Five Potential Key Impacts of CARES Act Expiration for Students and Schools The CARES Act was a necessary and positive action to help students and families through this unprecedented time. When student loan repayment suspension ends, it will set up an unusual set of challenges for students and the Financial Aid Office. This article outlines five overlying potential challenges as they relate to students and financial aid offices. As a reminder, FFEL Loans and private loans held by lenders are not included in these changes. All delinquent borrowers as of March 13, 2020 were brought current and will be kept current until the suspension expires. Everyone not making payments before March 13 were brought current without having to do anything. Some of these borrowers may have been on the verge of default and may not even know their loans are now current. On the suspension expires, they will all reenter repayment at roughly the same time. For those that were on the edge of default, it will have been more than a year since they have done anything on their student loans. Some borrowers were in a suspended status such as a deferment or forbearance. These borrowers started that suspension before March 13, 2020, and should have come out of that status before the end of the suspension. Since the servicers are ensuring that no borrower goes beyond 31 days delinquent, these borrowers may forget that they had payments coming due. With the provisions of the CARES Act, these borrowers may not be engaged until after the suspension expires. Massive job loss for both student borrowers and parents. It is likely there will be more borrowers unable to start repayment. The CARES Act is providing temporary relief, but borrowers will need to determine a repayment plan option that fits within their budget once the Act expires. Increased number of borrowers renewing IDRs at the same time. Under guidance from the United Stated Department of Education, IDR plans that expire after March 13, 2020, but before the Act expiration will automatically have their renewal deadline extended. This could be for up to six months after the original expiration or only through the Act expiration. Based on previous experience with natural disasters, it is predicted that when repayment resumes, there will be an influx of delinquent borrowers. These borrowers will be more challenging to resolve because all borrowers who could not, or chose not to, make payments, will reenter repayment at the same time. Restarting all at once will likely result in a large number of borrowers becoming 60 days delinquent at the same time creating a larger number of borrowers requiring repayment guidance at once.