A Market in Need of a Marketplace: Unleashing Innovation in a New Era of Education Freedom

The Issue

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For the past 30 years, government aid has expanded almost unimpeded¹—a reality that has contributed to students’ 246 percent increase in tuition costs.² Despite the increase in tuition, though, the government’s indiscriminate lending and artificial cap on interest rates have caused demand for higher education to soar.³

Today, student loan debt makes up the second-largest category of household debt in the United States— tied with auto loans at 9 percent of total household debt.⁴ Eighty-five percent of all higher education student loans are issued by federal student loan programs, which now total over $1.7 trillion in outstanding debt.⁵ This government monopoly on student loans distorts the market, where it and the rising cost of tuition do little to incentivize innovation or competition among private student lenders.

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Takeaways

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• Over the past three decades, the price of the federal student loan program has added up, with the now $1.7 trillion program estimated to cost over $197 billion in taxpayer dollars. That’s before considering the cost of administering the loan programs, the price distortion in lending and tuition costs, and the decreasing quality of education.
• Even as the Trump administration seeks to dismantle the Department of Education, Congress should do its part by repealing all current federal education lending and aid programs. Further, the federal government should sell its student loan portfolio to the private market.
• The Trump administration should deploy cutting-edge blockchain technology to liquidate the loan portfolio on an accelerated timeline while maximizing taxpayer value. This would allow for a new marketplace for student loan digital assets, facilitating lending innovations that would better connect individuals, employers, and schools to the education finance ecosystem.

Private lenders offer loans at upwards of 15 percent annual interest, and have largely maintained the same loan structure over the past three decades.⁶ That structure is high risk for lenders, with repayment terms of 10-15 years after a four-year interest deferment period during school and a six-month grace period after graduation. This structure also affects students, as it can result in total repayment amounts that are sometimes double the initial amount borrowed.⁷ At the same time, lenders have no tradability: when they need to adjust portfolios, there is no liquid secondary market for buying, selling, or trading private loans. All told, private lenders wind up locking up significant capital on decade-plus unsecured loans to borrowers with little-to-no credit history—a situation that reflects a sticky marketplace with large quantities of high-risk long-term debt and few counterparties to exchange.

Not only does government aid inflate market prices, but the program itself costs American taxpayers considerably. While projected to secure $114 billion in revenue for the government, over the past three decades, the federal direct loan program has instead cost $197 billion. That $311 billion shortfall, which does not include internal administration or third-party servicing costs, resulted from policy changes to the programs and financial miscalculations.^8
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The downstream effects on educational institutions have been demonstrably negative.

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There is a strong correlation between expansion of government aid policies and total college enrollment figures—a relationship consistent with the original goal of such policies.⁹ But the expansion of those policies also correlated with an increase in defaults,¹⁰ suggesting that an abundance of artificially low lending costs ushered individuals into programs they would otherwise would not attend but for easy access to credit.

The same data suggest that underperforming institutions rely on federal aid programs to support their admissions. During previous periods of tightening credit, institutions with the highest default rates (and by extension, lowest academic achievement) have been forced to close.¹¹ Now though, ever-expanding government aid programs have become a safety net for ailing institutions dependent on student access to funding.¹²

And while the expansion of government aid programs has correlated with expansion to admissions, it has not resulted in any material change in academic achievement (measured in terms of graduation rates). In fact, the data suggest that the increases in student lending and accompanying increases in tuition prices have incentivized educational institutions to focus less on increasing education quality and to instead direct excess resources toward growing administrative overhead.¹³

Perhaps most egregiously, the government has used aid programs as financial extortion to force educational institutions to enact a social agenda¹⁴—a practice it’s even employed against faith-based organizations to impose policies violating their sincerely held religious beliefs.¹⁵

It is abundantly clear a solution to this crisis is desperately needed. So far, little has been done to curb government complicity, but with the prospect of the Trump administration setting a new course for education finance in America, the outlook has never been better.

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The government’s limited role should be to support rule of law conditions that allow markets to exist.

