Comment on FR Doc # 2013-11515

As an experienced aid administrator, this new 150% loan limit will be difficult if not impossible to explain to students. In the past we’ve been able to say it’s a subsidized loan and here are the benefits…. Now though, that’s not going to be the case. It’s almost as complicated as the TEACH grant that becomes a loan. How can you explain something to a new borrower when the rules change down the road depending on these multiple variables??? Having started in financial aid at 4-year schools and then moving to a 2-year school, what has been troubling to me was to NOT see a different cumulative loan limit for someone in a Certificate or Associate degrees. It seems like most of what you are trying to accomplish could be fixed a lot simpler if there were these different cumulative loan limits. Certificate = $5250 SUB limit (150% of $3500) Associate = $11,500 SUB limit ($3500/$3500/$4500 or 50% of $23,000) If you want to take it a bit further, instead of allowing a part-time student to borrow the max for their grade level, pro-rate it like the Pell is pro-rated… ¾ or ½ of their annual loan limit for their grade level. Unfortunately, what I’ve seen is that if a student can get the full award, they will no matter how much talking we do. So it’s in the best interest of the student (and the indebtedness of our country) for us to make that decision for them and limit their eligibility. If they don’t over-borrow at a 2 year school, they will have funding available at their Bachelor school. The above is something that is at least manageable by schools and something that can be explained to students. If they are already at their SUB loan limits for their program of study we only award them Unsub, if remaining eligibility exists. There won’t be any bait and switch action down the road.