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Ian Foss and Brian Smith | Dec. 2015
U.S. Department of Education
2015 FSA Training Conference for Financial Aid Professionals
Income-Driven Repayment Plans/Pay As You Earn (PAYE)
Session 33
Details of Income-Driven Repayment Plans
2
Overview
• Income-Contingent Repayment Plan (ICR) – 1994• Income-Based Repayment Plan (IBR) – 2009• Pay As You Earn Plan (PAYE) – 2012
3
Overview
• Revised Pay As You Earn (REPAYE) – 2015• Negotiations February – April, 2015• Consensus reached• NPRM published July 9, 2015• Final Rule published October 30, 2015• Early implementation announced (December 2015)
4
Eligible Borrowers
5
Eligible Borrowers
6
Eligible Loan Programs
Loan Program ICR IBR PAYE REPAYE
Direct Loans X X X X
FFELP X
Perkins Loans
7
Eligible Loan Type
Loan Type ICR IBR PAYE REPAYE
Loan received as student X X X X
Loan received as parent
Consolidation (no underlying parent loans)
X X X X
Consolidation (underlying parent loans) X
8
Payment Amounts
9
Repayment Plan Payment based only on income
Payment based on loan debt
ICR 20% of discretionary income 12-year standard payment adjusted based on income
IBR 15% of discretionary income 10-year standard amount
PAYE / “new” IBR 10% of discretionary income 10-year standard amount
REPAYE 10% of discretionary income None
Most IDR plans have two formulas--for those that do, borrowers always pay the lesser of the two.
Interest Subsidy Benefits
10
Interest Capitalization
11
12
20 years is for undergraduate
borrowers and 25 years is for graduate
borrowers
20 years is for undergraduate
borrowers and 25 years is for graduate
borrowers
Generally, payments on an IDR plan, 10-year standard plan, or periods of economic hardship
deferment count toward forgiveness
Generally, payments on an IDR plan, 10-year standard plan, or periods of economic hardship
deferment count toward forgiveness
Loan Forgiveness
• Billy Borrower:• Is single with no dependents and lives in Georgia• Has an AGI of $35,000 that rises at 5% per year • Has $50,000 in Direct Loan debt ($23,000 of which is
subsidized), all of which has a 6% interest rate• Borrowed for graduate school
13
Billy Borrower
Billy - ICRYear Interest Payment
1 $250 $3872 $242 $4053 $231 $4104 $220 $4155 $208 $4196 $195 $4247 $181 $4298 $166 $4349 $150 $440
10 $132 $44511 $112 $45112 $91 $45713 $69 $46314 $45 $46915 $18 $475
14
Billy – “old” IBRYear Interest Payment Subsidy
1 $250 $217 $152 $250 $236 $63 $250 $254 $04 $250 $273 5 $250 $293 6 $248 $314 7 $244 $336 8 $239 $359 9 $231 $384
10 $222 $410 11 $210 $438 12 $196 $467 13 $180 $497 14 $160 $530 15 $137 $555 16 $112 $555 17 $84 $555 18 $55 $555 19 $24 $555
15
Billy – PAYE/“new” IBRYear Interest Payment Subsidy
1 $250 $145 $492 $250 $158 $433 $250 $170 $374 $250 $182 5 $250 $195 6 $250 $209 7 $250 $224 8 $250 $240 9 $250 $256
10 $250 $273 11 $250 $292 12 $250 $311 13 $250 $331 14 $250 $353 15 $250 $376 16 $250 $400 17 $243 $425 18 $231 $452 19 $218 $480 20 $202 $510
16
Billy - REPAYEYear Interest Payment Subsidy
1 $250 $145 $772 $250 $158 $683 $250 $170 $594 $250 $182 $345 $250 $195 $276 $250 $209 $207 $250 $224 $138 $250 $240 $59 $250 $256 $0
10 $250 $273 $011 $250 $292 $012 $250 $311 $013 $249 $331 $014 $247 $353 $015 $241 $376 $016 $233 $400 $017 $222 $425 $018 $210 $452 $019 $195 $480 $020 $177 $510 $021 $157 $541 $022 $133 $574 $023 $106 $609 $024 $75 $646 $025 $40 $685 $0
17
Billy – All IDR PlansYear IBR ICR PAYE REPAYE
1 $217 $387 $145 $1452 $236 $405 $158 $1583 $254 $410 $170 $1704 $273 $415 $182 $1825 $293 $419 $195 $1956 $314 $424 $209 $2097 $336 $429 $224 $2248 $359 $434 $240 $2409 $384 $440 $256 $256
10 $410 $445 $273 $27311 $438 $451 $292 $29212 $467 $457 $311 $31113 $497 $463 $331 $33114 $530 $469 $353 $35315 $555 $475 $376 $37616 $555 $0 $400 $40017 $555 $0 $425 $42518 $555 $0 $452 $45219 $555 $0 $480 $48020 $0 $0 $510 $51021 $0 $0 - $54122 $0 $0 - $57423 $0 $0 - $60924 $0 $0 - $64625 $0 $0 - $685
18
StudentAid.gov/Repayment-Estimator
1919
Income-Driven Repayment Plans
Application Process
20
21
ADOI = “alternative documentation of income;” not AGI.
Applying: Electronic or Paper
Income-Driven Repayment Plans
22
Application Process: Spouses
23
Repayment Plan Married borrower filing jointly Married borrower filing separately
ICR Use joint AGI Use borrower’s AGI
IBR Use joint AGI Use borrower’s AGI
PAYE Use joint AGI Use borrower’s AGI
REPAYE Use joint AGI Combine AGI of borrower and borrower’s spouse
Application Process: Spouses
Billy gets Married in Year 5 • Spouse has $20,000 in income, and $40,000 in Direct
Loans, all of which are unsubsidized, and which has an interest rate of 6%
• Billy and his spouse decide to file separately
24
Effect of Billy’s Marriage
25
In Year 6, Spouse Pays Off Loans
26
27
A married borrower is not required to provide spouse’s AGI if the borrower is:
Application Process: Spouses
REPAYE—If a borrower is separated or unable to reasonably access spouse’s income information:
The borrower’s spouse is not counted in family size If the spouse has eligible loans, the spouse’s loans are not
considered in the monthly payment amount adjustment
Application Process: Spouses (REPAYE)
28
29
Application Process: Income Documentation
30
Application Process: Income Documentation
31
Application Process: Annual Life Cycle
Consequences of failing to recertify
32
Billy Doesn’t Recertify – Year 4 End
33
QUESTIONS?
34
Ian Foss – [email protected] – 202-377-3681
Brian Smith – [email protected] – 202-502-7551