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One particular commenter thought that our proposed adjustments to your IDR program give undergraduate borrowers a grant in lieu of a loan. This commenter asserted that It might be superior to provide the money upfront as grants, which can positively influence obtain, affordability, and achievement.

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Commenters argued the modifications to REPAYE would violate the vesting clause by creating an unconstitutional delegation of legislative electrical power into the Office. They claimed that the Department's looking through with the authority granted from the 1993 HEA provision is overly wide and lack

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