SSN Public Comment

This Proposed Rule will Disproportionately Harm Black and Latinx Student Borrowers

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University of North Carolina at Chapel Hill

Below is an excerpt from a public comment submitted to the U.S. Department of Education in regard to the Notice of Proposed Rulemaking (NPRM) titled  “Reimagining and Improving Student Education,” on March 1, 2026. 

Dear Secretary McMahon, 

Thank you for the opportunity to comment on the Notice of Proposed Rulemaking (NPRM) titled  “Reimagining and Improving Student Education,” published in the Federal Register on January  30, 2026 (91 Fed. Reg. 4254). 

I am a leading scholar of debt and wealth inequality and a Professor of Public Policy at the  University of North Carolina at Chapel Hill. My research program has been dedicated to  understanding how structural inequalities shape financial security, social mobility, and family  dynamics, with a particular focus on racial disparities in student debt and the reproduction of the  racial wealth gap through consumer lending. I am the co-author of A Dream Defaulted: The  Student Loan Crisis Among Black Borrowers (Harvard Education Press, 2022), which centers the  lived experiences of Black borrowers within the broader student debt landscape.