President Trump Publishes Executive Order Limiting Public Service Loan Forgiveness & Will Likely Publish Another Executive Order This Week Outlining Restructuring of the Department of Education

Overview
Late in the day last Friday, March 7th, President Trump released a new Executive Order (EO) entitled, “Restoring Public Service Loan Forgiveness (www.whitehouse.gov/presidential-actions/2025/03/restoring-public-service-loan-forgiveness/) .” The stated purpose of the EO was to uphold the President’s responsibility to, “protect, preserve, and defend the Constitution and our national security, which includes ending the subsidization of illegal activities, including illegal immigration, human smuggling, child trafficking, pervasive damage to public property, and disruption of the public order, which threaten the security and stability of the United States.”

Concluding, “it is the policy of my Administration that individuals employed by organizations whose activities have a substantial illegal purpose shall not be eligible for public service loan forgiveness.”

In order to achieve the stated purpose of the EO, the declaration directs the Department of Education, in coordination with the Secretary of the Treasury, ensures that the definition of “public service” excludes organizations that engage in activities that have a substantial illegal purpose.

The EO defines organizations engaging in substantial illegal purposes as:

  1. aiding or abetting violations of 8 U.S.C. 1325 or other Federal immigration laws;
  2. supporting terrorism, including by facilitating funding to, or the operations of, cartels designated as Foreign Terrorist Organizations consistent with 8 U.S.C. 1189, or by engaging in violence for the purpose of obstructing or influencing Federal Government policy;
  3. child abuse, including the chemical and surgical castration or mutilation of children or the trafficking of children to so-called transgender sanctuary States for purposes of emancipation from their lawful parents, in violation of applicable law;
  4. engaging in a pattern of aiding and abetting illegal discrimination; or
  5. engaging in a pattern of violating State tort laws, including laws against trespassing, disorderly conduct, public nuisance, vandalism, and obstruction of highways.

While no details are provided on how the EO will be enforced, it is anticipated that the Department of Education, and possibly the Department of Treasury, will provide initial interpretation guidance detailing how these organizations will be identified, and how the borrowers will be notified of their removal from eligibility under the Public Service Loan Forgiveness program.

What’s Next
CSPEN will continue to monitor and provide additional information on this latest EO, as we also await a more expansive EO that was rumored to be prepared for publication last week, but was not released. The rumored EO is the widely anticipated declaration from President Trump providing the details on how the President intends to fulfill his campaign promise to eliminate the U.S. Department of Education – returning many of the current responsibilities of the Department to the states (predominately in Elementary-Secondary Education) and considering was to allocate the existing responsibilities of the Department to other cabinet agencies, including the Department of the Treasury, Commerce, and/or the Small Business Administration.

CSPEN continues to monitor very closely the ongoing reports of the imminent release of the EO, will immediately notify the community upon its release, and provide as much information as possible on this week’s CSPEN Federal Legislative & Regulatory Update webinar.

Our efforts to stay as up to date on the pending release and the details of the EO were the reason CSPEN had to cancel last week’s webinar. We will share more details on the activities we have been involved in on this week’s webinar.