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The government does have a role in creating markets—a limited one. Governmental bodies at all levels are responsible for establishing and maintaining the rule of law conditions necessary for markets to exist. However, government policy enacted to influence desired market outcomes (whether directly or indirectly) nearly always amounts to a subsidy borne by taxpayers, and the programs themselves become susceptible to waste, fraud, and abuse over time.

Governments have priorities that differ from those held by most private participants in a free market—namely, policy goals that take precedence over profit-seeking. For this reason, governments will never exhibit the same level of profit-seeking behavior as private market participants, and they cannot be relied upon to keep any promises to do so—at least not permanently. In contrast to most private participants, governments have so much sway that even the smallest intervention significantly influences market behavior, leading to distortions of supply and demand. This classic free market principle is perhaps best seen in the market for student loans.¹⁶

As the chart above shows, the average cost of tuition, fees, room and board has risen over the same period that annual federal lending has risen. Not only has federal student lending resulted in higher tuition costs, but the price effects of this intervention are more predominant at schools that rely more heavily on federal lending. Further, the higher tuition costs resulting from federal lending significantly reduce the benefits of the program for many borrowers who qualify for private loans. This benefit “offset” suggests that many qualified borrowers might be better off borrowing from private lenders in a market without the price inflation.¹⁷

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A Brief History of Federal Student Lending

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In crafting solutions for a path forward, we have decades of knowledge on what to avoid.

The Federal Family Education Loan program (FFEL) was born out of a student lending program started under a different name in 1965. Over time, it grew to enjoy all the ingredients of a neoliberal-style private-public partnership: private lenders, state insurance agencies, nonprofit entities, tax-exempt bond issuances, and loan default guarantees. In short, it had all the hallmarks of a promising “free market” solution—except in one crucial detail: Congress, not supply and demand, set the interest rates that participating lenders could charge borrowers.

With price controls on money and no ability to differentiate risk, the FFEL effectively functioned the same as today’s direct lending program, except that it used private banks and other entities as intermediaries and guarantors. Over the decades after its creation, the FFEL program underwent significant changes before eventually being terminated by the Affordable Care Act of 2010, leaving the 1993 federal direct loan program in its place.¹⁸

FFEL was not the only such venture into the market for student loans. In 1972, Congress also experimented with creating a government-sponsored enterprise called Student Loan Marketing Authority (“Sallie Mae”), whose purpose was to buy federal student loans to create liquidity for private banks to lend more. In 2004, Sallie Mae became a fully private organization, and subsequently, during the 2008 finanical crisis, it was forced to sell billions of its FFEL loans to the U.S. Department of Education.¹⁹ It is now a private lending institution instead of a government-controlled secondary market facility

Several decades and trillions of dollars later, the federal government has “taken the loan program far beyond the original goal of creating a student loan market where one never existed; the program now displaces what would otherwise be a competitive private market for large categories of students.”²⁰

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It’s Time to End Federal Student Aid

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With the new Trump administration’s aggressive plan to wind down the U.S. Department of Education, there is finally political will to enact the policy changes necessary to revitalize higher education.

Repeal All Federal Student Aid Programs. To remedy government-caused market distortion, the first and most critical step is to immediately stop all federal government lending and grant programs for higher education. Congress should repeal all student loan and Pell Grant programs, and in the meantime, the Trump administration should exercise executive authority to impound funding and curtail expansion of existing programs. The resulting transition of student borrowing from federal sources to the private market will encourage competition between lenders, placing downward pressure on interest rates. Meanwhile, the lack of Pell Grant and other aid programs will prevent federal agencies from financially coercing schools into adopting radical social policies in the future.

