Defense to Repayment Regulations: June 2016

Champion Comments Submitted on July 26, 2016
(download the pdf version of the Champion comments)

July 26, 2016

ATTN:  Jean-Didier Gaina
400 Maryland Ave., SW, Room 6W232B
Washington, DC 20202

RE:  Docket ID ED-2015-OPE-0103

Dear Ms. Gaina,

Thank you for allowing Champion College Services to submit comments for the above referenced Notice of Proposed Rulemaking.  My intention in respectfully submitting these comments is to request the implementation of rules to ensure all schools are held to the same accountability standards as an endeavor to truly protect students.

Over Champion’s 26+ year history representing the best interest of several million student loan borrowers, we have established our company as an advocate for students, especially those who are considered “at-risk.”  We pride ourselves in changing people’s lives by providing borrower education and financial literacy information and guidance. Our programs lift students to establish lives as responsible and financially independent citizens; especially those with little financial guidance at home due to multigenerational family structures enmeshed in poverty or dependency on entitlement programs.

I understand the specific individual needs of at-risk students. I was an at-risk student; I grew up in an extremely abusive home; and I used my education experience at a private career college to change my destiny.  While my degree from this proprietary school was not my only education, it was the foundation I needed to leave my past behind me and grow into a successful, contributing taxpayer, female business owner, and employer. I made it my mission to help other at-risk students change their destinies by offering effective behavior-changing support through my company, Champion College Services, formerly “Hands On” Default Management, and I am proud to say that to date, we have supported over 3 million student borrowers.

I understand students’ needs, but I also understand the history of default management since I was a central part of it. To my knowledge, I was the first full-time student loan default manager in the history of this country.  I helped the U.S. Department of Education write “Appendix D”, the original regulatory criteria for default management that was published in June 1989.  Since then, I have assisted in writing both legislative and regulatory language for the majority of changes and additions that have affected default management and loan repayment including defining cohort default rate (CDR) adjustment and appeals options, helping to draft the ED’s original Default Management Guide, and the rewrite of Appendix D into “Subpart M” and “Subpart N”.  I have attached my biography at the end of these comments for your information.

Schools in every sector need high levels of oversight however I, along with many others, am concerned that extreme focus and monitoring of proprietary schools has allowed the failures of public and private institutions to occur without corrective measures being implemented to protect students. This is evident in the June 2016 list of institutions on heightened cash monitoring[1], most being sighted for “financial responsibility,” that includes 110 public institutions and 114 private institutions in addition to those proprietary institutions listed.  This fact alone should warrant holding all institutions accountable to the same standards of quality and oversight so that every student is protected equally.

Please, note that since the first list of schools on heightened cash monitoring was publicly released, the number of public institutions on the list are increasing and the number of private nonprofit and proprietary schools are decreasing.

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Champion Historic Industry Issue Article Archive

The following articles, in pdf form, explore the history of issues that have had an effect on schools and student loan regulations today.



Champion Historic
Industry Issue Article Archive

The following articles, in pdf form, explore the history of issues that have had an effect on schools and student loan regulations today.