We’ve been talking about America’s student-loan problem all wrong, according to the former top student-loan official in the country.

Seth Frotman, who resigned in protest earlier this year from his role as the Consumer Financial Protection Bureau’s student loan ombudsman, made the case Thursday that solving our nation’s student-debt challenges requires acknowledging policy makers’ and company executives’ role in creating it.

In his speech, Frotman painted a picture of a crisis built on policy makers’ choices. He highlighted how state officials cut funding for public higher education, pushing up prices and requiring students to increasingly rely on debt to finance college. At the same time, policy makers did little to put regulations in place to handle the rapid rise in student loans, according to Frotman.

“Simply put, we dropped a trillion dollars of debt into the market without any thought of the oversight, consumer protection, or accountability that is necessary to manage it,” he said.

“ The CFPB hasn’t announced a replacement for Seth Frotman, raising questions about how effectively the consumer agency is monitoring the student-loan market. ”

In remarks delivered at a conference for consumer rights attorneys hosted by the National Consumer Law Center, Frotman derided pundits and experts who have attempted to minimize the consequences of America’s $1.5 trillion in student debt. Too often, they frame it as a temporary problem of individuals who will likely benefit down the road from investing in their education.

His former boss is one of the most egregious promoters of this rhetoric, Frotman suggested. “Some even go so far as to declare on CNBC that student-loan borrowers are not suffering amid a debt crisis, but are instead themselves an economic and moral hazard to the rest of us,” Frotman said, according to prepared remarks.

Though Frotman didn’t mention him by name, the comment is likely a reference to a September CNBC appearance by CFPB acting director Mick Mulvaney, who said on the network that he’s worried from “a moral standpoint” about borrowers not repaying their student loans.

Frotman added, “Minimizing average folks’ struggle, and blaming others is always easier than acknowledging our role — our collective decisions and policies — in how we ended up here.”

His remarks come as borrower advocates worry the student-loan problem could get worse thanks to today’s policy makers. The Department of Education under Betsy DeVos is working to rewrite regulations aimed at ensuring student-aid dollars aren’t spent on poor-performing programs and that borrowers are made whole when they’re misled by their schools.

The agency is also trying to shield student-loan companies from state consumer protection laws. At the same time, the CFPB hasn’t announced a replacement for Frotman, raising questions about how effectively the consumer agency is monitoring the student-loan market.

“ In a speech Thursday, Frotman argued that ’aggressive legal action’ is one of the few ways to hold the student loan system and its players in check. ”

The remarks also add Frotman’s voice — perhaps the loudest — to a chorus of advocates arguing for a re-framing of the conversation around student debt from one that’s narrowly focused on separate pieces to one that interrogates the system that got us to where we are.

“The most important thing to remember here is that we can’t solve the problem until we name what it is,” said Julie Margetta-Morgan, a fellow at the Roosevelt Institute. She recently co-authored a paper arguing that America’s $1.5 trillion in outstanding student loans is a “failed social experiment.”

When experts and policy makers talk about the student debt problem, they’re often talking about different things and that can lead them to different solutions, Margetta-Morgan said. Some will point to a “repayment crisis,” which narrows any policy fixes to the category of making payments more manageable. Others talk about the issue as a systemic problem over which borrowers have limited control, which can open the door to more radical solutions like debt cancellation, she said.

In his remarks, Frotman described the consequences of policies that pushed borrowers towards debt, without comparable efforts to regulate the growing market. That approach created room for industry to take advantage of student loan borrowers, Frotman argued in his speech, through practices ranging from making it more difficult for borrowers to repay their loans to outright scams.

For Fortman, the logical conclusion of acknowledging policy makers’ and company executives’ role in creating the student-debt problem is establishing more oversight of these entities. Frotman derided the idea that the Department of Education, particularly under DeVos, could be trusted to work in the best interest of borrowers, given its role as a lender to students. “It has the incentives of a large financial institution, because it is one,” Frotman said in the speech.

In addition to independent oversight, Frotman argued that “aggressive legal action” is one of the few ways to hold the student loan system and its players in check, essentially framing his speech as a call to action for the consumer lawyers in the audience.

“The champions for justice are dwindling,” he said, later adding, “that is where each of you come in.”