Guest Post: Insulating Student Loans from the Credit Crunch
By Art Hauptman
Congress and the Bush administration wisely are trying to ensure that the broadening housing credit crisis does not engulf higher education and thus prevent many college students from being able to borrow. But they need to be careful not to overreact and make matters worse.
First, it's important to understand the problem. Thus far, it is not with the federal student loan programs as some have suggested. Relative to their overall number, few lenders have withdrawn from the federally guaranteed programs and federal Direct Loans remain a viable option.
The student loan credit crunch problem instead is in the burgeoning private student loan market that now accounts for one-fifth of all borrowing for postsecondary education. The private student loan market has grown because federal loan limits are insufficient to meet demand, particularly among students enrolled in most proprietary trade schools and many private, nonprofit institutions. Unsecured private student loans to high-risk borrowers are drying up as many lenders confront the reality of much more limited access to capital.
The concern among policymakers is that fewer private loans will mean less access to college and that a continuation in overall credit tightness will eventually affect federal student loans as well.
This is hardly the first time that general credit conditions have threatened the viability of federal student loans. Rising market interest rates over time led the government first to create and then increase special allowance payments to compensate lenders for the difference between student rates and market rates of interest. Concerns about limited liquidity led Congress to create Sallie Mae in 1972 and later encourage the creation of state lenders of last resort. Over time, lenders and other participants have reacted to various federal cost cutting proposals by threatening to pull out from the federal program.
The difference now is that the federal Direct Loan program exists. It can provide much needed liquidity for banks and other loan holders by buying up existing student loans, thus freeing up capital. This potential provision of liquidity, along with federal cost savings and much greater competition in the student loan market, are two principal advantages of having a Direct Loan program.
What is curious in the current student loan credit market debate is why some in Congress first turned to state lenders of last resort to augment liquidity. The more recent focus on Direct Loans as the primary backup source of capital is a welcome development in my view. Greater use of Direct Loans as a source of capital could have the added benefit of helping to address a very real problems in student loans -- the large and growing number of borrowers who have trouble repaying their loans.
When the Congressional Democrats first came back into power last year, they cut interest rates for new borrowers who already qualify for federal payment of interest while they remain in school. But that left out the millions of existing borrowers who are having trouble repaying their loans. Having the government buy up existing FFEL loans now would greatly increase the number of borrowers who would benefit from income contingent repayment and loan consolidation provisions. A greater policy focus on what happens when students enter repayment rather than when they initially borrow would be a welcome change in the student loan debate.
The most troubling proposal now being debated, however, is one that would greatly increase the amount that students could borrow in the federal student loan programs. These changes in loan limits are surely well intentioned, aimed at letting students shift from risky and expensive private loans to cheaper and guaranteed federal student loans.
But the proposed increases in loan limits have the potential of taking a problem created by the market and shifting it to the federal government. These increases in loan limits represent a bailout of many proprietary schools, some private colleges, and a number of lenders who have come to rely on private student loans to skirt the limits in the federal student loan programs. Particularly troubling is the increase in loan limits for independent students that would grow to an astounding $57,000 cumulatively under the House Committee bill as it could be an invitation for a renewal of large-scale defaults in the federal student loan program.
There are better ways to help those students who now borrow private student loans. All entail greater risk sharing by lenders and institutions.
- Lenders should have to absorb a higher share of default costs in the federal student loan programs;
- Institutions should be required to pay a portion of each loan on which their students default;
- Institutions should be required to offer discounts to student borrowers so that the federal government is no longer put in the position of guaranteeing and subsidizing loans geared to the full sticker price, which fewer and fewer students actually pay; and
- Any increase in federal loan limits should be much more modest with no difference for whether students are dependent on their parents or financially independent -- students should be able to borrow a standard amount for living expenses whatever their circumstances.
