The agency punted for now on one key question: whether students must be in default in order to apply for loan forgiveness. Allowing "affirmative claims" from students who are current on their loan payments could invite a flood of applications, the agency warned, because there is little downside to asking for loan forgiveness. At the same time, the Education Department said, it does not want to create incentives for borrowers to fall into default in hopes of winning debt relief.