Restore Financial Health to Current Loan Portfolio. Administrators of the current federal programs must continue reversing loan forgiveness policies and reinstatement payment plans to breathe financial health back into the current portfolio. Past changes to the loan programs—including COVID-19 forbearance and excessive hardship allowances—have thrust millions of borrowers in and out of default, costing taxpayers millions,²¹ sowing confusion among borrowers, and dramatically increasing the risk of loans becoming uncollectible.²²

Harvest Returns for Taxpayers. To prevent a future congress or executive branch from adopting forgiveness plans harmful to taxpayers, the Trump administration should work with private banks and credit funds to sell as many loans to private debt holders as possible. Priority should be given to selling loans currently in repayment at the highest market price to generate cash flow. Certain loans in non-repayment status can be sold at a discount that adequately reflects the risk of default. Loans that are severely defaulted should be sent to the U.S. Department of Treasury for attempts at collection action, and those deemed uncollectible should be charged off or sold. Proceeds from the sales of loans to the private market should be used to pay for process improvements, technology, or services required to execute an accelerated liquidation plan.

Give Schools a Report Card. Publish a report card of educational institutions receiving federal student aid—ranked by the percentage of borrower defaults—and recommend accreditation review for schools with excessively high default rates. School data should be made available to the public (with borrower information anonymized) so taxpayers can see how educational institutions are performing in terms of their student rates of default.

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A Bargaining Alternative

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If the Trump administration decides it wishes to continue operating federal lending through another agency (e.g. Small Business Administration, etc.), its programs should be directed entirely by participants in the private loan market, with government serving only as a passive “investor” with targeted programmatic backing for private lending.

Government Guarantee Without Government Price Controls. If the FFEL program had been able to operate without congressional control over interest rates, it might have resulted in a healthier market for education financing and not led to the easy money conditions that perpetuate “zombie” institutions and poor education. Notwithstanding price controls, the FFEL program’s guarantee model operated similar to the current SBA 7(a) program, which guarantees a certain percentage of a loan issued by a private lender.²³ The guarantee is meant to provide a backstop allowing lenders to take risk on borrowers who would otherwise not be eligible for credit.

To minimize the impact of market distortion and narrowly target programmatic objectives, any new program should adhere to the following principles:

1. Programs should be focused on assisting only borrowers who cannot be served by the private market. This primarily includes borrowers who have no credit history or capital assets and who could not otherwise be assessed for credit worthiness. Eligible loans should apply only to the first academic year of school enrollment, and borrowers should be required to make small “touch payments” on the loan to establish payment history so they can qualify for a private non-guaranteed loan for future academic years.
2. Government guarantees should be extremely limited in size and scope, as government actions to relax credit standards or increase loan caps can also influence pricing behavior.²⁴ Government guarantees should be shared with a borrower’s educational institution and/or corporate sponsor as co-guarantors for these market beneficiaries so they have “skin in the game.” Further, guarantees should be phased out after a year of demonstrated repayment history; loans to parents on behalf of students, loans to graduate students, and loans with parent co-signers should not be eligible for government guarantees.
3. There should be no price controls on interest and no taxpayer subsidies, direct or indirect. The only exception should be in the case of loan defaults, in which situation the losses should be shared with the bank and sponsoring institution(s). Market interest rates should be allowed to fluctuate so they reflect the appropriate credit risk with the guarantee of the sponsoring parties.

Any new program should avoid other tools that either amount to a taxpayer subsidy, add regulatory complexity, result in market distortion, or are susceptible to expansion, waste, fraud, or abuse. Those include:

• Direct payments of any kind to banks, borrowers, institutions, and states to fund or subsidize programs
• Tax credits, tax exemptions on special characters of income, and special tax deductions
• Federally funded insurance programs
• Government purchases of loans in a secondary market

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A Market Without a Marketplace

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As the Trump administration works with Congress to consider the future of the federal direct loan program, one thing is certain: the private market needs to step up to satisfy demand. To do that, it needs a marketplace for student loans to change hands and increase liquidity.

Today’s student loans are unwieldly financial products. They generate an attractive return for lenders, but that return starts only after the borrower’s “in school” period (generally capped at five years) and lasts over a repayment term of 10-15 years. That means lenders essentially place a long-term bet on a student’s ability to repay based on limited credit history and financial information, with no assets securing the loan as collateral in case of default. A college diploma cannot be considered a capital asset. At best, it’s an intangible asset that increases an individual’s market value in the workforce—but it cannot be re-possessed in case of default (in contrast to a car tied to an auto loan or a home tied to a mortgage).

