Pan, Circuit Judge:
When Congress passed the Higher Education Act of 1965 (the "Act"), 20 U.S.C. §§ 1001-1155, it created the Federal Family Education Loan Program ("FFELP" or "Program"), see id. § 1071-1087-4. The FFELP incentivized financial institutions to lend money to borrowers with poor credit or low incomes by establishing...
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