It’s been awhile since I’ve written anything about PSLF. My last post on the subject detailed the confusion many borrowers feel around knowing whether you qualify for PSLF. The confusion stems from the fact that FedLoan Servicing notified certain borrowers that they were eligible, only to yank those qualifications away significantly later once the Department of Education decided that the borrowers didn’t qualify after all.
The lesson is that if you’re pursuing Public Student Loan Forgiveness you must fill out a certification form sooner rather than later. Once you do, your loans will be transferred from your current servicer to FedLoan Servicing, as they are the only servicer that is authorized to handle the PSLF program.
When you send in your certification form, you’ll receive a response from FedLoan certifying that your employer meets the “qualified employer” test which makes any payments made under a qualifying repayment plan eligible to count toward your 120 qualifying payments.
The response from FedLoan will indicate that the next step is for them to tally up the number of qualifying payments you’ve made and provide you with a letter stating the amount. How long does it take to get this letter? We still don’t know. Despite sending our certification form to FedLoan Servicing in February on behalf of my wife’s loans, we still have not received a letter stating the number of qualifying payments.
Naturally, I’m a bit alarmed that it’s taken over 9 months for FedLoan Servicing to respond and have been following up with them on a monthly basis. Each time we seem to get a little closer to getting the actual response but then another month rolls by and we still seem to be stuck in the same place.
It’s important to get an actual number of qualifying payments from FedLoan Servicing because I’m not at all convinced they’ll get it right. Think that can’t happen? Site sponsor Travis over at Student Loan Planner wrote an article about how FedLoan Servicing cost him $20,000. It’s one of the reasons why he started Student Loan Planner. Which among us knew in law school that handling PSLF would be a part time job in and of itself?
I’m still hopeful that FedLoan Servicing will get the number of qualified payments right. But, if they disagree (i.e. are wrong), I’d like to find out sooner rather than later so we can gather the evidence to show that the payments have been made. This is not something you want to leave until you’re 1 month shy of receiving PSLF forgiveness. Can you imagine digging up records from 9 years ago to prove that you made payments if FedLoan Servicing reports that they have no information on file? File the certification form today and get started on the process.
PSLF Forgiveness
Speaking of forgiveness, several of you have emailed asking if anyone has seen their loans forgiven under the PSLF program. The program began in October 2007, so the first wave of eligible borrowers should have hit 120 qualifying payments in October 2017. As you can imagine, there’s a lot of excitement and buzz about whether the program will work as intended.
The good news is that the PSLF application for forgiveness is available. The bad news is that I haven’t found anyone who has received forgiveness yet (and I’ve been looking). I’m aware that several people have applied for forgiveness but so far I haven’t a person who has received forgiveness. And it’s really the receiving forgiveness that we’re all looking for. The process seems to be that FedLoan Servicing reviews the application and then passes it along to the Department of Education.
You won’t be shocked to hear that forgiveness may take months as it winds its way through the various government and quasi-government bureaucracies. For eligible borrowers navigating this process, I believe your loans are placed in forbearance during the forgiveness review so that you are no longer required to make payments. If the Department of Education determines that you qualify for PSLF, your loans will be forgiven. If they determine that you don’t qualify, you’ll have to back to making payments or otherwise meet the 120 qualifying payment standard.
As I said, that’s my understanding of what’s going on. It’s really the Wild West out there and the guideposts are feeble at best. If you’re seeking PSLF, I hope that doesn’t add to your anxiety over the program but we’re certainly keeping track of it here and will be publishing further posts as our own experience grows. If you’ve applied for forgiveness, let me know in the comments send me an email.
Other Lessons Learned
If the above hasn’t convinced you to fill out a certification form, we also learned a few other lessons in the process of transferring our loans to FedLoan Servicing. It turns out that three of them (for about $5K total) aren’t eligible for forgiveness.
Had I paid closer attention, I would have recognized this earlier.
Most of my wife’s loans are Direct Federal loans, the kind that qualify.
Unfortunately, a few of the small ones are of the FFEFL variety. Although that program ended in 2010, many lawyers still may have a few of these loans from either their undergraduate education or law school.
FFEFL loans are not eligible for the PSLF program unless you’ve consolidated them into a new Direct Federal loan. But, of course, if you consolidate your loans you end up with a “new” Direct Federal loan which completely restarts the clock when it comes to making 120 qualifying payments (i.e. all of your previously qualifying payments to a Direct Federal loan which is rolled up into a consolidated loan are erased). If you consolidate your loans, you need to tread carefully.
