I'll need time to read it all but one big change..not a good one. While counts for IBR..icr and paye will count for rap forgiveness. Rap payments won't count towards the others. So the strategy of getting on the rap for the interest subsidy and then switching back to ibr at the end for shorter forgiveness is out the window. And yes, the RAP still counts for PSLF
We can thank whomever submitted a comment to the feds that what they had originally on this was unlawful.
No changes to the definition of professional degrees..so they didn't expand that
I'll update the rest by tomorrow so please hold off on your questions for now
EDIT: I've completed my first very very quick skim and there are no other major changes from the draft rules. So my initial summary should still stand. If I pick up anything else noteworthy in the comments I'll continue to edit this post.