From the introduction of the letter

The undersigned organizations representing Virginia consumers, students, student loan borrowers, and educators submit this comment in response to the State Corporation Commission’s (the “Commission”) July 9, 2021, Order Requesting Additional Comments (the “Order”) on proposed regulations to implement Virginia’s new Student Borrower Bill of Rights. The Commission specifically requested comments further addressing whether the new law and/or its implementing regulations implicate either federal preemption or intergovernmental immunity. The Commonwealth seeks this information in response to a false alarm raised by lobbyists for the student loan industry, the National Association of Student Loan Administrators ("NASLA") and Student Loan Servicing Alliance ("SLSA").