Since the FFEFL loans are quite small in the grand scheme of things, we’ll just pay these off and move on. It’s not worth the headache of converting these into Federal Direct loans and then beginning the 10-year process of repayment. I might be able to save a few bucks but I’m not crazy enough to follow the math argument to its logical conclusion. We’d much rather end this painful process and get on to the fun things in life.
Let’s talk about it. So that’s the PSLF update! It’s a slow, winding process but as a lawyer whose job revolves around shepherding deals forward, I feel up to the task. FedLoan Servicing may be incompetent but I’m patient and persistent.
You're gonna love my emails
I think another component of qualifying for forgiveness is that you have to currently work for your public-interest employer at the time the loans are forgiven.
If this process could take months (or even years?), one could end up working for a public-interest employer for much longer than the 10 years.
Good point Robin. I’ve also read that there is some uncertainty on this point, since on one hand you only need 120 qualifying payments to receive forgiveness but on the other hand there’s some language (if I remember correctly) that says you need to be employed by a qualifying employer at the time of forgiveness.
Regardless, I think it’s safe to assume that anyone who is a few months away from receiving forgiveness will not leave a PSLF-eligible job during that time period for fear of screwing it up, so effectively you get tot he same place: one will likely end up working for a public-interest employer for longer than 10 years.
I am still waiting for them to tally my number of qualifying payments and am starting to worry. Did they ever get back with how many?
Thanks!
No. They never sent a letter showing exactly how many qualifying payments we’ve made. However, if you look at your most recent monthly statement there is a column that lists the number of qualifying payments that you’ve made so far (as of the last date of certification). Ours is wrong but at least there is some information there. Let me know if you have any trouble finding it in your statement.
Thanks for the update! I have only
Certified once when my loan was transferred and my statement still says 0 qualifying payments. I should have several years from my previous lender. I do have unpaid interest from a forbearance but from what I have read that should not effect eligibility. I transferred in August. Thanks for your help
Yes, that’s too long. They are awful at this but rest assured that they are awful with everyone. Anecdotally, I’ve heard from several other people who have submitted certification forms and still have not received any confirmation of how many qualifying payments they’ve made (have you at least received confirmation that you work for a qualifying employer?).
I suggest you call FedLoan Servicing and ask them to explain why the number hasn’t been updated. In my experience, the person won’t be able to help you on the phone but will pass your question on the right department, at which point you’ll never hear from them again (still, I think it’s worth it just to get the discussion going and who knows, maybe they’ll figure it out for you!).
We certified over a year ago, so at this point aren’t expecting FedLoan to one day update the loans that have a “0 qualifying payments” to the correct number. Our plan is to submit (or re-submit I guess) a new ECF and then see how they respond. I’ll definitely write more posts in the future as we make progress.
I submitted my PSLF application for forgiveness last November. Around January 2 it was sent to FSA by FedLoan. I have been unable to find out anything about where it might be in the process. My forbearance is good though June 22. I hope I hear before then.
My understanding is that the process can take some time, although that seems like a long time. Have you tried to call FedLoan or the Department of Education to see if you could get any more information? I’d be curious to hear an update. Are you a lawyer?
We have loans going back to 2000. Fortunately all were consolidated into a direct loan in 2005. Now the hard part. We’ve sent 5 ECF’s going (back to 2007) into Fedloans and it took about 18 months for a response. This was after contacting Fedloans, FSA Office, the CFPB, Ombudsman, my senator etc.. We were approved for a whopping 24 payments during that time. My records how about 85 payments made. Don’t think for one minute the services work
For you the customer- it’s all about their contract terms with DOE and financial incentives they get that are adverse to the borrowers situation. I just filed a privacy act request from DOE to get every record from the four loan servicers we had going back to 2000. Just today I received a random administrative forbearance for one day in 2012. How can I not laugh but be skeptical for their motivations or simple incompetence. I haven’t figured out what’s worse. They have sent the same form letter four times now about the 24 payments they have “qualified” since 2007. Seems like a cruel joke. There are some many ways they play the “gotcha” game it’s deplorable.
