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On July 4, 2025, the One Big Beautiful Bill Act (OBBBA) was signed into law, resulting in changes to federal student aid programs. Some of these changes went into effect immediately, while others will go into effect in 2026 and beyond. On May 1, 2026, the U.S. Department of Education (ED) published a final rule concerning most of the loan-related provisions in the OBBBA.

If a student meets certain requirements, they will have a period of time after July 1, 2026, and before the new regulations apply during which they may be eligible for a Federal Direct Loan or Graduate PLUS loans under the pre-OBBBA limits. This is called the "interim exception" or legacy status.

If a student qualifies for the interim exception/legacy status, they are exempt from certain loan limits and loan eligibility changes for the lesser of:
  • three academic years/6 terms, or
  • the difference between the published length of the program of study in which they are enrolled in (3 years) and the period of time remaining to complete that program.

For current students, the Financial Aid Office will determine if they are qualified for the interim exception/legacy status for the Federal Direct Loan Program or are subject to the new regulations.

Under the new regulations, students starting after July 1, 2026 and some current students are limited to borrowing $257,500 in federal student loans over their lifetime. This includes Federal Perkins Loans, Direct Subsidized/Unsubsidized loans at both the undergraduate and graduate levels, and Graduate PLUS loans.

If federal financial aid, scholarships, and other funding sources do not fully cover the cost of attendance, students may consider private lender loans to meet the remaining need. Current and incoming students may review additional information on private loans on the internal student portal, Cooley Connect.

 

Factors to Consider When Selecting a Private Lender Loan

Students may choose any lender, and the school will process the loan certification promptly regardless of the selection.

Consider using federal loan options as a first funding source as federal student loans typically offer more favorable terms, borrower protections, and repayment options than private loans.

Compare private lender loans carefully using platforms like the AccessLex Private Loan eXchange to use side-by-side comparisons to review interest rates, loan terms, co-signer requirements, and repayment features without affecting credit score. Note that interest rates, fees, and loan terms can vary widely.

Before borrowing, consider ways to manage or reduce expenses to borrow only the amount needed for education-related costs.

For additional information about federal and private student loans, visit StudentAid.gov or see an Associate Director of Enrollment and Students Services.

 

Private Loan Process Steps

1. Apply for a private loan with the selected private lender.

2. Complete all required lender application and credit approval steps, including any self-certification forms.

3. Cooley will certify your loan based on enrollment and cost of attendance.

4. Log on to your Cooley financial aid portal, JFA, to accept the loan offer after receiving an Offer Notice email from Cooley.

5. Complete the federally-required waiting period.

6. The selected private lender will send funds to Cooley and the funds will be applied to the student account. As this process involves multiple reviews and a waiting period, students should plan for funds to be applied 3-4 weeks after loan certification.