{
  "effective": "Periods of enrollment/instruction beginning on or after July 1, 2026 (20 U.S.C. §1087e(a)(3)-(6); 34 CFR 685.203)",
  "graduate": {
    "annual": 20500,
    "aggregate": 100000,
    "aggregateRestorable": true,
    "aggregateExcludes": [
      "undergraduate loans",
      "old Grad PLUS balances (those count only against the $257,500 lifetime cap)"
    ],
    "note": "Direct Unsubsidized only — subsidized loans for graduate students ended in 2012 and were not revived. The $100,000 applies to a graduate student who is not (and has not been) a professional student; otherwise the shared $200,000 pool applies (20 U.S.C. §1087e(a)(4)(B))."
  },
  "professional": {
    "annual": 50000,
    "aggregate": 200000,
    "sharedPoolWithGraduate": true,
    "aggregateRestorable": true,
    "note": "Graduate and professional borrowing share one $200,000 pool — borrowing in one status shrinks the other (20 U.S.C. §1087e(a)(4)(B))."
  },
  "lifetime": {
    "cap": 257500,
    "odometer": true,
    "includes": [
      "Direct + FFEL subsidized/unsubsidized (undergraduate + graduate + professional)",
      "Grad PLUS (Direct + FFEL)"
    ],
    "excludes": [
      "Parent PLUS borrowed on behalf of a dependent student",
      "consolidation loan shell (the underlying loans are included)",
      "HEAL / health-professions program loans"
    ],
    "note": "True odometer: 'without regard to any amounts repaid, forgiven, canceled, or otherwise discharged' (20 U.S.C. §1087e(a)(6); 34 CFR 685.203(j)(2)). Returned loan funds do not count."
  },
  "parentPlus": {
    "annual": 20000,
    "aggregate": 65000,
    "odometer": true,
    "perDependentStudentAllParentsCombined": true,
    "note": "NEW caps per dependent student, combined across ALL parents: $20,000/academic year, $65,000 aggregate 'without regard to any amounts repaid, forgiven, canceled, or otherwise discharged' (20 U.S.C. §1087e(a)(5); 34 CFR 685.203(f)(2), (g)(2)). Excluded from the $257,500 lifetime cap. Returned funds do not count."
  },
  "undergraduate": {
    "unchanged": true,
    "dependent": {
      "annualByYear": [
        5500,
        6500,
        7500
      ],
      "aggregate": 31000,
      "maxSubsidizedByYear": [
        3500,
        4500,
        5500
      ],
      "maxSubsidizedAggregate": 23000
    },
    "independent": {
      "annualByYear": [
        9500,
        10500,
        12500
      ],
      "aggregate": 57500
    },
    "note": "P.L. 119-21 does not amend annual or aggregate limits for loans to undergraduate students (CRS R48727; 34 CFR 685.203(a)-(d) untouched). Only the parent (Parent PLUS) side changed."
  },
  "legacyException": {
    "conditions": "Enrolled in the program of study as of June 30, 2026 AND a Direct Loan was made for that program before July 1, 2026 (for the Parent PLUS exception: a Direct Loan to the parent borrower OR to the dependent student qualifies). Voided if the student withdraws / ceases enrollment; changing majors within the same degree preserves it (34 CFR 685.203(b)(2)(iv)(B)-(C), (f)(2)(ii)/(iv), (g)(3)/(5); 20 U.S.C. §1087e(a)(8)).",
    "durationRule": "Expected time to credential = the lesser of 3 academic years (clock runs from July 1, 2026) or the remaining program length (34 CFR 685.102(b)); it can never run past ~June 30, 2029.",
    "outerBound": "2029-06-30",
    "effect": "While it lasts, the new annual, aggregate, Parent PLUS, and $257,500 limits do NOT apply; Grad PLUS and Parent PLUS remain available up to cost of attendance minus other financial assistance; the pre-OBBBA unsubsidized aggregate applies instead.",
    "oldAnnualUnsub": 20500,
    "preObbbaGradAggregate": 138500,
    "preObbbaHealthAggregate": 224000
  },
  "litigation": {
    "status": "Professional-degree definition preliminarily stayed in federal court; ED interim 29-program list in effect",
    "asOf": "2026-07-12",
    "stayDate": "2026-06-24",
    "stayCourt": "U.S. District Court for the District of Columbia (Judge Beryl Howell)",
    "stayedDefinitionFields": 11,
    "interimListCount": 29,
    "interimListUpdated": "2026-07-10",
    "interimListExamples": [
      "Medicine (M.D.)",
      "Law (J.D.)",
      "Dentistry (D.D.S./D.M.D.)",
      "Pharmacy (Pharm.D.)",
      "Registered Nursing (MSN)",
      "Nursing Practice (DNP)",
      "Physical Therapy (DPT)",
      "Occupational Therapy (MSOT/OTD)",
      "Physician Assistant (MSPA/PA)",
      "Audiology (AuD)",
      "Speech-Language Pathology",
      "Clinical Psychology (Psy.D./Ph.D.)"
    ],
    "edListUrl": "https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2026-06-29/update-list-professional-degree-programs-due-court-order",
    "note": "Whether a program counts as professional ($50,000/yr, $200,000 pool) or graduate ($20,500/yr, $100,000 pool) is in active litigation and can change while the case proceeds. This tool does not classify your program — select the status your school's financial aid office confirms, and re-check ED's current list."
  },
  "coaRule": "No Direct Loan may exceed the cost of attendance minus other financial assistance (34 CFR 685.203(j)(1)); schools may also set lower, consistently-applied program-wide limits (34 CFR 685.203(m)(2)); less-than-full-time annual amounts are prorated by enrollment intensity, rounded to the nearest whole percentage point (20 U.S.C. §1087e(a)(7); 34 CFR 685.203(m)(1)).",
  "sources": [
    {
      "claim": "All caps + interim exception, statutory text (20 U.S.C. §1087e(a), as amended by P.L. 119-21 §81001)",
      "url": "https://www.law.cornell.edu/uscode/text/20/1087e"
    },
    {
      "claim": "P.L. 119-21 §81001 (enacted July 4, 2025)",
      "url": "https://www.congress.gov/119/plaws/publ21/PLAW-119publ21.pdf"
    },
    {
      "claim": "RISE final rule regulatory text + counting-method preamble (91 FR 23768, May 1, 2026)",
      "url": "https://www.govinfo.gov/content/pkg/FR-2026-05-01/pdf/2026-08556.pdf"
    },
    {
      "claim": "NSLDS aggregate processing: lifetime-cap composition, per-student Parent PLUS, legacy aggregates (FSA EA Apr 24, 2026, updated May 7, 2026)",
      "url": "https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2026-04-24/one-big-beautiful-bill-act-nslds-eligibility-processing-updates-updated-may-7-2026"
    },
    {
      "claim": "29-program professional-degree list during the court stay (FSA EA Jun 29, 2026, updated Jul 10, 2026)",
      "url": "https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2026-06-29/update-list-professional-degree-programs-due-court-order"
    },
    {
      "claim": "Undergraduate limits unchanged (CRS R48727 corroboration)",
      "url": "https://www.everycrsreport.com/reports/R48727.html"
    }
  ]
}