<P> 3 . Revised Pay As You Earn (REPAYE) </P> <P> 4 . Income - Contingent Repayment (ICR) </P> <P> United States Federal student loans and some private student loans can be discharged in bankruptcy only with a showing of "undue hardship ." In contrast to credit card debt, which often can be discharged through bankruptcy proceedings, this option is not generally available for educational loan debt . Additionally, those seeking to discharge their student loan debt must initiate an adversary proceeding, a separate lawsuit within the bankruptcy case where they illustrate the required undue hardship . Many borrowers cannot afford to retain an attorney or the additional litigation costs associated with an adversary proceeding, let alone a bankruptcy case . Further complicating matters, the undue hardship standard varies from jurisdiction to jurisdiction, but is generally difficult to meet, making student loans practically non-dischargeable through bankruptcy . In most circuits discharge depends on meeting three prongs in the Brunner test: </P> <P> As noted by the district court, there is very little appellate authority on the definition of "undue hardship" in the context of 11 U.S.C. § 523 (a) (8) (B). Based on legislative history and the decisions of other district and bankruptcy courts, the district court adopted a standard for "undue hardship" requiring a three - part showing: (1) that the debtor cannot maintain, based on current income and expenses, a "minimal" standard of living for herself and her dependents if forced to repay the loans; (2) that additional circumstances exist indicating that this state of affairs is likely to persist for a significant portion of the repayment period of the student loans; and (3) that the debtor has made good faith efforts to repay the loans . For the reasons set forth in the district court's order, we adopt this analysis . The first part of this test has been applied frequently as the minimum necessary to establish "undue hardship ." See, e.g., Bryant v. Pennsylvania Higher Educ . Assistance Agency (In re Bryant), 72 B.R. 913, 915 (Bankr. E.D. Pa. 1987); North Dakota State Bd. of Higher Educ . v. Frech (In re Frech), 62 B.R. 235 (Bankr. D. Minn. 1986); Marion v. Pennsylvania Higher Educ . Assistance Agency (In re Marion), 61 B.R. 815 (Bankr. W.D. Pa. 1986). Requiring such a showing comports with common sense as well . </P>

Where does federal student loan money come from