The memorandum claims the nearly two-decade-old law gives the Biden administration "broad authority to grant relief from student loan requirements during specific periods (a war, other military operation, or national emergency, such as the present COVID-19 pandemic) and for specific purposes (including to address the financial harms of such a war, other military operation, or emergency)."
Thus Biden is exploiting the supposed national emergency stemming from the pandemic as the legal justification for sweeping debt forgiveness.
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