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9 Audra Turner, and I'm the Executive Director of the Paul
10 Mitchell Schools located in Ardmore, Oklahoma,
11 Arlington, Dallas, San Antonio, Texas, and Miami,
12 Florida.
13 I'm here to voice my support for the
14 Department's efforts to review the Borrower Defense
15 Repayment and Gainful Employment regulations. Like John
16 Turnage I, too, hope the Department will consider
17 representatives from our Paul Mitchell School network on
18 both Gainful Employment and Borrower Defense Repayment
19 committees. I've been working in the hair care industry
20 for 30 years as a stylist, a salon owner, and an
21 educator. That experience has helped shape the remarks
22 I'm sharing today.
23 As you can imagine, in our industry, it's
24 mostly women. The reality is 95 percent of people who
25 enter cosmetology schools are women. Many of them are

1 single, and some of them are single mothers. Future


2 professionals who are single often enter training
3 thinking they will stay in the business for a few years
4 full-time and then transition to a part-time
5 supplemental income as they marry and have children.
6 Yet they know they have a school that they can employ
7 full-time that will take care of their families should
8 the need arise.
9 In contrast, single mothers often enter our
10 programs because the cosmetology training is quick.
11 It's about a year. When licensed, a career in
12 cosmetology offers a flexible work schedule to allow
13 part-time or full-time as your family needs dictate.
14 These realities are not reflected in the
15 one-size-fits-all approach under Gainful Employment
16 regulations which currently only consider full-time
17 employment to have sufficient value. The reality is the
18 schools are unable to dictate the degree of work a
19 graduate chooses. Again, our graduates are frequently
20 second-income earners and decide to work part-time or
21 not at all. We fully support these decisions but feel
22 it's inappropriate for the reduced or missing income
23 from these graduates to harm a school's GE ratios,
24 especially when their household income clearly shows
25 sufficient means to repay these loans.



1 I would also hope the committee will
2 examine the need for schools to provide greater direct
3 counseling for students taking out federal student
4 loans. Too often, we see students who come in and
5 borrow too much money or more than they need. Of
6 course, some of these students need additional income to
7 pay for rent and transportation. However, we know a few
8 instances where they take significantly more. For
9 example, one young woman told a school owner that the
10 extra money from her student loans would be used by her
11 mother to renovate the family kitchen. Unfortunately,
12 under Gainful Employment, the school that that young
13 lady attended is now being held accountable for the
14 unwise and excessive federal student loan. Currently,
15 there is nothing this school can do or say to prevent
16 it. That's just not appropriate.
17 Another concern that I have with Gainful
18 Employment is that our schools are to be held
19 accountable for what our graduates report. The reality
20 is that cosmetology is a cash- and tip-based industry.
21 People dealing in cash often underreport their income.
22 The IRS estimates a substantial chunk of our $458
23 billion tax gap likely comes from underreported
24 small-business income, and especially those dealing with
25 cash.

1 According to the Tax Policy Center,


2 individual taxpayers fail to report about 65 percent --
3 or sorry -- 63 percent of income from sources from which
4 there is no information reporting, such as credit cards.
5 That is consistent with the recent results we received
6 when we did our appeals process with our Paul Mitchell
7 Schools. After interviewing our graduates, their income
8 underreported -- was underreported an average of 65.5
9 percent across our network. To conduct these earnings
10 appeals, we needed to call most of our graduates
11 multiple times and were required to impose upon them by
12 questioning their income, many of which had
13 underreported to the IRS.
14 Just finding our graduates is a major task.
15 As mentioned before, our graduates are women, and they
16 change their names upon being married. It's often
17 difficult for our schools in military bases, because
18 these now married women follow their spouses to move
19 multiple locations and sometimes abroad. These factors
20 add significant costs in our efforts to track down and
21 document how much money they really made. The Gainful
22 Employment regulation has been poorly planned in its
23 implementation but, especially, as it applies to
24 cosmetology.
25 Now, I would like to discuss the Borrower



1 Defense to Repayment regulations. I, again, express my
2 support for the Department's suggested review of the
3 rules and regulations and current implementation of that
4 effort. There is, certainly, a need for a fair process
5 for the students and the taxpayers. We need to be
6 protected from unscrupulous schools, but the Borrower
7 Defense to Repayment process as established under the
8 previous administration has added a negative effect on
9 cosmetology schools. Lenders and landlords are anxious
10 about the regulations that provide stackable penalties,
11 and the risk of those penalties can turn the owners to a
12 place where they're apprehensive about opening new
13 schools.
14 I would really like to ensure that we find
15 a solution so that we can continue to provide future
16 generations with the opportunities that I have enjoyed
17 in this industry.
18 Thank you for allowing me to speak on
19 behalf of cosmetologists.
20 MR. MANNING: Thank you very much.
21 MR. MARTIN: Sandy Sarge.
22 MS. SARGE: Good afternoon. My name is
23 Sandy Sarge, and I'm the president of Sarge Advisors, a


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