With the recent turmoil driven by the coronavirus pandemic, people across the country are faced with tremendous uncertainty about their financial situations. In response to the crisis, Congress passed the Coronavirus Aid, Relief, and Economic Security (CARES) Act, a $2 trillion emergency fiscal stimulus package, in order to offer much-needed relief for both individuals and business owners to meet their short-term cashflow demands. For borrowers of Federal student loans, in particular, Section 3513 of the CARES Act offers a full suspension of Federal student loan payments with no interest accrual on those loans through September 30, 2020.
In this guest post, Ryan Frailich – Founder of Deliberate Finances, a fee-only financial planning firm in New Orleans, Louisiana – breaks down the key features of this relief provision and how the suspension of payments plays into forgiveness plans. Additionally, he offers strategies that advisors can use to help their clients leverage available CARES Act relief benefits as they relate to their student loans.
For instance, clients with direct student loans and Federal Family Education Loans (FFELs) owned by the U.S. Education Department can take advantage of suspended payments during the relief period, with no action required from the borrower. Importantly, though, FFELs that are not owned by the Education Department do not qualify for relief under the CARES Act, nor do other types of privately serviced student loans. Additionally, borrowers can confirm that the interest rates on their eligible loan accounts are set at 0% throughout the relief period, during which time any unpaid interest on loans will not be capitalized.
Meanwhile, for borrowers in forgiveness programs in which the forgiven amounts will be considered tax-free income, such as the Public Service Loan Forgiveness (PSLF) program, the relief period during which payments are suspended will count for payment periods; accordingly, borrowers in such forgiveness programs should be encouraged to stop payments during the relief period. Some forgiveness-eligible loans that don’t offer tax-free forgiveness, like Income-Driven Repayment (IDR) plans, may pose more complex challenges about whether to pay during the relief payment period, and the best choices will largely depend on anticipated future income levels and whether any forgiveness will actually be pursued.
Other clients with unique student loan situations may also benefit from relief efforts. For example, borrowers with FFEL or Perkins Loans that are not owned by the U.S. Department of Education, which will not qualify for CARES Act relief, may be able to consolidate their loans into a Direct Loan, which will qualify for CARES Act relief. Clients who may be expecting a reduction in income might benefit from entering into an IDR plan, which, after the relief period, may potentially reduce their payments by substantial amounts. And finally, clients who have stable income levels not impacted by the crisis and with no high-interest debt might be better off not taking advantage of the option to suspend payments, and may instead benefit more by making regular payments as usual in order to reduce their principal loan balances as quickly as possible (still taking advantage of interest rates while they are set at 0% during the relief period).
Ultimately, the key point is that the relief provided by the CARES Act for student loan borrowers is yet another way advisors can help their clients cope with the current crisis. Especially in light of the rapidly changing legislation, clients will need their advisors to help them determine if their loan payments are eligible for suspension, how loans that do not qualify for relief can best be managed, and how the rules may impact those in more complex financial circumstances.