In this report, we develop a comprehensive set of benchmarks that provide reasonable criteria for allowing postsecondary institutions to award federal student aid. To develop these guidelines, we look to existing legislation and regulations in the US, policies that have been proposed but not implemented, and regulations in Canada. We discuss the logic behind potential benchmarks, seeking ways to ground the benchmarking in evidence about the probabilities that borrowing will be a sound investment. We leave the design of specific policies that could operationalize these benchmarks to future work.
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