Add to those characteristics the incredible demand for college education, the need for financing, and the increasing cost of tuition. For the 2022-2023 academic year, an estimated 6.4 million participants in federal direct loan programs received loans averaging $9,230.25 Total federal direct lending exceeded $83 billion, while private student lending reached nearly $15 billion in the same period.²⁶

Without bundling loans into asset-backed securities (securitization) or conducting large bank-to-bank portfolio sales, there exists no real marketplace for selling student loans. Larger players in the industry possess the ability to exchange loan portfolios, making liquidity less of a concern, but the general difficulty involved in getting in and out of these financial holdings creates a “stickiness” that hinders the ability to quickly free up capital in a sale. Not only that, but this difficulty raises the barrier to entry for the student loan market, essentially establishing a required minimum portfolio size that’s necessary to make a due diligence or securitization process worthwhile.

While the government succeeded in creating a market for student loans, it failed—even in its earlier experiment with Sallie Mae—to create a marketplace where these loans could change hands.²⁷ Because of its complex design to accommodate unemployed full-time students, even the loan product itself creates challenges that make it accessible and attractive only to certain institutional lenders, thus further concentrating the pool of market participants. What is needed is a way to reduce the complexity and “stickiness” of these assets, making them tradeable and accessible so new participants can engage in a whole-of-industry solution both individually and at scale.

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Blockchain and the Future of Finance

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Fortunately, a technological innovation may offer a solution.

Today, blockchain networks are disrupting traditional financial structures, prompting a cultural awareness of monetary issues surrounding fiat money, digital assets, custody, and the role of financial intermediaries.²⁸ Blockchain is a software system architecture—a network design—for governing individual units of digital property that employs a full historical ledger built into each unit. This “distributed ledger” contains the full truth and history of every asset, allowing self-custody without banks, transparency, and standardized data access. While still young,²⁹ blockchain is allowing the formation of new peer-to-peer financial networks with seamless cross-asset interoperability of a type unthinkable under traditional financial systems and processes.

By digitizing financial instruments—such as a loan—into exchangeable software units called “tokens” and building a network that governs how those tokens function, blockchain shifts the mechanics of financial engineering from human operation in a static, centralized system to automatic operation in an interactive, decentralized system. Key elements of the traditional process—elements like issuance, ownership transfers, and posting payments — are recorded directly into the token’s distributed ledger, allowing the owner full access to the history of that asset and eliminating doubt and the time that would otherwise be spent requesting underlying details from a custodian or intermediary.

This dynamic built-in historical data set allows for standardization in terms of data accessibility, structure, and interoperability—which in turn creates the ability to exchange.  After all, if these instruments’ digital structure can be standardized, they can be analyzed, valued, and exchanged with greater efficiency and confidence than can traditional assets because the truth of their identity is easily accessible in immutable records. And because transactions occur within a digital network using digital currency instead of traditional payment rails, settlement is instant, auditable, and reportable in real time, dramatically reducing time in verification procedures.

In short, blockchain’s most radical feature is its ability to take articles of property, including unwieldly student loan assets, and transfer the governance into a digital network environment that makes ownership and movement of that property fast and frictionless.

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Tokenization in a Loan Participation Legal Framework

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Education finance is perhaps the industry in most need of this modernization.

When student loans are tokenized, potential buyers gain the ability to purchase loans in any whole, fraction, or bundle. While this may seem like a new concept, it actually already exists—simply in a much slower and more complex manual process. In fact, loan participation is a common and encouraged³⁰ practice, with lenders spreading risk and increasing liquidity by inviting other lenders to “participate” in a loan by contributing a piece of the total loan amount in exchange for a piece of the interest earned.

