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Regarding #10 - I thought the best arguments for retaining and actually improving the "bank" based program were 1) even the US government can only borrow so much money and this forces it to borrow tens of billions more than it needed to in the good old robust FFEL days and 2) the guarantors really do provide a lot of hands on default prevention and face-to-face time with high school counselors and college financial aid teams.

Regarding #3 - I would like to see this analysis, too.

In general, I am surprised to not see any response from NCHELP (at least looking on its website as recently as yesterday.)

Tim, what's your take?

Will your clients that are FFELP schools be better off moving to the Direct Loan school? Will they be better off having absolutely no choice in the matter?

Will your clients that are in the Direct Loan program be better off if the department no longer has any competition from FFELP? Over the long term do government bureaucracies do a better job than the private sector? Do government bureacracies do a better job when there is a private sector alternative?

Is the nation better off that FedEx, UPS, DHL, etc. exist and compete with the Post Service?

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