Director of Policy and Research Krisztina Pusok shared key concerns with the Borrower Defense Repayment (BDR) rule:

  • The proposed changes to “substantial misrepresentation” could facilitate costly loan forgiveness on almost any grounds.
  • The Department proposes creating an Aggressive and Deceptive Recruiting standard that could be used to target institutions for engaging in lawful behavior if the Department views that behavior as sufficiently “aggressive.”

We recommend that the Department develop clear and consistently applied guidelines so that schools can focus on building innovative education models to meet each student’s unique educational needs.

Read ACI’s analysis of the BDR Rule.