The traditional process involves a “lead lender” who originates the loan, designates the servicer, and sets the terms of the agreement that other lenders, called “participants,” adopt for governance of the pro-rata rights. Unfortunately, this practice suffers from frequent
issues, including a long due diligence and legal process, difficulty with collections and defaults, and struggles with the management and timing of payment proceeds. But by converting this process into a blockchain environment, all these problems can be mitigated.
Agreements are standardized, governance is automated, data is accessible, and payment remittances are processed in real time.

In traditional arrangements, participants are almost always other financial lending institutions because the required legal and procedural knowledge makes the effort too great for non-lenders. In contrast, the tokenization process breaks down the barriers to entry, simplifying the process so it mirrors a brokerage account experience in which users place orders to purchase shares of funds or publicly traded companies. Because of this, tokenization expands the number of potential participants by multiples. Within the student loan context, tokenization could lead to any number of creative financing arrangements, offering a “back door” approach for any non-lender—whether an individual or institution—to support the lending ecosystem by purchasing already-originated loans in any quantity
or fraction.

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The Benefits of Securitization without the Cost

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Why is this useful? The market for mortgage-backed securities (MBS) provides an example of the benefits of selling pieces of debt instruments. In that market, individual mortgages are organized by credit grade, bundled according to desired risk-return, and then placed into an entity that issues shares to investors. This allows for MBS sales, offering liquidity to lenders by freeing up capital that can be used to lend more. When practiced at scale, this lowers industry risk, increases competition among lenders, and places downward pressure on interest rates.³¹

Tokenization of individual loans offers the same benefits without the lengthy securitization process. Because the asset underneath the digital “twin” is a loan, it is not considered a security, meaning the complex legal frameworks and compliance measures governing securities do not apply. Not only that, but securitization is largely unnecessary due to the software interface that makes digital loan tokens easy to slice, dice, sort, and bundle. Thus, tokenization enables issuers to cut administrative fees, legal and advisory costs, rating agency fees, and downstream management costs. The effort and time traditionally spent carving out tranches (risk groups) or dealing with complex assets is dramatically reduced, if not eliminated entirely. Further, self-custody and the distributed ledger detail enable unfettered access to “truth” data, removing the need for “trusted” financial intermediaries. In short, tokenization essentially eliminates the need for securitization, with its functions instead programmatically enabled by digital assets and software tools—thus dramatically lowering traditional barriers and allowing loans to change hands between any parties in any quantity.

Of course, this does nothing to eliminate the need for buyers and sellers in the marketplace. Today, the private student loan market stands at around $130 billion of the total $1.7 trillion market.³² Although the private market is large in its own right, it still represents only a fraction of all student loans. Thus, for the marketplace to be fully optimized, and for liquidity and interest rate benefits to be maximized,³³ federal direct loan portfolios must participate in this tokenization of assets.

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The U.S. Federal Government Should Lead the Way

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The U.S. government and the education finance industry at large should embrace blockchain technology as a means of revolutionizing education by transforming its underlying financial ecosystem.

The Trump administration can achieve the previously discussed policy changes with greater speed and lower taxpayer cost by:

1. Converting its current $1.7T+ loan portfolio into digital tokens. In line with calls to place the entire federal budget on-chain,³⁴ the entire direct loan portfolio should be tokenized to take advantage of immutable record-keeping benefits in both repayment and default.
2. Liquidating its ownership of student loans. This should take place as part of a broader plan that rejuvenates the portfolio, generates maximum cash proceeds, and fully sunsets the lending program on an accelerated timeline.
   
