The rapidly increasing number of student loans maturing under the relatively new guaranteed student loan program have spawned a dramatic increase in the number of educational loans discharged in bankruptcy. This comment will examine former students' ability to obtain college transcripts after discharge of their student loans through bankruptcy. It will discuss the two cases holding that a private college can deny transcripts to bankrupts, but a state college cannot." Furthermore, it will inquire into the purposes of the Bankruptcy Act, the correctness of the restrictive judicial interpretation of the 1970 amendments," and alternative judicial approaches that better reflect the amendments' purpose. Finally, it will examine the 1978 bankruptcy reform legislation and its potential effect on bankrupt students seeking transcripts.
Barbara Linde, A Fresh Start through Bankruptcy: Fact or Frustration for the Student Loan Debtor?, 2 SEATTLE U. L. REV. 365 (1979).