It's not all bad. WRAP does have some features that I think some borrowers will like. So one of them is an interest subsidy that's similar to what the SAVE plan had. Basically, what the SAVE plan did is it stopped any future balance growth associated with interest accrual if your payments are too low. So in other words, if your payments under the plan aren't high enough to cover the amount of interest that accrues, they'll waive the difference to prevent your balance from growing on a runaway basis, which is what a lot of borrowers have experienced under these plans historically. So the WRAP plan would have that feature. So your balance would not increase if you're not paying enough to cover the interest because your income is too low. Another benefit is there would be like a principal match, essentially. So if you're underwater, currently all your payments go to interest, so you're not bringing down the balance, whereas under WRAP, at least a small portion of your payment could go to principal if you're underwater on your payments. And so you would help you bring down the balance. And I think that's a legitimately good feature of the plan that I think a lot of people will like. Whether that's worth the trade-off of the additional five or 10 years of repayment, I don't know. Right. Yeah, I guess a little bit more granular here. Do you have a sense or understanding or is it clear yet how they are going to count family size under the WRAP plan versus how it's counted today? My understanding is it's going to be much different than under the other plans. The way it works right now is all of the plans have an income exemption based on a percentage of the federal poverty limit based on the borrower's family size. To put it in a more straightforward way, a certain amount of income isn't counted under the existing plans, and that initial exemption is larger for larger family sizes. So the bigger your family size, the bigger amount of income is exempted. The WRAP plan is basically completely different from that. There is no income exemption at all. And so, in fact, this would hurt the lowest income borrowers the most because while you can have a $0 payment under all the existing plans, you can't have that under WRAP. You would have a minimum payment due of $10, and it could be more than that if you're earning even a minimal income. But you would get, I think it's like a $50 credit essentially, so to speak, based on the number of children that you have. So you would get a reduction in your payment per dependent is how I understand it. So it just is a much different way of factoring in family size in the current plans. I was honing in on that part because I think about my clients who have their parents staying with them, and they're not able to claim them as a dependent on their tax return, but they are supporting this person more than half the time living with them. And the way I read this WRAP plan, there's not a provision to include that person in your family size. But again, this is so dense and challenging to read that I worry that I may be missing something in how they're defining family size under WRAP. Do I have that correct that they're no longer counting adults that live with you more than half the time? I think so. To be candid, I haven't read that part of the bill super closely recently, so I'd have to double check that. But that's my recollection. I think it's focused on children rather than, more broadly speaking, people who live with you who receive at least half their support from you, which is how it's currently held. So that potentially could make WRAP less favorable for those people who are, say, not married and their partner lives with them and they take care of that partner more than half the time or that their parents live with them or whatever. This kind of very dynamic way that families exist and support systems exist as an ecosystem but aren't properly reflected on a tax return because that's a different way of defining family size than what we have historically had for student loan purposes. And you also mentioned that there's really no concept of discretionary income anymore moving forward under WRAP either. And one of the things I think Travis Hornsby from Student Loan Planner pointed out, or maybe it was Jason Dallal from Urban Institute, but there's really no COLA adjustment either moving forward. Like with these, it's just a hard line, 1% to 10% based on your income, which could mean these plans actually get more expensive over time. Yeah, basically. I think that's, you know, so it's a weird formula. So all the current plans use a flat formula, but this basically uses a progressive formula. So basically a larger percentage of your income is counted as your income increases. The problem is with inflation and rising wages, more people are going to fall into the higher percentage brackets of the repayment plan as time goes on. And that basically could mean without any associated adjustments, it means that at some point everyone is just going to be in the higher or the highest percentage of their income being counted because there's no cost of living adjustment to that formula. Right. So there's a world exists where WRAP looks good for you today. And then down the road as your wages continue to increase, but they're also your cost of everything is increasing as well, that a greater portion of your money is now going to student loans potentially. And you are actually doing way worse under WRAP than you would have been under IBR. It's possible. It's definitely possible. And with the provision that does not allow you to switch plans out of WRAP once you're locked in, you may be signing yourself up for a financially ruinous situation possibly. Possibly. And especially when you tack in that additional five to 10 years of repayment, like you said during peak earning years, that it all fits together. Right. And so it could be a problem. All right. So I want to bring this home now and I guess really hone in on those people who, because we can't say what to do because it's all so just laying out framework. But what if it's clear that under IBR or under WRAP that you can't afford the payments no matter what? What does your future look like? Not great. I mean, a lot of advocacy groups and frankly myself are concerned that there's going to be a spike in defaults, that people are going to have no choice but to go into default and that can have pretty disastrous consequences. I mean, the reality is we're going to have to see how this shakes out, when this shakes out. For some people, you might have no choice but to go into some sort of deferment or forbearance to keep the loans in good standing, buy yourself some time while we look into other options. Some people might want to look into bankruptcy. There's a misconception that I think bankruptcy is impossible or you can't discharge your student loans in bankruptcy. It's more complicated than that. It