   • Restoring financial health. As reported in February 2025, repayment rates on federal direct loans dropped significantly due to the multi-year pandemic deferment granted to borrowers.³⁵ The Department of Education subsequently resumed payments and collections against defaulted borrowers in May 2025.³⁶ The federal government has enforcement tools (wage garnishment, Treasury data, etc.)³⁷ unavailable to private lenders, so it should continue reasonable efforts to bring as many delinquent and defaulted loans back to active as quickly as possible.
   • Maximizing cash proceeds for taxpayers. Active loans in repayment should be prioritized for tokenization and immediate sale. Loans created under the FFEL program will likely be the easiest to liquidate since they first originated with private lenders. The many changes to the direct loan programs may complicate the legal procedures for transferring ownership, so the administration should adopt a multi-factor approach to quickly assess market value of loans and optimize the speed with which they can be sold.
   • Fully cease federal direct lending and student financial aid programs. All such programs should be halted at the federal level so the new marketplace can function without harmful price distortion.
3. Expanding adoption to other government direct lending programs. The federal government should encourage adoption of tokenization among private industry leaders and state-based financial aid programs. Other direct loan portfolios at other agencies should be moved into the blockchain network, thereby diversifying the marketplace and sending signals of change to the private sector. Federal Pell Grant programs should be ended entirely, leaving behind state-based grant programs that may also benefit from tokenization. Such tokenized grants can create a marketplace of pre-paid “Tuition Tokens” carrying a set dollar value that can be applied against the future cost of tuition.
4. Encouraging innovation. The administration should implement policies and programs that engage schools, lenders, and investors.
   
   • Allow the marketplace to give schools and degrees a “scorecard.”. Loan tokens will trade at a market-determined price—one which will reflect the risk of default based on school, field of study, and other attributes. Schools with high graduation and job placement rates will see that reflected in the trading values of student loans. Similarly, market value will also reward student loans issued to pursue jobs in high demand—thus creating a feedback loop that will correct errors of misallocation towards degrees the market does not need at a given time.
   • Encourage corporate employers and schools to purchase tokens to have “skin in the game.” Corporate networks benefit from educated talent, and schools benefit from education financing. Therefore, both of these groups should have some degree of exposure to the downside of poor education services and poor allocation of market talent. Two of the top three predictors of default are unemployment and limited financial assets.38 To reduce risk in student lending, the Trump administration should pursue policies that connect the interests of students, schools, and employers. A secondary market of tokenized student loans provides that connection.
   • Reset to neutral the government’s posture towards higher education and allow the market to get creative. Not everyone should seek a college degree, and not everyone needs to seek a degree right after high school. “Gap years” before entering college can allow students to build work experience, credit history, and savings. Government student loan programs were created to solve a problem that doesn’t have to exist. Already, the market has spoken through the creation of new school models (like trade schools) that produce highly skilled graduates in less time and with less debt.39 Inevitably, this will lead the market to produce new lending models that accompany those school models. To best serve taxpayers, the government should provide the legal environment for such innovations to exist—innovations that include:
   • i. Work repayment and income-sharing agreements
   • ii. Cross-collateralization with other digital assets
   • iii. Corporate-sponsored/guaranteed education
   • iv. Debt consolidation and refinance
   • v. Community and philanthropic support

These policy recommendations offer a holistic solution for reducing the cost of education financing, lowering risk to lenders, increasing the involvement of primary beneficiaries, and unleashing lending innovations with next-generation financial technology that can benefit the next generation of students.

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An Opportunity to Revolutionize Education

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Over the last 30+ years of government credit expansion in student lending, student outcomes have not improved. Instead, the opposite has occurred. There have been many proposals for reforming higher education at the institutional level, and those are important and necessary. But just as much in need of reform is the financial ecosystem behind higher education. Decades of credit expansion and inflated demand have distorted the market, incentivizing the wrong behavior by pushing high school graduates into college when they would be better served in trades, turning schools into diploma factories, and normalizing unhealthy amounts of debt. This is what cheap money does—it prevents free markets from sorting properly and addressing true needs with the best solutions. Cheap money leads to cheap goods and services.⁴⁰ 

It is beyond time for the federal government to end student loan and grant programs once and for all and allow states to administer aid programs as they choose. Existing loans should be sold to the private market, and the Trump administration should deploy cutting-edge blockchain technology to makes that exchange faster and less expensive, thus maximizing value for taxpayers and creating a self-sustaining marketplace.

The federal government built the student loan market. Now, on its way out, it should leave us with a healthy marketplace and a new mandate for private industry—thus steering us into a new era of education freedom.

