Overview:
The OBBBA [PDF] was signed into law on July 4, 2025.
The Department of Education released final regulations regarding Federal Student Loan Program changes on May 1, 2026.
This legislation impacts Federal Student Aid programs, including Federal Student Loan repayment plans, Federal Student Loan limits, Federal Parent PLUS Loans, and Federal Graduate PLUS Loans. These changes are effective on July 1, 2026.
Parent PLUS Loan Legacy Provisions:
To qualify for the legacy provision, a student must meet all of the following criteria:
Program of Study
The student was enrolled in a program of study** before July 1, 2026.
**Program of Study – Undergraduate: For students enrolled in an undergraduate program and who had a federal student loan disbursed prior to July 1, 2026, the program of study refers to their credential level at Syracuse University.
- If a student enrolled in a bachelor’s program at Syracuse University before July 1, 2026, they may maintain legacy status during the course of their bachelor’s program (even if they change their major).
- Similarly, if a student enrolled in an associate’s degree program at Syracuse University before July 1, 2026, they may maintain legacy status during the course of their associate’s degree program, but will not be granted legacy status if they change to a bachelor’s degree program.
- If a student enrolled in an associate’s or bachelor’s degree program at Syracuse University before July 1, 2026, and the student transfers out of Syracuse University, they will not maintain legacy status at their new institution.
Federal Loan Disbursement
The student had a federal subsidized/unsubsidized student loan or federal parent PLUS loan for their program of study disbursed before July 1, 2026.
Student-Specific Criteria
Legacy provisions for Parent PLUS borrowers are specific to each student*, who must have been enrolled in a program of study** before July 1, 2026.
*Legacy provisions do not apply to other dependent students, unless they were also enrolled in a program of study as of June 30, 2026, and received a loan or a loan was received on their behalf for that program of study**.
Expected Time to Credential
This legacy provision allows them to continue borrowing from the program for:
- Three academic years; or
- the period determined by calculating the difference between—
(i) the program length for the program of study in which the individual is enrolled; and
(ii) the period of such program of study that such individual has completed as of the date of the determination - whichever is less.
Cannot Cease Enrollment or Withdraw
If the student ceases enrollment or withdraws from the university and does not re-enroll in their program of study before June 30, 2026, the legacy status no longer applies, and the new limits take effect immediately.
FAQs:
- What are the new limits if I don’t qualify for legacy status?
- Parents are limited to $20,000 per year per dependent student, with a combined lifetime maximum of $65,000.
- Will I keep legacy status if I change my major?
- Undergraduate students: Yes, as long as you remain in the same degree program
- Does legacy status transfer to other siblings entering college?
- No. Legacy status is tied to the specific student and program. A sibling entering college will be subject to the new borrowing caps.
- Can I lose my legacy status?
- Yes. If the student withdraws, transfers to a different university, changes their degree program (ex: bachelor’s to master’s), completes their program of study, or exceeds the expected time to credential, then legacy eligibility is forfeited.
- Can I appeal the loss of my legacy provisions?
- No. The Department of Education is not allowing any appeals or extensions to the legacy provisions.
- How does withdrawing from the University impact my loan eligibility and my expected time to credential?
- Any student who withdraws entirely from the University or ceases all enrollment will lose all legacy provision eligibility.
- Any term that a student did not complete prior to July 1, 2026, does not count towards expected time to credential.
- A term that was “not completed” means the student did not earn any credits for the given term. An earned grade of “F” is considered an earned credit(s) for the term.
- How is the “expected time to credential” determined?
- The expected time to credential is based on the length of the program measured in academic years for a full-time student to complete. The expected time to credential starts at the time the student began their program, regardless of how much time they anticipate needing to complete their program.
- Most bachelor’s degrees are four-year programs (other than the 5-year B.Arch in the School of Architecture). Therefore, a student who began a bachelor’s program in the fall of 2024 would only qualify for two years of legacy loan provisions.
- Fall 2024 (program start) – Spring 2025: Year One
- Fall 2025 – Spring 2026: Year Two
- Fall 2026 – Spring 2027: Year Three
- Fall 2027 – Spring 2028: Year Four
- If a student transfers credits from another institution or transfers credits earned in high school, this may shorten the expected time to credential.
- How do transfer credits or AP/IB/Dual Enrollment credits impact my expected time to credential?
- We are still awaiting guidance from the Department of Education on the treatment of AP/IB/DE and other transfer credits and their impact on expected time to credential.
- What happens if a student eligible for the legacy loan provisions takes longer than the three additional years or their “expected time to credential” to complete their current academic program?
- There are no extensions to the legacy loan provisions and no appeals for legacy provisions. At the end of your eligibility period, you will be subject to the new annual, aggregate, and lifetime loan limits.