150713_cfpb_servicing.pdfThis comment letter responds to the Consumer Financial Protection Bureau (CFPB) request for information on student loan servicing, in particular its questions on data. The letter draws upon lessons from the Home Mortgage Disclosure Act and the National Mortgage Database in order to make recommendations on expanding public data on student loans. In particular, the letter urges the CFPB to include granularity, timeliness, borrower demographic information, borrower and co-signer financial characteristics, school characteristics, loan characteristics, and loan performance data in any expansions of public student data.