PEER Center Comments: RISE Regulations on Loan Limits and Loan Repayment

The One Big Beautiful Bill Act (OBBBA) will create significant changes in higher education policy. Graduate students and the parents of undergraduate students will face new annual and aggregate loan limits, for instance. PEER Center research has found these new limits will reduce federal borrowing for about one-third of parent borrowers and of graduate student borrowers. OBBBA changes will also reshape the student loan repayment landscape, phasing out old income-driven repayment plans in favor of the new Repayment Assistance Plan.

We submitted comments to the U.S. Department of Education on its proposed regulations implementing these provisions, noting in particular several ways in which the Regulatory Impact Analysis falls short. Specifically, we note that:

• The benefits of loan limits described by the Department rely on a critical assumption about reductions in tuition that are not supported by the research it cites. 

• The costs to students of both the new loan limits and the Repayment Assistance Plan are understated and sometimes not quantified. 

• The Department could further improve transparency by describing and enhancing the modeling and assumptions underlying its budget estimates in the RIA.