A few things I’ve learned. Do everything in writing with them. Take screenshots if you chat or get secure messages. Keep detailed notes after every call if you want a human. Get your original loan promissory note to see what the language states about the terms of your loan. Things like loan capitalization etc.
If Fedloans won’t respond to your questions (like they have with us) for several years now file a privacy act request on yourself to get all the info they have in your account. Get all their mail in hard copy and skip their friendly reminder to go paperless. Even in this day of enlightenment where I do everything else electronically there is no trust for student loan servicers. Also you can only go back a few years and download their digital documents. If you haven’t moved to Fedloans yet don’t bother until you are forced into it or they are out of business. We’ve generally had better luck with other servicers. If you breathe anything to your current servicer about the PSLF they will gladly send you packing to Fedloans. Be discreet about your intentions and make sure your loans are in The right repayment plans and you’re making full payment within 15 days of due date.
Thanks for sharing your story Clint. Sounds pretty familiar (unfortunately) and glad that you’re taking an aggressive stance with FedLoan Servicing. I couldn’t agree more with you: document, document, document!
A couple of questions: Can you elaborate on the privacy act request? How did you file it and what did you requests?
You advise not moving to FedLoan Serving until you have to. But if that’s the case, you’ll never file an ECF until toward the end of your 10 years of payments. What if FedLoan Servicing rejects it or you otherwise have a difficult time substantiating records from 8-9 years ago? As much as I don’t like working with FedLoan Servicing, I’d be wary of filing an ECF with them in year 9 right as I’m expecting to get forgiveness.
A privacy act request can be filed by an individual seeking records from a government agency similar to a freedom of of information request except you are asking for the files on yourself. I requested pretty much everything from the Dept of Ed on all my servicing records and statements. There are good
example letters on line. Our problem in part is that Fedloans will not provide documentation as to what payments they have qualified and what payments they have not and reasons for each of the latter. Seems like a reasonable request as the customer. Of Course they don’t want consumers questioning their determinations and one way of doing so is by not providing reasons behind their decisions. Also the NSLDS shows no data on our loans between 2005 and 2012 so I’m very curious what records are being used to make decisions about the qualifying payments. I’ve inquired about this from four different entities within DOE and the servicer and everyone passes the buck to another office. We also received a letter back in 2012 from ACS stating that 36 payments were qualified for PSLF. Fedloans won’t even acknowledge that determination and now says many of those payments were In the wrong repayment plan even though we were assured by the servicer at the time they would count.
I’m terms of not switching over to Fedloans until the end perhaps it’s a bit of a tongue and cheek response. Our experiences with other servicers were decent over the years. The nightmare only began with Fedloans. We switched over in 2014 and it has not made any difference as it seems the Fedloans strategy is one of obstruction and stalling tactics in their implementation of PSLF. For example I just submitted an ECF for the past two years and the first response back was that my signature wasn’t valid. I re submitted that very day and today got back a letter saying I was denied because the form wasn’t the most current one available. I compared the one I used to their “ current one” and didn’t see a bit of difference. I work in government and outdated forms are used every day. Once again Fedloans is not serving the consumer. I think next time I resubmit for the third time I’ll call and ask if there is a specific day of the week or type font I need to submit the form in for it to get approved.
So how long is it taking folks to hear back about how many credit they have? I got a letter back saying that my employer was approved and they would reply back with further information within a few weeks, but that was 5 months ago. How long are others waiting?
We’ve been waiting over a year. It’s not going to happen. The only way forward seems to be to re-submit the PSLF certification form again. One thing I’ll point out is that your monthly statements contain the number of months they believe qualifies for PSLF (it’s easy to miss) – so check your monthly statement and see what information they have there.
Hi,
I received a response from FedLoan and they certified my payments within about a 3 month time span. My payments went into deferment during the transfer, and at about the end of the 60 days when the deferment was up, they had completed the certification. I did notice some of my smaller loans did not show payments towards the 120, but I also noted that those loans are small enough I would pay them off before the 120, so I didn’t think much of is. In conversing the the FL agent (who is always very helpful and prompt), they said there are sometimes counting issues, and the process can take 9 months-year if there is a problem as they have to reverify every payment. They also said when you do a recert, they re-verify all of the payments from that employer to ensure they match.