In sum, the (remote) possibility of a federal student loan credit crunch should not be used to justify a raid on the Treasury in the form of large increases in federal student loan limits. Instead, the federal government should be ready to rely on Direct Loans to provide liquidity and expand income contingent options for borrowers having trouble making their repayments. Greater cost sharing for defaults should be instituted for lenders and institutions, and institutions also should be required to step up to the plate and offer sizable discounts to reduce how much students must borrow to attend their institution.
The latest, perceived student loan crisis should be used to help borrowers in trouble, not bail out lenders and schools that have come to rely on private loans.
Art Hauptman is an independent consultant on higher education finance issues. The views expressed herein are his own and do not necessarily reflect the positions of the New America Foundation.
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Corrections on Some Facts
My good friend Art knows much more about student lending than I, but there are some inaccurate or incomplete statements in his analysis that I would like to correct. I am not confident that even if he accepts my points he would support the Kennedy/Miller/Enzi/McKeon legislation, as virtually all of higher education does, but I hope he would.
First, increases in unsubsidized Stafford loan limits to help students fill the gap are not "a raid on the Treasury." They do not cost the taxpayers a cent. They generate a "profit" for the government, money that can be used to increase grants to the neediest students, for instance. The overall bills offered in the House and Senate are cost neutral.
Secondly, as Mark Kantrowitz and others have demonstrated, it is a myth that particular sectors of higher education are more harmed by the drying up of private lenders than others. NPSAS data show that 20% of private loan borrowers attend for profit colleges, 32% four year public institutions, 32% four year not for profit private colleges, and 15% community colleges. So students, whatever their choice of higher education path, are suffering from a dearth of private lending.
Thirdly, Art is correct that relatively few FFEL lenders, if one takes 2000 lenders as the base, have withdrawn in whole or in part from student lending. But he also knows that the lenders that have withdrawn, because many of them have been major FFEL players, constitute a high percentage of the lending volume. Some have estimated 15% of the FFEL volume is gone. On top of that, some of the lenders that remain have begun selective lending, dropping many community colleges, career colleges, and other institutions with high percentages of lower income students and minorities. Finally, dependent students can get PLUS loans if their parents agree and qualify; independent students cannot, as he knows.
So unless Congress creates a new program for independent students equivalent to the PLUS program (which CCA supports), an increase in loan limits for independent students greater than that for dependent students makes sense.
Harris N. Miller, President/CEO, Career College Association
No free lunch for student loans
I admit to being not up to date on the ins and outs of current proposals or statistics so I defer to Harris' figures and to the analysis of Mark Kantrowitz and others regarding who is using private loans. But that's part of my worry. If nearly half of the students using private loans now are enrolled in public institutions that means they are borrowing high-interest unsecured loans to pay for their living costs as the tuition levels in the public sector are not high enough to require borrowing above the federal loan limits.
Frankly, my interest in this issue was captured when I read that financially independent students would be eligible to borrow $57,000 under the House bill! That means that the students who are often the ones most at risk would be now eligible to borrow tens of thousands of federally guaranteed loans to pay for their living expenses because of the quirky way in which costs of attendance is determined for these students (where basic costs of living outside of college-related expenses are included in the calculation of need which accounts for the vast preponderence of 'unmet need' in the various reports that have come out on this subject over the years).
I also would take issue with Harris' assertion that increases in the loan limits for federal unsubsidized loans entail no federal cost and generate profits. Again, I've been on the outside of this debate for a while and I gather it is now commonly asserted that unsubsidized loans generate profits because of the 2006 change that reduces lender special allowance payments when market interest rates are below student rates. This assertion makes it much easier to understand how the Congress is ready to increase loan limits by so much. If you believe that a program generates profits why not increase the limits and make even more profits which can then be used to plow back into grants (although given federal budget rules entitlement savings are difficult to translate into discretionary program increases)?.
The problem with this kind of thinking it it ignores the impact on hundreds of thousands of student borrowers who will accumulate unsustainable debt burdens as they borrow more and more. And it also ignores basic economics that recognizes there is no free lunch. The only thing that is unsubsidized in this program is that students do not qualify for the in-school interest subsidy. To project government profits from more borrowing, this requires assuming that market interest rates remain below student rates for a sustained period of time and that default rates remain low. Both of these assumptions are highly questionable and should not be the basis for important policy decisions.
