There is plenty of blame to go around for the student-loan-debt debacle, and the Consumer Financial Protection Bureau along with the Departments of Education and Treasury are particularly interested in the role that the loan-servicing industry has played.

In its recent report on student loan payment performance, the CFPB analyzed some 30,000 comments it received from borrowers, financial services providers, law enforcement officials, banking regulators, policy experts and organizations that represent students, lenders, servicing companies and, of course, the schools.

The crux of the matter, according to the bureau, is that “there are no consistent, market-wide federal standards for student loan servicing and servicers generally have discretion to determine policies related to many aspects of servicing operations.” Hence the myriad complaints about incomplete or inaccurate information, payment processing issues and other problems—which vary in degree among loan-servicing companies—that contribute to the extraordinarily high level of payment delinquency and loan default that is emblematic of the second largest form of consumer-financing in the U.S.

The bureau’s report culminates in a series of reform recommendations to policymakers and a jointly issued statement of principles on student-loan servicing by the bureau and its governmental department collaborators: Servicers are to be consistent in their approach to the tasks at hand; information and recommendations are to be accurate and actionable; all servicers (for-profit and not-for-profit alike) will be held accountable for their missteps, and higher-quality performance-related data is to be made freely available.

The thing that most bothers me about this and earlier reports on the matter of loan-servicing malfeasance is the notion that servicers are exclusively at fault.

Don’t get me wrong. From all that I’ve read and heard firsthand from debtors who are actively dealing with many of the issues cited in the CFPB report, it’s hard not to conclude that even if they aren’t deliberately deceitful, some of these companies are at the very least hopelessly incompetent. But what about those who also stand to benefit from these injurious practices?

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Mitchell D. Weiss