During loan repayment, Direct Loan borrowers are subject to loan servicing by ACS (a Xerox company).
ACS misrepresents the Dept. of Education, Direct Loans, and the rights of borrowers. Specifically, the right to prepay any part at any time is violated, e.g., loans with higher interest rates:
Direct Loans Master Promissory Note,
"I may prepay all or any part of the unpaid balance on my loans at any time without penalty"; and
Higher Education Act of 1965,
"entitles the students borrower to accelerate without penalty repayment of the whole or any part of the loan..."
These rights must be reaffirmed, implemented, and communicated to borrowers.
Borrower rights should be expanded, e.g., Credit Card Act, "Excess payments must always be allocated first to the balance with the highest rate."