Interest rate projections are a notorious problem in student loans and some other federal programs because CBO acts as though low current market rates will continue throughout the life of the loan even though this is obviously not likely. That's how the consolidation deal was sold some years ago as budget neutral which it clearly was not with hindsight. It is also important to note that these loans remain fully guaranteed against default.
The default rate on these loans is clearly going to be higher than the average - it's hard to imagine a default rate of less than 10 percent for students who are currently borrowing private loans - at what rate are these loans currently defaulting and that's with lenders having no federal guarantee to rely upon? Imagine what the default rate will be if lenders can turn over these loans to the feds after 'due diligence'.
So the notion that the federal government will profit from increasing loan limits is not credible and my assertion of a raid on the Treasury - especially if lenders can get no-interest loans to storehouse their loans until the current fire subsides - seems a reasonably accurate one. This really is an invitation for student loans to join the sub-prime market as an example of federal mismanagement of a crisis or the manufacture of a crisis.
Regardless, I hope that my proposals -- that lenders and institutions should have to share in the costs of any defaults, that schools do more in the way of discounts in order to have their students participate in the federal programs, and that students should only be able to borrow a standard amount for living costs regardless of their status -- are not lost in the hubbub of how to avert this 'crisis'. These would be sensible changes with or without a crisis.
FFEL
"First, it's important to understand the problem. Thus far, it is not with the federal student loan programs as some have suggested. Relative to their overall number, few lenders have withdrawn from the federally guaranteed programs and federal Direct Loans remain a viable option."
Oh but the problems do lie with the FFELP loans. Every single non-bank FFELP lender is losing money on every single loan they were issuing recently. You really think they are going to issue loans at a loss this next year? Just because there wasn't news about more lenders exiting the business, it doesn't mean they weren't going to make that announcement prior to the peak disbursement season. I applaude the government in their quick actions. I think the government realized that Direct Lending does not have the capabilities to meet all the demand. It would be a logistical nightmare.
That 70s Show
The non-bank lenders (who have long gotten higher subsidies, even in last years’ cuts), have been sideswiped by a temporary municipal-bond slump. Other types of lenders are feeling the temporary side effects of the subprime mortgage credit averse behavior. The elephant in the room is that, despite a handful of "new wave" not-for-profit lenders, "non-bank lenders" really means state government agencies. They have every subsidy advantage available at both the federal and state levels; if they can't make money they should be de-authorized; they are a throwback to the 1970s. The nonbank for-profit marketers in the consolidation sector were just a temporary activity; the decline in the consolidation segment was driven by the programmatic changes of the 2006 "Deficit Reduction Act" rather than anything that has happened during 2007 or 2008.
Although the state agencies which are secondary markets and lenders control a relatively-small percentage of the market, their political power is strong, as evidenced by their ability to win a higher subsidy level than for-profit lenders in the bill enacted last fall and their ability to maintain a minimum 9.5% yield provision long after it was presumed it was phased out. Many Senators and Congresspersons are former state legislators and executives, and their doors are always open to the state educational agencies. The nonprofit lenders arguably should have gotten a lower subsidy level than the for-profits because their cost of funds is much lower, and they don't pay taxes.
For Profit Schools
Perhaps the problem is with the type of schools themselves. These for profit universities, especially on-line ones, are not really providing for a real education one gets at a bricks and mortar institution.
Taking a management class with the University of Phoenix in six weeks is certainly cutting out important information and learning when the normal class time is 15 weeks. One big reason why students go for these type of institutions is because they don't want to spend the four or five years earning a real degree. Instead they want the easy and quick way out, and much of corporate America is allowing and encouraging this.
It will be a sad day when your future doctor or nurse earned her degree in less than half the time, and did it all online.