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Notes

1. “A History of Federal Student Aid,” Lumina Foundation, https://www.luminafoundation.org/history-of-federalstudent-aid/ (accessed July 11, 2025).
2. “Trends in College Pricing and Student Aid 2023,” The College Board, https://research.collegeboard.org/media/pdf/ Trends%20Report%202023%20Updated.pdf (accessed July 11, 2025).
3. David O. Lucca, Taylor Nadauld, and Karen Shen. “Credit Supply and the Rise in College Tuition: Evidence from the Expansion in Federal Student Aid Programs,” Federal Reserve Bank of New York (July 2015), https://www. newyorkfed.org/medialibrary/media/research/staff_reports/ sr733.pdf?la=en (accessed July 11, 2025).
4. “Household Debt and Credit Report,” Federal Reserve Bank of New York, https://www.newyorkfed.org/microeconomics/ hhdc.html (accessed July 11, 2025).
5. “Trends in College Pricing.”
6. Ryan Wangman, “Student Loan Interest Rates: What to Know in 2025,” Business Insider, May 20, 2025, https://www. businessinsider.com/personal-finance/student-loans/currentstudent-loan-interest-rates (accessed July 11, 2025).
7. Assuming an original loan amount of $6,800.00, fixed interest of 10% per annum, four year in-school deferment period, sixmonth grace period after graudation, and ten year repayment term, a borrower will pay back $2,890.17 in capitalized interest through deferment and $5,676.62 interst through repayment, totaling $8,566.79.
8. U.S. Government Accountability Office, Education Has Increased Federal Cost Estimates of Direct Loans by Billions due to Programmatic and Other Changes, GAO-22-105365, July 2022, https://www.gao.gov/assets/gao-22-105365.pdf (accessed July 11, 2025).
9. Melanie Hanson, “College Enrollment & Student Demographic Statistics,” Education Data Initiative, March 17, 2025, https:// educationdata.org/college-enrollment-statistics (accessed July 11, 2025).
10. Adam Looney and Constantine Yannelis, The Consequences of Student Loan Credit Expansions: Evidence from Three Decades of Default Cycles, Federal Reserve Bank of Philadelphia, July 2019, https://www.philadelphiafed.org/-/media/frbp/assets/ working-papers/2019/wp19-32.pdf (accessed July 11, 2025).
11. Ibid.
12. Senate Committee on Health, Education, Labor, and Pensions, “Higher Education Accreditation Concepts and Proposals,” 2015, https://www.insidehighered.com/sites/default/server_ files /files/Accreditation.pdf (accessed July 11, 2025).
13. “The Cost of Excess: Why Colleges and Universities Must Control Runaway Spending,” American Council of Trustees and Alumni Institute for Effective Governance, August 17, 2021, https://www.goacta.org/wp-content/uploads/2021/08/ The-Cost-of-Excess_2.pdf (accessed July 11, 2025).
14. “U.S. Department of Education Issues Report on ‘Strategies for Increasing Diversity and Opportunity in Higher Education,’” Crowell & Moring LLP, https://www.crowell. com/en/insights/client-alerts/us-department-of-educationissues-report-on-strategies-for-increasing-diversity-andopportunity-in-higher-education (accessed July 11, 2025).
15. Dr. Amanda Staggenborg, “U.S. Appeals Court Upholds Dismissal of Hunter v. Department of Education Lawsuit,” Council for Christian Colleges and Universities, https://www. cccu.org/magazine/u-s-appeals-court-upholds-dismissalhunter-v-department-education-lawsuit/ (accessed July 11, 2025).
16. Graphic: Nicholas Stoltzfus. Data Source: “Digest of Education Statistics,” National Center for Education Statistics, https://nces.ed.gov/programs/digest/current_tables.asp (accessed July 11, 2025).
17. “Credit Supply and the Rise in College Tuition.”
18. Jason D. Delisle, Private in Name Only: Lessons from the Defunct Guaranteed Student Loan Program, American Enterprise Institute, February 15, 2017, https://www.aei. org/research-products/report/private-in-name-only-lessonsfrom-the-defunct-guaranteed-student-loan-program/ (accessed July 11, 2025).
