Comment on FR Doc # 2013-11515

The views expressed here, while shared by many in my position are my perspective from 11 plus years as a financial aid administrator and do not necessarily represent those of my employer. Much of the discussion and solutions below, while applicable to undergraduate debt, is particularly pertinent to graduate level debt, where the loan limits and therefore the risk of loan loss are much higher. This is not limited to any particular school or school type (private for-profit, private non-profit or public) as the excessive borrowing occurs across the spectrum of colleges and universities. When considering the cost to taxpayers, these proposals are common sense and follow the intent of MAP 21 signed 7/6/2012 to encourage on time graduation and reducing indebtedness.