Last week, the CFPB issued a “Student Loan Servicing Special Edition” of Supervisory Highlights. In this blog post, we highlight a stealth expansion of supervisory jurisdiction and focus on the CFPB’s findings in two key areas:
- Transcript withholding policies at institutional lenders (e.g. for-profit colleges that make private loans directly to student); and
- Administration by servicers of Public Service Loan Forgiveness (PSLF), Income-Driven Repayment (IDR), and Teacher Loan Forgiveness (TLF).
Supervisory jurisdiction. The CFPB indicated that simultaneously with issuing the Special Edition, but after apparently having already conducted exams based on its interpretation of Dodd Frank, it had updated its Education Loan Examination Procedures regarding the definition of “private education loans” for purposes of its authority to supervise nonbanks.