19. Cole Robertson, “The Student Loan Bailout,” The Nation, January 2, 2009, https://www.thenation.com/article/archive/ student-loan-bailout/ (accessed July 11, 2025).
20. Private in Name Only.
21. Education Has Increased Federal Cost Estimates of Direct Loans.
22. Preston Cooper, “Less Than Half of Student Borrowers are Paying Their Loans,” American Enterprise Institute, March 25, 2025, https://www.aei.org/education/less-than-half-of-studentborrowers-are-paying-their-loans/ (accessed July 11, 2025).
23. “7(a) loans,” U.S. Small Business Administration, https:// www.sba.gov/funding-programs/loans/7a-loans (accessed July 11, 2025).
24. “…Evidence of a cross-demand effect of a credit expansion through a pecuniary externality with a relaxation of the borrowing constraint for some students affecting pricing to other students.” From “Credit Supply and the Rise in College Tuition.”
25. “Trends in College Pricing.”
26. Ibid.
27. “The Student Loan Bailout.”
28. David G.W. Birch, “Larry Fink Says Tokens Are ‘The Next Generation For Markets’,” Forbes, March 1, 2023, https:// www.forbes.com/sites/davidbirch/2023/03/01/larry-finksays-tokens-are-the-next-generation-for-markets/ (accessed July 11, 2025).
29. At $25B, the amount of “real world assets” that have been tokenized using blockchain technology still has a long way to go to catch up to the trillions in total financial assets in circulation around the globe. https://app.rwa.xyz/ (accessed July 14, 2025)
30. “The ABC’s of Loan Participation Due Diligence,” National Credit Union Administration, May 13, 2019, https://ncua. gov/newsroom/ncua-report/2016/abcs-loan-participationdue-diligence (accessed July 11, 2025).
31. “Understanding Securitized Products,” PIMCO, https:// www.pimco.com/resources/education/understandingsecuritized-products (accessed July 11, 2025).
32. “Trends in College Pricing.” 16 A Market in Need of a Marketplace: Unleashing Innovation in a New Era of Education Freedom
33. Douglas Gimple, “Mechanics and Benefits of Securitization,” Diamond Hill, July 6, 2023, https://www.diamond-hill. com/insights/a-191/articles/mechanics-and-benefits-ofsecuritization (accessed July 11, 2025).
34. Olga Kharif and Stephanie Lai, “Musk Exploring Blockchain Use in US Government Efficiency Effort”, Bloomberg, January 25, 2025, https://www.bloomberg.com/news/ articles/2025-01-25/musk-exploring-blockchain-use-in-usgovernment-efficiency-effort (accessed July 14, 2025)
35. “Less Than Half of Student Borrowers Are Paying Their Loans.”
36. Linda McMahon, “Linda McMahon: Accountability Returns to Student Loans,” Wall Street Journal, April 21, 2025, https:// www.wsj.com/opinion/accountability-returns-to-studentloans-forgiveness-borrower-debt-payment (accessed July 11, 2025).
37. Naveen Athrappully, “1.8 Million Student Loan Borrowers Face Wage Garnishment, No Tax Refunds, Lower Credit Score,” The Epoch Times, June 27, 2025, https://www. theepochtimes.com/us/1-8-million-student-loan-borrowersface-wage-garnishment-no-tax-refunds-lower-creditscore-5879466? (accessed July 11, 2025).
38. “Who Experiences Default?” Pew, March 1, 2024, https://www.pew.org/en/research-and-analysis/datavisualizations/2024/who-experiences-default (accessed July 11, 2025).
39. One example of an innovative new model is the College of St. Joseph the Worker, where students receive a bachelors degree along with a certification in a trade. https://www. collegeofstjoseph.com/ (accessed July 11, 2025).
40. Saifedean Ammous, The Fiat Standard, “Chapter 9: Fiat Food” https://saifedean.com/fiatfood (accessed July 14, 2025)

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