is possible. It's just a process. But in the course of the bankruptcy, some people, if you can't get a discharge, can sometimes get deals made. But I expect that we might see more bankruptcy filings in the coming years as well if people really don't have any other option other than defaulting for dealing with their debt. No, you don't practice bankruptcy like that, so I'll carry the load here. What you may see is that if people do go into bankruptcy, you're probably going to see a spike in Chapter 13 bankruptcy filings because you will be able to pause your payments on a lot of things and kind of set up a plan with the bankruptcy court to pay something back. And then there's provision inside of Chapter 13 that says the payments you make towards that would count towards income-driven repayment. However, I don't know how this current administration is going to process that particular set of rules that allow for you to get proper credit, no matter what that payment is, towards income-driven repayment forgiveness. Then there's always the adversary proceeding process, which is a little bit trickier even though it is easier potentially to get some discharges or negotiate some deals. But for those people who are newer borrowers, you may not have that same benefit. And so that may lead you to where after you run out of forbearances, and let's say this extends into a new administration, no change comes, that maybe defaulting is your only option. What does default look like consequence-wise? I just want to make sure we spell those out for people. Yeah, so defaulting on federal student loans means you've fallen more than 270 days behind on your payments. It will trigger a whole bunch of consequences, including some credit damage, could be pretty significant. You might be placed into a forced collection situation where you could get your wages garnished, your tax refunds seized. They could offset a portion of Social Security, although they currently have paused that for the time being. They could sue you to go after other assets. It's rare, but it does happen. You might be denied new federal aid. The credit damage might make it difficult for you to be able to get an apartment or a car loan or a mortgage. There are ways out of default. That's the good news, and you could get back into good standing again on federal student loans, but defaulting can be pretty serious for people. All right, so if you default on your loans, you're looking at potentially wage garnishment, tax refund offset, normally Social Security offset as well, but that is temporarily paused, and all three of those things can happen at the same time, correct? They could, and they can happen administratively. What that means is the Department of Ed doesn't need to take you to court to do that. They can do that without stepping foot in a courtroom. Right. And another risk is that you could be sued. However, that's pretty rare today. It was a bit more popular about a decade or so ago, even more than that, I guess, like 2004, 5, 6, 7. Is that the time frame you remember? I mean, I wasn't doing this work back then, but I don't think it's ever been the government's most popular way of going after people because they have other ways to do it without needing to go that route. Is it possible the current administration could ramp up collections lawsuits? Yeah. I mean, we'll have to see what happens. Pam Bondi wrapping up lawsuits? Maybe. All right. So we have kind of the offset of those government wage garnishment, tax refund, Social Security, but we don't have at risk, at least immediately, your house. And then as I understand it, there's really not a way to access your 401k benefits and your pension and believe those are protected as well under different laws. And there's no jail either. So there is a way that you can look at those collection costs and say, actually, that's more favorable for me than the actual payments I may have to pay under these plans. That is one outcome here, right? Possible. I mean, I think it depends on the numbers. And when you add up wage garnishment, tax refund seizures, and federal benefits offset, it may not be cheaper than just being in an income driven plan. They can garnish 15% of your pay. IBR is a 15% discretionary income formula. RAP, the highest bracket is 10% of income. So from that perspective, garnishment could be more expensive. So I would be hard pressed to find someone where default makes the most sense. But I think that where we might see that happen are these parent plus borrowers who cannot access income driven plans, truly cannot afford their payments as a result of these changes in the bills, they might go into default and that might be the only way that they'll have an affordable payment. Absolutely. I guess, so with that said, where are you at today in kind of like your outlook on student loan repayment? Do you find yourself like, man, WTF all the time? Or is it more like, I'm just trying to make it day to day here? A little bit of both. I think that I'm reading what's happening and I'm definitely like, what the hell is going on? But I'm also, I try to be level headed because I have to be for my clients. And I try to say, look, we're going to try to figure out what to do based on what things are like now. It doesn't mean that's going to be what things are like forever. So let's do what's best for you for now. And then let's figure out if there are further changes in a few years, how best to take advantage of that. But I think we can only get through this by taking it one step at a time. And I think that's how we have to approach this, both as a practitioner and as a borrower. All right. So in terms of next step, I guess, what is the next milestone that you're looking for? Is it just what happens with this plan or is there some other milestone? Yeah, I think what happens with these bills is kind of the big thing that I'm going to be looking out for. There are definitely some other important things that are happening as well, sort of in parallel to that. We're expecting another status report from the Department of Ed in just a few days over the processing of IDR applications and that major backlog. That's going to be impactful for 2 million borrowers. We're watching to see what happens to negotiated rulemaking, which is the Department of Education process to rewrite rules, in particular for public service loan forgiveness. We're going to be keeping an eye on that too. So there's a lot to watch, but I think sort of the most impactful thing that's happening right now is the reconciliation bill. All right, Adam. Thank you for your time today. I do appreciate you, man. I look forward to having you back because we didn't talk about one-time account adjustment stuff at all, but I was like, that could take up like 30 minutes of time right there. I'll have to come back to talk about that. Yes. But thanks for having me. All right. Thank you. Have a wonderful day. You too.