u/Altruistic-Impact225

Quick note for the community. Standard caveat first: I'm not a lawyer and I'm not a financial advisor. I'm a SAVE borrower posting this because I know people are confused, and the more clearly, we can read what the DOED is actually saying versus what it wants us to hear, the better. You can check my account for previous posts on the SAVE litigation and the RAP rollout if you want the longer analysis.

The "Second Notice" email that went out today is functionally identical to the first March 31 notice. Worth reading carefully, because the email contradicts its own urgency. The headline tells you SAVE has ended and you must select a new plan. Paragraph two admits "your loan servicer will contact you about your specific deadline" and that you'll have 90 days from that contact to choose. RAP and Tiered Standard are not available until July 1, which is still six weeks away. Additionally, at the bottom of the email, there is an unsubscribe option. An official notice would not include this option.

On the legal side, as you know I have been tracking the Missouri v Trump Case which the early sunsetting of SAVE hinges on. I just checked the docket in Missouri v. Trump (4:24-cv-00520-JAR) has been silent since the April 6 filing. Nothing has changed legally between the first notice and this one. If you haven't received a written notice from your actual servicer with a real deadline, the procedural reality is that you don't have one yet.

I am continuing to hold pat and wait for an official notice to hit my inbox then reassess. There is a lot up in the air from the ongoing cases to active petitions, with a critical election this November. I won't tell you what to do as choice is based on an individual situation, but I am providing this information so you can make the decision that best suits you.

If you have been following my posts, you know I have been closely following the chaotic legal battle behind the SAVE plan. Today I want to post about something else. The Repayment Assistance Plan, or RAP. What is it? Why is the Department of Education so hell bent on pushing it? And most importantly, the truth about who it will likely hurt most.

To start, what exactly is RAP? The RAP is the Trump Administration's answer to the student loan crisis, included in the One Big Beautiful Bill Act.

Right now, the Department of Education is pushing borrowers toward it. Social media is full of lawyers, financial advisors, and commenters on these boards are all saying the same thing. Get on RAP. It is the safe choice. It is the new plan. It is what the government is offering. But is it actually better. And better for whom?

I sat down with the bill text and ran the numbers. Here is what I found.

RAP is the ideological opposite of SAVE. SAVE was built on the philosophy that debt should not be a life sentence. The formula exempted 225 percent of the federal poverty line from your payment calculation. For millions of borrowers that meant zero dollars a month. Not because they were getting away with something. Because Congress decided that keeping a teacher in the classroom was worth more than extracting a payment from someone who could not afford one. RAP is built on a different philosophy. The tiered percentage sounds compassionate but it never goes to zero. The minimum payment is $10. Everyone pays. Always.

RAP calculates your monthly payment as a percentage of your adjusted gross income on a sliding scale. If you have a dependent, subtract $50 a month per dependent.

• Up to $10,000 AGI: $120 flat
• $10,001 to $20,000: 1 percent of AGI
• $20,001 to $30,000: 2 percent
• $30,001 to $40,000: 3 percent
• $40,001 to $50,000: 4 percent
• $50,001 to $60,000: 5 percent
• $60,001 to $70,000: 6 percent
• $70,001 to $80,000: 7 percent
• $80,001 to $90,000: 8 percent
• $90,001 to $100,000: 9 percent
• Over $100,000: 10 percent

At first glance, even I will admit, the scale looks fair on its face. Lower income borrowers pay a lower percentage. Higher income borrowers pay more. Simple and fair in theory.

So why have policy analysts and borrower advocacy groups been so blunt in calling it out?

• They have called RAP "not much of a safety net" and warned that borrowers will likely be trapped in a draconian collections system.
• They argue that similar income driven plans have historically functioned as cruel jokes where most people are eventually disqualified, and they expect RAP to behave the same way.
• The formula is poorly designed and creates cliff effects. A small raise in salary can trigger a disproportionate spike in monthly payment.
• Unlike previous plans that allowed for $0 payments at low or no income, RAP requires a minimum payment of $10 even if you are unemployed or facing extreme hardship.
• RAP extends loan forgiveness to 30 years, effectively trapping the lowest income borrowers in debt for decades.

Here is what the math actually does.

