Imagine a simple form you fill out to tell the government your school tricked you, and you want your student loans forgiven. That form used to be about 21 pages, but now the official Borrower Defense to Repayment (BDR) application has grown to about 39 pages.
You might wonder: Why so many more pages?
And more importantly — how does that affect whether your claim gets approved?
Short answer:
The U.S. Department of Education added more questions to make sure they collect enough specific information so they can fairly decide if your school committed misconduct and how much your harm was. More detailed questions = longer form.
Before we talk about the length, let’s be very clear about what this is:
➡️ It’s the official form you use to ask the U.S. Department of Education to forgive your federal student loans because your school misled you, lied about jobs, costs, or outcomes, or otherwise did something wrong.
📈 Why the Form Got Longer — The Big Picture
Here are the main reasons the BDR form expanded:
The Department added questions that ask:
Government reviewers need details — not just feelings — to decide if the laws were broken.
Borrower defense rules have changed over time through regulations and court cases. The Department updated the application to reflect those changes so they can properly evaluate each claim.
These include:
The new application form doesn’t just ask what happened — it now asks when it happened, because the rules change based on your loan period.
| Loan Period | Qualifying Misconduct | Key Changes from Old Form |
|---|---|---|
| Pre-July 1, 2017 | Misleading statements/acts important to enrollment decision, causing harm, and suable under state law (consumer protection statutes primarily). No omissions, aggressive recruitment, or breach mentioned separately. | Adds state law requirement (not in old form). Old form doesn't differentiate periods. |
| July 1, 2017 - June 30, 2020 | Misleading statements/acts or omissions/concealments important to enrollment, causing harm. Limited to employment outcomes, educational programs, financial charges. Judgments (only non-default, favorable, contested; no settlements). Breach of contract if obligations were key to decision and caused harm. | Similar to old but excludes aggressive recruitment (present in old form as a category). Specifies no settlements for judgments (old allows any favorable judgment). Omissions explicitly included. |
| July 1, 2020 onward | Only misleading statements/acts with school's knowledge of falsity/deception, important to enrollment, causing financial harm. Limited to three areas (employment, programs, charges). No omissions, aggressive recruitment, judgments, or breach. | Stricter: Requires "knowledge" and "financial harm" (old form uses general "harm"). Removes categories like aggressive recruitment (in old form: pages 2, 13-14), omissions, judgments, and breach. Adds financial harm section with examples (e.g., unemployment not due to recession, reduced earnings). |
The 2025 Borrower Defense application introduces a brand-new category of misconduct:
Misleading statements made by your school to third party organizations.
This includes false or deceptive claims your school may have made to:
Why this matters:
These external representations impact not just your experience, but public perception, funding, and eligibility rules — and the government wants to know if your school misled outsiders to benefit unfairly.
If your loan was first disbursed on or after July 1, 2020, you must now complete an entirely new section about financial harm — Section 5a.
This section matters more than ever because it asks:
What the Department wants:
To avoid applications being sent back as “incomplete,” the new form asks for:
This saves you time later — and reduces denials due to missing evidence.
Longer forms aren’t meant to frustrate you — they help the reviewer see your story better.
This means you might need more time to gather your files — but that also means fewer denials because of missing information.
If you don’t fill out the details now, your form could be returned or delayed — costing time and relief. https://www.law.cornell.edu/cfr/text/34/685.206
The extra pages help the Department:
That’s why the legal community — including courts and advocates — keep discussing how the BDR rules work and how the Department applies them.
📌 Related Resources
➡️OUR DIY Guide to Borrower Defense:
https://defenseclaims.com/borrower-defense-diy-guide
➡️Schools with proven misconduct issues:
https://defenseclaims.com/usable-misconduct
➡️Full list of colleges & universities:
https://defenseclaims.com/all-universities
The Department didn’t add pages just to make it longer. They added them to:
If you’re serious about student loan forgiveness, take the time to fill out the full application carefully at your own using our DIY guide or contact us for an eligibility check.
The highest level of education and consulting in Borrower Defense for Student Loans.
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