Thank you for writing this article. I googled this exact topic because I made a request for them to count all of my qualifying PSLF payments as my loans were transferred from the Dept of Education when they were still the PSLF servicer. When they transferred they didn’t count those payments so I requested they conduct a recount. That was in October of 2017. I have also been calling frequently. Their response has been it should be done in a month to now they are saying it is taking longer than they originally thought. I imagine everyone who started PSLF before 2013 is in the same boat because I believe that is when Fedloan became the new servicer.
Thank you for sharing so I do not feel I am the only one in this boat. It is quite frustrating as this has a huge impact on many of our life decision as we as finances.
You are definitely not alone. This won’t make you feel better but they never “caught up” and got the count right with my wife’s loans, so our plan is to resubmit a PSLF certification form covering the missed payments because that seems to be the only way to get them to do their job (i.e. start the process all over again).
I am living this exact situation right now. I was told they converted to an automatic counting system for 2017 and big surprise they misappropriated my 12 payments. I submitted a request in February 2018 when I received my letter indicating my new total payments. What’s funny is I just got off the phone with them as I too call monthly and receive the exact same story each time. “It’s under review”. I even did the math in excel with bank statements and sent that in via the “inbox”. That was June and here we still are. I wish I could do more as my certification for 2018 will be coming up but based on your experience perhaps they will just recount all over and resolve the matter. Who knows….
I’m going through a payment review due to Fedloan losing 11 payments. They kept telling me they would get to it. Finally, they said my servicer from 2013-2014 hasn’t gotten back to them. The thing is, there’s a letter in my file that the payments were qualified before. I’m getting my old bank records to figure out who my servicer was for those years to see if I can get the information. This is the first problem I’ve had with Fedloan. I would’t characterize my previous experience as a nightmare but obviously losing 11 payments/a year of my life is. They have been conducting the “payment review” for a year now.
Thanks for this article. My old loan was with EdFinancial, with 49 payments that had already been approved by FEDLOAN as of December 2017. In fact, their paperwork (I get paper bills from them) certified the 49 payments on their bills.
In January 2018, I received a my new bill saying that I had only 19 payments and 18 payments (I had two loans) and when I called, they told me that the 49 payments had to be researched by hand… even though all of the payments were from the same company. It’s eight months later and I still don’t have an answer as to how many payments I’ve made. I call them at least once a month and they give me the same story… it’s taking more time than usual to hand count and research payments… that they already certified in December 2017. It’s very frustrating.
This is my problem as well. Went from 61 down to 7/17 with Edfinancial. They also haven’t counted the 22 I paid to Direct Loans. Did they work it out?
I ran into an interesting situation with FedLoan Servicing. I apparently reached a certain threshold for accumulated interest on my loans which required them to take my loan and split it into two loans….This locked me out of my account for several days where I could not access and pay my bill. I then was able to access it several days later and my qualifying payments went from 60- something payments to 0….Ive called them a few times and emailed and they keep stating they are trying to figure out my number of qualifying payments. It was JUST on their website before the loan was divided, pretty sure they are able to pull that info up. I am guessing that once it is all said and done there will be missing payments conveniently enough.
I’ve been making payments through my lenders (first Sallie Mae and now Navient) for the last 6 years. I recently submitted the employment verification letter for my current employer as well as my past two employers. I work for a county so I should qualify for PSLF. I haven’t heard anything back from FedLoan. Should I receive any notification letting me know that they got my forms? How long after they receive my forms should I expect to have my loans transferred to them? Is there anything other than the employment verification form that I have to submit in order to get my loans transferred? It seems impossible to find a clear answer to any of this and I can’t create an account with FedLoan to be able to email them (so I can get the response in writing) because my loans aren’t with them.
Is it wrong to hope that I just get forever lost in the shuffle? My previous loan provider says I have a zero balance. FedLoan says I have a zero balance. Can it just remain that way?
I did receive a letter saying that my employer is qualified; however, that’s the last thing I heard.
I have experienced a slightly similar situation. I received the notice that my job qualified/was certified for the PSLF program, then subsequently received a letter letting me know all 12 payments from the previous year counted toward that program. Then 2 months later I received a letter saying that I had zero qualifying PSLF payments. I currently have a claim that I started 3 months ago with FedLoan to investigate this error (which the agent admitted was clearly an error on their side) but as of today, the most recent agent I spoke with says they have no idea when or if this will be resolved. What kind of answer is that? Do we have any rights or are we at the mercy of this company?