The One Big Beautiful Bill Act (OBBB/OB3), passed by Congress and signed into law on July 4, 2025, contained several provisions impacting federal student loans. Many common questions are highlighted below. Unless otherwise noted, these changes will be effective July 1, 2026.

Learn more about these changes.

  • What is a legacy borrower or interim exemption?

    You may continue to borrow under the current rules (including PLUS loans up to the Cost of Attendance) for up to three additional years or until the expected time to completion, whichever comes first, if you meet BOTH of the following criteria:

    1. You are enrolled in the same credentialed program at Catholic University in 2026–27 that you were enrolled in prior to July 1, 2026.
    2. You borrowed a federal student loan (Subsidized, Unsubsidized, or PLUS) for that specific program at The Catholic University of America, and the loan was disbursed before July 1, 2026.
      1. Parent PLUS: Parents who have already borrowed a Parent PLUS Loan before July 1, 2026 for that specific program, or students who already borrowed a Direct Loan prior to July 1, 2026, will still be able to borrow according to current rules - even if they didn’t borrow that exact type of loan previously.

    If you change programs or start a new degree after July 1, 2026, you will be subject to the new limits.

  • What is my loan eligibility if I am not full-time?

    OB3 uses a "fractional" math formula. Your annual loan limit is multiplied by the percentage of a full-time load you are taking.

    Undergraduate Example: If full-time is 24 credits per year and you take 12 credits (half-time), you are eligible for 50% of your annual limit.

    Graduate/Legacy Professional Example: If your program considers 16 credits a full year and you take 8, you are eligible for 50% of the $20,500 limit ($10,250).

    New Professional Example: If your program considers 16 credits a full year and you take 8, you are eligible for 50% of the $50,000 limit ($25,000).

  • What is time to completion/credential?

    The expected time-to-credential calculation begins on July 1, 2026, and is the lesser of three academic years or the difference between the program length and the period of such program of study that such individual has completed prior to July 1, 2026.

  • Is the expected time to credential the same as the student's graduation date?

    Is the expected time to credential the same as the student’s graduation date?

    No. The expected time to credential is calculated beginning on July 1, 2026, and it is the lesser of three academic years or the difference between the program length for the program of study in which the individual is enrolled and the period of such program of study that such individual has completed prior to July 1, 2026. Program length is defined as the minimum amount of time in weeks, months, or years that is specified in the catalog, marketing materials, or other official publications of an institution for a full-time
    student to complete the requirements for a specific program of study. In some cases, this will be before the student’s actual graduation date.

    Expected time to credential is measured in academic years.

  • Can a student lose their legacy status?

    Yes – There are 3 ways a student can lose their legacy status:

    • A student changes their program
      • Undergraduate student loss of legacy: the student would have to change their program type. Example: Switching from a Bachelor of Science to an Associate of Arts
      • Graduate/Doctoral student loss of legacy: the student would have to switch to a program outside of their current program’s four-digit Classification of Instructional Programs (CIP) code.
    • Failing to maintain continuous enrollment – A student must be enrolled every fall and spring semester in each academic year. The summer semester is considered optional.
    • Completing a Total Withdrawal or taking a leave of absence

  • I am only enrolled in one course in a term. Can I withdraw from it and still keep my legacy status?

    No – you would lose your legacy status, because withdrawing from your only course in a term would be considered ceasing enrollment or completely withdrawing from the term. This applies to capstone/dissertation courses as well.

  • If I just transferred into Catholic University and I qualified for the legacy status at my last school, will I still qualify for legacy?

    No – transferring into Catholic University or to another school will cause a loss of legacy status.

  • I was an M.Div., J.D., or Psy.D. student at Catholic University prior to July 1, 2026. Can I borrow unsubsidized loans at the higher annual limit after July 1?

    No – your unsubsidized annual loan limit would remain at the legacy limit of $20,500 annually unless you lose legacy status.

  • I am legacy student but was not able to borrow Graduate PLUS Loans in the 2025-26 academic year, due to there being no room in my cost of attendance. Am I eligible to borrow a Graduate PLUS Loan in the 2026-27 academic year?

    Yes – as long as you had another federal student loan disbursed prior to July 1, 2026, for the same academic program at The Catholic University of America that established your legacy status, you are eligible to borrow. It did not have to be a Graduate PLUS Loan specifically. The loan would still have to fit into your cost of attendance to be eligible.

  • What is Lifetime Loan Limit?

    The lifetime loan limit for all borrowers is $257,500. This is the maximum amount a borrower can receive, regardless of any amounts paid or discharged, in any combination of subsidized, unsubsidized, and PLUS loans for graduate or professional study. Learn more.

  • What may be a professional degree program?

    The Department of Education has issued temporary guidance regarding eligible professional degree programs in response to a court order. Because this remains in active litigation, eligibility requirements may change as the case proceeds. For the most current information, please refer to the Department’s latest guidance: GENERAL-26-42 Update to List of Professional Programs Due to Court Order.

  • If a Student Loses Legacy Eligibility, Do PLUS Amounts Previously Borrowed Count Towards the New Parent PLUS Aggregate Limit?

    Yes. The regulatory text for all of the aggregate loan limits refers to the amount the student or parent can borrow “for a period of enrollment beginning July 1, 2026.”  The new aggregate loan limits begin applying on July 1, 2026, and because aggregate loan limits are cumulative, loan amounts borrowed prior to July 1, 2026, will apply to the new aggregate amount borrowed by or on behalf of the student throughout their studies.

  • Is this final?

    The Dept. of Education has instructed all universities to implement these changes after July 1, 2026. These changes are still being worked through the Department of Education and Federal Student Aid. Interpretations of federal statute may change.