RAP is regressive on the low end. At $10,000 AGI the payment is $120 flat. That is 1.44 percent of total income going to loan payments before taxes, food, or rent. Federal minimum wage at $7.25 an hour equates to roughly $15,000 a year on a 40 hour schedule. Median rent in this country is $1,700 a month, $20,400 a year. With an already widening wealth gap, that additional $120 a month can mean the choice between food and electricity. Under SAVE that borrower paid zero.

A teacher in Wisconsin making $45,000 a year had a $0 payment under SAVE. Under RAP she pays roughly $150 a month, $1,800 a year, before any other expense. These are the people responsible for molding the next generation of professionals.

A single mother working in public health in Detroit making $38,000 had a $0 payment under SAVE. Under RAP she pays roughly $95 a month. Her dependent deduction at $50 per child does not close the gap.

A first-generation college graduate working at a nonprofit in rural Alabama making $32,000 had a $0 payment under SAVE. Under RAP she pays roughly $80 a month.

Now look at the flip side. The borrowers the Trump Administration scapegoated as the reason SAVE was unfair. The Ivy Leaguers, the PhDs, the lawyers, the financiers, and the tech bros. Under RAP a borrower with $220,000 AGI pays roughly $1,833 a month, basically identical to the Tiered Standard 25-year payment. Under SAVE the payment was comparable but came with a real safety net for higher earners who lost a job, took a pay cut, or hit unforeseen hardship.

It is safe to conclude that the borrowers hurt by this transition are not the ones the administration says they are.

Interest safeguards are no more. Under SAVE, if your payment did not cover the interest that month the government ate the difference. Your balance never grew. Under RAP there is an interest subsidy but only if you make your required payment, and the mechanism is more complicated and less protective. Balances will grow for borrowers who miss a payment or whose payment does not cover accruing interest.

The forgiveness timeline from 20 to 30 years. RAP forgiveness comes after 360 qualifying payments. That is 30 years. SAVE was 20 years for undergraduate borrowers. That is a full decade of additional payments for the lowest income borrowers, the ones closest to the finish line. Hence the decades long debt trap. Community college graduates with $15,000 in loans who were 8 years into a 20 year forgiveness timeline are now looking at 30. Public service workers close to PSLF who were in SAVE forbearance are now losing credit toward their 120 qualifying payments.

The dependent deduction is inadequate. $50 per dependent per month. A single mother with two kids gets $100 off her payment. That is not meaningful relief for someone making $25,000 a year.

Who is being hurt? As is typical, the people being hurt are hardworking Americans who are already barely making ends meet. The teachers. The nonprofit workers. Our government workers. The TSA agents. The nurses in training. The service industry workers. The first generation Americans. The everyday person trying to make an honest living in this country.

They are who this hurts. Not the Ivy Leaguers. Not the highly educated. Not the financiers. And certainly not the tech bros. As usual for this administration and the constructive conservatives that preceded them, the BBB benefits the rich with tax cuts while hurting the everyday working American.

The political framing is wrong. The administration has framed SAVE as a bailout for elite borrowers, the Ivy League debt the Missouri Attorney General invoked in his Wall Street Journal op-ed. That framing is deliberately misleading. The people most devastated by SAVE's elimination are not lawyers with $300,000 in debt. They are teachers, public health workers, nonprofit employees, community college graduates, and first generation students whose entire family wealth went into making them the first one to walk across a stage with a degree.

RAP versus SAVE is being framed as a legal dispute. It is a class issue dressed up in legal clothing. Further, starting this year, all new borrowers lose access to the previous repayment plans. RAP will be their only option, making higher education more of a privilege and not a right.

What to do with this. Do not let the Department of Education's framing be the only one you hear. Read the bill. Run the numbers on your own income. Compare RAP to the Tiered Standard Plan and to whatever IBR or PAYE option may still be available depending on your loan history.

If you are in SAVE forbearance right now, do not voluntarily switch plans before MOHELA or your servicer sends you a specific written notice telling you to act. Administrative forbearance is buying time for the litigation to play out. Time is the most valuable asset borrowers have right now.

If you are a low-income borrower who would have qualified for a $0 payment under SAVE, RAP is not assistance. It is a payment you cannot afford rebranded as a benefit.

Ask who that serves.

Solidarity Forever.