New York State Private Student Loan Refinancing Task Force
November 8, 2022
To: Student Loan Advocates, Lenders, Regulators, Servicers, and Other Stakeholders
Re: Request for Information Regarding Private Student Loan Refinancing in New York State
Chapter 774 of the Laws of 2021, signed into law in 2022, established a Private Student Loan Refinancing Task Force (the “Task Force”) tasked with “study[ing] and analyz[ing] ways lending institutions that offer non-federal student loans to students of New York institutions of higher education can be incentivized and encouraged to create student loan refinance programs.” The Task Force, consisting of appointees of the Governor and Assembly and Senate leadership, has issued the following questions to solicit information from interested stakeholders to inform the forthcoming report.
Request for Information:
In light of the foregoing, the Task Force is seeking responses to the following questions concerning private-sector refinancing of student loans, in order to help guide the work of the Task Force:
- What options are available for student loan borrowers to refinance private student loans both in New York State and outside the state? Who is offering these loans? What are the terms? Are they limited to certain types of student loans?
- What options are available for student loan borrowers to refinance federal student loans both in New York State and outside the state? Who is offering these loans? What are the terms? Are they limited to certain types of student loans?
- What is the volume of private student loans refinanced, the terms of the borrowers’ prior loans, the terms of the borrowers’ refinancing loans, the unmet need for student loan refinancing, and the impact of these refinancing loans in New York and nationwide?
- What is the volume of federal student loans refinanced, the terms of the borrowers’ prior loans, the terms of the borrowers’ refinancing loans, the unmet need for student loan refinancing, and the impact of these refinancing loans in New York and nationwide?
- What publicly available data should the Task Force review? Is there privately owned data that could be made available to the Task Force?
- Why do student loan borrowers in New York typically choose to refinance their student loans?
- How does the prospect of government loan forgiveness or cancellation affect student loan refinancing?
- What is the profile of student loan borrowers (including race, ethnicity, age, household income, highest level of educational attainment, type of degree, and any other demographics or groupings) who refinance private student loans in New York State, and how do they compare to student loan borrowers in New York State as a whole, as well as to New York State residents as a whole?
- How and to whom is student loan refinancing currently marketed in New York State?
- What disclosures are made to borrowers who refinance into private loans, including disclosures concerning the effects of refinancing and the potential loss of any benefits on borrowers who refinance their federal loans? What disclosures should be required?
- Identify any predatory practices in the private student loan refinancing market in or outside New York State.
- What qualitative information should the Task Force consider regarding student loan refinancing and the experiences student loan borrowers have had regarding refinancing?
- What programs do state or federal agencies support to help students loan borrowers refinance their private student loans? What information is available on the effectiveness of these programs?
- What factors limit the availability of private student loan refinancing in the private sector?
- What can the public or private sectors do to make safe and affordable private student loan refinancing more accessible to borrowers?
- Are there any statutory or regulatory actions that could make private student loan refinancing safer, more affordable, and more accessible? Are there other programs or public incentives that could make private student loan refinancing safer, more affordable, and more accessible? What are the estimated costs, benefits, outcomes, and other effects of these programs?
- Are there successful public or private refinancing programs addressing debts other than student loans that could serve as a model for a student loan refinancing program?
- Are there student loan refinancing opportunities that exist outside of New York State, and what are the main obstacles for those opportunities to become available in New York State?
- Are there policy solutions for private student loan borrowers other than refinancing that New York State can offer to assist borrowers who currently are seeking to refinance their loans?
- What other information should the Task Force consider in its review and analysis?
The Task Force encourages organizations to be as specific as possible in submitting their responses. Responses should be submitted by Thursday, December 8, 2022, to [email protected]. Please use “Request for Information Regarding Private Student Loan Refinancing” in the subject line. Responses may be subject to public inspection and should not include any sensitive or confidential information.
If you have any questions about the above, please contact Terry McMahon, Assistant Counsel, Consumer Examinations, at [email protected].