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Various commenters argued which the adjustments to REPAYE violate the key questions doctrine and would violate the constitutional principal of separation of powers. They pointed to your ruling in West VirginiaJust one commenter stated that our proposals for that revised REPAYE strategy don't contain a regular payment cap and that, for some borrower
Like a reaction to our request for feed-back [seventy eight] on whether or not we must always involve comparable deferments for Direct Loan borrowers with exceptional balances on FFEL loans manufactured in advance of 1993 toward IDR forgiveness, some commenters responded with the perspective that we should involve time spent on these deferments t