The bill reinstates in-school loan consolidation. Can borrowers only consolidate FFELP, ECASLA, and Direct Loans while they are in school?
NASFAA believes that the legislative language is not meant to restrict which loans can be consolidated, only which borrowers may consolidate while they are in school. Borrowers may obtain a Direct Consolidation loan between July 1, 2010, and July 1, 2011, while they are in school only if they have loans in at least two of in the following categories: the Direct Loan program, the FFEL program, and loans purchased by the Department under ECASLA. At least one of those loans must not yet have entered the repayment period. If borrowers qualify for an in-school consolidation, they will likely be able to consolidate all of their Title IV loans – including Perkins – into that consolidation loan. The Department of Education is in the process of confirming this interpretation.