Below is a copy of the letter Democrats Abroad sent to the Department of Education and Financial Student Aid about the Federal Student Loan Relief application form being inaccessible for Americans Abroad. Democrats Abroad strongly encourages Americans abroad impacted to contact their Members of Congress.
Dear Deputy Secretary Marten, Acting CIO Peters, COO Cordray, and Principal Deputy COO Malague:
Democrats Abroad is a volunteer-led organization and is the largest U.S. citizen organization outside of the United States. We thank you for your leadership within the Biden Administration, and we write to you today in a non-partisan capacity on behalf of our 200,000 members and the 9 million Americans living abroad.
In addition to confirming reports in the media, we have received hundreds of reports from eligible members residing outside the U.S. who have been unable to access the online Federal student loan relief application form at https://studentaid.gov/debt-relief/application
We have been advised by our Congressional contacts that the Dept. of Education and Federal Student Aid are aware of and working to resolve the issue. However, we are concerned that the online application form has been available for a week and the problem has not been remedied. We would greatly appreciate the opportunity to speak with you on a call to inform you of the problems this has caused for Americans abroad, offer our aid in fixing the form, and discuss how we can prevent this from happening again.
Some of our concerns include:
Geo-blocking the application form provides a false sense of security while depriving Americans abroad of an essential service
We understand the need for security, but geo-blocking citizens worldwide who have a federal student loan is not effective or acceptable. This harms legitimate users of the website while presenting no significant barrier to malicious attackers. There are trivial means by which attackers can purchase a U.S. Virtual Private Network (VPN) or rent a U.S.-based computer to launch an attack.
In short, geo-blocking is security theater of the worst kind: any motivated attacker’s anonymity precautions would bypass a “U.S. Only” IP filter while actual citizens residing abroad would be unable to access the online application for loan forgiveness. If a VPN is considered as a workaround for legitimate access, it is also a workaround for malicious access.
Recommending VPN use poses often unnecessary risks to citizens
Congressional offices have suggested using a U.S.-based VPN to access the online application form. This is also not acceptable. Sensitive data, especially social security numbers, should not be processed over an untrusted VPN or any “in the middle”" proxy.
Americans abroad cannot be commonly expected to know whether the VPN they are using is reputable or safe. It is almost a certainty that free VPNs, likely to be used by the least savvy individuals, are not.
To avoid potential interception of sensitive personal information up to and including people’s social security numbers, it is best to allow direct access over a standard web browser session rather than encouraging the use of a service capable of data interception. For a more secure session, access could be restricted to authenticated user sessions established over the existing FSA ID login system.
Accessing the application from a U.S. Embassy or Consulate is not an option
Visiting a U.S. Embassy or Consulate to access the online form has also been suggested, but most U.S. Embassies and Consulates forbid visitors from bringing or using electronic devices into the building. It is not possible for ordinary citizens to use an Internet connection provided by the State Department. We have also received reports that some Embassies have not been able to access the online form, so it’s simply not a viable option.
Form should not require a U.S. phone number
We have also received reports that, once the form is accessible, a U.S. phone number is required. Not all citizens living abroad have a U.S. phone number. Most have only a phone number in the country where they live. Please change the settings on the application form to allow any global phone number to be entered.
Mailing or faxing a paper application form is not a suitable alternative
We understand that a paper application form will be made available for mailing or faxing, but citizens abroad overwhelmingly prefer to transmit confidential information online. It is the easiest, fastest, and most reliable way.
Postal services abroad are often unreliable and costly, and most citizens abroad do not have access to a fax machine, particularly one that supports international faxing.
So again, for those with non-U.S. IP addresses, an accessible online application form is needed as soon as possible along with notification of the update for affected users.
Time is running out. Citizens abroad are desperate to apply for relief to reduce their payments before payments and interest resumes January 1, 2023. Removing the geo-block is the best and safest way to ensure that they can do so as easily as Americans living inside of the U.S.
We would greatly appreciate it if you could contact Rebecca Lammers from our leadership team at [email protected] with an estimate of when these problems can be resolved, and let her know if a call would be helpful.