Comment on FR Doc # 2026-09442

The Borrower Defense to Loan Repayment Universal Forms impose a significant and recurring administrative burden on institutions such as Baylor University, particularly due to the volume of claims received and the limited specificity provided in many borrower submissions. Institutions are required to conduct detailed, cross-functional reviews involving financial aid, registrar, academic affairs, admissions, and legal counsel to reconstruct historical records, policies, marketing materials, and program information—often spanning many years and requiring manual retrieval from legacy systems. This process is resource-intensive and further complicated by staff turnover and evolving record retention systems. While institutions fully support the Department’s responsibility to evaluate borrower defense claims and provide appropriate relief where warranted, the current intake structure results in a disproportionate institutional workload relative to the quality and specificity of initial borrower allegations. To improve efficiency and reduce unnecessary burden, we recommend several targeted enhancements to the intake and review process. First, the application should require more structured and specific allegations, including dates, program details, and identification of alleged institutional statements or materials. Second, the Department should implement an initial completeness or screening threshold to ensure only sufficiently detailed claims proceed to full institutional response. Finally, standardized response templates or a secure submission portal for institutional documentation would improve consistency and reduce duplicative effort across cases. These changes would preserve access to the borrower defense process while improving the quality of information collected, reducing institutional burden, and enhancing the timeliness and effectiveness of claim resolution.